ML20151T625

Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Licensee.* W/Certificate of Svc. Related Correspondence

ML20151T625
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/22/1988
From:	Harlow D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
References
CON-#288-6160 OL-3, NUDOCS 8804290086
Download: ML20151T625 (11)

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LILCO, April 22,1988 WTED CORRgsyggD$ ,

DOCKETED USHRC.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 18 APR 26 P2 :25 crLICE CF MUJIM Before the Atomic Safety and Licensing Board 00CKEig'g f C 1 In the Matter of )

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

- ) (Emergency Planning)

(Shoreham Nuclear Power Station, ) (Best Efforts Issue)

Unit 1)

IJLCO'S RESPONSES AND OBJECTIONS TO SUFFOLK COUNTY'S SECOND SET OF INTERROG ATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING CONTENTIONS 1-2,4-8, AND 10 TO TIIE LONG ISLAND LIGIITING COMPANY LILCO hereby responds to Suffolk County's Second Set of Interrogatories and Requests for Production of Documents, dated April 9,1988.

I. GENERAL ANSWERS AND OBJECTIONS TO INTERROGATORIES, DEFINITIONS, AND INSTRUCTIONS LILCO gives the same general answers and makes the same general objections to Suffolk County's Definitions and Instructions that it made in response to Suffolk County's First Set of Interrogatories and Requests for Production of Documents. See LILCO's Responses and Objections to Suffo'.R County's First Set of Interrogatories and Requests for Production of Doc-uments (March 30,1988), at 1-2.

II. ANSWERS AND OBJECTIONS TO INTERROGATORIES Suffolk County Interrogatory No.1 Does LILCO intend to pursue its "immateriality" theory with respect to Contentions 1 and 2 in the CLI-86-13 remand proceedings?

Response: Yes.

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Suffolk County Interrogatory No. 2 Unless the answer to Interrogatory 1 is negative, identify all witnesses who will testify on that issue, and for each such witness, identify the facts and opinions to which the witness will testify.

Response: LILC ) has already identified the witnesses it expects will testify in the "best ef-forts" remand proceeding. See LILCO's Responses and Objections to Suffolk County's First Set of Interrogatories and Requests for Production of Documents (March 30, 1988) and LILCO's Supplemental Responses and Objections to Suffolk County's First Set of Interrogatories and Requests for Production of Documents (April 1,1988). With respect to the immateriality issue, Mr. Behr, Mr. Crocker, Mrs. Dreikorn, and Mr. Weismantle will testify generally that implementation of a Shoreham evacuation "without traffic controls" would not "eliminate evacuation as a viable protective action." See CLI-86-13, 24 NRC 22, 31 (1986). Mrs.

Dreikorn will also testify to the immateriality of any increased doses which might result due to longer evacuation times in the event of an "uncontrolled" Shoreham evacuation. M r.

Lieberman will testify to the matters discussed in his affidavit, which is attached to LILCO's Motion for fsummary Disposition of Contentions 1,2, and 9 - Immateriality (Dec. 18, 1987).

Suffolk County Interrogatory No. 3 Identify all modifications to LILCO's traffic analysis which were incorporated into the revised evacuation time estimates of Revision 5 of the LILCO Plan ("Rev. 5"), including but not limited to, changes in methodology and in assumptions.

Response: The fellowing is a general description of the modifications which were made to the Revision 3 input streams to the DYNEV modeh Four new origin centroids were established within Zone Q to represent traffic that was previously assumed to use local streets in evacuating the network. Five new links were added in Zone Q to represent a collector road that was previously not included in the evacuation network. In the process,it was necessary to subdivide an existing link into two serial links in order to represent this new configuration.

It was also necessary to reassign traffic from an existing origin controid so that it was consistent with the new network configuration.

Changes which were responsive to the concerns expressed by the Suffolk County Police in their previous testimony were incorporated.

A complete audit was done of the previous simulation input stream and a few er-rors which were detected in the course of this audit were corrected.

A complete audit was done of the traffic assignment input stream and some of those inputs were refined.

There were no changes in methodology. An iterative procedure was again used in executing the traffic assignment model followed by execution of the traffic simulation model within the DYNEV system.

Suffolk County Interrogatory No. 4 Explain why EPZ Zone Q was reanalyzed to produce the revised evacuation time esti-mates in Rev. 5. Were any other subzones of the EPZ reanalyzed? If so, identify them and the results of the reanalysis of the additional subzones.

Response: As is indicated in LILCO's Response to Interrogatory No. 3 above, the review con-ducted to produce the updated evacuation time estimates (ETES) extended over the entire input stream. The changes in Zone Q were the only ones which took the form of changes in the representation of the evacuation network configuration. This change in network configu-ration reflected LILCO's belief that the previous estimate of the number of vehicles in that area evacuating via local roads might not realistically represent the actual traffic patterns in that area. This conclusion was based upon a careful review of the roadway geometrics in Zone Q. It was therefore decided to refine the previous analysis by extending the analysis network to include a north-south road called Crystal Brook Hollow Road, which extends from the vicin-ity of the coast, south to Route 25A.

Suffolk County Interrogatory No. 5 Identify and explain all factors which contributed to a reduction reflected in Rev. 5 of LILCO's uncontrolled evacuation time estimates.

Response: A general description of the factors which probably contributed to a reduction in the uncontrolled ETE for Revision 5 relative to those of Revision 3 is as follows:

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. . 4 The assignment of traffic (Le., the routing of evacuation traffic from the various origin-centroids within the EPZ along .the existing roadway system _ to the EPZ boundary) depends primatlly on-the "attractiveness" of one evacuation path relative to the other avail-able paths. .In other' words, there is a competition for service among the various vehicles which are seeking to evacuate or travel from within a given area.

The network configuration used for the Rev. 3 ETEs assumed that a significant amount

- of traffic originating in Zone Q used local streets exclusively to evacuate from that . zone.-

This representation meant that the northwestern routes which consist of Shore Road, Old Post Road and East Broadway; North County Road; and Route 25A were loaded with less traffic for the Rev. 3 calculations than for the Rev. 5 calculations. Thus, for the Rev. 5 representation these three evacuation routes serviced more traffic from Zone Q than was the case for Rev. 3 representation. Consequently, the "attractiveness" of these routes differed between the Rev.

5 and Rev. 3 studies. As a result, the traffic in Zone F, which is to the east of Zone Q and which uses the routes, was assigned by the DYNEV model differently in the Rev. 5 representa; tion than in Rev. 3. Consistent with the previous methodology, that is described in Appendix D of Appendix A of the LILCO Plan, an iterative procedure was undertaken for the Rev. 5 cal-culations in the same manner as for the previous set of ETEs. As part of this activity, LILCO

, . identified the need to change signal splits in rough proportion to the competing volumes of traffic at each node. This reassignment of traffic and the associated changes in signal splits that were necessary to respond to the resulting changes in link-specific traffic volumes are

probably the dominant factors in changing the ETEs for all case studies.

It appears that for uncontrolled evacuations, the new traffic patterns which resulted from thece analyses resulted in a somewhat more efficient usage of available capacity of the highway system in the northwest region of the EPZ. This conclusion appears to be supported by the results of the other sensitivity runs that were conducted for Rev. 5. Specifically, the increase in ETEs for the noncompliance cases implies that for the Rev. 5 runs, noncompliance i produces a less efficient usage of the existing highway roadway system than for the case where 100% compliance is assumed. For the Rev. 3 study, the effect of noncompliance was

virtually nil, relative to the 100% compliance case, since that case already represented a rela-tively inefficient usage of the available highway system.

This more efficient usage of the highway system in the uncontrolled cases outweighed the effect of the additional 1500 or so cars which were added to the evacuation network in the Rev. 5 study relative to the Rev. 3 study. These 1500 cars constituted less than 3% of the total demand. For the controlled case, the ETE did increase slightly in the Rev. 5 study rela-tive to that of Rev. 3.

Suffolk County Interrogatory No. 6 Was traffic in Zone F reassigned in the revised traffic analysis reflected in Rev. 5? If so, explain how such traffic was reassigned, the assumptions underlying the reassignment, the routes to which such traffic was reassigned, and the number of vehicles reassigned.

Response: As indicated in LILCO's Response to Interrogatory No. 5 above, a new reassignment was made, consistent with the methodology described in Appendix D of Appendix A, so that traffic everywhere in the EPZ was potentially "reassigned" in the revised traffic analysis re-flected in Revision 5. Absent a detailed review of computer output, these reassignments in Zones F and Q were the significant reassignments in the network.

Suffolk County Interrogatory No. 7 Identify and explain the criteria used to select additional roads in Zone Q for the as-signment of evacuating traffic.

Response: As noted in LILCO's Response to Interrogatory No. 4 above, only one additional col-lector road was added to Zone Q. This was the only road which crossed the three major east-west routes passing through Zone Q. Specifically, Crystal Brook Hollow Road crosses Old Post Road, North County Road, and Route 25A in addition tn acting as a collector road for residents in the area. While there are other collector roads in Zone Q (for example, Oakwood Road and Cliff Road), these roads merely act as conduits for traffic to enter an evacuation road; they do not act as conduits for traffic to travel between these east-west roads as does Crystal Brook Hollow Road. Consequently, it was concluded that introducing Crystal Brook Hollow Road to the evacuation network could have a meaningful impact on the rate of flow along the three

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evacuation routes identified earlier and would also serve as a means for traffic to distribute itself among those three roads.

Suffolk County Interrogatory No. 8 Identify all assumptions regarding the capacities of the additional roads referred to in Interrogatory 7 above.

Response: The estimates of capacity for Crystal Brook Hollow Road were derived using the same procedures as those applied for all the other roads within the EPZ network. Specifically, a field survey was made and the assessments were based thereon. It should be noted that the allocation of green time at those nodes where Crystal Brook Hollow Road intersects the three evacuation routes also influences the capacities of all approaches to these nodes. Specifically, the nominal capacities of the Crystal Brook Hollow Road approaches to Old Post Road, North Country Road, and Route 25A are, respectively, 270,270, and 240 vehicles per hour.

Suffolk County Interrogatory No. 9 Explain the basis for adding 1310 additional cars to the network in Zone Q for the Rev.

5 evacuation time estimate analysis.

Response: The basis for adding cars to the network in Zone Q was discussed in LILCO's Re-sponse to Interrogatory No. 4, above. It must be recognized that these "additional cars" do not represent an increase in the vehicle population of the area but rather in the way that traffic is represented in the input stream to the DYNEV model. Recent review of the computer out-puts indicates that the number of additional vehicles approximates 1500.

Suffolk County Interrogatory No.10 Explain the basis for the Rev. 5 assumption that approximately 300 cars from Zone Q will evacuate by local roadways not represented as links in the evacuation network. See Affi-davit of Edward B. Lieberman 15 (Dec.14,1987) (attached to LILCO's Motion for Summary

, Disposition on Contentions 1,2 and 9 -Immateriality (Dec. 18,1987))("Lieberman Affidavit").

l Response: Within Port Jefferson to the east of Main Street, there are many local streets which intersect directly with Main Street. Thus, there is the opportunity for residents in the area to avail themselves of these local streets and to depart from the EPZ by entering Main Street directly without recourse to any of the three east-west evacuation routes identified

previously. The estimate of 300 or so' vehicles which would use these local streets represents a conservative assessment of that usage.

Suffolk County Interrogatory No.11 Provide all documents, including computer inputs and outputs, concerning the revised Rev. 5 evacuation time estimates.

Response: LILCO is reviewing its records for documents that are responsive to this interroga-tory and will make such documents available for inspection the week of April 25,1988.

Suffolk County Interrogatory No.12 Explain why the Rev. 5 time estimates are more sensitive to non-compliance with as-signed routing than previous estimates. Identify and explain all factors which contributed to the increased sensitivity of the Rev. 5 time estimates to noncompliance with assigned routing.

Response: LILCO objects to Interrogatory No.12 as vague and ambiguous since the request to "explain why the Rev. 5 time estimates are more sensitive to noncompliance with assigned routing than previous estimates" can be construed to mean different things and it is unclear what the County intends. Without walving this objection,in an effort to be responsive to this request, LILCO directs the County's attention to the discussion of noncompliance in LILCO's Response to Interrogatory No. 5.

Suffolk County Interrogatory No.13 Explain specifically how the reassignment of traffic from two subzones in Zone F had the effect of decreasing the uncontrolled evacuation time estimate. See Lieberman Affidavit 1 7.

Response: See LILCO's Responses to Interrogatories Nos. 5 and 6, above.

Objections Stated by Counsdl All objections and references to objections were stated by counsel.

Respectfully submitted, AD (Jamd. Christman

5. @/-

Lee B. Zeugin David S. Harlow Counsel for Long Island Lighting Company Hunton & Williams .

707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: April 22,1988

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VERIFICATION Douglas M. Crocker, being first duly sworn on oath, deposes and says: that he is currently the Manager, Nuclear Emergency Preparedness, Nuclear Operations Support Department for Long Island Lighting Company; that he has personal knowledge of a portion of the subject matter of this litigation; that responsible corporate employees have provided him with additional facts necessary to provide the information contained in the foregoing Answers to Interrogatories; that he has read the answers, ion of which he has personal knowledge and with which heand knows the c informat has been provided, he is informed and believes the matters stated therein to be true, and on these grounds alleges that the matters stated therein are true and therefore verifies the forgoing on behalf of Long Island Lighting Company.

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Douglas M. Crockar State of New York SS:

I $7d b , a Notary Public in and for the jurisd1cM.on aforgtgid, hereby certify that Douglas M. Crocker whose d$e is sigM8 to the foregoing Answers to Interrogatories, date c:22. , 19 8 8, has personally sworn before me that the staterpents therein are true to the best of his knowledge and be1isf.

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My Commission expires:

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LILCO, April 22,1988 DM KETED U>NRC

'88 APR 26 P2 :25 CERTIFICATE OF SERVICE OFFICE (J Si.Qlt l At't 00CKEltNii & SEPVICL BRANCH In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S RESPONSES AND OBJECTIONS TO SUFFOLK COUNTY'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING CONTENTIONS 1-2,4-8, AND 10 TO THE LONG ISLAND LIGHTING COMPANY were served this date upon the following by Fed-eral Express as indicated by one asterisk, or by first-class mail, postage prepaid.

James P. Gleason, Chairman

• Adjudicatory File

. Atomic Safety and Licensing Board Atomic Safety and Licensing 513 Gilmoure Drive Board Panel Docket Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline

• Atomic Safety and Licensing Richard G. Bachmann, Esq.

• Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission One White Flint North East-West Towers, Rm. 427 11555 Rockville Pike 4350 East-West Hwy. Rockville, MD 20852 Bethesda, MD 20814 Herbert H. Brown, Esq.

• Mr. Frederick J. Shon

• Lawrence Coe Lanpher, Esq.

Atomic Safety and Licensing Karla J. Letsche, Esq.

Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 M Street, N.W.

4350 East-West Hwy. Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq.

• Secretary of the Commission , Richard J. Zahnleuter, Esq.

Attention Docketing and Service Special Counsel to the Governor Section Executive Chamber U.S. Nuclear Regulatory Commission Room 229 1717 H Street, N.W. State Capitol i Washington, D.C. 20555 Albany, New York 12224 Atomic Safety and Licensing

, Appeal Board Panel l U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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. Alfred L. Nardelli, Esq. Jonathan D. Feinberg, Esq.

Assistant Attorney General New York State Department of l 120 Broadway Public Service, Staff Counsel l Room 3-118 Three Rockefeller Plaza New York, New York 10271 Albany, New York 12223 George W. Watson, Esq.

• Ms. Nora Bredes William R. Cumming, Esq. Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Evan A. Davis, Esq.

Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New i .,rk 12223 E. Thomas Boyle, Esq.

Stephen B. Latham, Esq.

• Suffolk County Attorney Twomey, Latham & Shea Building 158 North County Complex 33 West Second Street Veterans Memorial Highway P.O. Box 298 .Hauppauge, New York 11788 Riverhead, New York 11901 Dr. Monroe Schneider Mr. Philip McIntire North Shore Committee Federal Emergency Management P.O. Box 231 Agency Wading River, NY 11792 26 Federal Plaza New York, New York 10278 3A3>5

[Daykrs. Harlow Ab Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212

~ DATED: April 22,1988 I

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