ML20206T607
| ML20206T607 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/13/1987 |
| From: | Baranski J, Czech L, Papile J NEW YORK, STATE OF |
| To: | |
| Shared Package | |
| ML20206T612 | List: |
| References | |
| CON-#287-3206 OL-3, NUDOCS 8704230210 | |
| Download: ML20206T607 (44) | |
Text
gno COMN Anril 13, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station,
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Unit 1)
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DIRECT TESTIMONY OF JAMES D.
- PAPILE, l
JAMES C. BARANSKI AND LAWRENCE B. CZECH ON BEHALF OF THE STATE OF NEW YORK REGARDING LILCO'S RECEPTION CENTERS I.
Introduqtion Q.
Please state your names, occupations, and experience.
A.
[Papile] My name is James D.
Papile.
I am currently the Director of the State of New York's Radiological Emergency Preparedness Group ("REPG"), a position which I have held for a little over a year.
Prior to that and since 1980, I was one of three Associate Planners for REPG.
In my seven years with REPG I have helped write and/or review numerous radiological emergency response plans.
As part of these efforts, I have become familiar 8704230210 870413 PDR ADOCK 05000322 T
- PDR, g
with the factors which must be addressed when evaluating the suitability of reception centers and the adequacy of monitoring and decontaminating procedures.
A copy of my resume is attached to this testimony as Exhibit 1.
(Baranski] My na'me is James C. Baranski.
I am a nuclear l
facility specialist with REPG and currently hold the additional position of Exercise Director.
I have been Exercise Director r
since January, 1985, and have been an emergency planning nuclear facility specialist since 1981.
I have had extensive experience with nuclear power operations, including eight years in the U.
S.
Navy Nuclear Power Program and six years as a Senior Reactor Operator at Indian Point Unit 3.
As a result of my duties with REPG, I have become familiar with the factors and standards to be considered in assessing whether reception centers are suitable for monitoring and decon-taminating evacuees and whether those factors and standards have been met.
A copy of my resume is attached hereto as Exhibit 2.
(Czech] My name is Lawrence B. Czech.
My current position is Chief of Nuclear Protection Planning with REPG.
In that posi-tion, I am responsible for the preparation, maintenance, revi-sion, and oversight of the State portion of the New York State...
J
Emergency Response Plan.
I am trained in health physics and have worked in the area of radiological health and radiation protec-tion for approximately 25 years.
Through my experience and training, I have become familiar with the evaluation of the adequacy of monitoring and decon-tamination procedures in a radiological emergency plan, as well as the adequacy of the facil.ities and staff dedicated to those activities.
A copy of my resume is attached hereto as Exhibit 3.
Q.
What is the purpose of your testimony?
A.
The purpose of our testimony is to address the suit-ability of the three facilities which LILCO designated in Revi-sion 8 of its Plan to serve as " reception cen~ters."
The three facilities are LILCO-owned operations centers located approxi-mately 40 miles west of the Shoreham plant in Bellmore, Roslyn and Hicksville (all of which are in Nassau County).
Egg Plan, at 3.6-7.1 Under the LILCO Plan, in the event of an accident at the Shoreham plant involving a release of radioactive materials, residents of the EPZ may be advised to proceed to the reception centers for radiological monitoring and, if necessary, decontami-nation.
Id.; OPIP 3.6.1, at 2.
Specifically, our testimony will address the adequacy of the LILCO's monitoring and decontamina-tion procedures described in Revision 8 of the LILCO Plan.
Where 1
All references to the LILCO Plan are to Revision 8, unless otherwise noted.
4 i l
possible, we will also discuss certain subsequent " draft" revi-sions of those procedures, contained in certain documents, dated February 20, 1987, which were provided during discovery.
They are Attachment P to LILCO's testimony and will be cited as the
" Draft Materials."
We focus on the following matters pertaining to LILCO's monitoring and decontamination procedures.
First, we testify regarding the new planning basis underlying LILCO's monitoring and decontamination procedures.
Second, we address the adequacy of the methods used by LILCO to monitor evacuees arriving at the three reception centers.
In conjunction with this testimony, we address the amount of time necessary to monitor arriving evacuees and their vehicles.
Third, we discuss the adequacy of LILCO's decontamination procedures.
Finally, we discuss whether LILCO has adequate staffing to provide necessary monitoring and decontamination services to evacuees arriving at its reception centers.
Our testimony is offered to assist the Board in resolving the following issues which have been admitted by the Board:
1.
Whether LILCO's new monitoring procedures are adequate; 2.
Staff requirements given LILCO's new reception center scheme; and... -
3.
Whe'ther the proposal to send evacuees to LILCO parking lots could or would ever be implemented in a way to protect the public health and safety.
Egg Memorandum and Order (Rulings on LILCO Motion to Reopen Record and Remand of Coliseum Issue) (December 11, 1986), at 17, 18-19.2 For reasons explained more fully below, we conclude that LILCO's Plan and procedures, as they pertain to the reception centers, are inadequate.
II. LILCO's Plannino Basis Q.
What does the term " planning basis" mean in the context of LILCO's reception centers and monitoring procedures?
A.
In the context of this proceeding, the term " planning basis" means the estimated number of people who may arrive at LILCO's reception centers for monitoring and, if necessary, decon-tamination.
Assuming that such an estimate is sound and based on prudent emergency planning principles, the emergency planner can 1
2 Our testimony regarding the actual time required to monitor evacuees is also relevant to the issues regarding traffic con-gestion in and around the reception centers, which are presently before the Board.
Id., at 7, 18-19.
As explained by the State's expert witnesses from the Department of Transportation, the abil-ity of the reception centers to function effectively is strongly affected by the rate at which LILCO can monitor arriving evacuees and their vehicles.
Direct Testimony of David T. Hartgen and Robert C. Millspaugh on Behalf of the State of New York Regarding LILCO's Reception Centers (April 13, 1987).
- i..
determine the number of personnel and the amount of equipment which must be provided at the reception centers for monitoring and decontamination purposes.
In addition, the emergency planner can determine whether the facilities provided as reception centers are physically capable of serving as reception centers.
This Board has previously found that LILCO's failure to provide an appropriate planning basis made it impossible for the Board to determine whether LILCO's earlier-designated reception center (the Nassau Coliseum) was suitable.
Concluding Partial Initial Decision On Emergency Planning, LBP-85-31, 22 NRC 410, 417 (1985).
Q.
What planning basis has LILCO chosen in developing the reception center-related portions of the most recent versions of its Plan?
A.
In the only " official" version of the Plan presently before the Board, which is Revision 8 of the LILCO Plan, LILCO has provided no planning basis regarding its reception centers.
Therefore, Revision 8 of the LILCO Plan suffers from the very same deficiency noted by the Board with respect to earlier versions of the LILCO Plan.
Judging from LILCO's testimony, however, LILCO appears to have adopted a 20-30% planning basis.
Egg also Draft Materials, Plan at 3.9-5.
Given the 1985 estimated summer population of the EPZ as 160,000 people, this means that LILCO claims to be provid-,
,e
ing planning and resources to monitor 32,000-48,000 people at its reception centers.
If more than that number of evacuees arrived for monitoring, LILCO would be required to rely on "ad hoc measures" to monitor any higher percentage of the population.
l Draft Materials, Plan at 3.9-5.
Q.
Is LILCO's apparent 20-30% planning basis appropriate?
A.
No.
In our opinion, an emergency plan and associated procedures should provide planning and identify resources (personnel, and equipment) to monitor 100% of the EPZ population
-- in this case, 160,000 persons -- within about a 12-hour period.
Q.
Please explain the reasons for your opinion.
A.
NUREG 0654 Section II.J.12 states:
Each organization shall describe the means for registering and monitoring of evacuees at relocation centers in host areas.
The per-sonnel and equipment available should be capa-ble of monitoring within about a 12-hour period all residents and transients in the plume exposure EPZ arriving at relocation centers.
(Emphasis added).
A common-sense reading of Section J.12 means to us, as emergency planners, that there must be planning for monitoring 100% of the EPZ population.3 NUREG 9654 requires planning for a spectrum of accidents, not just accidents affecting only 20 or 30% of the population.
Planning for monitoring 100% of the EPZ population is required to deal with the spectrum of accidents which are the basis for NUREG 0654.
This interpretation is consistent with comments we have received from FEMA personnel in the past to the effect that compliance with Section J.12 requires planning and resources for monitoring 100% of the EPZ population.
Nothing in Section J.12 suggests that a plan need only pro-vide personnel and equipment for 20%, 30%, or some other fraction of the EPZ population.
In addition, neither the LILCO Plan nor LILCO's testimony provides a reasoned basis for adopting a plan-ning basis as low as that found in the LILCO Plan.
In our opinion, no basis exists.
An accident at the Shoreham plant could require monitoring of a much larger fraction of the popula-tion than the 20-30% LILCO assumes; severe accident conditions might even require monitoring the entire EPZ population.
In fact, in the exercise of the LILCO Plan held on February 13, 1986, LILCO instructed (simulated, of course) over 95,000 people to report to its reception center (at that time the Nassau Coliseum) for radiological monitoring.
This scenario, which was 3
Note that while Section J.12 mentions " relocation centers,"
registration, monitoring and decontamination in New York State is typically done at " reception centers" with shelter provided at
" congregate care centers."
1
'part of LILCO's own exercise, demonstrates that it is reasonable d
for planning purposes to assume that a much larger number of i
people than merely 20-30% of the EPZ population will require or a
i seek monitoring.
l 4
In addition, we believe that it is probable that some people will seek monitoring even though not advised to do so.
This is j
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because radiation is perceived as a unique type of hazard.
People cannot determine whether they have come into contact with it without the use of special instruments.
People are also generally more fearful of radiation than other types of hazards.
This perception, coupled with the properties of radiation, make j
it likely that members of the public may travel to LILCO's reception centers to be monitored even though they have not been advised to do so, and even though they may not have an appropri-ate technological or scientific basis to believe that they have been contaminated.
This was demonstrated during the 1979 l
accident at TMI when some people appeared at the Albany Medical Center and requested to be monitored, even though they were 200 i
4 miles or more from TMI.
Furthermore, neither Revision 8 of the LILCO Plan nor the Draft Materials describe (nor could LILCO probably implement) any means to distinguish between evacuees from areas advised to seek i
i monitoring and those from other areas.
Those people seeking monitoring, but who do not really require it, will therefore be i
i l
t
-g-l 1
i
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. placing additional demands on the monitoring resources provided j
by LILCO under its Plan.
This means it will take longer to complete the monitoring of those who actually require monitoring and to identify those_who need decontamination.
4 In short, we believe that at a minimum, LILCO must plan and identify resources for monitoring gli EPZ residents within the I
approximately 12-hour time frame specified by NUREG 0654.
We consider this to be a prudent approach for emergency planners to take.
Anything less would mean that under certain accident situ-ations, LILCO would not have the resources or personnel to pro-I vide monitoring in a timely manner to those members of the public
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who need it.
i f
Q.
What are the implications of LILCO's intention to provide planning and resources for monitoring less than 100% of
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the EPZ population at its reception centers?
1 A.
LILCO's low planning basis means that in many accident scenarios, LILCO will be unable to meet the NUREG 0654 require-ment that all EPZ residents and transients arriving at LILCO's reception centers be monitored within approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
i
]
Delays in monitoring the public beyond the time frame set forth in NUREG 0654 will mean that those members of the public requir-i ing decontamination will not be identified in a timely manner.
Delays in decontamination could lead to unnecessary exposure to i
l ;
i
.__,_._,._.._m___.._....,_.
l l
l ionizing radiation.
One of the principal tenets of radiation l
protection is keeping exposures as low as reasonably achievable.
By falling to meet the guidance specified in NUREG 0654, the potential for unnecessary exposure is increased.
l l
l Q.
What does LILCO rely upon to support the 20-30%
1 planning basis set forth in the Draft Materials?
A.
LILCO's apparent basis is a December 24, 1985, memo-randum authored by Richard W. Krimm, Assistant Associate Director for State and Local Programs and Support, Federal Emergency Management Agency.
The Krimm Memorandum, which is Attachment L to LILCO's testimony, states that Section J.12 of NUREG 0654 is met where planning and resources are provided for 20% of the EPZ population.
If more than 20% of the EPZ population arrives at an applicants' reception centers, unspecified "ad hoc" measures are to be developed and implemented during an accident.
Q.
Do you agree with the Krimm Memorandum and the 20%
planning basis it suggests?
A.
No.
First, for the reasons explained above, the Krimm Memorandum is in conflict with the plain language of Section J.12 and the guidance which we have previously received from FEMA personnel interpreting this provision..
I i
1 i
Second, the basis for the Krimm Memorandum is not clear.
The Memorandum notes in the second paragraph that while " previous I
experiences" in unspecified natural and technological emergencies j
are "not conclusive," "research" shows that "anywhere from 3 to i
20% of the evacuees arrived at relocation centers or shelters."
LILCO Attachment L at 1.
It appears, however, that this range of percentages is derived from the number of people who have sought I
I shelter, not monitoring, in previous emergencies.
The Krimm i
Memorandum then concludes that because people will want to allay their concerns about radiation, the upper bound of the 3 to 20%
1 shelter-seekina range is appropriate for determining the number 3
i of people who will go to reception centers for monitorina, i
l The Krimm Memorandum confuses two separate functions --
seeking shelter on the one hand and seeking monitorina on the i
1 t
l other hand.
Using data pertaining to shelter-seeking to support I
estimates of those in need of monitoring, as the Krimm Memorandum does, is contrary to this Board's and the Appeal Board's conclusions that the former provide no support for the latter.
i l
ALAB 855, 24 NRC (Dec. 12, 1986) slip op. at 9, 16-17
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("ALAB-855"); LBP-85-31, 22 NRC 410, 417 (1985).
In rejecting I
LILCO's previous attempts to confuse the two distinct functions, the Appeal Board stated in ALAB 855 thats t
l 1
l t
i i
i !
1 l
5
LILCO's planning estimate simply failed to take into account that radiological accidents produce a category of individuals who require monitoring and decontamination, even if they do not require sheltering.
ALAB 855, slip. op. at 9.
The Appeal Board went on to state that:
Surely, the need of evacuees for monitoring and decontamination services does not hinge to any extent upon whether they have been able to make their own sheltering arrangements.
It seems highly probable that many individuals who manifestly should be monitored as a matter of caution will both wish and be able to obtain sheltering at other than a facility supplied by LILCO or another participant in the emergency response plan.
Id., slip op. at 16, 17 and n. 31.4 Finally, the Appeal Board stated that in this reopened pro-ceeding, LILCO's 20% planning basis could be reasserted before the Licensing Board, but that LILCO's claim that this figure was adequate " appears to us to be of dubious validity."
Id. at 18.
4 Sit Alan this Board's concluding Partial Init'a' Decision on Emergency Planning, LBP-85-31, 22 NRC 410, 417 (1985) in which this Board found that the number of persons expected to seek shelter in the event of a disaster is not necessarily the same as the number of persons who might seek monitoring in the event of a radiological accident.
4 Likewise, the Krimm Memorandum must be considered to be of
" dubious validity."
For the same reasons articulated by this Board and the Appeal Board in rejecting LILCO's attempt to link a sheltering planning basis with a monitorina planning basis, the Krime Memorandum must be rejected.
The Krimm Memorandum is also inapplicable because it does not address the circumstances which would apply to an emergency response under the LILCO Plan.
If a release of radioactive mate-rials occurs during an accident at Shoreham "with the potential to contaminate evacuees," those evacuees will be instructed by EBS messages to proceed to LILCO's reception centers for monitoring.
i Plan, OPIP 3.6.1, at 2.
The Krimm Memorandum does not appear to take.into account what will occur when evacuees are instructed to go to a specific site for monitorina or analogous reasons.
Under certain conditions, far more than 20% of the population may be told to do so.
FEMA has no basis for suggesting that at most only 20% of EPZ residents would comply with this instruction, or that it is permissible under NUREG 0654 Section J.12 to rely upon ad hoc measures for evacuees in excess of a particular fraction of the EPZ population.
We should also note that the Krimm Memorandum was never brought to our attention by FEMA, and we were only made aware of it at the commencement of the most recent reception center litigation by our counsel.
This is contrary to FEMA's normal.
l procedure of providing us with applicable guidance.
If FEMA seriously intended the Krimm Memorandum to be implemented as j
general guidance, we believe FEMA would have circulated the Krimm Memorandum (or the substance of it) to us and to others.
In short, based upon our experiences in conducting federally-evaluated exercises and our experience in the FEMA plan review process, the State's interpretation of NUREG 0654 Section J.12 is that there must be planning and identification of resources for monitoring 100% of the population of the EPZ within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
We thus conclude that LILCO's 20% planning basis is inade-quate for proper emergency planning, and that the Krimm Memorandum provides no support for that planning basis.
i i
III. Knaltorina Methods i
1.
Backaround i
Q.
What is your understanding of how LILCO intends to moni-tor evacuees?
A.
Different procedures are described in Revision 8 and the Draft Materials.
In both cases, however, the pertinent informa-tion is contained mostly in OPIPs 3.9.2 and 4.2.3.
Under Revision 8 of the LILCO Plan, evacuees arriving in private vehicles enter the parking lots of the three reception centers and proceed to 6
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monitoring stations, each of which is manned by two LILCO monitors.
There are 14 stations at Bellmore, 10 stations at Roslyn and 24 stations at Hicksville.
One LILCO monitor scans the hands and feet of the driver of the vehicle.
Vehicle passengers are not monitored at all.
The monitoring of the driver is done while he remains seated in the car.
The other monitor takes a
" swipe" of the top of the hood and a " swipe" from the wheel well.
Both swipes are then monitored for contamination.
OPIP 3.9.2, at 9-9a; OPIP 4.2.3, at 5-6, 15.
If the vehicle and the driver are determined to be " clean,"
any passengers are also assumed to be clean and the vehicle is directed out of the parking lot.
If levels of contamination are discovered'above acceptable levels, then the vehicle and its occupants are directed to a decontamination trailer located within the LILCO parking lots.
OPIP 3.9.2, at 49a; OPIP 4.2.3, at 5-8.
LILCO estimates that monitoting a vehicle and its driver will take approximately 35 seconds per vehicle.
OPIP 4.2.3, at 6.
In contrast to the procedure used for persons arriving by private vehicles, people arriving by buses (11a2, those without their own means of transportation) are taken to the Hicksville i
reception center where they receive a full body scan, including a thyroid scan.
OPIP 3.9.2, at 6-8.
LILCO estimates that this j -
procedure will take about 90 seconds, not including the thyroid scan which would take an additional five seconds for an adult and an additional 30 seconds for a child.
OPIP 3.9.2, at 7-8.
Under the Draft Materials, it appears that LILCO now intends to monitor all persons, passengers included, in an arriving private vehicle.
The areas of the body to be monitored have also been expanded to the head, shoulders, feet and hands.
The vehicles themselves are to be monitored by taking a swipe of about one quarter of the front of the hood and one wheel well.
L'ILCO estimates that this process will take approximately 100 seconds per vehicle.
Draft Materials at 3.9-5, OPIP 3.9.2, at 9-9A.
LILCO also estimates in the Draft Materials that it has sufficient resources and personnel to monitor about 30 percent of the EPZ population within the time constraints of NUREG 0654 using this procedure.
Draft Materials, Plan at 3.9-5 through 3.9-6.
If (by a procedure not specified by LILCO) it is determined that a greater number of evacuees will require monitoring, LILCO will ask the Institute of Nuclear Power Operations ("INPO") for additional monitors to staff additional monitoring stations.
If (again under unspecified criteria or procedures) it in determined that timely INPO assistance is not forthcoming, or will not be adequate, LILCO's monitoring procedures will revert to the proceduren not forth in Revision 8 -- that is, only the driver of an arriving vehicle will be monitored.
Draft Materials, Plan at 3.9-5A. -
Bus evacuees appear to be treated the same way under the Draft Materials as under Revision 8, except that under the Draft Materials, the monitoring will be done on the bus.
Monitoring is l
still estimated to take 90 seconds for each bus evacuee.
Draft Materials, OPIP 3.9.2 at 9b.
2.
Concerns About Monitorina Techniouen Q.
In your opinion, are LILCO's monitoring procedures ade-quate to protect the public health and safety in the event of an l
accident at Shoreham?
l A.
No.
Let un first addreno the procedure set forth in the only official version of this Plan before this Board, which is Revision 8 of the LILCO Plan.
LILCO's Reviolon 8 monitoring procedure calla for monitoring an arriving vehicle and its driver only.
That procedure in contrary to NUREG 0654 which calla for monitoring all arriving evacueen, not just drivern.
In addition to being contrary to NUREG 0654, LILCO's proposal to monitor only arriving drivers in fundamentally unsound.
The 1
apparent bania for thin procedure in that if the driver in not contaminated, the pannengern of the vehicle may be annumed to be uncontaminated as well.
Thin LILCO annumption, however, does not i
logically follow.
For instance, the driver of a vehicle may have come from a different point within the EPZ than his pannengern; or l
l l
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l he may have been indoors during the passage of the plume while l
passengers were outdoors.
In short, it is improper for LILCO to assume that a passenger in a car is " clean" if the driver is
" clean."
Indeed, the Regional Assistance Committee ("RAC") found Revision 8 to be inadequate for, among other things, precisely l
this reason.
A copy of the pertinent portion of the RAC's findings, dated December 15, 1986, is attached hereto as Exhibit 4.
We agree with the RAC on this point.
t t
Second, monitoring the hands and feet only of any individual is not adequate.
This procedure could cause a monitor to miss l
other parts of the body that may be contaminated.
In our opinion, the best procedure is to give each arriving evacuee a whole-body scan as was done in previous versions of the LILCO Plan and as is done for bus evacuees.
This procedure takes. longer, but it pro-vides greater protection for the public.
There is no supportable reason for evacuees arriving by private vehicle to be afforded less protection than evacuees arriving by bus.
Third, we believe that LILCO's procedure for monitoring vehicles is also inadequate.
Vehicle monitoring is limited to a i
" swipe" of the front hood and of a wheel well.
This is not l
enough.
In our opinion, the outside surface of the entire vehicle should be monitored.
Anything less means that possible " hot l
l spots" might be missed.
This in turn could lead to the eventual contamination of other thingo or people coming into contact with i
those vehicle areas that LILCO's procedures ignore.
In addition, we believe that the trunk of a vehicle should also be monitored if there are indications of contamination in other parts of the car.
It is possible that contaminated items taken from the EPZ may have been placed in the vehicle trunk.
To our knowledge, the LILCO Plan has no provision for monitoring the trunks of cars.
The Draft Materials, which are meant to be an improvement on Revision 8, also contain several deficiencies.
First, it should be noted that the monitoring of arriving vehicles is to be done in the same basic way as under Revision 8.
This is still inadequate for the reasons stated above.
i Second, while the scope of evacuee monitoring has been increased somewhat, neveral problems still remain.
For instance, while the Draft Materials now call for passengers to be monitored, as well an drivern (at least until the equivalent of 30% of the EPZ residents arrive), it should be noted that the monitoring of l
all vehicle occupanto in to be done inside the vehicle.
We are not necennarily opposed to this procedure, but it han drawbacks.
Monitoring pannengern inside an automobile in, to say the least, awkward.
Monitors are going to have to reach into arriving vehicles with their proben and, in nome canon, even crawl into the automobilen.
Monitoring people in the back neatn of two-door l
vehicles will be especially difficult.
Our concern with thin 7
procedure in that LILCO han apparently devised it an a meann of
l monitoring large numbers of people quickly.
Indeed, LILCO seems to believe that a vehicle and all of its occupants can be scanned in only 100 seconds.
Draft Materials, Plan at 3.9-5.
As dis-cussed below, we dispute this time estimato.
However, no matter what the circumstances, monitoring must be done carefully.
Monitoring passengers while they are seated in locations which are accessible only with difficulty may cause improper scanning and inaccurate results.
Inaccurate monitorlag results can lead to undetected contamination which could, in turn, lead to adverse health consequences.
I Third, we also note that while additional areas of the body are being monitored, LILCO is still not providing a whole-body survey.
Thus, areas of possible contamination may be missed, especially on the back of the shoulders.
We find this to be unacceptable.
I Fourth, we do not agree with LILCO's intention to provide monitoring for all arriving evacuees only until it appears that I
more than 30% of the EPZ population will arrive at the reception centern, at which time LILCO intends to revert to the Revision 8 procedure that was previously found to be inadequate by the RAC (i.e. - driver's hands and feet only are monitored).
For the same reasono that the procedure in Revision 8 in inadequate, the " fall- - - - -
back" procedure set forth in the Draft Materials is also inadequate.
As stated above, in our opinion LILCO must provide monitoring for all evacuees arriving at the reception centers.
We are also skeptical about INPO's ability to provide personnel and resources in time to assist LILCO in meeting Section J.12's 12-hour time limit.
Our skepticism is supported by events at LILCO's February 13, 1986, exercise during which INPO was contacted for the purpose of providing additional monitoring personnel.
INPO reported that the arrival times of additional personnel ranged from six to seven hours up to 15 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.
This highlights the need for L",CO to provide more of its own resources and personnel sufficient for it to monitor the entire EPZ population.
3.
Record Keeoina Q.
Do you have any other concerns about LILCO's monitoring procedures?
A.
Yes.
We have an additional concern about inadequate record keeping.
Under the Draft Materials, the Traffic Guide assigned to each monitoring station is instructed to record the license plate of each vehicle monitored at his station and the number of people in each car.
This is not sufficient.
In our opinion, it is important to record the names of all people who -
have been monitored, whether they are contaminated or not, and, if possible, to record their intended destination.
We have found in our experience with other emergencies that it is important to record the identities of all people going through reception centers for purposes of reuniting families, providing data for medical follow-ups, and other such reasons.
It is also useful to determine evacuees' destinations so that LILCO can respond appro-priately to inquiries from anxious relatives or others regarding the whereabouts of particular evacuees.
4.
Time Reauired to Monitor Q.
You stated earlier that LILCO estimates that under the monitoring procedures established in Revision 8, a vehicle and driver can be monitored in approximately 35 seconds and that under the procedures established in the Draft Materials, a vehicle and its occupants can be monitored in approximately 100 seconds.
Do you agree with LILCO's estimates?
A.
No.
Preliminarily, we wish to stress that monitoring must be done carefully.
The movement of the monitoring probe over the body cannot be too swift, otherwise an inaccurate reading will result.
Likewise, ignoring areas of the body or of a vehicle means that contaminated areas may be missed.
For this reason, we generally estimate that it takes two to three minutes to monitor a person and two to five minutes to monitor a vehicle.
Regarding the procedures used in Revision 8 (the driver-enly procedure), 35 seconds may well be the amount of time required to l'
complete them.
However, for the reasons we discussed above, those procedures are so inadequate that the 35-second time frame established by LILCO is meaningless.
A poor procedure is not made better by the fact that it can be done quickly.
With respect to the February 20 draft revision, LILCO's 100-second estimate is based on two time trials conducted on January 5 and February 10, 1987.
Egg LILCO Testimony at 42.
However, the data from those time trials are suspect for a number of reasons and do not support LILCO's 100-second estimate.
First, the vehicles were monitored using the methods which we have already testified could leave much contamination undiscovered.
Monitoring.
a vehicle properly takes more time -- between two and five 1
minutes.
Second, the 100-second estimate fails to account for activi-ties other than scanning arriving evacuees and their vehicles.
For instance, the time trials did not adequately measure '.he time necessary for cars to pull up to the monitoring stations and then drive away after the monitoring process is complete.
This factor is especially important because cars will be entering most of the monitoring stations in lines of from two to four cars.
Egg Plan, OPIP 4.2.3 at 17, 21, 25; Draft Materials, OPIP 4.2.3 at 17-17a, i
21-21a,25-25a.
Using this method, a second line of cars cannot
- l
be pulled in to the monitoring stations until the last car of the previous series has been monitored and all cars are moved out.
The trials did not adequately test the scope of delays inherent in moving cars in and out of the monitoring stations in series.
In addition, the time trials did not take into account the time necessary to respond to questions posed by drivers or the vehicle occupants, which could cause additional delays.
Third, the time trials were done in a controlled atmosphere and not at the reception center sites.
In particular, the January time trial was conducted only by LILCO monitoring instructors, not LILCO monitors themselves.
The time trials were also held in favorable conditions.
The darkness of night, or bad weather, might delay the monitoring even further.
Moreover, because only a limited number of trials were conducted, such factors as fatigue or stress were not taken into account.
Fatigue or stress would slow monitoring times to well below the swift pace set by LILCO.
Fourth, the 100-second time estimate does not take into account possible equipment breakdowns, vehicle breakdowns, or other such " glitches".
Finally, it must be remembered that monitors are going to have to reach into or climb into the vehicles arriving at the monitoring stations.
If this is the way LILCO intends to monitor people, then extra care must be taken to assure that the monitoring is conducted properly.
This means j
taking more time than the 100 seconds which LILCO assumes.
1 i
In short, we find LILCO's 100-second time estimate unrealistic.
Even conceding that some time may be saved by using LILCO's procedures, we estimate that it would actually take at least three to five minutes to monitor each arriving car and its passengers.
Q.
What are the consequences of your more realistic esti-mates of the time required to conduct proper monitoring of evac-uees in vehicles?
A.
Using more realistic estimates means that LILCO has provided planning, personnel, and resources for even less of the population than the 30% it assumes in its Draft Materials.
Given the three to five-minute estimate set forth above, we calculate that LILCO actually has the resources to monitor only from 10 to 17% of the EPZ population in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
5.
Staffina Q.
Based on your testimony so far, what are your opinions regarding the number of personnel provided by LILCO for monitoring evacuees at the reception centers?
A.
Staffing levels are not adequate.
Under Revision 8 of the Plan, only 48 monitoring stations (14 at Bellmore, 24 at Hicksville, and 10 at Roslyn) are provided.
OPIP 4.2.3, page 15 of 29.
Under the Draft Materials, only 10 more stations have purportedly been added, even though all arriving evacuees are to be monitored (until arrivals exceed 30% of the EPZ population).
According to its t(stimony, LILCO intends to add 3 more stations.
This addition of only 13 more monitoring stations is not sufficient.
As we denonstrated above, LILCO has provided only enough monitoring stations and staff to monitor from 10 to 17% of the EPZ population.
This is inadequate, even under LILCO's own planning basis.
Again, however, we emphasize that in our opinion Section J.12 requires that for planning purposes, LILCO must provide monitoring personnel and resources sufficient to monitor all EPZ residents.
IV.
Decontamination Proced,Legg Q.
How is Jecontamination of evacuees to be conducted under the LILCO Plan
- A.
Under both Revision 8 and the Draft Materials, decon-j tamination of evacuees who :equire it is to be conducted in
- railers equipped with sinks and showers.
There will be two
.. callers located at Hicksville, but only one trailer each at Bellmore and Roslyn.
Each trailer has nine sinks and 20 shower heads.
San Draft Materials at 3.9-5A.
h !
At the trailers, contaminated individuals are remonitored, and instructed to remove contaminated clothing.
Then the skin underneath the contaminated clothing is monitored.
If the skin is contaminated, the individual is instructed to wash himself using a four-step process, with the contaminated area monitored between each step.
OPIP 3.9.2, at 10.
If successfully decontaminated, the person is given paper clothing.
Egg LILCO Testimony at 55.
l However, it is not clear where a decontaminated person goes after receiving the paper clothing (which is of some concern if that person's vehicle is still contaminated and he cannot therefore drive himself to shelter).
If the person cannot be decontami-nated, he is expected to drive himself to an unspecified hospital for further treatment.
OPIP 4.2.3, at 7.
People awaiting decontamination are to be kept in the
" transportation buildings" at Hicksville and Bellmore and the
" warehouse in Roslyn."
Draft Materials, OPIP 4.2.3, at 8.
Q.
What concerns do you have about the adequacy of these procedures?
A.
Initially, we are concerned about whether the number of trailers, with only one trailer each at Bellmore and Roslyn, is enough.
As demonstrated by the testimony of the New York State Department of Transportation witnesses (Direct Testimony of David T. Hartgen and Robert Millspaugh on Behalf of the State of New __
York Regarding LILCO's Reception Centers), in a serious accident people may have to wait a long time for decontamination because of the lack of adequate showering and washing facilities.
Unfortu-nately, LILCO has not yet obtained the trailers, so that we have been unable to inspect them.
However, it must be questioned whether the trailers will be big enough to accommodate sufficient LILCO monitors and evacuees.
The Plan also does not indicate how long it will take to set up the trailers for their intended purposes.
If people do have to wait to be decontaminated, LILCO has provided inadequate facilities for sheltering such people.
The
" transportation buildings" at Hicksville and Bellmore are garages which are inappropriate for personnel and provide little space to sit, except on the floor.
The heavy equipment found throughout those buildings also presents a dangerous environment for evacuees.
The Roslyn warehouse is also unsuitable for keeping people awaiting decontamination.
Its floor space is filled with shelves containing various electrical equipment.
Thus there is very little space to put people.
We also have concerns about LILCO's issuance of paper clothing.
While the use of such clothing is in most instances appropriate, it may not be appropriate under the LILCO Plan because LILCO is providing virtually no shelter for people arriv-ing at the reception centers.
This is especially true at Bellmore..
and Roslyn where there is very little suitable sheltered space.
Thus, people may be exposed to adverse weather conditions in nothing more than paper clothing.
We note that LILCO attempts to address this point in its testimony by stating that it may be able to obtain blankets from " local suppliers" (LILCO Testimony at 55);
1 however, this proposed ad hoc response does not assure that appropriate clothing or other materials will in fact be available.
Finally, in our opinion it is absolutely wrong for LILCO to expect a contaminated person who cannot be decontaminated at the reception centers to drive himself to a hospital.
A person told that he has contamination which cannot be removed by normal means is likely to be distraught and scared.
Evacuees in that condition should not be-left alone and certainly should not be sent back onto the road to drive in what will already be a stressful and congested environment.
l V.
Conclusions Q.
Please state your conclusions.
A.
LILCO's Plan and procedures for monitoring and decon-taminating evacuees are inadequate.
The planning basis adopted by LILCO, in our opinion, is not in accordance with NUREG 0654 Section J.12.
The Krimm Memorandum does not provide a basis for LILCO's inappropriately low planning basis. -
In addition, the methods to be used by LILCO for monitoring I
evacuees, both under Revision 8 and the Draft Material, are inade-quate and could lead to unnecessary exposure to radiation.
LILCO has also underestimated the time required to monitor evacuees and their vehicles.
This, of course, means that LILCO will actually be able to provide monitoring to less than 30% of the population Jithin the approximately 12-hour time limit of NUREG 0654 Section J.12.
With respect to staffing, LILCO has not provided sufficient staff to monitor 100% of the EPZ population.
In fact, given its underestimation of the time required to monitor evacuees and their automobiles, LILCO appears to have provided sufficient staff to monitor only 10-17% of the EPZ population.
Finally, we are concerned that LILCO may have insufficient capacity in its proposed trailers to decontaminate those requiring decontamination in a timely manner.
In addition, LILCO's decon-tamination procedures have not provided adequate space for people requiring decontaminatian.
Q.
Does this conclude your testimony?
A.
Yes, it does. -
EXHIBIT 1
EXHIBIT 1 James D. Papile 6 Capital Avenue Delmar, New York 12054 OBJECTIVE To obtain a management position which will allow me to use executive management and analytical experience.
SUMMARY
OF QUALIFICATIONS Extensive experience in planning, programing, budgeting and management for Advanced degree in management large procurement and maintenance program. Advance education in field of business to include systems analysis.
education. Completed over 30 years regular Army Service as a Colonel.
CIVILIAN RELATED MANAGEMENT _
Director, Radiological Emergency Preparedness Group for 1986 - Present_:
the State of New York.
1980 - 1985: Associate Planner with the New York State Radiological Emergency Preparedness Group involved with writing and addressing County, Utilities and State plans for handling emergencies at Nuclear Power Plants.
i 1979 - 1980: Deputy Commander, Task Force Lake Placid for State of New York during the 1980 Winter Olynpics. This Task Force provided logistic and administration support to the US Olympic Committee prior, during and after the 1980 Winter Olympics.
Supervised an organization of 29 personnel in 14 locations 1976 - 1979:
throughout State of New York. Advisor to the Chfef of Staff to the Governor of New York as well as to members of his office. Acted as President of various boards in the handling cf personnel and logistics matters.
Deputy Program Manager for weapons procurement program which 1975 - 1976:
include the modernization of equipment to save the government millions of dollars.
The program included procurement of components, parts and equipment as well as providing the facility to have the job done.
Monitored government procurement procedures from writing of Referral for
)
Bids through award and production.
1973 - 1975: Chief of Maintenance, Rebuild and Overhaul Program which included all types of equipment. This world wide program was budgeted f6r As Chief, was required to plan approximately One Billion Dollars per year.
programs and budget over a five year period and then defend the program before Budget Analyst and Congressional Staffers. The management of.the program required knowledge of systems analysis, computer oriented programs and a thorough knowledge of the Budget System.
EDUCATION Industrial College of Armed Forces 1973 - Master of Science, Logistics Management Air Force Institute of Technology 1967 - Graduate School of Education, Boston University 1950 - Bachelor of Science in Business Administration, Northeastern University 1949 - Majored in Accounting.
Awarded permanent Teaching Certificate for Business Education, State of New York.
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EXHIBIT 2
EXHIBIT 2 RESUME JAES C. BARANSKI Business Address:
Radiological Emergency Preparedness Group State Campus, Public Security Building Albany, New York 12226-5000 Education:
Formal Training for Senior Reactor Operator Obtained SRO License #2102 May 1972 - April 1974 Westchester Community College, Valhalla, New York A.A.S. in Business Administration September 1973 - August 1976 Iona College, New Rochelle, New York B.S. in Business Administration August 1976 - December 1977 Experience:
January 1985 to present: Exercise Director, Radiological Emergency Preparedness Group (REPG).
Lead responsibility for scenario writing, offsite exercise planning and development of offsite objectives.
Coordinates development of onsite/offsite scenario among Federal, State, counties and nuclear utilities to meet necessary objectives.
Responsible for ensuring that drills and exercise activities are perfonned to maximize training requirements and meet defined objectives.
Decembe'.- 1981 - January 1985: Emergency Planning Nuclear Facility Spec:lalist, Radiological Emergency Preparedness Group.
Prov;ide immediate concise technical evaluations to Senior State decision-makers during actual emergencies (Ginna), drills and FEMA evaluated exercises. Provide technical support and interface with the nuclear facilities, NRC and FEMA in preparation of drill scenarios.
Develop, implement and conduct technical training for State Commissioner, County Executive Officers and Health Officers, county dose assessment staff, public information staff and other REPG staff.
OctobeI1978-Cecember1981:
Nuclear Facility Specialist, New York State i
Enetgy Office, Nuclear Operations.
^
Perform reviews, analyze and prepare recommendations on safety related b
e l
components, systems, technical specifications, and operating, maintenance and testing procedures for nuclear power plants proposed and operating in New York State. Maintain an awareness of safety related problems, l
reportable occurrences, at nuclear plants throughout the State and United States, and determine the safety significance for each of the nuclear plants operating within State.
i JAMES C. BARANSKI Indian Point Unit #3 Senior Reactor Operator _,
May 1972 - October 1978:
Consolidated Edison of New York Inc., New York, New York.
Responsible for the safe and efficient plant operation in accordanceSupervi with all Federal, State and local and company regulations.
and coordinate all testing activities associated with the operationC and operability of plant equipment.
room operation and three plant operators.
Indian Point Unit #3 Test Supervisor.
i During construction phase of I.P. f3 coordinated and directed plant 1
Responsibilities activities associated with the start-up program.
included writing I.P. #3 operating and emergency procedures, completing start-up procedures and instituting changes to procedures when applicab Mechanical Plant Operator, Connecticut Yankee January 1971 - May 1972:
Power, Haddam Neck, Connecticut.
Worked on all reactor plant, steam plant and auxiliary systems including During refueling temporarily new fuel, spent fuel handling and movement.
assigned as a Health Physics Technician working primarily on steam g tube plugging project.
United States Navy (Nuclear Power Program).
September 1962 - December 1970:
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t l
. I EXHIBIT 3
,,u
EXHIBIT 3 RESUME LAWRENCE B. CZECH Business Address:
Radiological Emergency Preparedness Group State Campus, Public Security Building Albany, NY 12226-5000 Education:
B.S. Physics - State University of New York at Albany January 1960 M.S. Physics - State University of New York at Albany June 1961 Experience:
January 1981 to present: Chief, Nuclear Protection Planning, Radiological Emergency Preparedness Group (REPG).
Duties include providing radiological (health physics) input for the State's emergency preparedness efforts for operating nuclear power reactors; assisting local officials in preparation of federally required local (county) plans and implementing procedures; participate in exercises and drills; coordinating the State's emergency plans and procedures with responsible officials in the States of Vemont, Massachusetts, Connecticut, and the Province on Ontario, Canada; coordinating the State's planning activities with the operating licensee's staff; and assisting in training for response to radiological emergencies. Currently responsible for maintaining and updating the State portion of the Radiological Emergency Preparedness Plan and acting as a REPG liaison to Orange County.
May 1972 to January 1981:
Principal Radiological Health Specialist.
Emergency Plans and Special Projects Unit, Bureau of Radiological Health, New York State Department of Health.
Duties included developing and maintaining the general New York State radiation emergency plan for fixed nuclear facilities, assisting local disaster coordination agencies in developing local procedures to implement protective actions, and developing procedures for response to radiation accidents and incidents; i.e., spills, lost sources, overexposures and transportation incidents.
September 1970 to May 1972:
Senior Personnel Examiner, New York State Department of Civil Service.
Duties included development of written engineering and technical j
examinations for State and local merit system appointments.
February 1966 to September 1970:
Senior Civil Defense Radiological i
Representative, New York State Civil Defense Commission.
Duties included civil defense radiological training and planning activities.
LAWRENCE B. CZECH 2
September 1965 to February 1966: Science Teacher, W. H. Lynch High School, Amsterdam, New York.
Duties involved teaching of high school physics and chemistry.
June 1961 to September 1965:
Senior Biophysicist, Radiological Sciences Laboratory, Division of Laboratories and Research, New York State Department of Health.
Established and operated a calibration facility for radiation survey instruments used by State and local realth regulatory personnel.
l
4 EXHIBIT 4 t
I i
EXHIBIT 4 LILCO Transition Plan for Shoreham - Revision _t Key to Consolidated RAC Review Dated Dccomber 18,1984 The Regional Assistanee Committee (RAC) review of the LILCO Transition Plan for Shoreham (Attachment 0 is based upon planning eriteria speelfled la NUREG-4484, FEMA-REF-1, Rev. Is Celteria for Pr6paration and Evaluation of Radletorleal Emerzener Response Plans and Preparedness la Sucoort of Nuclear Power Plants.
November,1944. The plan has been evaluated agalast each planning element speelfled la NUREG-4654 applicable to State and/or Localjurisdictions. These evaluations are keyed to the following rating systems l
ADEQUATE RATING A (Adequate)
A* (Adequate - eooeerns pertalains to LERO% legal authority identitled durlag this review) i The element is adequately addressed la The element is adequately addressed la
,the plan.
Recommendations for the plea provided eoneerns portalalag improvement shows la italie are not to LERO's legal authority are resolved.
i l
mandatory, but their consideratlom The lesues of legal authority affeet-i would further Improve the LERO plan.
lag these elements are desertbed la These recommendatless include Attachment t to the RAC review of revisloes to the NUREG-4484 eross-Revision'S.
referenes, and other alaer leprovementa.-
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1 LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1986 Page 11 of 15 WUREC-0654 Rating Element Review Comment (s) j J.10.k In response to an exercise lasue, the plan been (Cont'd) revised to add a traffle engineer to the f at the OC to evaluate any possible Impedim ts to evae-a on and to make recommendatto on necessary i
c ges to evacuation routes in te nse to poten-tial Impediments.
Procedures e field workers, i
I.e.,
us drivers, traffic guld, ete., have been modif d to include Instrue ns to make prompt notifica ons through their ommunication network of any ential Imped!
nt. Provisions have been made to ue an E message la the event that changes to e acuatlo routes are necessary.
Internal comm estions within the LERO EOC l
regarding asse nt of,an response to evacuation Impediments n, adequately addressed through I
modificati to th procedures (esp. OP!P 3.6.3, Traffle ntrol). The vacuation Route coordinator la res nsible for obta ng periodle updates from l
the acuation Route Spo ers, and for immedlately i
re rting road Impediment or other problems to Traffle Control Coordinat and Road Logistles Coordinator (See OPIP 3.8.3, tion 5.6.7) Lead l
Traffle Guides (at the staging sie are to report any incident.
A J.10.1 See review of Revision 5.
A J.10.
See review of Revision 5.
A J 1 See review of Revision 5.
J.12 See review.of Revision 5. In addition, the following I
r I
comments are now applicable.
The LERO Reception Center previously designated at the Nassau County Veterans Memorial Coliseum has been changed to three (3) LILCO facilltles located in Bellmore, Hicksville and Roslyn. The r
adequacy of these facilities as reception centers must be eva:.'..'1d at a future exercise.
LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1986 Page 12 of 15
.VUREC-0654 Rating Element Review Conunent(s)_
J.12 In addition to the change of Reception Center (s)
(Cont'd) location, the plan specifles (see page 3.9-5 of Revision 8) that a screening process will be used to check evacuees for contamination.
Incoming vehicles will be directed to monitoring stations where the vehicle and driver will be checked for contamination.
According to this screening procedure, passengers of the vehicle will also be assumed to be uncontaminated and a clean tag will be issued to them if the driver is below contamina-tion limita. This screening procedure is inadequate since the applicable guidance requires the capability 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 EPZ arriving at tBIs Reception Centers, j
LERO is responsible for monitoring all evacuees arriving at reception centers. It is not adequate to plan for this monitoring with personnel and equipment when available.
It is not possible to evaluate the number of personnel required for monitoring at the speclat population reception centers since the plan shows in procedure OPIP 3.6.5 pages 21-37, "to be arranged
- for most of the special population reception centers.
E.
Radiological Exposure Control K.3.a Se review of Revision 5. Sev
!ssues involving I
eme cy worker knowled and use of dosimetry were Ide Ifled at the ruary 13,1986 exercise.
This eleme has n rated inadequate because dostmetry and Ing were not provided to the Bus Drivers used r se o1 evacuation.
(1)
Drivers used fogchool evacuation should be tralned in the use or s! meters.
(2)
Adequate supplies of dostm should be provided for Bus Drivers used school evacuation.
l l! __
RELATED MON" UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board
)
In the Matter of
)
Docket No. 50-322-OL-3
)
LONG ISLAND LIGHTING COMPANY
)
(Emergency Planning)
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
)
DIRECT TESTIMONY OF DAVID T. HARTGEN AND ROBERT C. MILLSPAUGH ON BEHALF OF THE STATE OF NEW YORK REGARDING LILCO'S RECEPTION CENTERS I.
Names and Oualifications Q.
Please state your names and occupations.
A.
Hartgen:
My name is David T. Hartgen.
I am the Director of Statistics and Analysis for the New York State Department of Transportation, Albany, New York.
Millspaugh:
My name is Robert C. Millspaugh.
I am the Supervisor of the Traffic Engineering Design Section, New York State Department of Transportation, Albany, New York.
l m
.a 8704230237 870413 PDR ADOCK 05000322 I
T,_ _
Q.
Please provide a brief description of your qualifications.
A.
Hartgen:
I have been engaged in transportation planning and information systems management with the New York State Department of Transportation since 1967.
As Director of Transportation Statistics and Analysis, a position I have held for 6 years, I am responsible for the collection and analysis of transportation j
statistics pertaining to the State's highways.
I am directly involved in assessing the performance of various aspects of the State's highway system, including highway condition, capacity, i
and traffic.
This often involves the use of sophisticated com-puterized transportation models, such as the one relied upon in this testimony.
I am the author of 123 transportation-related articles and reports, 63 of which are in the published literature.
I have served on or chaired over 20 professional panels and committees on transportation issues.
In addition, I serve as an Adjunct Professor in the Department of Geography of the State University i
of New York at Albany, where I assisted in establishing a trans-portation studies program and teach courses related to transpor-l tation analysis.
A copy of my resume is attached as Exhibit 1 to this testimony.
1 l !
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