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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc 1995-10-18
[Table view] Category:TRANSCRIPTS
MONTHYEARML20245K9371989-04-20020 April 1989 Transcript of Commission 890420 Affirmation/Discussion & Vote in Rockville,Md.Pp 1-5 ML20247R4421989-04-20020 April 1989 Transcript of Commission 890420 Press Conference in Rockville,Md.Pp 1-10 ML20245G5661989-04-17017 April 1989 Transcript of 890417 Discussion of Plant Full Power OL in Rockville,Md.Pp 1-70.Supporting Documentation Encl ML20236E1021989-03-0303 March 1989 Transcript of Commission 890303 Affirmation,Discussion & Vote in Rockville,Md Re SECY-89-77, Shoreham Sanction Decision. Pp 1-5 ML20247R4321989-03-0303 March 1989 Transcript of Commission 890303 Press Conference in Rockville,Md Re Shoreham Proceedings.Pp 1-10 ML20235V6301989-03-0101 March 1989 Testimony of F Kantor,Em Podolak & Rt Hogan of NRC Staff on Scope of Exercise.* Purpose of Testimony Is to Rebut Testimony of Intervenors Re Contention 1 ML20235V3841989-03-0101 March 1989 Direct Testimony of Iw Husar & Jh Keller Concerning June 1988 Emergency Preparedness Exercise.* Certificate of Svc Encl.Related Correspondence ML20235N1221989-02-24024 February 1989 Rebuttal Testimony of Jr Asher,Dm Crocker,Rb Kelly,Jj Kozak & Cl Stovall on Contention 1 (Scope of Exercise).* Related Documentation Encl.Related Correspondence ML20235N1501989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 6 (Emergency Broadcast Sys Messages) & 7.E & F (Enc).* Attachments Encl. Related Correspondence ML20235N1641989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 18 (Communications Equipment & Reception Failures).* Related Correspondence ML20235Y5811989-02-21021 February 1989 Transcript of Commission Oral Argument on 890221 in Rockville,Md Re Sanction Issue in Shoreham Proceeding ML20247R4091988-12-31031 December 1988 Transcript of Commission 881221 Press Conference in Rockville,Md.Pp 1-31 ML20196F2881988-12-0606 December 1988 Transcript of 881206 Hearing in Bethesda,Md Re Plant. Pp 1-122 ML20154E4761988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Appeal of Initial Decision Concerning Emergency Exercise.Pp 1-91 ML20154E4631988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Util Reception Ctrs That Will Be Used in Event of Radiological Emergency.Pp 1-98 ML20151C3041988-07-19019 July 1988 Transcript of 880719 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,830-22,074.Witnesses:F Jones,We Regan, R Shepherd & D Davidoff ML20151B3391988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,537-21,720.Witnesses:N Kelly & D Axelrod ML20151B3671988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,721-21,829.Witnesses:N Kelly, D Axelrod & Aj Geramo ML20150E0791988-07-11011 July 1988 Transcript of 880711 Hearing in Bethesda,Md Re Emergency Planning.Pp 20,944-21,174 ML20150F7781988-07-11011 July 1988 Transcript of 880711 Evening Session in Bethesda,Md Re Emergency Planning.Pp 21,175-21,290.Witnesses:JD Papile & DA Devito ML20196J4891988-06-29029 June 1988 Transcript of 880629 Conference in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,929-20,943 ML20196A4261988-06-24024 June 1988 Transcript of 880624 Hearing in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,894-20,928 ML20155K5671988-06-17017 June 1988 Transcript of 880617 Telcon Hearing in Bethesda,Md Re Emergency Planning/School Bus Driver Issue.Pp 20,863-20,893 ML20154D1181988-06-15015 June 1988 Transcript of FEMA 880615 Public Meeting in Patchougue,Ny Re Util.Pp 1-131 ML20155E1751988-06-10010 June 1988 Transcript of 880610 Telcon in Washington,Dc Re Remand/ Emergency Planning.Pp 20,845-20,862 ML20197E3231988-06-0303 June 1988 Transcript of 880603 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 20,686-20,844.Supporting Documentation Encl.Witness:D Hartgen ML20154R2881988-06-0202 June 1988 Transcript of 880602 Hearing in Happauge,Ny Re Emergency Planning.Pp 20,555-20,685.Supporting Documentation Encl ML20197E0401988-05-31031 May 1988 Corrections to Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Bases & Accuracy of Lilco Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20154M8571988-05-27027 May 1988 Transcript of 880527 Hearing in Hauppauge,Ny. Pp 20,440-20,554.Witness:T Urbanik ML20154M8511988-05-26026 May 1988 Transcript of 880526 Hearing Re Emergency Planning/School Bus Driver Issue in Hauppauge,Ny.Pp 20,245-20,439.Supporting Documentation Encl.Witnesses:Bg Brodsky,Ej Doherty, Hm Koenig,Ar Rossi,Rw Petrilak,Nf Muto,Jt Smith,Rn Suprina ML20197E1201988-05-26026 May 1988 Surrebuttal Testimony of Dt Haertgen on Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20197E1631988-05-24024 May 1988 Addendum to Direct Testimony of Bg Brodsky,Ej Doherty, Hm Koenig,Nf Muto,Rw Petrilak,Ar Rossi,Jt Smith & Rn Suprina on Behalf of Suffolk County Re Contention 25.C.* W/ Certificate of Svc.Related Correspondence ML20154F7741988-05-18018 May 1988 Transcript of 880518 Hearing in Hauppauge,Ny. Pp 19,831-19,998.Witnesses:D Mileti,Mk Lindell,Rb Kelly ML20154H7981988-05-18018 May 1988 Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Base & Accuracy of Lilco Hosp Evacution Time Estimates.Certificate of Svc Encl ML20154F7421988-05-17017 May 1988 Transcript of 880517 Hearing in Hauppauge,Ny. Pp 19,612-19,830 ML20154D4751988-05-16016 May 1988 Transcript of 880516 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 19,390-19,611.Supporting Documentation Encl.Witnesses:Dm Crocker,D Mileti,Mk Lindell, RB Kelly ML20154D9221988-05-12012 May 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Immateriality Issues.* Hartgen Resume & Certificate of Svc Encl.Related Correspondence ML20153H6721988-05-10010 May 1988 Transcript of 880510 Prehearing Conference in Bethesda,Md. Pp 19,323-19,389 ML20154B4621988-05-10010 May 1988 Lilco Supplemental Testimony on Remanded Issue of Role Conflict of School Bus Drivers.* Certificate of Svc Encl ML20154B7841988-05-0606 May 1988 Direct Testimony of Gc Minor & Sc Sholly on Behalf of Suffolk County Re Immateriality.* Certificate of Svc Encl. Related Correspondence ML20154B5421988-05-0606 May 1988 Testimony of DM Behr,Dm Crocker,Dp Dreikorn,Eb Lieberman & Ja Weismantle on Best Efforts Contentions EP 1-2,4-8 & 10.* Supporting Documentation & Certificate of Svc Encl.W/One Oversize Map.Related Correspondence ML20154C7511988-05-0404 May 1988 Transcript of 880504 Annual Briefing on State of Nuclear Industry in Rockville,Md.Pp 1-60. Introductory Remarks, State of Industry Rept & Status Rept on Util Research... Encl.Served on 880509 ML20151V9271988-04-28028 April 1988 Transcript of 880428 Hearing in Bethesda,Md Re Emergency Preparedness Exercise.Pp 1-94 ML20151Z0711988-04-28028 April 1988 Testimony of Jj Boursy.* Addresses Issue of Measured Signal Strength of Fm Radio Station Wplr,New Haven,Ct within EPZ for Plant.Related Correspondence ML20154B7061988-04-22022 April 1988 Deposition of D Axelrod.* Deposition Taken in Albany,Ny Re Emergency Planning ML20154H6621988-04-21021 April 1988 Deposition of Gc Minor.* Transcript of Gc Minor Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154H6311988-04-21021 April 1988 Deposition of Sc Sholly.* Transcript of Sc Sholly Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154B6861988-04-19019 April 1988 Deposition of Pg Halpin.* Deposition Taken in Happauge,Ny Re Emergency Planning/Best Efforts Issue ML20148T0191988-04-13013 April 1988 Testimony of DM Crocker,Rb Kelly,Mk Lindell & Ds Mileti on Remanded Issue of Role Conflict of School Bus Drivers.* Addl Info Re Bus Driver Issue During Emergency Evacuations Encl.W/Certificate of Svc.Related Correspondence ML20151N9191988-04-13013 April 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Util Hosp Evacuation Time Estimates Not Reliable for Stated Reasons.Certificate of Svc Encl.Related Correspondence 1989-04-20
[Table view] Category:DEPOSITIONS
MONTHYEARML20245K9371989-04-20020 April 1989 Transcript of Commission 890420 Affirmation/Discussion & Vote in Rockville,Md.Pp 1-5 ML20247R4421989-04-20020 April 1989 Transcript of Commission 890420 Press Conference in Rockville,Md.Pp 1-10 ML20245G5661989-04-17017 April 1989 Transcript of 890417 Discussion of Plant Full Power OL in Rockville,Md.Pp 1-70.Supporting Documentation Encl ML20236E1021989-03-0303 March 1989 Transcript of Commission 890303 Affirmation,Discussion & Vote in Rockville,Md Re SECY-89-77, Shoreham Sanction Decision. Pp 1-5 ML20247R4321989-03-0303 March 1989 Transcript of Commission 890303 Press Conference in Rockville,Md Re Shoreham Proceedings.Pp 1-10 ML20235V6301989-03-0101 March 1989 Testimony of F Kantor,Em Podolak & Rt Hogan of NRC Staff on Scope of Exercise.* Purpose of Testimony Is to Rebut Testimony of Intervenors Re Contention 1 ML20235V3841989-03-0101 March 1989 Direct Testimony of Iw Husar & Jh Keller Concerning June 1988 Emergency Preparedness Exercise.* Certificate of Svc Encl.Related Correspondence ML20235N1221989-02-24024 February 1989 Rebuttal Testimony of Jr Asher,Dm Crocker,Rb Kelly,Jj Kozak & Cl Stovall on Contention 1 (Scope of Exercise).* Related Documentation Encl.Related Correspondence ML20235N1501989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 6 (Emergency Broadcast Sys Messages) & 7.E & F (Enc).* Attachments Encl. Related Correspondence ML20235N1641989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 18 (Communications Equipment & Reception Failures).* Related Correspondence ML20235Y5811989-02-21021 February 1989 Transcript of Commission Oral Argument on 890221 in Rockville,Md Re Sanction Issue in Shoreham Proceeding ML20247R4091988-12-31031 December 1988 Transcript of Commission 881221 Press Conference in Rockville,Md.Pp 1-31 ML20196F2881988-12-0606 December 1988 Transcript of 881206 Hearing in Bethesda,Md Re Plant. Pp 1-122 ML20154E4761988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Appeal of Initial Decision Concerning Emergency Exercise.Pp 1-91 ML20154E4631988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Util Reception Ctrs That Will Be Used in Event of Radiological Emergency.Pp 1-98 ML20151C3041988-07-19019 July 1988 Transcript of 880719 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,830-22,074.Witnesses:F Jones,We Regan, R Shepherd & D Davidoff ML20151B3391988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,537-21,720.Witnesses:N Kelly & D Axelrod ML20151B3671988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,721-21,829.Witnesses:N Kelly, D Axelrod & Aj Geramo ML20150E0791988-07-11011 July 1988 Transcript of 880711 Hearing in Bethesda,Md Re Emergency Planning.Pp 20,944-21,174 ML20150F7781988-07-11011 July 1988 Transcript of 880711 Evening Session in Bethesda,Md Re Emergency Planning.Pp 21,175-21,290.Witnesses:JD Papile & DA Devito ML20196J4891988-06-29029 June 1988 Transcript of 880629 Conference in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,929-20,943 ML20196A4261988-06-24024 June 1988 Transcript of 880624 Hearing in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,894-20,928 ML20155K5671988-06-17017 June 1988 Transcript of 880617 Telcon Hearing in Bethesda,Md Re Emergency Planning/School Bus Driver Issue.Pp 20,863-20,893 ML20154D1181988-06-15015 June 1988 Transcript of FEMA 880615 Public Meeting in Patchougue,Ny Re Util.Pp 1-131 ML20155E1751988-06-10010 June 1988 Transcript of 880610 Telcon in Washington,Dc Re Remand/ Emergency Planning.Pp 20,845-20,862 ML20197E3231988-06-0303 June 1988 Transcript of 880603 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 20,686-20,844.Supporting Documentation Encl.Witness:D Hartgen ML20154R2881988-06-0202 June 1988 Transcript of 880602 Hearing in Happauge,Ny Re Emergency Planning.Pp 20,555-20,685.Supporting Documentation Encl ML20197E0401988-05-31031 May 1988 Corrections to Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Bases & Accuracy of Lilco Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20154M8571988-05-27027 May 1988 Transcript of 880527 Hearing in Hauppauge,Ny. Pp 20,440-20,554.Witness:T Urbanik ML20154M8511988-05-26026 May 1988 Transcript of 880526 Hearing Re Emergency Planning/School Bus Driver Issue in Hauppauge,Ny.Pp 20,245-20,439.Supporting Documentation Encl.Witnesses:Bg Brodsky,Ej Doherty, Hm Koenig,Ar Rossi,Rw Petrilak,Nf Muto,Jt Smith,Rn Suprina ML20197E1201988-05-26026 May 1988 Surrebuttal Testimony of Dt Haertgen on Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20197E1631988-05-24024 May 1988 Addendum to Direct Testimony of Bg Brodsky,Ej Doherty, Hm Koenig,Nf Muto,Rw Petrilak,Ar Rossi,Jt Smith & Rn Suprina on Behalf of Suffolk County Re Contention 25.C.* W/ Certificate of Svc.Related Correspondence ML20154F7741988-05-18018 May 1988 Transcript of 880518 Hearing in Hauppauge,Ny. Pp 19,831-19,998.Witnesses:D Mileti,Mk Lindell,Rb Kelly ML20154H7981988-05-18018 May 1988 Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Base & Accuracy of Lilco Hosp Evacution Time Estimates.Certificate of Svc Encl ML20154F7421988-05-17017 May 1988 Transcript of 880517 Hearing in Hauppauge,Ny. Pp 19,612-19,830 ML20154D4751988-05-16016 May 1988 Transcript of 880516 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 19,390-19,611.Supporting Documentation Encl.Witnesses:Dm Crocker,D Mileti,Mk Lindell, RB Kelly ML20154D9221988-05-12012 May 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Immateriality Issues.* Hartgen Resume & Certificate of Svc Encl.Related Correspondence ML20153H6721988-05-10010 May 1988 Transcript of 880510 Prehearing Conference in Bethesda,Md. Pp 19,323-19,389 ML20154B4621988-05-10010 May 1988 Lilco Supplemental Testimony on Remanded Issue of Role Conflict of School Bus Drivers.* Certificate of Svc Encl ML20154B7841988-05-0606 May 1988 Direct Testimony of Gc Minor & Sc Sholly on Behalf of Suffolk County Re Immateriality.* Certificate of Svc Encl. Related Correspondence ML20154B5421988-05-0606 May 1988 Testimony of DM Behr,Dm Crocker,Dp Dreikorn,Eb Lieberman & Ja Weismantle on Best Efforts Contentions EP 1-2,4-8 & 10.* Supporting Documentation & Certificate of Svc Encl.W/One Oversize Map.Related Correspondence ML20154C7511988-05-0404 May 1988 Transcript of 880504 Annual Briefing on State of Nuclear Industry in Rockville,Md.Pp 1-60. Introductory Remarks, State of Industry Rept & Status Rept on Util Research... Encl.Served on 880509 ML20151V9271988-04-28028 April 1988 Transcript of 880428 Hearing in Bethesda,Md Re Emergency Preparedness Exercise.Pp 1-94 ML20151Z0711988-04-28028 April 1988 Testimony of Jj Boursy.* Addresses Issue of Measured Signal Strength of Fm Radio Station Wplr,New Haven,Ct within EPZ for Plant.Related Correspondence ML20154B7061988-04-22022 April 1988 Deposition of D Axelrod.* Deposition Taken in Albany,Ny Re Emergency Planning ML20154H6621988-04-21021 April 1988 Deposition of Gc Minor.* Transcript of Gc Minor Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154H6311988-04-21021 April 1988 Deposition of Sc Sholly.* Transcript of Sc Sholly Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154B6861988-04-19019 April 1988 Deposition of Pg Halpin.* Deposition Taken in Happauge,Ny Re Emergency Planning/Best Efforts Issue ML20148T0191988-04-13013 April 1988 Testimony of DM Crocker,Rb Kelly,Mk Lindell & Ds Mileti on Remanded Issue of Role Conflict of School Bus Drivers.* Addl Info Re Bus Driver Issue During Emergency Evacuations Encl.W/Certificate of Svc.Related Correspondence ML20151N9191988-04-13013 April 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Util Hosp Evacuation Time Estimates Not Reliable for Stated Reasons.Certificate of Svc Encl.Related Correspondence 1989-04-20
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20245K9371989-04-20020 April 1989 Transcript of Commission 890420 Affirmation/Discussion & Vote in Rockville,Md.Pp 1-5 ML20247R4421989-04-20020 April 1989 Transcript of Commission 890420 Press Conference in Rockville,Md.Pp 1-10 ML20245G5661989-04-17017 April 1989 Transcript of 890417 Discussion of Plant Full Power OL in Rockville,Md.Pp 1-70.Supporting Documentation Encl ML20236E1021989-03-0303 March 1989 Transcript of Commission 890303 Affirmation,Discussion & Vote in Rockville,Md Re SECY-89-77, Shoreham Sanction Decision. Pp 1-5 ML20247R4321989-03-0303 March 1989 Transcript of Commission 890303 Press Conference in Rockville,Md Re Shoreham Proceedings.Pp 1-10 ML20235V6301989-03-0101 March 1989 Testimony of F Kantor,Em Podolak & Rt Hogan of NRC Staff on Scope of Exercise.* Purpose of Testimony Is to Rebut Testimony of Intervenors Re Contention 1 ML20235V3841989-03-0101 March 1989 Direct Testimony of Iw Husar & Jh Keller Concerning June 1988 Emergency Preparedness Exercise.* Certificate of Svc Encl.Related Correspondence ML20235N1221989-02-24024 February 1989 Rebuttal Testimony of Jr Asher,Dm Crocker,Rb Kelly,Jj Kozak & Cl Stovall on Contention 1 (Scope of Exercise).* Related Documentation Encl.Related Correspondence ML20235N1501989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 6 (Emergency Broadcast Sys Messages) & 7.E & F (Enc).* Attachments Encl. Related Correspondence ML20235N1641989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 18 (Communications Equipment & Reception Failures).* Related Correspondence ML20235Y5811989-02-21021 February 1989 Transcript of Commission Oral Argument on 890221 in Rockville,Md Re Sanction Issue in Shoreham Proceeding ML20247R4091988-12-31031 December 1988 Transcript of Commission 881221 Press Conference in Rockville,Md.Pp 1-31 ML20196F2881988-12-0606 December 1988 Transcript of 881206 Hearing in Bethesda,Md Re Plant. Pp 1-122 ML20154E4761988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Appeal of Initial Decision Concerning Emergency Exercise.Pp 1-91 ML20154E4631988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Util Reception Ctrs That Will Be Used in Event of Radiological Emergency.Pp 1-98 ML20151C3041988-07-19019 July 1988 Transcript of 880719 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,830-22,074.Witnesses:F Jones,We Regan, R Shepherd & D Davidoff ML20151B3391988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,537-21,720.Witnesses:N Kelly & D Axelrod ML20151B3671988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,721-21,829.Witnesses:N Kelly, D Axelrod & Aj Geramo ML20150E0791988-07-11011 July 1988 Transcript of 880711 Hearing in Bethesda,Md Re Emergency Planning.Pp 20,944-21,174 ML20150F7781988-07-11011 July 1988 Transcript of 880711 Evening Session in Bethesda,Md Re Emergency Planning.Pp 21,175-21,290.Witnesses:JD Papile & DA Devito ML20196J4891988-06-29029 June 1988 Transcript of 880629 Conference in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,929-20,943 ML20196A4261988-06-24024 June 1988 Transcript of 880624 Hearing in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,894-20,928 ML20155K5671988-06-17017 June 1988 Transcript of 880617 Telcon Hearing in Bethesda,Md Re Emergency Planning/School Bus Driver Issue.Pp 20,863-20,893 ML20154D1181988-06-15015 June 1988 Transcript of FEMA 880615 Public Meeting in Patchougue,Ny Re Util.Pp 1-131 ML20155E1751988-06-10010 June 1988 Transcript of 880610 Telcon in Washington,Dc Re Remand/ Emergency Planning.Pp 20,845-20,862 ML20197E3231988-06-0303 June 1988 Transcript of 880603 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 20,686-20,844.Supporting Documentation Encl.Witness:D Hartgen ML20154R2881988-06-0202 June 1988 Transcript of 880602 Hearing in Happauge,Ny Re Emergency Planning.Pp 20,555-20,685.Supporting Documentation Encl ML20197E0401988-05-31031 May 1988 Corrections to Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Bases & Accuracy of Lilco Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20154M8571988-05-27027 May 1988 Transcript of 880527 Hearing in Hauppauge,Ny. Pp 20,440-20,554.Witness:T Urbanik ML20154M8511988-05-26026 May 1988 Transcript of 880526 Hearing Re Emergency Planning/School Bus Driver Issue in Hauppauge,Ny.Pp 20,245-20,439.Supporting Documentation Encl.Witnesses:Bg Brodsky,Ej Doherty, Hm Koenig,Ar Rossi,Rw Petrilak,Nf Muto,Jt Smith,Rn Suprina ML20197E1201988-05-26026 May 1988 Surrebuttal Testimony of Dt Haertgen on Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20197E1631988-05-24024 May 1988 Addendum to Direct Testimony of Bg Brodsky,Ej Doherty, Hm Koenig,Nf Muto,Rw Petrilak,Ar Rossi,Jt Smith & Rn Suprina on Behalf of Suffolk County Re Contention 25.C.* W/ Certificate of Svc.Related Correspondence ML20154F7741988-05-18018 May 1988 Transcript of 880518 Hearing in Hauppauge,Ny. Pp 19,831-19,998.Witnesses:D Mileti,Mk Lindell,Rb Kelly ML20154H7981988-05-18018 May 1988 Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Base & Accuracy of Lilco Hosp Evacution Time Estimates.Certificate of Svc Encl ML20154F7421988-05-17017 May 1988 Transcript of 880517 Hearing in Hauppauge,Ny. Pp 19,612-19,830 ML20154D4751988-05-16016 May 1988 Transcript of 880516 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 19,390-19,611.Supporting Documentation Encl.Witnesses:Dm Crocker,D Mileti,Mk Lindell, RB Kelly ML20154D9221988-05-12012 May 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Immateriality Issues.* Hartgen Resume & Certificate of Svc Encl.Related Correspondence ML20153H6721988-05-10010 May 1988 Transcript of 880510 Prehearing Conference in Bethesda,Md. Pp 19,323-19,389 ML20154B4621988-05-10010 May 1988 Lilco Supplemental Testimony on Remanded Issue of Role Conflict of School Bus Drivers.* Certificate of Svc Encl ML20154B7841988-05-0606 May 1988 Direct Testimony of Gc Minor & Sc Sholly on Behalf of Suffolk County Re Immateriality.* Certificate of Svc Encl. Related Correspondence ML20154B5421988-05-0606 May 1988 Testimony of DM Behr,Dm Crocker,Dp Dreikorn,Eb Lieberman & Ja Weismantle on Best Efforts Contentions EP 1-2,4-8 & 10.* Supporting Documentation & Certificate of Svc Encl.W/One Oversize Map.Related Correspondence ML20154C7511988-05-0404 May 1988 Transcript of 880504 Annual Briefing on State of Nuclear Industry in Rockville,Md.Pp 1-60. Introductory Remarks, State of Industry Rept & Status Rept on Util Research... Encl.Served on 880509 ML20151V9271988-04-28028 April 1988 Transcript of 880428 Hearing in Bethesda,Md Re Emergency Preparedness Exercise.Pp 1-94 ML20151Z0711988-04-28028 April 1988 Testimony of Jj Boursy.* Addresses Issue of Measured Signal Strength of Fm Radio Station Wplr,New Haven,Ct within EPZ for Plant.Related Correspondence ML20154B7061988-04-22022 April 1988 Deposition of D Axelrod.* Deposition Taken in Albany,Ny Re Emergency Planning ML20154H6621988-04-21021 April 1988 Deposition of Gc Minor.* Transcript of Gc Minor Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154H6311988-04-21021 April 1988 Deposition of Sc Sholly.* Transcript of Sc Sholly Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154B6861988-04-19019 April 1988 Deposition of Pg Halpin.* Deposition Taken in Happauge,Ny Re Emergency Planning/Best Efforts Issue ML20148T0191988-04-13013 April 1988 Testimony of DM Crocker,Rb Kelly,Mk Lindell & Ds Mileti on Remanded Issue of Role Conflict of School Bus Drivers.* Addl Info Re Bus Driver Issue During Emergency Evacuations Encl.W/Certificate of Svc.Related Correspondence ML20151N9191988-04-13013 April 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Util Hosp Evacuation Time Estimates Not Reliable for Stated Reasons.Certificate of Svc Encl.Related Correspondence 1989-04-20
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LILCO, March 2, 1984 l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
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LONG ISLAND LIGHTING COMPANY ) Dochet No. 50-322-OL-3
) (Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1) )
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TESTIMONY OF MATTHEW C. CORDARO, JOHN A. WEISMANTLE AND EDWARD B. LIEBERMAN ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTION 66 9
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l Hunton & Williams 707 East Main Street P.O. Box 1535 i Richmond, Virginia 23212 l
(804) 788-8200 l
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8403070198 840302 PDR ADOCK 0500032P T PDR I
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LILCO, March 2, 1984 UNITED STATES OF AMERICA l!UCLEAR 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 AND EDWARD B. LIEBERMAN ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTION 66 PURPOSE Contention 66 raises a series of questions about whether the LILCO Transition Plan adequately addresses a number of contin-gencies that could occur during an evacuation of the Shoreham EPZ.
Specifically, Contention 66 questions (1) whether there are a suf-ficient number of tow trucks to enable LILCO personnel to remove potential obstructions from roadways, (2) whether the removal of those obstacles will be completed expeditiously, (3) whether mea-sures have been provided for evacuating people whose cars have become disabled, (4) whether snow will be removed during an evacu-ation, and (5) whether the fuel distribution plan will meet its objective.
This testimony demonstrates that these contingencies have been addressed, and that Contention 66 is without merit. First, the Plan provides for a maximum of twelve tow trucks during an
a
_2_
4 evacuation. This number of tow trucks is three times the expected number of accidents (four) during the entire evacuation. Second, these tow trucks have been strategically spaced along major evacu-ation routes to permit a rapid response to any roadway obstruc-tion. Third, a variety of measures exist for ensuring that evacuees whose cars have become disabled will be able to obtain a ride out of the EPZ. Fourth. the continued removal of snow during an evacuation should have no effect on protective action recommen-dations. Finally, the fuel distribution plan will more than ade-quately serve those evacuees needing additional fuel.
4
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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 AND EDWARD B. LIEBERMAN ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTION 66 TESTIMONY
- 1. Q. Please state four 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 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.
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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-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 be'.ng met, and that the technical direction and content of emergency planning are being conveyed to corporate management.
(Weismantle] I am Manager of the Local Emergency Response Implementing Organization for LILCO. My professional 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.
[Lieberman] I am Vice President of KLD Associates, Incor-porated. My professional qualifications are being offered into evidence as part of the document entitled
" Professional Qualifications of LILCO Witnesses." My familiarity with this contention stems from work KLD Asso-ciates has performed for LILOO on evacuation time esti-mates for the Shoreham EPZ.
- 3. Q. Please summarize the issues raised by Contention 66.
A. [Cordaro, Weismantle, Lieberman] Suffolk County Conten-tion 66 questions whether-the LILCO Transition Plan prop-erly provides for the removal of obstacles from roadways and for the dispensing of gasoline to evacuees needing additional fuel. Specifically, Contention 66 states:
Contention 66. NUREG 0654 Section II.J.lO.k requires that an offsite plan pro-vide "[i]dentification of and means for dealing with potential impediments . . . to use of evacuation routes, and contingency I measures."
In the event of a radiological emergency at Shoreham and subsequent evacuation (re:-
ommended and/or voluntary), it is likely that there will be many instances of automo-bile accidents and vehicle breakdowns caused by the large number of vehicles on the road, stop-and-go conditions, overheating while idling in queues, driver inattention, fail-ure to obey the rules of the road and other such conditions. In addition, it is likely that many evacuees will not begin the.evacu-ation with a full tank of gasoline. Many automobiles may run out of gasoline, both inside and outside the EPZ, as a result of extended operation times due to congestion, stop-and-go conditions and time spent sit-ting in queues. Such occurrences, along with abandonment of vehicles and construc-tion which may be in progress at the time an evacuation is ordered, will result in ob-structions and blockages on roadways in use during the evacuation. Taking such occur-rences into account would cause evacuation
time estimates to increase. (See Contention 65). In addition, it is essential that such obstacles be removed in a timely manner so that evacuation times will not increase even more due to substantial periods of reduced roadway capacity. Under the LILCO Plan, removal of obstacles will be performed by LILCO road crews using 12 LILCO tow trucks and line trucks. Gasoline will be provided by LILCO fuel trucks which are to be dis-patched to seven specific locations. (See Plan at 4.4-3; Appendix A at IV-176; OPIP 3.6.3 at 46a-46b).
Intervenors contend that the LILCO Plan fails to comply with 10 CFR Sections 50.47(a)(1), 50.47(b)(10) and NUREG 0654,Section II.J, because LILCO will be unable to provide for obstacles to be removed from the roads, or to provide adequate fuel sup-plies for evacuees for the following rea-sons:
A. LILCO does not have an adequate num-ber of tow trucks to enable LILCO personnel to remove all potential road obstructions.
(See FEMA Report at 11, citing non-compli-ance with NUREG 0654,Section II.J.10.k).
B. The tow truck deployment points pro-posed by LILCO are not located so as to allow rapid dispatch of the tow trucks to the aid of disabled vehicles. In addition, once they have been dispatched to an obstruction location, the tow trucks and other LILCO equipment will only be able to move as fast as the traffic flow, which will be extremely slow. Therefore, they will be unable to respond to the site of an obstruc-tion in an expeditious manner.
C. LILCO's Plan makes no provision for the evacuation of persons whose cars break down or are in accidents.
D. The LILCO Plan does not provide for snow removal. (See FEMA Report at 11, cit-ing non-compliance with NUREG 0654, Section f II.J.10.k). Rather, the Plan assumes that
" snow removal will be provided by local organizations in their normal fashion during
l l 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 pro-vide snow removal services during an emer-gency, nor can it assure that local person-nel assigned to snow removal duties will perform those functions during an emergency, for the reasons cited in Contentions 15, 25 and 27.
E. [ Withdrawn.]
F. The seven fixed sites chosen for fuel distribution will be able to service only a small portion of the evacuating population.
Therefore, the fuel needs of many evacuees will be unmet. Furthermore, no provisions have been made to handle queues at fuel allocation sites which may back up into evacuating traffic, thus causing further congestion and delays.
- 4. Q. Could you briefly summarine the scope of this testimony?
A. [Cordaro, Weismantle, Lieberman] Yes. This testimony will address primarily the specific concerns raised in subparts A through D and F of this contention. The pref-ace to these subparts of Contention 66 contains broad statements about the potential effects of roadway obstruc-tions on the evacuation time estimates contained in Appen-dix A. These concerns have already been litigated in great detail in Contention 65, and for that reason, they will not be addressed in this testimony. In addition, Contention 66.D cites other Suffolk County contentions --
specifically, Contentions 15, 25 and 27. Those conten-tions are addressed in other pieces of LILCO's testimony, and their merits will not be addressed here.
Contention 66.A
- 5. Q. How many road crews are assigned the job of removing obstructions from roadways during an evacuation?
A. [Cordaro, Weismantle] The LILCO Transition Plan specifies that a maximum of twelve road crews will be assigned the job of removing obstructions from roadways during an evac-uation (Plan at 4.4-3). The number of crews that will ,
l actually be dispatched if an evacuation is ordered depends on the area ordered to evacuate. If a two-mile radius area is ordered to evacuate, eight road crews will be. dis-patched, while all twelve will be dispatched if five- or ten-mile radii are ordered to evacuate A listing of road crew deployment locations and identification of the loca-tions to be manned under varying evacuation scenarios are detailed in Attachment 8 to OPIP 3.6.3 of the LILCO Tran-sition Plan (Attachment 1 to this testimony).
These road crews will use LILCO-owned tow trucks in removing obstacles from roadways. If a sufficient number of tow trucks are not available, either for locational or mechanical reasons, then other LILCO vehicles will be used in their place (see OPIP 3.6.3,.p. 6). These alternate vehicles will be chosen because of their proximity to the EPZ and their physical characteristics. For example, vehicles located at the Brentwood, Patchogue and Riverhead Operations Centers will be the first used should an
evacuation be ordered. Another factor in selecting these vehicles will be the ability of the vehicle to perform the necessary road clearing activities. In making this judg-ment, the power, size, maneuverability and equipment (i.e., bumpers and winches) of these trucks will be con-sidered. Among the LILCO-cwned vehicles that fit these criteria are dump trucks, four wheel drive pickups equipped with winches and push bumpers, and derrick trucks with ballast bumpers.
- 6. Q. Why was this number of road crews chosen?
A. [Cordaro, Weismantle, Lieberman] Two major factors were considered in the selection of twelve road crews: first, the number of obstructions likely to need clearing, and second, the time needed to clear a given obstruction.
With respect to the number of obstructions that will need to be removed during an evacuation, we believe that twelve road crews provide a wide margin of excess manpower to accomplish this task. Obstructions in roadways will gen-erally be caused either by accidents or by vehicle break-downs resulting from mechanical failures or flat tires, or by automobiles running out of gasoline. As was detailed in this panel's earlier testimony on Contention 65, the available literature on evacuations indicates that the expected accident rate during an evacuation will be simi-lar to the national average (Testimony of Cordaro, et al.
on Contention 65 at 79-81). National accident statistics predict that approximately four accidents will occur dur-ing an evacuation of the Shoreham EPZ (id. at 81). As a practical matter, these predicted accidents will require road crew response only if they result in the disablement of a vehicle. Since vehicles will be expected to travel at low speeds during an evacuation -- generally less than 10 miles per hour -- it is likely that a number of these predicted accidents will produce no disabled vehicles, and hence, no need for road crew response.
With respect to vehicle breakdowns, it must again be noted that not all breakdowns will require road crew assistance. Some types of breakdowns will still permit cars to be driven (i.e., a flat tire) or to coast (i.e.,
an automobile running out of gasoline) off of the roadway onto the shoulder of the road. The number of vehicle breakdowns that would obstruct roadways during an evacua-tion of the Shoreham EPZ is therefore difficult to pre-dict. National statistics on vehicle breakdowns are nonexistent. The only testimony in this proceeding that provides any insight into normal vehicle breakdown frequencies is the 10,000 " incidents" reported on the Long Island Expressway (LIE) in 1982 (Testimony of Roberts, et al. at 55). This incident rate includes both accidents and breakdowns and does not attempt to distinguish between
_g.
them or to indicate their severity (see id.). By taking the length of the LIE examined in this assessment of inci-dents (43 miles) and the annual daily traffic flow aver-aged over this stretch of the LIE (approximately 65,000 vehicles / day), one can derive an incident rate expressed in terms of vehicle miles. The resultant rate is 1 inci-dent per 100,000 vehicle miles. Since a total of approxi-mately 300,000 vehicle miles is expected to be driven dur-ing an evacuation of the entire EPZ, it follows from these data that three " incidents" would be expected during an evacuation. Thus, these data suggest that the number of expected accidents and breakdowns requiring road crew re-sponse are far fewer than the number of road crews avail-able to respond.
A more important consideration in the selection of twelve road crews was the desire to provide sufficient road crews to permit a rapid response to any obstruction.
This goal was accomplished by locating road crews throughout the EPZ, principally at the intersections of major east-west and north-south evacuation routes (see Attachments 1 and 2). A review of the major evacuation routes and maps of the Shoreham EPZ indicated that twelve road crews would satisfy the goal of providing expedited response to roadway blockages.
Thus, contrary to the assertion of Contention 66.A, the LILCO Transition Plan specifies an adequate number of road j crews to remove roadway obstacles.
Contention 66.B
- 7. Q. Could you explain in more detail how the road crew deploy-ment locations will permit expeditious response to roadway blockages?
A. [Cordaro, Weismantle, Lieberman] Yes. The speed at which LERO road crews will be able to remove an obstruction from a roadway depends on the proximity of the road cr<v to the obstruction and on the congestion they will encounter in responding to the obstruction. The placement of LERO road crews was designed to minimize both of these factors.
First, road crews were placed on the evacuation routes having the largest traffic flows and thus, the highest likelihood of an obstruction (see Attachmen 3). This is true both of major east-west and north-south evacuation routes. Second, the road crews were spaced at distances of approximately two to four miles. This spacing will help to minimize the distance a road crew will need to travel to reach an obstruction even if the nearest road crew is unable to respond because of a prior assignment.
Finally, the predominant placement of the road crews is to the west and south of the Shoreham plant, normally at radial distances of five to ten miles. This orientation
l increases the probability that road crews will be able to move in a countercurrent direction to the main evacuation flow, thus permitting them to avoid the congestion and attendant delays of having to travel with that flow.
Contention 66.C
- 8. Q. How does the LILCO Transition Plan provide for the evacua-tion of people whose cars have broken down, or who have been in accidents that have disabled their vehicles?
A. [Cordaro, Weismantle) The LILCO Transition Plan does not expressly provide for the transportation of evacuees whose automobiles have become inoperative either because of a mechanical breakdown or an accident. The exclusion of express treatment for this very small group was premised on a desire not to clutter the Plan and Procedures with what is expected to be a minute detail.
As a practical matter, people whose cars have become disabled will have a number of available means for evacuating the EPZ. These people can either ride with other evacuees, catch one of the numerous buses providing transportation to the general public without access to cars, or ride with the road crew back to the road crew's deployment location, where they can either catch a bus out of the EPZ or evacuate with the road crew when the road crew finishes its duties.
- 9. Q. How are these people typically treated in other evacuation plans?
A. [Cordaro, Weismantle] Other evacuation plans with which we are familiar make no reference to providing transporta-tion for evacuees whose automobiles have broken down or been disabled by accidents. It is probably the general assumption of these plans that fellow evacuees will offer rides to these people. This assumption is consistent with LILCO's testimony in Phase I of this litigation, which showed that a spirit of cooperation prevails in community-wide disasters, and with the conclusion contained in the report entitled, "A Perspective on Disaster Planning" 3rd Edition, by Dynes, Quarantelli and Kreps. That report at page 19 concludes that "[m]utual aid rather than panicky abandonment of others is a very manifest characteristic of withdrawal behavior in the presence of danger," and that
"[f] light from a threatening situation involves playing traditional social roles including the taking care of others."
Contention 66.D
- 10. Q. How does the LILCO Transition Plan. propose to deal with snow removal?
A. [Cordaro, Weismantle] The LILCO Transition Plan states:
It is anticipated that snow removal operations within the ten mile EPZ will be_provided by local organizations in their normal fashion during an emergency.
Plan at 2.2-5. LILCO believes that local governmental bodies have a continuing responsibility to provide normal governmental services during the time of an emergency at the Shoreham Nuclear Power Plant. The presence of an emergency does not remove that responsibility from them, nor does it require LILCO to have a special agreement with local jurisdictions to guarantee that they will carry out their normal duties, as suggested by Contention 66.D.
- 11. Q. What would be the effect on the LILCO Transition Plan if snow removal crews did not perform their normal functions during an emergency at the Shoreham plant?
A. [Cordaro, Weismantle, Lieberman] In all likelihood, there would be little or no effect. For light to moderate (gen-erally less than four inches) snowfalls, the protective actio:. recommendation would be based on the evacuation time estimate for adverse, winter weather (see OPIP 3.6.1, pp. ld and 42). It is the practice on Long Island for snow removal activities to commence as soon as there is a reasonable accumulation, regardless of whether the snow-fall has ended. It can be reasonaoly assumed that snow removal will be ongoing up to the time at which the sirens are sounded. If the snow removal crews are then assumed to abandon their jobs, the roads will be in reasonably clear condition at that time and the additional snowfall during the evacuation will not affect the assumptions made in computing the evacuation time estimates for adverse, Winter weather.
For heavy snowfall or blizzard conditions, the protec-tive action recommendations are based on an evacuation time estimate for severe, Winter weather, in which it is assumed that, without snow removal, all roads will be lit-erally or nearly impassable (see OPIP 3.6.1, pp. 28-29).
In virtually all cases, the default value for the evacua-tion time estimate -- 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> -- would produce a shelter recommendation. This recommendation is unlikely to change whether or not road crews are attempting to clear road-ways, since that effort would be primarily focused on major roadways. Some local streets and many driveways would remain impassable. The conditions on these iocal streets would undoubtedly lead the decisionmakar to define the weather conditions as severe. In these circumstances, whether or not snow clearing operations were in progress during an evacuation would not affect the protective action recommendations.
Contention 66.F
- 12. Q. How will fuel be dispensed under the LILCO Transition Plan?
A. [Cordaro, Weismantle) The LILCO Transition Plan provides for fuel to be dispensed to vehicles at seven sites within or near the Shoreham EPZ. These fuel allocation sites have been located along the major east-west and north-south evacuation routes (Attachment 4). The location of
l these sites is displayed in Attachment 2 to this testi-mony.
Located at each site will be a fuel truck with at least 1200 gallons of capacity. The road crews that will man the fuel trucks will be instructed to place signs that will identify the presence and location of the fuel allo-cation site and to dispense only three gallons of gasoline to each car seeking such service. Thus, each fuel truck will be able to service over 400 vehicles, or almost twice the number of vehicles predicted to run out of gasoline by earlier Suffolk County testimony (see Testimony of Peter Polk on Contention 65 at 16).1/
- 13. Q. What steps have been taken in LERO's fuel allocation plan to ensure taat queues that may form at allocation sites do not back up into evacuating traffic?
A. [Cordaro, Weismantle, Lieberman] Three steps are being taken to ensure that should a queue be formed, it will not extend back into evacuating traffic. First, the alloca-tion sites will be located at areas that adjoin the evacu-ation roadway. Second, the sites will be carefully stud-ied to ensure that they have sufficient space to hold 1/ Mr. Polk's testimony suggests that 277 automobiles will run out of fuel. In unrebutted supplemental testimony, LILCO has demonstrated that there were several computational errors in deriving this value. LILCO's testimony indicates that had these errors been corrected, the predicted number of automo-biles running out of gasoline would be 96 (see Supplemental Testimony of Cordaro, et al. on Contention 65, pp. 29-31).
multiple vehicles. Third, the three-gallon limit on the amount of gasoline to be dispensed to each car, and the clear posting of this limit, should discourage vehicles from seeking fuel unless there was an immediate need.
This limit should reduce the amount of time required to service each vehicie and the likelihood of long queues forming at any fuel allocation site.
In rummary, the fuel allocation plan will provide ade-quate fuel supplies to evacuating traffic and will not cause delays on evacuation routes.
ATTACHMENTS ATTACHMENT 1 Road Crew Deployment Locations ATTACHMENT 2 Map, Road Crew Deploynient Locations and Fuel Allocation Sites ATTACHMENT 3 Map, Evacuation Routes With Highest Traffic Flow ATTACHMENT 4 Fuel Allocation Sites 9
ATTACHMENT 1 1
OPIP 3.6.3 Page 42 of 46 Attachment 8 Page 1 of 2 ROAD CREW DEPLOYMENT LOCATIONS l
l l Wind l l
Staging Areas l Zones l Direction l Patchogue i Port Jefferson l l l (From) l Riverhead !
l l 0 - 2 Miles l l l l l I l .
l l l l William Floyd Parkway & l Port Jefferson Patchogue l Middle Country Road l l A, B, C, D, E l All I l l l Route 25 (TCP 62) l Road (Route 112) & Route l (Route 25) & Middle Island l l l 495 (TCP 77) l Road (TCP 11) l l l l l l l Wading River Manorville l l l
l l Road & Route 25 (TCP 10) l Patchogue Yaphank Road - l l l l l l l Sills Road & Route 495 l l l l l l Wading River Road & l (TCP 70) '
l l l l Route 495 (TCP 27) l l l l William Floyd Parkway & I l l l~ l l l Route 495 (TCP 126) l l l l l Edwards Avenue & l l l l l Middle Country Road l l l
l l l l l l (Route 25) (TCP 14) l l l 1 l l l l l l l l 0 - 5 Miles l The following Road Crew Deployment locations are to be activated in addition to those l
l l activated for the 0 - 2 mile area. l l l l l l l l l
l l Route 25A & Rocky Point l l A - E, F, G l E l l ENE l l l Road (TCP 38) l l l l l NE l l 1
l l Route 25A & Patchogue - l l l l l l l l Mt. Sinal Road (Route 83) l l
l l l l (TCP 56) l
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l l Patchogue - Port Jefferson l l l l l
l l l l Road (Route 112) & l l
l l l l l Nesconset Road (TCP 50) l l l l l 1 l l Rev. 2 I
10/15/83 I
OPIP 3.6.3 Page 43 of 46 Attachment 8 Page 2 of 2 ROAD CREW DEPl.0YMENT LOCATIONS (continued) j l l Wind I l
Staging Areas l Zones l Direction l Patchogue l Port Jefferson l l l (From) l Riverhead l l
l 1 l l 0 - 5 Hiles l Tha following Road Crew Deployment locations are to be activated in addition to those l
l (continued) l activated for the 0 - 2 mile area. l l 1 I l 1 1 l l l A - E, C, H, I l NNE l l Sunrise liighway & William l Route 25A & Rocky Point l N l l Floyd Parkway (TCP 30) l Road (TCP 38) l l l I 1 l l l l
l l Route 25A & Patchogue - l l l l l I j l Mt. Sinal Road (Route 83) l 1 l (TCP 56) l l l l l l l l l
l l l
l Patchogue - Port Jefferson l l l l l l l Road (Route 112) & l l l l l l Nesconset Road (TCP 50) l l l I I l 1 l l i
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NNW l l Sunrise Highway & William l l l A - E, H, I, J l l NW l l Floyd Parkway (TCP 30) l l l
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l l A - E, I, J l WNW l No additional locations to the 0 - 2 mile area are necessary. l l l W l l l 1 l l l l l 0 - 10 Miles l Activate all Road Crew Deployment locations. l l l I l 1 Rev. 2 10/15/83
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OPIP 3.6.3 Page 46b of 46 l Att.achment 13 Page 1 of 1 FUEL TANK TRUCK DEPLOYMENT LOCATIONS
- 1. Sunrise Highway (Ree. 27), east of Rte. 112 .
- 2. Rt. 25A, east of CR 83
- 3. Center Moriches Road, north of Long Island Expressway
- 4. William Floyd Parkway Median, one mile south of Longwood Road
- 5. Ree. 25, east of Coram
- 6. Rest area on westbound Long Island Expressway, west of Bellport.
Avenue ,
- 7. North Country Road, east of Pipe Stave Hollow Road l
l l Rev. 3
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