ML20086U327
| ML20086U327 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/02/1984 |
| From: | Cordaro M, Edward Robinson, Weismantle J LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20086U072 | List: |
| References | |
| OL-3, NUDOCS 8403070227 | |
| Download: ML20086U327 (15) | |
Text
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LILCO, March, 2, 1984 n
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j UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
]
Before the Atomic Safety and Licensing Board 2:
In the Matter of
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LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3 o
?!
) (Emergency Planning
, j (Shoreham Nuclear Power Station, )
Proceeding)
Unit 1)
)
i TESTIMONY OF MATTHEW C.
CORDARO, ELAINE D.
]
ROBINSON, AND JOHN A. WEISMANTLE ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY i
PLANNING CONTENTIONS 96.A AND 96.C (LOSS OF OFFSITE POWER) y Hunton & Williams P.O.
Box 1535 707 East Main Street i
Richmond, Virginia 23212
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(804) 788-8200
. i 8403070227 840302 PDRADOCK05000gg T
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l LILCO, March, 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
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LONG ISLAND r'OFTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning (Shoreham Nuclear Power Station, )
Proceeding)
Unit 1)
)
TESTIMONY OF MATTHEW C. CORDARO, ELAINE D.
ROBINSON, AND JOHN A. WEISMANTLE ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTIONS 96.A AND 96.C (LOSS OF OFFSITE POWER) 4 PURPOSE Contentions 96.A and 96.C allege that the LILCO Transition Plan is inadequate because it does not provide for backup power supplies for (1) all ambulance and bus companies that might supply emergency vehicles and (2) residential lighting, public streetlights, traffic signals, and service stations in the EPZ.
This testimony will establish that such backup power supplies are not necessary either to comply with the reguletions or as a i
practical matter.
There is no mentien in the regulations or NUREG-0654 guidelines of the backup power supplies contemplated in Contentions.96.A and 96.C.
Moreover,-a losstoffpower
'f would not significantly impede an evacuation emergency.
d response.
1
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 (Shoreham Nuclear Power Station, )
Proceeding)
Unit 1)
)
TESTIMONY OF MATTHEW C. CORDARO, ELAINE D.
ROBINSON, AND JOHN A. WEISMANTLE ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTIONS 96.A AND 96.C (LOSS OF OFFSITE POWER)
TESTIMONY 1.
Q. Please state your names and business addresses.
A.
[Cordaro]
My name is Matthew C. Cordaro and my busi-ness address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York, 11801.
[ Robinson]
My name is Elaine D. Robinson and my busi-ness address is Long Island Lighting Company,.100 East Old Country Road, Hicksville, New York, 11801.
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[Weismantle]
My name is John A. Weismantle and my business address is Long Island Lighting Company, 100 East Old Country Road, Hicksville, New York, 11801.
2.
Q. Please summarize your professional qualifications and your role in emergency planning for the Shoreham Nuclear Power Station.
A.
[Cerdaro]
I.am Vice President, Engineering, for LILCO and have-heldithis position since the~ spring of 1978.
My professional qualifications are being separately of-fered into evidence as part of the document entitled
" Professional Qualifications of LILCO Witnesses."
I am sitting on this panel to provide the LILCO management perspective on emergency planning, and to answer any questions pertinent to management.
My role in emergen-cy 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 emer-gency planning are being conveyed to corporate manage-ment.
(Robinson]
I head the External Organizations Division of LERIO.
My professional qualifications are being of-fered into evidence as part of the document entitled
" Professional Qualifications of LILCO Witnesses."
As Manager of External Organizations, I am responsible for coordinating the efforts of outside organizations in emergency planning.
In this capacity, I have super-vised the work with ambulance and bus companies and am aware of the effect that a loss of offsite power would have on these facilities.
[Weismantle]
I am Manager of the Local Emergency Re-sponse Implementing Organization (LERIO) for LILCO.
My professional qualifications are being offered into l
. _ _ - _ _ _ _ _ _ _ _ - evidence as part of the document entitled " Professional Qualifications of LILCO Witnesses."
My familiarity with the issues surrounding these contentions stems from my work in developing and implementing the LILCO Transition Plan.
3.
Q. What is the " Preamble to Contentions 93-96?"
A. [Cordaro, Robinson, Weismantle]
The " Preamble to Con-tentions 93-96" reads as follows:
Preamble to Contentions 93-96.
The LILCO Plan must provide an adequate response for even "the worst possible accident, regard-less of its extremely low likelihood."
at 7.
This in-I cludes a loss of offsite power, which would not be unlikely in conjunction with a severe accident at Shoreham.
The LILCO Plan, how-ever, contains no measures for dealing with such a circumstance, and thus does not pro-vide for the protection of the public health I
and safety, for the reasons set forth in contentions 93-96 below.
4.
Q. Is it true, as is stated in the Preamble to Contentions 93-96, that a loss of offsite power "would not be unlikely in conjunction with a severe accident at Shoreham?"
A.
[Weismantle]
No.
My testimony on this issue is included in LILCO's testimony for Contentions 93, 94, and 95.
i 5.
Q. What is Contention 96?
A. [Cordaro, Robinson, Weismantle]
Contention 96 reads as follows:
. Contention 96.
10 CFR Section 50.47(b)(10) requires each emergency plan to provide for protective actions which protect-the public health and safety in the event of l-
_______________________ _ an accident.
NUREG 0654,Section II.J.9 re-
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quires a demonstration that the protective actions within a plan are capable of being implemented.
The LILCO Plan does not satis-fy these requirements because it fails to take account of the possibility of a loss of offsite power.
6.
Q. What are Contentions 96.A and 96.C?
A. Contentions 96.A and 96.C read as follows:
Contention 96.A.
Assuming that an evacu-ation of the plume EPZ were determined to be the appropriate protective action, the LILCO Plan relies heavily on the services of pri-vate firms such as ambulance services, LILCO Plan at 3.7, and bus companies, OPIP 3.6.4.
However, in the avent of a loss of offsite power these firms and facilities would be-come inoperable and close.
LERO would thus become unable to utilize those services.
Contention 96.C.
Assumir.g that evacua-tion of the plume EPZ were determined to be the appropriate protective act2on, the suc-cessful implementation of such an action would depend on the functioning of systems and facilities that would in fact be inoper-able in the absence of offsite power.
These include:
recidential lighting, public streetlights; traffic signals, and service stations.
The LILCO Plan does not indicate that any of these facilities and systems have backup power supplies.
Therefore, in the event of a loss of offsite power, the Plan would not provide for the protection of the public health and safety.
7.
Q. What are the legal standards cited in Contention 96?
A. [Cordaro, Robinson, Weismantle]. The legal standards cited in Contention 96 are the following:
1 10 C.F.R. S 50.47(b)(10)
I
. A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public.
Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
NUREG-0654, II.J.9 Each State and local organization shall establish a capability for implementing protective measures based upon protective action guides and other criteria.
This shall be consistent with the recommenda-tions of EPA regarding exposure resulting from passage of radioactive airborne plumes (EPA-520/1-75-001) and with those of DHEW (DEHS)/FDA regarding radioactive contamination of human food and animal feeds as published in the Federal Register of December 15, 1978 (43 FR 58790).
8.
Q. Please summarize the allegations in Contentions 96.A and 96.C.
A.
[Cordaro, Robinson, Weismantle]
Contentions 96.A and 96.C suggest that an offsite emergency plan does not meet the NRC regulations and NUREG-0654 guidelines unless it can ensure that there is a backup power sup-l ply (1) for all ambulance and bus companies that might supply emergency vehicles, and (2) for residential l
lighting, public streetlights, traffic signals, and service stations in the 10-mile EPZ.
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l 9.
Q. Does the LILCO Transition Plan provide for such backup power supplies?
A.
[Cordaro, Robinson, Weismantle]
No, and we do not think it is necessary to provide for such backup power i
supplies either as a practical matter or to comply with the NRC regulations or NUREG-0654 guidelines.
- 10. Q. Why do you say that it is not necessary to provide such backup power under the regulations or NUREG-0654 guidelines?
A.
[Cordaro, Robinson, Weismantle]
First, there is no mention of such backup power requirements in the regu-lations or NUREG-0654 guidelines.
Second, we feel that it is obvious that such a major reworking of the commu-nity is not contemplated by the regulations or NUREG-0654 guidelines.
As the EPA-NRC task force that produced NUREG-0396 states:
The Task Force does not recommend that mas-sive emergency preparedness programs be es-tablished arouns all nuclear power stations.
The following examples are given to further clarify the Task Force guidance on EPZs:
No special local decontamination provisions for the general public (e.g.,
- blankets, changes of clothing, food, special showers)
No stockpiles of ar.ti-contamination equipment for the general public No construction of specially equipped fallout shelters
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i No special radiological medical-provisions for the general public
! No new construction of special public facili-ties for emergency use j
No special stockpiles of emergency animal feed No special decontamination equipment for property and equipment No participation by the general public in test exercises of emergency plans Some capabilities in these areas, of course, already exist under the general emergency plans of Federal and State agencies.
NUREG-0396, Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants 14-15 (Dec. 1978) (emphasis in original).
If no spe-cial stockpiles of blankets or decontamination. equip-ment were intended, then neither was it intended that whole communities should be modified as Contentions 96.A and 96.C suppose.
- 11. Q. Do you know of any local radiological emergency plan that includes special measures dealing with the situa-tions contemplated in Contentions 96.A and 96.C?
A.
[Cordaro, Robinson, Weismantle]
Ho.
- 12. Q. Why do you say that it is not necessary'to provide such-backup power.as a practical matter?
A.
[Cordaro, Robinson, Weismantle]
.In the first plate, if there were a severe radiological accident,-and if it-occurred in the middle of the night, and if-it were t-
.. accompanied by a wide-spread loss of power such that evacuation would be severely hampered, then the appro-priate protective action probably would be sheltering, and sheltering can be implemented with or without power.
If evacuation were the recommended protective action, a loss of power would not have a significant effect on ambulance or bus services or the ability of people to evacuate.
- 13. Q. Contention 96.A alleges that ambulance facilities will become inoperable and will close in the event of a loss of offsite power.
Is that true?
A.
(Cordaro, Robinson, Weismantle]
No.
Ambulance ser-vices still operate during power outages.
LILCO has contacted the ambulance companies relied on in the Plan and confirmed this.
A summary of the information re-ceived from ambulance companies about their responses in a' power outage is appended to this testimony as At-tachment 1.
A loss of offsite power would not affect the availability of ambulance service.
It is implausible that ambulance companies,-which are relied upon to provide emergency services every day, would be inoperable simply because of a loss of-electricity,-
Ambulances do not have to'be equipped with-any special equipment in an emergency at Shoreham.
The driver need-only get into the ambulance'and drive'to a designated-location.
- 14. Q. Are the dispatch radios electrically operated?
A.
{Cordaro, Robinson, Weismantle]
Yes.
- 15. Q. How then will the dispatcher be able to communicate with ambulance drivers if the dispatch radio is not functioning?
A.
[Cordaro, Robinson, Weismantle]
Ambulance drivers will be instructed to call their dispatchar in the event they are not receiving radio communications.
- 16. Q. Contention 96.A alleges that bus facilities will become inoperable and close in the event of a loss of offsite power.
Is that true?
A.
[Cordaro, Robinson, Weismantle]
No.
A loss of offsite power will not affect the availability of buses.
A dispatcher remains on duty regardless of a loss of electricity.
Bus companies will be even less affected by a loss of electricity than ambulance facilities, be-cause bus drivers will not be contacted by electrically operated dispatch radios.
Bus drivers are all LERO workers and will report to staging areas to receive their instructions before picking up the buses.
- 17. Q. Contention-96.C suggests that there must be provisions for backup residential lighting.
What effect would a loss of residential lighting have on the ability for residents to evacuate at night?
A.
[Cordaro, Robinson, Weismantle]
First, it is unreason-able to suggest that a radiological emergency plan must make provisions for the loss of lights in people's homes.
While the loss of electric power'might delay
- slightly the mobilization of some evacuees, it is un-reasonable to think that a loss of lighting would pre-vent people from gathering a few belongings and getting into their cars.
Even though area wide or regional blackouts are rare, it is not uncommon for people to lose power in their homes when circuits become over-loaded.
As a result, people generally have some sec-
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ondary source of light in their homes, e.g.,
flash-i lights or candles.
- 18. Q. What effect would a loss of streetlights have on the ability-for people to evacuate at night?
1 A.
[Cordaro, Robinson, Weismantle]
A loss of streetlights would not impair a person's ability to evacuate, be-cause vehicles have headlights and, therefore, can be l
operated effectively without streetlights.
- 19. Q. If offsite power is lost, service stations can not op-erate.
Wouldn't this be a problem in a Shoreham emer-gency?
A.
[Cordaro, Robinson, Weismantle]
No.
Service stations would not be essential because LILCO itself would pro-vide fuel and fuel trucks.
In addition, if someone were to run out of fuel, buses would be available to evacuate these people.
Bus transportation is discussed at length in LILCO's testimony on Contention 66.
As a last resort, a person could ask other evacuees for a
. ride.
1 20. Q. What effect would a loss of power for traffic signals have on the ability of the public to evacuate?
A.
(Cordaro, Robinson, Weismantle]
A loss of power for traffic signals would not adversely affect the ability of people to evacuate, because a vast majority of in-tersections in the EPZ with traffic signals will be manned by traffic guides who override the traffic sig-nals anyway.
- 21. Q. Please summarize your testimony for Contentions 96.A and 96.C.
A.
[Cordaro, Robinson, Weismantle]
Backup power supplies for ambulance and bus facilities, residential lighting, public streetlights, traffic signals, and service sta-tions are not necessary either under-the regulations or as a practical matter.
There is no mention in the reg-ulations or NUREG-0654 guidelines of the backup power supplies contemplated in Contentions 96.A and 96.C.
Moreover, such a loss of power will not significantly impede an evacuation emergency response.
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ATTACHMENT 1 I
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AMEULANCE COIfANT TYPE OF DISPATCE SERFICE C0fegfMICATION DURING POWER 00 FACE Di County Ambulance Co.
Can reopend at all times. Have All will operate. Vehicles have two-way a dispatcher at facilities at all radios, mobile communicattom equipment
. M i h W m e Co.
- tismes, connected to central dispatch location; 4
personnel have pocket 1 agere. Additionally, 5
Stat Equipment Corp.
j
~ have backup 12 volt battery system and emer-
~
sency standby generator.
4 j
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1 Geerdima Ambnimace Co.
Can respond at all times. Have All will operate. Vehicles have two-way i
a dispatcher at facmties ht alt radioeg " personnel have pocket pagers. Addi-l Caesau Ambulanca Co..
tionally, have emergency backup radio systen times.
powered by emergency standby generator.
j Orlando Ambulance Co.
ii Cos11am h 1= ace Co.
Cam respond at all times. Main Will operate. Vehie1== have tw Q radios; j
bours has menned dispatcher. All persomaal have pochat pegers "ad walki-j ether times has.24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> answering talkia. Ees backup radio system with emer-service.
gency power connected to owner's home through i
telephone system.
i i
i Weir Metro Ambalmace Co.
Can respond et all tinse. Has a Will operate. fehicles have t m radios; dispeecher et facility at all times, pereoamel have pocket pagers.
l l
Transportatica With Care Can respond at all times. Malm Will o9erate. Yebicles have two-way radice.
j hours has mammed dispatcher. All Bas backup battery system.
y '9 other times has 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> answering
> re
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tJ W
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i p CostANY TYPE OF BISPATCE SEEFIM
'C(BGltlWICATION BRIR1HG MMER OUTAGE Fecomic Ambu 2mmes Co.
Can respond at all times. Main Will operate. Yehicles have t w y
~
hours has manned dispatcher. All radios.
other times has 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> enouerlag service.
Mercy Ambulance Co.
Can respond at all times. Main Will operata. Yahicles beve two-way hours has manned dispatcher. All
- radios, other times has 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> answerfag l
eervice.
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