ML20207A303
| ML20207A303 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/09/1987 |
| From: | Lieberman E KLD ASSOCIATES, INC., SUFFOLK COUNTY, NY |
| To: | |
| References | |
| CON-#287-3227 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8704270079 | |
| Download: ML20207A303 (200) | |
Text
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UNITED STATES OF AMERICA una m
NUCLEAR REGULATORY COMMISSION DOCKETitt ;. E is N.f.
Bit A NC6-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- - - - - - - - - - - - - - - - - - -x In the Matter of:
Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY (EP Exercise)
(Shoreham Nuclear Power Station, (ASLBP No. 86-533-01-OL)
Unit 1)
x DEPOSITION OF EDWARD BARR I.IE5ERMAN Hauppauge, New York Friday, January 9, 1987 ACE-FEDERAL REPORTERS, INC.
Stenotype Ravrters 44 North Capitol Street Washington, D.C. 20001 b
(202) 347-3700 Nationwide Coverage 800-336-6646 8704270079 870109 PDR ADOCK 0500 2
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knrysimons 1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
X 5
In the Matter of:
6 LONG ISLAND LIGHTING COMPANY
- Docket No. 50-322-OL-5 7
(Shoreham Nuclear Power Station (EP Exercise) 8 Unit 1) 9
X 10 Hauppauge, New York 11 Friday, January 9, 1987 O
12 Deposition of 13 EDWARD BARR LIEBERMAN 14 the deponent, called for examination by counsel for Suffolk 15 County, pursuant to notice, in the County Attorney's t
16 Office, Conference Room 102, Building 158, North County 17 Complex, Hauppauge, New York, beginning at 3:10 o' clock 18
.p.m.,
before, by stipulation of counsel, Mary C. Simons, a j
19 Notary Public in and for the District of Columbia, when 20 were present on behalf of the respective parties:
21 1
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22 ACE-FEDERAL REPORTERS, INC.
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Nationstide Conetage A4XL)36-fM6
353,1 01 01 2
marysimons 1 On Behalf of Suffolk County:
2 P.
MATTHEW SUTKO, ESQ.
3 CHRISTOPHER M.
McMURRAY, ESO.
4 Kirkpatrick & Lockhart 5
1900 M Street, N.W.
6 Wash ing ton,
D.C.
20036 7
On Behalf of LILCO:
8 LEE B.
ZEUGIN, ESO.
9 Hunton & Williams 10 707 E. Main Street 11 P.O.
Box 1535
,7m, 12 Richmond, Virginia 23212 13 14 15 16 17 18 l
I 19 20 21,
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ACE-FEDERAL REPORTERS, INC.
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3511 01 01 3
arysimons 1 CONTENTS 2
WITNESS EXAMINATION BY PAGE 3
Edward Barr Lieberman By Mr. Sutko 4
4 By Mr. Zeugin 105 5
LIEBERMAN DEPOSITION EXHIBIT NO.
MARKED AND SUBMITTED 7
Exhibit No. 1 24 8
Exhibit No. 2 43 9
Exhibit No. 3 70 10 Exhibit No. 4 81 11 13 14 15 i
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g s Jarysimons 1 PROCEEDINGS s
2 Whereupon, 3
EDWARD BARR LIEBERMAN 4
was called for examination by counsel for Suffolk County 5
and, having been first duly sworn by the Notary Public, was 6
examined and testified as follows:
7 EXAMINATION 8
BY MR. SUTKO:
9 0
would you please state your full name and also 10 your business address.
11 A
My full name is Edward Barr Lieberman.
The 12 business address is KLD Associates, Inc., 300 Broadway, 13 Huntington Station, New York 11746.
14 MR. SUTKO:
Mr. Lieberman, my name is Mat Sutko, 15 and with me is Chris McMurray who I believe you know.
We 16 are both with the law firm of Kirkpatrick & Lockhart and we 17 are special counsel to Suffolk County of the State of New 18 York.
19 Today I am going to ask you a few questions 20 l regarding the February 13th, 1986 exercise which occurred 1
l 21 relating to the Shoreham Plant and also some questions
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22 about events which arose out of that exercise.
l l
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l narysimons 1 BY MR. SUTKO:
2 O
It's my understanding that you have been deposed 3
before; is that correct?
4 A
That is correct.
5 O
Have you been deposed since 1983?
6 A
No.
7 MR. SUTKO:
You probably know this, but I'm 8
going to go through a couple of ground rules for 9
depositions.
10 The first is that whenever I ask a question you 11 have to give an audible response so that the court reporter
(,,
l 12 can take down your response.
Do you realize that?
13 THE WITNESS:
Yes.
14 MR. SUTKO:
The second thing is if at any time 15 during the day I ask a question that you find is vague or 16 that you don't understand, please ask me to clarify the 17 question and I will be glad to do so.
18 (
THE WITNESS:
Fine.
19 !
BY MR. SUTKO:
l 20 '
O Do you plan to provide testimony in this 21 proceeding?
I
'~')
22 A
Yes, I do.
l ACE-FEDERAL REPORTERS, INC.
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barysimons 1 O
And what contentions do you plan as of now to 2
provide testimony on?
3 A
Right now I plan to provide testimony on 4
Contentions 40 and 41.
5 O
Do you know that certain other contentions, 6
which at one time were separated, have now been subsumed 7
within Contention 41?
8 A
No.
I'm not that familiar with the historical 9
development of these contentions.
10 0
Have you reviewed those contentions on which you 11 plan to provide testimony?
i i
12 A
Yes.
Not recently.
I would say three or four 13 weeks ago.
14 0
When you reviewed those contentions, did you see 15 reference to Contentions 25 and 29, for example?
16 A
If so, I don't recall.
17 l 0
Mr. Lieberman, how did you decide which 18 i contentions you were going to testify about in this 19 proceeding?
I 20 A
Well, it was brought to my attention by the 21 LILCO attorneys that they would like to have me testify on 22 I these contentions and they sont me these contentions for (N) l ACE-FEDERAL REPORTERS, INC.
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l 3511 01 01 7
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_ harysimons I review.
So in reading them over I determined that there 2
were elements in there which I could testify on and 3
therefore that led to the decision.
4 0
Were there any elements that you felt that you 5
could not testify on?
6 A
I would have to have those contentions in front 7
of me in order to answer that question.
8 MR. SUTKO:
Mr. Zeugin, do you have a copy of 9
the contention?
10 MR. ZEUGIN:
Yes.
11 MR. SUTKO:
Perhaps you could show it to Mr.
O 12 Lieberman and that would refresh his recollection.
13 (The document referred to was placed before the 14 witness.)
15 (Pause while the witness reviews the document.)
16 THE WITNESS:
I guess the only thing in here 17 that is not directly relevant to my work is the EBS 18 messages.
19 BY MR. SUTKO:
20 0
I've observed you as you were reading, and what 21 you looked at ---
22 A
I was scanning.
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narysimons 1 0
--- what you looked at were Contentions 40 and 2
41; is that correct?
3 A
Tha t's correc t.
4 0
At any time in the past have you looked at any 5
other of the contentions that Mr. Zeugin has provided you?
6 A
If so, not in great detail.
7 Q
Has there ever been any discussion about whether 8
you might provide testimony on any contention other than 40 9
and 41?
10 A
Not to this point.
11 Q
Do you anticipate there being any in the future?
l 12 A
I have no way of knowing that.
13 0
When were you first contacted regarding the 14 possibility of you providing testimony in this proceeding?
15 l A
I would say it was shortly after the exercise 16 itself when we began discussions about including the role 17 of the traffic engineer as part of the LERO team.
18 l 0
Who did you discuss that you might be te s ti f ying 19 i with?
t 20 A
It was with Mr. Zeugin.
21,
O Anyone other than with Mr. Zeugin?
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22 A
Well, there were discussions with Mr. Sobotka l
I l
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larysimons I who was in the LERO organization and possibly with Mr.
2 Daverio.
3 0
Approximately when did those discussions take 4
place?
5 A
I would say two or three weeks after the 6
exercise.
7 0
Mr. Lieberman, what have you done to prepare for 8
the deposition today?
9 A
Well, I've reviewed material consisting of the 10 log books, documenting the activities of people who il participated in the exercise.
I took a look at the FEMA O
12 report dealing with the impediments.
I reviewed the PID 13 section dealing with mobilization.
I reviewed Appendix A 14 in those sections dealing with traffic guides, the location 15 of the TCP's, the priorities of the TCP's, the route 16 spo t te r, that is the routes that the spotters would take, 17 and that's basically it.
I also looked at the flow 18 characteristics in a cursory way over the evacuation 19 network.
And I did review testimony that I gave again 20 dealing with the mobilization issue.
21 0
That would have been testimony in the Shoreham 22 proceedings?
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ACE-FEDERAL REPORTERS, INC.
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3511 01 01 10 arysimons 1 A
That's correct.
2 0
Anything else?
3 A
I didn't review all that testimony.
I looked at 4
the lead-in questions and then I jumped directly to the 5
mobilization issues which I think was the last testimony 6
that I gave.
So I didn't look at the testimony in between.
7 Q
Some witnesses in this proceeding have looked at 8
depositions that other individuals have given.
Did you 9
look at any depositions in preparation?
10 A
No.
11 O
Other individuals have looked at a number of
(
i 12 time lines, including one that is quite thick.
It's been 13 referred to as a massive time line.
Have you looked at any 14 time line of events?
15 A
That was in the material which I described as 16 logs.
Yes, there were time lines there.
17 0
How many time lines approximately?
18 A
I don't think there were more than three or four 19 time lines.
20 !
MR. SUTKO:
Mr. Zeugin, we would request those i
21 time lines and all other time lines that have been
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22 prepared.
I ACE-FEDERAL REPORTERS, INC.
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3511 01 01 11
.O It,.harysimons 1 MR. ZEUGIN:
I'm aware of those requests.
2 They're the same requests that I've had previously from Mr.
3 Miller.
4 BY MR. SUTKO:
5 0
Do you recall what the time lines that you 6
reviewed are about, what they were time lines of?
i 7
A I think there was one time line for each of the 8
impediments.
There may have been a time line for 9
mobilization.
I don't recall that too well.
10 0
The log books that you reviewed.
Do you know 11 what individuals prepared those log books?
12 A
No, I don't.
They do appear to be handwritten, 13 and it appears as those many people contributed to them.
14 0
Do you know if they were logs that were kept 15 during the exercise on behalf of specific individuals or 16 under the direction and control of specific individuals?
17 A
What I saw was a collection of notes just bound
(
18 '
together without too much organization.
19 0
For example, there are what are sometimes 20 referred to as logs that were kept by Mr. Weismantle, for 21 example, or Mr. Wilms.
I was wondering if you had looked pJ s
22 at those logs?
ACE-FEDERAL REPORTERS, INC.
202J47-3 Nanonwide Cos erage mn 336-NM
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3511 01 01 12 l
barysimons1 A
I may have.
As I say, it was a cursory review.
2
'O In preparation for this deposition have you 3
talked to any LILCO or LERO employees?
4 A
Yes.
I talked with Mr. Sobotka, Mr. Weismantle, 4
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Mr. Zeugin and basically that's it.
6 0
How about Mr. Wilms, did you speak with Mr.
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7 Wilms?
8 A
No, I did not.
9 0
Ms. Robinson?
I 10 A
No.
1 11 0
When you spoke to Mr. Sobotka, was counsel i
12 present at those meetings?
j 13 A
Sometimes.
14 0
And sometimes not?
i 15 A
Right.
i 16 0
Could you please tell me those instances, and 17 identify them by date if you can approximately, when those s
I 18 meetings were held at which counsel was not present?
19 A
In preparatior for this deposition?
l i
i 20 0
Yes.
i l
21 A
Well, earlier today, yesterday and that's all j
(7) 22 that comes to mind.
!i ACE-FEDERAL REPORTERS, INC.
202 347-37to Ntionmide rmerage N43)MM6
3511 01 01 13 l
karysimons 1 0
Would you briefly summarize the-substance of 2
those conversations.
3 A
Essentially what I did was use him as a sounding 4
board for my understanding of what I had read to determine 5
whether my understanding was consistent with his 6
understanding since he had been involved in the exercise 7
and in LERO on a continuing basis.
So the substance had to 8
do with essentially the elements of Contentions 40 and 41, 9
the mobilization of the traffic guides and the responses to 10
_the impediments and the definition of the impediments by 11 PEMA.
O 12 0
What was Mr. Sobotka's impression of the facts 13 lof Contentions 40 and 41?
14 A
Well, essentially they were representative of 15 what I had read.
I'm not sure that I understand what you 16 mean by interpretation.
l i
17 0
Was Mr. Sobotka in general agreement with the i
18 facts he set out in Contentions 40 and 41?
1 l
19 A
We really didn't talk about it from the
}
20 viewpoint of the County's contentions.
We talked about it f
21 from the viewpoint of the logs and the information which
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22 appeared in the FEMA review and so forth.
So we really t
l ACE-FEDERAL REPORTERS, INC.
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3511 01 01 14 narysimons 1 didn't discuss the point of view of the County.
2 0
What is Mr. Sobotka's full name?
3 A
Jeffrey Sobotka.
I don't know if he has a 4
middle initial.
5 0
What is his position in LILCO?
6 A
He is a consultant to LILCO.
7 0
Does he work full time for LILCO?
8 A
As a consultant I believe that is true.
I can't 9
say for sure.
10 0
Do you know if he is employed by LILCO?
11 A
No, he is not employed l>y LILCO.
12 O
Who is he employed by?
13 A
He is now an employee of Adakoff Associates.
14 0
And who is Adakof f Associates?
15 A
Adakoff Associates is a consultant firm in the 16 area of emergency planning and training.
17 l 0
Where are their offices located?
I 18 l A
In New York City.
I don' t know the exact i
19 address.
l 20 ;
O Why was it that you were talking to Mr. Sobotka?
i 21 A
Well he and I have worked together on the
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22 Shoreham issue for several years now and his current i
i l
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3511 01 01 15 l
harysimons 1 involvement is in this area.
2 O
Do you know if he participated in the February 3
13th exercise?
4 A
I believe he did.
5 0
Do you know what his function was during the 6
exercise?
7 A
Not really.
8 0
Is there any chance that he may appear as a 9
witness in this proceeding?
10 A
I have no idea.
11 0
Did you discuss the possibility that he might be O
12 on one or more panels with you?
13 A
No.
14 0
Was there any discussion at all about whether or
.s 15 not he might u ^tify in this proceeding?
j 16 A
No.
17 0
Previously you and Mr. Sobotka worked upon a 18 number of areas together; is that correct?
19 A
That's correct.
20 0
What were those areas?
4 I
21 A
Well, during the development of the evacuation 22 plan he acted as support in several of the data acquisition
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ACE-FEDERAL REPORTERS, INC.
202-347-37(10 Nationwide Coverage NXh336-6646
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3511 01 01 16 barysimons1 areas.
We first got involved in surveying the highway 2
system shortly af ter our involvement with the Shoreham 3
evacuation plan.
I 4
0 What exactly do you mean by support data 5
acquisition?
6 A
Well there are times when we developed sketches 7
of specific intersections at which traffic control was 8
asserted and others which we thought might be candidates.
I 9
So we went out together to survey those areas and he helped i
10 me sketch those intersections.
1 i
11 0
Do you know what his education or training is?
(:)
12 A
I believe he is a mechanical engineer with a l
13 master's degree.
t 14 0
At whose request did you all meet yesterday?
15 A
That was at Mr. Zeugin's request.
i 16 0
Where did you meet?
17 A
In Hauppauge.
18 0
Did you discuss with Mr. Sobotka the possibility i
1 19 that he might perform any studies or provide any support 20 data acquisition or do any surveying either at your request i
i 21 or at the request of LILCO or LILCO's counsel?
l i
22 A
In the future?
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3511 01 01 17 l
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Yes.
2 A
No.
3 0
Has he done any of those things already?
4 A
What he has done is gathered together the 5
documents I described earlier and have them for me when I 6
came over to Hauppauge yesterday.
7 0
What what specific intersections did he have 8
documents?
9 A
I'm speaking here of the documentation that I 10 referred to earlier concerning my preparation for this 11 deposition having to do with the logs of the exercise and O
12 so forth.
The intersection sketches are years ago, i
13 Q
He's not doing any intersection sketches now?
14 A
Not for me.
15 0
And you don' t plan to have him do any in the 16 future?
17 A
Well, I can' t say what the future holds.
I have 18 no current plana for him do tha t.
19 0
I don' t understand why he had ;these particular 20 documents if they are what I think they are, the player 21 logs, for example.
Is that the type of documents they are?
22 A
Right.
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ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 8(X)-3346M6
3511 01 01 18 knarysimons1 O
A copy of the contentions ---
2 A
Well, the contentions I had earlier.
3 0
Was a separate copy of those documents provided 4
to you by Mr. Zeugin?
5 A
Not all of them, no.
I had the contentions and 6
most of the documents which detailed these logs were 7
provided to me yesterday.
8 0
I don't understand if presently he's not being 9
contemplated as being called as a witness and you don't 10 contemplate upon and neither does LILCO ---
11 A
I can't speak for LILCO.
12 O
To the best of your knowledge, though, he is not 13 contemplating doing any work relating to this proceeding 14 for LILCO; is that correct?
15 A
I can't make that statement.
I don't know what 16 work is going to be assigned to him.
17 0
I ask simply to the best of your knowledge as 18 you sit here today you have no belief that he plans to do 19 any type of work for LILCO relating to this proceeding; is i
20 that correct?
l 21 '
A No, I can't make that statement.
22 O
What might he be doing?
u, ACE-FEDERAL REPORTERS, INC.
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3511 01 01 19 7-(,.arysimons 1 A
I don't know.
It's not my responsibility.
What 2
I'm telling you is that my relationship with him is such 3
that he han supported my preparation for this deposition.
4 0
Do you know if LILCO has asked him to perform 5
any surveys or do any studies?
6 A
No, I don't.
I just don' t know.
7 0
Is yesterday the first time that you looked at 8
player logs?
9 A
I would say it's the first time.
Yes, I think 10 so.
I may have had other material that I looked at some 11 time ago, but I would say yesterday was the first time that
('
12 I actually focused on this issue.
13 O
And those were documents given to you by Mr.
14 Sobotka?
15 A
Right.
16 0
You stated that you also spoke with Mr.
17 Weismantle when counsel was not present; is that correct?
18 A
In passing, but all discussion on this issue 19,
with Mr. Weismantle was with counsel present.
20 0
What were those discussions in passing?
21 A
Just social and it had nothing to do with the
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22 issues at hand.
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ACE-FEDERAL REPORTERS, INC.
202 347-37m Nationwide Coserage 800-336-6M6
3511 01 01 20 l barysimons 1 0
Have you met with any other potential LILCO 2
witnesses in preparation for this deposition?
3 A
Well, Charles Daverio was present in the room 4
that I was reviewing the documents and I suppose I did 5
discuss these with him, but superficially.
6 0
How about Mr. Millioti?
7 A
I met Dennis yesterday, and I suppose I informed 8
him that I was going to be deposed today on these issues.
9 Again, I don't think we went into any depth on it.
10 0
Did you make any effort to determine whether 11 your opinions were similar to dissimilar in any way?
O 12 A
No. I don't think he is involved in this issue.
13 0
To date have you or has anyone on your behalf 14 done anything to begin preparing testimony for this 15 proceeding?
16 A
Other than the reading I described earlier, no.
17 0
Have you reviewed or prepared any studies other 18 than what you previously discussed?
19 A
No.
20 0
Have you performed any tests?
21 A
Tests?
! {}
22 0
Yes.
ACE-FEDERAL REPORTERS, INC.
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sarysimons 1 A
No.
I 2
0 Have you done any computer programs or drafted 3
any computer programs or done any computer runs?
4 A
No.
5 O
Have you prepared any documents?
6 A
No.
4 7
0 Have you prepared any papers?
8 A
No.
9 Q
Do you have any handwritten notes that you've 10 prepared?
4 I'
11 A
I have some handwritten notes which I prepared 12 to synthesize my own thinking and essentially boil down i
13 what I've read.
i l
14 0
Were those notes based upon any data other than 15 that which was found in the contentions and the other i
16 documents that we've talked about this afternoon?-
l 17 A
No.
18 Q
Have you actually begun draf ting any. testimony?
19 A
No.
20 0
Has Mr. Sobotka done any of the entire list of l
l 21 things that we have just discussed, to your knowledge?
{
22 A
To my knowledge, no.
l l
l ACE-FEDERAL REPORTERS, INC.
202-347-37(U Nationwide roverage an336-6M6
3511 01 01 22 marysimons 1 Q
And he also, as far as you know, has not done 2
any studies?
3 A
As far as I know.
4 O
And prepared no tests?
5 A
Right.
6 0
Do you know what the term " summary disposition" 7
means?
8 A
Yes.
9 0
Have you done any work in the last six months in 10 preparing for drafting any summary disposition motions?
11 A
No.
7 12 Q
Have you discussed summary disposition motions 13 with anyone as they would relate to this proceeding?
14 A
Yes.
I have discussed it with Mr. Zeugin.
15 0
Have you discussed it with anyone else?
16 A
I don' t believe so.
17,
O When did those discussions with Mr. Zeugin take l
18 j place?
19 l A
Over the last week for the most part.
20 O
Are you aware of whether anyone else may provide 21 l testimony on behalf of LILCO in this proceeding?
I 22 MR. ZEUGIN:
Are you asking the question ACE-FEDERAL REPORTERS, INC.
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3511 01 01 23 narysimons 1 generally or about specifically Contentions 40 and 41?
2 MR. SUTKO:
Generally, if he knows.
3 THE WITNESS:
Well, I know Mr. Weismantle is 4
going to be involved and Mr. Daverio will be involved.
Mr.
5 Wilms will be involved.
Specifically I can't think of 6
anyone else, but I'm sure other people are involved.
- Well, l
l 7
Dr. kiillio ti I imagine will be involved.
l l
8 BY MR. SUTKO:
9 O
Do you anticipate drafting any summary 10 disposition motions?
11 A
I can' t anticipate that.
1 on to another line of 12 O
I would like to -
13 questioning.
14 Have you ever discussed the February 13th 15 exercise with anyone affiliated with FEMA or with the NRC?
16 A
No.
17 0
Does the name Roger Kowieski mean anything to 18 l you?
19 i A
I've met him a couple of times.
20 0
When was the most recent instance that you met 21 l him?
i
(')
22 j A
It goes back years.
I can' t give you any more
{
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l l
1 ACE-FEDERAL REPORTERS, INC.
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{
3511 01 01 24 hmarysimons1 precise time.
2 O
Have you discussed the February 13 th exercise 3
with him?
4 A
No.
I haven't talked with him or met with him 5
since that point.
6 0
How about Tom Baldwin?
7 A
I don't know who he is.
8 Q
Edward Tanzman?
9 A
Same.
10 MR. SUTKO:
1 would like to have marked as 11 Lieberman Exhibit No. 1 your resume, and I would like to
~'
12 ask you just a few questions regarding it.
13 (The document referred to was 14 marked Lieberman Deposition 15 Exhibit No. 1 for identification J
16 and submitted for the record. )
17 BY MR. SUTKO:
18 0
The first question is that I see tha t you are a 19 Vice President.
What are you Vice President of?
20 i A
Of the company.
21 O
Which is?
/~~
22,
A KLD Associates.
' _)
ACE-FEDERAL REPORTERS, INC.
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3511 01 01 25 l
barysimons 1 0
You have previously provided testimony in these 2
proceedings, and I'm not going to go back to anything which 3
is pre-1984.
I do have some questions about some recent 4
publications that you have authored or co-authored, and 5
those are found on a page which is stamped in the bottom 6
right-hand corner as 764779.
7 The first document that I would like for you to 8
describe for me is found about half way down the page, and 9
it is entitled " Evacuation Plan Update (Robert G. Ginna 10 Power Station)."
Do you see that?
11 A
Yes.
O 12 O
Could you please briefly describe what that was?
4-13 A
It's essentially what the title indicates.
It's 14 an update of the evacuation plan which had been done for 15 them back in 1980 or '81 by another consultant.
16 Practically what we did was to prepare an evacuation plan 17 of a considerably lesser scope than we did for LILCO 18 because they had certain budget constraints.
But it 19 involves evacuation time estimates, or ETE as they're 20-called.
It includes identification of routing, of traffic 21 control tactics to be applied at intersections similar to 22 what we did at Shoreham.
And in this particular case we
{}
ACE-FEDERAL REPORTERS, INC.
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3511 01 01 26 marysimons I had to also prepare separate appendices for the two 2
counties that are involved.
3 0
The next publication is for Davis-Besse.
Was it 4
a similar type publication?
5 A
Yes, it was.
6 0
The one after that is for Seabrook.
Was it a 7
similar type publication?
8 A
No.
That was more extensive in scope.
Neither 9
Ginna nor Davis-Besse is in the licensing procedure, that 10 is both plants have their licenses.
Seabrook, in the other 11 hand, like Shoreham is looking for a license, and that plan
('~'-
12 is much more extensive than the other two.
It contains the 13 same ingredients that I've just described for the other 14 two, but we went into greater detail, j
15 0
Could you briefly describe the last two 16 publications that are listed on this page?
17 A
I think these are like technical summaries of 18 the two plants.
19 l 0
Why were they prepared?
20 A
I don't remember, quite frankly.
21 0
Were they prepared based on the licensing
(
22 proceedings at least in the first instance?
I ACE-FEDERAL REPORTERS, INC.
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3511'01 01 27
()marysimons1 A
I think the one for Seabrook was prepared as a l
2 handout for a press conference in which I gave a 3
presentation.
4 The second one was prepared in advance of a 5
meeting that we had with county personnel and they wanted 6
to see less technical detail and essentially a summary that 7
they could hand over to the County Executive without all 8
the technical detail.
9 0
Have you ever draf ted any articles that relate 10 to full-scale drills at nuclear power plants?
11 A
No.
O 12 0
Have you ever been present or participated in a 13 full-scale drill at a nuclear power plant?
14 A
Yes.
15 0
What would that be?
16 A
With the LERO organization for Shoreham.
17 0
Would t be the February 13 th exercise?
18 A
No.
That was a drill that was conducted 19 subsequently.
20 0
When did that drill take place?
21 A
I can't recall the exact date.
22 0
Was this simply a tabletop exercise or was it a ACE-FEDERAL REPORTERS, INC.
m-a
==
-3511 01 01 28 barysimons 1 full drill?
2 A
It was a full drill.
I also attended a tabletop 3
exercise in addition.
4 0
In the full drill there was a simulated 5
evacuation of the EPZ?
6 A
Oh, yes.
7 0
What role or roles did you play in that?
8 A
I played the roll of a traffic engineer.
9 0
I think the tabletop you are referring may have 10 taken place in May.
Does that sound correct?
11 A
No, that sounds a little early.
a 12 O
When do you think it would have been?
13 A
I don't know.
Life has been kind of busy and I 14 can' t sort it out.
It was later than that.
15 MR. ZEUGIN:
Mr. Sutko, maybe I can help you a l
16 little bit.
Because there are three shif ts of traf fic i
17 engineers, what one person may refer to as the table top l
l 18 they went to may have been for one shift, and Mr. Lieberman 1
j 19 may have been on a different shift that was scheduled for a l'
20 different point in time.
That is why you may get different 21 times because of the different shifts.
{}
22 MR. SUTKO:
I see.
1 ACE-FEDERAL REPORTERS, INC.
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k 3511 01 01 29 barysimons 1 BY MR. SUTKO:
2 0
I am trying to de termine, Mr. Lieberman, when it 3
was that you participated in the full-scale drill acting as 4
a traffic engineer?
5 A
I can't for the life of me identify where in 6
time that took place.
7 0
Maybe you could tell me what tile wea ther was.
8 A
Yes -- (Laughter) -- that's exactly what I'm 9
trying to do.
It was a lovely day.
As I recall, the 10 drills were kind of closely spaced.
The one that I went to 11 was the first one of these.
There were three drills I
(
12 believe, one for each shift, and we sent a different person 13 from our firm to each one of those.
And I think that there 14 was a fourth drill a little later which I did not attend.
15 Someone else in our staff did.
16 0
Were you the person who was at the first or what
'l 17 is sometimes called the shift one?
18 A
I'm inclined to think yes, but I wouldn' t make 19 that a positive statement.
It's a fuzzy statement.
20 0
I would like to return to this probably a little 4
21 later in your deposition and talk some more about it.
22 A
Okay.
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ACE-FEDERAL REPORTERS, INC.
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'30 arysimons 1 Q
But, first, I would like to talk about any 4
2 activities that you may have provided or engaged in prior i
3 to the February 13th exercise.
l 4
Did you have any involvement of any kind in 5
preparing for that exercise?
2 6
A I don' t believe so.
7 Q
Were you involved in any drills that occurred 8
within six months preceding the February 13th exercise?
9 A
No.
10 0
Did you provide any type of assessment of any of 11 the LERO performers who might have participated in those O
12 types of drills?
T 13 A
No.
s 14 0
Do you know whether anyone at your company 15 provided that type of service?
16 A
No.
l 17 0
Were you aware that prior to February 13 th there i
I 18 was going to be an exercise on the 13th?
l 19 A
I knew there was going to be an exercise.
I l
20 can' t say now whether I was aware of the specific date.
I 21 might have been.
I 22 O
Did you provide any sort of training or training 1
ACE-FEDERAL REPORTERS, INC.
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3511 01 01 31 kaarysimons 1
ma terials to be used in preparation for that exercise?
2 A
No.
3 0
Did you have any preassigned responsibilities 4
for the day of the exercise?
4 5
A No.
4 6
0 Did you talk to any LERO or LILCO employee or I
7 anyone acting on their behalf about the exercise in the i-8 week or so prior to the exercise?
I 9
A No.
10 0
On the day of the exercise did you have any.
11 reason to think that you might be contacted or asked to
(:)
12 participate by LERO or LILCO?
13 A
No.
Let me think back.
I may have known that I
i 14 the exercise was that day.
I was given no assurance or no 15 hint that I would be contacted on that day.
l 16 0
were you contacted?
(
17 A
Yes, I was.
18 0-Could you briefly describe how that came about?
i
(
19 A
Well, I received a telephone call at the office l
20 in the early afternoon, and I was informed tha t -- well, 21 the first thing was this is a drill was announced, and the i
l
{
22 caller was Mr. Weismantle.
He informed that in the course i
ACE-FEDERAL REPORTERS, INC.
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3511 01 01 a2 knarysimons 1
of the drill there were impediments postulated and certain 2
actions taken and he wanted my opinion concerning the i
3 rerouting of traffic.
He described where the impediments 4
were and what rerouting was suggested and he asked my 5
opinion if that rerouting was reasonable and what would the 6
effect be in terms of increased evacuation time, if any.
7 My recollection was that I didn' t have all my 8
material ready since I didn't anticipate the call.
So I j
9 told him I would call him back.
I took a look at my 10 reference material, which was Appendix A and I had a map of i
11 the traffic control points and I reviewed the evacuation 12 travel times.
i 13 I call him back 10 or 15 minutes later and 14 indica ted that I thought the rerouting responses that had 15 been suggested were reasonable, and I ventured the opinion 4
16 that perhaps there might be an additional delay of an ho -
17 associated with the need to primarily reroute the few that Hi df 18 had gathered upstream to the impediments.
He informed that t
19 the impediments were such that they blocked the entire j
20 roadway which I found difficult to accept because it's very 21 unusual that an impediment would do that.
I 22 So I figured out in that interim period between ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coserage 800 33MM6
3511 01 01 33 marysimons 1 receiving his call and answering how many vehicles would be 2
queued and roughly how long it would take to turn them 3
around and get them on an alternate route.
On that basis 4
primarily I determined that it would be about an hour for 5
those routes.
Now that does not translate into an increase 6
in evacuation time for the EPZ because one of those routes, 7
the one in Yaphank, or both routes.
The location of the 8
impediments were such that there were none on the critical 9
path.
So it's possible to delay a traffic stream with some 10 vehicles to up to an hour without affecting the total 11 evacuation time for the EPZ.
I>
l
'~'
12 O
So by not being on the critical path, in your 13 opinion, is it relatively easy to reroute those?
14 A
I don't know what easy is.
It's never easy to 15 take a queue of cars which are on a two-lane road and 16 reverse their paths because effectively you've got to 17 orchestrate this.
Cars have to make U turns and move back 18 !
along that road to the juncture with an alternate path.
So 19 it's not " easy."
I 20 '
O Maybe then you can define for me what you mean 21 i by the critical path.
(~')
22 l A
There are multiple paths of travel along the
'us' i
ACE-FEDERAL REPORTERS, INC.
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l 3511 01 01 34 lknarysimons 1
evacuation route and some paths empty out sooner than 2
others.
So if you have an evacuation time say five hours, 3
that does not imply that each path empties at precisely 4
five hours.
Five hours implies that the longest path 5
empties a t five hours.
6 So these particular locations were not on the 7
critical path and therefore the extension in time for those 8
involving vehicles of one hour probably would not translate 9
into an extension in evacuation time of one hour.
It may 10 not extend the evacuation time at all or it might extend 11 the evacuation time for some lesser amount.
12 0
Is it f air to say that there are other places 13 where a tie-up or impediment blocking a roadway would 14 change evacuation times?
15 A
Yes, I think that is a fair statement.
It 16 depends on how long the impediment lasts.
You could 17 orchestrate an impediment any way you pleased of course and i
l 18 thereby produce an increase in evacuation time.
19 l 0
When Mr. Weismantle spoke to you did he i
20 characterize the impediments as a problem?
21 j MR. ZEUGIN:
I'll object to that question and F
I 22,
instruct the witness not to answer because I believe Mr.
l ACE-FEDERAL REPORTERS, INC.
202-347-37tU Nanonwide Cos erage N n 346646 I
. ~.
2 -
3511 01 01 35 narysimons 1-Lieberman said early that the only time he spoke with Mr.
2 Weismantle about these contentions was when counsel for 3
LILCO was present.
4 MR. SUTKO:
I'm talking about the telephone j
5 call.
6 MR. ZEUGIN:
I'm sorry.
I misunderstood you.
4-.
i 7
BY MR. SUTKO:
8 0
What I'm asking you is when Mr. Weismantle spoke i
9 to you on the 13th did he say we have a problem with 10 impediments?
11 A
I can't recall him using the word " problem."
l ~(
12 0-Did he discuss the delays that they had had as a l-13 result of these impediments?
i i
14 A
No.
As a matter of fact, he asked me what the l
l 15 delays would be.
I j
16 0
Did he talk about any delays in getting the 17 roads cleared?
18 A
I asked him a series of questions as to how many l
l 19 lanes were blocked and how long would it take to get the W254 ha 20 cleared.
He response to me,ps' assume that they are no f p
21 cleared whether the diversion of traffic that he had 22 suggested is reasonable and what would be the lengthening
{}
l i-ACE-FEDERAL REPORTERS, INC.
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3511 01 01 36 knarysimons 1
of the ETE on the basis that these impediments were not 2
cleared.
3 0
In order to assist you in making your 4
calculations did he tell you how long to his understanding l
5 these impediments had been in place?
6 A
Not that I can recall.
7 0
I'll represent to you, and there is a log that 8
reflects some of these telephone conversations, and we are 9
going to discuss those in just a little bit, but I'll 10 represent to you that the impediments were first reported to LERO at approximately 10:40 and 11 o' clock and that you 11
(
12 were first called I believe at approximately 1:20.
So they 13 had been there well in excess of two hours in both 14 instances.
15 Wasn't that the type of information you would 16 need in order to determine the size of the queue and the 17 amount of time that it would take to reroute and to clear 18 everyone from the EPZ?
19 A
No.
20 O
Why is that?
21 l A
Because again people are not automatons.
If i
22 '
they see a blockage in which traffic isn't moving they will
(
)
/
i i
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3511 01 01 37 l
harysimons 1 divert on their own given that there is an alternative 2
path.
l 3
O Did you make certain assumptions as based upon 4
the maps that you used the number of people that had been 5
able to divert themselves on their own?
6 A
No.
What I focused on was under the assumption 7
that these who were blocked by the impediment would have to 8
reroute themselves.
Anyone upstream of the tail of that 9
queue would have moved to daylight.
In other words, if you 10 see a standing queue that is motionless then cars are going 11 to on their own volition take an alternative path that
(:1 12 appears to be in the direction that they want to go.
13 Once that happens you set-in motion a whole 14 process of cars following those cars-that will move along f
15 that path and there will be a steady diversion of traffic.
l j
16 0
Mr. Lieberman, isn't time one of the elements 17 that will determine the size of the queue?
18-A Yes, given that the queue makes no adjustments I
l 19 to correct the si tuation.
If you assume again that you're i
20 dealing with a line-up of cars on a freeway, say, and le t's 21 say that there are six miles between exits, and say further 22 that the impediment is just upstream of that one exit.
}
I i
ACE-FEDERAL REPORTERS, INC.
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3511 01 01 38 l
harysimons 1 Then what will happen is that that queue will grow over 2
time back to that next upstream exit, but it'will not grow 3
beyond so long as cars can use that exit to divert.
4 Q
But won't the pressure placed upon that other 5
exit wind up slowing down traffic leaving by that exit and 6
as time grows won' t that exit as well become congested and 7
itself a queue?
8 A
It's possible.
You have to look at the 9
circumstances.
In this particular case based on the 10 location of the Yaphank location I would say that there is 11 probably some~ additional delay by traf fic instead of moving O
12 south along the Yaphank Middle Island Road tha t they would 13 continue moving west along Route 25.
We also have a 14 traffic control point on Route 25 west of where Yaphank 15 Middle Island Road intersects where roughly half the 16 traffic goes down on I think Bartlett Road or East Bartlett 17 Road and thew down to Granny Lane or Granny Road and the I
18 other half continues west on Route 25, 19 So effectively what you are saying is correct.
20 You would increase the load on Route 25 and on Granny 21 Road.
However, neither of those two routes in on the 22 critical path.
So, again, I'm going back to what I said ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationside Coserage 800-33MM6
4 3511 01 01 39 l
harysimons 1
earlier, there would be an increase in evacuation time 2
along those routes because you're moving more traffic on 3
those routes than you would have otherwise.
t 4
O Is it your testimony that there could be a 5
substantial number of impediments upon non-critical path 6
routes and that would not af fect the overall evacuation 7
time from the EPZ?
8 A
Did you use the word " considerable" and could 9
you quantify that?
)
10 0
Is it your testimony that so long as there are l
11 not impediments along critical path lines that there will
(:)
12 be no increase in the amount of time it takes to evacuate 13 the EPZ?
t 14 A
I'm saying that is a possibility.
You can't 15 make an absolute statement to that ef fect.
16 0
What are the road that you consider the critical 17 paths within the EPZ?
18 A
I would say that the critical paths are the 19 William Floyd Parkway, the Long Island Expressway, the 20 North County Road and quite possible Route 25A west of I 21 think it's Echo Road.
j 22 O
Echo?
ACE-FEDERAL REPORTERS, INC.
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3511 01 01 40 lhmarysimons 1
A Echo.
I think so.
2 Q
So if you had an impediment on any of these, it 3
would be a much greater problem than the two that were 4
encountered in the exercise; isn't that a fair statement?
5 A
It depends on ---
6 MR. ZEUGIN:
Let me first make sure that the 7
question is clear.
You said a much greater problem.
Do 8
you mean a problem in terms of evacuation time estimates.,
9 is that what you' re referring to, or a problem in terms of 10 ability to clear the impediment?
11 MR. SUTKO:
Mr. Zeugin is correct.
I'm talking
(
)
12 about in terms of evacuation time estimates.
13 THE WITNESS:
Potentially it would, depending
{
14 upon when in the evacua tion process it occurs and how long 15 it remains before it is removed and how many lanes are 16 blocked.
All of those are factors.
17 BY MR. SUTKO:
18 0
After Mr. Weismantle first spoke with you, you 19 then did some calculations; is that correct?
20 '
A Very quickly, yes.
21 0
Could you just, please, walk me through what it
/~;
22 is that you did?
</
ACE-FEDERAL REPORTERS, INC.
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3511 01 01 41 knarysimons 1
A Sure.
The thing that I focused on was to 2
calculate how many cars would be caught in that queue, and 3
by caught I mean between the head of the queue being where 4
the incident was located and the tail of the queue being at 5
the juncture of a diversion route.
6 So I went to the map and I estimated the 7l distance and translated that distance into cars.
When I 8
estimated how long it would take for these cars to make 9
their U turns and move back to that juncture and go on 10 their way on the alternate route.
11 Then to the best extent that I could under the 12 short time frame that I assumed I had I estimated what 13 would be the incremental time on the alternate evacuation 14 rou tes, and that's the way I came up with my estimate.
15 0
On that last issue what did you conclude for 16 incremental time on the alternate evacuation routes?
17 A
For the Yaphank case I estimated that it woulo 18 be up to an hour which would include -- see, these thing s 19 don' t happen in series.
The cars that are reversing 20 i themselves are doing that as soon as they can obviously, i
21 The diversion of traffic takes place as soon as the queue
'1 22 gets back to that first junction.
So all this is happening x_s l
ACE-FEDERAL REPORTERS, INC.
l 202-347-3'U0 Nanonwide Coserag MNk 33MMA l
3511 01 01 42 hmarysimons1 in parallel.
That is where I came up with the estimate of
^
2 an hour.
3 0
So I take it that you agreed with the diversions 4
that had been made by LERO personnel; is that correct?
5 A
I agree that they were reasonable.
For the one 6
on Route 25A that was just about the only reasonable 7
diversion that made sense.
8 0
So that they were really faced with one clear 9
choice?
10 A
At that point they were.
It turns out that the 11 traffic along 25A there is not that heavy because that l
12 point is east of Echo Avenue.
Effectively the alternate 13 route was to send them up to Echo Avenue to join the other i
14 evacuating traf fic and ef fectively bypass the location of 15 the impediment.
16 The one in Yaphank, I would have done that 17 differently.
I think what they had su,ggested was to divert 18 the traf fic onto Bartlett Road.
I would have kept them 19 going west on Route 25 because I knew.that half the traffic 20 would be moved south on East Bartlett Road and the other 21 half continue west on Route 25.
That would have been in my 22 view the better way to go, although what they did was
(}
ACE-FEDERAL REPORTERS,INC.
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3511 01 01 43 knarysimons 1
reasonable.
They kept the traffic moving.
2 MR. SUTKO:
Would you please mark this as 3
Exhibit 2.
4 (The document referred to was 5
marked Lieberman Deposition 6
Exhibit No. 2 for identification 7
and submitted for the record.)
8 BY MR. SUTKO:
S O
Mr. Lieberman, let me show you what has been 10 i marked as Lieberman Exhibit 2 and ask you if this is the 11 one which you would have rerouted differently if you had
(
I 1
12 been involved in that decision?
13 I will represent for the record that this is the 14 gravel truck impediment.
15 (Pause while the witness reviews the document.)
16 A
I notice here that it is at 12:41 and my call 17 was after 1.
So ef fectively they called me af ter they had 18 made these recommendations and effectively I was reviewing what they had recommended.
19 j 20 Yes, this is the only where I would have 21 preferred to send the traf fic directly west on Route 25 l
22 because it's a be tter road, and by better road I mean ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationaide Cos erage 60fk3346646
'3511 01 01 44
(
marysimons 1 geometrically.
2 0
I'm going to show you something that was marked 3
as an exhibit in Mr. Weismantle's deposition.
It's a copy 4
of the log that he kept, and I'll represent to you that he 5
had an assistant who took down statements that he 6
dictated.
I'm not ' going to mark it as an exhibit in this 7
deposition because it can be found in the Weismantle 8
deposition.
9 I would like to show you those instances in 10 which there are' references to contac ts with you.
I 11-The first is found at the bottom of the page 12 which is numbered 15 up in the upper-right-hand corner.
I 13 believe the time is 1320 which would be 1:20 p.m.
14 Is this the first conversation that we have been l
15 talking about?
16 A
Which one are you looking at now?
i 17 0
It would be right at the bottom of page 15.
18 A
Okay.
19 (Pause while the witness reviews the document. )
20 That certainly looks about right.
21 0
Have you seen this document before right now?
22 A
Yes.
I have gone through quite a few documents 4
i ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 85336-646 i
3511 01 01 45 lhmarysimonsI like this.
It's difficult to read.
2 0
Does this statement accurately reflect your 3
recollection of that conversation?
4 A
Which statement?
5 0
The statement that is on the bottom of page 15.
6 A
Just that one?
7 0
If you want to go ahead, you can review page 16 8
which I believe refers to that conversation and may well 9
also refer to the subsequent conversation that we've talked 10 about.
11 (Pause while the witness reviews the document.)
7
)
12 A
Yes, I think it f airly represents my 13 recollection of the phone call.
It doesn' t go into as much 14 de ta il.
For example, it says here " explained accident 15 situation."
We talked for several minutes in which I 16 requested a detailed description of the accident.
17 0
Mr. Lieberman, it's my understanding that you I
18 ;
also had some conversations with Mr. Wilms; is that 19 correct?
20 l A
Yes.
He was on the line with Mr. Weismantle.
21 l 0
And that would have been regarding the same t
/"x 22 decisions as to evacuation time estimates?
K l
t I
ACE-FEDERAL REPORTERS, INC.
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'3511 01 01 46 arysimons 1 A
Right.
They were on the line together actually.
2 0
Did you at any other time during the day speak 3
with anyone else at LERO or LILCO?
4 A
Yes.
There was a call later that day.
I'm 5
trying to remember what it was about, quite frankly. I knew 6
what it was when I walked in here, but it slipped my mind.
7 Is it down here?
8 0
I think it is, but in very brief form.
It would 9
be on the page 354 and there is an entry of 1455.
See if 10 that refreshes your recollection.
11 (Pause while the witness reviews the document. )
O 12 A
Oh, yes.
They asked me how many people did I 13 think were still in their homes at 1455, and I said no more 14 than 10 percent.
15 0
How did you reach that figure?
l 16 A
It's based upon the work that we had done in l
17 calculating the mobilization time, or actually what I 7
18 prefer to call the sa generation time of evacuees.
l 19 0
When you reached that decision did you do any 20 calculations or did you essentially assume that the l
l 21 exercise implemented the plan as anticipated?
l 22 A
No.
I just knew either the previous phone call u
l l
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coserage 800-336W46
3511 01 01 47 knarysimons1 or this one told me what time the order to evacuate was 2
given and I was able to determine the elapsed time, and 3
from that and from the studies we had done earlier I was 4
able to make that statement.
5 0
And there were not other variables that you 6
considered in your calculations; is that correct?
7 A
That's correct.
8 0
Other than the conversations we discussed, did 9
you have any other conversations with any LERO or LILCO 10 employees on the 13 th of February?
11 A
No.
12 0
Do you still have in your possession any of the 13 notes or calculations that you might have made on the 13th?
14 A
I didn' t make any notes on the 13th.
15 0
Did you do any calculations?
16 A
Well, I did some rough calculations, yes.
17 0
Did you retain any of those?
18 A
No.
19,
Q Do you know if anyone else in your company in 20 l any way participated in the exercise on the 13 th?
21 A
No, they did not.
(')
22 MR. SUTKO:
I would like to take just about a ACE-FEDERAL REPORTERS, INC.
202-347-370)
Nationwide Cos erage 800-336-6M6
1511 01 01 48 1
lllbarysimons1 five-minute break here.
2 (Brief recess taken.)
3 MR. SUTKO:
Le t's go back on the record.
4 EXAMINATION (Resumed) 4 5
BY MR. SUTKO:
6 O
Mr. Lieberman, previously we discussed that you
{
7 were at an exercise or a drill.in which you. acted as a 8
traffic engineer.
I would appreciate it if you could just 9
briefly explain to me how it came about that you became a 10 traffic engineer in the LERO organization.
11 A
Well, we were approached by LILCO to provide O
12 personnel to fulfill that position and we agreed to do so.
4 13 We have three people at KLD who all live in Suffolk in the 14 Town of Huntington and who are all qualified for that role 15 who are graduate engineers.
We have*therefore taken on 16 that role as a consultant.
17 0
When did these conversations about filling this 18 position begin?
j 19 A
Just a few weeks after the exercise.
20
'O Did they arise due to the problems which had 4
21 occurred in the exercise with performance in areas in which 22 the traffic engineer is now going to provide assistance?
{}
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationvide Coserage 800-336-6646
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3511 01 01 49 lhmarysimons1 A
I can't say there are problems.
I guess this is 2
some speculation on my part, but it had to do with the fact 3
that they felt it would be much better if someone were on 4
the scene rather than on the other end of the phone line in 4
5 the event an accident did in fact take place.
6 0
When did you and your company become 7
contractually bound to act as traffic engineers?
8 A
In the early part of '86.
I can' t remember the 9
date.
I could find that out.
10 0
That's not necessary.
11 What have you done since that date to perform O
12 your function as traffic engineer?
13 MR. ZEUGIN:
Are you asking Mr. Lieberman 14 specifically or with regard to his company?
15 MR. SUTKO:
Initially just specifically to try 16 to keep it from being too confusing and then we'll catch up 17 and ask you about your company as well.
18 THE WITNESS:
Well we were given documentation 19 about the LERO organization and roles that each member of 20 the organization plays.
Also, the call-up procedures in 21 the event an emergency or a drill or an exercise were to
[}
take place of how we would be contacted and how we would 22 ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coserage 8(n336-(M6
3511 01 01 50 l
harysimons 1 respond and then what our response would be effectively.
2 BY-MR. SUTKO:
3 0
What documentation was it that you were given?
4 A
We were given a workbook on the LERO 5
organization on the response procedures.
6 0
Does this book-have a title?
7 A
It does, but I don' t recall it of fhand.
j 8
0 Could you explain what is in the book?
9 A
Well, it's a looseleaf book and it essentially 10 contains I believe an extract from the OPIP -- well several 11 extracts from the OPIP which describes the implementation O
%/
t 12 procedures which are relevant to our role.
13 0
Did you receive any other documentation other 14 than this workbook?
15 A
I don't believe so.
We already had Appendix A r
I 16 of course and that was updated.
So we have the latest i
17 revision of that.
18 O
To the best of your knowledge, is this all that l
19 the other members of your company have received?
20 A
Yes.
We were tested.
I have to say this, that 21 we went through a tabletop exercise with this notebook 22 filling out responses to written questions and these were
{}
l ACE-FEDERAL REPORTERS, INC.
202-347-37m Nationwide roverage 800-336-6646
3511 01 01 51 arysimons I written responses.
That was followed by a discussion of 2
this material, and that training session as it happened was 3
run by Mr. Sobotka.
4 0
Is Mr. Sobotka a member of LERO?
5 A
I think that's true.
6 MR. ZEUGIN:
I want to make sure we've got the 0
7 acronym right.
yeisamemberofLERIOandnotamemberof l
8 LERO.
9 MR. SUTKO:
10 0
Within the LERO/LERIO framework would you i
11 consider Mr. Sobotka to be a superior to the traf fic O
12 engineer?
13 A
No.
14 0
In these discussions that you had after the 15 tabletop exercise what function was he performing?
16 A
Training.
He was the moderator in the training 17 session.
18 0
I think previously you testified that there are 19 three traffic engineers; is that correct?
20 A
That's correct.
21 0
And that presently they are all members of your 22 company?
ACE-FEDERAL REPORTERS, INC.
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l 3511 01 01 52 harysimons 1
A Yes.
2 Q
Does anyone with your company have any other 3
role in LERO?
4 A
No.
5 0
I would like to take a few minutes now and 6
discuss the drill that you participated in, and why don't
)
7 you explain to me how you first knew there was going to be 8
a drill?
9 A
Well, I was informed by LILCO that there would 10 be a drill on a certain date and at a certain location and 11 to be there at a certain time, at 8 o' clock or so in the 12 morning.
13 0
were the call-up procedures used in this drill?
14 A
No.
15 Q
What don' t you take me step by step through your 16 entire participation in that drill.
17 A
Well after arriving there I was escorted to a 18 desk which had been set aside for the traffic engineer.
I i
19 !
was given the documentation that would be required by the 1
20,
traffic engineering to perform that f unc tion.
I reviewed l
21 l that documentation to make sure that it was adequate.
(~s 22,
I also reviewed the maps that were made i
l l
ACE-FEDERAL REPORTERS, INC.
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j 3511 01 01 53 hmarysimons1 available.
These were on rollers like portable blackboards 2
except that they were maps.
i 3
0 What were these documentation and the maps that 4
you reviewed?
5 A
They were the OPIP procedures and Appendix A, 6
writing paper, writing utensils and that's basically it.
7 0
What were the maps of?
8 A
They were all of the EPZ with different overlays t,
9 on them.
One had the bus routes, one had the TC P ' s, one i
10 had indications of traffic flow and those were the three i
~
11 that were of most importance to me.
There was also the
(
12 road crews, the route alerts.
13 0
At this point when you first arrived and had 14 done some initial review of documentation and maps, did you 15 know what the drill scenario was going to be?
.1-16 A
No.
17 0
Af ter you did this initial review, what happened 18 next?
q 19 A
Well, very little actually.
The scenario was 20 played out.
I was introduced to everybody.
I was 21 introduced to the various coordinators.
They all had signs 22 on their desks so I knew who they were, the Evacuation
[
i i
ACE-FEDERAL REPORTERS, INC.
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3511 01 01 54 harysimons1 Coordinator, the Traffic Control Coordinator, the l
2 Transportation Systems Coordinator, the Communications 3
Coordinator and the other players whom I would be 4
interacting with in my" role.
So I just became familiar 5
with the general setup of the EOC.
J 6
0 What happened af ter that?
7 A
Well, I had little to do until it was announced 8
that an impediment had taken place.
This was announced and 9
I became involved in reviewing the impediment and I recommended certain actions be taken to respond to this 10 1
11 situation.
0 12 0
Who informed you that there was an impediment?
13 A
I believe it was Mr. Wilms.
He was I guess the 14 Evacuation Coordinator or the Manager.
No, he was the 15 Emergency Coordinator.
He informed me that there was an 16 impediment and the Traffic Coordinator appraised me of the i
i 17 location of the impediment, and my role at that point was 18 to recommend -- well, the first thing I wanted to do was to I
19 get more information, to get as much information as I 1
20 could.
21 0
What was that information, where was it loca ted 22 and what was the impediment?
ACE-FEDERAL REPORTERS, INC.
1 202-347 3700 Nationside Coserare 80tk334646
)
3511 01 01 55 4
marysimons'l A
Well first you had to confirm that in f act you 2
did have an impediment.
When you got a report from the 3
field, you had to confirm that there was in' fact an i
4 impediment.
5 0
Was that your. responsibility?
6 A
To actually do the confirmation?
They asked for 7
my inputs, and one of my inputs was that we had to confirm j
8 that there was in fact an impediment.
6
)
9 So I related this to the Traffic Coordinator and 10 then he went over to the Communications Coordinator to set I
11 in motion whatever activities had to take place to confirm 12 that there was in fact an impediment.
We identified, for 13 example, the nearby traf fic control points and the route, 14 that is the route the spotter travels on which passed by 15 that location, and suggested that either a traffic guide 16 from a nearby TCP or the route spotter be sent to that 17 location, not only to confirm that there is an impediment, c
i 18 but also to identify what the extent of the impediment was, 19 what kind of vehicle it was, how many lanes were blocked, 20 which approaches were blocked and so forth, in other words, 21 get the detailed information.
l 22 I then recommended that the Suffolk County i
ACE-FEDERAL REPORTERS, INC.
202-347-37(X)
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3511 01 01 56 lhm$rysimons1 Police be informed and asked them to send a car to the 2
location.
I then went to the various maps to lay out the 3
alternate routes for evacuating traffic and then I went to 4
the other route to identify which bus routes could be 5
impacted by this impediment.
6 I believe that the time of the impediment was 7
before the buses were ready.
So I didn't take any further I
8' action since the buses weren' t ou t there yet and we had 9
some time.
But I did lay out the alternative routes 10 pending the confirmation of the impediment.
In other 11 words, I did not want any new instructions made to the 3
\\
12 traffic guards at the TCP 's to implement an alternative 13 route until we did in f act confirm that there was an 14 impediment and that in fact it would take a long time to 15 move the impediment.
16 0
Did you then make a decision as to rerouting if 17 it was necessary?
18,
A I think it was.
The scenario that was laid out I
is that all the lanes were in fact blocked, that it was a 19 j 20 l truck and that it would take some amount of time to remove l
1 21 i i t.
So then we went through the exercise of informing the i
22 lead traffic guide at the staging area, and I didn' t do ACE-FEDERAL REPORTERS, INC.
m_ m r-
3511 01 01 57 lhmarysimons 1
that myself of course, who in turn informed the traffic 2
guides at the adjoining or the nearby TCP's who would have 3
to change their guidance instructions.
4 Q
During this drill were there other impediments 5
that you had to ---
6 A
Yes, there was another one.
There were actually 7
two impediments.
My recollection is that they came hard on 8
the heels of one another in different locations.
I think 9
one of them was a mayonnaise truck.
10 (Laughter.)
11 0
Did you follow a similar procedure in that ---
\\
}
12 (Laughter.)
13 A
Yes.
We went through the same procedure.
It 14 involved a different staging area and different traffic 15 guidance.
So that was different.
16 We also subsequently kept in touch with the 17 Traffic Control Coordinator to determine when the first 18 impediment was removed, and in fact one was as I can recall 19 l and the other one may not have been by the end of the 20 I exercise, at which time we instructed the traffic guides to 21 lj go back to the original routing when the impediment was i
.r'N 22 l removed and returned to " normal" conditions.
w i
ACE-FEDERAL REPORTERS, INC.
~ _ m <-
3511 01 01 58 n rysimons 1 0
At the end of this drill did you receive any 2
evaluation or critique of your performance as traffic 3
engineer?
4 A
Yes.
There was a meeting held subsequently in 5
which the time line of activities for that drill was 6
reviewed by the players in the EOC.
The assessment was 7
that that part of the drill went very well.
8 0
Who performed the assessment?
9 A
Again, that was Mr. Sobotka who led that.
10 0
Do you have any notes of that assessment?
11 A
No.
r 12 0
Do you know if any were made?
13 A
I think Mr. Sobotka had some notes, some 14 handwritten notes which he used as a guide.
15 0
I would like now, Mr. Lieberman, to turn to the 16 contentions in this proceeding and I have some questions 17 that I would like to ask you regarding them.
18 I would like to first draw your attention to 19,
Contention 40 and ask you to review it.
l 20 !
A Well I've already done that.
So why don't we i
21 l move on.
('N 22 O
Do you have an opinion regarding this t
l ACE-FEDERAL REPORTERS, INC.
202-347-3700 NanonaiJe Cos erage N u k 3 h NA
i
$511 01 01 59 i
(1) l marysimons 1 contention?
5 2
A
~Well I only scanned it before.
I of course have 3
no way of identifying whether your data that you used to-l 4
support your argument is in fact accurate.
I haven't gone 5
into that much analysis of it.
j 6
Let me go through it again, if you would like, 7
and I'll offer some comments as I go along, if that's what i
8 you want.
9 O
That would be fine.
10 (Pause while the witness reviews the document.)
11 Perhaps let me ask you this question.
This j
12 afternoon do you know what your testimony on Contention 40 1
13 will be?
14 A
No.
As I said, I have reviewed the logs and I 15 do have some contrary opinions relative to what you have l
16 expressed here.
1 17 l 0
Do you have an overall conclusion or opinion as i
18 to whether or not you agree with the conclusions drawn in 19 Contention 40?
20 l A
Well I don't perceive any fundamental flaw as 21 apparently you do.
I think some of your interpretations 22 are not correct.
I get the sense that you expect that ACE-FEDERAL REPORTERS, INC.
2fi2-347 37(K)
Nationwide Coserage RG33MM6
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(
511 01 01 60 marysimons 1 every traffic guide has to be at their traffic control post 2
before you can accept the idea that the evacuation is 3
unflawed, and of course that is not true.
4 There are only a limited number of locations 5
where the presence of a traffic guide could potentially 4
5 6
' influence the ETE, and we have established a priority i
7 system which is designed to man those posts as early in the 8
game as possible and the less important posts sometime i
9 later.
10 0
Have you done any studies, or has anyone else, 11 to your knowledge, done studies to determine whether those
{}
12 specific posts were manned at any specific time on the day 13 of the exercise?
i, 14 A
I have reviewed the logs and it seems to me that 15 the important posts were manned in a timely manner, perhaps l
l 16 not all of them, but I think that to the extent there was a l
17 delay in manning those critical posts I don't think that I
18 l the effect on ETE is ---
i 19 )
(Counsel confers with the witness.)
i 20 l Oh, I'm sorry.
ETE stands for evacuation time l
21 !
estimates.
(
22 See, we have, and I have already testified to i
I l
ACE-FEDERAL REPORTERS, INC.
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I i
3511 01 01 61 fg V marysimons 1 that, we have incorporated into our estimates some 2
conservatisms which take into account the fact that 3
motorists may not be responding to the traffic scenario 4
ahead of them as well as they would under normal times.
So 5
our ETE then, in my view, is on the conservative side.
6 That is, it is on the longer side.
7 The only places where -- there are relatively 8
few places where the guides have a pronounced effect on l
9 increasing capacity, and these are along North Country 10 Road, a short stretch on Route 25A, some critical 11 intersections such as entry to the Long Island Expressway 12 from the William Floyd Parkway, and all the other locations 13 are there to resolve any conflicts that may arise in terms
]
14 of traffic streams entering the intersection from different
]
15 locations.
But, otherwise, they don't provide increases in 16 capacity, which essentially would be the major function of i
17 traffic guides.
l 18 So as long as those critical locations are 19 manned at a reasonable time, preferably before congestion 20 arises or at least shortly after congestion arises, I think 21 !
the ETE would be satisfied.
l i ()
22 O
Do you know which critical locations were timely ACE-FEDERAL REPORTERS, INC.
m-x-m_
511 01.01 62 marysimons 1 manned and which were not?
2 A
Well, again, you have to define what you mean by 3
being manned in a timely way.
We have estimated based on 4
our studies that congestion would become pronounced about 5
an hour af ter the order to evacuate.
So timely in that 6
manner would imply that the critical intersections were for 7
the most p' art manned at that time.
8 If they are manned somewhat later, then we can 9
expect that to that extent capacity would be somewhat less 10 than we used in our studies.
For example, if we have a 11 five-hour evacuation and of those five hours four hours 12 were congested, which is true for the critical routes, and 13 let us say the traffic guide got there a half hour late, 14 that means that for roughly 12 percent of the congested 15 period there is no traffic guide.
For the remaining 88 16 percert there was a traffic guide.
So to that extent you 17 might argue that well, the ETE is lengthened by an amount 18 which is an interpolate between what we call a controlled 19 evacuation and what we call an uncontrolled evacuation.
20 ;
O Is the only criteria by which you are measuring l
f whether or not the manning of traffic guides is effective 21 22 is whether or not the time it took to man them increased l
ACE-FEDERAL REPORTERS, INC.
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l 511 01 01 63 marysimons 1 the ETE?
2 A
From my perspective, yes.
We have found, for 3
example, that in the event the routing of traffic differed L
4 somewhat from that which we assumed in deriving our ETE, 5
the effect was virtually nill.
.There is no significant 6
change in ETE if people took different routing than what we 7
assumed they would or we recommended they should.
8 So, therefore, if there was any departure from 9
the routing which we recommended and which the people had 10 been informed to take, it would not affect the evacuation.
11 0
Mr. Lieberman, could you tell me what is your
{}
12 basis for stating that the location is a critical location?
13 A
Location is critical when the action of the 14 traffic guides is such as to increase capacity.
I've 15 always said that.
That I say would be the primary 16 criteria.
17 On a second level it would be, and I won't use 18 the word " critical" for that reason, but it would be i
19 l
important to have traffic guides at locations where there 20 l is heavy traffic volume simply from the point of view of 21 traffic control.
(
22 l At a third level I would say there would be ACE-FEDERAL REPORTERS, INC.
202-347 3?(k)
Natioriwide Coserage 8m31MM6 I
b i
511 01 01 64 marysimons 1 locations where there might be alternative routes to be 2
taken by evacuating traf fic where we would prefer that the 1
3 evacuees would take a particular route.
In other words, if 4
there are two directions leaving an intersection and our 5
analysis indicates that one direction is superior to the 6
other in terms of an expeditious evacuation, then the role 7
of the traffic guide there would be to indicate as much.
8 0
Can you identify all locations in the EPZ which 9
you would classify as critical locations?
10 A
Given some time I could, yes.
I can tell you 11 that these are the locations which appear first in the 12-prioritization of the TCP which appears in Appendix A.
,13 0
Is that defined in terms of being within a 14 certain mile zone of the EPZ?
Is that the way you are 15 defining it, cr are you defining it by location?
16 A
No. It is defined in terms of the criteria I 17 just described.
The only time that distance enters into it 18 is in the two-mile area.
I think all the traffic control 19 i points which, or most of them certainly, which expedite the i
i 20 !
movement of people who are evacuating within the two-mile 21 zone would be considered critical for that reason.
(
22 -
0 But as you sit here today you do not have an all-I ACE-FEDERAL REPORTERS, INC.
ms,m sm e_,.
mom
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3511 01 01 65 Omarysimons 1 encompassing list of critical locations; is that correct?
2 A
Well, I have not segmented the list of TCP's 3
which appear in the prioritization table identifying some 4
'as " critical" and others as important and so forth.
It's i
5 something I could do.
6 0
Is that something that you plan to do in i
7 preparation for testifying?
8 A
I may well do that now that you've brought it 9
up.
10 0
Would you please look at contention 40 and tell l
11 me if there are any specific factual statements with which i
12 you disagree?
13 (Pause while the witness reviews the document.)
i 14 A
I think the first sentence.is not correct.
15 0
Why is that?
l 16 A
Well my reading of the logs indicated that many, 17 if not most, traffic guides were deployed in a timely
(
18 manner according to the criteria that I just set forth.
l 19 It's true that they were not all out there at one hour, but i
20 as I said earlier, from the point of view of having a 21 successful evacuation it isn't necessary that they all be 22 out there but just the critical ones.
i ACE-FEDERAL REPORTERS, INC.
I 202-347-37(U Nationwide Cos er age
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511 01 01 66 marysimons 1' And to the extent that the guides at the 2
critical ones are late, it would have the potential effect i
3 of extending the evacuation time by that interpolated 4
amount.
For example, I gave the example earlier that a 5
half-hour lateness translates into 12 percent of the time 6l that the roads are congested.
So I guess if you did an 7 fi interpolation in the simplistic sense you would say that 3
8l for that particular location on these paths you can expect b
9 f that the evacuation time would be extended by 12 percent of a
10 the difference between the uncontrolled evacuation time and 0
,'~1 11 l
the controlled evacuation time.
'J l
4 12 l 0
Using your definitions, please identify all 13 critical locations that were not timely manned.
I 14 A
I can't do that without a lot of informat.> on in r
4 15 k front of me.
.I 16 1 O
As you sit here today can you identify any that 17 were not timely manned?
18 ;
A No.
19 0
Can you identify any that were timely manned?
1 20 l A
My recollection was that basically within an 21 l hour and a half after the order to evacuate virtually al]
l
/m
'x-)
22 l the critical evacuations were manned to the extent that I
l l
ACE-FEDERAL REPORTERS, INC.
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3511 01 01 67 0marysimons 1 data was available.
There was no data from Riverhead.
2 Apparently that data was lost.
What I did have at my 3
disposal was data which showed the times that they left the 4
Riverhead staging area.
So if I were to add an average of 5
20 minutes and perhaps a little more because they had to 6
handle some TCP's near the plant and that was a longer 7
distance, but I still think 20 minutes was appropriate in 8
that case.
9 So I would say that if I added 20 minutes to 10 those times and assumed that the traffic guides got there 11 at that point, I would have to conclude, and again 12 depending on my recollection, that virtually all the 13 critical points were in fact manned.
14 '
O This analysis that you did, do you still have a 15 copy of any of the underlying documents relating to it?
16 A
I made some notes.
I mentioned I made some j
17 handwritten notes of that, and I believe I still have 18 that.
It's just a yellow piece of paper.
19 0
Does it consist of anything other than a yellow t
20 lh sheet of paper?
k 21 A
Well, it consisted of a yellow sheet of paper l
(
22 plus the table of the prioritized TCP which is in Appendix 4
3 ACE-FEDERAL REPORTERS, INC.
2t C-347-3 L n)
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&B DMM6
3511 01 01 68
)
marysimons 1 A.
In other words, essentially what I did was I compared 2
the times that the guides got to their locations identified 3
by location with the prioritization of TCP in Appendix A.
4 O
Have you converted any of this research into any 5
type of a study or report or article or any other type of 6
document?
7 A
No.
I just did this yesterday.
8 0
Moving on through Contention 40 are there any 9
other facts with which you disagree?
10 A
Let's see.
11 (Pause while the witness reviews the document.)
12 MR. ZEUGIN:
Mr. Sutko, I'm not sure the record i
13 is going to be real clear when he gets through this 14 exercise because Mr. Lieberman may read certain sentences 15 as not " factual" but rather more opinion and therefore not 16 make a statement about whether he agrees or disagrees with 17 that.
18 If what you are really getting at is are the 19 l specific facts correct, that is a slightly different l
20 ;
inquiry and it may be easier and clearer for the record if i
21 I Mr. Lieberman just went through each one, that you identify I
(
22 it for him and he can basically say whether he has any ACE-FEDERAL REPORTERS, INC.
202 147-37 0
%none de Coser.lge R n.1%M4 j
g 3511 01 01 69 U
marysimons 1 knowledge one way or the other.
2 MR. SUTKO:
I think the record is clear, Mr.
3 Zeugin.
4 You can just continue, and if you see anything 5
with which you disagree of a factual nature, please let me 6"
know, and if you have nothing with which you disagree, you 7
can simply review it and tell me that.
i 8l THE WITNESS:
I guess the response I just made i
I 9L was more of a comment on the conclusion that is made in the il 10 h contention rather than of a factual nature.
What you said 0
(%
11 l was " fails to provide assistance until long after they are C)
[
12 lil likely to be on the roads."
That's a qualitative h
13 !!
conclusion rather than a fact, but I commented on it h
e 14 4 anyway.
So I don't know if I'm being responsive to your 15 question or not, but we'll plunge ahead.
S 16 i I can't comment on your statistics saying at 9 t
17 l o' clock only two traffic guides had reported and so forth.
1 C{u'h 18 )
I just garr recall that.
Il 19 ]
BY MR. SUTKO:
I 20 ii 0
Mr. Lieberman, why don' t we then move to l
21 Contention 40(e) which is found on page 70.
O 22 ;
were veu inve1ved in deveieging the chenges s
c l
ACE-FEDERAL REPORTERS, INC.
l x_.<-
~
511 01 01 70 marysimons I which are set out in 40(e)?
2 (Pause while the witness reviews the document.)
3 A
Are you referring to the changes at the 4
Riverhead staging area?
5 0
I'm talking about the changes to immediately man 6
the two-mile zone.
7 A
No, I was not involved with that.
4 8
MR. SUTKO:
Let me refer you to the document 9
which is referred to as a June 20, 1986 letter from John D.
10 Leonard to Harold R.
Denton, which is also referred to as 11 SNRK-1269, that I would like marked as Lieberman Exhibit 3.
{}
j 12 (The document referred to was j
i 13 marked Lieberman Deposition i
l 14 Exhibit No. 3 for identification i
i 15 and submitted for the record.)
4 16 BY MR. SUTKO:
t 17 0
This is a compilation of documents, and I am i
i 18 referring to one which is marked page 16 of 19 and at the 19 top it says "Shoreham Nuclear Power Station - Schedule For i
20 Correcting Deficiencies on Areas Requiring Corrective i
l 21 l Action."
22 1 I would ask you to review the entry which is l
l l
ACE-FEDERAL REPOlrFERS, INC.
. um.,
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3511 01 01 71 gU marysimons 1 marked No.
2.
2 (Pause while the witness reviews the document.)
3 I take it it is your testimony that you had no 4
hand in making this revision to the LERO response; 1s that 5,
correct?
I 6'
A That is correct.
7 0
Do you believe that this modification to LILCO's 8
I plans and procedures was necessary?
9 A
Necessary in what sense?
10 0
To improve LERO's ability to man traffic control 11 posts.
)
12 A
This fix is only for the two-mile EPZ.
I recall 13 there was some criticism by the RAC.
They appeared to be 14 i
very sensitive about the need to be extra responsive for i
15 the folks within the two-mile region.
So I think this 16 response will expedite the assignment of traffic guides to h
17 1 those TCP's.
1
- )
18.]
I have problems with the word "necessary."
i 19 i 0
were you aware of this change prior to this 20 afternoon, Mr. Lieberman?
21 )
A I hadn't seen this letter, but I had seen some 22.
words to the effect that this will be taking place in the a
J 0
i l
ACE-FEDERAL REPORTERS, INC.
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3511 01 01 72 Omarysimons 1' future.
2 0
What is your understanding of the LERO response I
3 ll where it says that traffic guides will be pre-equipped?
O 4 I!
A I'm not sure.
I 5 i O
Do you know what it means when they state that l\\
- l 6h there will be an immediate dispatch for the two-mile EPZ?
h 7f A
Well, traffic guides, once they get to the
!l 8
staging area they go through a briefing process and then p
1 9j they are given equipment prior to being dispatched.
It may 10 be, and I'm unsure of this, but it may be that they may
(~'S 11 preclude the briefing and send them directly out.
(_J
[
12 0
Do you have any understanding of what is meant 3
ii 13 l by the second sentence, "An additional person will be j
14 i assigned to assist with equipment distribution"?
15 A
Yes, just what it says.
As I said, the 16 i equipment is provided to all traffic guides and there may 17 have been delays in the process during the exercise.
So 18 that by adding another person to hand out this equipment i
i 19 you could in effect double the throughput of that process f
l 20 and almost halve the time that takes.
l l
21 O
Do you agree with that?
(~'s i
\\
/
22 A
Given that we are dealing with parallel l
i i
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1 il 3511 01 01 73 emarysimons I channels, and it's like having two tellers in a bank 2
instead of one, yes, that's true.
The mean service time 3/
will be roughly halve given that there is always a queue 1
4j present.
5?
O Referring to Contention 40 in its entirety, FEMA 6i found that the time it took to deploy the traffic guides s
l
\\
t 7
constituted a deficiency.
Do you agree with that 8
assessment?
i
(
l 9.
A I could only answer that if I knew what the l
l 10 criteria were for an activity which was adequate and not
(]
11 deficient compared with one that is deficient.
So you will v
12 L have to tell me what the criteria were that they used to 13 arrive at that conclusion.
14 0
IIave you reviewed the FEMA report?
15 A
Not all of it.
16 '
O So I take it you have no recollection as to the 17 criteria that they applied and the objectives that they had 18 for traffic guides in this exercise?
I 19 A
No, I didn't.
l 20 0
Is that something that you plan to review prior 21 to providing testimony?
()
l V
22 A
Yes, sir.
ACE-FEoliRA1. Rl! PORTERS, INC.
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3511 01 01 74 Omarysimons 1 O
Referring again to page 16, would you please ---
I l
2d A
Page 16 where?
Oh, in this.
4 0
3 ll 0
--- would you please review under No. 2 the RAC 1
1 4
j recommendation for corrective action and tell me whether or 0
5 not you agree with their characterization that taking s
6]
between 50 and 70 minutes for deployment of traf fic guides j
0 7) was excessive.
1, 8)
(Pause while the witness reviews the document.)
- I
{
l 9
A I'm having trouble with the wording.
Deployment p
l 10 of traffic guides from the staging area.
Does that ti ne I
O 11 include -- it looks as though that time includes the 30
'O 12 minutes spent in line at the staging area.
So there seems 13 J to be a contradiction in terms here.
14 I'm asking the question is the 50 to 70 minutes 15 the travel time after leaving the staging area or does it 16 i include the time spent in line receiving field kits and i
l 17,
procedures?
l 18 0
Would you please address it under both i
19 possibilities.
I i
i 20 l A
Okay.
I would say if the 50 minutes and 70 21 minutes were just the travel time, yes, that would be n
i V
22 excessive in my view.
If it included say 30 minutes spent ACE-FEDERAI REI'ORTERS, INC.
l a
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3511 01 01 75 j
msrysimons 1[
in line at the staging area and then the travel, the travel f
e 2:
time I think is reasonable.
That would work out to be 1
i; 3,,
around 20 minutes up to 40 minutes if my subtraction is s
4j correct.
So I think that would be essentially reasonable.
5; O
Thank you.
3 6 1 Mr. Lieberman, are there any opinions relating 7 [
to Contention 40 and its subparts which you have which we 8
have not discussed?
9 A
By that you are asking me for my opinion?
10 0
As you sit here today do you have any opinions 11,
relating to contention 40 which we have not discussed?
12 ;
A We are back to where we were 15 minutes ago.
I I
l 13 1 would have to go through it.
i 14 O
That's fine.
l i
15 (Pause while w witness reviews the document. )
l t
16 A
Well, I can't comment about the facts under l
l 17 "A".
I don' t know if you are accurate.
So I have no I
18 comment about that.
19 (Pause while the witness reviews the document.)
f i
20 Under "B" you complain that they are not i
21 dispatched until the order to evacuate is given.
I don't r'3
()
22 think there is a basis for that complaint.
I think that i
ACE-FEDERAI. REPORTERS, INC.
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1511 01 01
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76 9
i mcrysimons 1 it's fitting and proper that they should be dicpatched at 20 that point in time.
There can be many hours that elapse J
3j between the general emergency and the order to evacuate and E
4]
there is no point in having these people out there before j
n 5[
the evacuation is actually ordered.
I 60 0
Any other statements with which you cannot i
l 7
agree?
8, A
Again, I can't comment on your statistics.
I 9j just can't recall it.
10 1 (Pause while the witness reviews the document.)
(~)
11 l I think, and I hesitate to use the word i
</
12
" disingenuous," but you bring up the time when the last guy j
i 13 arrived at his post.
I don't think that is relevant.
14 0
Why is that?
15 A
Because he could be an outlier.
I think what is l
16 important is that again these critical points are manned in l
l 17 a timely manner and if the others are manned at some later I
18 time the effect is -- there may be no effect or little i
19 effect.
So if there is one person that got lost say or who j
20 for any reason took a longer time than he should have, i
21 there is no reason to cite that person as being indicative i
<n k.)
22 of the entire process which is what is implied here.
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l 1511 01 01 h
77 lII morysimons 1 0
Any other statements with which you disagree?
2 ll (Pause while the witness reviews the document.)
l 3"
A Again, I think you repeated something here, at
.i 4
least you did under "A" under the introduction, namely ---
5 (Counsel confers with his witness.)
6 I'm on page 69 here.
I'm still under "B".
7 You have got " fails to provide any evacuation 8
assistance," et cetera, "until long after the evacuees 9
would be on the road," and I don't think the facts bear l
t 10 that out.
11 0
What is your understanding of when they would be
}
12 on the road?
13 A
Our analysis showed that it would be about 15 to 14 i 20 minutes after the OTE ---
l f
15 0
What is an OTE?
16 A
Order to evacuate, sorry, before any substantial 17 amount of traffic would be generated, and then, as I said l
18 carlier, it would be an hour after the OTE before
,\\
l 19 congestion arises.
So I think this statement is not 1
20 correct.
21 0
Annume that the OTE were at 1024.
r~'s
_)
22 A
Yes.
An-Flinlil<AI. Riilul< Ilil<s, INC.
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'1511 01 01 78 9
marysimons 1l 0
What would you consider to be a long time after i
l 2
evacuees would be on the road attempting to evacuate?
1 3
A Well, I would focus on the start of congested 4$
conditions for the reasons given earlier, that the role of 5
the traf fic guide is to take whatever action is necessary 6
to maximize capacity.
There is no need to maximize 7
capacity until the demand reaches that level.
So I would 8
say that if they got out there past 12:30 I would be 9
concerned because then an hour would have gone by and they 10 would have about an hour of congestion at some locations 11 i without traffic guides.
12 Ilowe ve r, if the critical intersections were l
l 13 '
manned before that time, then I would not feel f
l 14 uncomfortable about it and I think the statement is t
i 15 substantially correct.
16 0
Let me make sure that I understand your 17 testimony.
If evacuation were ordered at approximately 18 10:30, it is your testimony that for you to be satisfied 19 that traffic control posts were adequately manned that they 20 would not have to be manned until approximately 12:307 21 A
tio, I didn't say that.
What I nald is that if
^
V)
(
22 the critical traffic control posts are manned by 12:30,
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1 3511 01 01 0
79 then I would feel that the extension of ETE is well within m2rysimons 1 2
the uncertainty envelope of any forecasting analysis, which 3
in English means I think that the actual ETE would 4
approximately what they have computed.
5l 0
So if the critical control posts were not manned 6
prior to 12:30 that would not give you great concern; is l
7' that correct?
I 8
A No, you've got it backwards.
l i
9 0
If they were not manned until af ter 12:30 you j
10 would have concern?
r~)
11 A
I would have concern that the ETE would in fact N~'
12 be realized.
I think it would start extending out.
t i
13 0
Hut if they were not manned prior to 12:30 that I
i i
14 would not concern you; is that correct?
)
I 15 A
Mo, you've got it backwards again.
If they were j
16 manned prior to 12:30, then that would not concern me.
I 17 0
Hut you do not agree with the statement that you 18 are not concerned if prior to 12:30 thone posts remained 19 unmanned?
20 A
No, you've got it backwards again.
21 0
in there ---
(O
,1 22 A
See, there'n no nharp point of demarcation.
Aci:-Fitni:iui Ricivi< ii I<s, Ixc.
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1511 01 01 80 h
marysimons 1 Remember what I said earlier.
I said to the extent that i
2t these critical TCP's are not manned, then the actual i
l l
3 evact.ation time is going to move from the controlled i
I 4
towards the uncontrolled, and the extent to which it moves I
i 5
in that direction depends upon the lateness in which these 1
6 critical traffic control points are manned.
7 0
In there anything eine in Contention 40 with t
8 which you disagree?
l 9
Well the conclusion at the bottom of page 69 I l
10 dinagree with.
I think that it's just not good practice to i
l
(']
11 dinpatch traffic guides before the order to evacuate is U
l 12 given nince there in no way of predicting when that order l
13 will be given.
It might be hours and they are ntanding out l
l 1
14 there for no purpone.
l 15 I'm going on to page 70, No.
40."c".
16 (Paune while the witi.ons reviewn the document.)
17 A
Well I don't agree that the information provided 10 by the Elis advinory wan falne.
I would like to noe the 19 actual quotation of the Elis monnage.
Do you have it?
20 Pin. SUTK0:
Yen.
I can nhow you that.
21 I would like thin marked an Exhibit 4, pleano.
,O V
22 Aci:-l'I{Ill{RAi Ri{IuR i I{Rs,1NL.
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1511 01 01 I
81 marysimons 1 ]
(The document referred to was 0
2 ;;
marked Lieberman Deposition i!
3 L Exhibit No. 4 for identification ll 4(
and submitted for the record.)
?
BY MR. SUTKO:
5 6l 0
Please turn to the page which at the top is l
7r marked 49 of 63 and you will find a statomont that says "You will be directed along ovacuation routes by trained 8
i 9
traffic guidon who know which way you should go."
10 1 In light of that statomont do you find this
'~1 11 troubling?
O 12,
A No ---
f1R. ZEUGIN:
I want to mcke sure the question is 13 14 clear to Mr. Lieberman.
Are you asking him given that ono 15 particular statomont does he find what is stated in 40(c) 16 troubling?
17 '
MR. SUTKO So.
IIis conclusion troubling.
I 18 MR. ZEUGIN:
I'm not sure I'm clear.
i 19 l Tile WITNESS:
I'm not clear oither, but I'll try I
20 ft.
21 The monnaqo nayn "You will be directed along V(~'s 22 ovacuatton routon by trained traffic quidos who know which
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3511 01 01 0
82 marysimons 1 way you should go."
j.
ii 2 fl Over the greater part of the evacuation process i
3 that is a true statement.
4 BY MR. SUTKO:
5 0
Isn't it a fact that as of 1024 there were no 6
traffic guidos that woro deployed?
7 A
That is true.
8 0
And isn't it also correct that the EDS messago l
9 doon not make any exceptions for any individuals as to 10,
whether or not there will be traffic guidos to guido them?
I
(~ ^;
11 A
Look at the tense of the mossago.
It says "you (J
12 ;
will be."
That's a future tenso.
It doesn't say they aro 13 out there already.
l l
14 0
Do you have an opinion an to when you would l
15 expect ovacuoen to firnt be on the road?
16 A
I already said it would probably be about 15 to 17 20 minutos after the OTC.
l j
18 0
In light of that fact do you believo that thin 19 monnago in minionding?
I 20 A
tio, becauno it doonn't imply any time frame.
21 0
ff, an a mattor of fact, within 15 or 20 minuton r'~T
(_,/
22 there woro not traffic quiden at the pointn at which ACl!-li (I )l(R Al RI:.luuTi(Rs, INC.
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l 3511 01 01 P
83 g
marysimons 11 individuals woro driving, would you find that to be 2
misleading?
3 A
I think that with those early ovacueos who make u.
I 4
it through the network without encountering a traffic 5
guido, they would have their expectations violated.
l l
6 0
What functions do you think traffic guidos
{
l 7
perform in anslating ovacuation?
I O
A I think wo have boon through that.
Their l
9' primary function, the one that is mont important from my l
10 point of view, in thone critical TCP'n whero they act to
[]
11 increano the capacity of the roads, and I have already v
12 defined whero they aro.
Other functions involve annintanco i
I 13 in routing by virtue of their hand and arm movementn.
l l
14 Other functionn involve the resolution of acconn to 15 intornoctionn by traffic ntroams which approach from l
16 dif ferent directionn onnontially performing the rod, green 17 cyclo.
18 Another f unction I would nay in one of general 19 reinforcement.
Simply their prononco could tond to 20 roannuro evacunon that thin in a controllod ovacuation and 21 that their bont intoronto are boing taken caro of.
px C
22 O
tio you noe thom an providing any information At 'l -l?Fl )ER Al. R El'()R I ERS, int.
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1511 01 01 h
84 9
1 ;!
unction?
marysimons f
l 2l A
Directional information function, yes, which 3 '
would be hand and arm movements that I've indicated.
41 0
How about any directions as to where evacuoos 5e should go as relating to specific locations?
6 A
No.
7 O
In there anything 01so in thin report with which 0
you disagroo?
9 (Pause while the witness reviews the document.)
10 Mr. Lloborman, you can exclude 40(o) which I (7
11 bollove wan discunned.
l 12 A
Well, the conc 1 union draw at the end of (o) I 13 don't agroo with on pago 71.
j 14 0
Which conclusion in that?
l 15 A
That the plan in fundamentally flawed.
1 I
16 0
And why in that?
17 A
!)ocauno I think that whatever exceptionn the RAC 18 took to what went on in the oxorcino can be fixed, and I 19 think that baniently the performance of the traffic guidon 20 woro in kooping with the plan.
21 0
I have a few more quontionn for you.
f-)
()
22 Do you know when you will boqin writing Aci:.-Fia lia< Ai Ria'oR n:1<s, In.
I I
)
1511 01 01 0
85 O
marysimons1]
testimony on Contention 407 J
2 A
No, I don't.
4 30 0
Do you have any plans to do so in the near 0
40 future?
5 A
Not within the next wook.
That's cortain.
6J 0
Do you know of any research or studies which you s
s f
7 plan to rely on in drafting that testimony?
I 8
A Yes.
I probably would look at the proceduros 9
drawn up in other plann.
j 10 0
What do you mean by other plans?
11 A
Other ovacuation plann, particularly thono in 12,
New York Stato.
13 0
Do you have any npocific plann in mind?
j 14 A
Woll, there are only a limited number of nuclear 15 power stationn in Now York Stato.
So that would be Indian I
16 Point, Ginna, which I'm nomewhat familiar with and Nino 17 Milo.
10 0
Why would you find thin helpful?
I 19 A
Woll, becauno it'n alwayn unoful in developing 20 any kind of ntudy to noo what han boon dono by othorn no i
1 21 that you have a framework on which to comparo your point of (U
22 view with othorn.
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86 e
9 l
marysimons 1 l 0
If you discovered that TCP's were manned in c
I L
i shorter timen in other drills, would that load you to i
2 l
\\
l 3
chango your conclusion as to whether or not the LERO 1
4 organization adequately performed that function on February l
l 51 13th?
I 6
A Well it might have an influence.
7 0
Is thoro anything etno you can think of that you l
8 would rely on?
9 A
Not offhand.
}
}
10 0
llave you gathorod any of thone matorialn that I
(~)
11 you intend to review for thone other plantn?
l V
l 12 A
Well, not npocifically for thin purposo, but I l
l 1
13 do have in my filen a portion of the plan for Indian 1
l 14 Point.
Of courno I have the prior plan for Ginna, and l
l i
15 that'n about it.
And I have about a dozon other plann in I
16 the filen.
l 17 f1 R. StJTK0:
I nuggent we tako another fivo-18 minuto break and hopofully we can expedito thin.
19 (flho r t reconn taken.)
i 20 fly MR. titJTK0 :
21 0
Mr. Lloborman, ploano turn to Contention 41.
AU 22 l'l:M A found that the delnyn in ronpondinq to tho two
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1511 01 01 87 l
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marynimons 1 li impediment free play messages constitutes a deficiency.
2 Are you in a position to agree or disagree with that 3
statement?
4 A
Do you have a list of criteria on which they I
5 baned this?
l 6
0 What critoria would you like to sco?
l 7
A Well, my reading of the logs indicated that 3
8 there was a failing in that the information wan not fed up 9
the chain of command.
. was only fed down the chain of 10 command.
I think if that constituten a deficiency, well 11 then I will accept that.
v 12 But I think that the actionn that they took, if 13 you turn away from that, were timely and were reanonable.
i 14 I alno think that, and thin in my own opinion, that it in 15 very difficult to nimulate an event such an an impediment.
l 16 i think in one cano there van conniderable confunion from 17 FI:fiA'n point of view an to where the impediment actually 10 wan.
I think thin wan in Yaphank whoro the initial 19 neonario located tho accident north of the intornoction and 20 i think about l'i minuton lator the routo npottor went by in 21 renponno to a rottuont from the I:OC and found nothing thoro, O
'N j 22 and t ho ITf1A reprenont ativo wan actually cant of the 21 intornoction.
Al'l-li l I ' lilt \\l RI l'( )lil lil<S, INC.
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9 88 e'1511 01 011 marynimonn 1 ?
Now if that had boon a real event there in no 2 i quention but that the route spotter would have identified 3
the existence and location and extent of the accident, I
i 4.
wherean in actual fact he indicated that he naw nothing and i
5 he continued his route.
I 6h Then I think thoro wan nomo flip-flop lator an 7
to whethor it wan cant or north of the intornoction.
I don't remember the detalin fiu t I think in that nituation, P
9 I think thoro in nome deficiency on FI't1A'n part an woll.
i 10 In general an accident of the novoro nature j
(~';
11 which in pontulated in very difficult to hido.
It'n U
12 nomething that provoken a ronponno in torma of traffic 13 behavior which in rather dramatic and in cany to detoct.
I i
14 no that what we had horo wan an artificial environment 15 which, in my view, in not repronentativo of a real world 16 condit inn.
17 0
Can you identify any problemn with I,I:it0'n 10 ronponno to tho impedimentn other than the fact that thoro 19 war confunion an to location?
20 A
1,'o l l t ho r o ' n t h e o ne t h a t I montioned.
I think 21 it wan tho, aqain by memory, a traf fic contr ol coordinator (V>
22
-- no, i t. wan the routo coordinator to whom thin At 'i:-l'i:l )lxsI RI:I'( m I i Rs,1NL ~.
I t
i I
'4511 01 01 4
89 1
l marynimonn 1 information was givon, and if he had followed the i
2 proceduren he would have sont that information up the
)
i 3
organization to the Evacuation Coordinator who would then l
4 have taken action, which he eventually did.
5 Acido from that, an I nald earlier, I believe t
6 the monnage went out to the route spottern to confirm the 7
oxintonce of the impediment.
An I nald, one routo apotter 8
got thoro very quickly and didn't non anything which, an I l
\\
9 nald already, in unroalintic.
10 The other one took a little longer.
I don't p
11 recall what the pannago of time wan.
I do believe it wan i
l G
l 12 40 minuten or no before ho got out thoro, and I bollove 13 that he did identify the impedimant.
I don't recall what 14 happoned after that.
15 Ho in that ronpoet I think the 40 minuten in a 16 little lonqor than you would liko it to bo, but I don't 17 think it in exconnivo.
10 0
An you nit hero thin aftornoon, do you know what 19 the banic nubntanco of your tontimony will be concerninq 20 Contont ton 41 ?
21 A
Not at thin point, no.
O V
22 0
Have you developed any ovorall opinion an to
(
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k 1511 01 01 90 9
mnrysimons 1 a whether or not you agree with the general conclusion of 2
Contention 41, which is that LERO failed to properly 3
respond to the impediments both in terms of being timely i
l 4
and in the equipment and personnel which they brought to j
5 remove the impediment?
l i
6 A
Well, there are two impediments.
Do you want to i
i 7
talk about one at a timo?
I 8
0 Do your opinions diffor an to the two?
I 9
A Yes, they do.
I just naid that the route 10 npotter qot to tho firnt one within I think 15 minuten, and i
(
O 11 I think you can't boat that.
l G
l 12 O
Which one in that?
i l
13 A
Thin in the one in Yaphank.
It'n the gravel l
14 truck I think.
l l
l l
15 0
What in your opinion then an to the II!to l
l 16 ronponno to the gravol truck impodiment?
l 17 A
fly rocollection wan that FEMA I think FEMA i
I f1 wan concorned that tho monnaqo did not identify that thoro 19 woro throo other vohiclon involved and that only one tow 20 truck wan nont, and aqain I'm relyinq on my memory.
21 My argument in that thoro probably wan no nood n
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22 to nond moro than ono tow truck hocauno if you havo throo Al'l--lli l )l:R.\\l RlR *11:RS,IN(.
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'l511 01 01 ll 91 marysimons 1 vehicles plus a gravel truck splattered over the landscape l
2 all you have to do is to open up the road for evacuating 3
traffic.
You don't have to move all the vehicles off the l
l 4
road and clean up the roadway.
All you have to do is to l
5 clear a path for the outbound lanes.
f 6
If you can allow room for the inbound lanes, so i
7 much the better.
But you do have to clear the lane for the f
8 outbound lano and clear the lanon for the outbound 9
traffic.
In all probability a ningle tow truck would be l
10 able to do that in the cane of thin accident.
If he found
{')
11 that he could not do it, then there would be a need for him v
12 to ank for annintance.
I l
13 I think that even if the EOC had known there i
I
/l 14 were three vehicion plun a gravel truck involved, t hey d ici-l-
l innondingonlyono_ltwotruckbecauno Lf p l
. i, w f y 15 the right thing 16 accidentn are eventn which are random in timo and locat wn l
17 and thoro could have boon another one over the name time 10 frame which would require an adjoining tow truck to renpond 19 to it.
It would be improper, in my view, to nond more tow 20 truckn than may be neconnary.
21 Let'n talk about the other one.
I don't know if qU 22 you have more queqtionn about thin one.
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Let me just ask a follow-up question on the 2
gravel truck.
3 A
Sure.
4 0
Do you have any other basis for your opinion 0
5 regarding the adequacy of LERO's response to the gravel 6
truck?
l 7k A
I think I've said most of it.
l l
8' O
Please then give me your opinion as to the fuel 9
truck of whether or not LERO's responso was adequate and l
10 your basis for that conclusion.
l 11 A
The fuel truck also had a long responso, and f
12 that again was due to the fact that the information was not 13 fod up.
So I think that was the basic deficiency and 14 everything followed from there.
15 j That particular impediment involved a fuel truck I
16 4 that was -- I think the statomont was something that thoro 17 i was an oruption of a fuel truck.
I don't remember if the 18 !
statomont of the impediment indicated that thoro was fuoi i
19 spillod.
I think it did not, and yet FEMA inttrproted that 20 to moan that there was fuol spilled.
I think that was a 21 problem with the definition of the incident.
4 I
22 )
I don't remember in great detail what LERO's Acti-FEDERAL REl',ORTERS, INC.
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1511 01 01 93 llI K
marysimons 1W response was, but I do believe that they did call a fire 2
department and they did call the owner of the fuel truck to 3
dispatch a vehicle into which you could pump the fuel, and 4c I think those are the proper responses.
5 i 0
Do you have an opinion as to whether or not LERO 6
responded to the fuel truck impediment in a timely manner?
.l 7
A I think that was later than it should have been l
8 in simulation space, but I don't think, as I said before, 9
that the simulation was properly representative of the real 10 '
world again because of the immediate change in the traffic
(~T 11 h environment which would be noted.
\\)
12 0
Do you feel that LERO was deficient in not i
13 seeing that information was fed up?
14 A
I think so, yes.
I think that was an error on I
l 15 the part of the individual involved.
i i
16 0
Do you have any other opinions relating to the 17 fuel truck impediment?
l l
18 A
I think that the scenario is an extreme one.
It i
19 takes a hell of a lot of speed to turn a fuel truck over.
20 They are very heavy and they are very stable vehicles, and i
21 I think the postulate of an impediment of that nature is l
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22 unreasonable.
It's not that it can't happen.
Anything is l
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1 )j marysimons possible in the real world, but the prospect of it 2
happening, especially on a two-lane road, which is Route 0
3 !!
25A, under conditions where you have clear weather and a g
dry pavement is so remote as to be, in my view, not an 4
a 5f acceptable example for an exercise of this type.
I just 0
61 think they bent over backwards to create a scenario which 7
is not realistic.
8 0
Assume that this scenario was realistic,
)
9, however, do you have any other opinions as to the response d
10 to the scenario?
(~)
11 A
I think other than the deficiency that I noted, t/
12 l they did the right things once the information got to the 13 top in a timely manner.
14 0 0
I would like to direct your attention to the 15 last sentence on the bottom of page 78 of the contentions 16 l which is part of Contention 22(1) which will be dealt with 17 under Contention 41 and ask you to review that sentence and 18 the remaining portion of that paragraph which goes on to 79 l
19 and then I would like to ask you some questions about the 20 study that is referred to there.
21 MR. 2EUGIN:
I take it you are referring to the l
('^))
N._
22 sentence that begins "In fact, during the two-week period"?
l l
l ACE-FEDERAL REPORTERS, INC.
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3511 01 01 95 Omarysimons 1 MR. SUTKO:
That's correct.
2 (Pause while the witness reviews the document.)
3 THE WITNESS:
Okay, I've read it.
4 BY MR. SUTKO:
5 0
Have you had an opportunity to review this 6
study?
7 A
The study being the police study?
8 0
That is correct.
9 A
Yes, I've reviewed that sheet.
In fact, I think 10 each precinct provided a summary over 15 days of accidents.
11 0
Do you have an opinion regarding that data?
12 A
Relative to what?
i 13 0
Do you agree that it is representative for that 14 time period in Suf folk County in terms of the number of 15 accidents?
16 A
Well definitionally if it is in fact a 17 statistical summary of what happened, then it is 18 representative.
n 19 0
Have you had an opportunity to perform any 20 studies of the area that was the subject of that study 21 during during the two-week period?
22 A
The area being the Sixth Precinct?
ACE-FEDERAL REPORTERS, INC.
202-147-3MX)
Nationwide Cos erage 80Lk336-6M6
511 01 01 96 marysimons 1 0
That's correct.
i 2
A No.
3 0
Do you believe that the study supports the 4
conclusion for which it is relied upon?
4 5
A No, I think it is a false conclusio 1 6
0 Why is that?
7 A
The study actually supports a finding to the 8
contrary.
9 0
Why is that?
10 A
Really what you have to do is analyze these 11 accidents in greater detail than is provided in the police 12 summary lists.
That's my opinion.
Many accidents occur l
13 during periods of very low volume.
Those are the types of 14 accidents which could be more severe than those which occur 15 during high volume, and there is data to support the 16 statement I just made, the reason being that t e severity h1b 17 of an accident isdirectlyrelatedtotheinstantfneousin I
18 l kinetic energy involved.
In other words, if you have a car l
i 19 ;
that is traveling at 60 miles an hour, you have four times i
l 20 l the kinetic energy of the same car traveling 30 miles an l
21 hour2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />.
l
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22 f When you have an evacuation where the mean speed l
ACE-FEDERAL REPORTERS, INC.
20L347-3700 Nanonwide rmerage
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3511 01 01 97 0marysimons 1 is under six miles an hour, you have a completely different 2
traffic environment than that which is described by this 3
accident listing.
So one cannot make a transference 4
between this experience and what would happen during an 5
evacuation.
6 The second thing is that the area involved 7
extends beyond the EPZ.
It's the entire Sixth Precinct, 8
which I believe is roughly double the area of the EPZ.
So
(
9 on that basis alone, assuming a uniform population density 10 throughout the Sixth Precinct, you would have to divide 11 these figures by half.
12' I'll argue further that that part of the Sixth 13 Precinct which lies outside the EPZ is more heavily 14 populated than the EPZ which means you should divide it by 15 more than half, or perhaps by a third.
16 Having done that, if you take the 22 accidents 17 per day and divide it by three, you come out with a number 5
18 l like let's say eight per day.
That is eight per day over a 19 24-hour period or one every three hours on average.
20 l You have an evacuation that takes place over 21 ;
five hours.
So you are going to have between one and two 22 accidents during the evacuation within the EPZ.
We
{
ACE-FEDERAL REPORTERS, INC.
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511 01 01 98 marysimons I estimated something on the order of four.
2 So what this evidence seems to say is that our i-l 3
estimate of four is about twice as high as it should have i
4 been.
So one can expect perhaps two accidents.
Of the two 5
accidents you have about one chance in five of one having a 6
tow truck.
I would argue that is much less than that I
t 7
because of the speeds involved.
8 So I think what you have presented here is 9
evidence which supports the information which we provided 10 in the plan and runs contrary to your conclusion.
11 0
Do you have any other impressions regarding the
{
I 12 study conducted by the Suf folk County Police Department?
i 13 A
Not without a further investigation into the
\\
14 details of these accidents.
15 0
I have a few more lines of questions I would l
16 like to ask you.
17 First, I would like for you to turn to 18 l Contention 41(a) which is found beginning on page 72, and I 19 l would ask you if you agree with the conclusion that it 20 i reaches regarding mobilization.
l 21 f (Pause while 'the witness reviews the document.)
22 A
Well, if the conclusion is based upon facts l
ACE-FEDERAL REPORTERS, INC.
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i 511 01 01 99 i
marysimons 1 which are undisputed, then it just follows naturally.
2 0
So if the facts are as they are stated, you 3
would agree with the conclusion; is that correct?
4 A
Yes.
I would say that if only 65 percent were 5
mobilized, then the conclusion that the -- oh, wait a 6
minute.
I don't like the wording here.
No, you've 7
overstated it.
You said, "the LERO personnel essential to 8
the implementation of the recommendation."
Which 9
recommendation?
10 0
Where are you reading?
i 11 A
I'm look!ng at the last -- I presume the last 12 sentence contains your conclusion on page 73.
13 0
That is correct.
i 14 A
And I have a problem with the wording of it.
15 0
What problem do you have?
16 A
"The LERO personnel essential to the 3
17,
implementation of the recommendation who are not even fully 18 l mobilized."
Well, it's cute wording because the 65 percent 19 {
being less than 100 percent says that you are not fully I
20 i mobilized.
But the implication is the fact that they are i
1 21 i not fully mobilized means that there were an insufficient i
22 number of personnel that are essential to the 1
f I
ACE-FEDERAL REPORTERS, INC.
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511 01 01 100 marysimons 1 implementation of the plan and that doesn't follow.
2 You have to show that it requires 100 percent of 3
the people to be there in order for the plan to be 4
implemented.
That is not shown here and I don't think it i
5 follows.
6 0
Do you have an opinion as to whether or not you t
7 need 100 percent?
I 8
A It depends on how you define the term need.
9 Certainly the evacuation can go forward, as I said earlier, 10 without all the traffic guides being in place, and that is 11 also true with the road crews.
{
12 0
Do you believe it's essential for the l
l 13 implementation of the LILCO plan that 100 percent of the 14 road crews be in place?
15 A
At what time?
16 0
At the beginning of the evacuation.
l 17 A
No, I don't think that is essential.
i 18 j 0
Do you have an opinion as to what percentage are 19 necessary?
20 !
A I would say that you have to have enough people l
21 !
on hand to deal with the circumstances which are reasonably 22 expected to take place.
If you expect, for example, to ACE-FEDERAL REPORTERS, INC.
202-347 37(o Nationwide Coserage Mn33M616
511 01 01 101 marysimons 1 have four accidents over a five-hour period or in the case I
2 as we just discussed we should expect no more than two I
3 accidents, then you should have a minimum of two or four, T
i 4
depending upon your point of view, of the road crews on I
l 5
hand.
6 0
For the LERO plan do you know what the absolute 7
number is?
l 8
A I could look it up.
It's in Appendix A.
I 1
9 think it's about a dozen.
10 0
Do you believe that 65 percent is sufficient?
11 A
At the outset of the plan?
12 O
Yes.
l 13 A
Yes, I think so.
That 65 percent translates to i
i 14 eight or so.
15 0
I would next like to ask you to review 4
16 Contention 41(e) which relates to the traffic engineer 17 j which we previously discussed, and ask you if you agree 18 with the conclusion expressed in 41(e) regarding the 19 )
ability of the traffic engineer?
20 f (Pause while the witness reviews the document.)
a 1
21 )
Have you had an opportunity co review that?
1 O
22 4 A
Yes.
i ACE-FEDERAL REPORTERS, INC.
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marysimons 1 0
Do you agree with the statement contained in 2
41(e) that even assuming that such a person could provide 3-such assistance, it would have no impact on the basic 4
structural flaws in the plan and demonstrated incapacities 5
of LERO personnel described in this contention?
6 A
Well I don't agree with the conclusions that 7
you've reached that there are basic structural flaws.
So 3
l 8
obviously I can' t agree with this conclusion.
9 0
In your opinion, was the addition of a traffic 4
10 engineer necessary?
11 A
I'm not sure it was necessary.
I think it was a
[}
12 good' idea to have someone in the EOC who has a knowledge of
(
l 13 the traffic patterns as they would be under evacuation I
14 conditions, and the background to identify how best to 15 respond to an unscheduled, unpredictable event.
So I think 16 it strengthens the team.
I'm not sure I would go so far as 17 to saying that-it was necessary.
18 I'm willing to bet that there are many of the 3
i 19 l operating plants who have EOC staffs which do not include a I
20 traffic engineer.
21 0
Did you participate in the revision of the LILCO 22 plan and procedures in which a traf fic engineer function i
1 1
r ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationw kle Cm erage 800-33MM6
511 01 01 103 marysimons 1 was inserted into the plan?
2 A
Yes.
I reviewed what his function was, yes.
3 0
Did you draft those changes?
4 A
I don't think I drafted the changes, but I know 5
I reviewed it and may have edited it.
6 0
When you reviewed the draft, what was your 7
response to the draft?
8 A
I don't remember.
l 9
0 Do you know who actually did draft the changes?
10 A
No.
11 0
Referring to Contention 41, are there any 12 documents or studies or articles that you plan to rely on 1
5 13 in drafting your testimony?
j 14 A
I would say the same as those I mentioned before i
i 15 for Contention 40.
I might also look into the literature f
16 and see whether there is any data which -- I know there is i
l 17 data which describes response times in terms of how long it l
1 18 l takes to remove an impediment.
I j
19 l 0
Have you begun drafting any types of studies f
20 )
yourself or any other compilations that directly 91 ate to a
a 21 l the testimony that you might provide regarding Contention 22 41?
I l
I l
ACE-FEDERAL REPORTERS, INC.
202-347 3700 N.tiionwide Cos erage 8tb 346646 k
511 01 01 104 marysimons 1 A
No.
I think the comments I made earlier about 2
getting a more detailed description of the accidents might 3
lead to a study, but I would have to think about that.
4 0
Do you anticipate receiving the assistance of 5
any other individual or individuals in drafting your k
6 testimony other than counsel?
7 A
There may be other people at KLD who would 8
assist me.
9 0
Anyone outside of KLD?
10 A
I don't have anyone in mind at this point.
11 0
The next question I have is within the framework 12 of the way in which the contentions now stand, Contentions 13 25, 29 and 22(1) are all included within Contention 41 and 14 I I think we even discussed portions of those this afternoon 15 and this evening.
I take it that when you provide h
16 ;
testimony on Contention 41 you also will be providing I
l 17 f testimony on 25, 29 and 22(i) as those relate to 417 18 A
It's possible.
I l
19 l MR. SUTKO:
I have no further questions.
I i
I 20 !
Thank you.
l l
21 MR. ZEUGIN:
I think I may have one or two very 22 quick questions.
ACE-FEDERAL REPORTERS, INC.
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-105 marysimons 1 (Pause.)
2 EXAMINATION 3
BY MR. ZEUGIN:
4 0
Mr. Lieberman, do you recall during your 5
deposition that Mr. Sutko asked you a series of questions 6
about LILCO's response to the two roadway impediments, and 7
in response to that you identified what you called the 8
deficiency in upward communication?
Do you remember that?
9 A
Right.
10 0
Could you explain what you meant when you used 11 the word " deficiency"?
/}
12 A
Well, it is a deficiency relative to the 13 procedures which are laid out in the plan that this 14 information should be transmitted upward to the Evacuation 15 Coordinator.
16 0
I take it then that you did not use the word 17
" deficiency" in the same, or you didn't intend to use it in 18 the same way FEMA uses that word in its formal report?
19 l MR. SUTKO:
I will object because he stated that 20 l he doesn't how FEMA used the word.
i 21 MR. 2EUGIN:
I just want to make sure the record l
is clear.
22 i
ACE-FEDERAL REPORTERS, INC.
I 202 147-3700 Nationwide Coserage Mi-31N
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marysimons 1 !i THE WITNESS:
Well, you're both right.
I don' t li 3
2 !!
know how FEMA used the word, and I didn't intend it to be 1
3 used in that form.
4h MR. ZEUGIN:
Fine.
1 5 il No further questions.
il F
6[
(Whereupon, at 6: 20 p.m., the deposition of i
(
7 i,i EDWARD BARR LIEBERMAN concluded.)
8$
d 91 I have read the foregoing pages 10
/
through /Od, inclusive, which r1 11 ]
contain a correct transcript of
(
)
v 12 the answers made by me to the 13 ll questions therein recorded.
14 Signature is subject to 15 h corrections.
16 EDWARD BARR LIEBERMAN t
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marysimons 1 ;lil i
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i 2 ll I,
/ICW H'6 AodC M'"",
Notary Public in and 3
f o r t he b/ 7 E C '" #"#'~
dc hereby certify that I a
4 am notarizing and witnessing signature for the Deposition 5 l!
of EDWARD BARR LIEBERMAN on this
,j a day S '4 ^'M^D' li 6
of 196[.
4 7j Notary Public in and for the l
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My Commission expires Nnr:nN N,r/3 7 9l
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ROCHELLE LANDSMAN 11 f Notary Pubhc. State of New York
,s i
i, M 52-4742519
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Quahfied in Suffolk County 7
Commission Expires March 30.19 [
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1 CERTIFICATE OF NOTARY PUBLIC 2
1 3
I, MARY C.
SIMONS, the officer before whom the l
4 foregoing deposition was taken, do hereby certify that the
}
5 witness whose testimony appears in the foregoing deposition 6
was duly sworn by me; that the testimony of said witness 7
was taken by me in stenomask to the best of my ability and 8
thereafter reduced to word processing by me, that said 9
deposition is a true record of the testimony given by said j
10 witness; that I am neither counsel for, related to, nor 11 employed by any of the parties to the action in which this 12 deposition was taken; and further that I am not a relative 13 or employee of any attorney or counsel employed by the 14 parties thereto, nor financially or otherwise interested in 15 the outcome of the action.
j 16 i
17
/*
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i
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l 18 Mary C. Simons l
l 19 Notary Public in and for the i
i 20 District of Columbia 21 My Commission expires 22 August 15, 1989 l
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EDWARD LTEBERMAN I
7 L AiMeOAv O
Position Vice President Educatient B.s., civil Engineering, 1951, Polytechnic Institute of Brooklyn M.S., Civil Engineering, 1954, Columbia University M.S., Aero Engineering, 1967, Polytechnic Institute of Brooklyn subsequent studies toward a Ph.D.'in Transportation Planning at Polytechnic University Professional Backerround With almost 30 years' professional experience, Mr. Lieberman has managed numerous major projects.
Mr. Lieberman pioneered the development and application of traffic simulation models, making major innovatione in the state of the art in the Traffic Engineering profession.
He has also been responsible for many engineering studies involving data collection, analysis and design of traffic control systems to-expedite traffic flow and relieve congestion.
He has developed simulation models to study traffic performance on urban networks, on freeways, and on freeway corridors.
These programs include consideration of pedestrians' interacting with vehicular traffic, truck and bus operations, special turning lanes, and vehicle fuel consumption and emissions; both pratimed 1
Q and actuated traffic signal control are represented.
Selected project activities includes Principal Investigator for development of traffic signal e
control strategies for congested conditions in mid-Manhattan.
These strategies were implemented and evaluated in the field.
Floating car tests indicated substantial reductions in delay combined with increased vehicle throughput.
Principal Investigator in the development of an e
interactive computer graphics displaying traffic simulation r(ICG) software system for esults generated by the Netsim model.
Mr. Lieberman designed the overall structure of the software for implementation on PC AT computers and, subsequently,~on larger ICG work stations.
This work was sponsored by FHWA.
Responsibility for the theoretical development of DYNZV, a e
dynamic evacuation simulation model.
DYNIV is designed to be used as a tool to develop and optimize evacuation plans i
needed as part of general disaster preparedness planning.
DYNZV was used to analyze an existing evacuation scenario
{
at the Con Edison Indian Point Nuclear Power Station and O
was used to develop an extensive evacuation plan for the LILCO Shoreham Nuclear Power Station on Long Island, New l
l L764774
Served as a principal in the development of an evacuation o
([)
plan for the Long Island Lighting Company's shoreham Nuclear Power Station.
Mr. Lieberman's activities in this project include, definition of evacuation scenarios, definition of the evacuation network, analysis of trip tables, analysis and optimization of simulation results the preparation of formal documentation and testimony, a,nd providing testimony at public hearings conducted as part of the licensing procedures.
Responsible for the development of the I-DYNEV model, an e
interactive version and enhancement of the DYNEV model, under contract with the Federal Emergency Management Agency (FEMA).
I-DYNEV, in turn, was integrated into the Integrated Emergency Management Information System (IEMIS), developed by FEMA.
Applied I-DYNEV to estimate the evacuation times for the e
Emegency Planning zones (EPZ) for eight nuclear power stations.
)
e Developed course material and conducted training for i
amargency planning personnel at the National Emergency Training Center (NETC) in Emmittsburgh, MD.
l Designed the NETSIM microscopic traffic simulation e
l
([)
model (formerly UTCS-1) for urban environments to evaluate traffic operations, for the Federal Highway j
Administration.
I The Scot model which simulates traffic on freeway e
corridors was developed for the Transportation System Center of the Department of Transportation.
This program includes a dynamic traffic assignment algorithm which routes traffic over a network to satisfy a specified origin-destination table, in response to changing traffic flow characteristics.
Developed edvanced traffic control policies for urban e
traffic for the FNWA-sponsored UTCS Project, as well as a bus preemption policy to enhance the performance of mass transit operations within urban environs.
Designed and programmed the advanced " Third Generation" e
area-wide, cycle-free control policies for moderate and congested traffic flow for computer-monitored real-time systems.
Developed a cycle-based, off-line computational e
procedure named SIGOP-II, to optimize signal timing patterns to minimize system "disutility."
764775 L
Led a group of traffic engineers and systems analysts e
in developing a system of macroscopic traffic simulation
(])
models designed to evaluate Transportation Systems Management (TSM) strategies.
This software system, named TRAFIo, also includes an equilibrium traffic assignment model.
This model has been distributed to other agencias including FEMA.
k An " Integrated Traffic Simulation System," named TRAF, has
\\
o been des:,gned by Mr. Lieberman.
This model will incorporate all the best traffic simulation models available.
Using structured programming techniques, TRAF will integrate:
NETSIM, TRAFLO, INTRAS (a microscopic freeway traffic simulation model), and a microscopic rural-road traffic simulation model.
Mr. Lieberman set " *. as Principal Investigator on NCHRP e
Project 3-20 entitled, " Traffic Signal Warrants."
This project involved both field data collection and the application of the NETSIM model to study intersection delay as a function of traffic volume, type of control and geometries.
New signal warrants were developed and documented.
=
Under NHTSA sponsorship, Mr. Lieberman directed a research e
study to evaluate a Driver Vehicle Evaluation Model named DRIVEM.
This model simulates, the response of motorists O
to harardous events.
The effort included analysis of the model formulation and software and sensitivity testing.
A workshop was designed, organized, scheduled and conducted by KLD; experts were invited from all over the U.S. to recommend specific NETSA research activities for the further development of the mode.
A recommended research program constituted the major output of the contract.
Prior to 1965, Mr. Lieberman applied his skills to the areas of stress analysis, vibrations, fluid dynamics and numerical analysis of differential equations.
These analyses were programmed for the IBM 7090 and System 360, CDC 6600, G.E. 625 and UNIVAC 1108 digital computers in assembly language, FORTRAN and PLI.
He also designed the logic and real-time programming for a sonar simulator built for the Department of Navy and monitored by a PDP-8 process-control digital computer.
Professional Activitiest Member of the American Society of Civil Engineers, the Institute of Traffic Engineers, the Association of Computing Machinery and the Transportation Research Board (TRB).
He was a member of the Highway Capacity Committee and is on the Traffic Flow Theory and Characteristics Committee of the TR3.
He is a licensed Professional Engineer in New York, Maryland and in Florida.
()
Honorary Societyt He is a member of the Chi Epsilon Honorary Fraternity.
[764776
Selected Publications:
O "DYNET - A D Proceedings,ynamic Network Simulation of Urban Traffic Flow,"
Third Annual Simulation Symposium, 1970.
" simulation of Traffic Flow at 81gnalized Intersections: the SURF systaa," Proceedings, 1970 Summer Computer Simulation Conference, 1970.
" Dynamic Analysis of Freeway Corridor Traffic," ASME paper, Trans. 70-42.
" Simulation of Corridor Traffic:
The SCOT Model, Michway Raaaarch Record No. 409, 1772.
)
"Iagical Design and Demonstration of UTCS-1 Network Simulation Model," Minhway Ramaarch Record No. 409, 1972 (with R.D. Worrall and J.M. Bruggerman).
" Variable Cycle signal Timing Program Volumes 1-4," Final
=
Paport of Contract DOT-FH-11-7924, June 1974.
" Traffic signal Warrants, KLD TR-51, Final Report on NCHRP Project 3-20/1, December 1976 (with G. F. King and R. Goldblatt).
" Rapid signal Transition Algoritha," Trananortation Research
(}
Record No. 509, 1974 (with D. Wicks).
"subnetwork structuring and Inerfacing for UTCs Project-Program of Simulation Studies," KLD TR-5, January 1972.
" Development of a Bus Signal Preemption Policy and a System Analysis of Bus Operations," KLD TR-11, April 1973.
"8IGOP-II - Program to Calculate Optimal, Cycle-Based Traffic Signal Timing Patterns, Volumes 1 and 2, " Final Report, Contract DOT-FH-11-7924, KLD TR-29 and TR-30, December 1974.
Summary Renort in Trananortation Research Record. 596, 1976 (with J.
Woo).
" Developing a Predictor for Highway Responsive Systam-Based Control,# Trananortation Research Record. 596, 1976 (with W.
McShane and R. Goldblatt).
"A New Approach for specifying Delay-Based Traffic signal Warrants," Transportation Research Special Report 153 - Better Use of Existina Trananortation Facilities, 1976.
" Network Flow Simulation for Urban Traffic Control Systaas,"
Vols. 1-5, PB230-760, PB230-761, PB230-762, PB230-763, PB230-764, 1974 (with R. Worrall).
Vols. 2-4 updated 1977, KLD TR-60,
()
TR-61, TR-62 (with D. Wicks and J. Woo).
I.764777
" Extension of the UTCS-1 Traffio Simulation Program to Incorporate Computation of Vehicular Fuel Consumption and O
==iesions," xto r=-es, 197 (with.M. mosaarisia).
" Analysis and Comparisons of the UTCs second-and Third-Generation Predictor Models," KLD TR-35, 1975.
r
" Urban Traffic control systems (UTCS) Third Generation Control (3-GC) Policy," Vol. 1, 197C, (with A. Liff).
' Design of TRAFIC Operating System (TOS), KLD TR-57, 1977.
" Revisions to the UTCS-1 Traffic simulation Model to Enhance operational Efficiency," KLD TR-59, 1977 (with A. Wu).
"The Role of Capacity in Computer Traffic Control," in Raaaarch j
Directiona in comeuter control of Urban Traffie Svetana, ASCE, 1979.
i
" Traffic simulations Past, Present and Potential," in Hamburger W. 5. and Steinman, L.,
eds., Procandines of the Tnternationa1 synnesium of Traffic centrol avstana, University of California, Berkeley, 1979.
"TRAFIJ3:
A New Tool to Evaluate Transportation system Management strategies," presented at the 59th Annual Meeting of the i
Transportation Research Board, 1980 (with B. Andrews).
" Determination of the Lateral Deployment of Traffic on an Approach to an Intersection,a presented at the 59th Annual i
Meeting of the Transportation Research Board, 1980.
J
" Service Rates of Mixed Traffic on the Left-Most Lane of an Approach," presented at the 59th Annual Meeting of the 1
Transportation Research Board, 1980 (with W.R. McShane).
" Development of a TRAN8YT-Based Traffic Simulation Model,"
presented at the 59th Annual Meeting of the Transportation Research Board, 1980, (with M. Yedling).
" Hybrid Macroscopic-Microscopic Traffic simulation Model,"
presented at the 59th Annual Meeting of the Transportation Research Board, 1980 (with M.C. Davila).
"A Model for Calculating Safe Passing Distances on Two Lane Rural Road," presented at the 60th Annual Meeting of the Transportation Research Board, 1981.
"The TRAF System - Analytic Formulation and Logical Design of the Roadsia Model", KLD: TR-139, June 1983.
"PREDYN User's Guide", KLD: TR-131, June 1983.
O L 764778 1
4
-.-.~-L-
"The TRAF System - Technical Report", KLD: TR-136, August 1983 (with M. Yedlin, 3. Andrews and K. Sheridan).
O
- Application of the I-DYNEV System to Compute Estimates of Evacuation Travel Time at Nuclear Power Stations -- Four Demonstration Case Studies", KLD: TR-142, De. comber 1983.
" Users Manual for the Interactive DYnazio Network Evacuation Modelt I-DYNIV", KLD TR-144, February 1984.
" Formulations of the DYNEV and I-DYNEV Traffic Simulation Models Used in EISF", KLD: TR-154, March 1984.
"PREDYN/IDYNEV Training Guide", KLD: TR-155, April 1984 (with R.
Goldblatt).
" Specifications of Recommended Interactive Graphics Hardware Configuration and Graphics Support Software for the Netsia Graphics Display Package", KLDt TM-93, July 1985.
" Metering of High-Density Sectors comparison of Traffic Operations Along Fifth Avenue in Mid-Manhattant Metering Control vs. Existing Control", KLD: TM-94, July 1985.
" Description of an Integrated Traffic Assignment and Distribution Model (TRAD) for the IDYNEV System", KLD: TR-187, April 1986.
" Evacuation Plan Update (Robert G. Ginna Nuclear Power Station)",
KLD: TR-189, May 1986 (with R. Goldblatt).
" Evacuation Plan Update (Davis Besse)",
KLD: TR-190, July 1986 (with R. Goldblatt).
"Seabrook Station Evacuation Time Estimates and Traffic Management Plan Update", KLD: TR-174, August 1986.
" Reducing Traffic Congestion at Herald Square", ITE Journal, September 1986, pp. 27-31 (with A.K. Rathi).
" Congestion Based Traffic Control Scheme for High Traffic Density sectors", Transnortation Research Record No. 1057, TRE, National Research Council, Washington, D.C.,
1986, pp. 49-57 (with A.K.
Rathi and G.F. King).
" Overview of the Evacuation Plan and of the Evacuation Time Estimates for the Seabrook Nuclear Power Station", KLD: TM-98, Octo'bar 1986.
" Overview of the Evacuation Plan and of the Evacuation Time Estimates for the Ginna Nuclear Power Station", KLD: TM-99, November 1986 (with R. Goldblatt).
O
[764779
" Overview of the Coastal Region within the Pilgrim Station Emergency Planning Zone", KLD TM-100, November 1986.
O
" Enhanced Fraflo Progrant Simulation of Congested Environments",
paper submitted for presentation at Transportation Research Board's 66th Annual Meeting, January 1987 (with A.K. Rathi and M.
Yedlin).
O
)
l l
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O
[764780
r EDWARD B. LIEBERMAN
( )
estimony Hearing Testimony Dates 01/17/84 Transcript Page 01/17/84 2337 01/17/84 2337 01/17/84 2337 01/17/84 2337 02/23/84 2337 04/25/84 3857 04/26/84 6685 I
05/02/84 7043 05/03/84 7698 hs 05/08/84 7980 05/11/84 8536 05/30/84 9101 I
Volume 2 Deposition Dates 69/19/83 09/20/83 01/05/84 O
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Q Page 1 of 1 LERO MESSAGE FORM No.
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gEgO LONG ISLAND LIGHTING COMPANY nb SHOREHAM NUCLEAR POWER STATION P.O. DOX 618. NORTH COUNTRY RO AD e WADING RIVER. N.Y.11792 Joss o. Lt oN ARD. JR.
osposmon vics,nision=r. =vetran oet aations EXHlefT fy fh7 L /&MFMAA/
SNRC~1269 l
JUN 2 01986 l
Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation L.S. Nuclear Regulatory Commission Washington, D.C.
20555 Submittal of LILCO's Response to the FEMA Post Exercise Report For Shoreham Emergency Exercise of February 13, 1986 Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 O
Dear Mr. Denton
(
On April 30, 1986 the NRC Region I forwarded to LILCO the FEMA Region II Post Exercise Assessment for the Shoreham Emergency Exercise held on February 13, 1986, along with a request for LILCO's response.
This assessment identified five deficiencies and 38 Areas Requiring Corrective Action (ARCA).
LILCO's response to the FEMA assessment, appropriate remedial actions, and a schedule for implementation are detailed in Enclosure 1.
LILCO believes that these actions, when com NRC to conclude, with reasonable assurance,plete, will enable the that appropriate measures can be taken to protect the health and safety of the public living in the Shoreham vicinity in the event of a radiological emergency.
LILCO is issuing, under separate cover, Revision 7 of the SNPS Local Offsite Radiological Emergency Response Plan and Procedures to resolve those deficiencies identified by the FEMA exercise assessment requiring plan and/or procedure changes.
T We ask that you cause a request to be made to FEMA, pursuant to the NRC-FEMA Memorandum of Understanding, for an expedited review of LILCO's response to the FEMA Exercise Assessment.
To this end, we are forwarding under separate cover sixteen (16) copies directly to members of the RAC.
SNRC-1269 Pags 2 t
. i O
Should you have any questions, please contact this office.
j A's ' 2'g $:. -
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John D. Leonar Jr' Vice President -
uclear Operation L
i CAD:ck a
1 Enclosures cc: J. A. Berry R. Caruso/R. Lo f
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EleCIDSt3RE 1 Tetla 3.1 Pete 1 et 0 DEIntmast Ieen ras pows STAfl0iB = SOIFDt2I POR CtstECTInc DEFICIEnClts ce astAS St(3stelec Crem1CTtvt ACTlose Febewery 13.19e6 toercise 5220 EM:
Dettegency se Area
- See, kequiring At t.
Freposed Correcatee hoop.
Ceep.
Ceeptetten Ad. er er RAC Recommendetten for Correcties Actles Actlee LEB0 Reepense (Action) laste f7MA toaleottom of Lfm Respenee lead.
Incesp e
J.lt.h Deleys to reopendtes to the two (2) esecussion D
1 Procedures heee t>een teetewed and S/36/s6 Sepeateret tree play messages Smeerted et the reessed to esaure taformatten en 12o0 LOC were caused by the fallare to lef orm topedimente le prompt ly poseed to the E**cemettee Coordinator to e timely scener.
all televant pereennel and e le additten there see a lect of Internal cas-coordtaated reopense loplemented.
semicettee to reopenee to these tapediment pre-In additten, e Traffic Entineer 6 tees. Partineet lateemetten mee met tacIwded hee been added to the IJau UC en the 106% and 1306 Ltmo neessee Forme f r=m the et.sif to oettat en.. 1 etfaa te_ec at ten soute Coordaneter to the teermet ten J_ ped _gapedimenteendee==taltag g s__Cammunicetoe to the teacmetten Sepper's Qrmate rowstag.
Communicetor ser meure apettere/Emed Crewe te gardsaa the eteulated tapedy n===telas rirt 3.
The Traffic Guidance Tette Tap TT-6 1,f5/26/66 greeet trwt and feel truck armhtems. As a re-hee theen medilled to fecerporate the en s a,. s=na teck of teformatten, the Impediment cheoges to the procedures. Attachmentf prettees were met emelysed to e steely f eehlen 1
lI and tacamplete egelpment wee dispeeched to headle the greeel trwk topedlemet in the field.
laternal e--f eet tene erecedures chauld be revie-ed e.d reesee. e. - h e.e.r< Th.t is Te_ rmet tom en lopedimente le pres,tly podei both up the cheta es commeed to the teeceaCan Caerdinator and dewswerd and laterally teh-Imad coordinatore maneer the teacuat ten Castk-metoe and the$r staf f e.
Qttlemet tretateg'te
- : d to e.eure th.t w 7-e ogf~er cure.=e
- -,, - * - * @eent ed.
All coordinatore et the ROC, and these este lettlete meseeges, emot he tralmed to include all pertimoot inforeetten se the LESO seeeste forse and to analyse the equipment requirements to claer tapedteente.
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Pese f et 13 febli 3.1 5
Page T of 6 mm inn 1 ras PowR STAftole - ROTE 3tLE FOR cleRfCTIRC DEFICIENCIES On attAS RE@ttinC CreRFCTIVE ACTi(EI February 13e 1986 faeretse 11R0 EOC (Cofft'D)
Defletency er Area Res.
Requirlag Art.
Proposed Correctl*e Resp.
Camp.
C o pletten RAC Recommendettee for Correctlee Actten Actles LERO Reepanee (ACTIGE)
Date FEMA Evoluet tee of Lta0 Reepense lead.
Incomy
- 44. er og
),e Neo see same comfweten regarding the method ARCA N FAA will be contacted as part of 3/26/R6 for settfyles the Federal Aetetten the FDS FRERP reopense. The plan Aestolettetten (FAA).
and tretalag will be modtited accord-tagly se part of Rev. F.
(1) h e u ne precedures should be reelewed and reetoed as necessary to emeere that a potet of contact with the FAA hee been deelgneted.
(2) The LERO EOC staf f should be trained la the appreyrtete precedures se that the FAA ces be mettfted la e tteely amaner..
Stac3 there ore as precedures for notificetten ARCA The proc eilt be medlited in Rev. S 9ftfR6 of the Long leland Bellreed (Lita) to the Flam, to include e phone cell to the LIRR.
the LIRR wee not mettfled dettag the eserstee.
LfE0 treintog etti te modified accordingly.
(1) The LERO procedures cheuld be resteed to establish a pelat of contact and e amene for mettfying the LIRR.
(2) The trao 20C etett eheute be tratmed to the reetoed precedures se that the LIRA ces he settiged to e timely meaner.
The dose eseosoment statue board in the accident ARCA The deee essessment board will be modt*
9/1/86 etee2ement area had to accMate both Dot RAF fled to ace w te date from both s
and LIIID field maattering date. There were not DOE RAP tease and Lit 4D tesee, ensu@ colume se the beord to beep the two (2) ocurate of date separated. LEDO ehould esterse the dose secessment statue board to accommodate e steer separetten between the date reports from tl:3 DOE RAF and LII40 field amenitoring tese3.
e O
Fase 3 af 19 feels 3.1 Fase 3 sf 6 l
anna gyn ene polder STAT 10ft - SOff4LE FOR CoasECTigeG DErlCIDeCIES 1
OR AREAS BfQUIRING ConsECTlvt ACTICII i
February 13, 1986 teoretse i
1290 EOC (GatT'D)
Dettetency er Area
- Ree, Seguirlog Corrective Frepeeed Act.
SAC Decamendettee for Corrective Actten Casplet tes Resp.
Camp.
Actten LERO Response (ACTICIt)
Ad. er er Date FDth tweluetles of 1D0 toepense Inad.
leccep e
he doesnrine dietence of the semple ses lacef-ARCA rectly reported to 7,000 metere instead of 700 All esterlet for troneelseten 9/3/86 esters for one of the thyreld desee reported by of field date elll be revleved to ensure L2a0 and Dot practtees e EM *RAF field senttering team. Ihle error wee are constatent. To be included caused by a decimet yetat eleplaced during the in Rev. 8 senverstem of the eletence unito and meant that the trittst calculetten of thyroid dose bened as chts estaurement ses 9000 esem/hr. et 6.3 elles essanted testead el 9.000 eAme/hr. et etest 0.5 ottss dausuled. Ahaut five (5) eloutes elopeed befers (Ata error was found and corrected. All daneseted strtence free the field should be reported sanelstently in either elles or esters.
Dettaa the reporting of the Inittet DOE RAF ASCA thyr 213 deoes, only one field emaeurement, the Lta0 procedures will be reviewed 9/l/04 1600 mRD8/hr measurement mede et about 1204 et end a note added to ensure better two (2) sitto f ree the plant, ese eeelleble.
esordinetten and accurate wee of field date. To be facerrorated tits esfue see seed et the L230 EOC to entre-la tee. S.
polits doses et other diesences. These estre-polised dEts sere reported es actual seasure-ersta gt etter distences rather then se pro-jected data en the dose secessment erstes board.
It teak que and one half (3.5) heure te Iden-ttfy and cerrect thfe error. 1220 reporting precedurie should be restened to enevre peper coerfinetten and proper report tag.
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Pese 4 et le Tobla 3.1 Page 4 of 6 SIsomestast ausrv ras plmdER STATical
- SCNESIA.E POS CritettTInc DEFICitpCIES CA AntAS St(AflRInC CUestCTIVE ACTICue i
February 13. Sten Faerttee 1290 EOC (Colff'DI Dettelency er Aree
- se.
Pegstring Correctlee Proposed Act.
toep.
Camp.
RAC Beceamendettom for Corrective Action Csempletten Actlen LtRO Beepense (ACTICII)
Ad. er er Date TEMA tweluettee of lea 0 Response Inad.
Incesy O
Althoude he teter quoted the PAC correctly edies ARCA he Health Servlees Coordeneser hee 6/19/86 seted to de se by a Feferal evolueter, dharing a bettfing held at the IIRO EOC et shout lite, the been provided with review esterial meilth Services Coordtseter elastated the EPA en the use and meaning of the tra PAC's.
PAC se totag sendetery swecuenten estem the pJsjected thyteld dose see five ($) Res. he Mealth Services Caerdinator should restew the i
EP3 FAC guldence le order to eveld any poesible 5
tenfuesen that could result due to eletaferne-tien given dettag briefings.
i i
Peter to the esercles. LIl2 management mode the ARCA dectstem that the stren eyeten weield not be h e etten system M ll be activated es N,A acttisted se part of the febrisery 13.1,86 part of a prompt nettiteetton test.
emerrtee. Activetten of the stres erstes should prior to commercial operetten.
he actinelly tested to the future.
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eennel aselsnment. Yhte will emeuse trisch tapeeteret and the dispatch of that tysttar f rom the Port Jef fersen 5testag Area.
that pereennel are lamediately dia*
j his delayed steely oertiteettee of the patched for tapeatment vertiscatten er other evacuellen entgency.
j j
thred forms. reroessiel need to be *- -
isithe devotermeet of alternettve apasseches este vv.eenteegy enticleased Am ww i
to niei..ertric.rren.,se,s..nte to
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Page S of 19 Tabli 3.1 Page S cf 6 SHOREMAM NUQ. EAR F0WER STATION = SC3tEDLLE Fon crearrTING DEFICIENCIES
]
On AREAS REqulRING CDRRECTIVE ACTION February 13, 1966 Emerstee LERG EOC (CONT'D)
De ficiency
=
or Area
- Bem, Requiring Act.
Proposed Corrective Resp.
Comp.
Completion RAC Recamendetten for Corrective Action Aceton LERO Response (ACTION)
Date FDIA Evaluation of LERO Response lead.
Incoup.
Ad. or or I"/R Only the Shoreham-Wading River School Distrtet ARCA Schools util be requested to partt-N/A porttelpated in the February 13, 1986 esercise.
ctpate in future esercises.
Frtor to the eseretee, Lilio management made the dectates that other school districts teere not to be included in the esercise. le the future all schoote must be included in all Federally evaluated emerstees and drille.
1 E.3 Doetmetry and trotnias beve not been provided ARCA LilIO to ready to abide by its N/A E.S.e to the Rue Drivere used for school evacustica.
comettaent to provide trotning to beste principles of redtation and (1) Rue Drivere used for school evacuation doetmetry use and to provide personal should be trained to the see of doetmeters, doelmeters and KI tablets to all school bus drivers upon request.
(2) Adequate supplies of doetaetry should be provided for Rue Drivere used for school evacuation.
J.19. 3 Some of the Ambulette Detwere were not aware ARCA Training of embulance/ embulette 9/1/86 of seien to take their El. Tratatag on El drivers to being scheduled and procedures should be given to the Antaulette utII be revised to provide Drivers.
Increased emphasis on dosta-etry and radiological pro-tective actions for emergency workers.
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2 Fege 7 c.f 19 Tebas 3.4 F:se I cf 2 Se0RERAM puCLF.At p0WER ST* TION - SorEEtti FDA CoperCflNC DEFICIENCitS on ARLA5 BFQUlttuc naaICTivt ACTION February 33. 1986 teoretoe DESCDCT stW5 CENTER Dettelency or Area
- Ree, Requiring Correcttwo Frepeeed Act.
me.
RAC Beceamendetten for Corrective Act ten Completion Reep.
Comp.
Action 1120 Response (ACitGE)
Ad. er er Date FDu testsetten of LEno Besponse lead.
Incomy 1
S.4.6 Inowf f tetent copytas cepobitstles et the D
EMC resulted to delays to the distributtee Copylng mechlaes is the EMC are being 8/l/86 of Informatten. These delays effected the evolmated for upgrade and replacement f ollowing two (1) aresas se necessary.
e Rard coptee of ESS messages were not in order to espedite dieseetnetten of 6/19/86 provided to the media to e steely meaner.
Internetton, precedures have been re,leed, resentist emergency infer-e Beer centrol pereennel were not able to setton will be put in sunsery ters and enever queettene recatoed tree the puhtte almultaneously tronomitted wie camputer becewee they were not given accurate ey-to the INC and all rumor control locatione.
to-date states reporte.
12a0 shawld mete prowlegene for rollette and rapte eqelpment to repreewce, in hard copy, all oppropriate messages for distributtaa to the EMC staff.
J.13.4 Mepe and displate le the eedte betering room ARCA The suggested addit tonal die-were sneeffletent. The felle=Ing displaye 9/1/s6 eheute be posted in se eroe saatly stelble to plays and status boards wt!!
reporteres be provided to the ENC.
e As ty! map ehich trache protective actlene a d pl e patheep.
e A erstes board etich provideo ICLe and their slees et declaretton.
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P;ge 9 c f 19 Tehts 3.5 Fese 1 Ef 1 generusse men rAe POWFR ST; TION - SCHEDULE FOR CDaAECTING DEFICIENCIES OR ASEAS REQUIRING CORAECTIVE ACTION February 13, 1986 Esercise PORT JEFFERSON STACING ASEA Defletency or Area Res.
Requiring Act.
Proposed Correcttwo Seep.
Comp.
me.
BAC Recommendesten for Corrective Acaton Completten Action LEAD Response (ACTION)
Ad. or or Date PEMA Evoluettan of LERO Response
- Inad, lacomp
\\
E.3.e, One (1) Bue Driver neglected to read hie DRD ARCA Training materials will be revised E.3.b et any time during the seventy-f twe (75) 9/1/e6 to provide additional mphasis on etnutee he use working in the EPZ. All Ses radiatlOn and dosimetry.
Drlwere should be trained to read their I>RDe every fif teen (15) sinutes se described in 1250 Procedures.
O e
Pese le of 1)
Tabl3 3.6 Page 1 of 6 SunaEnArt NUCLEAR POWER STATl0N - SortTWEE FOR CDastCTING DEFICIENCIES De AaEAS DE(RittlNC CostFCTivE Action February ll, 1966 Paerrtee PA1CM0GJE STACING AREA Defielency er Aree Ree.
Be ytring Act.
Proposed Corrective Seep.
Camp.
Coeytetten me.
RAC Recommendetten for Correcties Action Actten LERO Respense (ACTION)
Date TDu Evelmetten of 1220 Seepense
- Imed, locomy Ad. er.
er 1
J.9 Bee detwere were not elopetched watti two (2)
D There to me reptrement to dispetch N/A e
J.10 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> af ter recetyt of the Site Area Emergency bus drivers wtthin two hours et e ICL declaretten.
Site Area Emergency. The diepetch of bus drivere wee within t' e times p
(1) As adottlemal mees should be established detalled in th LERO plan. See for the distributten of desteetry to analyste of dispatch, Attachment 2.
reAsco Sue Drtver procesotog stem.
(2) Addittenal tralmed staf f should be pre =
wided to the Due Dispatcher to oestet his in depleytag over three hundred (300) drivere end Transfer relet Coordinatore mete are deployed free the Patchegue Staates Area.
)
Eft OPIP 4.T.1 spectites that the only pereennel ARCA OPIP 4.7.1 will be resteed la Bew. 3 9/l/86 entreece to to be the Mata Entrance en the to indicate actual flou of pereennel.
Conhlla Avenue olde of the butiding. The entrance octually used for thte purpose wee the one en the north olde of the bullatag (Rein Street). Stace the efetee actually seed seene to be suporter to the Plan mee to reduced ceaseatten, CPIP 4.T.1 should be resteed to Indicate that pereennet are to enter the Patchegue Stestag ares through the Mete Street entrance to the bulldtag.
~
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Page II of 19 Tetl2 3.S A
Fase 2 of 6 SHORENAM NUCIJ.AR FolE2 $7J.fl0N - SQrE!JULE FOR QRRfCTING DEFICIENCIES OR LSEA$ SEQJ1 RING rnencrTIVE ACTION February 13, 1986 Eseretse FAIDEICIJE STACING AREA (COWT'D)
DefIctency or Area
- pee, Seguiring
- geg, Proposed Correcttwo Reep.
Comp.
me.
RAC Recommendettaa ter Corrective Action Completion Action I.ERO Response (ACTION)
Ad. er or Date FEMA Evaluatton of LIRO Response ined.
Incoop 3
C/R LERO perecenet entered the upper floor ARCA OrlP 4.7.1 Rev. B will be rewteed to 9/1/86 repeetedly to use telephones for energency indicate that spetatre phones may be nottitcatten. Thte practice to empitcitly utt t t ted.
prohibited by OPIP 4.7.1 (page 38, item #1).
Either OP!F 4.7.1 should be resteed to re-flect the octual practice of using tele-phones en the second floor of the Patchegue Staates Aree buildtag, or more telephones should be prowlded on the f tret floor for Lino personnel to perform their emergency nottistatione.
t/R The south door was not locked for security as ARCA Vertilcation that doore should be 9/1/06 opectfled in OPIP 4.7.1.
All doore required to be lected by the Plan should be vertised as checked by the SAC will be Indicated in Rev. S.
actually locked by the Staging Area Coordinator er a designee.
t C/R Daouthertmed entrance to the staging area could ARCA be achtowed through the spes fire escape on the This area of building entry la being 9/1/86 testened. A guard wllt be posted at second floor of the east olde of the butiding.
The fire escape en the second fleer of the eset the deelpeted location until the side of the building should be destensted as a factitty review to completed, guard poet la the Plea en indtvidual should be assigned to Staff this guard poet.
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d Pese 12 et 1)
Tetts 3.4 w
Foge 3 (,f 6 SMDRENAft NUCLEAR PottB STATION
- SOtrDelLE FOR CDSRFCTINC DrTICathCIt$
08 AREAS atqtitalec calen&CTtvt ACTitus rebruary 13,19e6 faeretoe PATusanat ITACInc AntA (CuwT'D)
Detteteary er Area see.
Be ytetas Act.
Proposed Corrective Seep.
Ceep.
RAC Receamendettee for Corseettee Actsee Cmpletten Actten Liao peepense (ACTtos)
Ad. er er Date FEMA twelmetten of Liao peepense imed.
Inc ap J.G A sue Detwee tech two (2) heure and ten (to)
D LERO's invest Igetton of the e
J.19 3 etnotes to proceed free the stegtes eroe to problem revealed that durIng s/t/96 the tremef er potet. Amether desver went to past drille bus drawere howe i
the creas trenefer point, and his stateke wee repeatedly volunteered to 30 met recesntred by the Trameter Fotat Caerdt.
to the ease trenefer points mater. Det emether desver stooed a separat of and bue yards. Thus, they had en eestywd evecusttee route, not become f aellfar with the otter poselble locattone.
(1) Bee Delvere for seneret poputetten eesca-Lit.CO will run " road railtes" etten restes ehemid receive trotstas se to have the bue drivers f.aett-1 eseere their ettetty to feitew direcetone tartre themselves with other steen to thee e* they ten (a) fattow routee bus yarde and transfer points.
Erse the etestas eree to tue sersses and in the future, emergency pre-then to treaefer yet se and (b) tettes en aestynd bus route.
paredness training will force the use of different transfer
~
'i (3) 0FIP 3.6.6, attachaeot 2 (Peses 13-84) pointe and bue yards. The Transfer Point Coordinator end Attachment I (reges 10-12) should be Procedure w1Il IndtCate that resteed to reptre, respectively, the Rue Delver to present, and the Trenefer rotat bus dispatch forme are to be Coordenster te verify, each aus Detwer's checked upon drtver*e arr twel, in Rev. 7 copy of the Bue/ Van Stepatchlag Form (OPIP 3.6.4, Attachment 7. Pete 62) to sesore that the tue Driver hee otvived et the proper tremefer potat.
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Tetts 3.6 9
Fate 4 of 4 emesm smart ras pohts STAT 3res - SCDrDat.E FOR CDeRECTluC DEFICIDeCIES 08 AstAS St@ttlMC CORpECTlvt ACTI0le February 13, 1946 Eseretee PA10 0QM STACloc &ar.A (Court'D)
Defteleecy or Aree
- men, Act.
Segutttas Proposed Correctlee Beep.
Ceep.
Caspletten Ad. er er p
RAC Rec-tales for Corrective Actten Actlee LERO Response (Action)
Date FD44 Evaluettee of 1220 Seepense lead.
Incesy c
J.9, Traf fic Cutdee de met heee complete er correct ARCA The Traffic Calde Precedure will be 9/1/86 J.10 3 teformatten se the appropriate deettnettom for modified to Bee. 8 l
evacuees. All Traf fic Caldee should be treteed i
to edelse esterlate with wettene to tune to the ERS etettaen (4&LE-FM) for the latest leformatise se all setters related to the emergency, includtag the lacettee of the Seceptten Center.
I J.10.h appropriate pereeneet end egetposet were est ARCA Af ter reed crews are diepeeched to p/A i
diepesched to clost the multiple vehicle their field positions they accident eteulated as en tapedteret to commentsete ele redte with the EOC.
es ecusa tes. The appropetete pereennel et The f.eed Traffic Culdes et the Stesteg the Peschegue Stestag Area should be treteed Area de met decide uhtch tracto are to to request more teformettum from the 8230 be dispeeched to e perticular toyedt-EIC eews topedioeste to everustles are ledicated.
eent.
J.ls.d lastructlene for the desver of the mentaatt.
AacA The Trenefer Point Coordinators' 9/I/C6 tutteneltred mentltty-topetred bue to proceed training asterial will be to the secepetse teater were met properly modifled to ensure they relay treneettted to the sue Driver et the Brookhaves instruct tone from the SAC's to settemet laboratory Tremeter Fates. Transfer the bus drivers.
Potet Coordtastere should he treteed to felles toetructlene forthcestag free the staging eree regeretag directlene that are to be given to j
speciel popetetten eescuattom route Sue Drivers, etace they are treteed to reters to tre trenefer pelat for toetractione es spectiled is the 1230 Flen.
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9 9
rege 14 et D Table 3.6 e
Fase 5 of &
SMCRIMAM inn rat POWLR ST Iton - $0EDULE FOR CORRECTING DEFICIENCIES
.E OR ASTAS REG 1181mc rneartTIVE ACTION tebenery 13,19s6 Eseresse FAIDoCLt STACING AREA (CONT'D)
Defteteary see.
er Ares Act.
Requirtog Frsposed Beep.
Comp.
Correcttwo Completion Ad. er er me.
RAC Recommendetton for Cervective Action Action LERO Response (ACT!0s)
Date FIha Evaluetten of LERO Resposee Imed.
locamp 10 J.10.4 Beeldences of eene man-tastitutionalised ASCA The sape used to find homes la the 9/1/86 mettltry-tet.ared perooms were difficult to EFE will be restewed for clarity.
Itad. Detwere deetpated to ptch up mon-tastituttomatized echttity-tapetred evacuees et their realdences should be provided with more detailed espe and clearer descriptione of pichi, potete.
11 J.C.
It took forty (60) minutes free recetyt of a LE20 AACA Rev. 8 will be revised to 9/1/86 J.10.g request to stepesca a sue Orteer to atentate the indicate an an additional evacuatbe of forty (60) schest chtleren. The LERO Staff person will assist sue Dispeecher at the Fetchegue Staging Area the Special Populations Bus chauld be proulded with tretned staf f support se Dispatcher.
that Sue Drivere see be dispeeched in a more steely meneer.
il2 E.3e the Fetchegue $:egteg Area Sue Dispatcher made ARCA All personeel getag late the itold 9/1/86 E.4 repeated statements with a tutthern e tch recetwe e desteetry brieflag den empheatred only that generet populetten ewece-they are leeued their destaetry, atlan Route Sue Drieers were to call to if a The Lead Traffic Cutdee and Bue reedtes of 3.5 wee reached am their DRD6 he did Diepeschere training will be i
i met stee the imite seeecteted with the 3.5 modified to emphasize the mieher ser meetten the use of the 0-200 mRee need to be more precise tan each to suppseed to trtsser the itrat with their information.
call-tm et a reedtog at er ebeve 200 mAee. The verbal toetructtesa given to the generet popu-lasson evacustten route Due Drivere by the Fetchegue Bue D8spatcher ever the butthere should be more prectee to emphaelse the pryr use of both doelmetere end the careful reedtog of esposure concret lastructions for emergency workere.
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A Page 13 of 19 Tehls 3.3 Pese 6 of 6 SWWheft WKt2&B penet STafttpl. eremmam e pga (meeECTINC BtFICituctt5
^
l en AsEAS argstelmC OuseCTtut ACTieu 1
February 13. 1986 Emerstee Pat' w m ' STActeC Aeta (Cout*D)
\\
BefIcIeney er Area g,,,
Seguiring att.
j Propeeed Carrerttee Beep.
Ceep.
Completion tac tec
- tem for Corresties Arties Actten Ltmo Respumes (ACT!cm) 44, se Date l
Feen gesteettee of 5230 Beepemee feed.
Imreep 3.3.0, One generet yeyntetten eversettee route bue Deteer ARCA Training material will be 9/1186 j E.3.D read tese enty twice et the teatrurtlene of the modifled to emphaelse the j
Tremeter Petet Caereteeter ese emetter read his leportance of reading the j
thDe enty whom it vee reseenleet. Generet pape*
DRD and other espects of KI i
letten aveseatten remeo Bus Detweee should he end doelmetry.
tressed to reed their doeteetere appresteetely every (teteen (15) oteutes estee they are inside the tG-stle EPfe stepplag the hee to de se if enreseery.
{E.3.a Trefetc Cetdee et two (2) 1CPe did est base does ASCA See Patchegue S.A. Ites 13 o
jE.3.D eothertsetten tiette. Trete the Treffte Geldes 1/t/06
]
es that they base the dose authertsetten Itette.
ij J.10.c The Rente Alerties Detwee sheerved bettewed he ASCA See Petchegue 5.1. Itse 13. Deute sia o
'{J.to.f umuld recatee 83 authertsetten to se EDS arecago.
Alert Deteers reneume their El Thte to tasameleteet with 0FtP 3.3.h atterhemet tottet eben they heer a Ceeerst e
to Etm 89 Seete Alert Detwere eneste he Emergency doctored en the redle.
treteed to base that 58 outhertsettee to to he See OFIF 3.3.4 At t actemen t le teemed to them by their sugereteer se spectfled
$tep 9.
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to the RANO Plan.
i l E.6 Tretite Caldee et tue (3) 1CPe did not festy ASCA See Fetchegue S.A. Item 13 N/A
)
enderstand that the shete of senseed for emesee I
espeewre eethertsetten gives the Lead Traffic Guide motherity to authertse emcees esposure by
}
redte. and een. Traffte Cold e tedicated that they eight guestles the authority of the Lead i
T,.ff8. Gui
- t. to e the e.th.ri..tt fer estese espesure. Att Traffic Cetdee eheeld he treteed to hace that the Leed Treff ts Cutde een setherise eaposere Ia emeses of the genere8 poputetten FACE by reste.
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Tette 3.7 Fece 1 et 2 S.4 SWRTHABI e pas page STATION - SOIEDILE.E FOR 0389FCT1pC DEFICIENCitS Ce Antas st@tatec CtmarCTIVE ACil0N February 13, 1966 Foerstee BlvtaNEAD STActeG AREA Deficiency er Area 3.
Act.
Regetelog Propeeed Correctlee teep.
Camp.
Campletion Ad. er er me.
BAC Recomenredetten for Corrective Actlem Acttee LEBO Seppease t&CTION)
Date Ft3m Eesteettee of LERO Response imed.
faces,
1 c/t neitte the efetue meerd me updated pertedecolly, ARCA Trotning meterial will be 9/t/36 the time use set sleeye tecluded thee new Bodifled 80 enture $.A.
e tafermetten wee posted. Peroommet should to personnel put t taes ett tretmed to record the time that updated latest informat100.
leformatten to posted as the statue board.
2 J.lt.)
The time between deployment of Traffic Outdes D
Traffic Caldes etlt be pre egetyped 1/26/06 f rom the eleglmg eres and their arrivet et for immedtete diepetch for the 2 TCFe one escesstwo, taking between fif ty (50) ette EFZ. An odottlemet persen and seeesty (70) etmetest appreatmetely thirty efit be eastgeed to oestet alth staetes mee speet in SIme et the etsging eres egetyment distributtom.
recoletog field tite and precedures. A more espedittene seems of deepetchlag the Traf fic Culdes from the stagleg area to the field sheeld be de9etered.
3 O
The access reed et the segehhaven Subetetten AACA Brookhavee Subetetten T.F. to LitID N/A Trameter Petet see serrew and ceretos and could property eed to cleared regularly be topossette to inclement meether. Cameldeve-by Lital plewe. Thte factitty, tien should be stoes to relerettag the Brookhaves ehtch to et a centres and convenient 5detetten frameter Petet to e dif ferent lacetten, lacetten, see not a prettee seien moed dettag the drill en 1/30/06 tamedletely fellevies a smee etere.
4 s.3.h one (1) of the detwee for the seaeral popute.
AaCA sills 6 stem eeermetten two restes stepesched free the Training metertal will be et,erhead stestas Aree did set reed his DeDe modifled to emphaetze the every itfreen ill) etantes se stated to CFtr importance of reading the 3.9.1.
Bue Detwee for the generet populetten DRD and other espects of K1 h e restee eheute te st o. odelstenal trelates and dosteetry.
to read their les and old-range DaDe every itfteen 111) stantes.
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Pese IS of It Totte 3.0 Pese 1 et 1 TABLE 3.9 8""8""
BACSAR PradrB STATitus - Stwenn e PDS CoeBECTimC DEF1CitKIES 08 AAEAS ret 37ttlac omatCTitt ACTIGE Febrisery 13,1986 toerstee starflogi CarTra Def teteary se Area
- See, Regetrtog Correettee Frepeeed Act.
Cemytetten Seep.
Camp.
3, tac tec 1:tes tee Correettee Actles Actlam LERO Seepease 1ACTice)
Aa, or er Bete PtMt testeettee of LERO seopease
- seed, tecoup J.11 Can sweefst erroetease poveemmet vedtetesteet amCA Treteleg meterial will be meestertes team eyyresteeeely fear (6) to 9/1/s4 modified to emphaetae the seed flee (S) eteesee per testetente amtcm to emoetaevetty teesee sten the staety tool to accompt teh moottor teg with-la 90 seconde.
eeceede eyeststed to the 82a0 Frece4=ree.
At1 meu3terleg permesmeI seetgned to the Receptise Ceeses eheeld be treteed to meetter todtelseele etthis elasty (to) eessede as presselhed to the E230 Prerederee.
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Fese it of it Totte 3.10 Page 1 et t mm m ean yt24B STAT 10s - SotBEEE Fan nie8FCTinC DFFIC1EM lES em AstAS BEGetalpC CrestCTies ACTIGs Febreaey 13. 3906 Esereise h enraTE ChaE CEsrTEt3 Defteleery or Aree n,e, Segetries g,g, Correet t ee Propeeed aeop.
Comp.
RAC a cesasedettee for Correettee Arttee Ceeplettee c
artsee Ltap seepense (ACTims) ad, se se sete ytna g,elmentee of LEDO Resposee
- lead, faces, J.10f) mettmee of the tuo (2) sangregate sees fertittles naCA The Red Caese bee the teepenethttley g/4 eetteeted fee the Peteuery 13. 1994 emeestee are terettiled to the Setest estelsetse of the Lga3 fee menetetenes a tiet of cessregate smee resters. Store the llet le resteed Flee. The Flee shee84 he eagtsed to terlade all feattttles toteeded for ese se shelter fortsttles pegledtgally (se partigener gestege be*
rene unevellette se se see esos are added),
duetag a redtelegteel emerseery at S M. These tulittlee should to testeerd to the tiet it===14 to toeppropstese to teclose the tiet to the Liao Flee. Iseteed,apreedte S etteshed to IDO*e letter of egresseet with the Ameetsee Red Crees.
to the plan etit be seelsed to esseste e ece lettre of egrecuret eith the Red Crees uhtch entt otete teet the Red Crees etil estatete se ep-to-dete tiet of eengregate sete seatere and that the list stil be sede oestlette to the appropetete federal agreates se re w at.
h 4,56$ D i $~lU L 1
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- k. w LONG ISLAND LIGHTING CQiPANY LOCAL EMERGENCY RESPONSE ORGANIZATION
(
TRAFFIC CONTROL TABLETOP DRILL Y l
REV. 0 O
T' Prepared by:
LER10 Technical Support May,1986 O
LERO EXERCIST/ DRILL SCENARIO Part 1 Objectives and Guidelines Part 2 D a te / Ti me/ Lo c a ti o n s / Pa r ti c i p a n t s Part 3 Agenda - Sumary
- Topics of Discussion I Lk d Approved y Emergency Planning Coordinator
/
Date APPROYALS:
I I
l CAUTION I
I I
I APPROYALS MUST BE SIGNED AT LEAST 24 HOURS l
l l BEFORE ANY EXERCISE OR DRILL MAY BE PERFOINED. l l
l 1
l Manager of LERO Date O
4
- 1 1.0 OBJECTIVES AND GUIDELINES A.
Highlight major changes in the Offsite Emergency Plan and Implementing Procedures pertaining to Traffic Control and discuss any inquiries on these changes. Discuss the results and coments on the previous series of drills.
B.
Discuss proper handling of impediments to traffic along evacuation routes.
Emphasis is on information flow, timely response, equipment requirements response priorities and impact on the evacuation network.
C.
Utilizing an escalating accident scenario, provide a detailed description and discussion on the responsibilities and activities of all Traffic Control group members per the latest revision of the Plan and Implementing Procedures for each event in the scenario.
2.0 D AT E /T IM E /L OC AT I O N S/ P ARTI C I P AN TS Date/ Time:
May 29,1986 01:00 p.m. - 05:00 p.m.
June 3,1986 08:00 a.m. - 12:00 noon June 4, 1986 01:00 p.m. - 05:00 p.m.
Location:
Melville
Participants:
12 Evcacuation Coordinator 10A Traffic Control Coordinator 10B Traffic Control Point Coordinator 10C Road Logistics Coordinator 100 Evacuation Route Coordinator 22A Lead Traffic Guide 27 Staging Area Coordinator 03E Evacuation Support Communicators 39E Traffic Engineer l
e e
T' O
Page 1 of 24
3.0 AGENDA Sumary
~ i This tabletop provides an opportunity to inform the Traffic Control Group of the changes that have occurred in the-applicable Offsite Emergency Plan and Implementing Procedures.
This tabletop will be conducted in a meeting room setting and will be coordinated by a Drill Controller leading a seminar-type session in which an escalating accident scenario is presented to the Traffic Control Group and a detailed review of their responsibilities and duties will ensue after each i
major event. The scenario will begin at the onset of an accident while all members are at home or work and escalate through all emergency classifications to the carrying out of an evacuation.
The scenario will also introduce removable and 3
non-removable road impediments which require both road crew response and rerouting.
The review will cover all aspects of an emergency, from the initial notification of the Traffic Control Group to the deployment of staff members in support of an evacuation.
Special attention will be given to the proper 4
handling of road impediments.
Applicable procedures should be i
brought to the tabletop by each drill member which they will be directed to use during the various scenario events.
Revisions to these procedures will be discussed in detail as they affect their actions during the drill.
In addition, new LERO members will be paired with experienced LERO members (where possible) to assist the new members in j
understanding unfamiliar areas.
t l
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i
- O Page 2 of 24
l i
Topics of Discussion o Introduction T = 0/00 - 0/15 Have members introduce themselves and pair new members with those of the same title and with experience, if possible.
I Review progress to date on LERO activities.
Reiterate the changes due to procedure revisions.
o Review T = 0/15 - 1/00 OPIP 3.6.3, " Traffic Control" Traffic Engineer Responsible for evaluating the effects of road impediments and determining alternate routes as necessary.
As necessary, assists Transportation Support Coordinator to develop alternate bus routes for routes affected by road impediments.
As necessary, assists Traffic Control Coordinator to develop revised traffic routing instructions for traffic guides in the field.
Advises Evacuation Coordinator on all aspects of imple-menting the evacuation.
Evacuation Coordinator An immediate response is required for any impediment to the evacuation.
Upon identification of any non-removable road impediment, traffic rerouting is to be considered, i
l Review impediment with Traffic Engineer.
If appropriate, Traffic Engineer is to develop a rero~uting plan.
Rerouting plan must be approved by the Director or I,,~
Manager of Local Response before it is implemented.
1 i
- O Page 3 of 24
If The Traffic Engineer is to be instructed to work with 3
Traffic Control Coordinator to modify traffic strategies l
at traffic control points to support rerouting. The Traffic Control Point Coordinator will speak directly to the Lead Traffic Guides when relaying modified rerouting directions to the staging areas.
Lead Traffic, Guides then contact affected traffic control points.
Work with Coordinator of Public Information to develop an EBS, message to support rerouting plan.
The Traffic Engineer is to be instructed to assist the Transportation Support Coordinator in developing alternate bus routes for routes affected by road impediments.
The Evacuation Coordinator no longer contacts the FAA.
4 The FAA is notified by FDiA.
Traffic Control Coordinator Traffic Control Coordinator now reports any incident that effects the evacuation to the Evacuation Coordinator and Traffic Engineer.
Traffic Control Coordinator must monitor the activities of his group to ensure that they are acting in a l
n coordinated manner to respond to identified problems and U
that an appropriate response is being implemented.
Traffic Control Point Coordinator Comunications should be conducted primarily through the i
Evacuation Support Comunicator(s), but if they are back-logged, use your own phone to expedite communications.
Traffic Control Point Coordinator must now periodically update the Traffic Control Coordinator on the status of traffic control activities and report.all problems to him.
Lead Traffic Guides
- At a Site Area Emergency, Lead Traffic Guides are to l
assign Traffic Guides to 0-2 mile traffic control points from Attachment 7.
Packets, radios and all equipment are to be issued to these Traffic Guides and they are to remain on standby at the staging area.
Upon notification l
T*
of an evacuation, these Traffic Guides are to be dispatched immediately.
i f
1
- O Page 4 of 24
Field Crews are to be briefed on the status of the emergency and their emergency procedures.
They are to be O-told to report any incident that has the potential for slowing the evacuation.
Traffic Guides are to be pre-assigned to Traffic. Control Points while at the staging area.
They are also to be prebriefed and issued packets.
Road Logistics Coordinator Upon notification of a road impedimer,t from the Evacuation Route Coordinator, the appropriate Road Crews are to be contacted and instructed to clear the impediment. An adequate number of suitable road crew vehicles are to be dispatched to respond to impediments.
The Traffic Control Coordinator is to be informed of the impediment and response.
Evacuation Route Coordinator
- Reports problems or road impediments to the Traf fic Control Coordinator and the Road Logistics Coordinatnr.
O O
Page 5 of 24
o Event Schedule Time
(_ Hrs.: Mins.)
_ Event Sumary T = 00:00 Conditions at SNPS warrant that an Unusual Event be declared.
Control Room Communicator starts the notification process.
ANTICIPATED RESULTS
_ Supervising Service Operator s
Upon notification of an NUE at Shoreham begin notification of emergency response perso,nnel in accordance with OPIP 3.3.5.
Activate the Group Tone 1 pagers - Code 991111.
Provide status to Manager and Director of LERO at they call in.
01, rector of Local Response O
Call into the Supervising Service Operator for a status report.
Discuss with Manager of LERO o activating LERO at this time. ption of Manager of Local Response Call into the Supervising Service Operator for a status report.
Discuss plant conditions with the birector of LERO.
Other Group 1 Personnel Call into AVS and remain on standby.
Traffic Control Group I'
OPIP 3.3.2, Section 5-1 s
Not aware of occurrance.
T = 01:00 Plant conditions at SNPS warrant that an Alert be O
deciared.
coatrai aoom comuaicator itaris the notification process.
Page 6 of 24
P 1
Time (Hrs. : Mins. )
Event Sumary 5
ANTICIPATED RESULTS
~
Supervising Service Operator i
Carry out OPIP 3.3.5, $50 Procedure - Alert Notification.
j Activate the Group Tone 1 pagers - Code 2222.
i i
Activate the Group Tone 2 pagers - Code 2222.
l t
Activate the Group Tone 3 pagers - Code 2255.
i Inform Director and Manager of LERO of plant emergency and read RECS Data Form Part I to
(
Director and Manager.
i Group I, !! and !!! Personnel l
Call in to Automatic Verification System.
t j
Report to the E0C or Staging Area (Groups 1 and !! only).
1 Dire <. tor of Local Response Proceed to E0C and implement OPIP 4.1.1, "COC Activation."
i i
Approximately 01:30 E0C staff reports to and establishes the EOC facility.
At E0C, staff signs in on sign-in board.
ANTICIPATED RESULTS j
Director of Local Response
(
i c
Assume direction of the E0C.
t Carry out " Director of Local Response Action i
Checkof f List," Attachment 2 to OPIP 4.1.1.
J 1
i i
l l
Page 7 of 24 i
i
Time
( Hrs. : Mins. )
Event Sumary Evacuation Coordinator OP!P 3.6.3, Section 5.1 Notify U.S. Coast Guard.
Report to EOC.
Carry out " Evacuation Coordinator Action Checkoff List," Attachment 5 to OPIP 4.1.1.
Keep Traffic Group informed and confer on radiological information with Radiological Health Coordinator.
LERO Emergency Callers Receive a 2255 notification and are on standby.
Traffic Control Group OP1P 3.3.2 O
Traffic Coatrai Coordiaator. Traffic Coatrai Point Coordinator, Road Logistics Coordinator, Evacuation Route Coordinator, Traffic 1
Engineer Evacuation Support Comunicators and j
Lead Traf fic Guides.
I a.
Pager indicates 2222.
b.
Call into Automatic Verification System.
l 1.
Phone number to call is listed on l
callout list.
2.
Verification number is also listed on callout list.
3.
If unable to respond, telephone another member on callout list and request their mobilization.
c.
Report to pre-designated location.
.I 4
!O Page 8 of 24 2
Time
( Hrs. : Mins. )
Event Sumary Traffic Guides, Road Crews, Route Sgotters.
a.
Selected Traffic Guides who have been given Group Tone III pagers are notified by a 2255.
b.
Call into the Automatic Verification System.
c.
Then standby, which means to stay near a telephone.
d.
Road Crews and Route Spotters are not notified.
OPIP 4.1.1, Section 5.0 Traffic Control Coordinator, Traffic Control Point Coordinator, Road Logistics Coordinator, Evacuation Route Coordinator Traffic Engineer, Communicators i
a.
Sign in on sign-in board.
b.
Obtain appropriate equipment and set up
- area, c.
Traffic Control Coordintor obtains information on the status of the emergency.
Evacuation Support Communicators establish contact with Staging Areas.
Approximately 02:00 Staging Area staff reports to their Staging Areas and activates these facilities.
ANTICIPATED RESULTS Staging Area Coordinator OPIP 3.6.3, Section S.7 Y
Assume control of the Staging Area.
I O
Page 9 of 24
_.,.--_.-__.-_-,-,.------,,--.._.___..-___.-__.,-__.,,,-m
,_-,___,___.._-..,,,-.-__.,,,.,__y.m_.--.---,
.y,--
Time 4
(Hrs. : Mins. )
Event Sumary
(
OPIP 4.5.1 j
Establish comunications with the EOC.
~
Ensure dosimetry is being distributed as persons arrive via Dosimetry Record Keeper.
l
\\
Brief Bus Dispatcher and Lead Traffic Guide.
I Ensure material and equipment is available l
for distribution.
i
)
Assign Staging Area staff to assist in communications and administrative functions 3
l as required.
Ensure at least three people l
are assigned to equipment distribution.
Traffic Control Personnel Lead Traffic Guides OPIP 4.5.1, Section 5.4 O
e.
instruct Persoanei to ios in.
b.
Report to Staging Area Coordinator for a l
briefing.
{
c.
Obtain necessary supplies and j
communication equipment.
d.
Establish communications with EOC.
e.
Keep Staging Area Coordinator advised of j
activation status.
l l
Route Alert Drivers OP.IP 3.3.4, Section 5.3 a.
Report to Staging Area at Alert.
Receive
.)
dosimetry, mount PA Systems and standby for route alerting, t
- O 1
l Page 10 of 24 1
---.... m...
Time (Hrs. : Mins. )
Event Summary T = 03:00 Plant conditions warrant declaration of_a Site Area Emergency.
ANTICIPATED RESULTS RECS Communicator Receive RECS message from the TSC or EOF and distribute to key EOC staff.
Lead Communicator Contact the SSO in Hicksville to initiate the LERO notification system for the Site Area Emergency.
Check on status of Automated Verification System as information becomes available..
Call out additional people to support as necessary.
Special Facilities Evacuation Coordinator
()
Route Alerting Read through OPIP 3.3.4, Sections 5.2, 5.3, 5.4 and 5.5.
Section 5.2 a.
Coordinator of Public Information is inforced of siren failures through contact with Marketing Evaluations, b.
When notified of siren failure, the Manager of Local Response will direct Evacuation Coordinator to initiate route alerting.
Section 5.3 a.
Evacuation Coordinator directs Special r
Facilities Evacuation Coordinator to initiate route alerting.
(
b.
Special Facilities Evacuation Coordinator l
notifies appropriate Staging Areas using l.
Contact is with Lead Traffic Guide.
j Page 11 of 24
Time (Hrs.:Hins.)
Event Summary c.
tead Traffic Guide obtains packets, briefs drivers, verifies proper dosimetry and deploys drivers, d.
Route Alert Drivers use their procedure.
e.
Route Alert Driver (s) may be directed to report to EOC to be dispatched in helicopter which will assist Coast Guard 3
in warning Long Island Sound boaters
( 5.3 -e ).
Section 5.4 a.
If sheltering, notify both ambulatory and non-ambulatory.
b.
If evacuation, notify only ambulatory.
c.
Maps with location of deaf are in Staging Area.
O d.
tead traffic Guides obtain proper deaf alerting packets and distributes them.
s.
Route Alert Drivers use procedure in packet specifically Step 8.
Evacuation Coordinator OPIP 3.6.3, Section 5.1 a.
Again notifies Coast Guard on status of emergency, b.
Ensure Staging Areas are being staffed.
c.
Make preliminary assessment of where field personnel should be dispatched from the Staging Areas.
d.
Oversee Special Facilities Evacuation Coordinator in dispatching Route Alert Drivers as appropriate.
O Page 12 of 24
Time (Hrs. : Mins. )
Event Sumary OPIP 3.3.4, Section 5.5
~
a.
Directs notification to boaters on.ong Island Sound.
Traffic Control Group OPIP 3.6.3, Sections 5.2, 5.3, 5.5 and 5.6 Traffic Control Coordinator, Traffic Control Point Coordinator, Road Logistics Coordinator, f
Evacuation Route Coordinator, Connunicators.
a.
Obtain meteorological and radiological information.
Prepare for possible evacuation.
b.
Remain advised as per the activation status of the Staging Areas.
l c.
Comunicators relay updating information, i
May relay information for activating Route Alert Drivers. OPIP 3.3.4, Q
Sections 5.3 and 5.4 Staging Areas Personnel Staging Area Coordinator OPIP 3.6.3, Section 5.7 and OPIP 4.5.1, Section 5.1 a.
Ensure availability of Bus Drivers and Traffic Guides.
l b.
Ensure dosimetry is being issued.
c.
Brief Lead Traffic Guide on emergency status.
d.
Provides periodic updates to the Evacuation Coordinator.
r Lead Traffic Guides l
OPIP 3.6.3, Section 5.4.
a.
Keep Staging Area Coordinator briefed as O
to activatioa/arrivai status.
Page 13 of 24
Time (Hrs. : Mins. )
Event Sumary O
b.
Brief and dispatch Route Alert Drivers.
OPIP 3.3.4, Sections 5.3 and 5.4.,
Attachments 1, 2 and 3.
c.
Obtain list of traffic control points to be activated for 0-2 mile area from (OPIP 3.6.3).
Assign arriving traffic guides to these points, issue them packets, instruct them to obtain all required equipment including radios and load it into their vehicles.
They are to remain on standby at the staging area, d.
Brief all field personnel on the emer-gency and their specific procedures.
Inform them to report any road impediments that they observe.
e.
Pre-assign and pre-brief traffic guides to each traffic control point associated with your staging area.
f.
Women are to be assigned to locations outside of the EPZ.
Traffic Guides OPIP 3.6.3, Section 5.8 a.
Those with pagers get 3333 and call the Automated Verification System again.
Then they begin to call those on their call out lists.
b.
Traffic guides report to appropriate staging areas.
c.
Receive dosimetry.
d.
Receive briefings, e.
Some traffic guides will be assigned to i
0-2 mile traffic control points.
These guides will obtain all equipment, inventory packets and remain on standby, f.
The other traffic guides will be assigned Q
to the balance of the traffic control points.
Page 14 of 24
Time (Hrs. :14 ins. )
Event Sumary Road Crews OPIP 3.6.3, Section 5.9
- a. Receive call and report to appropriate staging area.
Some road crews will be directed to pick up road crew vehicles before reporting to staging area,
- b. Receive dosimetry.
- c. Receive briefing.
Evacuation Route Spotters OPIP 3.6.3, Section 5.10
- a. Receive call and report to appropriate staging area.
- b. Receive dosimetry.
Q
- c. Receive briefing.
T = 05:00 Plant status warrants the delcaration of a General Emergency.
ANTICIPATED RESULTS RECS Comunicator Receive RECS message from the EOF and distribute to the key EOC staff.
Lead Comunicator Contacts the SSO in Hicksville to initiate the LERO notification system.
Radiation Health Coordinator 1
Evaluate RECS information and projected doses.
l O Page 15 of 24
Time (Hr s. :liins. )
Event Sumary O
Perform independent dose assessment and protective action recommendations. -
Recomend appropriate protective actions to Director of Local Response.
Dispatch DOE / RAP survey teams in the down wind direction.
Evaluate field monitoring data and compare with projected.
Director of Local Response Recomend protective actions to the public.
Approve EBS message and press release.
Activate the Prompt Notification System.-
Confer with LILCO Response 14anager periodically relative to plant status.
Q Coordinator of Public Information Write EBS message and press release for approval by the Director of Local Response.
liaintain comunications with the ENC.
Evacuation Coordinator OPIP 3.6.3, Section 5.1 Ensure that Traffic Guides and Bus Drivers are dispatched to implement the recomended protective actions.
Ensure that Roa'd Crews, Route Spotters and Transfer Point Coordinators are dispatched to implement the recomended protective actions.
T' Traffic Control Coordinator
)
OPIP 3.6.3, Section 5.2 a.
Coordinate overall activities of Traffic l
O Control Group and issue orders to dispatch required field personnel.
Page 16 of 24
Time O
(Hrs.: Mins. )
Event Summary Road Crews OPIP 3.6.3, Section 5.9
- a. Receive call and report to appropriate staging area.
Some road crews will be directed to pick up road crew vehicles before reporting to staging area,
- b. Receive dosimetry.
- c. Receive briefing.
Evacuation Route Spotters OPIP 3.6.3, Section 5.10
- a. Receive call and report to appropriate staging area,
- b. Receive dosimetry.
()
- c. Receive briefing.
T = 05:00 Plant status warrants the delcaration of a General Emergency.
ANTICIPATED RESULTS RECS Communicator Receive RECS message from the EOF and distribute to the key EOC staff.
Lead Communicator Contacts the SSO in Hicksville to initiate the LERO notification system.
Radiation Health Coordinator T
Evaluate RECS information and projected doses.
O Page 15 of 24
Time (Hrs. : Mins. )
Event Surnary Traffic Control Point Coordinator OPIP 3.6.3, Section 5.3, Attachments 4 and 7 Section 5.3 a.
Verifies zones, b.
Detemines posts and contacts appropriate Staging Area, Attachment 7.
c.
Keeps Traffic Guides posted on emergency status - releases, etc.
d.
Notifies Radiation Health Coordinator of high field doses.
Road Logistics Coordinator OPIP 3.6.3, Section 5.5, Attachments 5,' 8, 12, 13 and 14 a.
Verifies zones.
b.
Determines site evacuation routes and clears roads if impediments exist.
c.
Uses Attachment 8 to dispatch tow and tank trucks.
d.
Informs Lead Traffic Guide to dispatch Road Crews.
e.
Keeps Road Crews posted on emergency status -
releases, etc.
f.
Notifies Radiation Health Coordinator of high field doses.
g.
Uses Attachment 12 to record dispatching of Road Crew trucks.
h.
Call transportation department if there is difficulty in obtaining trucks.
If off hours, Road Crews will go to storage areas to get needed trucks.
Page 17 of 24
Time
({])
(Hrs. : Mins. )
Event Summary Evacuation Route Coordinator OPIP 3.6.3, Section 5.6, Attachment 6 a.
Verify zones.
b.
Determine patrol routes, Attachment 6.
c.
Contact Lead Traffic Guides to dispatch Route Spotters.
1 d.
Contact Support Services Coordinator to send out dispatch call for helicopter.
Contact Patchogue to send Route Spotter to Brentwood, e.
Maintain contact with spotters in field and relay data on emergency situation.
Staging Area Coordinator OPIP 4.5.1, Section 5.1 and OPIP 3.6.3, Section 5.7 OPIP 4.5.1 discussed in Staging Area Management Tabletop.
a.
Verifies and oversees Staging Area activities.
b.
Obtains rosters.
Reports status to Evacuation Coordinator.
c.
Ensures dosimetry distributed, briefs on protective measures.
Lead Traffic Guides OPIP 3.6.3, Section 5.4, Attachments 9,10,11, 12 and 13.
a.
Upon notification of an eva'cuation, dispatch 0-2 mile traffic guides previously on standby.
b.
Breif field groups and issue emergency kits and equipment.
O Page 18 of 24
Time (Hrs. :141ns. )
Event Sumary c.
After receiving dispatching infonnation from the EOC, assign packets to all field groups as required.
NOTE:
Traffic Guides have already been assigned packets and TCPs. Dispatch Traffic Guides to TCPs as indicated from the Traffic Control Point Coordinator.
e.
Assign Road Crews to vehicles. Assign crew at Port Jefferson to one-way flow.
f.
Deploy groups.
Use dispatch logs, Attach-ments 9,10 and 11.
Instruct them to follow their procedures, g.
Remain in contact with field teams to relay evacuation and emergency status.
h.
Inform EOC of 200 mR and 3.5 R doses.
Traffic Guides OPIP 3.6.3, Section 5.8, Attachment I a.
Receive assignments and packets, b.
Inventory packets and obtain required equipment.
c.
Proceed to deployment locations when instructed by Lead Traffic Guides.
Road Crews OPIP 3.6.3, Section 5.9, Attachments 2, 8 and 13 a.
Receive assignments and packets, b.
Inventory packets and obtain required equipment and vehicles.
c.
Proceed to deployment locations when instructed T'
by Lead Traffic Guides.
s O
Page 19 of 24
.-,._.--,-_--.,m.-
Time (Hrs.: Mins.)
Event Sumary Route Spotters OPIP 3.6.3, Section 5.10. Attachments 3 and 6 a.
Receive assignments and packets.
b.
Inventory packets and obtain required equipment including Evacuation Route Spotter /
Road Crew radio, c.
Proceed to assigned routes when instructed by the Lead Traffic Guides.
T = 06:00 Evacuation Route Spotter reports disabled cement truck with a broken axle on William Floyd Parkway between Route 25 and Whiskey Road.
ANTICIPATED RESULTS Evacuation Route Coordinator Receive impediment information from Evacuation Support Communicator.
Report impediment to Traffic Control Coordinator and Road Logistics Coordinator.
Road Logistics Coordinator Receive impediment information from l
l l
Evacuation Route Coordinator.
Evaluate impediment.
Determine the number of road crew vehicles required to respond to the situation.
Dispatch a vehicle (s) that is capable of removing the impediment.
Inform the Traffic Control Coordinator of the situation and your response.
Traffic Control Coordinator Receive information on impediment and response from Evacuation Route Coordinator and Road Logistics Coordinator.
Monitor response to impediment to ensure it
'is removed expeditiously.
Page 20 of 24
Time (Hrs. : Mins. )
Event Surmary i
Traffic Engineer Receive infonnation on impediment from Traffic Control Coordinator.
Consider impact of impediment on evacuation network.
Support Road Logistics Coordinator as required.
T = 06:30 Cement truck impediment removed.
ANTICIPATED RESULTS Road Logistics Coordinator Receive information on removal Of impediment from responding road crew.
Inform traffic control group of impediment removal.
O T = 07:00 Lead Traffic Guide at Patchogue calls the Traffic Control Point Coordinator and informs him that th'e Traffic Guide at TCP 54 saw a truck hit a large utility pole just north of his location.
The pole fell over blocking both lanes of the road and caused a large pile up of cars.
The wires that came down are still live.
ANTICIPATED RESULTS I
Traffic Control Point Coordinator Inform Traffic Control Coordinator of impediment.
Inform rest of traffic group of impediment.
Traffic Control Coordinator Receive information on impediment.
p Inform Evacuation Coordinator and Traffic Engineer of impediment.
l O Page 21 of 24
,. ~.
Time (Hrs.:Hins.)
Event Summary Inform them of its magnitude and high probability of it taking a long time to remove (consult with Road Logistics Coordinator as required).
Instruct Road Logistics Coordinator to dispatch available road crews to impediment.
Road Logistics Coordinator Receive information on impediment from Traffic Control Coordinator or Traffic Control Point Coordinator.
Disptach Road Crews to location as requested by Traffic Control Coordinator.
Evacuation Coordinator Receive information on impediment from Traffic Control Coordinator.
Review impediment with Traffic Engineer and O
discuss rerouting option (traffic to be rerouted).
Instruct Traffic Engineer to develop rerouting plan.
Obtain approval of rerouting plan with the fianager or Director of Local Response.
Instruct Traffic Engineer to work with Traffic Control Coordinator to modify TCP directions to support rerouting.
Work with Coordinator of Public Information to develop an EBS message to support rerouting.
Instruct Traffic Engineer to' assist Trans-portation Support Coordinator in assessing impediments impact on bus route operations I...~
and to develop alternate bus routes as s
required.
Ensure information on alternate bus routes is given to appropriate Transfer Point O
Coordia tors tarousa the sus oisPetchers.
Page 22 of 24
Time
( Hr s. :Mi ns. )
Event Sumary Traffic Engineer Receive information on impediment from Traffic Control Coordinator and Evacuation i
Coordinator.
Assess impediment, location, expected traffic volumes, evacuation zones effected, and roads available for rerouting. Confer with Evacuation Coordinator and make decision on rerouting.
Develop rerouting plan.
If rerouting is approved by Manager or Direc-tor, work with Traffic Control Coordinator to develop new traffic strategies and turn movements for associated TCPs to support the rerouting plan.
i Work with Transportation Support Coordinator to determine impact of impediment or, bus route operations.
Develop alternate bus O
routes 4r reau$ red-Traffic Control Coordinator Work with Traffic Engineer to develop new TCP tr'affic strategies to support rerouting plan.
Utilize assistance of Traffic Control Coordinator to relay new TCP directions to appropriate Lead Traffic Guides.
i Traffic Control Point Coordinator When new TCP turn movements have been determined, contact the Lead Traffic Guides at the appropriate staging areas and relay rerouting instructions.. Ensure they clearly understand instructions.
~
Lead Traffic Guides Receive rerouting instructions for TCPs from Traffic Control Point Coordinator.
l Relay rerouting instructions to Traffic Guides at the appropriate TCPs.
Page 23 of 24 l
Time (Hrs. : Mins. )
Event Sumary O
Approximately 08:00 Release from the SNPS is isolated.
Conditions warrant that the emergency be downgraded to a I
Site Area Emergency.
General Per OPIP 3.10.1, " Recovery /Re-Entry " a committee of Senior LERO members is formed to perform the tasks assigned in this procedure.
Transportation Support Group Continue with evacuation until completed and inform the Evacuation Coordinator when the evacuation is completed.
O
,r O
Page 24 of 24
ATTACHMENT 2 O
DISPATCH OF GENERAL POPULATION BUSES FROM THE PATCHOGUE STAGING AREA DURING THE FEBRUARY 13 EXERCISE t
In the Post Exercise Assessment issued by the Federal Emergency Nbnagement Agency (FEMA) on April 17, 1986, FEMA graded as defi-cient LERO's dispatching of general population bus drivers from 4
the Patchogue Staging Area.
This deficiency was based on FEMA's perception that the dispatching of these drivers was not fully completed until two hours after receipt of the Site Area Emer-gency Classification Level declaration and that this dispatch time exceeded the timetables presented in OPIP 3.6.4 of the Shoreham Emergency Plan.
While FEMA is factually correct that the last general population bus drivers were dispatched from the Patchogue Staging Area approximately two hours after the Site Area declaration, whether that dispatch time was of concern to public health andthe safety.
Had FEMA applied the proper tests, it would have con-cluded that the bus drivers were dispatched in a timely manner.
i An analysis of the dispatch times at Patchogue must begin with a chronology of pertinent events.
Time Event Reference 1) 08:10 EOC Activated FEMA Report, Table 1.1
)
2) 08:24 Site Area Notification FEMA Report, Table 1.1 in EOC 3) 09:45 Prestage Decision in EOC Document 1 (Zones A-G) 4)
09:46 General Emer. Notif, in EOC FEMA Report, Table 1.1 5) 10:10 EOC Decides to Evacuate FEMA Report, Table 1.2 6) 10:24 EBS Evacuation Message FEMA Report, Table 1.2 (Zones A-M, Q, R) 7)
10:45 General Pop. Buses Dispatched FEMA Report, p. 62 Per Prestage Directive 8) 11:10 General Pop. Buses Not Exercise File l l
Prestaged Are Dispatched Per Evacuation Directive
- 9) 11:23-11:31 First Scheduled Buses Leave Document 2 Brookhaven T.P.
- 10) 11:36-11:40 First Scheduled Buses Leave Document 3 s
Middle Island T.P.
- 11) 11:45-12:07 First Scheduled Buses Leave Document 4 Coram T.P.
- 12) 12:02-12:16 First Scheduled Buses Leave Document 5
()
1/ xercise files contain all staging area dispatch forms.
E These forms show the dispatch times of buses from Patchogue for Coram Transfer Point (Zone K) and Expressway Plaza Transfer Point 3
(Zone R).
i,
Q The Shoreham Plan does not require any particular tim in which the dispatching of bus drivers from staging areas must be 1
completed.
Instead, the Plan states that "the dispatching of the first bus from each transfer point is to occur no sooner than one hour after the recommendation to evacuate was made to the public."
OPIP 3.6.4, Step 5.3.4.
The reason the plan is set up this way is straightforward.
People need to be given time to prepare to evacuate and to arrive at street corners on bus routes; to send buses on their routes prior to the arrival of meaningful numbers of passengers would be pointless, t
Thus, under this standard, the first scheduled buses s havelefttheirtransferpointsanysoonerthan11:24.gguldnot I
At the Brookhaven Transfer Point, which serves residents in Zones A-E
--the five zones which contain the entire 0-2 mile EPZ area --
the six buses that were scheduled to begin their routes at 11:24 were dispatched within seven minutes af ter that time.
At the other three transfer points served by the Patchogue Staging area--
Middle Island Shopping Center, Coram Plaza Shopping Center and Expressway Plaza Shopping Center, which respectively serve Zones G
K, and R-- the initial routes were begun anywhere from 10 to 50 minutes after 11:24.
This timing of bus dispatching to the outer zones of the EPZ would not have impacted public health and O
safety during an actual emergency.
The important consideration in determining whether public health and safety would have been affected in an actual emergency is 4
2 whether the bus schedules, in their entirety, were executed in a timely manner.
A review of the transfer point dispatch forms reveals that they were.
(See Documents 2-5).
For the Brook-haven and Middle Island Transfer Points, compliance with the dis-i patching schedule was virtually exact.
For the Coram Plaza and Expressway Plaza Transfer Points, while there were some early delays in dispatching buses, the later buses were again able to i
catch up with the schedule.
As a result, the evacuation of the j
transit dependent population would have been completed at the same time as the population evacuating in private vehicles.
Thus, public health and safety would not have been adversely l
affected.
I Finally, the two hours needed to dispatch the bus drivers following their initial notification (which coincides with the declaration t
of a Site Area Emergency) is entirely consistent with LILCO's y
testimony on mobilization times.
That testimony was expressly l
t 2/The bus schedules which appear in OPIP 3.6.4 are based in i
part on the criterion that "the first buses will arrive at the transfer points no later than 135 minutes (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.15 min.) follow-ing public notification."
LERO Plan, Appendix A, p. IV-74b.
Accordingly, on the day of the exercise the first buses.should have arrived at the transfer point no later than 12:39 (10:24 plus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 15 minutes).
Since all of the first scheduled wave of l
buses had left their transfer points by 12:16 (10:24 + 1 hr.,
l 52 min.), this criterion was met.
I
\\
()
accepted by the Licensing Board when it stated "thus, the Board finds that LILCO's estimate of approximately two hours to sub-stantially complete ~ staging area activities is reasonable."
Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), LBP-85-12, 21 NRC 644 723 (1985).
Indeed, the Board went on to find "that LILCO could substantially complete its mobilization in about three hours."
Id.
LERO clearly demon-strated that it could meet these mobiffzation times during the February 13 exercise.
Thus, no deficiency should have been found at the Patchogue Staging Area.
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~ f__ APPROVED BY:
TLlb 1b A u-OPIP 3.8.2' DAIE Al07) -
~
i V
9 c
et s
' TIME Page 35 of 47 i'
EBS SAMPLE MESSAGES 6
M2f ag %
(conCinued)
EtXHI 0*/r e.2 fazf I
MESSAGE H - GENERAL EMERGENCY (EVACUATION) ate 86habu This is the Emergency Broadcast System.
The Emergency Broadcast System has been activated due to an incident at the Shoreha= Nuclear Power Station.
This is q a test.
O
^ ceaer 1 t=erse=c7 oe=atetoa aect rea O939 (time) today at the Shoreham Nuclear at
/
Power Station.
A General Emergency condition is one of four emergency classifications and indicates that there has been a failure in plant safety systems.
A release of radiation into the air occurred O939 (time).
Basebonmeasurementsof at
/
radiation, the whole body / thyroid ' dose (s) '(select one) are expected to be/
% of the U.S.
EnvironmentalProtectionAgencysheltekingguidelines at 2 miles, I at 5dilesand I at 10
~
I i
miles downwind pf Shoreham.
O Rev. 5 9
10000162
I OPIP 3.8.2 Page 46 of 63 I
(A)
Page 36 of 47 l
EBS SAMPLE MESSAGES (continued)
MESSAGE H - CENERAL EMERGENCY (EVACUATION)
(continued)
The Local Emergency Response Organization for residents living in the 10-mile emergency planning zone around Shoreham has been activated and is responding to the incident.
l:
NOTE IF PROTECTI CTION RECOMMENDATIONS ARE MADE i
O WITH NO OF RADIATION, OMIT THE PREVIOUS TWO (2) P AND USE THE FOLLOWING:
/
.atuFra has be=u ne4=leasa n f ch 6.14 = pl orrt, Hovm4 ;ed en aquns ac
'Nh ergen Inffation to g resid in t h e Emergency Planning l
e incide g.
h ear cerivace n go e
The Director of Local Response for emergencies for the Shoreham Nuclear Power Station, dN/ (Esst4f
~
(name), has consulted with 3.. _7 M'
scientists, LILCO I
O Rev. 5 10000163
i OPIP 3.8.2 Page 47 of 63 1
Attach =ent 4 Page 37 of 47 l
EBS SAMPLE MESSAGES (continued) d Mr.h4 E **
af MESSAGE H - GENERAL EMERGENCY (EVACUATI (continued) 4 s&R(,,q 6nAvi@ie.c-VernW: ert,Ce%efAeMYL.
officials, nuclear engineers, h6 bA,
and officials from public agencies and has recommended the following public action:
1.
All school within the 1 mile emergency planning zone are adv sed to av cuate to predesignated relocation een ers.
drive to school to meet their Parents shoul no j
children si ce chil ren are being safely l
transpor d outside e zone to relocation center.
2.
If you are within the 10-mile emergency planning zone, you should refer to your Shoreham Public Emergency Procedures Brochure to determine the planning zone in which you live.
l 10000164 Rev. 5
.,,,_______..__m.
,,.,,..._-.__m_,__._--,-_.-.-__,_._._..,_._.,.-.____._-_-_,____r
l OPIP 3.8.2 Page 48 of 63 l
O, Attach = enc 4 Page 38 of 47 l
EBS SAMPLE MESSAGES (continued)
MESSAGE H - GENERAL EMERGENCY (EVACUATION)
(continued) 3 Evacuation is recommended for people in planning zones A+N,dik (identify by zone letters and area description).
People in these zones will be safer if they evacuate as soon as possible away from Shoreham.
The reception center and l
evacuation routes are listed in the Shoreham Public Emergency Procedures Brochure.
O If you are not within planning zones /+M, hIk 4.
(identify), there is no reason for you to evacuate.
If you are outside the 10-mile emergency planning zone, there is no reason to take any action.
If conditions change in the future, these recommendations may change and we
' vill inform you immediately.
5.
All milk producing animals in the 10-mile Emergency Planning Zone should be moved into shelters and placed on stored feed.
10000165
OPIP 3.8.2 Page49of63l
,(/
)
A cachment 4 Page 39 of 47 l
'EBS SAMPLE MESSAGES (cont inued)
MESSAGE H - GENERAL EMERGENCY (EVACUATION)
(con:inued)
You will be directed along evacua: ion rou:es by trained traffic guides who know which way you should go.
If you have been advised to evacua:e but do no: have your own transpor:acion and canno: obtain a ride from a neighbor or someone else, special buses will : ravel
(])
along emergency rou:es to t ransport you to the recep; ion center.
l If you have a bedridden, handicapped, or otner person in your home who needs special evacua: ion assis:ance and who has not previously regis:ered wi:n the Local Emergency Response Organizacion (LERO), please call 3k8-6710.
If you have previously regis:ered, enere is no need to call now, help will soon be on it s way.
O Rev. 5 10000166
bo 63 l ag Attach = enc 4 Page 40 of 47 l E5S SAMPLE MESSAGES (continued)
MESSAGE H - GENERAL EMERGENCY (EVACUATION)
(continued)
Before you leave your home or business, make sure you have closed all windows and doors, turned off all appliances, extinguished any fires, and closed fireplace dampers.
Lock all doors when you leave.
1 I
Take blankets and pillows with you for your own use and any medication that you regularly take.
You could be away for several days.
O The 10-mile emergency planning zone around Shoreham is roughly bounded by Main Street in downtown Riverhead to the east, Main Street in Port Jefferson to the west, and Sunrise Highway to the south.
If you live within the 10-mile emergency planning zone, you would have received periodic newsletters and other emergency information.
If you are located within the 10-mile planning zone and do not have a Shoreham Public Emergency Procedures Brochure, public information and a map of 0
Rev. 5 10000167
'OPIP 3.8.2 Page 51 of 63 i 4
Attach =ent 4 Page 41 of 47 [
EBS SAMPLE MESSAGES
~
(continued)
MESSAGE H - GENERAL EMERGENCY (EVACUATION)
(continued) the zone are included in a special insert of the Suffolk County Telephone Book and a more detailed map is in the local Yellow Book.
Posters with emergency information have been provided
{
to local businesses, public parks, beaches, and recreational facilities.
The posters describe the h
recommended evacuation routes out of each zone.
Once again, the Shoreham Nuclear Power Station is in a General Emergency condition (there has been a release of radiation into the air).
It is advised
-7Md/[
(identify) that people in planning zones evacuate as soon as possible away from Shoreham.
Relocation centers and evacuation routes are listed in the Shoreham Public Emergency Procedures Brochure.
Y This message will be repeated every fifteen minutes over this station unless new information'is available Keep tuned to this emergency broadcast sooner.
station for the latest official information.
cdl keieli co ble d dce for c,n) fucker i r m$ e n
'I k Nld Rev. 5 10000158 Y
__