ML20107E327
| ML20107E327 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/19/1985 |
| From: | Roberts R SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20107E279 | List: |
| References | |
| OL-3, NUDOCS 8502250523 | |
| Download: ML20107E327 (13) | |
Text
'6 WIitMED 00RREN f;
,k, DOCKETEQ USNRC
'05 E8 22 A11 :46 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ISOCJCFSECRETriv
%d"!G ', sti g;'
Before the Atomic Safety and Licensing Board;^4hCn
)
-+--.._m"'""
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Shoreham Nuclear Power Station,
)
(Emergency Planning)
)
Unit 1)
)
DIRECT TESTIMONY OF DEPUTY CHIEF INSPECTOR RICHARD C. ROBERTS ON BEHALF OF SUFFOLK COUNTY REGARDING LILCO'S PROFFERED EVIDENCE OF JANUARY 11 Please state your name, occupation and professional Q.
background.
A.
My name is Richard C. Roberts.
I am a Deputy Chief Inspector assigned to the Office of the Chief of District, A statement of my cualifica-County of Suffolk Police Department.
tions and experience, as well as a description of the structure of the Suffolk County Police Department, was included in the testimony sponsored by me and other officers of the Suffolk County Police Department on behalf of Suffolk County regarding Contention (Evacuation Time Estimates), which was admitted into evidence 65 by the Board.
(Tr. 2260).
Q.
What is the purpose of this testimony.
The purpose of this testimony is to address LILCO's A.
proffered evidence of January 11, 1985 concerning its proposed PM "2288H M L T
]
b s use of the Nassau Veterans Memorial Coliseum ("Nassau Coliseum")
to monitor and decontaminate evacuees in the event of an emergency at the Shoreham plant.
s Are you familiar with the evidence proffered by LILCO?
Q.
I have reviewed LILCO's evidence and am familiar A.
Yes.
with its contents.
Among other things, LILCO's evidence reveals that the Nassau Coliseum is located in south-central Nassau County, approximately 43 miles from the Shoreham plant and 33 Accord-miles from the westernmost boundary of the 10-mile EPZ.
"all evacuees will be directed to go to the Coliseum" ing to LILCO, for monitoring and decontamination.
See letter dated October 23, 1984, from Matthew C. Cordaro, Vice President, Long Island Lighting Company, to Frank M. Rasbury, Executive Director, Nassau County Chapter, American Red Cross.
What is your opinion regarding LILCO's proposed use of Q.
the Nassau Coliseum?
Given the heavy traffic congestion which must be A.
expected during an emergency at Shoreham and the distance of the Nassau Coliseum from the Shoreham EPZ, evacuees would likely experience substantial delays in attempting to reach the Coliseum.
See geaerally Suffolk County's testimony regarding Contention 65 (Evacuation Time Estimates).
Indeed, in my opinion, LILCO's proposal to direct all evacuees to the Coliseum, an area where the roads are heavily congested even under normal, day-to-day conditions, would result in heavy traffic congestion not only within' the EPZ, but also between the EPZ and the Coliseum.
1
~..
Can you quantify the amount of time it is likely to take Q.
for evacuees to reach the Nassau Coliseum?
Previous testimony has addressed LILCO's time A.
Yes.
For estimates in Appendix A of the Plan for evacuating the EPZ.
the reasons set forth in Suffolk County's testimony regarding Contention 65, those times should be much higher than estimated I will focus just on the time required to reach by LILCO.
- Here, the Coliseum after the EPZ has been evacuated.
See generally NUREG 0654,Section II.J.12 (capability must exist to monitor evacuees within about a 12-hour period).
In my opinion, the excessive distance of the Nassau Coliseum from the EPZ, as well as the extremely congested traffic conditions that will exist as a result of evacuation of the popu-lation from both inside and outside the EPZ, will lead to sub-stantial delays for evacuees attempting to reach the Nassau Coliseum.
This is true whether they are travelling in their personal vehicles or in LILCO-operated buses.
In order to illustrate this point, the Suffolk County Police Department has compiled time / distance data for travel between LILCO's proposed bus transfer pointsb!
and the Nassau Coliseum.
1/
For an explanation of LILCO's bus transfer points and their functions, see generally Suffolk County's testi-mony on Contention 67 (Evacuation of Persons Without Access to Automobiles).
O.
18, 1985, the Suffolk During January 14 through January County Police Department assigned an officer to drive an unmarked police car between the LILCO bus transfer points and the Nassau from where The distance between each transfer point, Coliseum.
evacuees without access to automobiles or other private vehicles will be bussed to the Nassau Coliseum, and the Coliseum was recorded in both miles and required travel time.
Only the more major east-west roadways within Suffolk County were driven.2/
In Nassau County, the Meadowbrook State Parkway and/or Glen Cove Road were used to arrive at the Coliseum, which is located on Hempstead The results are listed in Attachment 1 to this testimony.
Turnpike.
It should be noted that all the data in Attachment 1 were obtained on weekdays between 9:30 a.m. and 3:00 p.m.
None was obtained during peak rush hour traffic or periods of inclement weather.
Data collected were obtained for actual travel between the bus Therefore, the transfer points and the Nassau Coliseum only.
listed times do not reflect the amount of time that would be for evacuees and their belongings to be required, for example, transferred from a bus bringing them to the transfer point and another bus taking them to the Coliseum.
The roadways driven were the following:
2/
NY Route 347 (Nesconset Highway)
NY Route 25 (Jericho Turnpike)
NY Route 495 (Long Island Expressway)
(Sunrise Highway)
NY Route 27 NY Route 27A (Montauk-Merrick Road)
Northern State Parkway Southrrn State Parkway.
The procedure utilized to gather the data set forth in,
i.e., driving from LILCO's bus transfer points to the Nassau Coliseum, was decided upon in order to have definite beginning and end points for the routes travelled.
Obviously, this would not be possible for all evacuation traffic, since persons with access to private vehicles would evacuate the EPZ and attempt to and indeed reach the Nassau Coliseum from locations throughout, However, while the results in Attach-beyond, the EPZ's boundaries.
ment 1 more specifically apply to the time required for LILCO-operated these data are also illustrative buses to travel to the Nassau Coliseum, of the time required for private vehicles to reach the same destination since, in many instances, LILCO's buses and private vehicles will be following the'same routes once the EPZ is Moreover, it is important to bear in mind that, since evacuated.1[
the data set forth in Attachment 1 do not reflect the heavy traffic congestion expected during a Shoreham emergency or inclement weather, they represent an unrealistically low minimum daytime travel time
. required between LILCO's transfer points and the Nassau Coliseum.
Actual' times during an emergency would obviously be much higher.
For example, the data on page 1 of Attachment 1 show it would take approximately 14 minutes for a bus to reach the l
intersection of Routes 112 and 25 from the transfer point at i
It should be noted t.
t buses, unlike passenger vehicles, 3/
- Thus, are prohibited from using the parkways on Long Island.
highways such as the Northern State Parkway and the Southern State Parkway would not be available to LILCO's buses, i
l
Brookhaven National Laboratory.
From that intersection, it would take at least another 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 18 minutes to reach the Nassau Coliseum, for a total travel time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 32 minutes.
Evacuees bussed from the Riverhead transfer point at NY Route 25 and Doctors Path would require as long as 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 54 minutes to reach the Coliseum (40 minutes to reach the intersection of NY Routes 112 and 27A and an additional 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 14 minutes to reach the Coliseum taking NY Route 27A to the Meadowbrook State Parkway and then the Hempstead Turnpike).
Similarly long travel times would be necessary for bussing evacuees from LILCO's In almost all instances, evacuees would be other transfer points.
(after having been bussed from required to travel an hour or more their homes to the transfer points), to reach the Coliseum.
What are the traffic conditions that evacuees are likely O.
to encounter enroute to the Nassau Coliseum?
Evacuees are likely to encounter heavy traffic congestion A.
on their way to the Coliseum.
The extent of the congestion will, of course, depend on the time of day and the routes chosen to reach the Coliseum.
With respect to buses, to my knowledge the LILCO Plan nowhere specifies the routes buses would drive from the transfer points to the Coliseum, and due to lack of discovery, I was unable to gain any information regarding LILCO's proposed Without such information, it is or designated bus routes.
impossible to predict precisely the traffic conditions that would be encountered by LILCO's buses from the transfer points to the Coliseum.
If, however, a Shoreham emergency were to occur during the morning rush hour, significant delays in travel times would be likely, irrespective of the routes selected by evacuees or by Traffic along all highways and most other LILCO for its buses.
routes leading west toward the Coliseum is heavily congested during~the morning rush hour (6:30 a.m. to 9:30 a.m.).
Traffic the Southern along the Long Island Expressway (NY Route 495),
State Parkway, the Northern State Parkway, Jericho Turnpike
('Y Route 25), NY Route 347 (Nesconset Highway), NY Route 27A N
'(Montauk-Merrick Road), and the Sunrise Highway (NY Route 27) is Therefore, evacuees attempting to frequently stopped altogether.
travel to the Nassau Coliseum would be significantly impacted, and substantial delays in reaching the Coliseam would be likely.
Certainly, during an emergency at Shoreham, actual travel times would likely be hours longer than the travel times reflected in.
Furthermore, even if an emergency at Shoreham were to occur at times other than when traffic is normally heavy i
(i.e., peak rush hour) traffic congestion both inside and out-side the EPZ would be caused by the mere declaration of an emer-for the reasons discussed in Suffolk County's gency at Shoreham, testimony regarding Contention 65 (Evacuation Time Estimates)
(Mobilization of Emergency Response Personnel).
and. Contention 27 l
[
t L
A Such congestion would raise travel times for all evacuees sub-stantially above the times reported in Attachment 1.A/
It is also important to note that neither LILCO's Plan nor its proffered evidence offers any indication that LILCO will such as traffic guides, fuel trucks, tow provide the means, to expedite traffic movement along the major routes trucks, etc.,
This lack of planning will certainly add to the Nassau Coliseum.
to the delays which will be encountered by evacuees attempting to reach the Coliseum.
See generally Suffolk County's testimony on Contention 66.
Another problem that will extend the time necessary to reach the Nassau Coliseum is the parking capacity of the Coliseum.
The parking capacity at that location is approximately 6,000 4
However, given the number of vehicles that would be vehicles.
directed to the Coliseum in the event of a full-scale Shoreham emergency and the need to keep space available for contaminated vehicles that would have to be decontaminated, it must be concluded that the Coliseum's parking capacity would be insufficient.
For the reasons stated above, I would expect traffic queues to form from the area of the Coliseum back toward the EPZ.
Based upon my experience and knowledge of the Nassau Coliseum Furthermore, with respect to LILCO's proposal to bus evacuees 4/
without access to automobiles to the Nassau Coliseum, it must be kept in mind that by the time evacuees could be bussed to LILCO's transfer points, traffic both inside and outside the EPZ would be heavily congested by evacuees travelling in See Suffolk County's testimony regarding personal vehicles.
Contention 65.
area roadways, which are heavily congested even under normal conditions,.I would expect such queues to be significant, possibly leading to congested traffic all the way from the EPZ to the Coliseum.
Q.
Does that conclude your testimony?
A.
Yes.
ATTACilMENT 1
TIME - MILEACE CHART _
ROUTE 112 WESTBOUND ACCESS POINTS TO:
ROUTE 112 ROUTE 112 ROUTE 112 ROUTE 112 s 495
& 27
& 27A FROM EPZ TRANSFER POINTS s 25 322
- 14
- 13
- 14 13.9 13.0 Brookhaven National Laboratory 9.9 8.4 1.
William Floyd Parkway
- 13
- 20
- 12 13.1 LILCO Brookhaven Substation 12.1 12.2 2.
Weeks Avenue, N/of L.I.E.
- 05
- 08
- 07
- 02 2.9 2.0 1.1 3.
LILCO North Patchogue 4.4 Substation Medford Avenue s Shaber Roadl7
- 06
- 03
- 10
- 15 3.3 4.2 6.4 Bellport Restaurant 9.7 N.
4.
Bellport Avenue & Route 27
- 07
- 08
- 14 5.1 6.0 Brookhaven Fire Department 9.1 5.
Route 27A & South Country Road
- 15
- 27
- 17 16.0 15.7 LILCO Eastport Substation 16.3 6
Route 27A & Eastport Manor Road CR 97 - Nichols Road Northern State GC Rd.- Glen Cove Road LEGEND:
- liempstead Turnpike Meadowbrook State
!!/T MSP actual times and distances from Route 112 & Greenport 1/
Approximate time / distance data; located approximately one mile from the North Patchogue Avenue in North Patchogue, Substation.
location for the LILCO has used the Brookhaven Fire Department in drills as a substitute Shoreham Shirley Mall, which LILCO expects will be the actual transfer point in aTime 2/
the times
~
emergency.
forth here are reasonable approximations.
and distances set
1 TIME - MILEAGE CHART ROUTE 112 WESTBOUND ACCESS POINTS TO:-
ROUTE 112 ROUTE.112 ROUTE 112 ROUTE 112 ROUTE 112
& 347
& 25 s 495 s 27 s 27A FROM EPE TRANSFER POINTS 1
i
- 05
- 10
- 15 7.
Shopping Center 3.4 5.3 8.6 Miller Place Road s 25 A
- 02w
- 08
- 11 f
8.
LILCO Property 0.6w 6.9 9.9 Norwood Avenue s 347
- 05
- 10
- 17 9.
Middle Island Shopping Center 3.3 6.6 9.7 Middle Island /Yaphank Rd. s 25 j
i
- 00
- 05
- 12 i
10.
Plaza Shopping Center 0.0 3.3 6.4 Route 112 s 25, Coram
- 30
- 22
- 28
- 40 i
11.
Warehouse - Riverhead 19.8 20.9 23.9 24.7 l
Doctors Path & 25 1
NORWOOD AVENUE LOCATION IS WEST OF ROUTE 112 ON ROUTE 347 I
495 VIA NICHOLL's ROAD (CR 97) l DISTANCE FROM NORWOOD TO ROUTES 25 &
1' i
i i
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i
_ - ~
TIME - MILEAGE CHART i
TIME MILEAGE TO NASSAU COLISEUM FROM 112 ROUTES
- 54 40.0 347 to NSP to MSP to H/T c.
Route 347 & 112 39.5 1:18 25 to Glen Cove Road to H/T b.
Route 25 & 112
- 52 41.5 495 to Glen Cove Road to if/T 41.5
- 49 c.
Route 495 & 112 495 to NSP to MSP to II/T
- 55 36.5 27 to MSP to H/T
- 40 35.2 d.
Route 27 & 112 27 to SSP to MSP to H/T 1:14 38.7 o.
Route 27A & 112 27 A to MSP to II/T 1: 00 37.6 27 A to 27 to MSP to ll/T
- 46 36.4 27 A to 27 to SSP to MSP to II/T i
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