ML20140C603

Supplemental Testimony of Mc Cordaro,Ed Robinson & Ja Weismantle on Phase II Emergency Planning Contentions 24.0, 74 & 75 Re Relocation Ctrs for Public.Certificate of Svc Encl

ML20140C603
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/15/1984
From:	Cordaro M, Edward Robinson, Weismantle J LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20140C523	List: ML20140C519 ML20140C603
References
OL-3, NUDOCS 8406190388
Download: ML20140C603 (18)

Text

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LILCO, Juns 15, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

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

) (Emergency Planning (Shoreham Nuclear Power Station,) Proceeding)

Unit 1) , )

LILCO'S SUPPLEMENTAL TESTIMONY ON 4

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PHASE II EMERGENCY PLANNING CONTENTIONS 24.0, 74, AND 75 (RELOCATION CENTERS FOR THE PUBLIC)

1. Q. Please identify yourselves.

A. [Cordaro] My name is Matthew C. Cordaro.

[ Robinson] My name is Elaine D. Robinson.

[Weismantle] My name is John A. Weismantle.

[All witnesses] Our business addresses and roles in emergency planning for the Shoreham Nuclear Power Station are contained in our previously filed testi-mony on Contentions 24.0, 74, and 75, and our profes-sional qualifications have been entered into the record. This supplemental testimony should be read in conjunction with our previously filed testimony.on Contentions 24.0, 74, and 75. The answers in the re-mainder of.this testimony are sponsored by all of us.

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2. Q. Please summarize Contentions 24.0, 74, and 75.

A. Contention 24.0 states, in essence, that suffolk County refuses to make suffolk County Community Col-lege availabli as a relocation center, and therefore that there does not exist sufficient relocation cen-ter capacity; Contention 74 asserts that Suffolk County Community College and the State University of New York at Stonybrook are only three miles beyond the EPZ boundary, contrary to the requirements of NUREG-0654 II.J.lO.h; and Contention 75 asserts that

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the LILCO Plan does not provide adequate capacity or facilities at relocation centers. The complete text of the three contentions, and the text of the legal standards cited in the contentions, are set out in our direct testimony previously filed on these is-sues.

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3. Q. What relocation centers are relied upon in your tes-timony on Contentions 24.0, 74, and 75 and in Revi-sion 3 of the LILCO Plan?

A. The three primary relocation centers relied upon in our previous testimony and in Revision 3 are Suffolk County Community College, BOCES Occupational Center Complex at Islip (BOCES at Islip), and State Univer-sity of New York at Stonybrook (SUNY-Stonybrook); the two secondary relocation centers relied upon are i

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State University of New York at Farmingdale (SUNY-Farmingdale) and St. Joseph's College at Patchogue. )

l The location, capacity, and services of each of these j centers are discussed in our previously filed testi-mony.

4. Q. Has LILCO changed any of the facilities it will rely upon as relocation centers since the time that you filed testimony on Contentions 24.0, 74, and 75?

A. Yes. The Suffolk County Chapter of the American Red Cross has notified us that Suffolk County Community College and SUNY-Stonybrook will not be used by the Suffolk County Red Cross as relocation centers in a radiologic'al emergency, and that Dowling College in Oakdale will be used. The Suffolk County Red Cross therefore has designated BOCES in Islip, SUNY-Farmingdale, St. Joseph's in Patchogue, and Dowling College in Oakdale as relocation centers if centers are needed during a radiological emergency at Shoreham. If it becomes necessary to open additional relocation centers, the Suffolk County Red Cross will send people from these four centers to other build-ings nearby as the need arises. As with the Nassau County Chapter of the American Red Cross, the Suffolk County Red Cross has agreements with the owners of

'the designated relocation centers and with the owners

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of' additional buildings in the area'to provide shelter during emergencies.

_4 As a result of these changes, LILCO no longer relies upon Suffolk County Community College and SUNY-Stonybook as relocation centers. BOCES in Islip (an original primary center), SUNY-Farmingdale, and St.

Joseph's in Patchogue (original secondary centers) are now primary relocation centers, and Dowling Col-lege in Oakdale is a secondary relocation center.

Revised Attachment 5 to LILCO's testimony on Conten-tion 74, which is attached to this supplemental tes-timony, shows the location of these four facilities.

5. Q. What is the difference between a primary and a sec-ondary relocaticn center?

j A. LERO provides monitoring and decontamination at the primary relocation centers in accordance with Section 3.9 part B of the LILCO Plan beginning at page 3.9-5; Figure 2.1.1 page 2 of 4; and OPIP 3.9.2. Evacuees are sent, if necessary, from primary to secondary centers after being monitored. Secondary centers will be activated by the Red Cross to receive addi-tional evacuees should primary centers reach capaci-i ty.

6. Q. Why are you dropping Suffolk County Community College

, and~SUNY-Stonybrook from the relocation centers des-l

! ignated in the LILCO Plan?

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-5 A. The administrators of these facilities have refused the Red Cross' request that they agree to provide shelter for evacuees in the event of a radiological

. emergency at Shoreham, and therefore we have replaced them with other centers for planning purposes. We do so reluctantly, because they are excellent facilities that would provide shelter for a great many evacuees should that be necessary. (As is indicated in our

, testimony previously filed on Contention 74, these facilities were praised at the local and state level for their suitability as relocation centers.) The Red Cross is able to provide other good facilities in the area, however, and therefore LILCO need not rely a upon these two facilities to satisfy NUREG-0654 ,

guidelines regarding relocation centers. It is our belief that during an actual emergency, were the Red f Cross to call upon Suffolk County Community College j or SUNY-Stonybrook to open its doors to persons requiring shelter, those facilities would. respond positively.

7. -Q. Where is Dowling. College located in relation to the i EPZ boundary? ,

A. Dowling College is located in Oakdale, approximately i

11 miles.from the EPZ boundary and 21 miles from Shoreham.

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lege?

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A. DowlingCollegehasaca[acityof1,500 evacuees.

9. Q. What facilities are available at Dowling College?

A. Dowling College is a complete' dormitory facility with beds, showers, toilet facilities, and a cafeteria.

10. Q. What are the additional facilities that the Red Cross 3

would rely upon to house evacuees should the four named facilities become full?

j A. These facilities include public schools, school buildings no longer used as schools, private schools, j/ senio'r citizens' centers, and adult'and youth cen-ters. The had Cross has advised us that in the areas 1,

of Smithtown, Islip, Huntington, and Babylon alone, it could shelter a minimum of 20,000 people, not counting billeting in p'rivate homes, armories, or

'" large commercial and industrial establishments.

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, ...ljb.f Q . Why are(you planning initially to open only the four

.7 / named facilities for EPZ residents?

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A. As a-result of the Red Cross' information that

, SuEfolk County Community College and SUNY-Stonybrook are not available as relocation centers, LILCO has l reexamined, in consultation with the Red Cross, the i

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o best approach to be taken regarding relocation cen-ters for a Shoreham emergency. Experience in past emergencies suggests that significantly less than 20%

1 of the population may seek public shelter. In the r Mississauga accident, for example, only 5% of the i population sought public shelter, officials at Mississauga concluded after the accident that they

, had established too many relocation centers, thereby

, wasting resources, and that massive centralized fa-cilities were not necessarily better than staaller, 1 o more manageable facilities with essential services.

We have considered the changes made by the Red Cross I in the list of relocation centers, and have deter-1

mined in discussions with them that the best approach l for the_LILCO Plan would be to open the four named I

centers initially, and for the Red Cross to begin to

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open other centers in buildings for which it has agreements as (and if) those four centers reach ca-

• pacity. Since the additional secondary centers that

may be opened will be near the four named centers, Red Cross personnel will simply direct persons to the f

j additional centers should people arrive to find a l center filled. We believe that this approach (1) avoids wasting personnel, time, and equipment due i to what might be an overestimation of the number of evacuees who will come to or stay at a particular re-( location center, (2) provides flexibility, and

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- (3) ensures that shelter will be available for anyone seeking it.

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' 12. Q. As a result of these changes, what is the capacity available now at relocation centers to be provided by i

the Red Cross?

S A. ' The combined capacity of BOCES II in Islip, SUNY-Farmingdale, St. Jose'ph's in Pateb6gue, and Dowling College in Oakdale s'17,000 evacuees. another 20,000 could be housed at additional facilities pro-vided in Suffolk County by the Red Cross should it

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become necessary to open additional facili;1es. And as expla.n.cd in LILCO's previous testimony on Conten-1 s

tion 75, t'he Red.Choss has agreements with facilities 4

in Nassau County that can house up to 48,000 evacuees. Thlds, the total number of evacuees that

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could be sheltered by the Red Cross is upwards of 85,000. s 13 . Q . X What changes.will LILCO make to its Plan as a result of the information described above from the Red Cross?

A. The LILtv stan, procedures, and public.information material-wili'be' modified as appropriate _(1) to re-move' references to'SUNY-Stonybrook and Suffolk County Community College, (2) to designate SUNY-Farmingdale and St. Joseph's_in Pdtchogue as' primary ~rather than

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-g-i secondary relocation centers, (3) to add Dowling Col- l lege in Oakdale as a secondary relocation center, and (4) to indicate that additional centers in the area will be opened by the Red Cross as needed to accommo-date people should more than 17,000 people seek pub-lic shelter during an emergency at Shoreham. In ad-dition, LILCO will continue its understanding with the Nassau County Chapter of the American Red Cross to use facilities in Nassau County in the unlikely event that they are needed to supplement the centers being provided by the Red Cross in Suffolk County.

14. Q. As a result of the changes described in this supple-mental testimony, do you wish to make any changes to the testimony on Contention 24.0 regarding Suffolk County Community College?

A. Yes. The following sentence should be added on page 25 after line 3:

"The LILCO Plan does not presently rely upon Suffolk County Community College as a relocation center, based upon notification from the Red Cross that Suffolk County Community College has refused to agree to provide shel-ter for Suffolk County residents who may seek it during a radiological emergency E.t Shoreham."

15. Q. As a result.of the changes described in this supple-mental testimony,-do you wish to make any revisions-to your testimony on Contention 74 regarding the nearness of relocation centers to the EPZ boundary?

e-0 A. Yes. The following revisions should be made to con-form the testimony to the new information outlined above:

Purpose, page 1, line 3 Delete lines 3-9, beginning with "The five locations" and ending -

with "in Nassau County,"

and replace with the following: "These relocation centers include BOCES in Islip, SUNY-Farmingdale, St.

Joseph's in Patchogue, and Dowling College. The Suffolk County Chapter of the American Red Cross also has agreements with the owners of several other -

facilities available for use if needed."

Purpose, page 2, line 2 Delete lines 2-15, beginning with ", and as primary" and ending with " boundary." and replace with the following: ". None of the relocation centers relied upon by LILCO is within five miles of the EPZ boundary, and only one (St. Joseph's) is within ten miles of the EPZ boundary. Thus, LILCO complies with NUREG-0654 II.J.10.h."

Page 5, line 12 Delete " presently" and I replace with " relied upon by LILCO, which will be" Page 5, line 13 Delete "Suffolk County Community College"

! Page 5, lines 14-16 Delete "and the State University of New York at Stonybrook as primary relocation centers,'and"

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O Page 5, line 18 Delete the word "as," and insert ". Dowling College at Oakdale will serve as one of the" Page 5, last line Delete "The" and[ replace with "At the time that Revision 3 of the LILCO Plan was issued,"

Page 6, line 1 "has" should read "had" Page 6, line 4 "is" should read "was" Page 6, line 6 "will continue to use" should read " originally used" Page 6, line 7 Delete "of course, if the";

" advises" should read

"has now advised" Page 6, line 9 Replace "," with ";"

JPage 6, line 10 Delete. lines 10-18, beginning with " Prior to" and ending 7 with "in Nassau."

Page 7, line 1 Delete " prior to operating above 5% Power," and replace with "during an emergency" Page 7, line 8 "would" should read "will";

"any change" should read "the chanqes" Page 7, line 13 Delete lines 13-20, beginning with "Three of" and ending with "EPZ boundary." and replace with the following:

"Yes. All of the relocation centers now relied upon by LILCO are at least five miles l beyond the EPZ boundary, and only one is within ten miles of the EPZ boundary, as

~ indicated on the attached 7

map (Revised Attachment 5) and as described in our supplemental testimony on relocation centers."

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Page 7, line 22 "are" should read "would be" Page 12, line 10 Insert the following after line 10: "11.1 Q. If you think that Suffolk ,

County Community College and SUNY-Stonybrook would  ;

be good relocation facilities, why are you dropping them from the LILCO Plan?

A. The reasons are described in our supplemental testimony."

Page 12, line 15 Delete lines 15-22, from "The five locations" through Nassau County" t

Page 13, line 6 Delete lines 6-22, beginning with "and as" and ending with " boundary." and replace with the following:

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". None of the relocation centers relied upon in the LILCO Plan are within five miles of the EPZ boundary, and only one, St. Joseph's at Patchogue, is within ten miles. Thus, LILCO meets NUREG-0654 II.J.10.h."

Attachment 5 Delete Attachment 5 and replace it with " Revised Attachment 5" which is attached to this supple-mental testimony.

16. Q. As a result of the changes described in this supple-mental testimony, do you wish to make any changes to your previous testimony on Contention 75 regarding the capacity of relocation centers?

A. Yes. The following revisions should be made to con-

. form the testimony to the new information outlined above:

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Purpose, page 1, line 7; "32,000" should read page 10, line 8; page 12, "37,009" line 10 Purpose, page 1, line 7 Delete lines 7-9, beginning with "; that" and ending with "for."

and replace with ", over

' 20% of the projected 1985 EPZ population."

Page 6, line 27 Delete "the primary" Page 6, line 28 Delete "in the LILCO plan" Page 8, line 11 "or" should read "which is about" Page 9, line 13 Delete lines 13-18, beginning with " total primary" and ending with " accommodations",

and replace with

" capacity of BOCES at Islip is about 9,000 persons."

Page 9, line 19 Delete "two back up" Page 9, line 21 Insert after " people,"

the following: "Dowling College at Oakdale, which can hold about 1,500 people,"

Page 9,-line 23 "6,500" should read "8,000" Page 9, line 24 "Both" should read "All" Page 10, following line 2 Add this paragraph:

"In addition to the 17,000 evacuees who could be housed at the four named shelters, Suffolk County Red Cross, like Nassau County Red Cross', has agreements with other facilities to. house approximately 20,000 additional people should the need arise."~

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. l Page 10, line 8 "about" should read "over" Page 11, line 5 "80,000" should read "85,000"; )

"approximately" should read "over" Page 11, line 12 Delete lines 12-17, beginning with "As explained" and ending with " power."

Page 12, line 7 "is pursuing" should read "has" Page 12, line 8 "five" should read "four" (This change appears twice

. in this line.)

Page 12, line 14 Insert "over" before

" half" Page 12, line 15 Delete lines 15-20, beginning with "If" and ending with

" remaining" Page 12, line 20 Delete "would continue to" and add "will"

17. Q. Please summarize your testimony on Contentions 24.0,_

74, and 75.

A. Read in conjunction with our previously filed testi-mony as amended in this supplement, this testimony shows that LILCO has provided adequate relocation center capacity and facilities for an emergency at i

Shoreham. The LILCO Plan, procedures, and public in-formation will be revised to reflect the information from the Red Cross that relocation centers to be relied upon include BOCES at Islip, SUNY-Farmingdale, l

St. Joseph's at Patchogue, and Dowling College at i

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. 1 Oakdale. These four facili' ties have a combined ca- 1

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pacity of 17,000 evacuees; in addition, Suffolk Coun-ty Red Cross can make available additional space at other facilities if necessary to house at least an-other 20,000 evacuees. LILCO also has an understand-ing with Nassau County Red Cross to house up to 48,000 evacuees should that become necessary in an emergency. The capacity of these facilities, 85,000 people, is more than sufficient to met NUREG-0654 guidelines regarding relocation centers.

In addition, none of the facilities now relied upon by LILCO is within five miles on, the EPZ boundary and all but one are ten miles or more from-the boundary.

Therefore, the locations of the facilities also meet NUREG-0654 guidelines.

These relocation centers, as staffed and equipped by the Red Cross, have adequate facilities to care for evacuees, including toilet facilities, adequate space, and food facilities.

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RELOCATION CENTERS LOCATION '< rt o ci )

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LILCO, Juna 15, 1984

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CERTIFICATE OF SERVICE In the Matter of DOCKETED USNRC LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

(Emergency Planning Proceeding) g4 JUN 18 P3:32 Docket No. 50-322-OL-3 CIi . ~ ? .

[:[,

I certify that copies of LILCO's SUPPLEMENTAL ESIf ON CONTENTIONS 24.0, 74, AND 75 (RELOCATION CENTERS FOR THE PUBLIC) were served this date upon the following by first-class mail, postage prepaid, or (as indicated by one asterisk) by hand,-or (as indicated by two asterisks) by Federal Express.

t Secretary of the Commission James A. Laurenson, U.S. Nuclear Regulatory j Chairman

• Commission Atomic Safety and Licensing Washington, D.C. 20555 Board 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 Saf ety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory i Commission Commission Washington, D.C. 20555 East-West Tower , Rs. 427 i 4350 East-West Hwy. .

20814 Bernard M. Bordenick, Esq.*

Bethesda, MD Oreste Russ Pirfo, Esq.

Edwin J. Reis, Esq.

Mr. Frederick J. Shon* U. S.. Nuclear Regulatory Atomic Safety and Licensing 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.

i 20814 Stewart M. Glass, Esq.**

Bethesda, MD Regional Counsel Bleanor L. Frucci, Esq.* Federal Emergency. Management j Agency' t Attorney. .

26 Federal Plaza, Room 1349 Atomic Safety and Licensing New York, New York 10278 Board Panel

'U. S. Nuclear Regulatory Commission Stephen B. Latham, Esq.

East-West Tower, North Tower Twomey, Latham_& Shea 4350 East-West Highway :33 West Second Street l Bethesda, MD 20814 Post Office Box 398 l Riverhead, NY '11901 l

_ _ _}

5 - l i

. Fabian G. Palomino, Esq.** Ralph Shapiro, Esq.

Cammer & Shapiro, P.C.

Special Counsel to the 9 East 40th Street Governor New York, New York 10016 Executive Chamber Room 229 State Capitol James B. Dougherty, Esq.

Albany, New York 12224 3045 Porter Street Washington, D.C. 20008 Herbert H. Brown, Esq.*

Lawrence Coe Lanpher, Esq. Jonathan D. Feinberg, Esq.

Christopher M.'McMurray, Esq. New York State Public Service Kirkpatrick, Lockhart, Hill Commission, Staff Counsel Christopher & Phillips 3 Rockefeller Plaza Albany, New York 12223 8 th Floor ,

1900 M Street, N.W.

Washington, D.C. 20036 Spence W. Perry, Esq.**

Associate General Counsel Federal Emergency Management Mr. Marc W. Goldsmith Energy Research Group Agency 500 C Street, S.W., Rm. 840 4001 Totten Pond Road Washington, D.C. 20472 Waltham, Massachusetts 02154 MHB Technical Associates Ms. Nora Bredes 1723 Hamilton Avenue Executive Coordinator Suite K Shoreham Opponents' Coalition San Jose, California 95125 195 East Main Street Smithtown, New York 11787 Mr. Jay Dunkleberger Martin Bradley Ashare, Esq.

New York State Energy Office Suffolk County Attorney Agency Building 2 H. Lee Dennison Building Empire State Plaza Veterans Memorial Highway Albany, New York 12223 Hauppauge, New York 11788 Gerald C. Crotty, Esq.**

Counsel to the Governor Executive Chamber State Capitol Albany, New York 12224 Kathy f. B. McCleskey_

Hunton & Williams I 707 East Main Street l Post Office Box 1535 Richmond, Virginia 23212 l

DATED: June 15, 1984

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