ML20212D705
| ML20212D705 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/27/1987 |
| From: | Harris D, Mayer M SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20212D439 | List: |
| References | |
| OL-5, NUDOCS 8703040181 | |
| Download: ML20212D705 (76) | |
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'l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5
) (EP Exercise)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
DIRECT TESTIMONY OF DAVID HARRIS AND MARTIN MAYER ON BEHALF OF SUFFOLK COUNTY CONCERNING CONTENTIONS EX 47, 22.A AND 49 February 27, 1987 8702p7 cF DS Oh0b8l 050003gy PDit
-' o-UNITED STATES OF AMERICA
- UCLEAR REGULATORY COMMISSION Befotr ;tomic Safety and Licensina Board
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5
) (EP Exercise)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
DIRECT TESTIMONY OF DAVID HARRIS AND MARTIN MAYER ON BEHALF OF SUFFOLK COUNTY CONCERNING CONTENTIONS EX 47, 22.A AND 49 Q. Please state your names and positions.
A. My name is David Harris. I am the Commissioner of Health Services for Suffolk County, New York.
My name is Martin Mayer. I am the Deputy Director of Public l Health in the Suffolk County Department of Health Services.
4 Q. Please summarize briefly your professional backgrounds.
i.
- A. (Harris) I have been Commissioner of the Suffolk
! County Department of Health Services since 1977. From 1975 to 1977, I was Deputy Commissioner of Health Services for Suffolk t
i County. I was Associate Director of the Mt. Sinal Hospital from l
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e e 1971 to 1975, and prior to that I was associated with the New York City Department of Health where I was Deputy Commissioner of Health from 1969 to 1971.
I am board certified in the medical specialities of pediatrics and preventive medicine. I am also Professor of Clinical Community and Preventive Medicine Clinical Pediatrics, at the State University of New York at Stony Brook. In addition, I hold academic appointments at the New School for Social Research in New York City and at the C.W. Post Center of Long Island University, and I lecture at Columbia University School of Public Health. I am a member of the New York State Mental Hygiene Planning Council, and the Governing Counsel of the American Public Health Association; a copy of my professional qualifications is Attachment 1 to this testimony.
(Mayer) I have been the Deputy Director of Public Health in the Suffolk County Department of Health Services since 1972. I am a Clinical Assistant Professor in the Department of Community and Preventive Medicine at the State University of New York at Stony Brook. A copy of my professional qualifications is Attachment 2 to this testimony.
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Q. What is the purpose of this testimony?
A. The purpose of this testimony is to address Contentions Ex 47, Ex 22.A and portions of Ex 49, arising out of the exercise of LILCO's Offsite Emergency Plan for the Shoreham Nuclear Power Plant, which was held on February 13, 1986 (hereafter the
" Exercise"). The testimony which follows is jointly sponsored by both of us.
Q. Are you familiar with LILCO's offsite emergency plan for Shoreham?
A. We have reviewed, among others, those portions of the LILCO Plan and procedures which concern persons in special facilities or with special needs, and radiological monitoring and decontamination at reception centers for the general public.
During the previous Shoreham emergency planning litigation before an NRC Atomic Safety and Licensing Board, we submitted testimony concerning LILCO's proposals for providing relocation and reception services, as well as other LILCO proposals relating to protective actions for hospital and special facility residents, and for the homebound and mobility-impaired population in the 10-mile emergency planning zone (EPZ). Since the filing of that
- testimony, however, LILCO has changed its proposals for providing radiological monitoring and decontamination services to evacuees.
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We have reviewed those proposed changes as well as the events which took place during the February 13 Exercise which purported to demonstrate the implementation of some of those proposals.
Q. What do you understand to have been the purpose of the Exercise?
A. We understand that the NRC's regulations require there to be an exercise of the offsite emergency response plan for a nuclear power plant before a license can be issued authorizing full power operation. Such an exercise, according to the NRC's regulations, must be graded by FEMA and the NRC must then consider FEMA's findings concerning the results of the Exercise in its decision on whether there is reasonable assurance that adequate measures to protect the public health and safety can and will be taken in the event of a nuclear accident at the plant.
CONTENTION EX 47 Q. Please state Contention Ex 47.
A. The Contention states as follows:
The exercise revealed a fundamental flaw in the LILCO Plan in that LILCO failed to demonstrate the ability to register, monitor and decontaminate evacuees from special facilities who are transported to reception centers other than the Nassau Coliseum, or that such activities could be accomplished within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as required by NUREG 0654 5 II.J.12. Thus, LILCO has not satisfied objectives FIELD 13 and 21, and the exercise
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precludes a finding that the LILCO Plan com-plies with 10 CFR S 50.47(b)(1), (b)(8),
(b)(10) and NUREG 0654 S II.J.9, 10, and 12.
According to the estimates in the Plan, if there were an evacuation of the entire EPZ, there could be as many as 1600 residents of nursing and adult homes, health care and other special facilities, all with special needs, requiring that they be sent to special reception facilities (OPIP 3.6.5, Att. 2),
plus tens of thousands of school children.
This number could be increased by approximately 850 persons if the hospitals in the EPZ and the Suffolk Infirmary also were evacuated. Id. The LILCO Plan, Rev. 6, which was the subject of the exercise, has no provision for the registration, radiological monitoring or decontamination of such indi-viduals; nor does it include provisions for reception centers for the vast majority of such individuals, or agreements indicating that any such reception centers are in fact available or adequate to serve that purpose.
Rather, it includes registration, radiological monitoring and decontamination procedures to be implemented, a.nd equipment and personnel to be present, only at the Nassau Coliseum and the Emergency Worker Decontamination Center.
OPIP 4.2.3; OPIP 4.3.1. This is a deficiency ,
in the Plan which violates NUREG 0654 S II.A.3, J.10.d and 12, and 10 CFR S 50.47(b)(8) and (b)(10). It precludes a finding that the LILCO Plan is adequate, or that there is reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham emergency as required by 10 CFR S 50.47 (a)(1).
Furthermore, the proposal in the new Revision 7 version of OPIP 4.3.1, purportedly to address this deficiency (ggg letter dated June 20, 1986, from John D. Leonard to Harold Denton, (SNRC-1270), and Att. I at 4), fails to correct this deficiency for the following reasons:
A. The proposal to send only one monitor to each special facility reception center -- assuming arauendo reception centers existed -- is unworkable. Egg OPIP 4.3.1
, S 5.1.6 (Rev. 7). For example, one of the few I special facility reception centers designated I
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a o by LILCO is expected to receive up to 465 evacuees. OPIP 3.6.5, Att. 2. One person could not adequately or effectively perform the necessary monitoring, recorckeeping, and related activities that would be required at such a center.
B. The proposal to have monitoring done as evacuees leave their buses, ambulances or ambulettes (agg OPIP 4.3.1 S 5.4.9.c (Rev. 7))
is unworkable. It could not be done in inclement weather, there is no assurance that reception centers -- assuming arauendo they existed -- would be laid out to permit such activities at unloading points, and the evacuees, who by definition have special needs, cannot be subjected to waits in buses or ambulances while lines of others arriving ahead of them are monitored by one LERO worker.
C. The proposal to have bus drivers keep necessary monitoring records (agg OPIP 4.3.1 S 5.4.9.c (Rev. 7)) is unworkable. Such personnel have not been trained for such a function, nor have they been properly equipped to fulfill it. It is also impractical to expect a bus driver to be able to perform such a function.
D. The proposal to have persons found to be contaminated "cet back on the bus" and
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eventually driven to the Nassau Coliseum (agg OPIP 4.3.1. S 5.4.9.d (Rev. 7)) is unworkable, impractical and dangerous. The evacuees at special facility reception centers are, by definition, in need of special care that cannot be provided at the Nassau Coliseum. To refuse to decontaminate them, and instead to send them to a facility that is not equipped to handle their special needs, and in the process delay their decontamination and also expose them to other contaminated people on the bus, thus potentially increasing their exposure, is without justification.
E. The provision that it is not necessary to provide monitoring personnel at '
reception centers for schools (agg OPIP 4.3.1.
S 5.1.5 (Rev. 7)) is wholly inadequate.
Assuming arauendo that such reception centers exist -- and they do not -- there is no basis for LILCO's refusal to provide radiological
monitoring and decontamination services to the school children evacuees who would be taken there. This refusal is a clear violation of NUREG 0654 S II.J.12. Furthermore, the LILCO explanation that such services are not necessary "if the parents are going to be picking up the children," makes no sense, and fails to correct the deficiency.
Finally, during the exercise, messages apparently were transmitted among certain LILCO players referring to requests that monitoring personnel be sent to certain hospitals and facilities outside the EPZ. The exercise failed to demonstrate, however, that LILCO is capable of providing registration and monitoring at actual reception centers for actual evacuees with special needs during a real emergency, since: (a) such personnel were not actually sent to any special reception center facilities during the exercise (all the referenced facilities were only " simulated" reception centers in any event since none of them participated in the exercise); and (b) there was no demonstration that the LILCO personnel were capable of (i) performing the necessary registration and monitoring of the number of evacuees with special needs likely to be taken to cuch facilities, or (ii) otherwise properly imple-menting necessary procedures for registering, monitoring and decontaminating evacuees at such facilities, even assuming arauendo that facilities for use as special facility reception centers exist. Accordingly, the exercise precludes a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham accident, as required by 10 CFR S 50.47(a)(1).
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Q. Do you agree with that Contention?
A. Yes, we do.
Q. Before we discuss the issues raised in the subparts of the Contention, please summarize generally the bases for your agreement with Contention Ex 47.
A. The main point of Contention Ex 47 is that the Exercise provides no basis for evaluating any LILCO proposals for registration, radiological monitoring, or decontamination of the evacuees from special facilities who would be transported to special reception centers during a Shoreham accident. As noted in the Contention, regulatory requirements set forth in NUREG 0654 S II.J.12 require that there exist an ability to register and monitor evacuees at reception centers within approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. We understand that there is no dispute as to the fact that during the Exercise LILCO personnel did not demonstrate the registration, monitoring or decontamination of evacuees from special facilities.1 Furthermore, the version of the LILCO Plan which was the subject of the Exercise, Revision 6, contains no procedures detailing how evacuees sent to special reception centers would be registered, monitored, or decontaminated. For 1 LILCO's Response to Suffolk County, State of New York and the Town of Southampton's First Request for Admissions (November 17, 1986) (hereafter, "LILCO Admissions"), Admission No. 192, p. 41; FEMA Amended Answers to Suffolk County First Request for Admissions (January 27, 1987) (hereafter, " FEMA Amended Admissions"), Admission No. 37, p. 2.
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.these reasons among others which we discuss below, we believe that the Exercise provides no basis to conclude that the LILCO Plan complies with the regulatory requirements cited in Contention Ex 47, or that the activities required by the regulations could and would be implemented by LILCO in the event of a real accident.
An additional point made in Contention Ex 47 is that the proposals which LILCO generated after the Exercise to address the lack of planning for special facility residents are inadequate i
and unworkable. In our opinion, they are also incomplete, impractical, and potentially dangerous. They fail to take into l account the practical realities involved in dealing with and l caring for individuals with special needs. As a result, if LILCO were to attempt to use them in a real accident, they could further endanger or harm special people, rather than provide l necessary services and care to them following their evacuation.
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Q. What do you mean by the term "special facility resi-f dents" or people with "special needs?"
A. For purposes of this testimony, we use those terms to f
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refer to special people who are residents of those facilities located in the EPZ identified by LILCO as " Handicapped Facilities," " Nursing / Adult Homes," and hospitals. According to i
the LILCO Plan, the facilities for the handicapped and their l
i i approximate populations are the following:
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- . - - __. . _ , , . . . ~ . _ . . . _ . . . _ _ _ _ _ . _ _ , _ . _ _ _ . . _ . . , _ _ . , . . . . _ _ . . , . . _ _ _ . . . . . . _ . _ . ~ . _ _ _ _ _ _ _ . _ . . . _ _ - . . .
Facility No. of Residents Ambulatory Non-Ambulatorv Association for the Help of Retarded Children, Robert Sansone Intermediate Care Facility 26 22 Association for the Help of Retarded Children, Work Activities Center 98 2 Association for the Help of Retarded Children, Community Residence (Lincoln Street, Riverhead) 8 0 Association for the Help of Retarded Children, Community Residence (Roanoke Avenue, Riverhead) 6 0 Maryhaven Conter of Hope, Day Residential School (Port Jefferson) 98 0 Maryhaven Center of Hope, Therapeutic Preschool 55 0 Maryhaven Center of Hope, Community Residence / Training House 12 0 Maryhaven Center of Hope, CSS Continuing Treatment Center 50 0 Maryhaven Center of Hope, Hostel II 9 0 Maryhaven Center of Hope, Hostel IV 9 0 Maryhaven Center of Hope, Apartments Self 1 - 6 14 0 United Cerebral Palsy of Grea.er Suffolk, Inc., Hostel Residence (Ridge) 4 0 United Cerebral Palsy of Greater Suffolk, Inc., Hostel Residence (Mt. Sinal) 6 0 BOCES Learning Center _1H _n1 TOTALS 413 88 10 -
1 Appendix A, IV-167 through 168.
Nursing / Adult Homes and their approximate populations are listed as follows:
Crest Hall Health Related Facility and Oak Hollow Nursing Center 53 231 Millcrest-Adult Home 16 0
- Our Lady of Perpetual Help Convent 15 5 s
Ridge Rest Home 53 1 Riverhead Nursing Home and Health
- Related Facility 60 121 s
Sunrest Health Facilities, Inc. 27 180 1
Woodhaven Nursing Home and Woodhaven l Home for Adults 221 __Q TOTALS 548 538 Appendix A at IV-175.
Finally, the LILCO Plan identifies the following hospitals and their approximate populations:
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Suffolk Infirmary 215 1
, Central Suffolk Hospital 157 i St. Charles Hospital 271 i
John P. Mather Memorial Hospital IQ2 TOTAL 846 i
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. _ - . = - -._- . . . . , _ _ . . - _ ~ . . _ _ . . - . _ , _ _ . , _ _ . . _ _ _ _ _ _ _ _ , . _ _ _ _ . . _ . . . . . . _ _ _ . _ _ _ . . .. _,_
e OPIP 3.6.5, Attachment 2.
The individuals in the listed facilities all have special needs or they would not be in those facilities. Their needs and their medical conditions vary: large numbers are not ambulatory; large numbers are dependent upon special equipment due to their medical or physical conditions; many have mental, emotional, or physical conditions which make them unable to cope with ordinary life situations in the traditional or " expected" manner; and many require constant or a great deal of supervision.
I Q. Under the LILCO Plan as exercised, what is supposed to happen to these special facility residents if LILCO were to order an evacuation of the entire EPZ?
A. According to Revision 6 of the LILCO Plan, the residents of the facilities for the handicapped and nursing / adult homes in the EPZ would be advised to evacuate, and LILCO would provide transportation assistance in the form of ambulances, ambulettes, and buses in the numbers required to accomplish that evacuation. LILCO Plan, App. A, IV-166b, 174; OPIP 3.6.5.
l According to the Plan, the special facility residents would be l
taken to special reception centers different from the one (or ones) identified for the general public. This is because, as l
LILCO acknowledges, such individuals need specialized care and facilities. LILCO states:
Because of the number of the nursing home patients and the specialized care and facilities some of them require, it was felt that the public Reception Centers were not adecuate for all their needs.
Appendix A at IV-174 (emphasis added). Similarly, with respect to residents of facilities for the handicapped, LILCO states:
United Cerebral Palsy of Greater Suffolk, Inc.
will relocate to other UCP residences outside the EPZ. The Association for the Help of Retarded Children will relocate to the Suffolk Developmental Center. The other three organi-zations will be transported to predesignated relocation centers.
Appendix A, IV-166b. Significantly, however, for the vast majority of the special facilities in the EPZ, no such special reception centers have been identified by LILCO. Instead, the Plan indicates that such reception centers are "to be arranged."
Egg OPIP 3.6.5, Attachment 2.2 l 2 The only nursing / adult homes for which reception centers are identified in the LILCO Plan as exercised, are the Oak Hollow Nursing Center and Crest Hall Health Related Facility, and the Riverhead Nursing Home and Health Related Facility. The La Salle Military Academy is identified as the reception center for the residents of those facilities. By letter dated September 2, 1986, however, the administrator of the Oak Hollow and Crest Hall facilities rescinded an evacuation transportation agreement apparently signed for LILCO in November 1984. A copy of that letter is Attachment 3 hereto. Thus, while the revision of the Plan which was the subject of the Exercise indicated the exis-tence of an agreed upon reception center for 465 nursing / adult l home residents, in reality, such a center apparently exists, if l at all, only for the 181 residents of the Riverhead Nursing and l Health Related Facility.
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According to the Plan, evacuees are to be registered, monitored for radiation, and decontaminated, if necessary, at reception centers. In the LILCO Plan as exercised, however, the only procedure detailing how such activities should be performed refers to the Nassau County Veterans Memorial Coliseum and procedures for dealing with the general public. Egg Plan at 3.6-7; OPIP 4.2.3. Although the Plan makes passing reference to special facility reception centers, it falls to indicate how registration, radiological monitoring, or decontamination of residents of special facilities could actually be accomplished.
The only provisions on that subject contained in Revision 6 are the following:
If a radioactive release has occurred, the Radiation Health Coordinator will have the Decontamination Coordinator dispatch moni-toring personnel when available to special facility reception destinations identified by the Special Facilities Evacuation Coordinator.
OPIP 3.9.2 S 3.2.
When directed by the Radiation Health Coordi-nator to dispatch monitoring personnel to special reception facilities (the Decontamina-tion Coordinator should):
- a. Obtain a list of the facilities from the Special Facilities Evacuation Coordinator.
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- b. Contact Decontamination Leaders at the Reception Center and EWDF and ascertain which facility can spare monitoring personnel.
Arrange for available monitoring personnel to j be sent to the facilities.
- c. Keep the Radiation Health Coordi-4 nator informed of the status of this opera-l tion.
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OPIP 3.9.2, 5 5.1.5. !
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l Therefore, according to the Plan as exercised, there is
-essentially no provision for the majority of special facility i
residents other than to load them into vehicles to be transported out of the EPZ. Their destinations are unknown, whether they could or would be properly cared for is unknown, and there are, in essence, no provisions for registering, monitoring, or decontaminating them.
We understand that FEMA also found this aspect of LILCO's l
Revision 6 inadequate, in its review immediately prior to the t
Exercise.
FEMA stated the following with respect to OPIP 3.9.2:
In step 3.2 of the revised (OPIP 3.9.2), the statement is made that if a radioactive release has occurred, monitoring personnel '
will be dispatched to'special facility reception centers when available. LERO is '
responsible for monitoring all evacuees arriving at reception centers. It is not adequate to plan for this monitoring with personnel and equipment when available. It is not possible to evaluate the number of per-sonnel required for monitoring at the special population reception centers since the Plan i shows in procedure OPIP 3.6.5 pages 21-37, "to i be arranged" for most of the special (
population reception centers.
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I FEMA Review of Revision 6, dated February 13, 1986, at 2. FEMA also stated that monitoring personnel and equipment must be available for all reception centers which are not for the general public, as well as for any locations shown in the LILCO Plan as "to be arranged." Id.
Q. According to the Plan as exercised, what would happen to the residents of hospitals in the EPZ if the entire EPZ were evacuated?
A. In general, LILCO proposes to recommend sheltering for hospital patients, even if an evacuation is recommended for all other individuals in the EPZ. If a decision is made to evacuate the hospitals, however, under the LILCO Plan LILCO would provide necessary transportation for such evacuation on an ad has basis, after all the other special facility residents at.d individuals requiring transportation assistance had been evacuated and the necessary vehicles had become available. Egg OPIPs 3.6.1; 3.6.5.
Further, according to the Plan as exercised, patients evacuated from hospitals would be transported to reception hospitals. But, such hospitals are not identified in the Plan; instead the Plan merely contains the note "(filled in at time of emergency)" for the " reception centers" for hospitals. OPIP 3.6.5, Attachment 2.
l So, even though LILCO acknowledges the potential need to evacuate
! hospital patients, and the need, in the event of such an i
evacuation, to transport patient ovacueen to reception hospitals, l
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. e the LILCO Plan as exercised provides no basis to determine that such reception hospitals exist, nor is there any provision for the registration, radiological monitoring, or decontamination of patient evacuees at the unidentified reception facilities.
Q. Contention Ex 47 also refers to school children. Under the LILCO Plan as exercised, what is supposed to happen to school children if there is an evacuation order during a Shoreham accident?
A. According to the LILCO Plan as exercised, if schools are in session when evacuation is recommended for the EPZ, schools will be requested to implement an evacuation of their students to " pre-designated reception centers," where, presumably, they would be registered, monitored and decontaminated. Egg Appendix A at II-20; OPIP 3.6.5. The Plan as exercised, however, contains no identification of reception centers for any schools or school districts. Accordingly, the situation for school children is essentially the same under the exercised LILCO Plan as that described above for special facility and hospital patients: there is no provision for registration, radiological monitoring, or decontamination of school children in the event an evacuation were required. Both FEMA and LILCO have acknowledged that during the Exercise, there was no demonstration
of, and FEMA did not evaluate, the availability, location, accessibility or adequacy of reception centers for school children.3 Q. Why is it significant that the LILCO Plan fails to include the registration, monitoring and decontamination provisions which you have just discussed?
A. It is significant for several reasons. First, we understand that it is required by the applicable regulations.
Specifically, NUREG 0654,Section II.J.12 requires that plans
" describe the means for registering and monitoring of evacuees at relocation centers in host areas." It further requires that "the personnel and equipment available should be capable of monitoring within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period all residents and transients in the plume exposure EPZ arriving at relocation centers." And, NUREG 0654 S II.J.10.d requires there to be "means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement." In our professional opinion, such means must include the capability of providing radiological monitoring and if necessary decontamination.
3 LILCO Admissions, No. 56, p. 13; FEMA's Response to Suffolk County, State of New York, and Town of Southampton's First Request for Admissions and Second Set of Interrogatories Directed to FEMA (November 19, 1986) (hereafter, " FEMA Admissions"), Nos.
76, 122, pp. 20, 32.
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Second, the regulatory requirement reflects the obvious need, from a public health point of view, for registration, monitoring, and decontamination of evacuees folicwing a nuclear ,
accident. , .,
Third, LILCO itself has acknowledged the need to provide such services for members of the general public. Its failure to' include in its Plan implementable procedures to provido them for special populations in the EPZ is without basis and unacceptable. ,
i Such special populations are as much if not mere in need of such i essential services and they must be provided. ,
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Q. Please explain why registratic,n{ radiological
- monitoring, and decontamination services following a nuclear- }
4 accident are essential from a public healin point of view'. >
s A. Registration is essential for several reasons. FI'tst, families and loved ones must be able to locate special facility i residents after an accident. "Second, records must be kept concerning the effects of the accident, the evacuation process, and subsequent care and' t.reatment of special facility residents l
i on preexisting health conditions. Third, records must be kept on radiological exposures and contamination to permit the necessary medical follow-up on individuals who have been contaminated.
In l
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e' s Eddition, such records are an invaluable source for epidemiolo-
> gical, evaluations conducted after a radiological accident to
'I understand its consequences and make future policies.
Radiological monitoring is essential to identify persons who have been exposed so that necessary decontamination measures can be taken and other treatment, if necessary, can be administered.
It is also essential to calm fears and anxieties and concerns --
real or imagined -- about potential exposures. Such fears and I
anxieties raay be particularly great among individuals with rpecial needs and their families. Decontamination is essential for the very obvious health reasons.
tie should point out that the need for all three of these Ber'11Ces is particularly acute with respect to school children.
Parents will be very concerned about the condition of their
! children and for good reason, since children are more susceptible to the h6rmful effects of radiation.
Q. During the Exercise did LILCO demonstrate or attempt to demonstrate its ability to register, monitor and decontaminate residents of Ppecial facilities? If the answer is no, please
- provide your virws on the significance of the omission.
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A. LILCOdidnotattempb;todemonstrateduringthe Exercise any ability to registdr', monitor or decontaminate special facility population. Accordingly, the exercise results had the effect of confirming and demonstrating a fundamental void in LILCO's Plan: LILCO has, and has demonstrated, no capability
< of registering, monitoring, or decontaminating special facility residents.
We believe that the foregoing flaw in the LILCO Plan, as demonstrated during the Exercise, is significant for at least two reasons. First, in our professional opinion, responsible officials of special facilities -- be they adult homes, nursing homes, facilities for the handicapped, or schools -- would never permit their patients to be evacuated absent a prior demonstration of adequate facilities and procedures for the registration, monitoring, decontaminating, housing and care of their patients or charges. Since LILCO failed to provide such a demonstration, we conclude that LILCO lacks the capability to implement the protective action of evacuation of special facility residents.
Second, and related to the first, it is not easy to regis-ter, monitor, decontaminate, and house special facility evacuees.
As we discuss in more detail below, these are persons with
, special needs which, in turn, require special care in planning i
and implementing protective actions. One cannot take on faith t
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that any entity -- particularly LILCO -- has the ability to provide for these special needs. LILCO's decision at the Exercise to ignore these needs completely is significant because it underscores that the Exercise does not provide the basis for finding that LILCO can implement an evacuation of special facility residents.
Q. Contention Ex 47 goes on to discuss a LILCO proposal, made subsequent to the Exercise, apparently intended to address the failure of the Plan as exercised to provide for registration, monitoring, and decontamination services for special facility residents. Please describe the provisions of that proposal as you understand them.
A. In the Revision 7 version of LILCO's OPIP 4.3.1, there is what appears to be an offhanded attempt to deal with special facility residents. That OPIP contains a provision that the Decontamination Coordinator should contact the Emergency Worker Decontamination Facility Decontamination Leader, and "have him dispatch one monitor, with equipment, to each of the special facility relocation centers." OPIP 4.3.1 S 5.1.6 (Rev. 7). The Decontamination Leader, in turn, is instructed to " assign one monitor" "for each designated relocation center," to "give the monitor a map of the location from the box of maps in the EOC Storage Room," and to " ensure that the monitors have dosimetry l
1 and other equipment as specified in OPIP 3.9.2." OPIP 4.3.1 S 5.2.12. Finally, the assigned monitor is instructed to do the following:
- a. Obtain a map of the (Special Facility]
Relocation Center from the Decontamination Leader. The map will give directions and the number of child and adult evacuees expected at the relocation center.
- b. Proceed with personal dosimetry and radiological equivalent for monitoring of children and/or adults as appropriate.
- c. Upon arrival at relocation center, ensure evacuees have not already arrived.
Await buses and monitor evacuees as they come off the bus in accordance with OPIP 3.9.2.
Ask the bus driver to maintain a list of names of all monitored evacuees.
- d. If contamination above acceptable limits is found on an evacuee, have him get back on the bus. When monitoring is completed, the bus driver should drive the bus to the Nassau Coliseum.
- e. When all evacuees have been monitored, return with list of monitored evacuees to the EWDF.
OPIP 4.3.1 S 5.4.9 (Rev. 7). That is the totality of the provisions in LILCO's Rev. 7 which are apparently intended to address the need to provide registration, radiological monitoring and decontamination services to special facility evacuees. As we stated before, the proposal is impractical and unworkable. FEMA agrees. As recently as December 15, 1986, FEMA restated its earlier finding that the LILCO Plan is inadequate in its j provisions -- or more accurately, lack of provisions -- for
monitoring of special facility residents at special reception centers. Egg Consolidated RAC Review of Revision 8, dated December 15, 1986, Attachment 1 at 12.
Q. Subpart A of Contention Ex 47 refers to the portion of the Revision 7 proposal involving sending only one monitor to each special facility reception center. Please explain why that proposal is unworkable.
A. As noted in the Contention, the special facility reception centers, assuming they exist, are expected to be able to handle large numbers of evacuees. One person may be able to perform the necessary monitoring, registration, and related activities for a small number of individuals, assuming those individuals would require no special attention or treatment beyond a typical registration process and the passing of probes near the person's body to determine if they have been contaminated. That is not the type of activity which would be required, however, in dealing with the residents of special facilities. Rather, such individuals would require substantially more attention. Even the simplest tasks of passing probes near their bodies to determine if they have been contaminated, and obtaining basic registration data, would be much more complicated than one individual could handle, particularly if the numbers of people arriving at a location to receive such services were large.
Q. Please explain why providing registration and monitoring services to special facilities residents would require more than one individual.
A. The primary reason is because special facility residents, by definition, have special needs which must be recognized and dealt with. Individuals in wheelchairs, under medical treatment involving specialized equipment and medication, or with mental, emotional, or physical conditions requiring institutionalization or housing in a special facility, require special handling. Although the types of special needs will vary depending upon which portion of the special facility population one is discussing, in general one person would not be able to deal with the tasks involved in registering and performing radiological monitoring upon special needs evacuees. For example, performing the necessary tasks for non-ambulatory individuals would likely involve moving them, assisting them out of their wheelchairs, and holding them up while they are being monitored. Performing them for an elderly person could involve the same activities, plus perhaps also explaining the process to them to gain their cooperation, or to calm them if they are confused, frightened, or upset. If only one person were to attempt to perform such tasks for a large number of evacuees, one of two things could happen. The special facility residents being dealt with could be hurt or discomforted, or, dealing with them could take such a substantial amount of time that others arriving to receive such services would not be attended to in a timely or efficient manner. Since all such persons would be in need of attention, the delay resulting from the length of time necessary to deal with each individual resident would, in turn, be harmful to the other special facility residents arriving at the reception center.
Q. Subpart B of Contention Ex 47 refers to the portion of the Revision 7 proposal involving the monitoring of special facility residents "as evacuees leave their buses, ambulances or ambulettes." In your opinion, is this portion of the LILCO proposal workable?
A. No it is not. First, a large portion of special facility residents will be transported by ambulette or ambulance, because they are nonambulatory and/or have medical conditions which require transportation and equipment available in such specialized vehicles. These individuals do not present the typical situation of people simply filing off buses and being able to stand around waiting in a line to be monitored out on the sidewalk.
Second, the suggestion that radiological monitoring could be done in the casual manner implied by LILCO's proposal, prior to transferring special facility residents from their evacuation vehicles into buildings and rooms where they could be settled and
made comfortable, is completely unrealistic. It is difficult to be specific, since LILCO has failed to identify the reception centers to which such special facility residents would be transported. But, in general, the types of facilities which could be appropriate for this purpose are not set up or laid out to include sheltered areas either outside their buildings, or in foyers, where monitoring of large numbers of persons with special needs could be performed. On Long Island there are many months during which the weather would not permit leaving special facility residents outside while radiological monitoring is performed, one-by-one, upon them. Furthermore, given the special needs of such residents, including, for many, the need to have special equipment, diets, and medication, it is important that such individuals be quickly transported from evacuation vehicles into a stable environment. While having monitoring performed expeditiously is obviously also important, our point is that that goal must be met in a manner which recognizes and deals with the other needs of these special populations. LILCO has ignored this reality and as a result its proposal is unworkable.
Q. Subpart C of Contention Ex 47 refers to the portion of LILCO's Revision 7 proposal involving the keeping of necessary monitoring records by bus drivers. Do you agree that that proposal is unworkable?
1
A. As proposed by LILCO in its procedure, the proposal would not be workable. At first glance, it would appear that anyone, including a LILCO bus driver, could write down identification information for individuals who get off a bus and are monitored for radiological contamination. What LILCO proposes is not that simple, however. First, as noted, many of the special facility residents will arrive at reception centers by ambulance or ambulette, and not by bus. So, reliance on LILCO bus drivers to perform the registration function is impractical for the obvious reason that for many special facility evacuees, there will be no bus drivers to register them. In addition, and quite important, the concept of having important registration records scattered among dozens of vehicle drivers is completely contrary to good public health practice, in that it defeats the essential goal of having a central repository of information that can be used to locate evacuees and determine their conditions.
Second, many special facility residents will not present the typical situation of simply having to write down a name and address provided in response to a question. For example, elderly individuals may not be able to provide in a clear or coherent manner the necessary " registration information"; handicapped children, or individuals who require transport by ambulance because of serious mental or physical conditions, may also not be able to do so. The records to be kept at a reception center are very important. They must be accurate and they must contain t
I
certain essential information. To suggest, as LILCO does, that all that is involved is keeping a list of people's names as they disembark from a bus ignores the practical realities and public health responsibilities that would be involved in dealing with a population of special facility residents, arriving at an unfamiliar institution, in the midst of a nuclear accident.
Q. Subpart D of Contention Ex 47 refers to the portion of the LILCO proposal that persons found to be contaminated will be told to "get back on the bus" to be driven to the Nassau Coliseum for decontamination. What is your opinion of that portion of LILCO's proposal?
A. We agree with the allegation in the Contention. It is unworkable, impractical and potentially dangerous.
Q. Please explain.
A. First, it is difficult to justify a proposal that elderly, infirm, handicapped or ill patients should be unloaded from special vehicles, monitored and registered in some unidentified location (possibly outside), and then reloaded back into special vehicles to be taken to another location (and then, presumably, returned after decontamination to unidentified locations for housing), rather than providing the necessary care
- and treatment at the special reception center which would be
their first stop. For many residents of special facilities the mere act of being loaded onto or unloaded from a vehicle is itself traumatic, difficult, uncomfortable and potentially painful. To subject these individuals to the process more than once, unless absolutely necessary, is unacceptable.
Second, as we discussed above, the process of loading and unloading many of such individuals in and out of vehicles is also a complicated and difficult task requiring, in many instances, more than one attending staff member. Therefore, going through that process more than once for any given special facility resident should be avoided in the interest of maximizing the availability of staff to tend to the needs of patients.
Third, for many special facility residents, the travelling process itself would be uncomfortable or painful, and also traumatic. Remember, these people have been institutionalized for a reason. Removing them from the facilities and care provided at those institutions will deprive them of essentials which they require, as well as conveniences and comforts to which they are accustomed. The evacuation trips from the special facilities to the special reception centers will themselves likely take considerable time. Evacuation vehicles such as buses and ambulettes are not comfortable to begin with; for persons with special needs, spending one or two hours in them, or longer, could be very difficult. To have these people arrive at a special reception center, unload them from a vehicle, and then load them back up for a trip to the Nassau Coliseum (or some other location) for decontamination, and then load them again for a return trip -- all of which could take an additional several hours -- is unacceptable, unless absolutely necessary. It could prove dangerous to the physical and mental health of special facilities residents.
Fourth, if special facility residents are found to be contaminated, it is not in their interest or in the interest of other individuals to leave them in that state, and merely ship them off to another facility. Assuming that the contamination is not of the level that would require complex medical treatment (in which case a transfer may be medically necessary), the required decontamination measures should be taken immediately. Depending upon the type of contamination involved, a delay in decontamina-tion procedures could increase the exposure of the individual, and thereby increase the potential for harmful health effects.
Furthermore, from a medical point of view, the decontamination process should be initiated as soon as possible not only to minimize the health threat to the exposed individual, but also to minimize the potential of exposing others, such as those whom LILCO proposes to be in the buses or other vehicles with the contaminated persons, those who would be in those vehicles subsequently, and others who may come in contact with the contaminated individual. In addition, if individuals know that they are contaminated but are told that nothing will be done to decontaminate them until after they arrive at the Nassau Coliseum, that will likely cause substantial fear and anxiety.
Fifth, there is no evidence that whatever reception center or centers would be used for the general public in place of the Nassau Coliseum (which is referred to in LILCO's Revision 7) would be equipped to deal with the special needs of facility residents. Not only are there special physical requirements involved in loading and unloading and treating individuals with special needs, but as we discussed above, special staff knowledge and expertise is also required. The fact that LILCO has acknowledged the need to send special facility residents to facilities with special equipment and staff is evidence of the fact that suggesting decontamination of special facility residents at the general public reception center is unacceptable and would not work.
i Q. Subpart E of Contention Ex 47 refers to the provision of LILCO's Revision 7 concerning the monitoring of school children. Please explain the LILCO proposal as you understand it.
l t
A. The referenced provision of OPIP 4.3.1, S 5.1.5 (Rev.
7), states as follows:
o .
When an evacuation is recommended to the public, obtain a list of special facility relocation centers from the Special Facility Evacuation Coordinator (it is unnecessary to include reception locations for evacuating schools if the parents are going to be picking up the children).
As we stated earlier, under LILCO's Plan school children are to be taken to special reception centers (which to date have not been identified). The quoted portion of LILCO's procedure is cryptic, to say the least. But, whether or not parents ,
eventually pick up their children from such centers, the children nonetheless need to be monitored for radiation exposure as soon as it is feasible to do so. To suggest that children not be monitored is absolutely unacceptable.
Q. Perhaps LILCO's comment in the portion of Revision 7 which you quoted reflects an assumption that parents would take their children to the general population reception center to be monitored, after they had picked them up from the special-reception centers. If that in fact is what LILCO intended, would that alleviate your concerns?
A. No it would not. Children are particularly susceptible to radiation. They are also at least as likely as adults to have i
been exposed to radiation during a Shoreham accident, given the possibility of their being outside during a release, and the difficulty of preventing children from touching things which may I
[
have been contaminated. Accordingly, it is essential that they l
l l l
be monitored as soon as possible not only for their own protection, but to reduce.the likelihood that any contamination they might have-would be spread or dispersed, thereby endangering others. In addition, there is no basis for an assumption by
- i. LILCO that parents would know that they should take their child to another location to be monitored for radiation, or that they could do so in a reasonable amount of time. The LILCO Plan makes no provision for such a two-etep process, nor would such a process make sense. Moreover, to require parents to retrieve their children from special reception centers before the children are monitored, and then require the parents to travel to the general public reception center, could result in increased exposures for both parents and children. If the purpose of a reception center is to provide registration and radiological monitoring, there is no justification for a Plan provision that such centers for school children would not provide these essential and required services. Parents would expect no less.
Q. Contention Ex 47 alleges that during the Exercise LILCO did not satisfy Exercise objectives FIELD 13 and 21. What are those objectives?
A. Objective FIELD 13 is: " Demonstrate a sample of resources necessary to effect an orderly evacuation of the institutionalized mobility-impaired individuals within the 10-mile EPZ." Objective FIELD 21 is: " Demonstrate the adequacy of
.--. _ . .- -.________ ~ . - - _ _ .- -
procedures for registration, radiological monitoring, and decontamination of evacuees and vehicles including adequate provisions for handling contaminated waste at the Reception Center."
Q. Do you agree that during the Exercise LILCO did not satisfy those objectives?
A. Yes we do. Since there was no demonstration at all of the availability of facilities or the ability of LERO to perform registration, radiological monitoring, and decontamination of special facility evacuees, the Exercise provides literally no basis upon which it could be concluded that objective FIELD 21 was satisfied with respect to that large population of individuals.
Similarly, the Exercise provides no basis to conclude that necessary resources to permit an orderly evacuation of the institutionalized mobility-impaired in the EPZ are available to LILCO or that LILCO personnel could effectively and appropriately use them in a way that does not endanger special facility residents. An orderly evacuation does not end when a vehicle crosses the imaginary 10 mile EPZ line. It must end at a location where the evacuees are safe and, in the case of mobility-impaired institutionalized individuals, provided with necessary care and treatment. Because the Exercise failed to i
demonstrate any capability of achieving that goal for special facility residents, there is no basis to suggest that the Exercise results could support a conclusion that objective FIELD 13 was satisfied.
CONTENTION EX 22.A Q. Please state Contention Ex 22.A.
A. The Contention states as follows:
The exercise scenario and the activities, reports, and events which occurred during the exercise include or are premised upon certain assumptions, enumerated below, which conflict with established facts, uncontroverted evidence, and ASLB findings. Accordingly, FEMA's findings and conclusions identified in subparts A-K below, which incorporate or are based upon such false assumptions, are without basis and invalid, and cannot support a finding of reasonable assurance that the LILCO Plan can be implemented as required by 10 CFR S 50.47(a)(2). Thus, the exercise precludes a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham emergency as required by 10 CFR S 50.47 (a)(1), and, accordingly, the LILCO Plan is fundamentally flawed.
A. In the LILCO Plan, the Nassau
> Veterans Memorial Coliseum is identified as the only " reception center" for evacuees other t than those with special needs. Thus, under j the Plan, evacuees would be directed to report to the Coliseum for radiological monitoring and decontamination, registration, and direc-tion to facilities for sheltering. Plan at 4.2-1 thru 4.2-2; OPIP 4.2.3. The exercise scenario, and FEMA's conclusions on objectives EOC 16 and FIELD 9, 17, 19 and 21, are all
! based upon an assumption that the Nassau Veterans Memorial Coliseum is available for use by LILCO and the American Red Cross as a Reception Center for the registration and 4
radiological monitoring and decontamination of evacuees and vehicles pursuant to the LILCO Plan. That assumption is false. In fact, there is no valid agreement permitting the use of the Coliseum as set forth in the LILCO Plan. Nassau County has expressly refused to agree to, or permit, the use of Nassau County facilities as part of, or to implement, the LILCO Plan. See Nassau County Board of Super-visors Resolution No. 782B-1986, June 16, 1986. Since the basic underlying premise of FEMA's conclusions that objectives EOC 16 and FIELD 9, 17, 19 and 21 were met or partly met (see FEMA Report at 34, 58, 74 and 80) is factually and legally incorrect, those conclusions are without basis and are invalid.
Because the exercise and FEMA's conclusions were premised on the false assumption that the Nassau Coliseum would be available as a reception center, the results of the exercise preclude a finding of reasonable assurance that adequate protective measures can and will be taken. Accordingly, the LILCO Plan is fundamentally flawed.
Q. To you knowledge, is there any dispute as to the accuracy of the facts alleged in that Contention?
A. We understand that both FEMA and LILCO have admitted that activities during the Exercise, and FEMA's evaluation and conclusions concerning the results of the Exercise, were based on the assumption that the Nassau Veterans Memorial Coliseum was available for use by LILCO as a reception center for the registration, radiological monitoring, and decontamination of evacuees and vehicles.4 We also understand that there is no dispute concerning the Nassau County Board of Supervisors 4 See LILCO Admissions, No. 55, p. 13; FEMA Admissions, No.
73, p. 20.
Resolution, referenced in the Contention and Attachment 3 hereto, setting forth Nassau County's refusal to agree to, or permit, the use of Nassau County facilities to implement the LILCO Plan.
Q. The Contention refers to several particular exercise objectives in alleging that FEMA's conclusions are without basis and are invalid. Please state those objectives.
A. The objectives referenced in the Contention are EOC 16, FIELD 9, 17, 19 and 21. They are as follows:
EOC 16. Demonstrate the organizational ability to manage an orderly evacuation of all or part of the 10-mile EPZ including the water portion.
FIELD 9. Demonstrate a sample of resources necessary to implement an orderly evacuation of all or part of the 10-mile EPZ.
FIELD 17. Demonstrate the ability to mobilize, staff and activate the Reception l Center in a timely manner.
FIELD 19. Demonstrate through rosters the
- ability to maintain staffing at the Reception l Center on a 24-hour basis.
i l FIELD 21. Demonstrate the adequacy of procedures for registration, radiological monitoring, and decontamination of evacuees and vehicles including adequate provisions for handling contaminated waste at the Reception Center.
i 1 -- . - . - - -
Q. The contention alleges that the basic underlying premise of FEMA's conclusions relating to the objectives you just quoted is factually and legally incorrect and that therefore those conclusions are without basis and invalid. Do you agree with that allegation?
A. We cannot address whether FEMA's premise is legally incorrect. With that exception, however, we do agree with the allegation. With respect to objectives EOC 16 and FIELD 9, we agree for the reasons stated above on the subject of special facility evacuees. It cannot be said that an " orderly evacuation" can be accomplished or that such a capability has been demonstrated, if there is no facility available to be the end point of that evacuation. This is particularly true given LILCO's response to the hypothetical accident in the exercise scenario. During the Exercise, LILCO instructed approximately 95,000 individuals to go to the Nassau Coliseum Reception Center to be monitored because they may have been exposed to radiation during their simulated evaluation trips. Since in a real accident, evacuees could also be expressly instructed to report to a reception center where services would be performed necessary to protect their health, in the absence of a facility and the l
capability of performing those health-related services, there is no basis for a conclusion that an orderly evacuation would or could be implemented.
i .
Objectives FIELD 17, 19, and 21 each expressly refer to a
" Reception Center." Conclusions premised upon a nonexistent facility are not valid.
CONTENTION EX 49 Q. Please state Contention Ex 49 and Ex 31 which was subsumed therein.
A. Contention Ex 49 states as follows:
The exercise revealed a fundamental flaw in the LILCO Plan in that LILCO is incapable of performing necessary registration and radio-logical monitoring of evacuees within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as required by NUREG 0654 S II.J.12. For the reasons set forth below, during the exercise LILCO demonstrated that it has insufficient staffing, and insufficient equipment, to perform the necessary registration, monitoring and decontamination of evacuees which is required to effect an evacuation and to comply with 10 CFR SS 50.47(b)(1), (b)(8), (b)(10).
Therefore, LILCO does not satisfy objective FIELD 21 and its Plan is fundamentally flawed since it has no capacity to handle satis-factorily the evacuees that may arrive after a Shoreham emergency.
A. Although the Plan asserts that LILCO personnel assigned to the reception center to perform radiological monitoring will monitor one evacuee every ninety seconds (OPIP 3.9.2 l 5 5.4.7), in fact during the exercise this I procedure frequently took up to five minutea per evacuee. At that actual monitoring rate, the 78 monitors assigned to the reception center in the Plan could monitor only 11,232 evacuees in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (assuming no breaks, and assuming all monitors were constantly avail-able and monitoring). This is far less than the 32,000 evacuees which LILCO used to j believe might be directed to the Coliseum and i demonstrates the fundamental flaw in LILCO's l planning for evacuees needing monitoring and t
I I
a O decontamination. In fact, during the exer-cise, LILCO in simulated EBS messages advised over 100,000 evacuees (i.e., all those in zones A, B, F, G, K, and Q) to report to the Nassau Coliseum for radiological monitoring because they had been potentially exposed to radiation during their simulated evacuation trips. Clearly, under the LILCO Plan, even assuming that no persons other than those advised to do so by LILCO actually report to the reception center for monitoring and, if necessary, decontamination, such a number of anticipated evacuees could not be monitored in a timely fashion -- i.e., within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
B. Furthermore, the LILCO proposal to telephone INPO, other power plants, and other entities to obtain additional monitoring personnel, and the other features of the purported " alternate" monitoring plan in OPIP 4.2.3, S 5.11, were not implemented or demonstrated during the exercise. Such entities did not participate in the exercise nor was there any demonstration of the capability of those entities either to provide the personnel or equipment which LILCO players pretended would be available, or to provide them in a timely manner. In addition, FEMA did not evaluate the adequacy or implementability of any such proposals during the exercise. See FEMA Report at 81. Thus, the exercise provides no basis to find that such proposals could be implemented, or, even if they could, that they would result in an ability to perform the necessary monitoring of the number of evacuees anticipated to report to the reception center.
C. There is no basis to assume that only those persons expressly advised by LERO to report to the reception center for moni-toring because of potential exposure during evacuation activities would actually seek such monitoring. Indeed, upon hearing that all residents of so many zones had potentially been exposed, and in light of the large amount of voluntary evacuation likely to occur for the reasons set forth in Contention Ex 44, substantially more people than the number expressly advised to report would be likely to seek such monitoring. Thus, the LILCO response would, in fact, be even more deficient than was demonstrated during the exercise.
3- e For the foregoing reasons, the LILCO Plan fails to comply with 10 CFR S 50.47(b)(1),
(b)(8), (b)(10) and NUREG 0654 S II.J.12. The exercise thus precludes a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham emergency, as required by 10 CFR f 50.47(a)(1).
Contention Ex 31 which was-subsumed as part of Subpart A of Contention Ex 49 states:
The Reception Center ARCA refers to the fact that it took LERO personnel four to five minutes to monitor an individual evacuee, as opposed tc 90 seconds as presumed in OPIP 3.9.2 S 5.4.7. FEMA Report at 81. According to the LILCO Plan, 78 monitors are expected to o perform the radiological monitoring of all evacuees who report to the Reception Center.
OPIP 4.2.3 S 5.5.1. During the exercise approximately 100,000 persons were advised in simulated EBS messages to report to the Coliseum for monitoring. At the. rate of 4 minutes per evacuee the 78 monitors would need approximately 85 hours9.837963e-4 days <br />0.0236 hours <br />1.405423e-4 weeks <br />3.23425e-5 months <br /> to perform the monitoring required by NUREG 0654 S II.J.12.
Thus, this deficiency precludes a finding that LILCO has sufficient staff to respond as required by 10 CFR S 50.47(b)(1). It also precludes a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham accident.
Q. Do you agree with Contentions Ex 49 and Ex 31?
A. We do. We understand, however, that the substance of
(
subpart C of Contention Ex 49 will be discussed in a separate piece of testimony.
l l
I i
-t. o Q. Please describe in general the procedure contained in the LILCO Plan as exercised for the registration and radiological monitoring of evacuees at the reception center for the general public.
A. The procedure in Revision 6 of the Plan which was exercised assumed the availability of the Nassau Coliseum. Many of the details of the procedure no longer make any sense in the absence of the facility. Setting that aside, however, the procedure in general is that trailers containing monitoring equipment and supplies would be brought from LILCO's Garden City Substation to the Reception Center. Then, 120 LILCO personnel would be divided into groups to perform personnel monitoring, personnel decontamination, vehicle monitoring and vehicle decer' amination.
Evacuees would be monitored by 78 monitors. Each evacuee would be monitored for external contamination and for thyroid contamination. The monitoring process is expected to take approximately 90 seconds per evacuee. If not contaminated, the evacuees would be given " clean tags" and sent to recordkeepers who would fill out " log out forms," before the evacuees are either sent to a shelter location or allowed to leave. If they are found to be contaminated, they would be expected to proceed
't a to a decontamination area where LILCO workers would perform washing, showering, re-monitoring, and other related activities.
OPIPs 4.2.3, 3.9.2 (Rev. 6).
Q. Subpart A of Contention Ex 49 and Contention 31 which was subsumed therein allege that during the exercise the radiological monitoring process frequently took up to five minutes per evacuee. What is the basis for that allegation?
A. The FEMA Report states:
On several occasions personnel radiological monitoring took approximately four (4) to five (5) minutes per individual, which is con-siderably longer than the ninety (90) seconds !
specified in the LERO procedures. A large number of evacuees could result in a signifi-cant queue of individuals waiting to be moni-tored.
FEMA Report at 80. In the Report FEMA identified this subject as an " Area Requiring Corrective Action" (ARCA) in light of the requirement in NUREG 0654, S II.J.12, and recommended that "(alll monitoring personnel assigned to the Reception Center should be trained to monitor individuals within ninety (90) seconds as prescribed in the LERO Procedures." Id. at 81.
We understand that this FEMA conclusion was based upon FEMA evaluators' actual observations of LERO personnel performing radiological monitoring at the Coliseum during the Exercise, and the conclusion of the FEMA Regional Assistance Chairman Mr.
Kowieski that "in every single case [ monitors] should have processed people in 90 seconds." Transcript of Deposition of l
Roger B. Kowieski (Jan. 29, 1987), p. 49-50. We have also reviewed the critique forms prepared by the two FEMA evaluators who were at the Coliseum reception center during the Exercise.
They reflect the evaluators' factual observations concerning the amount of time it took LERO monitors to perform the monitoring process. Copies of those forms are Attachment 5 hereto. Both FEMA evaluators independently noted that monitoring took too long. Thus, evaluator R. Bernacki stated:
Personnel monitoring was observed to take 4-5 4;
minutes per individual which is considerably longer than the 90 seconds called for in the procedures. If there were a large number of evacuees this could have resulted in a significant backup.
See Attachment 5, p. 1-2. And, evaluator L. Slagle observed:
s For this exercise, the times spent monitoring individuals were longer (4-6 minutes per per-son) than would be necessary to accommodate a very high influx of contaminated or potenti-ally contaminated persons.
- See Attachment 5, p. 3.
1 Q. Based upon the FEMA observations and conclusions stated
- in the FEMA Report, it appears that during the Exercise in at least some and perhaps many instances, the radiological i
t
monitoring was performed within the 90 second period prescribed in the LILCO procedure. Why does it matter that in several instances the procedure took 4-5 minutes?
A. The primary reason is the one stated in the Contention itself. The 90 second monitoring rate is essential if there is going to be any reasonable ability to process evacuees through the center in a timely manner. Even if one were to assume that only 32,000 evacuees were to arrive at the reception centers, it would take LILCO's 78 monitors 10.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> at 90 seconds per evacuee to monitor all 32,000 -- and this assumes no breaks at all. Clearly, if only some evacuees take more than 90 seconds and if reasonable breaks are assumed, LILCO could not meet the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> monitoring requirement contained in NUREG 0654. As we noted above, FEMA drew the same conclusion from the exercise results.
See FEMA Report at 80, and evaluator comments in Attachment 5 hereto.
Further, if there were an even larger number of evacuees --
such as the 95,000 which, during the Exercise, LILCO " advised" to report for monitoring -- the need to take 4-5 minutes even for some of those individuals would make the entire process even more unworkable. Significantly, even LILCO recognizes in its procedure that "(a]t the evacuee Reception Center, it is important to monitor all arriving evacuees as soon as possible."
OPIP 3.9.2, S 5.2.8. Further, FEMA also stated that based on its
.x ,
evaluation of LILCO's performance during the Exercise, " FEMA i
infers that there were not, sufficient personnel to handle evacuees in excess of 32,000~. . . .
" FEMA Amended Admissions, Admission No. 148, p. 7. ,.,
Q. Is your concern limited to the total ~ amount of time . ,
' ~
that would be required to process all the evacuees who arrived seeking monitoring?
A. That is definitely one prob?.em which would be created by the individual monitoring processes'taking longer than 90 seconds. The mathematical result of that, as noted above,, i s' easily calculable. Given the number of reonitors assigned by LILCO to the Reception Center under Revision 6 of the Plan --
i.e., 78 -- it would not be possible to monitor even 32,000 evacuees within the 12-hour period mandated by NUREG 0,654.
! In addition, however, the prospect of having tens of 9
thousands of persons in line to be monitored for long periods of time also gives rise to other significant concerns. For example, I contamination could easily be spread, particularly by children I
and others who may not know that they should not touch persons or things prior to being monitored, or may be unable to refrain from i
doing so. People will need to eat, use restrooms, and use other ,
facilities, and if there are long periods of time before they are l
l monitored, contamination would be spread through that means as l
waw w *~r veme,g-----gr,_ .- ,_ ~,- ,,__ ,___ , _
y ._ ... . . . - _ . --.
.- __. _- .=. - . . ..- ..
o , .
1
(! ,
m 1 Furthermore, anxiety levels among evacuees will be
- 1,
- well.
1, .
it, y extremely high upon their arrival at a reception center, ;
j, / "particularly if they have been instructed to report for i monitoring because they may have been exposed to radiation during their evacuation,'as occurred during the Exercise. They will be r
,hupgry,1t_ ired > and in some instances, separated from their i families. Anxiety levels will rise even more -- and potentially 1
- to the point of panic -- if individuals are forced to wait for
( e long' periods of time before they are monitored. This would be
- i. -.
((
particularly likely if they perceived that delays in processing I are a result of either incompetence on the part of the monitors, or the discovery of contamination upon other evacuees. If
- , persons standing in line see that for some individuals the h monitoring process takes longer than for others, it would be logical for 6 hem to reach both conclusions. Thus, an inability-
- s J 'to kecp the processing lines moving quickly and efficiently would, in our opinion, increase fear and anxiety levels to a 4
i -
point where they could become dangerous.
! - Q. Dusing discovery depositions LILCO witnesses have i
! asserted that during a real accident, and if there were really i
, thousands of: evacuees in line to be monitored, the LILCO monitors would perform their jobs faster than they did during the
- ' Exercise. 'They have also asserted that during the Exercise, monitors took longer than 90 seconds because they were trying to i
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impress the FEMA evaluators, because there was no pressure from a large. number of expectant evacuees, and because they were trying-to fill up the time during the Exercise. Do you agree?
A. We have no basis for agreeing with those assertions.
They all appear highly speculative. We can say this about them, J
i however. If the pressure of knowing there has been a real
,yx radiological accident, or the " pressure" caused by knowing there are thousands of individuals in line demanding to be monftored, made LILCO monitors go faster, we would'be very concerned about the accuracy and adequacy of the monitoring. If anything, knowing that people really were potentially contaminated should make monitors be more careful, and take longer, rather than causing them to speed up. Further, while knowing that a large volume of people require services may, on an abstract level,
- encourage efficiency, given the seriousness of the job to be performed by monitors, and the potential consequences of
- mistakes, we would be very concerned if the procdss were speeded up, particularly since there is no " quality control" element in LILCO's monitoring proposal, an( individual citizens, not having radiological monitoring aq
- 32 -t themselves, have no way of knowing if they have been exposed or contaminated except' through the LILCO monitors.
49 -
Q. Subpart B of Contention Ex 47 refers to a so-called
" alternate" monitoring plan in LILCO Procedure OPIP 4.2.3, S 5.11. To what does this refer?
A. The referenced procedure describes a monitoring scheme which is completely different from that which was demonstrated during the Exercise. Thus, contrary to the scheme described 5bove, which has LILCO monitors inside the reception center doing a complete body and thyroid scan of each evacuee, S 5.11 of OPIP 4.2.3 proposes to have monitors in the parking lots who would scan only the hands and thyroid of vehicle drivers.
Q. Subpart B alleges that the " alternate" monitoring plan i
was not implemented or demonstrated during the Exercise. What is the basis for that allegation?
A. FEMA stated in its Report that "the alternate evacuee monitoring plan for the Reception Center was not evaluated at this exercise." FEMA Report at 81. In addition, although th'ere were apparently telephone calls during the Exercise to the Institute for Nuclear Power Operations (INPO) and simulated calls to other organizations to request additional monitoring personnel, we understand that none of these entities participated in the Exercise or actually provided any personnel. See LILCO Admissions, No. 199, p. 42; FEMA Admissions, No. 154, p. 40.
i Therefore, the Exercise provides no basis to determine whether i
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4 additional personnel would in fact be available from such organizations or that they could get to a LILCO reception center in a timely manner during a Shoreham accident.
Q. Please summarize your conclusions concerning Conten-tions Ex 49 and Ex 31.
A. Because the Exercise involved a facility which is no longer available to LILCO and therefore would not be the facility actually used in a real emergency, and because the Exercise failed to include any demonstration of LILCO's ability to cope with, much less adequately monitor, register and decontaminate, the large numbers of individuals that must be expected at a reception center, the Exercise cannot provide the basis to conclude that the regulatory requirements for providing radiological monitoring services have been met. The Exercise also provides no basis to conclude that Exercise objective FIELD 21 was met or even partly met, since the Exercise failed to provide data concerning LILCO's ability to provide services for the number of people it itself advised to report to the reception center during the Exercise. Finally, since on several occasions during the Exercise LILCO monitors were not able to perform their monitoring function in the amount of time proscribed by their own procedure, there is no basis to conclude that they could do so in an actual emergency when tens of thousands of evacuees could be
- in need of such monitoring.
Q. Does that conclude your testimony?
A. Yes it does.
4
ATTACHMENTS Attachment 1 Curriculum Vitae of David Harris Attachment 2 Curriculum Vitae of Martin D. Mayer-Attachment 3 Letter from Joan Portnoy, Administrator, Oak Hollow Nursing Center, to Charles A.
Gentile, LILCO, dated September 2, 1986 Attachment 4 Nassau County Board of Supervisors Resolution No. 782B-1986, dated June 16, 1986 Attachment 5 Exercise Evaluation Critique Form of Evaluator R. Bernacki for Objective Field 21 and Exercise Evaluation Critiq'ue Form of Evaluator L. Slagle for Objective Field 21
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ATTACHMENT ~1
,- CURRICULUM VITAE NAME & ADDRESS: David llarris Date of Birth: June 3,1932 438 Woodbury Road lluntington, N.Y.11743 Telephone Home:(516) 367-922G Office: (516) 348-2700
- EDUCATION: Cornell University, Ithaca, New York 1949-1952 - No degree New York University School of Medicine 1952-1956 - M.D. degree Columbia University School of Public Health & Administrative Medicine 1964-1965 - M.P.H. degree SPECIALTY CERTIFICATIONS: American Board of Pediatrics - December 1961 American Board of Preventive Medicine - June 1969 MEDICAL LICENSE: New York,1957 (#80968)
! POSITIONS HELD: Commissioner of Health Services Suffolk County, New York March 1977 - Present The Suffolk County Department of Health Services is a unified health l agency comprised of all governmental health services for Suffolk's 1.3 million population. The Commissioner of Health Services directs a staff 4
of more than 1300 and is responsible for a budget in excess of $60,000,000. i The Department, formed as a "superagency" in 1973 by combining previously existing separate departments, provides classical public health activities, patient care services (including a network of 8 ambulatory care centers
( delivering 250,000 patient visits a year and a 215 bed skilled nursing facility)
I mental health and mental retardation services, alcoholism and substance abuse services, environmental health services, emergency medical services, an AMA accredited Jail Health Service, the Office of the Chief Medical Examiner and the forensic sciences and public health laboratories. The Commissioner of Ilealth Services coordinates and directs all these activitics, is Chairman of the Board of Health and reports directly to the County Executive, the chief elected official of Suffolk County.
n Deputy Commissioner of Ilealth Services
! Suffolk County, New York August 1975 - February 1977 Associate Director, The Mount Sinal llospital 100 Street & Fifth Avenue, New York July 1971 - August 1975 The Associate Director of The Mount Sinal Hospital, one of the oldest and largest teaching hospitals in the nation, reported directly to the Director of the llospital and was in effect the Chief Operating Officer for all professional services, including clinical medical departments, nursing, social services, volunteer services and the $16,000,000 affiliation contract for professional services at Elmhurst City llospital.
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Deputy Commissioner New York City Department of IIcalth July 1969 - July 1971 The New York City liealth Department, at the time of my association with it, employed more than 4,000 individuals ant had a budget of approximately $100,000,000. The Deputy Commissioner of IIcelth was responsible for the direction of major professional programs, including maternal and child health, public health laboratories, the control of chronic and communicable diseases, nutrition and nursing services.
Assistant Commissioner, Maternal & Child Health Services New York City Department of Health July 1967 - June 1969 Director, Bureau of Handicapped Children New York City Department of Health June 1965 - July 1967 ACADEMIC APPOINTMENTS Professor of Clinical Community & Preventive Medicine State University of New York at Stony Brook 1975 - Present Professor of Clinical Pediatrics State University of New York at Stony Brook 1981 - Present Lecturer in Public Ilealth Columbia University School of Public IIcalth July 1972 - Present Adjunct Professor New School for Social Research 1978 - Present Adjunct Professor C. W. Post Center of Long Island University 1978 - Present Associate Professor of Administrative Medicine The Mount Sinai School of Medicine July 1971 - August 1975 l
Assistant Professor of Pediatrics The Mount Sinai School of Medicine July 1971 - August 1975 Adjunct Assistant Professor, Public IIcalth Practices Columbia University School of Public 11ealth &
Administrative Medicine July 1971 - June 1972 Assistant Clinical Professor of Pediatrics Albert Einstein College of Medicine July 1967 - July 1971 Clinical Instructor in Pediatrics Albert Einstein College of Medicine
' June 1965 - July 1967 4- -
6 INTERNSHIP & Straight Pediatric Internship RESIDENCY TitAINING: University llospitals of Cleveland Cleveland, Ohio July 1957 - July 1957 Pediatric Residency United States Naval Hospital Bethesda, Maryland July 1958 - August 1960 Public Health Residency New York City Department of Health
- December 1963 - December 1966 MILITARY SERVICE: United States Navy (Medical Corps)
July 1957 - July 1964 Rank: Lieutenant Commander PROFESSIONAL SOCIETIES: Fellow, American College of Preventive Medicine Fellow, American Academy of Pediatrics Fellow, American Public llealth Association Fellow, New York Academy of Medicine HONOR SOCIETIES: Phi Beta Kappa, Cornell University,1952 Alpha Omega Alpha, New York University School of Medicine,1956 AWARDS: llealth Care Administration Award for Excellence in Management, Leadership and Public Service - C. W. Post College - 1979 Certificate of Merit, Long Island Region New York State Public Health Association -1981 Environmentalist of the Year Sierra Club, Long Island Chapter,1984 OTIIER PROFESSIONAL ACTIVITIES & OFFICES: Medical & llealth Research Association of New York City,Inc.
Member, Board of Directors,1975 - Present New York State Advisory Council on Substance Abuse 1978 - Present New York State Mental flygiene Planning Council 1982 - Present New York State Advisory Council on Mental Retardation and Developmental Disabilities Advisory Council,1985 - Present C. W. Post Center of Long Island University Advisory Board,1978 - Present New School for Social Research Advisory Committee,1981 - Present New York State Public flealth Association President, 1981 - 1983
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OTilER PROFESSIONAL Nr.w Yerk Acidsmy cf MIdicina ACTIVITIES & OFFICES: Committee on Public Ilealth, Vice-Chairman,1985 Committee on Public Health, Member,1972 - Present Committee on Medical Education, 1969 - 1971 Secretary, Pediatric Section,1970 American Public liealth Association Governing Council, 1973 - 1975 and 1983 - Present Editorial Advisory Board, The Nation's llealth, 1971 - 1976 Editor, Maternal & Child Health Section Newsletter,1968 - 1971 Consultant, Professional Examination Service in the field of Maternal & Child Health -
American College of Preventive Medicine Secretary-Treasurer, 1976 - 1978 Board of Regents,1985 - Present New York State Commission on liealth Education & Illness Prevention, 1978 - 1981 Columbia University School of Public Ilealth Alumni Association President, 1979 - 1980 Adelphi University School of Business Administration Advisory Board, 1977 - 1978 American Academy of Pediatrics Vice-Chairman, District II, Chapter 3,1970 - 1971 Chairman, District II, Chapter 3,1971 - 1972 White flouse Conference on Children Consultant,1970 New York State Council on Health Care Financing Member, Technical Advisory Group,1982 National Foundation - March of Dimes, Greater New York Chapter, Executive Committee, 1972 - 1975 Chairman, Professional Advisory Committee, 1972 - 1975 Citizens Committee for Children Consultant, 1974 - 1975 The flermann Biggs Society Executive Committee, 1974 - 1975 Public flealth Association of New York City Board of Directors, 1972 -1975 Planned Parenthood of New York City Medical Advisory Committee, 1969 - 1974 Mayor's Task Force on Child Abuse (New York City 1969 - 1975 Visitation Committee, New York City, Juvenile Centers 1971 - 1972 4.
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OTilER PROFESSIONAL ACTIVITIES & OFFICES: New York Service for Orthopedically llandicapped Professional Advisory Committee,.1966 - 1971 Project liead Start (New York City), Medical Advisory Committee 1969 Joint Legislative Committee on Child Care Needs of the State of New York Advisory Council,1969 Mayor's Committee on Retardation (New York City) 1966 - 1968 Task Group on Transportation of Radioactive Materials in Urban Environs 1976 - 1980 American Lung Association of Nassau-Suffolk ,,
Board of Directors,1985 - Present SCIENTIFIC PAPERS &
PUBLICATIONS Ilarris, David and Cone, Thomas E. "Escherichia Freundii Meningitis",
Journal of Pediatrics, Vol. 56, No. 6, pp. 774-777, June 1960.
Harris, David; Pearson, Howard A. and Avery, Gordon B. " Total Body Irradiation", Proc. Children's Hospital of D.C., Vol. XVil, No. 6, pp.145-146, June 1961.
Boles, Lawrence R., and liarris, David. "Nasopharyngeal Dermoid of the Newborn", Laryngoscope, Vol. LXXV, No. 5, pp. 763-767, May 1965.
The Modern Medical Encyclopedia. Western Publishing Co., New York, Special Consultant Editor,1965 The Modern Medical Encyclopedia of Infant-Child Care. Western Publishing Co., New York, Associate Editor,1966 liarris, David, "The Development of Nurse-Midwifery in New York City",
Bulletin, American College of Nurse Midwifery, Vol. XIV, pp. 4-12, February, 1969.
Blackman, Norman S.; Blumenthal, Sol; Brownell, Katherine D.; Wolfson, Jean and liarris, David. " Cardiac Screening by Computerized Auscultation",
American Journal of Public flealth, Vol. 59, No. 7, pp,1177-1187, July 1969.
i O'llare, Donne and liarris, David. "The Impact of Medicaid on llandicapped Children", presented at the American Public flealth Association's Annual Meeting,1969.
Mayer, Shirley A.; Grossi, Margaret and liarris, David. " Epidemiology of Burns in Children", presented at the American Public Ilealth Association's Annual Meeting,1970.
Harris, David. " Utilization of Nurse Specialist: The Viewpoint of a Public Ilealth Physician", presented at the American Public Ilealth Association's Annual Meeting,1970.
liarris, David; Daily, Edwin and Lang, Dorothea. " Nurse-Midwifery in New York City", American Journal of Public Ilealth, Vol. 61, No.1, pp.
64-77, January 1971
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SCIENTIFIC PAPERS &
PUBLICATIONS Bergner, Lawrence; Mayer, Shirley A., and liarris, David. " Falls from lleights: A Childhood Epidemic in Urban Areas", American Journal of Public IIcalth, Vol. 61, No.1, pp. 90-96, January 1971.
Ilarris, David. " Current Problems in Maternal and Child liculth", New Jersey Public IIcalth News, Vol. 52, No.1, pp.5-lo, January 1971.
Pakter, Jean; liarris, David and Nelson, Frieda. " Surveillance of the Abortion Program in New York City: Preliminary Report", Clinical Obstetrics and Gynecology, Vol.14, No.1, pp. 262-291, March 1971.
Pakter, Jean; llarris, David and Nelson, Frieda. " Abortion in New York City: The First Six Months", presented at the Annual Meeting of the Population Association of America, April 24,1971.
liarris, David. " Developing Urban llealth Services for Mothers and Children", presented at the Second Annual Maternal and Child llealth Colloquium, The University of Michigan, School of Public ilcalth, Ann Arbor, Michigan, April 30,1971.
Pakter, Jean; Fiarris, David and Nelson, Frieda. " Surveillance of the Abortion Program in New York City", Bulletin of the New York Academy of Medicine, Vol. 47, No. 8, pp. 853-874, August 1971.
Lane, Michael F.; Barbarite, Robert V.; Bergner, Lawrence and Harris, David. " Child Resistant Medicine Containers: Experience in the llome",
American Journal of Public Ilealth, Vol. 61, No. 9, pp.1861-1868, September 1971.
Calafiore, Dorothy C.; Cohen, Arlan A.; llayes, Cer! G.; Lowrimore, Gene R.; Ireson, Robert G'.; liarris, David; Camp, Maurice; Morrow, Sahar and Peacock, Peter B. " Acute Respiratory Disease Risk and Urban Air Pollution", presented at the American Public flealth Association's Annual Meeting,1971.
liarris, David; O' Hare, Donna; Pakter, Jean and Nelson, Frieda. " Legal Abortion 1970-1971: The New York City Experience", American Journal of Public Ilealth, Vol. 63, No. 5, pp. 400-481, May 1973.
Harris, David; imperato, Pascal and Oken, Barry. " Dog Bites: An Unrecognized Epidemic", presented at The American Medical Association's Annual Meeting, June 25,1974.
- liarris, David; imperato, Pascal and Oken, Barry. " Dog Bites in New York City", presented at the Urban Annual Symposium, University of Texas, School of Public Ilealth, September 26,1974.
Ilarris, David; Imperato, Pascal and Oken, Barry. " Dog Bites: An Unrecognized Epidemic", Bulletin of the New York Academy of Medicine.
Vol. 50, No. 9, pp. 981-1000, October 1974.
Ilarris, David. "licalth Services for Women", presented at Seminar on Women's llealth issues, Suffolk County Community College, October 1975.
liarris, David and McLaughlin, Mary C. " Integrating Alcohol, Drug Abuse and Mental llealth at the Point of Services", presented at The New York Council on Alcoholism, Inc., Conference on Coordination of Services, Guidelines for National llealth Insurance as it Affects Services, December 1975.
SCIENTIFIC PAPEltS &
PUBLICATIONS McLaughlin, Mary C. and llurris, David. "The Single llealth Agency ...
A Viable Concept", New York State Journal of Medicine, Vol. 77, No.
7, June 1977.
Ilarris, David; Nicols, Joseph J.; Stark, Renee and 11111, Kenneth. "The Dental Working Environment and the Risk of Mercury Exposure: A Case Report and a Survey", presented at the American Public Health Association Annual Meeting, October 21,1976.
Zaki, Mahfouz H.; Miller, George S.; Sheppard, Robert J.; Harris, David and McLaughlin, Mary C. "An Extensive Salmonella Typhimurium Outbreak Probably Waterbourne", presented at The American Public Health Association Annual Meeting, October 21, 1976. American Waterworks Association Journal.
Harris, David. " Prevention as a Public Health Policy", Nassau County Medical Center Proceedings, Vol. 5, November 2,1978.
Harris, David; Nicols, Joseph J.; Stark, Renee and Hill, Kenneth. "The Dental Working Environment and the Risk of Mercury Exposure", Journal of the American Dental Association, Vol. 97, November 1978.
Kim, S.; Guirgis, S.; llarris, D.; Keelan, T.; Mayer, M., and Zaki, M. "Q Fever - New York", Morbidity and Mortality Weekly Report 8, Vol. 27, No. 35, pp. 321-322, September 1,1978.
Zaki, Mahfouz II.; Harris, David, and Moran, Dennis. " Trace Organics in Drinking Water: An Emerging Public Health Problem", presented at the American Public Health Association Annual Meeting, November 6, 1979.
liarris, David. "If Children Benefit So Much From Prevention, Why Aren't We Doing More Of it?", presented at the 26th Annual Meeting of the American College of Preventive Medicine, the 36th Annual Meeting of the Association of Teachers of Preventive Medicine and the IU7th Annual Meeting of the American Public Health Association (jointly held) November 4, 1979.
Rugg, Victor; McLauglin, Christopher; Bruno, Daniel and llarris, David.
"Self-Ilelp Professional Collaborative Groups with Methadone Maintenance i
Patients", presented at the New York State Drug Conference, March 25.
1981.
liarris, David. "The Genetic Revolution - A Social and Ethical Challenge",
presented at the Conference on Medical Genetics for the Practitioner.
Stony Brook, April 8,1981.
Ilarris, David; Vann, Albert and Wrightson, Karolyn. "Toward a llcalthy State: The Report of the State Commission on llealth Education and Illness Prevention", New York State Journal of Medicine, Vol. 81, No.
12, pp.1798-1801, November 1981.
liarris, David. "The Public ilcalth Officer's Res'ponse to Environmental Crises", presented at the joint meeting of the American College of
! Preventive Medicine and the Association of Teachers of Preventive Medicine, November 15,1982.
SCIENTIFIC PAPEl(S &
PU BLIC ATIONS_ Zaki, Mahfouz 11.; Moran, Dennis and llarris, David. " Pesticides in Groundwater The Aldicarb Story in Suffolk County", American Journal of Public Ilealth.
December 1982.
Ilarris, David; Baird, Greg; Clyburn, Steven A., and Mara, Joy 11.
" Developing a Teenage Pregnancy Program the Community Will Accept",
llealth Education, pp.17-20, May/ June 1983.
Harris, David. "llealth Department: Enemy or Champion of the People?"
Editorial. American Journal of Public Health, May 1984, Vol. 74, No. 5.
Ilarris, David. "The llealth Officer's Response to Citizen Action for Environmental Public Ilealth", presented at the Second Annual National Preventive Medicine Meeting, March 30, 1985.
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,' ATTACHMENT 2 4
j CURRICULUM VITAE MARTIN DAVID MAYER, M.D., M.P.H.
l ADDRESS: 96 Village Lane Hauppauge, New York 11787 HOME PHONE: (516) 979-7472 BIRTHDATE: January 9, 1941 BIRTHPLACE: Brooklyn, New York i
4 MARITAL STATUS: Married, June 1968
- WIFE
- Ellen, D.O.B., April 11, 1945 ,
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DAUGHTER: Erica, D.O.B., September 26, 1970 SOCIAL SECURITY 9: 069-32-0533 i
DRAFT STATUS: 4A (Retired, U.S. Public Health Service)
PRESENT POSITION: (as of September,1972) i Deputy Director of Public Health Suffolk County Department of Health Services Division of Public Health 225 Rabro Drive East l Hauppauge, New York 11788 Business Telephone: (516) 348-2757
, EDUCATION:
- Graduated June, 1957 i 2. City College of New York, New York, New York September 1957 to January, 1962 Received BChE Degree, January, 1962 i
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- O Curriculum Vitae Martin David Mayer, M.D., M.P.H.
Page 2 PROFESSIONAL EDUCATION:
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- 1. State University of New York, Upstate Medical Center Medical School, Syracuse, New York; September, 1965 to June,1969; Received M.D. , cum Laude, June,1969
- 2. Kings County Hospital, Brooklyn, New York; Straight l Pathology Internship, July, 1969 thru June, 1970
August, 1972 LICENSURE:
New York State, Physician License MD106724, August 5, 1970 i
Diplomat, National Board of Medical Examiners, Cert. No. 102795, July, 1970 HONORS:
- 1. Winner, competitive New York State Regents Scholorship, 1957-1961 j
- 2. Elected to Tau Beta Pi, National Engineering Honor Society (1960)
- 3. Elected to Omega Chi Epsilon, National Chemical Engineering
! Honor Society (1961) 1
- 4. Elected to Alpha Omega Alpha, National Medical Honor Society (1968)
ACADEMIC APPOINTMENTS:
Clinical Assistant Professor, Department of Community and Preventive Medicine, Health Sciences Center, State University of New York at Stony Brook.
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I Curriculum Vitae Martin David Mayer, M.D., M.P.H.
Page 3 EMPLOYMENT: ,
- 1. August / 1970 thru August, 1971 - Resident Physician in the New York State Department of Health Residency Program in Public Health and Preventive Medicine; assigned to Westchester County Health Department, White Plains, New Yor) ,
- 2. Summer 1966, Summer 1967, Summer 1968 - Assistant Sanitary l
Engineer, Division of Air Pollution, New York State Department of Health, 84 Holland Avenue, Albany, New York
- 3. July, 1963 thru July, 1965 - Senior Assistant Sanitary Engineer, United States Public Health Service, Robert A. Taf t Sanitary Engineering Center, Cincinnati, Ohio j 4. February, 1962 thru Jhnuary, 1963 - Assistant Process Engineer, ESSO Research and Development Corporation, Florham Park, New Jersey PUBLICATIONS:
Martin Mayer, A Compilation of Air Pollution Emission for Combustin Processes, Gasoline Evaporation, and Selected Processes U.S. Department of Health, Education and Welfare, Public Health Service, National Center for Air Pollution control, May,1965
REFERENCES:
References will be supplied on request.
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OAK HOLLOW NURSING CENTEI r
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S'eptember 2, 1986 Charles A. Gentile '
tadiation Protection Section LILCO 175 E. Old Country Road Hicksville, NY 11801
Dear Mr. Gentile:
In reference to the evacuajien transportation agreement signed between Oak Hollow Nursing Center and Crest Hall HRF 11/27/84, we feel that we were premature in consummating this agreement.
We hereby rescind said agreement until such time as the Shoreham plant receives its operating license.
Very truly yours, n
A k F Joan Portnoy Administrator JP/vt e
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ATTACHt1ENT 4 lsNIIE c U 27 P2 m MSOLUTICW No. 7823-1916 rn t r, 80ca:ti..Alchl'*O H
A MSOLUTION AMENDING A MSCLUTION ENTITLED: *A RESOLUTION MLATIVE TO TEE USE OF TEI NASSAU VETERANS MEMORIAL COLISEt:M IN A LONG ISLAND LIGITING COMPANY'S EVACUATION PLAN.*
(Fessed by Board of Supervisers as A8't 1g g Yates for 104 3* votes asataat. scr5 . Seeams a resoluttee se *Apot 1g g eith the approval of the Astias County Easou tve.)
WHEREAS, the Long Island Lighting Company has entered into an agreement with the Ryatt Management Corporation of New York, Inc., which purports to designate the Nassau Veterans Memorial Coliseum as a Nuclear Disaster Evacuation Center, and WHERZAS, the County Attorney of Nassau County has advise the Soard of Supervisors that the terms of the lease between Nassa County and the racility Management Corporation of New York, Inc.,
do not allow for such use of the Nassau Veterans Memorial Coliseur and now, therefore be it RESOLVED, that the purported designation of the Nassau Veterans Memorial Coliseum by the Long Island Lighting Company as a Nuclear Disaster Evacuation Center be and the same is hereby l
declared a nullity, contrary to law and voids and be it further
[
RESOLVED, that no Nassau County f acilities, including l
l the Nassau Veterans Memorial Coliseum, are or will be available for the use by the Long Island Lighting Company, or by the Tacti Hanagement Corporation of New York, Inc., as part of the Long j
!sland Lighting Company emergency plan, unless prior approval by resolution is first obtained from the Nassau County Board of Supe rvisors and be it further
- e gasoLVED, that a copy of this resolution shall be forth with served upon the Long Island Lighting Company and Facility Management of New York, Inc., formerly known as Myatt Management Corporation of New Yo'rk, Inc., and filed with notice of such service, vid the office of Nuclear Regulatory Coundesion at Washidgton D.C.: and be it further MSOLVED, that a copy of this resolution shall be forth with published in t.he official newspaper of the County of Nassau.
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STAU OF NEW YORK
, No.P 30097 COUNTY OF NASSA,U
- l. JOHN A. DeGRACE Clerk of the Board. Nassau County Boardof Supervusors. Jo hereby certufy that the foregoing is a true and correct copy of the original " Mi ' 115/ ~}/'a - ?lSA ~Nbb duly passed by the Board of Supervisors of Nassau County: hfew York. on f so- /!., / P N and approved by the County Esecutive on kusu /6, i?h-- . and on isle m my office and recorded sn the record of the proceedings of the Board of Superussors of the County of Nassau ana in the whole of said original.
IN WITNESS WHEREOF. I have hereunto :et my hand and affixed the officialseal of said Board of Supervisors, this N'W day of *r hu in the year one thousand nine hundred and i ~ ~4.
9 4. SLY# A.
JONA. DeGRACE aseene won Clerk of the Board ,
Nassau County Board of Supervssors l~
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- - EXERCISE EVAltJATION CRITIQUE FORM" ' - - - -
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, .. Other Field Activities Evalu. tor's ll.me: R. Bern.eki b
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unCISE OBJECTIVE AllD FOINTS _OF REVIEW EVALUA10lt(S) ASSICISIENT EDetENTS AND RECCIOtENDATIOllS U
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