ML20087C514

Rebuttal Testimony of Dt Hartgen & Fj Bench Re Emergency Planning Contention 65 on Evacuation Time Estimates. Certificate of Svc Encl

ML20087C514
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/08/1984
From:	Beach F, Hartgen D NEW YORK, STATE OF
To:
Shared Package
ML20087C497	List: ML20087C494 ML20087C514
References
OL-3, NUDOCS 8403130091
Download: ML20087C514 (20)

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NEW YORK STATE

' Parch 8, 1984 f

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UNITED STATES OF AMERICA

.a NUCLEAR REGULATORY COMMISSION

,/ ,:

7 Before the Atomic Safety and Licensing Board In.the Matter of )

)

LONG ISLAND LICHTING COMPANY ) Docket No. 50-322-OL-3

)' (Emergency Planning Proceeding) i (Shoreham Nuclear Power Station,. )

" Unit 1) )

- . REBUTTAL TESTIMONY OF DR. DAVID T. HARTGEN

,, e' it ., 4 ,.

y AND FOSTER J. BEACH, III

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tin , ~ ON BEHALF OF THE STATE OF NEW YORK PERTAINING T0 t- .

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- EMERGENCY PLANNING CONTENTION 65, EVACUATICdi TIME ESTIMATES X r I- k.Q',v} -

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3. Please state your narecs and addresses for the record.

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A.c My.name~1s' David T. Hartgen.

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I am the Director of the Statistics and 4  ;&.~ >

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. Analysis Section for~the New' York State Department of Transportation.

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Albhny,'N.Y.

' 8403130091 840300 ,

PDR-ADOcK 05000322 1

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-)hr name is roster J. Beach, III. I am the Supervisor of Regional Planning'& Development, Region 10 (Nassau-Suffolk) - New York State Department of Transportation.

-Q. Please provide your qualifications.

A. Our qualifications and-relevant experience were submitted in our direct testimony, which is bound into the transcript following page 3695. Our

' duties'have not changed since that time.

Q. 'On'page 3 of the supplemental testimony of Mathew C. Cordaro, John A.

'- -Weismantle, Edward B. Lieberman and' Dennis S. Mileti, which is bound into the transcript following page 3857, in response to question.4, Messrs. Cordaro, Weismantle, Lieberman and Mileti state:

' "In general, the State's testimony expresses only general, unquantified concerns about the evacuation time. estimates. In many cases, the State witnesses' concerns are presented in broad concepts of transportation planning and traffic engineering, including such concepts as 'capaci-ties or levels.of service', ' side friction' and ' calibration / valid-ation'.- They have further clouded the issues in this proceeding by applying these concepts to the broad field of transportation planning

,, - - rather.than the specific situation in question --

17:

an evacuation of the.Shorch'am EP2".

With respect.to this statement, have you applied the concepts of

" capacities:or levels of service", as they relate to directional flow, 2

to "the specific situation in question -- an evacuation of the Shorcham EPZ?"

A. Yes, we believe that the level of service D service volumes of roadway sections within the EPZ are in fact considerably , lower than those estimated by KLD. Appendix A of this rebuttal testimony, which is attached hereto, shows the level of service D service volumes of sections of State highways within the EPZ. These levels of service D service volumes have been calculated by using the State's photolog fil=s and data on the characterictics of routes maintained by the State. Appendix D of this rebettal testimony consists of a map which shows these routes .(level D values are shown in red pencil). Because

-Appendix D is quite large and is mounted on a board, we are not attach-ing it to this rebuttal testimony. We will submit Appendix D to the Board when this rebuttal testimony is introduced into the record.

However, Appendix D will be made available to the Board and all parties prior to its introduction into the record. Interested persons should contact counsel for New York State to make viewing arrangements.

As is apparent from Appendix A of this rebuttal testimony, the State's estimates of level of service D volumes are generally lower than KLD's.

Accordingly, the capacity of the network may depend not upon intersec-tion capacity, as KLD implies, but rather upon the capacity of the streets themselves. This is especially likely since many of the intersections in the network are characterized b, turn bays, which inflate the capacity of the intersection but have no effect on the capacity.of the streets brtween the intersections.

3

Appendix E of t F is rebuttal testimony consists of a photolog film of Rt. 25A from P.t. 25 westbound past the Shorehan plant to the town of Port Jefferson, filmed in 1982. It demonstrates the above points.

Because Appendix E is a 20-minute film which requires special viewing equipment, we are not attaching it to this rebuttal testimony. We will submit Appendix E to the Board and show it to the Board and all partia=

when this rebuttal testimony is introduced into the record. However, Appendix E and the necessary vieuing equipmert will be made available to the Board and all parties prior to the film's introduction into the record. Interested persons should contact counsel for New York State to make viewing arrangements.

Q. What is the reason for the difference.s between the State's estimates of capacity and KLD's?

A. We are not sure, since we do not have KLD's calculations. However, our review suggests that the difference is due primarily to a factor of 2/3 which the State has applied to the level of service D service volumes to account for directional flow. This correction is necessary because the Highway Capacity Manual Procedures calculate the 2-way capacity on service volumes for 2-lane rural roads. Unless it can be assumed that all traffic will be moving in one direction, this correction must be made. Traf fic will be 2-way because of reverse movement of school buses, energency vehicles, and mobilization traffic.

4

4 t.s an example, consider Link 11-36 (Rt. 25A Eastbound, from M. Rocky Pt. Landing'Rd. to Ridge Rd.), shown on the photolog film (Appendix E of this rebuttal testimony). The 2-way level of service D service volume is 1500 (2000 x .75). The State has made an additional direc-tional correction by applying a factor of .67 to the estimate of level of ' service D service volume (1500 x .67 = 1000). Additional smaller ,

factors for percent trucks, lane width and lateral clearance reduce the estime.te further to 950. It appears that the consultant has estimated the level of service ~ service volume similarly (1,500 = 2,000 x .75) in accordance with the procedures of the Hignway Capacity Manual, but has then applied an across-the-board factor of .85 to this estimate to reach his estimate of-1,275. No specific adjustment appears to have been made for directional flow,.or for other items in the Highway capacity Manual.

LILCO's own testimony (T. p. 3859) recognizes that the use of direction adjustments is "a standard procedure used in association with the Highway Capacity Manual." Yet (on T. p. 3860) LILCO asserts that "there should be no such adjustment. It is made quite clear in the text of the HCM that such an adjustment should not be made." These

- statements are inconsistent with each other. For 2 lane rural roads, the HCM procedure calculates 2-way capacity estimates; that is the total ~2-way level of service volume that the road can accommodate. If 2-way flow is permitted (as will be in an evacuation) then not all of the capacity will be availtble to one direction and, therefore, one-way capacity will be less than total capacity. The State's procedure of 5

~

cpplying a 2/3 factor follows good practice, is conservative, and makes sense, particularly in evacuation scenarios.

Q. With' respect to the statement of Messrs. Cordaro, Weismantle, Lieberxan and Milett (p. 3 of their supplemental testimony) referred to above, have you applied the concepts of " capacities or levels of service", as they relate to side friction, to "the specific situation in question --

an evacuation of the Shoreham EPZ?"

A. Yes, we believe that the-affects of side friction will reduce the capacities of roadway sections within the EPZ. Appendix,3 of this

~

rebuttal testimony, which is attached hereto, is a nonexhaustive list of State routes inside the EPZ characterized by roderate to heavy side friction, i.e., considerable roadside development between major inter-sections. These routes are colored yellow on the map in Appendix D of this rebuttal testimony. In addition, the photolog film of Rt. 25A (Appendix E of this rebuttal testimony) shows the same roadside devel-opment. We believe that the effect of vehicles entering from driveways and businesses is significant and'should be accounted for.

The State disagrees with KLD's contention that the effcet of side friction is greatest at levels of service A-D and will have marginal effect at level of service E. In the event of an evacuation, side friction is likely to be represented by~ vehicles attempting to nose their way into traffic from numerous side streets, not accounted for by RKLD. This behavior will, as KLD notes, have the effect of changing the order in which vehicles leave the EPZ. I!owever; it will also greatly 6

~ _ ._ . - - - - .-,_

1 lengthen the tail of the evacuation time distribution, if as the consultant suggests vehicles simply wait longer to use the networks.

, Q. On p. 14 of your direct testimony, you stated that the LILCO network appeared to be inherently not detailed enough to answer questicns about multiple routea of evacuees. With respect to the statemo.t of Messrs.

Cordero, Weismantle, Lieberman and Mileti (p. 3 of their supplemental testimony) referred to above, have you related the coarseness of the DYNEV network, to "the specific situation in question -- an evacuation of the Shoreham EPZ?"

A. Yes, we believe that the network is too coarse because it does not

-include numetous roads which the State feels are likely to be used by evacuees in the evacuation period. We maintain our belief despite the statement of Mr. Lieberman on pages 20 ar.d 21 of the supplemental testimony referred to above that "the configuration of the evacuation network for the Shoreham EPZ has been defir with great care" and that the "280 links include all expressways, primary, and secondary roads as well as many tertiary roads," and that "the delineation of the evacua-tion network was undertaken as the result of many field surveys, a detailed study of large scale maps and a careful review of the early Suffolk County Plan."

Appendix C of this rebuttal testimony. which is attached hereto, contains examples of sections of highway which are not in the network, but which the 7 tate believes would be used by residents as vehicle escape routes in an emergency. These routes are colored green in 7

Appendix D of this rebuttal testinony. These highways are both inside and outside the EPZ, and both east and west of the Shoreham site. A detailed review of the road structure in the area in and around Shoreham leads the State to the conclusion that its original concerns about the density of.the network are substantiated, and that the network is not dense enough to allow for alternative routes or for full assessment of evacuation behavior. Therefore, it is likely that the effects of travel on these routes are not modeled correctly in KLD's computer runs.

In addition, a review of one key evacuation route (Route 25A) showe

- that the network does not show nodes at 2 signalized intersections (Rt.

25A and R.andall Rd., Rt. 25A and Broadway) and that the complex ar-rangements in the area of the intersections of Rt. 347 uith Rt. 25A, Rt. 25A.with Rt. 112, and Rt. 112 with Rt. 347 have all been reduced to a single node. The photolog film (Appendix E of this rebuttal testimo-ny) shows clearly the existence of these signalized and complex inter-sections. In the State's. view, simplifications of this sort raise great concerns about the representativeness of the entire network.

Q. Would you summ'rize your. conclusions?

First, KLD has not used readily available film and computer-based information concerning the characteristics, capacity, and traffic on the highway systen in the EPZ.

8 r 1

L. . .

Second, KLD appears to have assumed that the capacity of intersections controls'the capacity of.the system, and c;.parently has not accounted

i. for_ directional flow, or the effects of side friction, particularly roadside businesses.

Third. these assumptions appear to have led KLD to overestimate capaci-

.ty'on r.ost of the sections of highway in the EPZ. These over-estimates have likely led KLD to substantially under-estimate the travel time necessary to traverse each section of highway and to leave the EPZ.

Fourth, the network used by KLD appears to be too coarsely coded to

-allow for accurate analysis of evacuation behavior.

1 In _ summary, we believe that estimates of capacity of highway sections should be redone and that the DYNEV model and its supporting tools be re-run with -

these revised estimates.

9

A APPENDIX A EXAMPLES OF ROADWAY CAPACITY CALCULATIONS, EPZ SECTIONS CAPACITY (VPH)

Roadway Section ~ Zone Links Nominal Congestion DOT  % Diff.*

Route 25A, Eastbound F,G (11, 36) 1500 1275 950 - 25.5 From No. Rocky Paint Landing.Rd. to Ridge Rd.

' Route 25A, Westbound D (54, 53) 1500 1275 960 - 24.7 From No. Country Rd.

to Wading River -

Manorv111e Rd.

Route 25A, Westbound F,G ( 9, 8) 1110 935 830 - 11.1 From Radio- Ave.

to Miller Place Rd.

Route 25A, Westbound FK ( 8, 7) 750 640 830 + 29.7

- From-Miller Place Rd..

'-to Echo Ave.

Route 25A, Westbound K' ( 7, 30) 3000 2550 830 - 67.5 From Echo Ave. to Patchogue-Mt. Sinal Road Ro'ute 25A,' Westbound K~ (30, 6) 1500 1275 830 - 34.9

. From Patchogue-Mt.

Sinal Rd. to Crystal Brook Hollow Rd.

Route 25A, Westbound Q,K ( 6, 12) 1200 1020 2390** + 134.3' from Crystal Brook

. Hollow Rd. to Route 112 I' --

Route 25A,' Westbound C -(53, 37) 1500 1275 950 -25.5 From Wading River -

Manorville Rd. to William Floyd' Pkwy.

Route 112,' Southbound -K (82, 17) 900 765 750 -

2.0 lFrom Grove Street to  !

Patchogue-Mt. Sinai Rd.

Route -112,' Southbound K (17, 21) 300 425 750 + 76.4 From Patchogue-Mt. Sinai.

Rd.'to Middle Country

-Rd. (Rt. 25)

'* DO1 vs. "Congestiot" Capacity

• • Route 347 Between' Crystal Brook Hollow RI. & Route 112 r - -

4 -

. 's A PPENDIX A EXAMPLES OF ROADWAY CAPACITY CALCULATIONS, EPZ SECTIONS CAPACITY (VPH)

Roadway'Section Zcne Links Nomina 1 Congestion DOT  % Diff.

Route 112,-Southbound R (21, 68) 2000 1700 800 - 52.9

-From Middle Country Rd. to Milton St.

Route 112 Southbound R (68, 47) 2000 1700 710 - 58.2 From Milton St. to Granny Rd.

~ Route 25, Westbound. P,0 -(75, 73) 1500 1275 950 - 25.5 Frem Old Country Rd.

to Edwards Ave.

Route 25, Westbound D,1 (58, 93) 1500 1275 950 - 25.5 From Rt. 25A to Line Rd.

Route 25, Westbound C.H (56, 86) 1500- 1275 950 - 25.5 From Wading River -

Manorville Rd. to Old Saddle Rd.

Route 25, Eastbound D,1 (56, 93) 1500 1275 950 - 25.5

.From Wading River -

'Manorville Rd. to l Line Rd.

t L

Route 25, Eastbound D J,I (93, 58) 800 680 From Line Rd. to (58, 95) 1200 1020 950 - 6.9

-Fresh Pond Ave.

!, Route 25. Eastbound J,1 (95, 73) _

1500 1275 950 - 25.5 L From Fresh Pond Ave.

to Edwards Ave.

L.I. Expressway, 0- (75, 74) 3600 3060 4090 + 33.7 Westbound From Rt. 25 to Edwards Ave.

L.I. Expressway, 1,0 (74, 94) 5400 4590 4090 - 10.9 Westbound. (94, 98)

From Edwards Ave. H,N (98, 96) to Mill Rd. (96. 71)

M,L (71, 88)

(88, 122)

(122, 44)

(44, 48)

(48, 33)

(33, 32)

(32. 79)

(23 62)

APPENDIX A EXAMPLES OF ROADWAY CAPACITY CALCULATIONS, EPZ SELI' IONS CAPACITY (VPH)

Roadway Section Zone Links Nominal Congestion DOT 7. Diff.

L.I. Expressway, M,N (119, 50) 5400 4590 4090 - 10.9 Eastbound at William Floyd Pkwy.

L.I. Expressway, 0 ( 74, 75) 5400 4590 4090 - 10.9 Eas tbour.d From Edwards Ave.

to Rt. 25 L.I. Expressway N,0 ( 50, 88) 5400 4590 4090 - 10.9 Eastbound from Wm. ( 88, 114)

Floyd Pkwy. to (114, 116) __

Edwards Ave. (116, 93)

( 98, 94)

( 94, 74)

APPENDIX B EXAMPLES OF STATE ROUTES INSIDE EPZ WITH MODERATE TO (

HEAVY SIDE FRICTION *

]

Route-25

-- WB From William- Floyd Parkway to Smith Road (99, 40)

. WB From Wading River Rd. to County Road 21- {81, 24)

- WB From Bartlett Rd. ' to Rt. 112 JCT (23, 21, inclusive)

Route 25A

- WB1From William Floyd Parkway to North Country Rd. (9, 37)

-~ . WB From Co ram-Mt . Sinal to Rt. 347 JCT-Roate 112 NB - Fro nt Granny Rd. to Rt. 25 JCT NB From Unnamed Residential Street to Rt. 347 JCT (82,12)

-- ~ SB From N. . Country Rd. to RT. 347 JCT (79, 12) h0THERS (Nor ON STATE SYSTEM)

' C nmi Rd.

(Both' Directions) From Rt.112 JCT to County Road 83 (12, 13)

MT. Sinai - Coram Rd.

SB From Canal Rd. to Middle Country Rd. (14, 22 inclusive)

Whi-key'Rd.

(Both Directions) From Ridge Rd. to William.Floyd Parkway (38, 39)

-Mill Rd.

. Form Rt. 112 to Granny Rd. (21, 69)

-*EPZ Node Numbers Shown-in Parentheses

.5 Appendix C ,

EXAMPLES OF ROADS THAT ARE NOT IN THE EVACUATION NETWORK -

'i Min.

Lane Shoulder R9*d , Limits Pavement Lanes Width Width Comments A. 'INSIDE EPZ (WEST OF SNPS)

1. Randall Rt. 25A-Whiskey Asphalt 2 12' 0-8' Winding & hilly; sev-Road Road eral driveways

2. R:ndall . Whiskey Rd.-Rt. Asphalt 2 12' 0-8' Several driveways ad-R:ad 25 jacent to N/B lane

3. Raynor Whiskey Rd.-Rt. Asphalt 2 16' O Winding & hilly just

. Road 25 south of Whiskey Rd.

several driveways

4. Woodlots Whiskey Rd.-Rt. Asphalt 2 10' 0 Winding & hilly; sharp

_ Road 25 curves; severa?. drive-ways 5.' Hollow Whiskey Rd.-Rt. None 2 10' 0 Dirt road Road 25

6. Wading Whiskey Rd.- None 2 10' 0 Dirt road Rivges Ridge Rd.

Rd.

7. Currans- Whiskey Rd.-Rt. None 2 10' 0 Dirt road Road 25 Coram-Swezytown Asphalt 2 12' O Winding; several drive-8.Swez{

Lane Rd.-Rt. 25 ways.

9. Coram- Whiskey Rd.-Mt. Asphalt 2 12' 0 Winding.

Swezztown Sinai-Coram Rd.

. Road' f

10. Pine Road Mt. Sinai-Coram Asphalt 2 12' 0 Sharp curves continues- Rd.-Old Town Rd.

'cs Penna-quid Rd. &

Wedgewood .

Dr.

11. Crystal Oakwood Rd.- Asphalt 2 10' 0-8' Winding north of Rt.

Brook Canal Rd. 25A Hollow Rd.

~12.'Shenandoah Crystal Brook Asphalt 2 12' 8' Several driveways

' Blvd. Hollow Rd. -

Canal Rd.

1 Fr: 0 street sign; AKA Swezey Lane.from Hagstrom Map, '83 Edition 2

3 From street sign; AKA Swezeytown Road from Hagstrom Map Fr~Magstrom Map _

Fiald inventientions 2/24 anc !/27 6 _ _ _ _ _ _ _ - _ - _ _ _ _ _ - _ .

I-lt ~

Min.

Lane Shoulder

' Ro-d Limit Pavement Lane Width Width Comments

13. Houte 347 Route 25A-Rt. Asphalt 4 12' 10' Minimum 10' grass

! .112 median with left turn storage lane

14. Shore Rd. Old Post Rd.- Asphalt 2 12' 0 Winding; several drive-Crystal ~ Brook ways Hollow Rd.

15.Orkwood Rd6 Crystal Brook Asphalt 2 12' 0 Winding; several drive-cont. as Hollow Rd. - ways B211e Terre Thompson St.

16. New St.4 Shore Rd.-North Asphalt 2 10' 0 Hilly; sharp curves; Country Rd. poor sight distance

'17.. Mt. Sinai-' North Country Asphalt 2 12' O Poor sight distance.

. Coram Rd. Rd.-Rt. 25A

18. Pipe Stave North Country Asphalt 2 12' 2-8' Hilly Hollow Rd. Rd.-Rt. 25A

19. North Echo Ave.-Rt.25A Asphalt 2 12' 2' Ccuntry Rd.

20. Broadway Locust Drive-Rt. Asphalt 2 12' 0-8' Several driveways 25A 21.' Smith- Medford Rd. - Asphalt 2 0 Road -Rt. 25

22. A hton Rd. E.' Bartlett Rd.- Asphalt 2 10' 0 Sharp curves; poor Granny Rd. sight distance.

23. E. Bartlett Ashton Rd.-Rt.25 Asphalt 2 10' 0 Sharp curves Rd.

-24. Bartlett Ashton Rd.-Yap.- Asphalt .

10' 0 Sharp curves; poor Rd. Middle Isl. Rd. sight distance

25. W. Bartlett Granny Rd.-E. Asphalt .

10' 0 Sharp curves; poor Rd . - Bartlett Rd. sight distance

[26.-M1111 Road Granny'Rd.-Bell- Asphalt i 12' 2' Sharp curves; poor port Ave. sight distance

27. B-llporc-Mill Rd.-Rt.27 Asphalt 2 12' O Passes out of EPZ

-Ave, con-between Mill Rd. &

.tinues as LIE Station Rd.

48.'Coram Rd.5 Bellport Ave.- Asphalt i 12' 2' Sharp curves Patchogue-Yap.

R( ,

.5

. AK v a a.

.4r,A:Miu,,... ll Road frtm N.Y.S. Quadanele

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m v. . . _ _ .v ., , . _ , ,, , . .. a ,4 e . , , u e t ,, : s n. ,i .

t Min.

Lane Shoulder R"d Limit Pavement I. anes Width Width Comments B. INSIDE EPZ (Sot!Til AND EAST OF SNPS)

29. Sound Ave. Doctor's Path- Asphalt 2 12' 0-4' Edwards Ave.

30. Twomey Sound Ave.- Asphalt 2 12' 0 Ave. Manor Rd.

31. Riley Ave. Edwards Ave.- Asphalt 2 12' 0 Twomey Ave.

32. Osborn Sound Ave.- Asphalt 2 16' O Sharp curve between Ave. Rt. 25 Horton Ave, and Rt. 25 Passes out of EPZ between r1 58 and NYS Rt. 55.

33. Ilorton Sound Ave.- Asphalt 2 12' O Ave. Osborn Ave.

-34. Reeves Osborn Ave.- Asphalt 2 10' 0 Ave. Doctor's Path

35. Roanoke Sound Ave.-Rt. Asphalt 2 12' north'0 Several driveways

! Ave. 25 of CR 58 south of CR 58 16' south 8' of CR 58.

36. Middle Rt. 25/CR 58- Asphalt 2 12' 0 Intersection sight I Rd. Horton Ave. distance poor @ Horton Ave, intersection

37. Youngs Twomey Ave.- . Asphalt 2 16' 0 Winding; sharp curves Ave. Osborn Ave.

38. Forge Rd. Rt. 25-South Asphalt 2 10' O Winding; sharp curves River Rd.

39. S. River CR 9'/Rt. 24- Asphalt 2 12' 0 Winding; sharp curves Road Forge Rd.

40. River Rd. Connecticut Ave.- Asphalt 2 12' O Winding; sharp curves Edwards Ave. ,

~41.SwagPond Wading River- Asphalt 2 16' 0 Rd. Manorville Rd.-

Connecticut Ave.

6 From street sign; AKA Grumman Blvd. from Hagstrom Map

Min.

Lane Shoulder Road Limit Pavement. Lanes Width Width Comments

42. Port Jeff- LLE LM t 70-E. Asphalt 4 12' 10' 4' flush cedian erson-Wtst- Moriches-River-hampton Rd. head Rd.

43. Chapman Port-Jefferson Asphalt 2 12' O Blvd. Westhampton Rd.-

continues Rt.27 as Rail-road Ave.

44. Italsey River Rd.-Port Asphalt 2 12' 0 Some sharp curves Manor R. Jefferson-West- -

continues hampton Rd.

as Conn-ecticut Ave.

45. Jerusalem Rt. 27-Wading Asphalt 2 12' 0 llollow Rd. Rivar Rd.

46. Jerusalem Wading River Rd. None 2 12' 0 Dirt road.

Ilollow Rd. Chapman Blvd.

47. Moricheu7 Manorville Rd. Asphalt 2 12' 0 Yap. ,Rd4 Rt. 27

48. Middle LIE-Manorville Asphalt 2 12' 0 Winding and hilly Island- Rd.0 Moriches Rd.

C. OUTSIDE EPZ

49. Sunrise llwy Wading River Rd. Concrete 4 12' 10' Limited access Riverhead Rd.

50. Moriches- Rt. 27A-Rt. 24 Asphalt 4 12' 10' Controlled access Riverhead Rd.

51. Ilorse Block Rt. 27-Nico11s Asphalt 2 12' 10' Rd. Rd.

52. Long Island Exit 66-Exit 62 Concrete 6 12' 10' Limited access Expressway I

53. Granny Rd. llores Block Rd.- Asphalt 2 12' 2+10' Several driveways Rt. 112

54. Rt. 347 Nicoils Rd.-Rt. Asphalt 4 12' 10' Controlled access 25A .

I From street sign; AKA Moriches-Middle Island Rd., AKA Yaphank-Middle Island Rd. from Hagstrom Map.

8 From street sign; AKA North St. f rom llagstrom Itap

Min.

Lane Shoulder Road I.imits Pavement Lanes Width Width Comments

55. Nic6Lis Rt. 25A-Rt. 27 Asphalt 4 12' 10' 20' grass median; left Rd. turn storage lanes

56. Patchogine- Mooney Pond Rd. Asphalt 4 12' 10' 10' flush median; left Mt. Sinal Granny Rd. turn storage lanes.

Rd.

57. North Granny Rd.-Rt. Asphalt 4 12' 10' 10' flush median; left ocean 27 turn storage lanes.

Ave.

58. Medford Rt. 27-ilo rse Asphalt 2 12' 2-10' Several driveways Ave. Block Rd.

continues es Medford Rd. .

59. Boyle Rd. Rt.25-01d Town Asphalt 2 12' 2-10' Several driveways Rd. south of llawkins Rd.

1-

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges James A. Laurenson, Chairman Dr. Jerry R. Kline Mr. Frederick J. Shon

)

In the Matter of )

) Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY ) (Emergency Planning Proceeding)

)

(Shoreham Nuclear Power Station, ) March 9, 1984 Unit 1) -

)

)

)

CERTIFICATE OF SERVICE I hereby certify that one copy of the MOTION OF GOVERNOR MARIO CUOMO, REPRESENTING THE STATE OF NEW YORK, FOR LEAVE TO FILE REBUTTAL TESTIMONY ON CONTENTION 65, EVACUATION TIME ESTIMATES AND REBUTTAL TESTIMONY OF DR. DAVID T. HARTGEN AND FOSTER J. BEACH III ON BEHALF OF THE STATE OF NEW YORK PERTAINING TO EMERGENCY PLANNING CONTENTION 65, EVACUATION TIME ESTIMATES has been served to each of the following this 9th day of March 1984 by U. S. Mail, first class, except as otherwise noted:

James A. Laurenson, Chairman ** Ralph Shapiro, Esq.

Atomic Safety and Licensing Board Cammer and Shapiro U.S. Nuclear Regulatory Commission 9 East 40th Street Washington, D. C. 20555 New York, New York 10016 Dr. Jerry R. Kline** Howard L. Blau, Esq.

Administrative Judge 217 Newbridge Road Atomic Scfety and Licensing Board Hicksville, New York 11801 U.S. Nuclear Regulatory Commission ,,

Washington, D. C. 20555 W. Taylor Reveley III, Esq.

,, Hunton & Williams Mr. Frederick J. Shon P. O. Box 1535 Administrative. Judge 707 East Main Street Atomic Safety and Licensing Board Richmond, Virginia 23212 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 l

_ - - _ _ _ - - - - - - - - - - - - - - - - - - - - _ - - - _ J

~

2-4- Mr. Jay Dunkleberger Marc W. Goldsmith New York State Energy Office Energy Research Group, Inc.

- Agency Building 2 400-1 Totten Pond Road

- Empire State Plaza Waltham, Massachusetts 02154 Albany, New York 12223 James B..Dougherty, Esq. 1723 Hamilton Avenue, Suite K l 3045 Porter Street, N. W. San Jose, California .95125 Washington, D. C. _20008 Honorable Peter F. Cohalan Mr._ Brian McCaffrey Suffolk County Executive Long Island Lighting Company H. Lee Dennison Building Shoreham Nuclear Power Station Veterans Memorial Highway P. O. Box 618 Hauppauge, New York 11788 North' Country Road Wading River, New York 11792 Ezra'I. Bialik, Esq.

Assistant Attorney General Martin Bradley Ashare, Esq. Envirommental Protection Bureau Suffolk County Attorney New York State Department of Law H. Lee Dennison Building 2 World Trade Center Veterans Memorial Highway New York, New York 10047 Hauppauge,-New York 11788

' Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory Commission U.S.-Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 ,,

Docketing and Service Section Regional Counsel Office.of_the Secretary Federal Emergency Management

- U.S.-Nuclear Regulatory Commission Agency

, 1717 H Street, N.W. 26 Federal Plaza, Room 1349 Washington, D. C. 20555 New York, New York 10278

Bernard M. Bordenick, Esq. Nora Bredes David A. Repka, Esq. Executive Director U.S. Nuclear Regulatory Commission Shoreham Opponents Coalition

' Washington, D. C. 20555' 195 East East Main Street Smithtown, New York 11787

.Stuart Diamond ,,

- Environment / Energy Writer Eleanor L. Frucci, Esq.

NEWSDAY .

Atomic Safety and Licensing Long Island, New York 11747 Board Panel U.S. Nuclear Regulatory Commission Stephen B. Latham, Esq. Washington, D. C. 20555 Twomey, Latham & Shea P. O.. Box 398 33 West Second Street.

- Riverhead, New York 11901

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Herbert H. Brown, Esq.

Lawrence Coe Lanpher, Esq.

Karla J. Letsche, Esq.

1900 M Street, N. W., Suite 800 Washington, D. C. 20036 q Spence Perry, Esq.

Associate General Counsel Federal Emergency Management Agency Washington, D. C. 20472

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RICHARD J. ZAHNLEUTER Assistant to the'Speci'al Counsel to the Governor of the State of New York Executive Chamber State Capitol Albany, New York 12224

• By Hand

• • By Federal Express on March 8, 1984

• • • By Telecopier

• • • • By U.S. Express Mail Albany, New York March 9, 1984 T

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