ML20107E300

Testimony of Jh Johnson Re Lilco 850111 Proffered Evidence. Supporting Documentation Encl.Related Correspondence

ML20107E300
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/19/1985
From:	Jerrica Johnson CALIFORNIA, UNIV. OF, LOS ANGELES, CA, SUFFOLK COUNTY, NY
To:
Shared Package
ML20107E279	List: ML20107E277 ML20107E291 ML20107E300 ML20107E318 ML20107E327 ML20107E343 ML20107E352 ML20107E399
References
OL-3, NUDOCS 8502250506
Download: ML20107E300 (8)

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- ED UNITED STATES OF AMERICA

• NUCLEAR REGULATORY COMMISSION 46 Before the Atomic Safety and Licensing Board It b,ECR AA44chE WCl!

)

)

In the Matter of )

) Docket No ' '5 & 32.2-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Plannin'gP ' m

)

(Shoreham Nuclear Power Station, )

)

Unit 1)

)

DIRECT TESTIMONY OF JAMES H. JOHNSON, JR.

ON BEHALF OF SUFFOLK COUNTY REGARDING LILCO'S PROFFERED EVIDENCE OF JANUARY 11, 1985 Q. Please state your name and qualifications.

A. My name is James H. Johnson, Jr. I am an Assistant .

Professor of Geography at UCLA, and I specialize in the field of social geography. My professional qualifications are detailed in the' curriculum vitae.which is attached to my testimony regarding Contention 23.1! Briefly, I hold degrees in geography from North Carolina Central University ( B . S .', 1975), University of Wisconsin at Madison (M.S., 1977), and Michigan State University (Ph.D.,

1980). My current research concerns human responses to hazar'ds of technological origin, especially nuclear power plant accidents,.and I have authored or co-authored a number of articles'and reports on actual and intended evacuation. behavior Ein a radiological emergency.

1! . Direct Testimony of Donald J. Zeigler and James H. Johnson, Jr. on Behalf of Suffolk County Concerning Contention 23 (Evacua-tion Shadow Phenomenon), ff. Tr. 2789-(hereinafter, testimony

-regarding. Contention 23).

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4 Y Q.. What is the purpose of this testimony?

A.. LILCO has recently proposed using the Nassau Coliseum as a monitoring and decontamination center in the event of a-radiological emergency at Shoreham. The purpose of this testi-mony is to assess the appropriateness of LILCO's proposal on the basis of what is known about the behavior of people in nuclear reactor emergencies.

Q. Are you familiar with the evidence proffered by LILCO?

A. Yes. I have reviewed LILCO's evidence, including the

. January 10, 1985. Affidavit of Elaine D. Robinson; the letter

, dated September 25, 1984 from William J. Catacosinos, Chairman and Chief Executive Officer, Long Island Lighting Company, to

- E .' B . Sumerlin, Jr., General Manager, Nassau Veterans' Memorial

. Coliseum; the letter dated October _23, 1984 from Matthew C.

Cordaro, Vice President, Long Island Lighting Company? to Frank' M. Rasbury CExecutive Director of'the Nassau County Ch' apter.of-the'American Red Cross; and the map that is Attachment'4-to the

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Ro'binson Affidavit. Among other. things, the evidence proffered by LILCO reveals.that: ('l ) the Nassau Coliseum is located in Esouth-central.Nassau-County, approximate 1yL4'3'miies fr'om'the

Shoreham' plant and ' 3 3 : mil'es f rom the mile. EPZ 's westernmost, boundary (Robinson Affidavit,'t 5 and Att'achment 4); (2) LILCO's-

-use of the Coliseum will include "[pjerforming radiologica17moni-c toring'and decontamination,.if'necessary, inethe Coliseum and/or-surrounding. property.in.tne event of a radiological emergency at-r 5

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Shoreham. . . .

" (September 25 letter, at 1); and (3) "all

[Shoreham] evacuees will be directed to go to the Coliseum"

.(October 23 letter, at 2).

O. In your opinion, is the Nassau Coliseum an appropriate location for LILCO's monitoring and decontamination center?

A. No. As set forth in my testimony regarding Contention 2 3 ~, a. number of social surveys have been conducted on Long Island to determine how residents would respond to a Shoreham accident.

The results of these studies, conducted on behalf of LILCO, Suffolk County and Newsday, are explained in detail in my testi-mony regarding Contention 23. All the surveys indicate that in the event of a radiological emergency at Shoreham, large numbers of people from both inside and outside the Shoreham EPZ would The survey seek to evacuate, even though not advised to do so.

conducted for Suffolk County revealed, for example, that, depending on the perceived severity of the accident,' -between 25% ,

?(215,000 families) and 50% (430,000 families) of the households on Long Island would be likely'to' evacuate spontaneously, casting

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an " evacuation shadow" extending'more than 25 miles'beyond the plant. See testimony regarding Contention 23, ff. Tr. 2789, at

. 15-21.

In-my opinion, LILCO's proposal to use the.Nassau Coli-seum'as a-relocation / decontamination center >in the event of an emergency;at Shoreham is~1ikely to increase both the magnitude 1

and geographic extent of the evacuation shadow phenomenon.

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.s-Evacuees escaping any disaster attempt to find a place of refuge, that is " safe;"

be it a public shelter orja relative's home,

.i .e.,=that puts a reasonable amount of distance between them and the' disaster agent. NUREG 0654 recommends that such shelters be located about ten miles beyond the boundary of the EPZ. NUREG 0654,Section II.J.10.h. Indeed, some of the monitoring and decontamination centers which LILCO originally proposed were located less than five miles from the EPZ.

Now LILCO proposes to direct all evacuees to a location some 33 miles from the edge of the EPZ. October 23 letter, at'2.

. Establishing the place of-safe refuge so far from the origin of

.the danger -- the Shoreham plant -- is likely to increase in-the minds of the public'the degree-of the perceived danger.- For example, because people will be told to= seek refuge at a location more than 40 miles from the sourcelaf the emergency, there'will-be a perceplion among many people in the area between the_ plant; and-the refuge 1(i.e., the 0-40 mile region)'that that:Larea (or

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much of it) is unsafe, because;the safe refuge center'(the Nassau As Coliseum) is still-further from the source lof;the emergency.

was amply demonstrated by:alloof the Shoreham surveys, the<

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greater;the.public's perception of danger, the1 greater-the: extent-

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Thus,!it.-is very likelyLthat.LILCO's

of:the; evacuation shadow.

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proposal to.locatefits monitoring:and decontamination center so

[far.-from the EPZ will'increaseJtheinumbernof voluntary evacuees

.The'resulting.

' expected in the. event of;a Shoreham accident'.

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increase in evacuees attempting to use the limited cast-west roadway capacity available on Long Island will lead to even

. greater congestion than discussed in my testimony regarding Con-tention 23. Increased congestion will likely result in greater evacuation times (making the LILCO estimates which were the focus of Contentiono65 even more inaccurate than previously was urged) and long delays in reaching the Nassau Coliseum, thus delaying the monitoring and decontamination process for evacuees. See the testimony of_. Edward-P. Radford regarding this issue for the potential ~ health effects resulting from such de lays.

Q. Do-you have'any other, concerns about LILCO's proposal to use the Nassau Coliseum as a monitoring and decontamination

' center?

A. Yes. LILCO's proposal is likely to.cause a great' deal of-congestion around the Nassau Coliseum which would further, delay the arrival of evacuees at that location. .Asidepicted in

' Figure'l to this testimony, data'previously collected during the

- survey conducted on Suffolk County's behalf show that even before LLILCO proposed to use.the Coliseum as a. monitoring and'decontami--

nation center, between 25% and'50% of the population'in the

'communitiesJsurrounding-the facility. indicated that.they would

'- evacuate in the~ event 1offa general; emergency at-Shoreham requiring ~ evacuation of'the full'10-mile.EPZ. ;With.the Nassau l Coliseum ~nowfdesignated to host people whotmay be contaminated by-tradioactive materials, and with decontamination'taking place both d

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inside and outside the structure, / the number of people in the surrounding communities perceiving a threat to their health (and that of their families) is likely to increase, thus increasing Likewise, the area the number who will attempt to evacuate.

immediately surrounding the Coliseum is characterized by substantial commerical development, including a number of private Workers in these buildings are and government office buidings.

safe and will attempt also likely to sense that the area is not to leave the area -- in many cases using roads and crossing intersections over which evacuees attempting to reach the Coliseum will travel.

The outflow of Nassau County residents and workers and the influx of evaucees from-Suffolk County, processes which could very well: occur simultaneously, could create major traffic

-problems within the vicinity of the Coliseum. This would make it even more difficult for evacuees to reach the Coliseum, thus.

making.it less likely that LILCO could providefradiation moni-See NUREG 0654, toring and' decontamination in'a timely manner.

Section II.J.12.

Q. Will you'pleaseLsummarize your conclusions?-

'c A . In my opinion, LILCO's proposal to locate its monitor-ing and. decontamination center at the.Nassau Coliseum will result' Lin a~much greater evacuation shadow than contemplated in my test-imony regarding Contention 23, and will result also-in'the

/It is my understanding that contaminated automobiles will_-

need.to be parked and~ washed down outside of_the Coliseum.

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' evacuation of large numbers of residents and workers in the communities surrounding the Coliseum. Both consequences will lead to increased traffic congestion which, in turn, will delay the arrival of' evacuees at.the Coliseum to commence the monitoring and,'if necessary, decontamination process.

Q. Does that conclude your testimony?

A. Yes.

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)s pf RCf MT INilm TO EMM g 7s-100 % N i N si-7s% E LEGENO

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Figure 1: Percent Intending to Evacuate 4

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