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Executed Affidavit of Rc Roberts Re Applicant Transition Plan & Proposed Radiological Emergency Response Plan
	ML20098G865
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	09/25/1984
From:	Roberts R; SUFFOLK COUNTY, NY
To:	;
Shared Package
ML20098G861	List: ML20098G860; ML20098G865;
References
	OL-3, NUDOCS 8410050625
	Download: ML20098G865 (15)
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'84 Attachment C

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UNITED STATES OF AMERICA

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-NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

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In the Matter of

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LONG ' ISLAND LIGHTING COMPANY

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Doc ke t No. 50-322-OL-3

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(Emergency Planning)

(Shoreham Nuclear Power Station,

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. Unit 1)

)

AFFIDAVIT OF RICHARD C.

ROBERTS Richard C.-Roberts, being duly sworn, does say under oath the~following:

1.

My name is Richard C.

Roberts.

I am a Deputy Chief Inspector;with the Suffolk County Police Department.

2.

I am familiar with the LILCO Transition Plan,- the radiological' emergency response plan which LILCO proposes to implement in the event of a radiological emergency at Shoreham.

I'have appeared as a witness on behalf-of Suffolk County in the i

ongoing Licensing Board proceeding concerning the adequacy of the LILCO Transition Plan.

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3.

Suffolk County Executive Peter Cohalan has stated that in the event of a radiological emergency at Shoreham,

"[ t] he County could not implement a response to a Shoreham ac-cident because County law -- particularly Resolution Nos.

262-1982, 456-1982, and 111-1983 -- prohibits that."

statement of Suffolk County Executive Peter F. Cohalan Before the Gover-nor's Shoreham Commission, September 30, 1983, at 9 (attached hereto).

In addition, County Executive Cohalan stated that there is no other government in a position to respond and that the State government does not have a prompt response capabili-ty.

Id. at 10.

4.

Assuming arguendo that there could be some sort of ad hoc response by Suffolk County personnel to a Shoreham radiological emergency.

Such personnel would not have been trained how to respond to a radiological emergency at Shoreham.

Accordingly, it is my opinion, based on my experience in re-sponding to emergency situations, that their response would be inadequate and could not be counted on to provide effective preparedness.

5.

LILCO has asserted that under the LILCO Transition Plan, State and County personnel could communicate with LILCO and LERO using existing systems which are already installed.,.

LILCO and LERO have no dedicated emergency planning communications system link with County offices.

There is no plan and there are ru) procedures for Suffolk County personnel to communicate with LILCO or LERO using any communication sys-

' tem in the ' event of a radiological emergency at Shoreham.

6.

LILCO has stated that space exists at the Emergency Operations Facility, the Emergency Operations Center, and the Emergency News Center for use by State and County officials.

As noted by County Execucive Cohalan, the County could not im-plement a response to a Shoreham emergency and the State has no prompt response capability.

See Cohalan Statement attached hereto.

7.

LILCO has state'd that the Transition Plan provides for the incorporation of the County Executive or his designated representative in responding to an emergency should that offi-cial choose to participate.

As noted in the attached statement of County Executive Cohalan, "[t]he County could not implement a response to a Shoreham accident because County law -- partic-ularly Resolution Nos. 262-1982, 456-1982, and 111-1983 --

prohibits that."

8.

LILCO has stated that the LERO Director of Local Re-sponse is to take into account in making any protective action

~ - - - _.

,e-recommendations advice that may be received from local and State government officials.

As noted in the attached statement of County. Executive Cohalan, "[t] he County could not implement a response to a shoreham accident because County law -- partic-ularly Resolution Nos.- 262-1982, 456-1982, and 111-1983 --

prohibits that."

9.

LILCO has stated that its LERO traffic guides are

' trained to assist police should the police participate in an emergency.

LILCO also has asserted that the Transition Plan provides for the incorporation by traffic guides trained under the Plan of any police assistance that is offered during an emergency.

As noted in County Executive Cohalan's attached statement, the County could not respond.

Assuming arguendo that Suffolk County's police did participate in response to an emergency, they would not rely upon the assistance or advice of LERO traffic guides whom they consider inexperienced and who would be lacking in essential training.

Roberts, et al.,

ff.

Tr. 2260, at 39-44.

10.

LILCO also has asserted that traffic juides are trained te explain to the police the situation existing at the time of an emergency, to turn over posts for facilitating traf-

-fic to the police, and to remain as assistants if necessary in.

coordinating the evacuation ef fort.

To repeat, County law bars the County from implementing any response to a Shoreham emer-gency.

See Cohalan Statement attached hereto.

Assuming arguendo - that the police would respond to a Shoreham emergency, the police would not rely inexperienced and inadequately trained LERO traffic guides for assessment or other purposes.

11.

LILCO has asserted that if the State of New York and Suffolk County participate in an emergency response, the LERO organization will coordinate its activities with State and County officials.

The attached Cohalan statement states that the County could not implement a response and the State has no resources for a prompt' response.

See Cohalan Statement at 9-10.

12.

LILCO has asserted that it could implement an uncontrolled evacuation, using no traffic guides, signs, cones, channelization or other traffic. control devices, with an in-crease of evacuation times of less th'an one hour 35' minutes in normal conditions and one hour 55 minutes in inclement weather.

I disagree.

LER3 does not have the capacity to implement any kind of effective evacuation of the EPZ or portions thereof due to its lack of experience in emergency evacuation operations.

The evacuation time estimates proposed by LILCO are far too 1

I l

l low, being based on unrealistic assumptions, particularly i

- regarding the likely congestion on the limited Suf folk County 4

road network.

Pigozzi, ff. Tr. 2909 (entire testimony and es-pecially pages 37-39); Herr, ff. Tr. 2909, at 8-10; Polk, ff.

Tr. 2909,'at 3-17; Saegert, ff. Tr. 2259, at 8-10; Roberts, et al., f f. Tr. 2260, at 8 - conclusion; Hartgen, - et al., f f. Tr.

3695, at 5-19.

Fur ther, the County's witnesses have specifi-cally contested the accuracy of LILCO's so-called 1

" uncontrolled" time estimates.

Pigozzi, ff. Tr. 2909, at 37-38.

. 3.

In my opinion, for an " uncontrolled" evacuation to 3

have any potential to succeed, an emergency response organiza-tion would - need to have traf fic guides, tow trucks, etc. in place on evacuation routes during the evacuation effort so that they could respond to developing situations as the need arose.

- This was a concept of " uncontrolled" evacuation that the SCPD i

suggested during the County's planning effort.

Thus, the evac-

- uation effort would be closely supported by trained and capable-response personnel to assist evacuees if, for istance, severe congestion developed at a particular location.

LILCO's concept of an uncontrolled evacuation is drastically different and com-pletely inadequate since LERO would have no capability for any 4 response to the needs of the evacuating public when traffic congestion and 'similar events occurred during an emergency.

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1 14.

LILCO suggests that its evacuation time estimates, including those for an uncontrolled evacuation, are reasonable when compared to time estimates at other nuclear power plant sites and that they meet the accuracy standards of NUREG-0654.

With respect to the accuracy assertion, I dispute that LILCO's time estimates are accurate Herr, ff. Tr. 2909; Polk, ff.

2909; Pigozzi, ff. Tr. 2909; Roberts, et al.,

ff. Tr. 2260.

Given the inaccuracy of the LILCO estimates, there is no basis to coinpare these estimates with those at other nuclear power plants.

15.

LILCO asserts that the controlled evacuation plan used in the LILCO Transition Plan could be modified to elimi-nate traffic guidance completely, with a resulting increase in evacuation time estimates of about 1-1/2 hours.

I disagree.

If there were no traffic guides and if LILCO/LERO were in charge of the evacuation effort, it is my opinion that chaotic conditions would result.

This is because LILCO does not have the institutional capabilities or experience to implement an adequate response to a radiological emergency, and the public will realize this and will react accordingly.

If chaos resulted, the evacuation would take considerably longer.

Fur-ther, without having the capability and authority to institute traffic control methods, there would be no effective means to - -

respond to the chaos that would result.

This would mean that evacuees would be stranded in traffic and likely be exposed to health threatening radiation.

16. - In the event of an evacuation of all or portions of the EPZ, whether under controlled or uncontrolled conditions, LILCO would need to have the capability to institute effective traffic control measures in order to have adequate prepared-ness.

During the course of an emergency, there likely will be severe traffic congestion and also accidents.

Unless the capa-bility exists to deal effectively with such traffic contingencies, it is my opinion that no effective preparedness can exist.

17.

The evacuation shadow phenomenon is expected to re-sult in-a large number of voluntary evacuees in the event of a Shoreham emergency.

In order to cope with the traffic conges-tion caused by these evacuees (who will be in addition to the 100,000 - 150,000 evacuees from within the EPZ), there must be a capability to deal with the traffic control problems which are certain to ensue, including traf fic jams, traffic going the wrong way, and roadway impediments.

LILCO has inadequately considered the evacuation shadow phenomenon.

Polk, ff. Tr.

2909, at 7-10; Pigozzi, ff. Tr. 2909, at 45-49. -

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4 18.

An uncontrolled evacuation would not result in ade-quate response under the LILCO Plan.

An essential attribute of adequate preparedness to respond to a radiological emergency at Shoreham is the capability to implement rapid and effective ac-tions to assist persons attempting to leave the EPZ.

Such ca-pability is essential because the precise way an emergency may

' develop cannot be predicted in advance.

Thus, for example, if a serious traffic tie-up occurs, it is essential that there be a capability to assist in alleviation of the resulting conges-tion.

If LILCO lacks legal authority to implement the traf fic and security-related functions contested in Contentions 1-4, 9,

and 10, then there will exist no capability to take necessary actions to assist persons ordered to leave the EPZ.

f 19..

I have reviewed the LILCO emergency plan and conclude that LERO employees, chiefly the traffic guides, will in fact will be directing traffic..One does not have to " compel" or

" require" people to move in a particular direction in order to be directing traf fic.

The traffic guides, using hand signals and other directional devices, including parked vehicles blocking lanes, will be directing and attempting to affect the driving patterns of Suffolk County residents.

This constitutes traffic direction in my opinion.

See Tr. 3468-69 (Urbanik)

(traffic strategy to block lanes of the LIE with vehicles to.

create congestion upstream, to attempt to preclude congestion downstream).

20.

Under LILCO's plan, traf fic guides are to be stationed at key intersections to facilitate the movement of traffic by using hand and arm signals, traffic cones, parked vehicles and flashing lights and thus to discourage travel in certain directions.

LILCO has asserted that traffic will not be restricted from traveling in a particular direction.

Howev-er, in my experience as a police officer, the stationing of traffic guides using hand and arm signals and other devices (such as parked vehicles and flashing lights) will restrict traffic from traveling in particular directions and will con-stitute the direction of traffic, something which I, as a po-lice of ficer, do not believe LILCO is permitted to do.

21.

The LILCO assumption regarding the likely number of accidents during an evacuation is too low.

Herr, ff. Tr. 2909, at 39-41.

22.

LILCO has asserted that it will not force anyone to turn in a particular direction should they choose not to do so.

However, LILCO intends to convert a two mile stretch of at least one two-way road to a one-way road.

LILCO Transition Plan, Appendix A, Table XIII.

LILCO will also be using _ _ _. -

t channeling techniques and concurrent continuous flow treatment, methods of traffic control which will likely require drivers to go in particular directions.

Thus, LILCO traffic guides will be forcing persons to turn in a particular direction.

In addi-tion, under LILCO's Plan, LILCO traffic guides will use cones, hand signals, arm movements, parked vehicles and flashing lights to encourage the movement of traf fic out of the EPZ.

Such actions, taken by persons standing in or next to the road-way, will constitute the direction of traffic.

23.

LILCO has asserted that the controlled evacuation contemplated under the LILCO Plan results in an evacuation time estimate of four hours and 55 minutes for evacuation of the en-tire 10-mile EPZ in summer and good weather and six hours in inclement weather.

The time estimate is substantially inaccu-rate, for reasons that are described in the expert testimony of Suffolk County and New York State Department of Transportation witnesses.

ML20098G865

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