ML20107M442
| ML20107M442 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/26/1985 |
| From: | Christman J LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-792 OL-3, NUDOCS 8503010274 | |
| Download: ML20107M442 (67) | |
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REATED CORRESPONDIiME w' ~.
LILCO, February 26, 1985 t ..
00CKETED i_ USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '85 cre 28 m 31
'~O QCF^Ecp m y Before the Atomic Safety and Licensing -Boafd' 'd' h' .
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In the Matter of )
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LONG ISLAND LIGHTING COMPANY ) DocketH4o, ,40,.322._p.L 3 ,
) (Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1)
LILCO'S RESPONSE TO INTERVENORS' PROFFERED TESTIMONY ON THE DESIGNATION OF NASSAU COLISEUM AS A RECEPTION CENTER Pursuant to the Board's January 28, 1985 Order granting LILCO's motion to reopen the record to identify Nassau Veterans Memorial Coliseum as the reception center for Shoreham, LILCO responds in this pleading 1/ to the testimony submitted by New York State and Suffolk County under cover letter dated February 19, 1985. For the reasons stated below, the Intervenors' tes- -
timor.y should not be admitted into the record, and does not es-tablish the need for further hearings on the adequacy of the Nassau Coliseum as a reception center.
If Attached to this Response is an unsigned Affidavit of John A.-Weismantle. Mr. Weismantle has reviewed it and will execute it today or tomorrow, after which an executed copy will be promptly served. Mr. Lieberman is likewise executing his affidavit today. LILCO apologizes for this procedure, made necessary by the logistic difficulties of getting documents between Richmond,. Washington, D.C., and Long Island.
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i I. THE INTERVENORS HAVE NOT ANSWERED THE BOARD'S THREE QUESTIONS In ths Board's January 28, 1985 Order granting LILCO's motion to reopen the record, the Board invited the parties to
" state specifically their positions concerning LILCO's evidence," as follows:
- 1) Do the parties question the authentici-ty of LILCO's documents? If so, set forth with particularity the reasons for such a challenge and the evidence such party intends to offer to chal-lenge the authenticity of the docu-ments.
- 2) If a party asserts a need to cross-examine LILCO's, witness on the sub-stance of the designation of the Nassau Veterans Memorial Coliseum as a relocation center, such party shall state the questions to be asked and the substance of what is expected to be proved by such interrogation.
- 3) If a party asserts a need to submit di-rect testimony or other evidence on the merits of LILCO's designation of the Coliseum as a relocation center, such party shall submit copies of all such documents and narrative testimony or an affidavit of any witness whose testimony is said to be necessary.
( The Intervenors February 19 filing does not address at all the question of the authenticity of LILCO's documents. The ques-tions to be asked on the substance of the expected responses was.not provided to LILCO so that LILCO could respond. And the testimony proffered by the_Intervenors in many instances does I
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I t not go to the merits of LILCO's designation of the Coliseum and in addition raises issues outside the limited purpose for which the Board reopened the record.
As to the Board's first question, the Intervenors' February 19 filing does not address the authenticity of LILCO's documents. LILCO assumes, then, that those documents are unchallenged. They therefore should be admitted into the record as proposed by LILCO on January 11, 1985.
As to the Board's second question, it appears from the cover letter accompanying the Intervenors' proffered testimony
.that Suffolk County and New York State have simply submitted to the Licensing Board cross-examination plans such as were used during previous hearings on emergency planning. This is not what appears to have been contemplated by the Board's January 28, 1985 Order, since the provision (on page 10 of the Order) for LILCO to respond to the other parties' submissions is, meaningless insofar as LILCO has not been provided those submissions. The submission of cross-examination plans only to tdue Board does not appear to LILCO to comply with the Board's Order and denies LILCO the opportunity to respond.
As to each piece of direct testimony, the evidence solicited by the Board in its January 28 Order was for the
. limited purpose of addressing "the merits of LILCO's
' designation of the Coliseum." In large measure the testimony
submitted by the Intervenors does not meet this criterion.
While Suffolk County represents in its cover letter that the testimony "is responsive to LILCO's proffered evidence of January 11 and is also withi,n the scope of the relocation cen-ter contentions previously admitted and litigated before the Board, i.e., Contentions 24.0, 24.P, 74, 75, and 77," February 19 letter from Suffolk County counsel at 2, n.3, the Intervenors' testimony in fact raises new issues outside the scope of the limited purpose for which the Board reopened the record. And the Intervenors have made no effort to meet the reopening standards or to raise new contentions. The testimo-ny, therefore, should be rejected.
Specific objections to each piece of testimony proffered by the Intervenors follow.
II. RESPONSES TO TESTIMONY A. Response to the Testimony of Leon Campo
'Suffolk County has not demonstrated that a public hearing is necessary due to Mr. Campo's testimony because (1) Mr.
Campo's testimony is outside the scope of the Board's limited inquiry concerning Nassau Veterans Memorial Coliseum an (2) taken as testimony on congregate care centers,2/ it is grossly 2/ Evacuees come first to the central " relocation center,"
where they are monitored by LERO and directed by the Red Cross (footnote continued) m
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. i out of time.
- 1. The Testimony Is Irrelevant To The Board's Present Inquiry In reopening the record, the Board is allowing the par-ties "to submit direct testimony or other evidence on the mer-its of LILCO's designation of the Coliseum," February 12 Board Order at 3. Mr. Campo's testimony provides no evidence.what e-
, 'ever on the merits of the use of the Nassau Veterans Memorial Coliseum as a reception center for Shoreham. Instead, Mr.
Campo's testimony is about congregate care centers, not the proposed reception center. Mr. Campo's testimony purports to
", respond to LILCO's proffered evidence of January 11, 1985,"
Campo Testimony at 1, by focusing on one phrase in a letter at-tached to LlLCO's January 11 submittal on the Nassau Coliseum, in which LILCO notes that Red Cross persont.el will " direct evacuees to congregate care centers operated by the Red Cross,"
Campo Testimony at 2. That letter describes briefly, for the purposes of the agreement between'the Red Cross and LILCO, the duties of the Red Cross during an emergency at Shoreham. It p (footnote continued) to " congregate care centers," where they are fed and housed.
The term " relocation center" was used when these two functions were combined in single facilities; it is a term best avoided now so as to prevent confusion.
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i does-.not provide a basis for reopening the entire relocation center issue for Shoreham.
- 2. The Testimony on Relocation Centers Is Untimely Mr. Campo's testimony discusses the previously litigated issues of the availability of East Meadow Union Free School District buildings to shelter Shoreham evacuees, and the mean-ing of the agreement between the school district and the Red Cross. Suffolk County has made no effort whatsoever to meet the reopening standard in. submitting this proffered testimony.
In fact, the testimony is grossly out of time.
While Mr. Campo states that he learned about the proposal by the Red Cross and LILCO "only recently," Campo Testimony at
.:2,.- the list of relocation centers used by the Nassau County Red
. Cross was provided to all' parties in July 1984, and copies of each individual agreement with those entities, one of which Mr.
Campo now seeks to enter.into the record, were provided to Suffolk County in August 1984. See Tr. 14,764-67. Thus, the information regarding the use of the East Meadow Union Free School District by the American Red Cross has been available lfor about seven months. Mr. Campo was a proffered witness in this proceeding as early as 1983, and so cannot argue that he was unaware of the issues surrounding the emergency plan at Shoreham.3/ No good cause has been established to show why,
'3/' -In fact LILCO deposed Mr. Campo in connection with his proffered testimony on January 5, 1984; his testimony was (footnote continued)
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seven months later, Mr. Campo's understanding of the meaning of the agreements and the alleged availability of his school dis-trict buildings should now be relitigated.
In addition, the issue of the availability of the buildings relied upon by the American Red Cross was litigated in August 1984 as part of the relocation center issues. Frank Rasbury, Director of the Nassau County Chapter of the American Red Cross, testified that the agreements with 'c he individual entities relied upon varied as to the wording of " natural di-easters," " disasters," or " emergencies," but that it was his understanding as a result of discussions and ongoing contacts with each of these entities that the buildings offered to the American Red Cross for use in a communitywide emergency are available for any kind of emergency, whether people are seeking shelter due to a hurricane, a chemical spill, the Grucci fire-works explosion, or any other calamity. Tr. 14,760-62, 14,771-72 (Rasbury); see Tr. 14,740 (Rasbury) ("We get people to make the facilities available to us on a broad spectrum, which includes the Shoreham circumstance, certainly, but is not limited to and is not specific only to.") While the agreements (footnote continued) entered into the record on January 25, 1984, ff. Tr. 3087, but he was unable to attend the hearings, and the County withdrew his testimony.
were provided to Suffolk County during the litigation of the i
relocation center issues, the Intervenors never sought to enter them into the record, or to present their own evidence re-garding the meaning of the agreements.4/ See Tr. 14,764-74.
Finally, Mr. Campo's testimony provides little in the way of probative evidence regarding relocation centers for Shoreham. While he testifies that in his view the school dis-trict agreement with the Red Cross does not provide assurance that buildings would be available, he does not assert that the East Meadow Union Free School District would refuse to shelter people in the event of an emergency.5/ On the contrary, Mr.
4/ LILCO's view then, as now, is that the individual agree-ments between the Red Cross and the relocation centers on which it relies are a level of detail that is unnecessary for this Board to scrutinize agreement by agreement. FEMA testified that LILCO's agreement with the Red Cross providing that the Red Cross will furnish relocation centers during an emergency at Shoreham is all that need be included in the LILCO Plan; while FEMA would like to have on file at its headquarters the individual agreements between the Red Cross and owners of buildings to be used as relocation centers, there is no need to include the individual agreements in the LILCO Plan. Tr.
14,611-13, 14,572-74, 14,611-15 (McIntire, Kowisski, Keller).
In addition, FEMA witnesses testified that, in their view, it is an accepted fact that the Red Cross provides relocation cen-ters and cares for people in an emergency. Tr. 12,989 (Keller). Suffolk County witnesses conceded that "it is (not]
inappropriate for LILCO to rely on the American Red Cross be-cause the American Red Cross has a good record in dealing with all sorts of natural disasters." Tr. 14,878 (Harris).
5/ Indeed, there is no good reason why a designated congre-gate care center would treat people needing shelter from a (footnote continued)
t Rasbury testified that, during the last major communitywide di-saster on Long Island (a hurricane), no agreements were in place and yet school districts and many others responded admirably to house the homeless. Cordaro, et al., ff. Tr.
14,707,-at 17; Tr. 14,815 (Rasbury). Mr. Rasbury explained that as an added measure of planning following the hurricane experience, the Red Cross sought agreements with various school districts, but that past experience showed people would respond whether or not agreements existed. Tr. 14,860 (Rasbury). He also testified that the agreements are updated periodically, that persons from his office are in contact with r,epresentatives of the various entities relied upon, and that, because no radiation monitoring or decontamination would take place at these buildings, he is treating the use of the build-ings for relocation centers for Shoreham as he would treat them for any other emergency. Tr. 14,774-80 (Rasbury). Thus, the (footnote continued) radiological disaster differently from people seeking shelter from a flood or hurricane, since the evacuees would be monitored, and decontaminated if necessary, elsewhere. The only bases for treating a Shoreham emergency as distinct are the political one, mentioned in paragraph 3 of Attachment 2 to Mr. Campo's testimony (which basis, as the record reflects, can be expected to evaporate when real people are in real need) and the misconception, which appears to be reflected in paragraph 4 of Attachment 2, that the congregate care centers would be used for monitoring and decontamination.
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record is clear that even without agreements, the Red Cross would provide shelter for those needing it during an emergen-cy.1/ Nothing in Mr. Campo's testimony sheds any light to the contrary.
In short, Mr. Campo's testimony does not address the des-ignation of'Nassau Coliseum as a reception center; good cause has not been established to reopen the record on congregate care centers; and even were reopening timely, which it is not, Mr. Campo's testimony presents no probative evidence that would i-further the record on this issue.
B. Response to Testimony of' James H. Johnson, Jr Dr. Johnson's testimony does not raise any issue that would require a public~ hearing on the adequacy of the Nassau Coliseum as a reception center.
First, Dr. Johnson states in his testimony that the location of the reception center from the Shoreham plant "is likely to increase in the minds of the public the degree of the perceived danger." - Johnson Testimony at 4. The Intervenors have known since last July that all. relocation centers and any
. g/ As the December 31, 1984, letter'from the Nassau County
' Executive to LILCO's Chairman shows, the Nassau County government would cooperate in making facilities available to
' t!. aid evacuees. This in itself provides substantial assurance that facilities would be available as needed.
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-reception center that might be established were to be in Nassau, not Suffolk County. See Cordaro, et al., ff. Tr.
14,707,- at 20-22. If the location of these centers from the source of the emergency is a generic concern to the Intervenors, they should have raised that concern last summer, either in connection with the congregate care centers, or with the then-undesignated reception center, because the County knew that those centers were to be in Nassau County, and the Nassau
- County border is 30 miles r om the Shoreham Nuclear Power Sta-tion. Thus, the argument, now raised in Dr. Johnson's testimo-ny,-that the " shadow phenomenon" will increase due to the loca-tion of the reception center is untimely.
In addition, the issue of the perceived distance from the source of danger as it affects emergency response was litigated at length in.this proceeding. See, e.g., Zeigler and Johnson, ff. Tr. 2789, at 3-4, 8-9, and Figures 1-4; Tr. 2866-67 (Cole);
Tr. 1994-99 (Dynes); Tr. 2878-79 (Zeigler). The issue of how public-perception is affected by emergency information was also litigated at length. See, e.g., Cordaro, et al., ff. Tr. 1470, at 26-41, 45; Tr. 2069 (Mileti); Zeigler and Johnson, et al.,
ff. Tr. 2789, at 35-38; Tr. 2884-85, 2892-93 (Johnson, J.);
Tr. 2888, 2891-92 (Zeigler). Consequently, Dr. Johnson is sim-ply rehashing old " shadow phenomenon" ground that this Board
' reviewed previously in six days of hearings, involving 18 witnesses and resulting in 826 pages of transcript.
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L To the extent that Dr. Johnson is being proffered by Suffolk County to assert his opinion that " 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," Johnson Testimony
- atL4,'his testimony is not probative because he has offered no basis for this assertion. Expert witnesses can give all kinds
-of opinions,.but their opinions are only as good as the basis upon which the opinions rest. As the Board said in Consumers Power Co. (Big Rock Point Plant). LBP-82-77, 16 NRC 1096, 1101 (1982):
While we accept Mr. Bement as.an honest and truthful witness, we are not persuaded when Mr. Bement offers overall assessments not accompanied by an explanation of his rea-sons.
See also Virginia Elec. & Power Co. (North Anna Power Station, Units 1 & 2), ALAB-555, 10 NRC 23, 26-27 (1979) (expert on the stand most have at hand enough underlying information to provide for reasonable probing of the ultimate opinions given).
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Dr.' Johnson has asserted no new evidence, literature, or-studies to support his-hypothesis that a reception center more than forty miles from the source of the emergency "is likely to increase in the minds of_the public the degree of the perceived danger."
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The record has already been developed regarding the appropriateness of having relocation and reception centers farther out from Shoreham than those originally designated in Suffolk County. FEMA witnesses testified that they were not troubled by reception centers farther away from nuclear plants, and consider the distance of these centers on a case-by-case basis. Tr. 14,575-77, 14,615-25 (Keller, Kowieski, McIntire).
In response to recent informal diocovery requests by Suffolk County, FEMA provided to Suffolk County a list of 34 licensed plants (attached to this Response) that have 442 reception and congregate care centers 30 to 40 miles and farther from the plant sites. This information is not included in the proffered testimony by Suffolk County.
In short, Dr. Johnson's thesis that reception and relocation centers in Nassau County are unacceptable under NUREG-0654 due to their distance is untimely. In addition, his testimony offers no probative information on that issue, and therefore should be rejected.
C. Response to the Testimony of Edward P. Radford The crux of Dr. Radford's testimony is that "the dose one receives during a radiological accident is a function not only of the " severity" of the release, i.e., the amount of radioactive materials released in an accident, but also of the
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time one is-exposed to such radioactive materials." Radford
- ' Testimony at 4. LILCO does not dispute this basic principle.
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' It was implicit in Dr. Radford's discussion on the record of health effects, see, e.g., Tr. 12,338 (Radford), and in LILCO's
- witnesses' discussion of dose assessment, see, e.g., Cordaro,
- et al., ff. Tr. 8760, at 30-40; Cordaro, et al., ff. Tr.
i 13,909, at 8. But Dr. Radford's testimony offers no data to i
support the assertion-that the result of this general principle is that the Nassau Coliseum cannot be used as a reception cen-ter.2/ Likewise. his hypothesis that it "may take many hours
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t-to reach,the coliseum and begin the monitoring and decontamination process," Radford Testimony at 4, is based on the' testimony of others (Roberts and Kilduff). He offers no
-evidence to bolster that opinion, and he is not a traffic ex-l
-pert qualified to give it. He offers no data in support of his hypothesis that use of the Nassau Coliseum may result in "an
- incremental increase in adverse health effects." Consequently, his testimony will not advance the record on the issue of the use of the Nassau Coliseum.
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Indeed, as we point out below in the response to Ms.
4 Meyland's testimony,.NUREG-0396 and NUREG-0654 do not contem-plate-that licensing boards will entertain detailed issues
. about how decontamination of the public will take place.
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The second point Dr. Radford raises in his testimony, beginning on page 5, is that LILCO may not be able to monitor and decontaminate the number of persons who may require it in an emergency at Shoreham. The issue of LILCO's monitoring and decontamination has already been litigated. See, e.g., 24-25; Cordaro, et al., ff. Tr. 14,707, at 15-16, 24-25; Tr.
14,712-714, 14,807, 14,825-30, 14,854 (Weismantle); Tr.
14,878-82, 14,888 (darris); see also LILCO Plan OPIP 3.9.2; Contention 77 (thyroid monitoring equipment). Mr. Radford's concern is untimely and should have been raised during the lit-igation of these issues previously. In addition, he gives no b, asis for his statement that LILCO cannot provide adequate mon-itoring and decontamination of the public. His testimony is untimely.
D. Response to the Testimony of Richard Roberts and Charles E. Kilduff Tha testimony of Deputy Chief Inspector Richard C.
Roberts and Charles E. Kilduff seeks to raise a spectrum of is-sues about alleged traffic problems resulting from the use of the Nassau Coliseum as a decontamination facility. Generally, this testimony does little more than talismanically recite themes that were litigated in the traffic-related contentions (Contentions 23, 65, 66, and 67). Accordingly, the testimony is untimely and does not justify a public hearing before this i
Board. In addition, no effort is made in either piece of tes-timony to identify any requirement in NUREG-0654 that dictates consideration and planning for traffic flow beyond the bound-aries of the 10-mile EPZ. Indeed, no such requirement exists.
This testimony represents but another attempt to expand planning boundaries beyond the lO-mile EPZ. This Board has refused to grant this request in the past, Special Prehearing Conference Order, at 8-l* (August 19, 1984) (order denied admission of contentions that had as their basis an expansion of the lO-mile emergency planning zone), and it should now do so again.
Briefly, Inspector Roberts' testimony focuses largely on.
alleged congestion and delays that will result in reaching the Nassau Coliseum (pages 3 to 8), In addition, he argues that no provision is made for traffic guides, fuel trucks, and tow trucks outside the EPZ along major routes to the Coliseum (page
- 8) and'that the Coliseum's parking capacity is insufficient to handle expected demand (page 8). Mr. Kilduff's testimony makes similar arguments, although packaged in the vernacular of ear-lier New York State witnesses.g/ Mr. Kilduff argues generally that congestion and delays will be encountered by evacuees g/ See, e.g.,- Direct Testimony of Dr. David T. Hartgen,
. Richard D. Albertin, Robert G. Knighton and Foster Beach on Contention 65, ff. Tr. 3695.
- attempting to reach the Coliseum. As bases for this argument, Mr. Kilduff cites limited roadway capacities impacted in part by " side' friction" (pages 3 to 6), intersection design defficiencies which have a propensity to increase accident rates (page 5), and future construction activities which may affect some routes to the Coliseum (pages 5 and 8). Of these factual assertions, only Inspector Roberts' claim about the ad-equacy of the parking facilities at the Nassau Coliseum is
. germane to the issues reopened on Contention 24.0, and as will be demonstrated below, this claim is factually meritless. The remaining issues are general concerns about traffic congestion, a,ccidents, construction,. and the effect of voluntary evacuation from areas outside the 10-mile EPZ that have already been liti-gated-in Contentions 23 and 65, and additional hearings are not
-required on these issues.9/
Even if accepted as germane tc Contention 24.0, these two pieces of testimony must fail for a' number of reasons. First, 9/ This response will not attempt to address in factual de-tail the myriad of traffic-related. issues raised in Inspector Roberts' and Mr. Kilduff's testir9ny concerning roadway condi-tions around the Nassau Coliseum. Suffice it to say that a study performed by a LILCO consu. tant showed that the Coliseum P parking lot and surrounding streets were clear of traffic with-in approximately 45 minutes following the end of a sold-out New York Islanders hockey game. Affidavit of Elaine D. Robinson at 3, attached to LILCO's January 11, 1985 Motion to Reopen Record.
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the vast majority of Inspector Roberts' and Mr. Kilduff's argu-ments are untimely. Concerns about traffic conditions on Long Island that would be encountered by evacuees traveling to relocation centers were never raised by either Suffolk County and New York State in earlier proceedings. Yet those issues are largely generic to any relocation center located on Long Island.10/ Thus, this testimony must be rejected as untimely.
Second, Intervenors have cited no basis in NUREG-0654 for the consider ation of traffic conditions outside the EPZ.
Indeed, Appendix 4 to NUREG-0654 only addresses traffic plan-ning within the lO-mile EPZ. The only NUREG-0654 guideline which even peripherally includes traffic conditions outside a 10-mile EPZ simply provides that:
. . . personnel and equipment available should be capable of monitoring within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period all residents and transients in the plume exposure EPZ arriv-ing at relocation centers.
NUREG-0654, II.J.12. Yet, even if one accepts the driving times contained in Inspector Roberts' testimony as accurate,11/
10/ For example, SUNY-Farmingdale, which was an earlier relo-cation center, is located about 13 miles from the Nassau Coli-seum. Claims about congestion on the Long Island Expressway and Northern States Parkway apply equally to SUNY Farmingdale.
In addition, it can hardly be claimed, and is not by Messrs.
Roberts or Kilduff, that the additional 13 miles to the Colise-um create unique problems which trigger the need for this testimony.
11/ While LILCO has doubts about the representativeneras of those travel times, LILCO will not burden the Board with a dis-(footnote continued) ,
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r the two-hour maximum driving time to the Coliseum comprises but a small percentage of the 12-hour monitoring time specified $c NUREG-0654, II.J.12, and indeed, Intervenors have not attempted to link travel times to the Coliseum with NUREG-0654 monitoring requirements.
Third, a majority of Inspector Roberts' and Mr. Kilduff's arguments are factually flawed because they proceed from an unsupported assumption -- namely that all EPZ evacuees will seek to travel to the reception center (Roberts, page 2; Kilduff, page 2). The capacity of relocation centers,'and hence, the number of evacuees expected to report to those f,acilities, was the subject of diccussion in Contention 75.
There, LILCO witnesses testified without refutation that no more than 20% of the population of 10-mile EPZ would seek shel-ter in relocation centers. See LILCO Proposed Findings, 1 529.
Intervenors' implicit attempt to relitigate this issue at this late date should not be permitted.
Finally, with regard to the one factual issue that 6
arguably relates to the Nassau Coliseum's suitability as a decontamination facility, Inspector Roberts merely asserts, (footnote continued) cussion of factual details that are irrelevant to the issues reopened by this Board.
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with little explanation, that the available parking facilities are inadequate (page 8). Again, this conclusion is premised on the faulty assumption that all EPZ residents will report to the Nassau Coliseum for decontamination. As the attached affidavit of Edward B. Lieberman clearly indicates, if correct assump-tions are made about the number of evacuees likely to use the Coliseum, then it must be concluded that sufficient parking ex-ists to accommodate that demand.
Thus, the testimony of Inspector Roberts and Mr. Kilduff fails to raise issues which justify a hearing before this Board, let alone a conclusion that the Nassau Coliseum is unsuitable as a decontamination facility.
E. Response to the Testimony of Langdon Marsh
- 1. The SEQRA Issue Is Not a Litigable Issue The testimony of Langdon Marsh (pages 3-9) asserts, in part,.that Nassau County has failed to prepare an environmental assessment, pursuant to ECL $ 8-0109(2) of the New York State Environmental Quality Review Act (SEQRA), for the use of the Nassau Coliseum as a relocation center. Mr. Marsh's testimony does not justify a public hearing before this Board, let alone a finding that LILCO's plan is inadequate. First, this testi-mony, like other pieces of Suffolk County's and New York
State's testimony, is untimely. The issue of compliance with SEQRA is the same at any facility designated as a relocation center, yet this issue was never raised before by Intervenors.
Second, Mr. Marsh's " testimony" is unsupported by the plain language of the statute and regulations on which it purports to rely. Finally, the issue of compliance with SEQRA is a matter for New York State agencies and state courts. It is unrelated to the question of whether NRC emergency regulations have been met.
- a. SEQRA Does Not Require Nassau County to Prepare an Environ-mental Assessment Mr. Marsh's testimony on Nassau Coliseum's compliance with SEQRA is essentially devoid of factual assertions. In-deed, the only arguable facts contained in that testimony are that Nassau County has not submitted a negative declaration t the New York State Department of Environmental Conservation (page 5) nor has it submitted a written statement based on a federal environmental impact statement (page 6). The remainder of Mr. Marsh's " testimony" is legal opinion that is not proper testimony and does not trigger the need for hearings before this Board.
Even if accepted as proper testimony, Mr. Marsh's analy-sis of SEQRA is legally flawed. Mr. Marsh's reasoning begins
.g' SN with'the threshold statement that SEQRA requires an environ-mental impact statement for any action that state agencies, including counties, " propose or approve which may have a sig-nificant effect on the environment" (page 3). What Mr. Marsh neglects ;is that certain actions are exempted from SEQRA. See 6 NYCRR ll 617.2(n); 617.13(a); 617.16. For those actions, no SEQRA findings are required. 6 NYCRR ll 617.13(a); 617.16(d).
Nassau County's approval of the use of the Nassau Colise-um as a decontamination facility is exempted from the SEQRA re-quirements on three grounds. First, the regulations exempt
" actions which are immediately necessary on a limited emergency ,
b, asis for the protection or preservation of life, health, prop-erty or natural resources." 6 NYCRR 5 617.2(n)(6). Defini-tionally, the Nassau Coliseum would only be used as a decontamination facility on a limited emergency basic. Hence, its use for this purpose is exempt from the requirements of SEQRA.
Second, the implementing regulations contain a list of
" Type II" governmental actions, 6 NYCRR 5 617.13, that have been generically " determined not to have a significant effect on the' environment" and "do not require environmental' impact statements'or any other determinationtor procedure" under the SEQRA regulations, 6 NYCRR $ (J7.13(a). These actions include
" minor temporary uses of land having negligible or no permanent l
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effect on the-' environment," 6 NYCRR $ 617.13(d)(19) -- a de-scription that clearly applies to-the use of the Nassau Colise-um as a relocation center.
Third, both the, state enabling statute (ECL 55 8-0111(1) .
and (2)).and the implementing regulations (6 NYCRR 5 617.16) recognize that if a federal EIS has been prepared, separate compliance with-the SEQRA is not required. .Mr. Marsh recognizes this exemption; however, he argues that the NRC's Shoreham EIS does not address the Shoreham evacuation plan and
-because of this omission, Nassau County needs to prepare a sep-arate environmental determination under SEQRA. This strained interpretation of the NRC's Shoreham EIS and New York State's e regulations is untenable. The Shoreham-EIS, like EIS's for' other nuclear power. plants, does nrt include the consideration of " Class 9" accidents that give rise to offsite radiation
-doses and hence,:the-need for emergency plans. .This omission
.is by no means an accident or oversight. Instead, Class 9 ac-cidents are-excluded because.they are too speculative and re-
! mote to require consideration in an EIS. Indeed, NRC's cate-gorical exclusion of these accidents has been upheld in Carolina Environmental Study Group v. U.S., 510 F.2d 796, 798-800 (D.C. Cir. 1975) and most recently in Deukmejian v.
NRC, :No. 81-2034 (D.C. Cir. Dec. 31, 1984) (CEQ worst case reg-g
.ulations do not require the supplementatic' of EIS's to include
- -r , r , w-, ,,-------r--- - w ,-en, .m .,rn- 4 ,- e4 -, - g - -- - , ,
f discussions of Class 9 accidents). Similarly, the SEQBA regu-lations only require the consideration of "environmenta. im-pacts which can be reasonably anticipated," 6 NYCRR $ 617.14(c)
-- a standard which is identical to the " reasonably fore-seeable" standard used by.the D.C. Circuit to judge, and ap-prove, the-EIS's in Carolina Environmental Study Group and Deukmejian. Thus, the NRC's EIS for Shoreham encompasses the environmental effects of accidents that would give rise to offsite emergency response; a separate Nassua County assessment of the use of the-Nassau Coliseum as a decontamination facility is unnecessary and not required by law.
- b. Compliance with SEQRA Is Not-an Issue.Within the Purview of This Board Even if' compliance with SEQRA were required, it would be solely a matter for New York State agencies to pursue.
Compliance with the SEQRA is not a matter cognizable within
-this licensing proceeding. No NRC regulation and no guideline in NUREG-0654 requires'an applicant to demonstrate that a relo-cation center has complied with.all state laws and local ordi-nances. Indeed, compliance with SEQRA is a matter of form rather than substance. Like the National Environmental Policy Act, SEQRA does not require environmental impacts to.be given determinative effect. 6 NYCRR 5 617.1(d). Thus, SEQRA is a
procedural statute which requires the disclosure of environmental effects; discussion of compliance with that stat-ute serves no purpose in an NRC licensing proceeding.
Moreover, New York State's actions indicate that their primary interest in this issue is to delay further a decision in the emergency planning proceedings. New York courts clearly have authority to review Nassau County's alleged noncompliance with SEQRA. Typically, review of a governmental agency's compliance with SEQRA is subject to a four-month period of lim-itations. CPLR 5 217; see also Ecology Action v. Van Cort, 417 N.Y.S. 2d 165, 169 (Sup. Ct. 1979). This four-month period runs from the time of the final permitting action by the appro-priate governmental body. -See Town of Yorktown v. N.Y.S. Dept.
of Mental Hygiene, 459 N.Y.S.2d 891, 892 (App. Div.) aff'd 466 N.Y.S.2d. 965, 453 N.E.2d 1254 (N.Y. 1983). Here, Nassau County approved the use of the Nassau Coliseum as a decontamination facility on October 1, 1984. More than four months have passed since that event, yet New York State has never sought review of Nassau County's alleged non-compliance with SEQRA in state courts. Such an action is now time barred. New York State's attempt to avoid this time bar by raising the issue of compli-ance with SEQRA before this Board should not be permitted.
l
(( ..
- 2. The Issue of an SPDES Permit Is Not Properly Before this Board
.Pages'9-lO of Mr. Marsh's testimony,-like the whole of Ms.,Meyland's (see below), attempts to raise a new issue about
. water pollution. In particular, Mr. Marsh raises the purely
-legal issue of whether the Coliseum must get a New York State
-permit (SPDES permit) to discharge the wash water after people k and vehicles have been decontaminated.
Assuming, for-the purpose of this Response, that Mr.
- Marsh is correct-that 1an SPDES permit is required by state law, there are two reasons why Mr. Marsh's testimony at pages'9-10
.does notujustify:the need for a public hearing, let alone a finding that LILCO's plan is inadequate. The two reasons are (1) that this issue would be precisely the same for any reloca--
. tion center. designated'by LILCO, and yet the.Intervenors did not raise it for any of the.previously designated relocation
= centers, _and'(2) that this is a ma'ter c to be pursued exclusive-s ly-by New, York State agencies and has' absolutely nothing to do with~ meeting NRC emergency planning regulations.
~
- a. The Issue of an SPDES Permit Is Untimely First, LILCO hasi in the past designated a number of other relocation centers before finally settling.on the-Nassau Coli-seum. In particular, the following were the relocation centers
.-named'in Revisions 0-3 of the LILCO Plan:
m____ _-_._._._._.m
c .
, Suffolk County Community College (primary)
SUNY-Stony Brook (primary)
BOCES Islip Occupational Center (primary)
SUNY-Farmingdale (secondary)
Saint Joseph's College (Patchogue) (secondary)
In all.the many. months that these other relocation centers were designated, the Intervenors never made the slightest mention of SPDES permits. Clearly this issue is not raised by any of the existing contentions; the only contention about monitoring and decontamination at the relocation center is Contention 77, which simply challenges the choice of the instrument used for monitoring. And if the Intervenors are now proposing to raise a new contention, they have failed to meet or even to address the standards for admitting late-filed contentiens.
In short, the issue of a state water discharge' permit'for the monitoring and decontamination site is one that could --
and should -- have been raised before, if the Intervenors wanted to raise it. It is not an issue raised by the designation of Nassau Coliseum, because it would be the same issue'no-matter where the reception center were located,
- b. The SPDES Permit is a Matter Entirely Outside NRC Regulations Second, assuming an SPDES permit is required, it is entirely a matter for New York State agencies to pursue, if they think it important. The issue of whether a permit is required, whether it must be applied for now or at the time of
.. _ _ _ _ _ _ _ _____. ._ 1
, .X
" s an accident, and what its terms ought to be are all matters of state law.12/
By the same token, the issue of the SPDES permit is not a matter cognizable within this NRC licensing proceeding. There
'is no NRC regulation and no guideline in NUREG-0654 that re-quires an applicant to show that the relocatien center has complied with all state laws, local ordinances, etc.13/ And there is no other reason for the Board to engage questions of state law. As another licensing board observed in a similar
' situation:
- 22. Intervenors raise as an issue whether the Office of the Governor is le-gally empowered to exercise the command and control responsibilities assigned to it under the South Carolina plan. In effect Intervenors are requesting us to legally interpret the State Constitution and a South Carolina statute to determine if the 12/ Indeed, the testimony invites the Board to rule on such matters of state law as whether runoff from a parking lot is an
" outlet or point source" within the meaning of ECL 5 17-0803 and'l 17-0105. LILCO believes that no relocation center for any other nuclear plant in New York State has been required to apply for an SPDES permit (see the Affidavit of John A.
Weismantle, attached to this Response), and this throws substantial doubt on Mr. Marsh's interpretation of the law.
While the question of whether or not an SPDES permit is required is largely or entirely a legal one and might well be resolved by summary disposition, there is simply no reason under NRC regulations for the Board to engage it at all.
13/ There is also no suggestion in Mr. Marsh's testimony that the existence or nonexistence of an SPDES permit would materi-ally affect the public health and safety. That point is raised by Ms. Meyland's testimony, which we deal with below.
s Office of the Governor is acting lawfully.
That is not our function nor is it neces-sary for deciding the emergency planning issue at hand.Section II.A.2.b. of NUREG-0654 only requires that the plan contain, by reference to specific acts, codes or statutes, the legal basis for such authori-ties. No legal interpretations by this Commission are called for. There.is a pre-sumption that State officials are carrying out their duties in a proper and lawful manner. If Intervenors question that, they should seek a more appropriate forum than this licensing proceeding. We conclude on the record before~us that the Office of the Governor can exercise the command and con-trol responsibilities assigned to it under the South Carolina plan.
Duke Power Co. (Catawba Nuclear Station, Units 1 & 2), LBP 37, 20 NRC 933, 967-68 '(1984).
In short, the Marsh testimony is deficient both because it is outside existing contentions (and because a new contention has not been proffered or justified) and because it is outside NRC regulations. Either would be sufficient reason for paying it no further attention.
F. Response to Testimony of Sarah J. Meyland The testimony of Sarah J. Meyland is a nonspecific, nonquantitative catalog of fears about how contaminated wash
-water from decontaminating cars or people might " conceivably" (page 8) find its way into the drinking water on Long Island.
(She adds, at page 10 of her testimony, that "the impact of ra-diologically contaminated urine and feces from evacuees should
not be overlooked," because the radiation might interfere with the bacteria necessary for sewage treatment.) Ms. Meyland's testimony does not require a public hearing, or show a defi-ciency in LILCO's Plan, for three reasons:
(1) The testimony-is untimely; it raises an issue that could have been raised with respect to other reloca-tion centers designated earlier, all of which are over the'same aquifer, and three of which are in pri-mary recharge areas for the aquifer.
(2) The testimony raises essentially an issue about moni-
'toring water supplies after a radiological accident that should have been raised when the 50-mile EPZ issues were still open for litigation; alternatively i
it is an issue addressing only one of the environ-mental impacts of a serious-radiological accident, and the environmental impacts of Class 9 accidents are not litigable for the reasons set out above in the discussion of Mr. Marsh's testimony.
(3)~The testimony raises an issue that are outside the scope of this proceeding, because-NRC regulations and
. guidelines require no particular decontamination mea-sures for the general public, and, indeed, NUREG-0396
provides that extraordinary measures need not be taken.
.1. The Issues Raised are Untimely The issue of discharge of wash water from the decontam-ination facility could have been raised long ago, when relocation centers were first designated in the plan. Clearly the same issue could have been raised with respect to those other, earlier relocation centers. As Ms. Meyland's testimony indicates (page 3), there is a single principal aquifer for all of Long Island. Moreover, as the attached Affidavit of John A.
Weismantle indicates, three of the relocation centers original-ly designated by LILCO are located in primary recharge areas for this aquifer. Yet this issue is not included in any of thu
. existing contentions, and the Intervenors have not attempted to meet the standards for submitting late contentions. It is tharefore improperly raised at this time.
- 2. The Issue Was Litigated in the 50-Mile EPZ Contentions It is obvious that if there were an accident at Shoreham
- severe enough to contaminate members of the general public so that they had to be decontami~nated, radioactive material would be spread over the ground, trees, buildings, etc. of some por-tion of the EPZ. This material would be washed into streams, r . .
,, _ _ _ _ _ m ____m_ -
L
' . rivers, storm drains, and ultimately the groundwater during the first rain after the accident. And it is equally obvious that the amount of radiation in the wash water used for decontamina-tion would be small compared to the contamination that would be spread generally over the landscape.
These indisputable facts raise two objections to the Meyland testimony. In the first place, the testimony is essen-tially a complaint about a portion of the environmental impact of a serious radiological accident. It has nothing to do with the emergency planning regulations, and, as noted above, the environmental impacts of Class 9 accidents are not litigated in NRC proceedings. In the second place, the concerns expressed in the Meyland testimony were already addressed in the litiga-tion of the contentions about the 50-mile ingestion pathway EPZ. The contamination of water, food, and land by the radia-tion from an accident is dealt with in the planning for the 50-mile EPZ, and the issue of decontamination wash water should have been raised under the contentions that the Intervenors submitted on the 50-mile EPZ. See Contentions 81, 85, and 88.14/
14/ In particular, Ms. Meyland's concern about contaminated feces and urine (page 10) is off base. The purpose of planning for the 50-mile EPZ is to prevent people from ingesting radio-active materials, and it is unlikely evacuees would ingest ra-dioactivity before they got to the Coliseum.
i
. o .
Since Contention 81.C very specifically raises the issue of how wash water from washing contaminated fruits and
. vegetables is to be disposed of, it is quite evident that the Intervenors thought of decontaminating foodstuffs but failed to think of decontaminating people and cars. Indeed, concerns of the type expressed in Ms. Meyland's testimony were addressed in LILCO's testir.ony. For example:
Contaminated fruits and vegetables may be washed or scrubbed in an ordinary kitchen sink. Radioactive particulates that are washed down the drain would be so diluted by the water purification process as not to pose a potential public health problem.
The average American household, for exam-ple, uses 50-100 gallons of water per day.
Washing fruits and vegetables to eliminate radioactive contamination is no different from washing them to remove other toxic residues. In both cases, the contamination is significantly diluted by the wash water, which is further diluted by sewer water or septic systems. By the same token, peelings and other residue should be dis-posed of as any other garbage would, in a trash receptacle or other container. In short, there is no need for the Plan to have specific procedures governing the dis-posal of radioactive wash we.ter and resi-due.
Cordaro, et al., ff. Tr. 13,563, at 21-22. Similarly, Contention 81.D.1 is premised on the as-sumption that the greater portion of the drinking water supply for residents of the 50-mile EPZ would be susceptible to radioactive contamination in the event of an accident. This premise is faulty.
L
, ,c-Wells provide the only-source of drinking water for residents of Nassau and Suffolk Counties. Because of the natural fil* ration process that occurs when surface water enters the aquifer, it is extremely unlikely that a release of radioactive ma-terial from a nuclear plant would cause the contamination of well water supplies.
Therefore, it is highly unlikely that resi-doncs of Nassau and Suffolk Counties (which represent approximately 80% of the New York portion of the 50-mile EPZ) would ever be in need of " alternative drinking water sup-plies."
Id. 26-27. This same testimony goes on to describe the
- monitoring of. wells'that would be done in the aftermath of an accident.at Shoreham. In short, there is no excuse for the Intervenors not having presented Ms. Meyland's testimony
. e'arlier.
- 3. The Testimony is Irrelevant to NRC Regulations Finally, Ms. Meyland's testimony is irrelevant to the
- meaning of NRC regulations and even the guidelines of NUREG-0654,.for the following reason. The emergency planning regula-tions do not require particular provisions for decontaminating the general public. NUREG-0654 Standard K provides for
- decontamination of " emergency personnel wounds, supplies, in-struments and equipment" (K.S.6) and " relocated onsite person-nel" (K.7). Criterion J.12 provides for registering and "moni-toring" (but not decontaminating) evacuees at relocation
.y ..y
' centers. .More telling still, NUREG-0396 at page 14 provides
- that no'special decontamination provisions for the general pub-
~11c need.be providedi The_EPZ g.idance does not change the-requirements for emergency planning, it
'only sets bounds on the planning problem.
The Task Force does not recommend.that mas-sive emergency preparedness programs be
. established around all nuclear power sta-tions. 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)
, '(Emphasis in original.) This is why licensing boards have not required specific decontamination materials, methods, sched-ules, etc. for the public. For example, in Shearon Harris 1 &
2, the licensing board refused to admit a contention insofar as it questioned the availability of materials for evacuee decontamination:
The ERPs do not give, and are.not called upon by regulation.or guidance'to give, an
-accounting of materials available for evacuee decontamination. Indeed, neither regulations nor guidance even mention (sic]
evacuee decontamination. Rather, NUREG-0654 focuses on providing for decontamination of emergency workers, who
.would be likely to face greater contamina-tion dangers.than evacuees would. See the evaluation criteria under $ II.K in NUREG-0654.
+
~' ' ' '
Therefore Contention 240 is admitted, but oniv on the following questions: (1)
What agency of Chatham County government is responsible for the uecontamination of
. evacuees at the Chatham County Shelters?
and.(2) Which' emergency response organiza-tions are assigned the responsibility of providing support for the decontamination of evecuees? Perhaps all that is-needed to answer these questions is authoritative clarification of the relevant sections of
~the ERPs.
Carc11na Power & Light Co. (Shearon Harris Nuclear Power Plant, Units 1 & 2), LBP-84-29B, 20 NRC 389, 397, 398 (1984). Another board considered disposal of wash water, but the opinion does not reveal whether this was limited to emergency workers and their' equipment or whether it covered the public as well. In any event,.the Board did not require particular methods.for disposing of wash water:
Contention 19(kk) alleges that the County Plan is deficient because it d es not provide for disposal of contaminated equipment, vehicles, deconcaminated [ sic]
water, or any other materials that might be contaminated.
- 84. Vehicles can be decontaminated by washing. Water would be released but is not'likely to be a public health or safety problem -- personal health and safety of evacuees would be the initial con-cern. . . . The State would, however, mon-itor the disposal of decontamination water
'in the host counties.
Kansas Gas & Elec. Co. (Wolf Creek Generating Station, Unit 1), ,
LBP-84-26, 20 NRC 53, 79, 111 (1984).
o l This view -- that wash _ water is not likely to be a public health or safety problem -- is consistent with the view of the Director of the New York State Radiological Emergency Prepared-ness Group. As he points out in the two letters attached to this Response, decontamination waste water would be so diluted that it would not be a problem. This is consistent also with LILCO's testimony on Contention 81, quoted above. In short, there are no NRC requirements or guidelines about how decontamination for members of the puolic should take place, and so the details of how LILCO will make such provisions are outside the scope ,f the regulations and outside the scope of this proceeding. To the extent that Ms. Meyland's testimony raises any issue recognizable by this Board, it is an issue, as noted above, that should have been raised in the context of planning for the 50-mile EPZ and is now untimely.
- 4. Specific Parts of the Testimony Would
, Be Irrelevant Even if the Testimony as a Whole Were Admissible In addition to the objections to Ms. Meyland's testimony set out above, two portions of the testimony are irrelevant
( even to the thesis that the testimony attempts to establish, i
To be specific, (1) lines 16-27 on page 7, which say that the aquifer is alreaay stressed by toxic chemical pollution, and (2) lines 15-26 on page 9, which say that too much water is
(.
t
- i. .-.o f- presently being drawn from the aquifer, are irrelevant. Their purpose seems to be to,show that the water supply is already in bad condition (and radiological contamination would make it even worse). But this is entirely irrelevant to the, issue of the impact on the water supply of an accident at Shoreham.
III. CONCLUSION For the foregoing reasons, LILCO submits that the i
testimony submitted by the Intervenors should not be admitted because it is untimely, outside the scope of the very narrow issue on which the record has been reopened, or not relevant to or probative of the issue whether NRC regulations are met.
s.
Likewise no public hearing on the testimony should be held.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY BY .
~
? r-*
ames N. Chkistman ee B. Zeugin Kathy E. B. McCleskey Hunton & Williams
. P.O. Box 1535
-/l 707 East Main Street Richmond, VA 23219 DATED: February 26, 1985
r- _,.
- v. "*
LILCO, Februcry 26, 1985 e . . . . .
gqgg~ Attachment 1 UNITED STATES OF AMERICA 0) f" '
NUCLEAR REGULATORY COMMISSION C77'CE CF SECRETARY 3%KETING & SERVICE 3 RANCH Before the Atomic Safety and Licensino Board t
In the Matter of )
,._m.... .
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning (Shoreham Nuclear. Power Station, ) Proceeding)
Unit 1) )
AFFIDAVIT OF JOHN A. WEISMANTLE My name ie Tsun A. Weismantle. I am Manager of the Local, Emergency Response Implementing Organization.
- 1. Based on discussions with planners involved in radiological emergency planning for the operating nuclear plants in New York State (Indian Point, FitzPatrick, Nine Mile Point, and Ginna), LERIO believes (1) that no monitoring and decontamination center designated in the emergency plans for any of those facilities has been required to apply for an SPDES permit and (2) that no such center has been the subject of a
. state environmental impact statement under the State Environ-
- mental Quality Review Act.
- 2. In order to protect Long Island's groundwater resources, a study entitled "The Long Island Comprehensive Waste Treatment Management Plan" (or "the 208 Study"), was com-pleted by the Long Island Regional Planning Board under Section I
(. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - -
c
'208 of the Clean Water Act Amendments of 1972. The 208 Study divides Long Island into eight hydrogeologic zones and makes specific recommendations pertaining to each zone. The 208 Study identified deep flow recharge areas on~Long Island as consisting of hydrogeologic zones I, II, and III. -
- 3. According to the 208 Study, Suffolk County Community College (Zone III), SUNY - Stony Brook (Zone I), and SUNY - Farmingdale (Zone II) are located in the primary groundwater recharge areas for Long Island, as shown on the map of hydrogeologic zones in the Nassau-Suffolk 208 Study Area
-(Figure 3-2 on page 45 of the 208 Study).
l John A. Weismantle subscribed and sworn to before me this day of
, 1985.
My commission expires: .
Notary Public l
e LI'UCO , Fcbruary 26, 1985 (If,PfC ' Attachment 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSId 3
- 28 Allil2 Before the Atomic Safety and Licensing B5ardH T . $$
In the Matter of )
) .
LONG ISLAND LIGHTING COMPANY ) Docket No*."~50'322-OL'-3 '
) (Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1) )
AFFIDAVIT OF EDWARD B. LIEBERMAN ON NASSAU COLISEUM
- 1. My name is Edward B. Lieberman. My professional qualifications are at Tab 10 after page 4068 o' the hearing transcript in this proceeding.
- 2. I have performed a variety of activities for LILCO relating to the traffic portions of the LILCO Transition Plan.
As part of those efforts, I have surveyed the available parking facilities accessible to the Nassau Coliseum.
- 3. The results of my survey are described in the three-page letter which is attached to this affidavit. Briefly, I have concluded that the Coliseum perking facilities are adequate to accommodate the expected peak demand from an evacuation of the entire Shoreham EPA. In addition, nearby parking areas provide additional capacity should an unexpected surge in traffic demand occur.
Subscribed and sworn to before me this day of February 1985.
My commission expires: __
Notary Public
KLD ASSOCIATES INCOMPORATED 300 Broadway Huntington Staten 'd 11746 (516) 54S'A03 July 24, 1984 Mr. John Weismantle LILCO 100 E. Old Country Road Hicksville, NY 11801 Dear Johns
, On July 20, 1984, I undertook an on-site survey of the available parking facilities accessible to the Nassau County Veterans Memorial Coliseum.
There are three major parking facilities:
e On-site e Hofstra University Campus e Nassau County Community College Campus l The on-site parking is partitioned into several fields,
! separated by access roads or curbed medians. The aggregate l number of parking slots, as counted during this survey, was
- estimated at 6900.
l The Hofstra site is to the west, across Earle Ovington Blvd. There are several large paved areas at the eastern edge of this site (closest to the Coliseum) which are not presently delineated for parking. (This pavement was originally used for flight operations.) I estimate a total parking capacity of 1300 vehicles on the paved areas. There are also grassy l areas at grade (i.e. no curbs) which could accomnodate some l 600 vehicles, weather permitting.
l l The Nassau County Community College (NCCC) campus to the north of the Coliseum, has a large parking field at its southern edge (closest to the Coliseum). This parking field, which is behind (i.e. south of) the College Union building can accommodate approximately 1800 vehicles.
7/24/84 Pcg3 2 l -
Mr. John Weismantle 1
Both the Hofstra and NCCC parking areas are within one-half mile of the Coliseum building and are accessible to the Coliseum l
property via paved roads and paths. Thus, the total number of f
vehicles that can be accommodated at any time is approximately:
i i i 6900 + 1300 + 1800 = 10,000 i
Estimate of Parking Demag l i
l This estimate addresses the worst-case scenario wherein the entire EPE must be evacuated during the summer. We will adopt l the assusption that 20 percent of all evacuating vehicles will travel to this coliseum. Thus, the total demand will approximates t
i i
I 0.2 x 53000 = 10,600 vehicles i
- The arrival rate must be estimated. It is well-known that '
traffic exhibits a natural tendency to disperse as it travels l
over a system of highways. Thus, if these vehicles leave the i
EPS over a period of 4.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, then they can be expected to J arrive in the neighborhood of the Coliseum over a period of l
j say, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, after travelling a distance of.some 45 miles.
The average arrival rate will then be approximately: ,
10,600 + 6 = 1770 vehicles per hour l i i
! The departure rate must be estimated. This departure rate i
depends on the rate at which people are processed and then assigned to a nearby shelter.
I At this time, we have not developed the detailed procedures l
l for processing these people. If we assume that all people will be processed in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, then the departure rate will approximate 880 vehicles per hour. If we assume a one-hour time lag, then l
- the maximum number of vehicles requiring parking at a point'in ,
i time that occurs at the end of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, is: I 1
I d
1770 + (1770 - 880) x 5 = 6220 vehicles It thus appears that the Coliseum parking facilities are ;
adequate to accommodate this peak demand (6220 < 6900). The ,
adjoining parking areas can be used to accommodate surges in demand. In all, the estimated peak demand for parking is less than two-thirds the available capacity.* .-
- NCCC has an additional 3800 parking slots available which are within one mile from the Coliseum. Hofstra University has ad- The ditional parking capacity within one mile of the Coliseum.
Marriott Motel, to the immediate east of the Coliseum property, l can probably provide about 100-200 parking areas.
7/24/84 Pcg3 3 Mr. Jchn Waicmantio Accessibility The Coliseum parking areas are accessible from the east via Meadowbrook Parkway (a total of 3 lanes on the ramps - 2 from the N.B. direction,1 from the S.B. direction) and from Merrick Avenue, onto the westbound Charles Lindbergh Blvd.
access road (3 lanes in each direction). Also, access from the south via Hempstead Turnpike (3 lanes in each direction),
from the west via Earle Covington Road. Direct access to the Coliseum parking lot is provided by more than 12 entry lanas.
It is my opinion that the aggregate capacity of all access rords to these parking facilities exceeds 4000 vehicles per hour in each direction (i.e. inflow and outflow).
Personnel It will be necessary to assign personnel to assist the '
public in gaining access to the parking areas. This personnel should consist oft e Nassau County Police along all public roads e Parking guides withip all parking areas.
Approximately a dozen personnel of each category would be desirable plus supervisory personnel.
Yours truly, Edward Lieberman ELild 9
""^'*"'S Wh Attachment 3
- Zuh
{ ~-
, )
STATE OF NEW YORK DEPARTMENT r, OF HEALTH x e n nit :1 2 TOWER BulLDIN G e THE GovanNom N ELSON A. 40CNEFEbbEM RW' IRE ST ATE PL AI A~ e A(.B AMV. N.Y.122p .
9 '
- '"f,,"'
,' NbdTibIU.NIU 33ANCH 1.
August 29, 1983
^
D )
m SEP 1 1983 "
gmCt Of 1888818CT FIEMA18#III
~
- Mr., George Brower j<;-
Director .
Disaster / Emergency Preparedness 200 North Second street -
Fulton, NY 13069 ,
f .
Dear Mr. Brower:
Referring to our question today on 'the decontaminatiort '
the 10 mile EFE as to what problems may of arise from water us to wash off a. vehicle that may become vehicles leaving'ed contaminated, we believe that this is not a problem that creates ,
any major concern. ,
I't is believed that the'small amount of contamination k that may settle on a car will be diluted to a great extent by washing and that this water can either seep into the ground or enter the sewer system. Care should be taken to see that the wash water does not enter the area where people gather.
The major concern with contamination is still with human beings.firatiand equipment second. I hope this information gives '- '
you'enoughig'uidaneseto answer your questions.
Sincerely you , , ,
M A*
Denald D. Davidoff Director RsJiologiosi Emergency Preparedness Group cc Mr. Nowieski, FEMA
i
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STAT F NEW YORK DEPARTMENT OF HEALT CORNtNG 70364 e TME GOVERNQ A M 8kSON A. ROCNEPELLgm suptRg STATE PLAEA e AL B AN Y, N.Y. II2N* * '* '* /
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,! c- November 16, 1983 j !
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. >4., NOV 1 1983', . .
g OECICN!UUCT U:,a;.::::,j
.f Mr. George Brower .
Dirac r
- 5 , -,
' Disaa /tr.orgency Preparedneae 't't {.~f G1.;",
200 N th Second'8treet ' ' -
ruito NY 13069 '
. t. ,
Dear . Brower:
. l The question of what to do with waste shower water ~4 tHat a become contaminated due to the contadinated individual has been asked.
cleansing of a t-()
t.
. In consultation with Dr. Karim Rimawi, Director, sureai 'I of Environmental Radiation Protection, it has been ,
deteri Lned that Auch waste water should be allowed to flow I -
direc' Ly into .the normal. sewer system since it would be N, . . Y ",yj g
great y diluted by the volume of water in the system and :
therf,oreposenohealthproblems. .' ,
'A ' '
- .. g .' .
sincere.1,y yours, ;,, . ,,
hr
- gos <
(h.'a..
, e, .
j . nald . Day d g ,
- * . ' -l* .* irector p ,(;.
adiological Emergency Preparedness Group 0
L.3 p
o t .
Attachm3nt 4
.w U' m -
Federal Emergency Management Agency
@ Region 11 26 Federal Plaza
- NewsYork, New York 10278
- di fif 7 ,.
February L12,[(1985 3M$cf M!
Michael S. tiiller, Esq.
Kirkpatrick & Iockhart . _. , '
1900 M Street, N.W. ..
Washington, D.C. 20036 In the Matter of IDNG ISIAND LIGKritG COiPAIN (Shorehan tbclear Power Station, Unit 1)
Docket tb. 50-322-0L-3 (Bnergency Planning)
Dear Mr. Miller:
This office is in receipt of your letter dated January 31, 1985 in which you requested the following information relating to the Shorehan Nuclear Ibwer Station and the proposed utilization of the Nassau Coliseun:
- 1. All docunents and correspondmce of any kind between or among representatives of the FEMA and the NRC Staff and/or LIILO concerning LIILO's proposed use of the Nassau Coliseus.
- 2. All docunents relating to the use or proposed use by any licensee, including L1140, of a relocation center (or other facility at which all evacuees would be monitored and, if necessary, decontaninated in the event of a radiological accident) which is 40 or more miles fran the licensee's nuclear power plant.
- 3. All docunents relating to the health effects to EPZ evacuees or to the population of Nassau County or other areas outside the EPZ that could result from LIILO's proposal to use the Nassau Coliseun as a relocation center.
Upon receipt of the above referenced letter FhMA's R. 3 tonal Counsel requested clarification of the request fran counsel for Suffolk County.
It was agreed that the second question only required identification of enose sites where monitoring and/or decontanination functions were locaced more than (40) iniles from a Nuclear Generating facility. In addition, it was agreed that the last question was directed to the identification of Shorehan site specific studies and was not an attenpc to ascertain the existence of general literature in the field.
s
~
[
l l In reference to the above inquiry, FEMA provides the following responses:
- 1. To the best of our knowledge and belief, all the docunents and correspondence concerning LIID0's proposed use of the Nassau Coliseun that are in FEMA's possession were provided through the service list in the above captioned matter.
- 2. The attached charts contain the identification of those sites utilizing facilities which are thirty or more miles fra a nuclear power plant to enitor, and if necessary, decontaninate evacuees in the event of a radiological accident. This material was compiled at the direction of this office. 'Ihe difference in form utilized in the attached charts is a result of having different individuals empile the material to insure a timely response and has no other intended significance.
- 3. It is our belief that generic material does exist relating to the hacith effects on EFZ evacuees around Nuclear Power Plants but this office is not aware of any specific docunents relating to LILOO's proposal to use the Nassau Coliseun as a relocation center.
FEMA is aware of the Board's ruling of February 5,1985 and its voluntary response to the above questions is intended to facilitate the dissanination of information in this proceeding without unduly hindering the ability of FEMA to carry out its assigned responsibilities. This response is not a waiver of any rights that 19tA has to formally object to these requests or any possible future requests that may result directly or indirectly from these responses.
Very truly yours, f >n )$$
Stewart M. Glass Regional Counsel lbrton B. Margulies, Gairman tbrman L. Greene, Esn.
ec: W. Taylor Reveley II*., Q.
Frederick J. Shan Stephen B. Iathan, Esq.
Dr. Jerry R. Kline Donna Duer, Esq.
Jonathan D. Feinberg, Esq. Atomic Safety and Licensing Howard L. Blau, Esq.
Atomic Safety and Licensing A. peal Board Panel Mr. Brian McCaffrey Board Panel Martin Bradley Ashare, Ecq.
~ Edward M. Barett, Esq.
itHB Technical Associr.tes Marc W. Goldsmith Mr. Jay Dunkleberger Fabian G. Palomino, Esq. Ibcketing and Service Section Ibn. Peter Cohalan Spence Perry, Esq.
John F. Shea, III, Esq. Ixon Friednan, Esq.
James B. Dougherty, Esq. Ben Wiles, Esq.
Ms. Mora Bredes Bernard M. Bordenick, Esq.
Gerald C. Crotty, Esq. Donald Irwin, Eng.
G ris Nolin Richard Zahnleuter
' - ~ - _ _ _ _ _ _ _ _ _ _ _
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- Attachment 1 Plant Distaace Name of Purpose of Name From Facility Facility Plant
- 1. Arkansas Nuclear 30 Miles Morrillton Reception Reception Center One Centerr Morrilltone Monitoriw] and Arkansas Decontanination
- 2. River Bend 30 Miles Riverside Centroplex East Saton Rouge LA
- 3. Grand Gulf 38 Miles Ferriday Reception Centero Ferridaya LA
- 4. Waterford 50 Miles Riverside Centroplex East Baton Rouge, LA S. Millstone 35 Miles City Hall /Parkin] lot Nonitorim Weatherfielde CT Decontamination Registration 35 Miles Yale Bowl New Haveno CT
- 6. Trojan 46 Miles
- Lewis County Registratione i *This aileage Assistance Center Monitorim is in air Decontamination miles (straight vector) from plant locations actual road miles would be greater than 46.
- 7. Browns Ferry 32 Miles Morris School Huntsviller M 32 Miles Westlawn Middle Schoolo Huntsviller E I
i 32 Miles Milton Fratk Stadium a Huntsville r E 32 Miles Huntsville-Madison County AL: porta Huntsville r E L
(
- s. .
2
. Plant Distance Name of Purpose of Name From Facility Facility Plant
- 8. Catawba 30 Miles Lockhart School, Shelter -
Lockharta SC Monitoring /
Decontamination 39 Miles Union High Schoola Unions -SC .
30 Miles Cherokee Vocational Schoolo Cherokee Countyr SC 34 Miles East Junior High School Cherokee Countyr SC 32 Miles Gaffney High Shelter -
School, Caffneyr Monitoring /
SC Decontamination 4
34 Miles Luther Vaugh Elementary School, Cherokee County, SC 35 Miles B. D. Lee Elementary School, Cherokee County SC 35 Miles West Schoolo Cherokee County, SC
- 9. Crystal River 41 Miles 3ronson High School Bronsono FL 42 Miles Chiefland High School Chieflanda FL 41 Miles Williston High Schoola Willistone FL 41 Miles Williston Elementary Schoolo Williston, FL 4L Miles Williston Intermediate School, Williston, FL 32 Miles Cedar Key Schoolo Cedar Keyr FL m.. ._ . . . _ _ , - ._ _ _ _ _ ,_ _ _ _ _ . . . . _ . - . . _ _ . _ .
~
a-
-3 Plant Distance Name of Purpose of Name From Facility , Facility Plant
- 10. Grani Gulf 40 Miles Hazlehurst North ,
Shelter -
Campus Elementar) Honitorin]/
Schoola Hazlehurste Decontamination MS 40 Miles Hazlehurst South Campus "
" Elemntary Schoolo Haziehurst, MS 37 Miles . North Natchez Adama High Schoolo Natcheza MS 37 Mile's South Matchez Adams High Schoolo NatchezoMS
- 11. Watts Bar 35 Miles Oliver Springs Shelter -
Elementary School, Monitoring /
Oliver Springsr TN Decontamination l " "
35 Hiles Oliver Springs High Schoolo Oliver Springs TN
- 12. Palo Verde 35 Miles Tolleson High School These four centers 1bilesono AZ are backup / overflow relocation centers
, 40 Miles Glendale High School onig. The primary Glendale, AZ centers, all less than 30 miles S0 Miles Trevor Brodne High from the planto School are designed to Trevor Browner AZ accomadate all anticipated needs.
50 Miles Quartzsite Commmunity Center Quartzsite, AZ
. . _ - _ , - . _ . . ~. - . - - . .- . - - . - - - . . ---
Attachment 2 Facilities Located 30-40 Miles From A Nuclear Power Plant Site Facility Name and Location Furpose of Facility I quad Cities red son ldeconlrsptlcong ce Mt Carroll Unit District Schools x x x x Mt Carroll. IL Sterling Eigh School a a a Sterling, IL a Challand Jr High School a a Sterling IL a' s Franklin Grade School a a a a Sterling, IL Lincoln Grade School u a x x Sterling, IL Wallace Grade School a m x x Sterling,'IL Washington Grade School a a Sterling. IL a a Jefferson Grade School a x s a i
Sterling, IL l
\
Byron Mt Carroll Unit District Schoole a a u a Mt Carroll, IL Paw Paw Elseentary School a x a Paw Pow, IL a Paw Paw Righ School a a a a Paw Paw, IL Sycesore Eigh School a x x Sycamore, IL z Sycamore Jr Eigh School z z a a Sycamore, IL Berth Slementary School a a a
- Sycamore, IL a i
Southeast Eleasatory School a g , ,
[
Sycamore, IL West Elseentary School a a l Sycamore, IL a a 1
l l
l
~
Etos Alden-Mobron Righ School (f19) z a x x Bebros, IL Aldes-Esbron Elementary School x x x x Bebros, IL Woodetoch Migh School a a a x Woodstock IL Northwood Jr High School a E E E Woodstock, IL usetwood School a a u a goodstock, IL t
Olson School s z a a goodeteck IL Northwood Elementary School u a a u
, Woodstock, IL Greenwood School a u a a Woodeteck, IL Desa Street School x x x x Woodstock, IL Clay Street School x a a u Woodstock, IL Merios Contral Catholic RS z a x a Woodstock, IL >
St Marye Grade School a z a x Woodstock, IL Illinois National Guard Armory z x x x Woodstock, IL Sodom School a a a a Woodstock, IL McNesty Community College . x a a a Crystal Lake, IL Crystal Lake Central Righ School x x x x Crystal Lake, 11 Crystal Lake Eigh School South a a a a Crystal Lake, IL
- North Jr Eigh School a a a a Crystal Lake, IL 2
J 4
vw--w- em,.~m-me w-w-~w me-s w- -w,e-s~ w,w-e-e- .- a~ ~-oe ~ -o.a-w vv w-e -w w m-w e-vow w w w w~w we--w e ve r w o---n -mev e - ww- ow--,,e -sm n - .- nme-*
Eies (sost) Lundahl Jr Eigh School a a a a Crystal Lake, IL Prairie Grove Schost z a x x
, Crystal Lake, IL Borth Elementary School a x x Crystal Lake, IL West Elementary School a x x x Crystal Lake, IL
, South Elenestery School a a a a t
Crystal Lake, IL Central Elementary School a a m x Crystal Lake, IL Coventry School a x x x Crystal Lake IL Centerbury Elementary School a .x a a Crystal Lake, IL . .
Emananal Lutheras School E E E E Crystal Lake,IL l St Thomas the Apostle School x a u u Crystal Lake, IL E.D.Jacobe Eigh School a a a x Algesquia, IL Algonquin Middle School a a a a Algonquin, IL Eenneth E. Neubert Eles School a a a a Algonquia IL 1
Eastview Elementary School a u a a Algonquin, IL Coasst Eigh School z a a a Boffesa Estates, IL Noffaen Estates Righ School a a a a Boffaen Estates, IL Schauaburg Eigh School s a a a Schaumburg IL Natae 1try Eigh School Eaet u a a a Park Ridge, IL 3
ew-us-we,,--y- g*w-mw-i-s--=---wwwww-w-v%_ 7Mgw-ag- -y-eo,. mqvW-9+ W m w w.
Eton (coat) Maine Twp Eigh School South Park' Ridge, IL a x x x Maine West High School Dee Plaines IL a x a a Algonquis Jr Nigh School x Des Plaines, IL x x x Chippewa Jr Eigh School a a a a Des Plaines IL 1
Iroquote Jr Eigh School *
- Des Platase, IL
- 2 i
Cumberland School *
- Dee Plaines, IL 3 E Central Righ School a Des Plaines, IL a a a Perrest School a a Dee Plaines, IL a a
! Worth School a Dee Platsee, IL a a a Orchard Place School a a x Dee Plaines, IL x Plainfield School a x x Dee Plaines IL a South School a Des Platase, IL a a a Terrace School a x Dee Plaines, IL x x Elk Grove Righ School x a Elk Grove Village IL a a Liberty Jr Righ School a u 31k Grove, IL a a Nergaret Mead Jr Eigh School a a 31k Grove, IL a a Grove Jr Righ School a Elk Grove, IL a a a Admiral Byrd Eleasatory School a a Blk Grove, IL a a 4
l t
!, Eton (cont) Clearment Eleanntary School a a Ilk Grove, IL a a Salt Creek Elementary School x x x Bik Grove, IL x Eupley Elementary School x x a Rik Grove, IL a 1
i Adlai Stevenson SCJfCCL- a a m a Elk Grove, IL Adolph Link SCfgC L , * *
! Elk Grove, IL 8 '
Elk Grove Twp Commualty Day z a x Care Center x Elk Grove IL Grant Wood Seafor Conter x x x x s
Elk Grove, It Elk Grove Public Library a x x x Elk Grove IL i
Lione Park Coeuusity Center x x x Elk Grove IL x Queen Of Rosary h 8L- a x u a Elk Grove, IL
~
Streamwood Nigh School a x x Streauvood, IL a I
- Canton Middle School a a a u Streamwood, IL Taf t Jr Righ School a u a a Streamwood, IL Glenbrook Elementary School a u a a Streamwood, IL Entitage Elementary School a x x x Streamwood It Gak N111 Elementary School a a a a Streamwood IL EidSe Circle Elementary School x a a a Streamwood, IL Sunnydale .$C4f004 n a a a
{ Streamwood, IL f
4
- -----r-r-ww--w,,----,, ,n,,-- -
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. . , _--n.w--.m.,,--~,.-w,.-_,__w,_,-,,,,mmw,_m,,,-we-,,,ma.~-~e,_.-w---,---
Eton (cont) Elgia Eigh School a a a x Elgia. IL I
Larkin Eigh School a a u a ,
Elgin, IL Abbott Middle School a E a a Elgia, IL Ellie Middle School a a a a Elgia, IL Etabell Jr Eigh School a a a u
- Elgia, IL Larson Middle School a a a a 4
Elgin, IL Century Oska School a x a m
, Elgia, IL ChaastagEkenesterySchool a x x x Elgia. IL Coleman Elementary School a a a a Elgia, IL Sifford Elementary Scheel a a a a Elgin, IL Eighland Elementary School a a a a Elgia, IL E111eroet School s a a a Elgia, IL Boff Elosentary Scheel a a a a Elgin, IL Illinois Park Scheel a a a a Elgia, IL Lords Park Elementary Scheel a a a a Elgia, IL Sheridan Eleasatory School a a a a Elgin, IL Willard Grammer School a a a a 51gia, IL Elgin Commanity College a a a a Elgin, IL 6
I
Sies (sost) Elgia Mental Maalth Center s x x x Elgin, IL 1111aoie National Guard Armory a a a a Elgia, IL Dundee Caumnamity Eigh School a a a Carpestersville, IL a Dundee Middle Scheel a a a a Dundee. IL Perry Middle Seheel a x x Carpentersville, IL a Dundee Eighlands Elementory School a a a a Dundee, IL Lakewood Middle Seboel a a a a Carpenterev111e, IL Golfview Elementary School a a a a Carpentersville, IL 1rvias Crown High School a a a a Carpentersville, IL Etage Read Elementary Scheel a a a a Carpentareville. IL Parkview Elementary School a a a a Carpenteroville, IL Meadowdale tienestery Scheel a a a a Carpentersville, IL Cary-4 rove Eigh Scheel u a u a Cary, IL Cary Jr Eigh School a a a a Cary, IL BriarSate Elementary Scheel a a a a Cary, IL Oak Eno11 Elementary Seheel a a u a Cary IL Maplewood Eleasatary Seheel a a a a Cary, IL Saints Peter and Paul $C)NW x a a a Cary, IL 1
O
s
- Bien (eaet) East Troy Jr Eigh Scheel East Troy Village. WI a a a a !
! St Petere Blessatary Scheel Best Troy Village VI a a a a East Troy Eigh Seheel Esat Troy Village WI a a a a East Troy Elementary Scheel
- East Trey Village. WI a a a a Stone Elementary seheel Eset Troy Village VI a a a a 8t Edoarde Elementary Scheel East Troy Village, VI a a a a Gateoay Technical Isotitute 31khorn City, VI a a a a St Patriche Grade Seheel a a 31khora City, WI a a 1.ekeland school a Elkhora City, WI a a a .
- Elkhora Middle School a a Elkhorn City WI a a Elkhorn Eigh Scheel 31khorn City VI a a a a l
I Westelde Primary Scheel 31hhora City, WI a a a u '
yestema Elementary Scheel Postana, WI a a a a Denteen Jr Ei a Lake Geneva,WIgh Scheel a a a Meloorth Elemmetery Seheel a Maloorth, WI a a a
- Big Feet Righ Scheel Maleerth, WI a a a a North Waloorth seheel a a Waleotth, WI a a Willisen Bay Eigh seheel a Williams Bay. WI a a a 8
I -
L._.__-_ ~ - . .
' sten (eenr) George Willisme College a a x x villiams Bay, VI Reek scheel a x x x Lisa Township, W1 Traver Elementary Seheel x a a u Lina Township, W1 N.W. Military Academy a a a Lisa Township, WI 3 Prairie Islead Univ of Visconsta - Stout a '
a a a nonseinse VI State Fair Grounde(4-H BL.%)a se peut, nw x x Nestisello State Fair Grounde h *M M z a a a St Paul, MN .
- Perry Southeast 31eenstory Scheel 52 s a m a Ceaseaut, ON Comaeaut Eigh School 32. x a a a Comoeaut, 0E Cheetaut Scheel 32. *
- E 8 l Ceaseaut. OE
- Lakeview scheel 52. = = = =
Ceaseaut, 05 West Main Scheel 32 a a a a Ceaseeut, 05 9
l 1
. - - _ . _ - _ _ - _ _ , . . - - . _ _ - - - _ - _ . . . - _ . . ~ _ - - . - - , , - _ - - _ . , . - - - - - - . . - - - - - . .
- - . _ _ - . - - - - . _ . _ ~ _ - - . _
Facilities Located Over 40 Milee Free A Nuclear Power Flaat Site facility Wees and 14esties Furpose of Facility 4
red mon ldeceslrsptjeems sa Prairie Island Olmsted County Fair Grounds a a a a Reehester,lef
_~. ~ _ ~ . - _ . ~ - . .._. -
Eisa St Andrews School a a a u i
Delavaa. VI .
I Delavan Christles Scheel a a a a Delavaa, WI Wileena Scheel a u x x Delavaa. VI Delavan Phoenix x x x x Delavaa. V1 Park Scheel a a x x Delaves, WI Delavas-Derien Eigh Scheel a z a a Delaves, VI Leara/ Flay persary Scheel a a a a Delavan, W1 Franklia Scheel s a u u Whiteweter, WI hitewater Eigh seheel a x x x hitewater, WI Weehington Steenstery Seheel a m a x
- Witewater, WI ,
t Christian 84usation Building a a a a i hiteweter, WI Lineeln 81eenstory School a x x x hatewater, W1 Univ Of Wissessis - Whiteweter a a a a hiteweter, W1 10 a
i
-c..-m. -
..,,,______._.___,-,___,___._,_,%.,_._,._._______.____,,-,___,_-__,m. . _ _,,.y_,..,__,.__,
r-- e l
l Attechnent 3 i
Region 111 - Philadelphia l
Plant Name/ Location Distance from Plant Ntanber of Facilities Furpose" Surry between 30 & 40 miles 1 i (Virginia) 1M1 between 30 & 40 miles 37 (Permsylvania) over 40 miles 146 ,
(One catacy lists all mass care '
centers - 90) will depend an need Limerick between 30 & 40 miles 2 (Pennsylvania)
Peach Boccan between 30 & 40 miles 2 L
(Pennsylvania) f .'
between 30 & 40 miles 4 l
Beaver Valley)
(Pennsylvania l Susquehana between 30 & 40 miles 24 l (Pennsylvania) over 40 miles 4 Salen between 30 & 40 miles 2 (New Jersey)
- All mass care facilities will potentially serve as public monitoring ed decontamination centers.
l O
Name & f acarion of Facility for 2nitoring and/or Purpose
~
Nuclear Pbwer decontamination Plant Distance 30-40 miles M O tiles
- from plarit front plant
- from plmt M and/or D Camusants s'
- Sites selected.
l Callmey 30 Heemes thit-Purpose M a:d D d based on these l
Bldg. 2 criteria only.
Cohsabia, le - Facilities <,30 , .
miles not included, unless they were very close to 30.
$s Cooper NW Missouri . M and D State Univ.
$a a) te ~ 50 . Maryville, te
, lith & 3rd Corse M and D + ,
! M b) NE 35 &.21st & 4th " "
perfonned at l Nebraska City,E -
roadblocks also l Lisane Arnold 58 Marshall town,IA M and D l 30 lawa City, IA M and D l 75 Deve w t, IA , M md D #
68 Dubuque, IA M and D 28 Independence, IA M and D _
Ft. Calnoun a) NE 43 First Baptist M and D -
Church, Bellevue, NC l
b) IA 50 Denision, IA Registration & M
- 1) Zion Lutheran Omarch Plan ses not l 2)Carlyle Memorial explicitly detail l 3)Sr. Citizens Center 14D l
. 4)Dension Jr. High !!-State Patrol -
I 5)Dension Oosus. High D-Selected Central ,
locationn Quad Cities All within 20 miles from plant ,
All in Kansas .
Wolf Creeek 32 Ottma H.S. e 28 Garnett H.S.
28 Dporia State Univ.
29 Lyon Co. Fairgromds 30 ola National A"OfY _
/
l
IDCATIONS OF IENIITORING/DECONTAMINar10N FACILITIES FE - amT 19s5
.n FACILITT IDCAtED 40 MILES FUREMEST FACILITY FROM TME PLANT h SITE NAIE OF NOW1YORING DECONTAMINATION FACILITIES OR MORE FEDM TME FIANT o _.___
M Carl Coets School None Approximately 25 miles Oyster Creek. N.J.
Fatterson Road Jackson. New Jersey Salee,NJ Claceboro College None Approximately 28 miles Route 322 Claseboro. New Jersey Dutchess Mall None Approximately 31 miles Indian Point. M.T.
Fishkill. New Jersey Sperry Sr. Migh School None Approximately 20 miles Cinna. N.Y.
1799 Lehlgh Station Road
- Nine Nile Fatat Jefferoom Community College Approximately 40 miles 120 Coffeen Street Watertown New Jersey l
e e
e
, , J t ,e LILCO, Ecbruary 26, 1985 2 XETE USNAC CERTIFICATE OF SERVICE 20 U! d2 CFi.Lt U n Lht i An >
In the Matter of 0 %'M UING A SE8 Wir' LONG ISLAND LIGHTING COMPANY 3 RANCH (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S RESPONShid5i'IN'" .-
TERVENORS' PROFFERED TESTIMONY ON THE DESIGNATION OF NASSAU COLISEUM AS A RECEPTION CENTER were served this date upon the following by first-class mail, postage prepaid or, as indicated by an asterisk, by Federal Express, or, as indicated by two as-terisks, by hand Morton B. Margulies,** Secretary of the Commission Chairman U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board, Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing East-West Tower, Rm. 402A Appeal Board Panel 4350 East-West Hwy. U.S. Nuclear Regulatory Bethesda, MD 20814 Commission Washington, D.C. 20555 Dr. Jerry R. Kline**
Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East-West Tower, Rm. 427 Washington, D.C. 20555 4350 East-West Hwy.
Bethesda, MD 20814 Bernard M. Bordenick, Esq.**
Oreste Russ Pirfo, Esq.
Mr. Frederick J. Shon** Edwin J. Reis, Esq.
Atomic Safety and Licensing U. S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory 7735 Old Georgetown Road Commission (to mailroom)
East-West Tower, Rm. 430 Bethesda, MD 20814 4350 East-West Hwy.
Dethesda, MD 20814 m
- .*o Donna Duer, Esq.** Stewart M. Glass, Esq.*
Attorney Regional Counsel Atomic Safety and Licensing Federal Emergency Management Board Panel Agency U. S. Nuclear Regulatory 26 Federal Plaza, Room 1349 Commission New York, New York 10278 East-West Tower, North Tower 4350 East-West Highway Stephen B. Latham, Esq.*
Bethesda, MD 20814 Twomey, Latham & Shea 33 West Second Street Fabian G. Palomino, Esq.* P.O. Box 398 Special Counsel to the Riverhead, New York 11901 Governor Executive Chamber Ralph Shapiro, Esq.*
Room 229 Cammer & Shapiro, P.C.
State Capitol 9 East 40th Street Albany, New York 12224 New York, New York 10016 Herbert H. Brown, Esq.** James Dougherty, Esq.
Lawrence Coe Lanpher, Esq. 3045 Porter Street Christopher McMurray, Esq. Washington, D.C. 20008 Kirkpatrick & Lockhart 8th Floor Jonathan D. Feinberg, Esq.
1900 M Street, N.W. New York State Department of Washington, D.C. 20036 Public Service, Staff Counsel Three Rockefeller Plaza MHB Technical Associates Albany, New York 12223 1723 Hamilton Avenue Suite K Spence W. Perry, Esq.
San Jose, California 95125 Associate General Counsel Federal Emergency Management Mr. Jay Dunkleberger Agency New York State Energy 500 C Street, S.W.
Office Room 840 Agency Building 2 Washington, D.C. 20472 Empire State Plaza Albany, New York 12223 Ms. Nora Bredes Executive Coordinator Shoreham Opponents' Coalition 195 East Main Street Smithtown, New York 11787 t -- -- - - -- -_ __-- --- __----_--_--- .
Gerald C. Crotty, Esq. Martin Bradley Ashare, Esq.
Counsel to the Governor suffolk County Attorney Executive Chamber H. Lee Dennison Building State Capitol Veterans Memorial Highway Albany, New York 12224 Hauppauge, New York 11788 pmesN.Christman h.W K Hunton & Williams 707 East Main Street i P.O. Box 1535 Richmond, Virginia 23212 DATED: February 26, 1985 k
h I
- h. . _ _ _ - _ _ _ . _ _ . _ _ . _ _ _ . . . _ _ _ _ _