ML20212D794
| ML20212D794 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/27/1987 |
| From: | Dormer R, Mcguire P, Eric Michel, Roberts C SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20212D439 | List: |
| References | |
| OL-5, NUDOCS 8703040206 | |
| Download: ML20212D794 (134) | |
Text
{{#Wiki_filter:g.- ca i .j u e u. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board t ) In the Matter of ) ~ ) LONG ISLAND LTGHTING COMPANY ) Docket No. 50-322-OL-5 ) (EP. Exercise) (Shoreham Nuclear Power Station, ) Unit 1) ) ) DIRECT TESTIMONY OF ASSISTANT CHIEF INSPECTOR RICHARD C. ROBERTS, INSPECTOR RICHARD DORMER, INSPECTOR PHILIP McGUIRE, and DEPUTY INSPECTOR EDWIN J. MICHEL ON BEHALF OF SUFFOLK COUNTY ) ) [ REGARDING CONTENTION EX 41 -- MOBILIZATION AND DISPATCH OF ROAD CREWS AND REMOVAL OF IMPEDIMENTS FROM THE ROADWAYS DURING THE FEBRUARY 13, 1986 SHOREHAM EXERCISE l l f l February 27, 1987 \\ l 8703040206 870227 PDR ADOCK 05000322 G PDR
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino 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 ASSISTANT CHIEF INSPECTOR RICHARD C.
- ROBERTS, INSPECTOR RICHARD DORMER, INSPECTOR PHILIP McGUIRE, AND DEPUTY INSPECTOR EDWIN J. MICHEL ON BEHALF OF SUFFOLK COUNTY REGARDING CONTENTION EX 41 -- MOBILIZATION AND DISPATCH OF ROAD CREWS AND REMOVAL OF IMPEDIMENTS FROM THE ROADWAYS DURING THE FEBRUARY 13, 1986 SHOREHAM EXERCISE I.
Introduction Q. Please state your names and occupations. A. My name is Richard C. Roberts. I am an Assistant Chief Inspector assigned to the Office of the Chief of Headquarters, County of Suffolk Police Department. My name is Richard Dormer. I am an Inspector assigned to the Office of the Chief of District, County of Suffolk Police Department. l I
c t O My name is Philip McGuire. I am the Executive Officer of the Office of the Chief Inspector, County of Suffolk Police Department. I hold the rank of Inspector in the Police Department. My name is Edwin J. Michel. I am the Commanding Officer of the Communications and Records Bureau, Headquarters Division, County of Suffolk Police Department. I hold the rank of Deputy Inspector in the Police Department. A summary discussion of our qualifications and professional backgrounds is included in our testimony regarding Contention Ex 40 -- Dispatch, Mobilization and Staffing of Traffic Control Posts during the February 13, 1986 Shoreham Exercise. Statements of our qualifications and experience also are attached to our Contention Ex 40 testimony. That testimony also explains the general organization and structure of the Suffolk County Police Department. We incorporate that prior testimony herein by reference. II. Purposes an( Conclusions Q. What is the purpose of this testimony? A. The purpose of this testimony is to address the matters raised in Contention Ex 41 (and the related matters in subpart I of Contention Ex 22 and Contentions Ex 25 and 29, which the Board r permitted to be considered in connection with Contention Ex 41) arising out of the Exercise of LILCO's Offsite Emergency Plan for Shoreham (the " Plan"), which was held on February 13, 1986 (hereafter, the " Exercise"). The testimony which follows is jointly sponsored by all of us. Q. Are you familiar with LILCO's Offsite Emergency Plan for Shoreham? A. Yes. As noted in our testimony regarding Contention Ex 40, except for Inspector Dormer, we all previously testified before the Atomic Safety and Licensing Board of the Nuclear Regulatory Commission which had jurisdiction over offsite emergency planning issues for Shoreham. To prepare that testimony, we reviewed, among other things, those portions of the LILCO Plan and its implementing procedures (sometimes hereafter "OPIPs") which dealt with the implementation of LILCO's traffic control strategies and techniques, including LILCO's proposals for deploying personnel, such as Traffic Guides, Road Crews, and Route Spotters throughout the EPZ. Since our earlier testimony, LILCO has changed certain aspects of its Plan and procedures. We have reviewed those changes which relate to LILCO's traffic control strategies and techniques. We also have attempted to gain an understanding of the events which took place during the February 13 Exercise -- for example, we have reviewed the conclusions and findings of
FEMA, which are based upon its observations and evaluations during the Exercise, as set forth in the Post Exercise Assessment l ' Report (what we call the " FEMA Report"). Q. What do you understand to have been the purpose of the February 13 Exercise for Shoreham? f 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 i consider FEMA's findings concerning the results of the Exercise i 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. l We understand that, in this proceeding, LILCO contends that the results of the February 13 Exercise demonstrate that its Plan can and will be implemented in the event of an accident at Shoreham, and that the NRC should use FEMA's findings about the results of that Exercise to conclude that there is reasonable assurance that the public can and will be protected in the event of such an accident. It is the position of Suffolk County, the State of New York and the Town of Southampton (the " Govern-l l l. _. -,
a ments"), however, that the results of the February 13 Exercise cannot be used to make the kind of affirmative finding desired by LILCO. Q. Based upon your review of the Exercise results which relate to the issues raised in Contention Ex 41, what have you concluded about LILCO's ability to implement effectively its Plan? A. The results of the Exercise demonstrate LILCO's inability to control and manage an orderly evacuation of the EPZ in accordance with the LILCO Plan, in that the Plan fails to provide -- and LILCO failed to demonstrate during the Exercise -- an ability to remove impediments from the roadways until long after evacuation had begun, if at all. To our knowledge, LILCO does not dispute that there will be accidents and other events creating blockages on evacuation routes during a Shoreham emergency. Sgg Cordaro gt al., ff. Tr. 6685, at 8. Therefore, LILCO must demonstrate that it is capable of dealing with such impediments. Under LILCO's Plan (and the l l evacuation time estimates relied upon by LILCO), it is assumed that LILCO has this capability. More specifically, the LILCO Plan assumes that evacuees will be able to, and will, follow the evacuation routes prescribed in the Plan, since the Plan further assumes that any impediments to evacuation that may arise will be removed -- efficiently and promptly -- by LILCO's Road Crews so l 1 1
that LILCO's prescribed routes remain open and available for use at full capacity during the entire evacuation process.
- Egg, e.g.,
Appendix A at IV-19 thru -23, V-1 thru -5, Table XII, and Fig. 8; OPIP 3.6.3. The February 13 Exercise, however, revealed that these LILCO assumptions are without basis. Indeed, not only did the Exercise demonstrate that LILCO's proposal for the removal of impediments is inherently unworkable, but it also showed that the LILCO personnel relied upon to remove such impediments are incapable of properly responding to, much less removing, impediments to evacuation. Thus, in our opinion, the results of the February 13 Exercise preclude finding that the protective action of evacuation, a major component of the LILCO Plan, can and will be effectively implemented in the event of a real Shoreham emergency. FEMA essentially agreed with us in its findings concerning the results of the Exercise. Thus, FEMA similarly found that LILCO's response to the two simulated evacuation impediments on the day of the Exercise was inadequate. In fact, FEMA identified l LILCO's response as a " Deficiency" (FEMA Report at 39), defined l by FEMA as follows: 1 a demonstrated and observed inadequacy that i would cause a finding that offsite emergency preparedness was not adequate to provide reasonable assurance that appropriate _
protective measures can be taken to protect the health and safety of the public. in the event of a radiological emergency. FEMA Report at 8. III. Contention Ex 41 Q. Please state Contention Ex 41. A. Contention Ex 41, except for subpart E, which will be discussed later in our testimony, states as follows: Contention Ex 41 [ Basis I of Ex 22 to be dealt with under Ex 41]. The exercise demonstrated a fundamental flaw in the LILCO Plan and in LILCO's ability to control and manage an orderly evacuation of the EPZ pur-suant to that Plan in that the Plan fails to provide -- and LILCO failed to demonstrate -- an ability to remove impediments from the roadways until long after evacuation had begun. There are likely to be accidents and other events creating blockages on evacuation routes during a Shoreham emergency. LILCO's inability to deal with such impediments will cause delay in the implementation of pro-tective actions and preclude LILCO from managing an orderly evacuation of the EPZ. Under the LILCO Plan and the evacuation time estimates used by the LILCO players during the exercise, it is assumed that evacuees will be able to, and will, follow the LILCO-prescribed evacuation routes, and that Road Crews will remove impediments efficiently so that the prescribed routes remain open and available for use at full capacity during the entire evacuation process.
- Egg, e.o., App. A at IV-19, -23, V-1 thru -5, Table XII, and Fig. 8; OPIP 3.6.3.
Not only did the exer-cise reveal that LILCO's proposal for the removal of impediments to evacuation is inherently unworkable, but it also demonstrated that the LERO players were incapable of properly responding to, much less " removing," the " impediments" created by !
FEMA's free play messages. For the reasons set forth in more detail below, the exercise results demonstrated fundamental flaws in LILCO's Plan, noncompliance with 10 CFR S 50.47(b)(10) and NUREG 0654 S II.J.10.k, and failure to satisfy exercise objectives, including EOC 5,.7, 8, 11, 16, 17, SA 1, 2, 5, 7, 8, 9, 10, and FIELD 9, 10. Thus, the exercise results preclude a finding that the protective action of evacuation can and will be implemented in the event of a Shoreham accident. EX 41.A. During the exercise and according to the LILCO Plan (Plan, Fig. 3.3.4; OPIP 3.3.2; OPIP 3.3.3; OPIP 3.6.3), the LERO Road Crews were not notified of the emergency or required to report to the staging areas until after the declaration of a Site Area Emergency. Such declaration was made at approximately 8:19. Even on February 13, when the LERO personnel were on notice that they would be called to report for duty, most Road Crew personnel did not arrive at the staging areas until well after 10:00. Thus, at 9:00, only one Road Crew member had reported to the Riverhead Staging Area (10 are required under the Plan), none had reported to Port Jefferson (14 are required under the Plan), and none had reported to Patchogue (14 are required under the Plan). At 9:40, after a General Emergency had been declared, only two had reported to Riverhead, none to Port Jefferson, and two to Patchogue. By 10:00, eight had reported to Riverhead, one to Port Jefferson, and five to Patchogue. And at 10:20 -- about the time of LILCO's EBS announcement advising evacuation -- still only 8 had reported to Riverhead, seven to Port Jefferson, and 10 to Patchogue. Thus, at the time a General Emergency was declared -- 9:39 -- only 10.5 percent of the Road Crew personnel essential to the implementation of the LILCO Plan were mobilized, even though the circumstances -- a pre-announced exercise -- were designed to maximize the likelihood of good LILCO performance. In fact, even at the time of LILCO's evacuation advisory, only about 65 percent of LILCO's Road Crew personnel were mobilized, even though the circumstances -- a pre-announced exercise -- were designed to maximize the likelihood of good LILCO performance. Thus, even assuming that no i member of the public attempted to evacuate - - - - -
prior to the evacuation order, at the time of that order the LERO personnel essential to the implementation of the recommendation according to the LILCO Plan were not even fully mobilized.1/ EX 41.B. [EX 25 and 29 to be dealt with under this suboart]. LILCO was incapable of re-l sponding as required to either of the two free play messages indicating existence of major road impediments, one involving a gravel truck and three cars, and the other involving a fuel i truck. Egg FEMA Report at 30, 36-38, 57-58, 65. For example, although FEMA's free play messages were injected at about 10:40 for the gravel truck accident and 11:00 for the fuel truck accident (FEMA Report at 36): j (1) The Evacuation Route Coordinator failed to advise the Evacuation Support Communicator for Route Spotters / Road Crews of pertinent facts, including that the gravel truck impediment was a multiple vehicle accident, that the fuel truck impediment involved the possibility of fire since fuel l was leaking, and that both shoulders of the road were blocked by the fuel truck. Such facts were required to be communicated under LILCO's Plan (ggg OPIP 3.6.3), and the consequence.of not doing so during the exercise was to delay substantially LILCO's response to the impediments (by approximately three hours for the fuel truck impediment). Egg FEMA Report at 30, 36-37, 57. 1/ Pursuant to OPIP 3.6.3, during the exercise the Road Crew personnel were not dispatched from the three staging areas until after the evacuation recommendation had been made to the public by simulated EBS message. The dispatch of Road Crew personnel began at Riverhead at about 10:47 and was completed at about 11:00; it began at about 10:46 at Port Jefferson and was completed at about 12:40 (with two Road Crews having to travel to .Brentwood to pick up their tow trucks); it began at about 10:45 l at Patchogue, and was completed at about 11:28. Subsequent to l their being dispatched, it took substantial time before crews were in a position to drive to an identified impediment in the field and attempt to remove it. Thus, for example, as noted in subpart B of this contention, a Road Crew to deal with the l simulated fuel truck impediment did not arrive at the impediment scene until about 2:10, three hours after it had been dispatched. FEMA Report at 37, 57-58. ---
(ii) The LERO Evacuation Coordinator, who is to be kept informed of any problems with implementing an evacuation of the EPZ, in-cluding impediments or suspected impediments (agg OPIP 3.6.3), was not informed of'either the gravel truck or the fuel truck impediment until after about 12:13, and even then it was FEMA, not any LERO personnel, which brought information regarding the impediments to the Evacuation Coordinator's attention. FEMA Report at 36. Only thereafter did the Evacuation Coordinator discuss LILCO's response to the impediments with his staff. Notwithstanding that FEMA-prompted discussion,
- however, (a)
As late as 12:40, the Transpor-tation Support Coordinator had not been in-formed that a bus evacuation route was poten-tially blocked by the gravel truck; (b) As late as 1:48, the Road Logistics Coordinator had not been informed that equipment needed to be sent to the site of the fuel truck accident (despite the fact I that the Evacuation Coordinator had discussed the situation with respect to road logistics with members of his staff as early as 12:16). As a result, the Road Crew assigned to the fuel truck impediment did not arrive at the scene of the simulated impediment until approximately 2:10 -- over three hours after the impediment had first been made known to LILCO by FEMA. FEMA Report at 36, 57. (c) There was no EBS broadcast, or other public dissemination of information about the impediments, until 1:45. (iii) LILCO's response, once it had finally begun, was inadequate with respect to both simulated impediments. (a) Only one tow truck was dis-patched to the scene of the gravel truck impediment and no scraper was sent to remove spilled gravel from the road. As a result, there was inadequate equipment available to remove the impediment, which would have required 30 minutes or more to clear even with the proper equipment. Ege FEMA Report at 37,
- 65. !
..._ -- =. (b) Although Road Crews from the Port Jefferson Staging Area were dispatched by 11:50, the Road Crew assigned to respond to the fuel. truck impediment (within Port Jefferson's area of responsibility) did not arrive at the impediment scene until about 2:10, by which time the FEMA evaluator had left. FEMA Report at 57-58. At about 11:15, the Route Spotter / Road Crew Communicator at the EOC had requested the Port Jefferson Evacuation Support Coordinator to dispatch the Route Spotter on whose route the fuel truck impediment was located. This Route Spotter, however, was not-dispatched until about 12:02, i a delay of over 45 minutes which interfered i with verification of the impediment. FEMA Report at 37.2/ 2/ Contentions Ex 25 and 29 were deemed to be dealt with in whole or in part in connection with Contention Ex 41. Their text follows: Ex 25. (Not separately admitted but to be dealt with under subpart B of Ex 41]. EOC t ARCA 8 refers to a delay of 45 minutes between an attempt to have field workers verify a fuel truck impediment and the dispatch of a Route Spotter from the Port Jefferson Staging Area. FEMA Report at 41. According to the LILCO Plan, all coordination of and decisionmaking concerning evacuation, l. including the direction of Traffic Guides, rerouting of traffic, and identification and responding to traffic impediments, is per-formed by personnel at the EOC. See OPIP 3.1.1; OPIP 3.6.3. In order to be able to make necessary decisions, achieve a coordi-nated response, and implement an evacuation, the coordinators and decisionmakers in the EOC must have accurate and timely information from the field. Without such information, an evacuation cannot be accomplished according to the LILCO Plan. Thus, this deficiency precludes a finding that an evacuation can and will be implemented as required by 10 CFR I S 50.47(b)(10), and precludes a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham accident. EX 29. (Not separately admitted but will be dealt with under subpart B of Ex 41]. Patchogue SA ARCA 2 refers to the fact that f (footnote continued) l l ! l l
i Q. Do you agree with Contention Ex 41? A. Yes, we do. l Q. Before we discuss the issues raised in Contention Ex 41, what do you mean by the term " impediments to evacuation" as used in the contention? A. " Impediments to evacuation," for purposes of this testimony, means traffic accidents or obstructions or other events, including inclement weather, that would create blockages and disruption of traffic flow on evacuation routes during a Shoreham emergency, until removed. During the Exercise, FEMA attempted to test LILCO's ability to remove impediments from the (footnote continued from previous page) appropriate personnel and equipment were not dispatched to remove the simulated multiple vehicle accident road impediment. FEMA Report at 67. The LILCO Plan and the evacua-tion time estimates in the Plan and used during the exercise assume that prescribed evacuation routes are clear of impediments and available for use by evacuees. App. A at V-2. Under the Plan, Road Crew personnel are assumed to be available, appropriately equip-ped, and capable of quickly removing any impediments that appear during an evacuation. OPIP 3.6.3. Thus, this deficiency precludes a finding that the protective action of i evacuation can and will be implemented as required by 10 CFR S 50.47(b)(10) as well as a finding that adequate emergency equipment to support the emergency response is avail-able as required by 10 CFR S 50.47(b)(8). It also precludes a finding of reasonable assur-ance that adequate protective measures can and will be taken in the event of a Shoreham accident. _
Emergency Planning Zone ("EPZ") roadways by inserting two " free play" messages into the Exercise scenario. FEMA Report at 22, 36.3/ Those " free play" messages assumed the occurrence of two separate traffic accidents, one involving a loaded gravel truck and three passenger cars, and the other involving an overturned fuel tank-truck. Seg FEMA Report at 36-39. Our testimony will focus upon LILCO's response to these two simulated traffic accidents, as well as LILCO's mobilization and dispatch of its Road Crews during the February 13 Exercise. Q. Contention Ex 41 refers to LILCO's Road Crews. Under the LILCO Plan, what are the assigned duties and responsibilities of Road Crews? l A. Under the LILCO Plan, LILCO's Road Crews are respon-sible for "[c]learing disabled vehicles or other obstacles from evacuation routes as directed by the Road Logistics Coordinator," "[d]ispens[ing] fuel to evacuating vehicles," and "[elstablish-l [ing] one-way traffic flow." OPIP 2.1.1 at page 35 of 79.1/ See 3/ As indicated later in this testimony, in our opinion the inclusion of only two simulated impediments did not constitute a realistic or sufficient test of LILCO's capability to handle impediments in a real Shoreham accident. The fact that LILCO failed each of the two tests that were included in the Exercise, however, is strong confirmation that LILCO is incapable of implementing an evacuation of the EPZ, in part because it cannot implement the portions of its Plan calling for the removal of l impediments. i/ According to LILCO's Plan, a two-mile section of roadway l (specifically, portions of Lower Rocky Point Road and North Country Road) would be converted to one-way flow in the event of a Shoreham emergency requiring any evacuation of Zone F of the (footnote continued) also OPIP 3.6.3 at 7, 14 and Atts. 2 and 13. It was the first of these responsibilities -- the ability of LILCO's Road Crews to remove road impediments "as directed by the Road Logistics Coordinator" -- that was " tested" by FEMA during the February 13 Exercise. Q. Contention Ex 41 also refers to certain other LILCO personnel. These include LILCO's Evacuation Route Coordinator, the Evacuation Coordinator, the Transportation Support Coordinator, the Road Logistics Coordinator, the Route Spotter / Road Crew Communicator, and Route Spotters. What are the duties and responsibilities of these LILCO personnel under LILCO's Plan? A. An organizational chart depicting the structure of LILCO's Offsite Emergency Response Organization ("LERO") is presented in LILCO's Plan as Figure 2.1.1. (attached hereto as ). This Figure diagrams positions in the LERO organization, the assigned locations of personnel staffing these j positions during an emergency, and the number of personnel ( assigned to one shift. The position of Evacuation Coordinator, l l and to a somewhat lesser extent, the positions of Evacuation Route Coordinator, Road Logistics Coordinator and Transportation (footnote continued from previous page) EPZ. See Appendix A at IV-8 and Table VIII; OPIP 3.6.3 at 7, 14 and Atts. 2 and 13. The objective of this traffic treatment would be to provide additional capacity to the heavy evacuation traffic flow anticipated in this area. Appendix A at IV-8, -14, -19 and Table VIII. I i.
Support Coordinator, are important supervisory positions within LERO. Egg Figure 2.1.1 (pages 1 and 3). These, and other positions which are significant to LILCO's evacuation response as it relates to Contention Ex 41, are discussed in the following paragraphs. Under LILCO's Plan, the Evacuation Coordinator directs LILCO's actions in the areas of traffic control, transportation and evacuation. He is located at the EOC in Brentwood, and is responsible for ensuring that all these activities are " rapidly" carried out and that sufficient manpower and resources exist to carry out these areas of responsibility. The Evacuation Coordinator reports to the Manager of Local Response. Egg LILCO Plan at 2.1-4 thru -5; OPIP 2.1.1; OPIP 3.6.3. LILCO's Traffic Control Coordinator reports to the Evacuation Coordinator and is also located at the EOC. The Traffic Control Coordinator's responsibilities include establishing and maintaining Traffic Control Posts ("TCPs"), coordinating the road logistics aspects of a public evacuation, overseeing evacuation routes, and overseeing traffic flow considerations. It is the responsibility of the Traffic Control Coordinator to ensure that these activities are rapidly taking place and that sufficient manpower and material exist to perform these functions. The Traffic Control Coordinator is required to make status reports on these matters to the Evacuation Coordinator. In order to implement these activities, the Traffic , l l I
_ _ _ =. - - - Control Coordinator supervises and directs the Traffic Control i Point Coordinator, the Road Logistics Coordinator, and the 1 Evacuation Route Coordinator. Egg LILCO Plan at 2.1-4; OPIP 2.1.1; OPIP 3.6.3. The Traffic Control Point Coordinator is stationed at the EOC and is responsible for coordinating the field activities of Traffic Guides. He is also responsible for distributing directions to, and receiving information from, Traffic Guides through " Communicators" located at the EOC. This would include receipt of information about road blockages and unexpected traffic flow. The Traffic Control Point Coordinator is to make status reports regarding these data to the Traffic Control Coordinator. See OPIP 2.1.1; OPIP 3.6.3,.Att. 1 (page 2 of 2). The Road Logistics Coordinator, who is also stationed at the EOC, is responsible for coordinating the field activities of LILCO Road Crews. He acts as the focal point for distribution f and receipt of information and directions to and from Road Crews. l The Road Logistics Coordinator determines which Road Crew posts i to activate based upon which EPZ zones have been ordered to evacuate, and determines the number of tow trucks to be deployed. The Road Logistics Coordinator reports to the Traffic Control Coordinator and is required to keep the Traffic Control Coordinator apprised of conditions through status reports. Eeg OPIP 2.1.1; OPIP 3.6.3. t 1 _ _,., _ - _ _ _ _., _ _. -., _.. _ _ _ _ _ _ _ _. _. ~. _ _, _ _, _ _ _. _ -. _... _ _. _.. _. _ _
Under LILCO's Plan, the Evacuation Route Coordinator also reports to the Traffic Control Coordinator. The Evacuation Route Coordinator is stationed at the EOC and is responsible for coordinating the field activities of LILCO's Evacuation Route Spotters. He is also required to relay information on evacuation traffic flow blockage to the Road Logistics Coordinator and the Traffic Control Point Coordinator, as well as keep the Traffic Control Coordinator apprised of such problems through status reports. In turn, the Traffic Control Coordinator should report such problems to the Evacuation Coordinator. See OPIP 2.1.1; OPIP 3.6.3. Another LILCO position mentioned in Contention Ex 41 is that of the Transportation Support Coordinator. He reports directly to the Evacuation Coordinator at the EOC, and is responsible for providing bus driver support and coordination in the event of an evacuation. The Transportation Support Coordinator also is responsible for implementing transportation assistance to the general public in the event of an evacuation; ensuring this support takes place rapidly; and ensuring that sufficient manpower and equipment are available to evacuate the general public as required under the LILCO Plan. The Transportation Support Coordinator is responsible for providing status reports to the Evacuation Coordinator on these issues. See LILCO Plan at 2.1-5; OPIP 2.1.1; OPIP 3.6.4.
- 1
._g e/ 2; _-_a 4@J 12 a.3s_r. _-:l a
- mMA, The LILCO Plan assumes that Evacuation Route Spotters, once dispatched from their respective staging areas, will travel through areas being evacuated and report on evacuation flow as directed by the Evacuation Route Coordinator.
Evacuation Route J Spotters are to radio the Evacuation Route Coordinator, through the Communicators located at the EOC, every 15 minutes to keep him up to date on conditions in the areas surveyed. If problems are observed, the Evacuation Route Coordinator is to be contacted immediately. Egg OPIP 2.1.1; OPIP 3.6.3, Att. 3 (page 1 of 2). The Road Crew and Route Spotter Communicator is situated at the EOC and is charged with facilitating communications between EOC personnel and Route Spotters and Road Crews. Egg OPIP 2.1.1. IV. Contention Ex 41.A j Q. Contention Ex 41.A alleges that during the Exercise, LILCO failed to mobilize its Road Crew personnel promptly. Do you agree? A. Yes. During the Exercise and according to the LILCO Plan (Plan, Fig. 3.3.4; OPIPs 3.3.2, 3.3.3 and 3.6.3), LILCO's Road Crews were not informed of the " emergency" at Shoreham or required to report to their staging areas / until after the 5 5/ Under LILCO's Plan, some Road Crew personnel assigned to the Patchogue and Port Jefferson Staging Areas must first drive to other locations, to pick up the LILCO vehicles relied upon by LILCO to remove roadway impediments from the facilities where such vehicles are stored, before then reporting to their staging areas. OPIP 3.6.3 at 6-7, 14. 18 -
declaration of a Site Area Emergency. Such declaration was made at approximately 8:19 and LILCO's Road Crews were notified of the " emergency" beginning shortly thereafter. Sag LILCO's Response to Suffolk County, State of New York and the Town of Southampton's First Request for Admissions (November 17, 1986), Admission No. 60.5/ Egg g.lso Plan, Fig. 3.3.4; OPIP 3.3.3, Att. 1 (page 2 of 3). Even on February 13, however, when LILCO's Road Crews (and other emergency response personnel) were on notice that they would be called to report for duty, most Road Crew personnel did not arrive at the staging areas until after a General Emergency had been declared by LILCO at 9:39. More specifically, at 9:00 -- over 40 minutes after LILCO's declaration of a Site Area Emergency -- only one Road Crew member had reported to the Riverhead Staging Area (10 are required under the Plan), none had reported to the Port Jefferson Staging Area (14 are required under the Plan), and none had reported to the Patchogue Staging Area (14 are required under the Plan).1/ LILCO Admission Nos. 143, 144 and 146. By 9:40 -- approximately one 6/ We understand that there is no dispute as to any facts " admitted" by LILCO. Hereafter, LILCO's Responses to the Governments' Request for Admissions will be cited as "LILCO Admission No. We also understand that there is no dispute as to any facts " admitted" by FEMA. Hereafter, FEMA's Responses to the Governments' Request for Admissions will be cited as " FEMA Admission No. Egg FEMA's Response to Suffolk County, State of New York, and Town of Southampton's First Request for Admissions and Second Set of Interrogatories, dated November 19,
- 1986, 1/
The LILCO Plan specifies that a maximum of 12 Road Crews would be assigned the job of removing obstructions from roadways during an evacuation of the EPZ. Plan at 4.4-3. The remainder of LILCO's Road Crew personnel are relied upon to dispense fuel to evacuees. See OPIP 3.6.3.. _ _.
hour and 20 minutes after LILCO began telling Road Crews to report -- only five had reported to Riverhead, none to Port Jefferson, and four to Patchogue. LILCO Admission Nos. 146, 147 and 148.8/ Thus, at the time a General Emergency was declared at 9:39, approximately one hour and twenty minutes after Road Crews should have begun reporting to their staging areas, less than 25 percent of the Road Crew personnel essential to the implementa-tion of LILCO's Plan were mobilized, even though the circum-stances -- a pre-announced exercise -- were designed to maximize the likelihood of good LILCO performance.9/ 1 Q. Wnat is the significance, in your opinion, of the response times of LILCO's Road Crew personnel in reporting to their staging areas during the February 13 Exercise? 8/ We are aware that, in some cases, numbers cited in this testimony regarding the reporting and dispatch times of LILCO's Road Crew personnel during the Exercise differ somewhat from the numbers set forth in Contention Ex 41.A. It is our understanding that, during discovery, the Governments were provided data and other information not available to them at the time the conten-tions were filed with this Licensing Board. In order to avoid confusion and to minimize contested issues of fact, this testimony, whenever possible, cites to mobilization figures and times as set out in LILCO's responses to the Governments' admission requests. There is no reason to dispute these numbers, since the thrust of Contention 41.A remains unchanged. 9/ Even by 10:20, two hours after Road Crews were to have begun reporting, approximately 16% of the required Road Crew members had not yet arrived at their staging area reporting locations. LILCO Admission Nos. 149, 150; LILCO's Response to Suffolk County, State of New York and Town of Southampton's Second Set of l Interrogatories to LILCO (dated January 5, 1987), Interrogatory l Response No. 8. t t i
o A. We believe they are too slow and severely impair LILCO's ability to implement the protective action of evacuation and the LILCO Plan. Although LILCO's initial order to evacuate was supposedly issued at 10:24 on the day of the Exercise (FEMA Report at 26) -- over two hours after the Site Area Emergency was declared at 8:19 -- it is our understanding that in the event of an actual Shoreham emergency, an order to evacuate could follow the declaration of a Site Area Emergency more rapidly than during the Exercise. LILCO's response in such a situation would likely be severely impaired, since delays by Road Crews in reporting to their staging areas could obviously delay the dispatching of Road Crews to their posts in the field. Furthermore, the fact that LILCO's personnel knew in advance when the Exercise would occur, makes their mobilization times during the Exercise suspect, and not necessarily reliable indications of what would happen in an actual (as opposed to a pre-announced and rehearsed) emergency. In summary, we believe that the long mobilization times during the Exercise are actually shorter than would be the case in a real emergency, when workers would not be prepared in advance for the need to report for emergency duty. Q. Once LILCO's Road Crews finally reported to their staging areas, were they promptly dispatched to assist in the simulated evacuation of the EPZ?
o A. No. Upon arriving at the staging areas, LILCO's Road Crew personnel were first required to obtain emergency kits, obtain and put on dosimetry equipment, complete the Emergency Worker Dose Record Form, attend the Lead Traffic Guide evacuation briefing, receive instructions from the Lead Traffic Guides re-garding deployment locations along evacuation routes, be assigned LILCO vehicles as those vehicles arrived,lE/ be instructed as to field procedures by Lead Traffic Guides, go to their assigned vehicles to ensure that they were in good working order, and, upon instruction from the Lead Traffic Guides, leave for designated field locations.ll/ Road Crews assigned specialized functions, such as the dispensing of fuel to evacuees or one-way traffic flow responsibilities, had other preparation responsibilities as well. Sag OPIP 3.6.3. Q. When did LILCO actually begin to dispatch its Road Crews to their posts in the field? A. Pursuant to OPIP 3.6.3, and during the Exercise, no Road Crews were dispatched from the three staging areas until after LILCO had simulated an evacuation recommendation to the l l lE/ As previously noted, the Plan requires some Road Crew personnel to pick up their assigned vehicles (tow trucks, etc.) before reporting to their staging areas. Egg OPIP 3.6.3. On the day of the Exercise, however, it appears that at least some of LILCO's Road Crew personnel neglected to follow this provision of l LILCO's Plan. l l 11/ In this testimony, we use the term " dispatch" to refer to Road Crews leaving the staging areas for their pre-designated field locations. ;
r i a public at 10:24 (zones A-M, Q and R). See FEMA Report at 26; to this testimony, which was prepared from documents produced by LILCO during discovery, and depicts the dispatch times of LILCO's Road Crews.12/ Q. Do you agree with Contention Ex 41's allegation that, during the February 13 Exercise, it took " substantial time" before LILCO's Road Crews were in position to respond to impediments in the field? A. Yes. Under LILCO's Plan, once dispatched from the staging areas, LILCO's Road Crews drive their designated vehicles (such as tow trucks) to pre-designated locations within the EPZ. l See OPIP 3.6.3, Att. 8, for a list of LILCO's pre-assigned Road ( Crew locations (attached hereto as Attachment 4 to this 4 testimony). It is our understanding that these locations have been selected by LILCO based upon several criteria, including: placement of Road Crews on the LILCO-prescribed evacuation routes which LILCO believes would have the largest anticipated traffic flows (and thus, according to LILCO, the highest likelihood of i obstructions); spacing of Road Crews (at distances of approximately two to four miles), so as to minimize, according to 12/ Even though LILCO had decided as early as 10:10 to issue an evacuation order to zones A-M, Q and R, it is our understanding that it was not until after 10:24, when LILCO's evacuation recommendation was made to the public, that the staging areas were instructed to begin dispatching LILCO's Road Crews. Seg to this testimony, which consists of LERO message forms from the day of the Exercise. Deposition of Jay Richard Kessler (February 2, 1987), Ex. 10. In our opinion, this delay was unnecessary and ill-advised. v A LILCO, the distances Road Crews need to travel to reach road obstructions; and placement of Road Crews predominantly to the west and south of the Shoreham plant, normally at radial distances of five to ten miles, so as to increase, in LILCO's opinion, the possibility that Road Crews could move in a countercurrent direction to the main evacuation flow (thus maximizing, according to LILCO, the chances of avoiding the congestion and attendant delays of having to travel with evacuation flow). See Cordaro et al., ff. Tr. 6685, at 10-11. After LILCO's Road Crews have reached their deployment locations, they are directed to the scene of traffic impediments by radio. OPIP 3.6.3, Att. 2 (page 1 of 2). During the Exercise, the dispatch of Road Crew personnel to their pre-designated deployment locations at Riverhead began at about 10:47 and was completed at about 11:00; it began at about 10:46 at Port Jefferson and was completed at about 12:40 (with two Road Crews having to travel first to Brentwood to pick up their tow trucks);13/ and it began at about 10:45 at Patchogue, and was completed at about 11:28. See Attachment 2 to this testimony. Subsequent to their being dispatched, it apparently took substantial time before LILCO's Road Crews actually arrived at their predesignated field deployment locations, from which they were then to drive as ordered to impediment scenes in the field. In general, we have been unable to ascertain the arrival 13/ This was apparently contrary to LILCO's procedures. See OPIP 3.6.3, S 5.4.5.b and c. l '
a times of LILCO's Road Crews at their preassigned field locations from the documents produced by LILCO following the Exercise. However, we have determined from LILCO's documents that the Road Crew directed to the scene of the simulated fuel truck impediment (Route 25A, approximately 75 yards east of the intersection of Miller Place Road) did not arrive at the impediment scene until about 2:10, over three hours after that impediment had first been made known to LILCO by FEMA. See FEMA Report at 37, 57-58.11/ Q. Based upon the results of the February 13 Exercise and your understanding of the LILCO Plan, would you expect any problems to be caused by LILCO's delay in getting its Road Crews to their posts in the field during an actual Shoreham emergency? A. Yes. As NUREG 0654 explicitly requires, an effective radiological emergency response plan must be capable of detecting roadway obstacles and removing them promptly. NUREG 0654, S II.J.10.k. Failure to do so during an evacuation on Long Island would, in our opinion, likely cause a substantially decreased rate of traffic flow and roadway capacities, thus lengthening evacuation times and increasing the likelihood that evacuees would be exposed to harmful radiation. We understand that the purpose of the protective action recommendation of evacuation is to achieve dose savings or dose reduction by ld/ LILCO has asserted that the Road Crew arrived at the scene of the fuel' truck impediment at 1:57. LILCO Admission No. 160. Even assuming LILCO's time is correct, the difference is insignificant.,
3 \\ / b enabling the public to escape the area before they are exposed to radiation. Thus, a failure by LILCO to deploy personnel promptly~ to remove obstructions on evacuation routes may make it impossible to implement effectively the protective action ofl n evacuation. x The LILCO Plan explicitly recognizes the need to deal with ~ roadway obstructions.
- See, e.o.,
OPIP 3.6.3. Moreover, LILCO assumes that its Ropd Crew personnelimust be mobilized and "in place at (the] outset of the evacuation process or soon i thereafter." Appendix A'at V-2. HowEver,.in our opinion, the results of the Exercise demonstrate that the Plan cannot be implemented in a way that ensures prompt or effective removal of roadway obstacles. Our opinion in this regard,is basdd, in part, on LILCO's inability to promptly mobilize and dispotch its Ro'ad Crews on the day of the Exercise. Our other reasons -fo reaching this conclusion are' detailed later in th,is testimony. Q. In your opinion, would the late mobilization and dispatch'ing of LILCO's Road Crew. personnel have any adverse impacts upon LILCO's ability to carry out effectively the protective action of evacuation? A. Yes. Not only does the LILCO Plan assign specific ~ evacuation routes and destinations to.the EPZ population.(sgi Appendix A at IV-75 thru -165), but LILCO's evacuation time estimates' assume that there will be adherence to these routes s
(agg Appendix A at V-2) -- an assumption (unrealistic in our opinion) which itself depends on the assumption that there would be no major vehicle breakdowns or other types of incidents which would blcck major routes for any extended period of time. Ege Appendix A at V-2. Given LILCO's reliance upon its Road Crews to remove roadway obstacles or other traffic impediments, it must be concluded that, without such personnel in place from the outset of the evacuation process, any roadway obstructions which occur at the', outset of that process would likely result in significant delays or even complete blockage of evacuation traffic. For this reason,.LILCO's Plan makes clear that any disabled vehicle (s) which impede movement of traffic on evacuation routes, whether the result of an accident, an empty fuel tank, or mechanical failure,.must be moved out of the flow of traffic "as quickly as possible.* Appendix A at IV-5. LILCO's performance on February 13 demonstrated an inability to accomplish this. Q. In your opinion, what would happen if a serious roadway accident occurred during a Shoreham emergency and LILCO's Road Crews took as long to arrive at the scene as was the case on the day of the Shoreham Exercise? A. If LILCO's Road Crews took anywhere near as long to arrive as was the case during the Exercise, they would in all likelihood be largely ineffective for a substantial period of time. First, it is not clear that the Road Crews would be able to make their way to the accident scene in the first place once
,-O 4 the impediment had been in place for any period of time, in light of the "self-help" measures evacuees would at least attempt to take, such as driving on shoulders, using other lanes, etc. Second, even assuming LILCO's Road Crews could get to the scene, it would be unlikely that they could effectively move the impediment out of the way -- again because the traffic patterns around the impediment location would have been set by the actions of evacuees before the Road Crews arrived, in all likelihood making impossible the maneuvering required to remove the impediment. I Q. Are there other problems which, in your opinion, could arise from LILCO's failure, as demonstrated during the Exercise, to mobilize and dispatch Road Crew personnel in a timely manner? A. Yes. The LILCO Plan calls for the implementation of several traffic control strategies and techniques in an attempt to " encourage" evacuees to adhere to LILCO's prescribed evacua-tion routes, or as a way of providing additional capacity to selected roadways. See Appendix A at IV-5 thru -65. One such technique involves the conversion of roadway sections to one-way traffic flow. Appendix A at IV-8, -14, -19 and Table VIII. This technique, unlike LILCO's other traffic control techniques and strategies (which are to be implemented by LILCO's Traffic / Guides), is carried out by Road Crew personnel. OPIP 3.6.3, at S 5.4.6a and Att. 13. i
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In our opinion, LILCO's proposed conversion of roadway sections to one-way flow would be extremely difficult and dangerous to implement and would require considerable lead time. i At the location of the proposed conversion (a two-mile section of roadway including portions of Lower Rocky Point Road and North Country Road), LILCO plans to establish two lanes of traffic westbound. LILCO's one-way conversion strategy would therefore require extensive set up time (e.o., the placement of cones and signs along the entire stretch of roadway), making it virtually impossible to implement this strategy on short notice, or once evacuees have filled the road. LILCO's demonstrated inability to mobilize and dit utch its Road Crews promptly leads us to conclude that it is highly unlikely that LILCO ever could successfully carry out its conversion of North Country Road to satisfy in a timely manner the traffic demands along this major evacuation route. V. Contention Ex 41.B Q. Contention Ex 41.B alleges that LILCO was incapable of adequately responding to either of the two " free play" messages interjected into the Exercise by FEMA, which simulated the existence of two major road impediments, one involving a gravel truck and three passenger cars, and the other involving an overturned fuel truck. Do you agree? 1 i
. = _ - -. A. Yes, we do. For purposes of this testimony, we will discuss the two impediments separately, beginning with the gravel truck impediment. 1 i Q. Please describe the gravel truck impediment, as presented to LILCO in FEMA's " free play" message on the day of the Exercise. A. The gravel truck " free play" impediment message required LILCO to assume that an accident involving a loaded gravel truck and three passenger cars was completely blocking one of LILCO's evacuation routes, Yaphank - Middle Island Road. The gravel truck impediment message was handed to LILCO's Evacuation Route Coordinator at the EOC by FEMA at 10:40. See FEMA Admission No. 165. It unambiguously stated as follows: i A loaded gravel truck with a broken drive-shaft, which is upright, but turned sideways in the road is blocking the north and south- [ bound lanes and both shoulders of Yaphank-t Middle Island Road, approximately fifty (50) yards north of the caution light at the "Y" intersection of Yaphank-Middle Island Road (in the vicinity of TCP #124). This is a multiple vehicle accident also involving three passen-ger cars that are blocking both the north and southbound shoulders of the road. There are no injuries to any individuals. l The LERO responder to the site of this impedi-l ment should locate the FEMA evaluator who will be wearing a red armband. r l i r l l , L
It should be noted that the FEMA message, in some ways, was crafted so as to encourage an effective and prompt response by LILCO to the " impediment." For example, the reference in the message to "TCP #124" -- i.e., Traffic Control Post #124 -- pinpointed the impediment's location.lE/ That is, the message used LILCO's own jargon to identify the location of the impedi-ment; it also prcvided clear instructions about how to locate and identify the FEMA evaluator. Therefore, the method used by FEMA l to alert LILCO to the impediment should, if anything, have shortened LILCO's response time. Q. Please explain why the FEMA " free play" message should have shortened LILCO's response time to the gravel truck 4 impediment. A. LILCO contends that, in a real Shoreham emergency, a traffic accident or other impediment would likely be " discovered" by cne or more LILCO personnel dispatched from one of LILCO's three staging areas into the field. Traffic Guides, Road Crew personnel, Evacuation Route Spotters, and Bus Drivers are examples of these kinds of personnel. The traffic impediment, once discovered, would then have to be reported -- either to one ll/ Traffic Control Posts, under LILCO's Plan, are locations staffed by LILCO's Traffic Guides. Eeg Appendix A, Fig. 8. Traffic Control Post #124 is situated at the intersection of Main Street and Yaphank - Middle Island Road. According to the Plan, this post is required to be staffed by two Traffic Guides, who would have been in full sight of the " impediment." Attached hereto as Attachment 5 is a schematic prepared by LILCO which diagrams TCP #124. 1 of the three LILCO staging areas (if discovered by Traffic Guides, for example, ggg OPIP 3.6.3, Att. 1, page 2 of 2) or to the ECC (if discovered by ncad Crmis or Route Spotterc, for example, see OPIP 3.6.3, Att. 2, page 2 of 2 and Att. 3, page 2 of 2). Under LILCO's Plan, an impediment reported by a Traffic Guide to his staging area results in a vertical line of communications, from Traffic Guide, to Lead Traffic Guide at the staging area, to a Communicator at the EOC, and thea to the Road Logistics Coordinator at the EOC. OPIP 3.6.3. Quentions or requests for additional information from the Road Logistics Coordinator, or others at the EOC, would require this communications path to be reversed. And then, of course, l responses to such questions or requests would have to filter back up this vertical chain. I i FEMA circumvented this time-consuming and potentially confusing process during the Exercise by directly informintf the EOC of the gravel truck (as well as the fuel truck) impediment. Field personnel were by passed. Staging area personnel were by-passed. Communicators at the EOC were by passed. The " free play" messages were concise and complete and were handed te LILCO EOC personnel in written form, thereby minimizing the risk of miscommunication. The impediment messages clearly and correctly stated the simulated impediment situations, the precise locations, and provided all information needed for a timelr, L
effective response by LILCO. In our opinion, based upon our experiences as police officers, it is unrealistic to believe that, in a real emergency, and given the complex communications set-up under LILCO's Plan, this kind of concise and complete information would have been provided to the LILCO EOC very quickly, if at all. Q. To whom was the gravel truck impediment message given by FEMA?
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It is our understanding that the written " free play" message was given by FEMA to the LILCO Evacuation Route Coordinator. FEMA Report at 30, 36. As previously noted, the Evacuation Route Coordinator's responsibilities include: a. Coordinating the field activities of the Evacuation Route Spotters [;] b. Relaying information received on evacu-ation traffic flow blockage to the Road Logistics Coordinator and the Traffic Control Point Coordinator [; and] c. Providing status updates to the Traffic Control Coordinator. OPIP 2.1.1, page 36 of 79. l Q. What should the Evacuation Route Coordinator have done with the information provided to him by FEMA's " free play" message regarding the gravel truck impediment? l A. According to LILCO's Plan, upon receipt of the message, the Evacuation Route Coordinator immediately should have informed the Road Logistics Coordinator and the Traffic Control Point Coordinator of the gravel truck impediment. If the Evacuation Route Coordinator did this during the Exercise (something which is unclear from our review of the FEMA Report and other Exercise documents), neither of these people informed their supervisor, the Traffic Control Coordinator, or the Evacuation Coordinator, that Yaphank-Middle Island Road was blocked by the gravel truck impediment. Nor did the Evacuation Route Coordinator report this message to his supervisor. All three were required to do so. Sge OPIP 2.1.1. Unlike the question of whether the Evacuation Route Coordinator informed the Road Logistics Coordinator or the Traffic Control Point Coordinator of the impediment, the FEMA Report makes clear that the Evacuation Route Coordinator did not advise the Evacuation Support Communicator for Route Spotters / l Road Crews of pertinent facts essential to an appropriate response, including that the gravel truck impediment was a multiple vehicle accident. This fact was required to be communicated under LILCO's Plan (see OPIP 3.6.3), and the consequence of not doing so during the Exercise was to delay substantially LILCO's response to the gravel truck impediment. See FEMA Report at 30, 36-37, 57. Q. Why was it important for the Evacuation Coordinator to be promptly informed of the gravel truck impediment? A. Under LILCO's Plan, the Evacuation Coordinator is required to be kept informed of any problems with implementing an evacuation of the EPZ, including impediments or suspected impediments, so that an informed, coordinated and planned response can be implemented. See OPIP 2.1.1; OPIP 3.6.3. If the Evacuation Coordinator is not so informed, the result will be a failure to implement an informed, coordinated and planned evacuation. Q. How did the Evacuation Coordinator learn of the gravel truck impediment during the Exercise? A. The FEMA Controller informed the Evacuation Coordinator of the gravel truck impediment (and the fuel truck impediment as well) at about 12:13. FEMA Report at 36; LILCO Admission No. 155. If FEMA had not injected this lack of realism into the Exercise and " saved" LILCO in this respect, LILCO's response to the impediment would have been even worse. l Q. As of about 12:13, when FEMA brought the gravel truck impediment to the Evacuation Coordinator's attention, what was the status of LILCO's response to the impediment? 1 l : t
A. Based upon our review of the FEMA Report and documents generated during the Exercise, it appears that little or no response had been made by LILCO as of that time. Traffic had not been rerouted around the impediment; in fact, there is no indication that the need to reroute traffic had even been discussed. Similarly, equipment sufficient to remove the gravel truck and the three disabled cars had not been dispatched, or even readied for deployment. For all practical purposes, LILCO had done nothing in response to the impediment. See FEMA Report at 36-37. Q. After LILCO's Evacuation Coordinator was informed of the gravel truck impediment at 12:13, did LILCO's response become adequate? A. No. Even after the Evacuation Coordinator was informed of the gravel truck impediment by FEMA, LILCO's response remained inadequate. The Evacuation Coordinator did discuss LILCO's response to the impediment with his staff, including the need to reroute traffic around the impediment and procedures for doing so. However, notwithstanding that FEMA-prompted discussion: As late as 12:40, the Transportation Support Coordina-tor had not been informed that a bus evacuation route was potentially blocked by the gravel truck (FEMA Report at 36; FEMA Admission No. 68; but see LILCO i l Admission Nos. 52 and 161); and !
There was no~EBS broadcast, or other public dissemina-tion of information about the impediment, until 1:45 (LILCO Admission No. 163). Q. Did LILCO eventually reroute traffic around the gravel truck impediment? A. Yes, but the rerouting scheme LILCO employed was improper and inadequate. LILCO belatedly stopped southbound traffic on Yaphank-Middle Island Road approximately one mile north of its intersection with Main Street. At that point, evacuation traffic was directed west along Bartlett Road. See to this testimony, which consists of a LILCO-generated document (a LERO message form) regarding LILCO's rerouting scheme for the gravel truck impediment -- a scheme developed and conveyed from the EOC at about 12:20. As we will discuss later in this testimony, rerouting traffic west along Bartlett Road was not a proper response. Q. During the Exercise, did LILCO eventually attempt to clear Yaphank-Middle Island Road of the gravel truck impediment? A. Yes, but LILCO's response, once it had finally begun, was inadequate.15/ For example, LILCO sent only one tow truck to 15/ FEMA agrees with our assessment. It has admitted "[t] hat during the Exercise, appropriate personnel and equipment were not dispatched by LILCO to remove the simulated gravel truck l_ impediment." FEMA Admission No. 70. -_.
the scene of the impediment, and no scraper or bucket-loader was sent to remove spilled gravel from the road (nor was any determination ever made as to whether any gravel had in fact been spilled). FEMA Report at 37, 65; LILCO Admission Nos. 158, 159. According to the FEMA Report, the Road Crew sent to the scene of the impediment was not even informed that the impediment involved a multiple-vehicle accident. FEMA Report at 65. As FEMA itself noted (FEMA Report at 65), one tow truck would have been inade-quate to remove a loaded gravel truck with a broken driveshaft and three disabled cars. At a minimum, several trucks and a scraper or bucket-loader (to remove spilled gravel) likely would have been necessary. Moreover, a 10,000 pound truck, like the one sent (according to LILCO's Evacuation Coordinator) on the day of the Exercise, would have been insufficient. See Deposition of Walter F. Wilm (January 8, 1987), at 56. This type of truck is designed to tow passenger vehicles and small commercial vehicles, not large, loaded gravel trucks. In our opinion, the truck dis-patched by LILCO could not have removed the gravel truck blockage and impediment, which LILCO's own Road Crew estimated would have required 30 minutes to clear with the proper equipment (FEMA Report at 65) -- i.e., several larger tow trucks, a scraper, etc. Indeed, it is not even clear to us that the necessary equipment j l to properly respond to the gravel truck impediment is available i to LILCO. i _ _.
The LILCO Plan recognizes the need to deal with roadway impedimenits ; inuwever, tiie r esults of tiie Exercise demuristcote that LILCO's personnel lack sufficient knowledge, training and skill to remove impediments to traffic and thus lack the ability to implement effectively the protective action of evacuation. LILCO's Evacuation Coordinator, for example, has admitted since the Exercise that he does not know whether one tow truck could have removed the gravel truck impediment. Deposition of Walter F. Wilm (January 8, 1987), at 57. Nevertheless, on the date of the Exercise, only one was dispatched to the scene of the impediment. According to Mr. Wilm, if that one tow truck would have been inadequate (which it was), he would have sent more. Id. In our opinion, this ad hoc type of response was inappropri-ate. LILCO's Evacuation Coordinator and others on his staff should know ahead of time what equipment is required to effectively remove specific impediments. They should not engage in time-consuming guess work during an actual emergency, as they did during the February 13 Exercise. These inadequacies underscore our conclusion that LILCO lacks the capability to implement adequately the protective action of evacuation. Q. What conclusions, if any, have you reached in light of LILCO's inadequate response on the date of the Exercise to the gravel truck impediment?. _ _.
i A. LILCO's inadequate response leads us to conclude that the Exercise demonstrated that LILCO is not capable of implementing.the protective action of evacuation. It is our understanding that as part of implementing the protective action of evacuation, LILCO must be capable of detecting roadway obstacles and removing them promptly. NUREG 0654, S II.J.10.k. Failure to do so during an actual Shoreham emergency would make it impossible to implement a timely evacuation and could result f in increased radiation doses to evacuees stranded on evacuation routes. The gravel truck impediment was located in zone M of the EPZ. We understand that during the Exercise, based upon dose projections and other data about likely radioactive releases, 4 individuals in that zone were advised at 10:24 to evacuate. Therefore, LILCO's inability to remove the gravel truck impediment quickly, and the traffic backups which would have resulted from LILCO's hours long delay in responding could have i resulted in evacuees being stranded in areas that were subject to serious contamination. t Q. Do you have any other concerns regarding LILCO's ability to remove roadway impediments? I I A. Yes. The LILCO Plan and the evacuation time estimates l relied upon by LILCO and used during the Exercise assume that LILCO's prescribed evacuation routes will be clear of impediments and available for use by evacuees during an actual Shoreham i emergency requiring evacuation of all or any portion of the EPZ. . I i i I _. _ _ _. _.. =, _
Appendix A at V-2. Furthermore, under the Plan, LILCO's Road Crew personnel are assumed to be available, appropriately equip-ped, and capable of quickly removing any impediments that occur during an evacuation. OPIP 3.6.3. The results of the Exercise proved these assumptions to be wrong, not just with respect to the gravel truck impediment, but also with respect to the fuel truck impediment, and other traffic impediments simulated during L7LCO training drills subsequent to the February 13 Exercise (sgg discussion later in this testimony). As a result, we reiterate our conclusion that LILCO has failed to demonstrate an ability to implement the protective action of evacuation during an actual Shoreham emergency.ll/ Q. You mentioned LILCO's response to the second impediment simulated during the February 13 Exercise -- the fuel truck impediment. Was LILCO's response to that impediment any better than its response to the gravel truck impediment? 11/ FEMA agrees, at least in part, with this conclusion, since it identified as an " Area Requiring Corrective Action" ("ARCA") the fact that LILCO failed to dispatch appropriate personnel and equipment to remove the simulated gravel truck impediment. FEMA Report at 67 (SA ARCA 2). We disagree strongly with any infer-ence that this constitutes merely an ARCA. Such a fundamental inability to deal effectively with a straightforward impediment situation, input in the most simple manner into the Exercise, demonstrates to us a severe shortcoming in LILCO's capabilities that would directly impact the public's health and safety.
- Thus, it should have been a " Deficiency," rather than an ARCA by FEMA's definitions. l i
L
o l I A. No. Like the gravel truck impediment, LILCO's response to the fuel truck impediment was ineffective, untimely and inappropriate. Q. Please describe FEMA's " free play" message for-the fuel truck impediment. A. The " free play" impediment message interjected by FEMA stated: On Route 25A, approximately 75 yards east of the intersection with Miller Place - Yaphank Road, (in the vicinity of traffic control post
- 41), a fuel tank-truck has jack-knifed and turned over on its side blocking both east-bound and westbound traffic lanes, as well as both shoulders of the road.
In the course of the accident, the fuel tank was ruptured and leaking fuel. There is a possibility that the fuel could ignite causing a fire. There is DO fire at present and there are no iniuries to any individuals. The LERO responder to the site of this impedi-ment should locate the FEMA Evaluator who will be wearing a colored arm band. Like the gravel truck " free play" message, the fuel truck impediment message was concise and complete. It fully described the accident and the accident's location (again, even using the l LILCO traffic control post number, TCP #41, to help LILCO find the impediment). Attached hereto as Attachment 7 is a schematic prepared by LILCO which diagrams TCP #41. It also explained how l to locate the FEMA evaluator. l l _, ~..,. _ _ _ _ _ _... - _ - _ _... _ _ _., _ _.. _ _ _ _ _.,. _ _ _.. _.. _... _ _.,
O. When was the message given to LILCO? A. The fuel truck message was provided to LILCO's Evacuation Route Coordinator at 11:00. FEMA Report at 36. See also FEMA Admission No. 166. Q. Please describe the Evacuation Route Coordinator's response to the fuel truck impediment message. A. As with the gravel truck impediment message, the Evacuation Route Coordinator failed to take appropriate action. He did not notify the Evacuation Coordinator (or the Traffic Control Coordinator or apparently the Road Logistics Coordinator) of the problem. As a result, a traffic rerouting scheme was not planned or implemented, and potential equipment needs for responding to the impediment were not ascartained or readied. Moreover, although the Evacuation Route Coordinator apparently did notify the Evacuation Support Communicator for Route Spotters / Road Crews of the fuel truck impediment, he once again failed to advise the Communicator of pertinent facts, including that the fuel truck impediment involved the possibility of fire, since fuel was leaking, and that both shoulders of the road were blocked by the fuel truck. LILCO Admission Nos. 153, 154; FEMA Admission No. 71. Such facts were required to be l communicated under LILCO's Plan (see OPIP 3.6.3), and the l l l. 1 L
consequence of not doing so during the Exercise was to substantially delay LILCO's response to the impediment. Sea FEMA Report at 30, 36-37, 57. Q. Was LILCO's Evacuation Route Coordinator solely responsible for LILCO's inadequate response to the fuel truck impediment? A. No, the problem went substantially beyond one individual. For example, by about 11:15, the Route Spotter / Road Crew Communicator at the EOC had requested the Port Jefferson Evacuation Support Coordinator to dispatch the Route Spotter on 1 whose route the fuel truck impediment was located to the impedi-ment scene. This Route Spotter, however, was not dispatched until about 12:02 according to FEMA, a delay of over 45 minutes which caused substantial delay in " verification" of the impediment. FEMA Report at 37; FEMA Admission No. 69.18/ Q. What conclusions, if any, have you reached from this delay by LILCO personnel in attempting to verify the fuel truck impediment? 18/ LILCO disagrees with FEMA regarding the time that the Route Spotter was dispatched. Thus, although LILCO agrees that the Route Spotter was requested to be dispatched at 11:15, it asserts J that he was dispatched at 11:45. LILCO Admission Nos. 164, 165. In either event, the time taken to dispatch the Route Spotter was too slow. - _ - -
A. Although identified as an " Area Requiring Corrective Action" by FEMA (EOC ARCA 8), we believe that LILCO's attempt to verify this impediment should have been identified as a " Deficiency," which precludes a finding that LILCO's Plan can and will be implemented in the event of an actual emergency at Shoreham. According to the LILCO Plan, all coordination of, and decisionmaking concerning, evacuation, including the direction of Traffic Guides, rerouting of traffic, and decisions relating to responding to traffic impediments, is performed by personnel at the EOC. See OPIP 3.1.1; OPIP 3.6.3. In order to be able to make necessary decisions, achieve a coordinated response, and implement an evacuation, the coordinators and decisionmakers in the EOC must have accurate and timely information from the field. Without such information, a timely evacuation cannot be accomplished. As noted, during the Exercise, FEMA eliminated the need for LILCO to demonstrate an ability to perform one-half of this process by " injecting" the impediment information directly to personnel at the EOC. In a real accident, the EOC would not know of such an impediment unless and until the field personnel were in the field, and able to report all the way up the vertical chain of command, to the EOC coordinators. In light of LILCO's demonstrated inability during the Exercise to perform just the second half of the response activities necessary to remove the road impediments, in our opinion, there is no basis to believe that in a real emergency LILCO could properly implement the l t -. - _. _. _. _.... ~. _ _ _
O I entire process. Thus, the problem identified during the Exercise resulting from LILCO's delay in attempting to verify the fuel truck impediment was a serious one: it further demonstrates LILCO's inability to implement adequately the protective action of evacuation. Q. Did LILCO's Evacuation Route Coordinator ever properly respond to the simulated fuel truck impediment? A. No. The FEMA Controller at the EOC ultimately had to " prompt" the Evacuation Coordinator, who is to be kept inforled of any problem with implementing an evacuation of the EPZ, including impediments or suspected impediments (see OPIP 3.6.3), about the impediment. That prompting took place at about 12:13 (the same time that the Evacuation Coordinator was informed by j FEMA of the gravel truck impediment). FEMA Report at 36; LILCO Admission No. 155. As in the case of the gravel truck impedi-ment, FEMA's " prompt" injected a lack of realism into the Exercise which likely saved LILCO from even greater difficulties in responding to the impediment. O. How did LILCO respond to the fuel truck impediment 1 following PEMA's prompt at about 12:13? A. Even after FEMA's prompt, LILCO's response was inadequate. For example, after being told of the fuel truck j impediment by FEMA, the Evacuation Coordinator discussed LILCO's 46 - 1 -,v-,,-.., , - n n-. -m--,, .,-.,,,---wnnn-mn.---_-------e,.---.r-,---, r._n. v-- r-,, - -,,, -,,- r- -,-,,,,-e-r,.-
response, including the need to reroute traffic around the impediment and the procedures for doing so, with his staff. Notwithstanding that FEMA-prompted discussion, however: As late as 1:48, the Road Logistics Coordinator had not dispatched needed equipment to the fuel truck accident site. LILCO Admission No. 157. This was the case despite the fact that the Evacuation Coordinator had discussed the situation with respect to road logistics with members of the Road Logistics Coordinator's staff as early as 12:16. There was no EBS broadcast, or other public dissemination of information about the impediments, until 1:45. LILCO Admission No. 163. i I Q. Was a traffic rerouting scheme eventually implemented for the fuel truck impediment? A. Yes, although in our opinion that rerouting scheme was incorrect, inadequate, and not timely implemented. As we will discuss in greater detail later in this testimony, LILCO simply rerouted traffic that would have travelled west on Route 25A onto North Country Road to Echo Avenue, and then back onto Route 25A. In our opinion, this was not an adequate response to the fuel j truck impediment. Moreover, it took 34 minutes for LILCO to devise this rerouting scheme and transmit it to the Lead Traffic
Guide at the Port Jefferson Staging Area. See Attachment 8 to this testimony, which consists of a LERO message form from the day of the Exercise. Q. Did LILCO subsequently attempt to remove the fuel truck impediment from the roadway? A. LILCO reports that it did. LILCO's response -- sending a single tow truck -- was not adequate or timely. That response was not adequate because the vehicle dispatched -- one 10,000 pound tow truck (see deposition of Walter F. Wilm (January 8, 1987), at 58-59) -- would have been much too small to remove an overturned tanker from the roadway. The response was untimely because, although Road Crews from the Port Jefferson Staging Area were dispatched by 11:50, the Road Crew assigned to respond to the fuel truck impediment (within Port Jefferson's area of responsibility) did not arrive at the impediment scene until about either 1:57 (according to LILCO; see LILCO Admission No. 160) or 2:10 (according to FEMA; see FEMA Report at 57-58) -- about 3 hours after LILCO first had been informed of the impediment. By that time, the FEMA evaluator had left the impediment scene. FEMA Report at 58; FEMA Admission No. 67. From our review of documents produced by LILCO during discovery, I it appears that the Road Crew was not even instructed to respond to the fuel truck impediment until 1:50, over an hour and a half after LILCO was prompted into action by FEMA and almost three l l . l l L
hours after LILCO was first alerted to the impediment. Seg to this. testimony, which consists of a LERO message form from the day of the Exercise; see also FEMA Report at 37. Moreover, it was not until 2:00 -- again, three hours after LILCO learned of the overturned fuel truck -- that the Traffic Control Coordinator instructed the Logistics Support Coordinator l to contact Hess Oil Company to request that an empty gasoline tanker truck be sent to the scene of the impediment to off-load the overturned fuel truck. Thereafter, Hess was called at about 2:15. FEMA Report at 37. Obviously, this call should have been made as much as three hours earlier, since LILCO had been informed in the initial free play message that the overturned truck was a fire hazard. Clearly, such a fire hazard could not I have been moved safely until the fuel was off-loaded. For this j reason (in addition to its inadequate size), the LILCO tow truck dispatched to the scene of the impediment would have been of no immediate use in removing the impediment. Q. What conclusions, if any, have you reached in light of LILCO's inadequate response during the Exercise to the fuel truck impediment? A. LILCO's inadequate response leads us to the same conclusion we reached in light of LILCO's response to the gravel truck impediment: that LILCO is not capable of implementing the protective action of evacuation. However, in some respects, LILCO's response to the simulated fuel truck impediment was even worse than was its response to the gravel truck impediment. With the fuel truck, LILCO's delayed and inadegaate response magnified i j the' potential danger to evacuees of the fire hazard from the accident; indeed, depending upon the kind of fuel leaking from i the fuel truck, there was present the risk of a serious fire or l explosion. Moreover, the fuel truck impediment was located in zone F of the EPZ. We understand that during the Exercise, based upon dose projections and other data about likely radioactive i releases, individuals in that zone were advised at about 10:24 to evacuate. Furthermore, at about 1:26, these persons were advised to report to the Nassau Coliseum, then relied upon by LILCO as the facility for monitoring and decontaminating evacuees and l vehicles, to be monitored, because they may have been exposed to radiation during their evacuation trip. Eeg deposition of Jay Richard Kessler (February 2, 1987), Ex. 10. Therefore, LILCO's inability to remove the fuel truck impediment quickly, and the traffic backups which would have resulted from LILCO's hours long delay in responding, would have resulted in evacuees being stranded in areas LILCO knew to be subject to serious contamination. i L Q. Previously in this testimony, you stated that the two l traffic rerouting schemes implemented by LILCO during the Exercise were inappropriate and incorrect. Why have you reached that conclusion? f : s -,.-n c,~,-~n.,--- ,-,-nn,,-.enn-__m_ --,-nn., r~w.-en-
A. There are several reasons why LILCO's rerouting was improper. First, LILCO's responses to the two impediments were so untimely that attempts to reroute traffic would likely have been ineffective. Second, even assuming more prompt responses, the rerouting schemes that were implemented were not the best schemes. Third, LILCO made no attempt to assist those evacuees who would have been trapped in the traffic backed up on Route 25A and Yaphank-Middle Island Road behind the two impediments.12/ Q. How could traffic have been rerouted around the gravel truck impediment? A. The key to properly rerouting traffic around the gravel truck impediment would have been to redirect traffic away from the impediment quickly, so that significant congestion would not have occurred at the impediment site. The same would have been true for the fuel truck impediment. The gravel truck impediment was brought to LILCO's attention by FEMA at about 10:40. Traffic should have been rerouted shortly thereafter. Then, the gravel truck impediment would have presented a relatively easy impediment around which to reroute traffic.20/ The goal would ( 12/ It should be noted that, because of LILCO's untimely j responses to the two impediments, PEMA failed to observe LILCO's rerouting schemes. FEMA Report at 37, 57, 65. 2Q/ We do not mean to imply here that LILCO, in our opinion, could have rerouted traffic effectively or appropriately around i the gravel truck impediment (or, for that matter, around the fuel truck impediment). To the contrary, we do not believe that LILCO would ever be capable of effectively rerouting traffic or i preventing traffic backups at the scene of traffic impediments. (footnote continued) ' 1 i
o have been to reroute traffic around tae impediment in the I direction of the Long Island Expressway or the Sunrise Highway, which is the way, under LILCO's Plan, that traffic in this area is to evacuate the EPZ. Egg Appendix A at IV-135. i The gravel truck and three car impediment was located at a point on Yaphank-Middle Island Road approximately 150 feet north of that road's intersection with Main Street in Yaphank. Egg 0, which consists of two aerial photographs and a map I of the gravel truck impediment scene. Approximately 184 feet i north of the impediment on Yaphank-Middle Island Road (and approximately 334 feet north of the caution light on Main Street /Yaphank-Middle Island intersection) is Walters Street. Walters Street presents an obvious and logical way to reroute the l traffic around the gravel truck impediment. It is clear that, by turning left onto Walters Street from Yaphank-Middle Island Road, and then turning right onto Everett Street, traffic would be 1 brought onto Main Street, slightly east of Main Street's intersection with Yaphank-Middle Island Road. Thus, by rerouting j traffic onto Walters Street before Yaphank-Middle Island Road i became congested from the impediment (i.e., promptly after the i impediment " occurred" at about 10:40), it would have been l } possible to return traffic to the point it wished to travel (Main (footnote continued from previous page) l Simply put, its personnel lack the training, skill and experience necessary to perform effective traffic control. If nothing else, i LILCO's responses to the two simulated traffic impediments during the February 13 Exercise emphasized and dramatically underscored this conclusion. 1 ' i i i .m
Street), so that evacuating vehicles could then reach the Long Island Expressway or the Sunrise Highway, and exit the EPZ. As a result, the impact of the gravel truck impediment could have been minimized. Q. Please describe what traffic control techniques should have been implemented to reroute traffic around the gravel truck impediment in the manner you have described. A. Looking down Yaphank-Middle Island Road in a southerly direction from its intersection with Bartlett Avenue, there are three roads which intersect Yaphank-Middle Island Road from the east. These roads are Shannon, Raymond, and Walters. All of these roads are north of the impediment, so traffic travelling south on Yaphank-Middle Island Road could have used any of them to detour around the impediment and still reach Main Street. However, in rerouting traffic around the gravel truck impediment, it would have been necessary to ensure that evacuees attempting f to detour from Yaphank-Middle Island Road could use only one of these three side roads to reach Everett Road and then Main l Street. In this way, traffic would have been kept moving in a i steady stream, preventing potential bottlenecks at the intersection of Everett and Walters from cars trying to make a right onto Everett from Walters Road and other cars traveling south on Everett, which previously would have made a right turn onto Everett from Raymond. \\ \\ Q. How could the type of traffic rerouting scheme you have described be implemented? I A. Very easily, if trained, experienced personnel were available to respond immediately to the scene of the impediment. Traffic personnel would have to have been assigned to barricade traffic from entering onto Shannon Road at its intersection with Yaphank-Middle Island Road. Othrpersonne.ywouldhavehadto barricade traffic from entering onto Raymond at its intersection with Yaphank-Middle Island Road. In this way, traffic would have been made to travel south on Yaphank - Middle Island Road to I Walters, where it could then make a.l' eft turn (assisted by traffic personnel) onto Walters and then a right turn onto Everett. At the Everett-Walters intersection, traffic personnel would have been needed to make traffic turn right toward Main Street rather than left, since by turning left, evacuees could easily get lost or trapped in the subdivision east of Yaphank- ~ Middle Island Road (a subdivision with no easy outlet).El/ i Q. In your opinion, would the rerouting scheme you just described have been the best way to have rerouted traffic around i the gravel truck impediment during the February 13 Exercise? i i l 21/ For this reason, it would.have been necessary to prevent traffic from turning left onto Shannon off of Yaphank-Middle l Island Road. : -~ ~
o-A. Yes. Such a rerouting scheme would have been easy and efficient. It would have definitely been better than the rerout-ing scheme adopted by LILCO, which, once it did anything, stopped southbound traffic on Yaphank - Middle Island Road approximately one mile north of its intersection with Main Street, from which ^' l point traffic was rerouted west along Barlett Road, p. Q. What was LILCO's rerouting response to the fuel truck impediment? 1 A. LILCO chose to reroute traffic away from the impediment by stopping traffic which otherwise would have driven west on Rout $ 25A beyond its intersection with North Country Road, 4 approximately 1.4 miles east of the impediment. This ' ntersection, known as TCP #40, was manned, although not until i 12:14 p.m., by Traffic Guides on February 13. Attached hereto as ! 1 is a schematic diagramed by LILCO which depicts TCP
- 40.
LILCO rerouted traffic at this intersection northwest onto North Country Road. Then, at North Country Road's intersection l l' with Echo Road, the traffic was rerouted southwest onto Echo, and tNen back down to Route 25A west of the impediment. I f Q. If LILCO had properly responded to and rerouted traffic around the fuel truck impediment, how should that rerouting have been accomplished? i e ! i
O 9 A. In our opinion, traffic should have been rerouted l[ diffc'rently than it was by LILCO. Q. Please explain. 4 A. The fuel truck impediment was located on Route 25A, approximately 75 yards east of its inters,echion with Miller Place Road. Sgg Attachment 12, which consists ofla map depicting the fuel truck impediment scene. According to. FEMA's " free play" message, the fuel truck was overturned and completely blocked all lanes of Route 25A, as well as both shoulders. Consequently, until the impediment was " removed," LILCO was required to reroute traffic around the impediment. Q. Was the rerouting scheme employed by LILCO the most effective way to reroute traffic around the fuel truck impediment? I A. No. The area north of North Country Road onto which LILCO rerouted traffic is among the most congested in the entire EPZ. Indeed, with respect to EPZ zone "F," where the fuel truck impediment was located, the LILCO Plan states as follows: l [T]his (Zone F] is one of two zones which, due to high population density, had to be adminis-tered differently from the other zones. Appendix A at IV-94. l ! l l = -.
Based upon our experiences as police officers familiar with the area of the simulated fuel truck impediment, it is obvious to us that no more traffic than absolutely is necessary should be put onto North Country Road west of its intersection with Route 25A at TCP #40. In fact, LILCO's evacuation scheme, in which traffic is routed west onto Route 25A rather than to the more crowded roadways to the north, including North Country Road, was designed for this very reason.22/ Q. If LILCO had properly rerouted traffic around the fuel truck impediment on the day of the Exercise, would it have directed traffic onto the already congested North Country Road as it in fact did during the Exercise? A. No.21/ Traffic traveling from the north on Sound Beach Boulevard could have turned right onto Route 25A (as provided by LILCO's Plan) and then have proceeded south onto Radio Avenue. Radio Avenue is not an evacuation route under the LILCO Plan, and l 22/ The traffic which is routed onto Route 25A under LILCO's l Plan actually travels toward the Shoreham plant in a southeaster-ly direction to reach Route 25A, at which point it then makes a right turn and proceeds west onto Route 25A. The reason LILCO routes this traffic southeasterly toward the plant for a period of time is to avoid North Country Road, which is already too i congested to permit this traffic to travel along North Country l Road and out of the EPZ. 21/ Again, we do not mean to imply in any way that LILCO would be able to effectively or appropriately direct traffic around the scene of a major roadway impediment or otherwise. Rather, our testimony in this regard is to the contrary and only intends to make the point that LILCO rerouted traffic in an inadequate and improper manner on the day of the Exercise by directing it onto North Country Road and into an extremely congested area of the EPZ. l ! l l-l L
it would not have been as congested as North Country Road, which is a major LILCO evacuation route. Traffic routed south onto Radio Avenue should then have continued to Canal Road via Whiskey Road. Then,-that traffic could have travelled westward out of the EPZ. Q. In rerouting around the fuel truck impediment, should anything else have been done? A. Yes. Assistance should have been rendered to those persons on Route 25A who had continued west on Route 25A beyond Oakland Avenue, thereby becoming trapped behind the impediment (Sge Attachment 12). 4 e Q. Why would that have been important? A. It would have been important because there is a six-tenths of a mile stretch of road on Route 25A between Oakland Avenue and the location of th'a fuel truck impediment, from which there is no road on which traffic can travel to reach other roads leading out of the EPZ. Once the fuel truck impediment " occurred," all traffic that would have continued west on Route l 25A beyond Oakland Avenue would have had to U-turn and leave the EPZ on Oakland Avenue or some other road that intersects Route 25A east of Oakland. l l __. _.
Q. In your opinion, how should this " trapped" traffic have been rerouted? A. First of all, traffic personnel should have blocked off the only road between Oakland and the fuel truck impediment site, which is Park Avenue, so that traffic could not have entered onto Park. This is necessary because Park Avenue opens only onto a number of cul-de-sacs, which loop around and back to Park Avenue. Persons turning onto Park Avenue therefore could have become lost and confused, thereby-lengthening their evacuation times out of the EPZ. Moreover, in order to minimize congestion, it would have been important for traffic personnel to make sure that the cars trapped west of Oakland on Route 25A were directed promptly out of the impediment area after they U-turned back into an easterly direction on Route 25A. The first road these cars would have encountered (except for Park, which should have been blocked off i so that motorists would have unable to turn onto Park) would have been Oakland Avenue. Persons turning left onto Oakland Avenue would have come out at its intersection with North Country Road. They would then have had to have attempted to make a left turn onto North Country Road. Unfortunately, North Country Road likely would have been very congested with traffic, making left turns time-consuming and difficult. The problem would have been l exacerbated by the fact that there is no traffic light to stop westbound traffic on North Country Road, Consequently, the ! l l
O intersection at Oakland and North Country would have had to have been manned to expedite persons attempting left turns. The other roads which travel north to North Country Road from Route 25A between Oakland and Route 25A's intersection with North Country Road -- Parkeide, Harrison and Tyler, as well as Oakland -- should have been blocked or at least manned at their intersections with Route 25A. Persons who would have made lefts onto any of these roads, except Tyler (which dead ends), would have reached North Country, where there would have been no personnel (or even a stop light) to allow them to make a left. Therefore, they would have been unable to easily merge into westbound traffic on North Country, and would have faced long delays. Consequently, traffic should not have been allowed to make a left onto Parkside, Harrison, Tyler or Oakland. A suitable blockade should have been placed at each of these road's intersection with Route 25A, to prevent traffic from making turns from Route 25A. Q. These roads, Oakland, Parkside, Harrison and Tyler, also travel south (right) from their intersection with Route 25A. Should traffic have been allowed to make right turns onto those i intersections? A. Definitely not. Persons who would have turned right (south) onto any of these roads would have wound up on very long, dead-end roads. They then would have had to U-turn back to Route 25A in an attempt to find another exit from the blockage caused l
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by the impediment. Consequently, the southbound lanes of Oakland, Parkside, Harrison, and Tyler should have been blocked or at least manned to prevent people from turning onto them. Q. What else should have been done to assist persons on Route 25A between Oakland Avenue and the fuel truck impediment? A. Traffic personnel should have been stationed on Route 25A at its intersection with Radio Avenue. Such personnel should have prevented traffic traveling eastward on Route 25A from the direction of the impediment from making a left (northbound) turn onto Radio Avenue, since that would lead to North Country Road where such traffic would have difficulty merging westbound. Rather, traffic traveling east on Route 25A from the direction of the impediment should have been directed to make a righthand turn (south) onto Radio Avenue, from which it could have then have traveled to Canal Road and other roads leading out of the EPZ. The traffic personnel at this intersection also could have assisted traffic traveling from Sound Beach Boulevard and other areas to the north in making lefthand turns (south) onto Radio Avenue. Q. Did LILCO employ any of the techniques that you have described on February 13? A. There is no evidence that LILCO employed any of these techniques. i l ! l 1
= 0 Is there any evidence that LILCO even considered rerouting traffic around the fuel truck impediment down Radio Avenue? A. We know of no such consideration being made by LILCO. In fact, we understand that LILCO's Evacuation Coordinator has testified that no other possible rerouting schemes were even considered by LILCO for the fuel truck impediment other than the improper one adopted by LILCO. Deposition of Walter F. Wilm (January 8, 1987), at 110. O. Returning to the other impediment, the gravel truck impediment, is there any evidence that LILCO considered using Walters as a rerouting scheme? A. To our knowledge, there is no evidence that LILCO considered using Walters Road. In fact, it appears that LILCO made a crucial error in formulating its rerouting scheme. During l his deposition, the LILCO Evacuation Coordinator who made the decision regarding how to reroute traffic during the February 13 Exercise stated that he never considered any other rerouting schemes using roadways south of Bartlett Avenue. Deposition of Walter F. Wilm (January 8, 1987), at 96-97. It should have been obvious, however, to someone actually familiar with traffic strategies in emergency situations that Walters and Raymond are both north of the location of the gravel truck impediment on l Yaphank-Middle Island Road and therefore offer relatively easy l l
9 access to Main Street. Thus, it appears that LILCO failed to even consider the easiest rerouting possibility around the gravel truck impediment. Q. You have previously discussed why it would have been important for LILCO to have rendered assistance to traffic that might have been trapped on Route 25A between Oakland Avenue and the impediment, and any traffic that might have been trapped on Yaphank-Middle Island Road behind the gravel truck impediment. Did LILCO's two rerouting schemes make any attempt to assist this traffic? A. No. LILCO's rerouting schemes were one-dimensional. All LILCO did was reroute traffic that had not yet reached Yaphank-Middle Island Road beyond Bartlett and traffic that had not yet reached Route 25A beyond North Country Road. The rerouting instructions generated at the LILCO EOC made no attempt to assist persons who would have been backed up on Route 25A behind the fuel truck impediment. These people were allowed to " fend for themselves" and, as a result, we would have to expect that at least some cf these people would have turned south onto f Oakland, Tyler, or Harrison, all of which eventually dead-end. Others likely would have made left turns onto Park Avenue, which becomes encircled in a subdivision exiting back only onto Park. Similarly, on Yaphank-Middle Island Road north of the gravel truck impediment, LILCO's inaction would have caused some persons to make left turns onto Shannon, only to become encircled in a ! l
e subdivision that exits only back onto Shannon. No effort was made to expedite evacuation traffic onto Everett via Walters by precluding persons from making turns onto Shannon or Raymond. Q. You have described many concerns about LILCO's rerouting strategies. Are these concerns significant? A. Yes. The precise details pertaining to particular 1 streets, etc., should not obscure the fundamental point: responding to major roadway impediments requires a highly professional response to difficult problems. LILCO failed to demonstrate a capacity to so respond. It demonstrated its i personnel's lack of familiarity with roadway planning and evacuation techniques and, in our opinion, the February 13 Exercise underscored the fact that utility personnel, no matter how well intentioned, cannot without real life experience become f proficient in handling difficult roadway impediments and similar i circumstances. Q. Please summarize your concerns and conclusions with respect to LILCO's ability to remove impediments from the roadways, as demonstrated during the February 13 Exercise. l A. Given LILCO's response to both of the two " free play" messages simulating the existence of major road impediments on the day of the Exercise, we conclude that during a real Shoreham emergency LILCO would not be able to adequately or appropriately._,.- -
remove roadway impediments or reroute traffic. Apparently, FEMA agrees with these conclusions, since it identified LILCO's delays in responding to the two simulated impediments during the Exercise as a " Deficiency" -- the most serious of the FEMA classifications. Seg FEMA Report at 39. Not only did the Exercise reveal that LILCO's proposal for the removal of 1 impediments is inherently unworkable, but it also demonstrated that LILCO's personnel are incapable of properly implementing that proposal in responding to, much less " removing," impediments to traffic. For all the reasons stated in this testimony, this fact, demonstrated during the Exercise, leads us to conclude that LILCO is not capable of implementing the protective action of evacuation in a way that would actually protect the public in the event of a real Shoreham accident. Moreover, the serious impact of LILCO's deficient response to the two FEMA " free play" impediments during the Exercise has been confirmed by the results of a June, 1986, LILCO training drill. During that drill, LILCO personnel failed to respond adequately to two impediments identical to those inadequately dealt with during the February 13 Exercise -- i.e., an overturned fuel truck and a gravel truck. In ' fact, LILCO's own contractor, f Impell Corp., severely criticized LILCO's June drill response to the impediments as follows: The Transportation Support Coordinator should o have done a better job of keeping control and managing his group during the road impediment scenarios. No one individual was assigned to be in charge of handling these impediments. l ' l
Because practically all groups in the EOC need to be made aware of such a problem it is im-portant that one individual be responsible for coordinating this effort. o The RHC was not made aware of the impediment to evacuation until 2:15 PM; 1 hour and 30 minutes after the event had occurred. The EBS message telling of the road impediment o was issued at 1:29 PM; almost 45 minutes after the event had occurred. In addition this important piece of information was included with the entire EBS message and might have been missed by the general public. A special EBS message should have been issued. o The message for the second road impediment was called into the EOC and was properly logged on a message form, however when the information was relayed to the field, the wrong road was mentioned; Route 25-A vs Route 25. The word came back from the controller, simulating a route spotter, that there was no impediment at the location indicated. At that time it was assumed that the impediment was either a false alarm or had been cleared, and no follow up action was taken. It was not until the controller in the EOC prompted the players three times to review the original message that any action was taken. O. Why does Impell's evaluation buttress your concerns and conclusions about LILCO's inability to respond as required to the removal of roadway impediments? A. For several reasons. First, Impell is LILCO's consultant / contractor. Yet, even though Impell must have recognized that its comments regarding the inadequacy of LILCO's performance during post-Exercise training on the handling of l ! l { t
roadway impediments were discoverable, nevertheless, it still felt it necessary to strongly criticize LILCO's impediment response. Second, prior to the June training drill, LILCO had just encountered the same two impediments (fuel truck, gravel truck) during the February 13 Exercise. Nonetheless, LILCO was unable to respond as required when faced with the impediments a second time. Finally, and perhaps most significantly, LILCO again demonstrated during the June drill that its cumbersome, complex, and vertical decisionmaking and communication hierarchy is unworkable and renders LILCO incapable of implementing a safe evacuation. For example, during the February 13 Exercise, LILCO ^ l confused the location of the gravel truck impediment. Although the FEMA message form clearly and concisely stated that the gravel truck impediment was on Yaphank-Middle Island Road, north of the Main Street intersection, LILCO's message forms became confused, and ultimately listed the accident as being on Main i l Street, east of the intersection. See attachment 13 to this testimony, which consists of various LERO message forms generated on the day of the Exercise. During the June drill, LILCO's personnel did the same thing -- they confused Route 25 and Route 25A. In both instances, LILCO's mistake led to an incorrect response and significant delays in responding to simulated l l l ( l
roadway impediments. Such mistakes again underscore that no one can have confidence in LILCO's ability to implement the protective response of evacuation. Q. Please state Contention Ex 22.I. A. Contention Ex 22.I states as follows: EX 22.I. [Not separately admitted but will be dealt with under Ex 41). During the exercise, two impediments to evacuation were postulated in " free play" messages. FEMA's conclusions on objectives EOC 16, FIELD 9 for the Port Jefferson Staging Area, and FIELD 10 for the Patchogue Staging Area, were all based upon the exercise assumption that in order to implement its Plan including the protective action of evacuation, LILCO needs to be capable of removing only two road impediments. That assumption has no basis. Even if road impediments were assumed to include only traffic accidents (contrary to the NUREG 0654 provision which clearly includes impediments caused by inclement weather), LILCO itself has estimated that four accidents / breakdowns would occur during an evacuation of the EPZ (see Cordaro et al., ff. Tr. 6685, at 8). In fact, during the two-week period from February 6-20, 1986 (i.e., the weeks immediately before and after the February 13 exercise, and including the day of the exercise), there were at total of 335 reoorted traffic accidents in the Sixth precinct of the Suffolk County Police Depart-ment, which includes the 10-mile EPZ.24/ og i these 335 reported accidents, 62 involved personal injuries, 38 required ambulance response, and 65 required the assistance of one or more tow trucks. Thus, on average, there were over 22 reported accidents per day during this two-week period, with more than 24/ Under New York law, an accident is required to be reported if the property damage exceeds $400, or if the accident results in personal injury. Of course, a substantial number of accidents that fall within these criteria are not reported.
a four, on average, involving personal injuries and the assistance of one or more tow trucks, and approximately two-and-one-half, cn aver-age, requiring ambulance response. Because the exercise was premised on the false assumption that the capability of re-moving two roadway impediments was sufficient to assure that an evacuation could be imple-mented, the results of the exercise, even assuming arauendo that LILCO could have demonstrated such capability, preclude a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham emergency. Accord-ingly, the LILCO Plan is fundamentally flawed. i. Q. Do you agree with Contention Ex 22.I? A. Yes. LILCO's failures in dealing with the FEMA " free play" messages during the Exercise were cast in the best possible light. In fact, there are many locations within the EPZ where the impediments introduced by FEMA during the Exercise would l likely have had a much greater impact on evacuation traffic than the locations chosen by the FEMA impediments, including the following: LIE & William Floyd Parkway; i Route 25A & Miller Place-Yaphank Road; LIE Exit 66 w/ bound ramp & Patchogue-Yaphank Road; Route 347 & Hallock Avenue; Sunrise Highway w/ bound on Ramp 59 & Wading River Road /Chickester Avenue; i l
North Country Road & Mt. Sinal-Coram Road; North Country Road & Main Street; and Route 347 & Old Town Road. This is not an exhaustive list. Q. Contention 22.I challenges FEMA's assumption that LILCO, in order to implement its Plan, including the protective ^ action of evacuation, needs to be capable of removing only two road impediments. Do you agree? A. Yes. Even if road impediments were assumed to include only traffic accidents (contrary to the NUREG 0654 provision, which clearly includes impediments caused by inclement weather), LILCO itself has estimated that four accident / breakdowns would occur during an evacuation of the EPZ. Seg Cordaro et al., ff. Tr. 6685, at 8.21/ In fact, during the two-week period from I February 6-20, 1986 (including the day of the Exercise), there were a total of 335 reoorted traffic accidents in the Sixth i Precinct of the Police Department, which includes most of the 10-mile EPZ.21/ Of these reported accidents, 62 involved 21/ We have previously testified that an evacuation of the EPZ would likely result in a far larger number of accidents than LILCO estimates, and that many of these accidents could result in delays or even complete blockage of traffic. See Roberts et al., ff. Tr. 2260, at 63-65. We will not, however, repeat here arguments previously made. 2{/ Under New York law, an accident is required to be reported if the property damage exceeds $600, or if the accident results in personal injury. A substantial number of accidents that fall (footnote continued) i l i
personal injuries, 38 required ambulance responses, and 65 required assistance of one or more tow trucks. Thus, on average, there were over 22 reported accidents per day during the two-week period, with more than four, on average, involving personal injuries and requiring the assistance of one or more tow trucks, and approximately two-and-one-half, on average, requiring ambulance response. 4 to this testimony is a copy of the Police Department's analysis from which these numbers are derived. Q. Is it harder to reroute and remove three or more roadway impediments than it is to reroute and remove two impediments? A. Yes. However, it would become harder geometrically for LILCO to deal with impediments as their numbers grow. Q. Why is that? A. For many reasons. The rerouting personnel at the EOC can only do one thing at a time. The more accidents there are, the less attention there is to divert to any one impediment. As the number of impediments grows, rerouting decisions become more i difficult. As more and more roads are unusable, it becomes critical that the EOC receive prompt reports from field personnel (footnote continued from previous page) t within these criteria are not reported. Thus, it is likely that the actual number of accidents is even higher than stated above.
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4 to keep up to date on traffic flow and movement. In addition, the greater the number of accidents, particularly if they occur close in time, the greater the strain on LILCO's field personnel, including its Road Crews. Under the LILCO Plan, Road Crews are dispersed to pre-designated locations throughout the EPZ. See OPIP 3.6.3, Att. 8 (page 4 of 5). Several accidents occurring in close geographic proximity would likely cause LILCO to experience significant delays in responding to the impediments with appropriate and sufficient equipment. Given the demonstrated inabilities of LERO personnel to deal with the two impediments during the Exercise -- which were "given" to LILCO in a manner which eliminated roughly half the process which LILCO would have j to perform in a real emergency -- there is no way, in our opinion, that LILCO could properly or effectively deal with even more impediments during a real Shoreham accident. l l ) Q. Contention Ex 41 alleges that, during the Exercise, LILCO failed to satisfy several Exercise objectives. Please state those objectives. 4 t l A. The particular Exercise objectives which, in our I opinion, were not satisfied by LILCO as they relate to the allegations raised in Contention Ex 41 (for the reasons discussed f in Contention Ex 41 and this testimony) are as follows: l l l l l,
e O EOC 7 Demonstrate that messages are transmitted in an accurate and timely manner, messages are properly logged, that status boards are accurately maintained and updated, that appropriate briefings are held, and that incoming personnel are briefed. EOC 8 Demonstrate that the appropriate official is in charge and in control of an overall coordinated response including decisions on protective action recommendations. EOC 11 Demonstrate the ability to communicate with all appropriate locations, organizations, and field personnel. EOC 16 Demonstrate the organizational ability to manage an orderly evacuation of all or part of the 10-mile EPZ including the water portion. EOC 17 Demonstrate the organizational ability to deal with impediments to evacuation, such as inclement weather or traffic obstructions. SA 2 Demonstrate the ability to mobilize staff and activate the staging areas in a timely manner. SA 7 Demonstrate that messages are transmitted in an accurate and timely manner, messages are properly logged, that status boards are accurately maintained and updated, that appropriate briefings are held, and that incoming personnel are briefed. SA 9 Demonstrate the ability to dispatch to and direct emergency workers in the field. FIELD 9 Demonstrate a sample of resources necessary to implement an orderly evacuation of all or part of the 10-mile EPZ. FIELD 10 Demonstrate a sample of resources necessary to deal with impediments to evacuation, such as inclement weather or traffic obstructions. Q. Please explain why you believe that these objectives were not satisfied by LILCO during the Exercise. l l i l l l ' l
A. With respect to objectives EOC 7, EOC 11, and SA 7, LILCO did not timely or accurately communicate important data either within the EOC or between the EOC and the staging areas. During the Exercise, data took too long to be conveyed to appropriate personnel. Further, miscommunication of data took place, as discussed in our testimony. As to EOC 8, there was no demonstration that the appropriate official was in charge of an overall coordinated response to evacuation. In fact, as our testimony demonstrates, subordinates made important evacuation-related decisions without coordination, and often without even informing other personnel or supervisors, who clearly needed to be informed in order to initiate an appro-priate response. Further, as documented in our testimony, these officials often made decisions not to inform appropriate offi-cials, thus indicating no clear understanding of whether the appropriate official was in charge. Objectives EOC 16 and FIELD 9 refer to LILCO's ability to demonstrate an organizational ability to manage an orderly i i ~ evacuation of the EPZ. LILCO's late and inadequate mobilization, miscommunication, failures to communicate, failure to coordinate responses, late responses to impediments and inadequate responses to impediments have all been discussed in our testimony. Each of I these demonstrates LILCO's failure to meet objectives EOC 16 and FIELD 9. Moreover, EOC 17 and FIELD 10 require a demonstration of resources to deal with impediments. Our testimony demon-strates why these objectives were not met by LILCO's untimely, incorrect, and inadequate responses to the two " free play" impediment messages interjected by FEMA into the Exercise. Finally, our testimony sets out how LILCO was unable to mobilize and dispatch emergency workers into the field. Consequently, we conclude objectives SA 2 and SA 9 were not met. VI. Contention Ex 41.E Q. Contention Ex 41.E addresses LILCO's proposed "fix" to the deficiencies identified during the Exercise relating to l l LILCO's ability to remove impediments from the roadv;,$. Please i state Contention 41.E. s A. Contention Ex 41.E states: i The proposal to add a Traffic Engineer to the LERO personnel at the EOC (see letter dated June 20, 1986, from John D. Leonard to Harold R. Denton (SNRC-1269), Encl. 1 at 1) would not eliminate the flaws in the Plan which were i demonstrated by the exercise, since that person's assigned task would be "to assist in evaluating road impediments and developing alternate routing." Even assuming such a person could provide such " assistance," it would have no impact on the basic structural flaws in the Plan and demonstrated incapacities of LERO personnel described in this contention. - - - - , _ -. -=.
Q. Have you reviewed SNRC-1269 and LILCO's revision to its Plan as they pertain to LILCO's proposal to add a Traffic Engineer to the LILCO personnel at the EOC? 1 A. Yes. Revision 7 to the LILCO Plan states that a 1 Traffic Engineer, " familiar with the Shoreham EPZ road network," will be assigned to the EOC, with responsibility for " assist [ing] the Evacuation Coordinator [in] respond [ing) to road impediments requiring the rerouting of evacuation traffic and buses to alternate routes." Plan, at 2.1-5 (Rev. 7). Q. In your opinion, will the addition of a Traffic Engineer solve the problems encountered by LILCO during the February 13 Exercise? A. No. LILCO's proposal will not eliminate the flaws in the Plan, or the incapabilities of LILCO's personnel, which were demonstrated during the Exercise. The addition of a " Traffic Engineer" will have no significant impact on the basic inability of LILCO's personnel to remove roadway impediments and effect an evacuation, as discussed in this testimony. The Traffic Engineer represents only another position in a complex, cumbersome vertical hierarchy which already has been demonstrated to be incapable of implementing a response to an expected " problem," which was posed in a way which effectively eliminated half of the l.
F necessary response process, and which occurred in an artificial situation involving no real people, traffic or reaction to a nuclear accident. l The only way to identify, respond to, and solve traffic problems, especially during a highly charged circumstance such as an evacuation, is to have trained and experienced field personnel who are able and authorized to quickly evaluate a problem, con-sult with other personnel in the field (via adequate communica-tions means which LILCO lacks) in order to determine other problems and ramifications to be considered, and then reach a decision, which is capable of being implemented quickly and j effectively. This requires competent field personnel who have the experience, the ability and the authority to make and implement traffic response decisions. It also requires trained personnel in supervisory positions who are informed, have accurate and current field information, know how to assist field l personnel who need to reroute traffic, and can send appropriate equipment to quickly and expeditiously remove impediments. Under LILCO's Plan, however, field personnel for the most I part do not confer with each other. Traffic Guides, for example, cannot inform each other of problems which require joint response. Thus, LILCO's plan for addressing the deficiencies identified during the Exercise lacks this essential element of l data collection from the field. Morepver, under LILCO's plan, f most decisions are made at the EOC by LILCO " coordinating" l {
personnel who are not adequately informed or trained in subjects necessary to respond to traffic problems, even assuming that they were able to ascertain from field personnel what was going on in the field. The addition of a person with the title of " Traffic Engineer" does nothing to address these problems. As previously noted, in both the February Exercise and the June training drill, LILCO's responses to impediments were slow and inadequate, in part because LILCO's field workers possessed inaccurate information about impediment locations. The addition of a Traffic Engineer would only increase the potential for error by adding yet another communication layer through which information would be lost or become confused. In fact, during an October 1, 1986 training drill, the third LILCO drill in which a Traffic Engineer participated, Impell admitted that serious communication problems continue to plague LERO: [o]ne of the major areas of concern during this drill continues to be the communications between the EOC and the Staging Areas. Long delays in getting information to the Staging Areas were experienced throughout the drills. l Much more emphasis needs be placed on commun-ications both in accuracy and timeliness.... It appears that the common denomir.ator in communications delays is the EOC and emphasis must be placed in training that facility. This bears out our observation that the Exercise demon-strated the inability of EOC personnel to communicate with the LILCO staging areas, as required to respond effectively to traffic impediments. Thus, during the Exercise, it took too long l to convey an order to send Traffic Guides into the field; it took too long to convey rerouting decisions; it took too long to have equipment dispatched; it took too long to ask field personnel to i provide additional traffic data. Not surprisingly, LILCO believes that future training will solve this problem. It will not. The problem is endemic to LILCO's organizational structure. Q. During the Exercise, LILCO failed to establish rerouting schemes in a timely manner. In your opinion, will a i Traffic Engineer solve this problem? A. He may only confound the problem. Adding a Traffic Engineer only adds yet another person who will be involved in rerouting decisions. There is no guarantee -- or basis to speculate -- that the Traffic Engineer will be any better than j existing LILCO personnel at quickly resolving problems, particularly since the proposed Traffic Engineer, like the other decisionmaking personnel during the Exercise, will be at the EOC, rather than in the field, and therefore completely dependent upon the field workers, and staging area personnel, to provide him the l data necessary to the making of informed rerouting decisions. In fact, during the June training drill, Impell conceded i that the Traffic Engineer got bogged down in " traffic engineering j details" rather than quickly devising an effective rerouting scheme: l l 1
The position of the Traffic Engineer was utilized for the first time. Their exact responsibilities was not very clear in their own minds. They became too involved in traffic engineering details, i.e. extent of the crown on the road and its effect on traffic flow, rather than quickly advising the Evacuation group of alternate evacuation routes and their effect on evacuation time estimates. Similarly, in its report critiquing the October 1, 1986 training drill, Impell again criticized the Traffic Engineer, noting that: [t]he Traffic Engineer however, had to be prompted to develop revised evacuation time estimates based upon the re-routed traffic. This criticism is also found in the evaluation of the I September 17, 1986 training drill, where Impell concluded: i (i]mprovement could be made in generating the re-routing information and arriving at new evacuation time estimates. Thus, there is no basis to conclude that the addition of a Traffic Engineer has done anything to solve the deficiencies identified during the Exercise in removing impediments from the I roadways and in rerouting traffic. Q. You have testified that the rerouting scheme adopted by LILCO during the Exercise was improper and inadequate. Is there i any reason to believe that LILCO's Traffic Engineer can devise better rerouting schemes? -
j A. No. There is no reason why this would be true. In the June drill, the Traffic Engineer mired himself in details. In the September and October drills, he was late in performing tasks and had to be prompted to do his job. Moreover, the Traffic E Engineer position will perform no new method of traffic rercuting analysis. He will perform the same function performed by other LILCO personnel during the February Exercise. There is no reason i to assume that this identical analysis will be better performed simply because the person performing the analysis is called i " Traffic Engineer" rather than " Evacuation Coordinator." Q. Does that conclude your testimony? f l l A. Yes. i I l l. --
.. _ _.. y.7, _ - - r - - - ( q ge j; j, o e r t I ,F m v, ,:/ A t'.l< ', - ~ y 3 y t [i ,-? -. /> } v l. ' b> l 4 AT'5ACHMENTS ,N h. s t M, ,j - ; i v LILCO Plan, Figure 2.l}'.11, ,, ^ * - ), LERO Schematic of Plapiss 4, t <n. N Port Jefferson, PatchogUe,'and Riverheid 3. N 'p' i Road Crew Dispatch CharP (prepared from Y ( 2 l - ' LILCO records and documents). \\- l .\\ g N 4,,,. ' .\\ \\ h.,., ) y r LERO Aessage Forms;trom EOC toja i'( s Riverhead, Patchogge, Jefferson Staging'nrea..and Port / % j s 2pgarding' g, ( s dispatch of Roadsfrews3 d' s' 1 si' t OPIP3.6.3,A;tachmentI.&A4 Road Crew Deployb.eit Locatiohh f Schematic prepared by LILCO which v j diagrams TCP #124 i V .s. e LERO Message Form from Traffic Control p Point Coordinator to the Patchogue Lead 'e Traffic Guide at 12:20 regarding gravel l ~ 7 ruck impediment s(. t e c;. ? ' Schematic prepared by LILCO which O' Ii '. diagrams TCP #41 Q '{l 4 LEPO Message Form from Traffic Control Point Ccordinatc- " f. j Traff,i.c Guide.at lh.o Port Jeffersan Lead" x
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) j .trhce impedimente f +L 4 y LERO Mqspage Fhrn f rom Road Logistics i, Coordirutor t0220C Evacuation Support; f Coordinator at'13:50 regarding dispatch l< ' s of Road Crew #2011 y s u s 3 \\ p. g. -Attachment 10 Aerial Photographs cad Xap depicting., ~ ~ ~ i-I gravel truck in.pesiir:ent 1ccation i 1 e t i s.. v 1 Schematic prepared by LILCO which i e _ q:' diacrams TCP #40' h k., ' 2 Map depict,ing5:uel truck impediment location \\' l s 4 b ,/- -wn .....r , ~ ,,#.~,.~.,,-.-..,,_,%,._..,. ,c. ~.. .r r ___m. --,n-,-.
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f: 3 'i. ATTACHMENT 4 1 t
OPIP 3.6.3 Page 49 of 77 Page 1 of 5 ROAD CREW DEPIDYMENT LOCATIONS I l Wind i I Zones l Direction l I Staging Areas l I I (From) l Riverhead l Patchogue l Port Jefferson l l 0 - 2 Miles l l Tow and Other Trucks i I I I I I i lA,B,C,D,E I Any 1 2001, 2002, 2003, 2004 1 2005, 2006, 2007 l 2009 I I I 1 1 1 1 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I l l 1 l Casoline Tank Trucks i I I I I I I I I l 3001 l 3002, 3003 l l l l l 1 1 I i i i I I I I I I I I I I O - 5 Miles l l Tow and Other Trucks l I I I I I l l A - E, F l ESE I 2001, 2002, 2003, 2004 l 2005, 2006, 2007 l 2009, 2010, 2011, 2012 I I I E l l l l I A - E, F, G I ENE l l l l 1 l SE I l l l l 1 I I I I I I I Gasoline Tank Trucks I I I I I I I l l 3001 1 3002, 3003 1 3005, 3006, 3007 l l 1 1 I I I I I I I I I I I I I i 1 l A - E, F, G, 11 i NE I 2001, 2002, 2003, 2004 l 2005, 2006, 2007, 2008 l 2009, 2010, 2011, 2012 l 1 l NNE I 1 l l l l l I I I I I I I I i 1 1 I 3001 1 3002, 3003, 3004 1 3005, 3006, 3007 I I I I I I I Rev. 5
OPIP 3.6.3 Page 50 of 77 Page 2 of 5 ROAD CREW DEPI4YMENT LOCATIONS l l Wind l l l Zones l Direction l Staging Areas I l I (From) l Riverhead l Patchogue l Port Jefferson i I O - 5 Miles l l Tow and Other Trucks l 1 1 I I I I i A - E, G, H l NNE I 2001, 2002, 2003, 2004 1 2005, 2006, 2007, 2008 l 2009, 2010, 2011, 2012 l l A - E, G, H, I I N l l l l l A - E, G, H, I, J l NNW I I i l i l i l I i l l I Gasoline Tank Trucks l 1 l l l 1 I I J l 3001 1 3002, 3003, 3004 I I I I I I I I I I I l l l l l 1 I I l l l l Tow and Other Trucks l l l l l l l l A - E, H, 1, J l WNW l 2001, 2002, 2003, 2004 l 2005, 2006, 2007, 2008 l l l l NW l l I i l I l l l l 1 l l Gasoline Tank Trucks l I I I I I I l l l 3001 1 3002, 3003, 3004 l l 1 1 I I I I I i l i l i l l I I I I I A - E, I, J l W l 2001, 2002, 2003, 2004 -l 2005, 2006, 2007 l 2009 I I A - E, J l WSW I I I l l l SW I I I I I I I l i 1 1 I I l l l l l 3001 1 3002, 3003 l l 1 1 I I I I Rev. 5
OPIP 3.6.3 Page 51 of 77 Page 3 of 5 ROAD CREW DEPLOYMENT IDCATIONS l 1 Wind j l 1 Zones i Direction i Staging Areas I l (From) l Riverhead l Patchogue l Port Jefferson I l Complete l l Tow and Other Trucks i I O - 5 Miles l 1 l l "I I I I I I I IA-J l Any 1 2001, 2002, 2003, 2004 l 2005, 2006, 2007, 2006 l 2009, 2010, 2011, 2012 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I l Caso11ne Tank Trucks l I I I I I i l l 1 3001 1 3002, 3003, 3004 1 3005, 3006, 3007 l l 1 1 I I I I I I I I I I I I I I I I I I I I O - 10 Miles I Any I Same as for evacuation of Zones A - J. l I I I i I i l I i i I i I I I i i l i l i i i i l I I I I i I i l i i l i I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I i i l i 1 I i l i l I i l i Rev. 5 t
OPIP 3.6.3 Page 52 of 77 Page 4 of 5 LEGEND FOR DEPLOYMENT LOCATIONS OF TOW TRUCKS AND OTHER TRUCKS Number Location 2001 William Floyd Parkway and Route 25 (TCP 62) 2002 Wading River Manorville Road and Route 25 (TCP 10) 2003 Wading River Road and Route 495 (TCP 27) 2004 Edwards Avenue and Middle Country Road (Route 25) (TCP 14) 2005 Port Jefferson Patchogue Road (Route 112) and Route 495 (TCP 77) 2006 Patchogue Yaphank Road - Sills Road and Route 495 (TCP 70) i i 2007 William Floyd Parkway and Route 495 (TCP 126) 2008 Sunrise Highway and William Floyd Parkway (TCP 30) t 2009 Middle Country Road (Route 25) and Middle Island Road (TCP 35) 2010 Route 25A and Rocky Point Road (TCP 38) 2011 Route 25A and Patchogue - Mt. Sinal Road (Route 83) (TCP 56) 2012 Patchogue - Port Jefferson Road (Route 112) and Nesconset Road (TCP 50) i Rev. 5 -y,,.-- ,.nng-
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[ 1/ e. e' ATTACHMENT 5
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3' 4 ATTACHMENT 7
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OPIP 4.1.2 /'/ Page 6 of 7 // [l / 8/ Page 1 of 1 LERO MESSAGE FORM no. 1 'L c V '=v rtcte Location i name Trom: fe ) Je,, feen] [6 C -w ys To: [dec fa ., / ron 1Ed C = -N Y - Date/ Time: 0Af/4 F/ //fo /m,,,. Mesange: Yr /s J hir, // j Qisa/e4 so,,J ex t f.2 os s / 6"i4 >4s /< M, /J/e M isL1 p) %%Vds' r/e Nu h.a L w,e A4 'flt V /ebn che /s v N 's p ths,b ~, rh,id/0 /c LJ/ Ph, />rsin sv + th / i // PN 6 hf/>roesf fnrevel /Fuc/c 0lo e Nr* r f Alos y Cu/L S u a d M e.' f .,hN Y tf (3 A b/?r Y lY <k Y bq"" / con 7,,, s en< '/ 'howl71oI roeira'i w fo+ , vs C4.,,r& us, m 6, e +. low., ~ Routing for: l l Action l[l Information Response Required: l[l In Response to Message No. V White copy - Addressee Yellow copy - Originator Rev. 5 Pink copy - Lead Communicator 10003524
c' f O h F ATTACHMENT 14 r l
POLICE DEPARTMENT COUNTY OF SUFFOLX, NEW YORX INTERNAL CORRESPONDENCE To: Richard Roberts, A/ Chief of Headquarters DATE: 5-20-86 Headquarters Division, Command 5000 FROM: Edward Webber, Lt., Commanding Officer COPY TO : Edwin Michel C Central Records Section, Command 5220 CO 5200
SUBJECT:
Motor Vehicle Accident Surrey 2/6'/86--2/20/86 File t Attached find a completed Motor Vehicle Accident Survey for the period February 6, 1986 through February 20, 1986. The material, which indicates PI, Ambulance and Tow, is presented by precinct and tour, with daily precinct totals. A grand total by precinct and police district is also attached. Respectfully submitted, e-~n Edward Webber, Lieutehant Commanding Officer 5220 Central Records Section EW:md Attach,p h Sf S Poc3 2042 F .,, - _,, - - - - - - - - - - - - ~,
e MOTOR VEHICLE ACCIDENTS FOR THE PERIOD 2/06/86 - 2/20/96 CUMULATIVE TOTALS OF ALL PRECINCTS
- OF P/I AM8ULANCE TOW PRECINCT TOUR ACCIDENTS YES - NO YES - NO YES - NO 1
58 10 48 7 51 14 44 1 2 156 24 132 13 143 17 139 3 119 21 98 t 13 106 27 92 1 44 5 39 4 40 18 26 2 2 144 24 120 14 130 38 106 3 103 22 81 16 87 34 69 e 1 50 12 38 7 43 14' 36 3 2 134 18 116 11 123 32 102 3 98 21 77 19 79 22 76 1 59 16 43 14 '45 19 40 4 2 139 22 117 16 123 28 111 3 82 20 62 7 75 19 63 1 55 15 40 12 43 17 38 5 2 134 28 106 17 117 27 107 3 103 26 77 13 90 21 82 1 49 11 38 7 42 15 34 6 2 175 27 148 17 158 30 145 3 111 24 87 14 97 20 91 ALL PRECINCTS 1 315 69 246 51 264 97 218 8Y TOUR 2 882 143 739 80 794 172 710 3 61-6 134 482 82 534 143 473 3 RAND TOTAL 1913 346 1467 221 1592 412 1401 1 l 7
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g 3 3 3 3 (' ' j '. i ', " ~ '. E/10 3 1 33 M ~T ~ ~ 3 4. 2 1 i 1 1 TOTAL 9 3 6 9 1 8 .... ' ] 3 4 1 3 4 4 2.*11 2 "M ""T ] 7 7 "TT ~~ 3 5. _2 _1 1 1 TUTA4. 25 4 21 1 24 .. -d f g 3 3 3 3 2/12 2 1 7 3 1, t 7 7 TUTA4. 18 18 la 3 15 A 1 1 1 2 1 2 4 3 2/13 2 3. 2 7 3 L 2 _j 3-4 TOTAL. 20 3 17 T 5 15 1, 1 i 1 ,,.} 5 1 5 2 4 t/14 a ~~3 7 ~7 ""~ 3 .11 _2 ,,22 ,2 3 33 TOTAL 35 3 33 3 33 6 30 f " 3; 5 5 5 ~~(' 3D D 32 ] 3 a/13 a ~. 3 7. ,2 3 2 J _2 q TOTA 25 s 20 3 23 5 1 a. 1 3 1 1 1 .j
- -' i, z/ 6 a
t 3D D ""3 ~ ~"* 3 _1 1 g JJ J ,2
- r..,,
TOTAL 14 3 11 1 13 2 12 . ~ .1 i 1 1 1 1 vif I DD D3 33 3 .,,1 ,,s J J _j TOTA 4. 14 t.o 3 11 3 11 4 ~3, g 4 1 5 1 5 3 3 ~ 2/te a 7 "TL 7 ""'15 7 ""T1 3 33 33 7 g TOTAL 32 4 24 6 26 7 ~ e 3 f 1 2 [_. 3 d 1 t/19 a ,.5 ,,,,,,,5 3 12 2 JJ 8 ME 17 3 14 1 16 1 16 3. g. i t 1 1 1 a/ao a D D' 7 77 73 3 3 2 2 J4 3 _4 TOTAL 12 3 9 2 10 4 8 u. ,-., m ,+ e g TOTALE 1 54 '10 48 7 51 14 44 TOTA 4.5 2 D ~T4 3 ""U "TO "'T7 TII l TcTALs 3 ".u~.3 fA g 3 "Es 33 l awe TcTAi. .m _55 _2_7 : 33 3_00 _. 5.: 275 i L. ~ ~ - =w. -- - ~ ~ ?.- -
ww, :.< p - -- evav -- .u.. w.w^ $ _ *= EE Y ~' '~~ W-
- ~f" m-
- ' ^ - -j 0 O OP O/2 AmeLA.#CE,,, TOW A,.sW:,,f '- DATE TOUR ACC100f75 YES _ NO YES - 40 YES _ 43 4 f f } $L 23 }3 2 1 1 ..) 2/o. 2 1 3 a. 1 k L TOTE l 4 14 4 14 3 13 a .t 1 .u. I t _.L _t I _t 2/07 2 ,,,2. ,,,.L L ._f. ,,.L t. 3 .in. L.LL L .L1, ,,.t, .LL TUTAL 35 5 _34 _3 32 26 _9 ~k s .3 _t 2/08 3 +- -e ~ 2 .u. a _t TOTA 23 _5 18 _2 _2_1 10 _13 "v.".. -;~ 4 4 4 g _3 q t . ~, ' 2/09 2 S 1 4 . 1 4 3 2
- ' ' N..
3 a ,,,.L 3 3 ~., ~ TOTAL J .10,,, J 9 1 9 5 5 0 . rT c- -C 1 2 2 2 1 1 '.. Y.G g/gG t 3 ~M M M T ~ e 3 .12,. L L _1 1 a1 TOTE 1 1 18 2 17 6 13 -j i 5 5 5 2 3 l 2/11 2 3 ,,, 1.L1 L.11 }, 1 3 A. L _L .L _L TOTE 25 1 _24 _1 _24 _9 _16 j a t 3 3 3 1 2 2/t2 2 3 33 33 ~T ~TT 3 7. L L _1 k i l NE _26 _4 _22 __2_ _24 _5 _21 1 1 1 1 1 2/13 2 3 33 ]
- T T
"'T j 3 1, L .,,,,1 _1 ,,,,1 .,,,1 _t, l TOTAL 19 3 16 3 16 5 14 i t 1 1 1 1 2/14 2 3 33 ,, 1,,, i _A i 3 .u. 1 1 1 ._s ._s t TOTE _17 _7 _to _5 _1_1 _5 _12 t 3 1 2 1' 2 1 2 1 S da dand I TUTAE" 3 _2_4. _6..__l e_., _4 __t o _10 _14. ,4 ,1 3 1 _i, 4 3,] 2 a a . k} TOTE g 1 7 3 4 4 I t J 1 1 1 2, 2/t7 2 _f. 3 '3 7 '"'T r 3 1 1 1 i _3 g. TOTAL 15 4 11 2 LJ 1 14 3 -I + 1 1 3
- 3
._) 2/ e 2 4
- . _11
.12 2 _a 3
- '*M 2 J 1 J 1
1 .l "... TOTAL 13 3 is 1 18 3 16 $, 6. 2/19 2 3 33 37 7 ~I 3 . 111 Q ,,,,,.8 3 33 1 C TOTAL'. le 3 15 1 17 5 13 l
- E
[ 4 l a g 3 1 2 1 ~2 3 l 2/20 2 1 .,,,,,1 _J 7 7 ~ 3 .l. 1 3 3. 7 TOTAL 15 3 12 2 13 8 7 TOTALS 44 5 39 4 40 18 25 1 t TOTALS 2 In nm nm nm i TOTai.s a IH DE ._n 32 n3 I owe TOTAL 2,1 st 240 34 :sv - 90 201. I ,3 sw
Y ._ - T2= mew.___, .,_f****9*.'La M: r^^ hhk. _m:%_ hhh h ? . E '.N - b ,. y r. m u/~'u ,/, oATE Toua Acc! DENTS YES = 2 YES = ND. YES = NO / 4- ,4 ,4 4 2 ^ 3 J d. L J. NAI* 14 14 *. 14 2 12 g 7 1 4 7 1 8 S/07 3 D 11 11 11 r o -..3 3 8 A. J 2. A. .l ME _34 _4 _3 00 1 33 9 25 s g 3 2 1 2 1 2 1 2/05 2 "T ~~ 7
- ~I'
"'~ ~ .i'. '. ' 3 "T T 7
- T "T
N#8-21 6 15 6 15 4 17 4 4 4 1 3 g 2/09 2 3 2 1 2 1 2 2 ..,,7, , ~ ~ '
- 'e 3
D ). 1 1 TOTAL. _9 2 7 _2 _7 2 7 2/SO 1 ~'~" ~~~ 3 E */ MAI-t 2 5 1 7 1 7 1 J __l. l. l. 3 4 2/ta 2 33 .Lt. 2. .za.
- s. A 3
L1 A .12. 2. .12. 2. L MAA= 37 a _29 _4 _33 _8 _29 - ~...: s ,3 ~ 2 2 2 2/S2 2 A 1 _, g_. 1 "1 T A. 1 3 .,,.,,) J k. ,,,k, _,l. i EA -I _15 _4 _11 _2 _13 _3 _12 l t 4 1 3 4 1 3 t g 2/83 2 7 "T "T "T "T "T 7 3 D ~5. 11 ~_ 1 ~~ I' Wal- _.21 _2 _19 _1 _to 3 18 t 2 2 2 1 1 t 2/14 2 7 7 7 2. Z. ~ ~ i 3 13 2. .12. 2. .12. i. .11. ^'* 11 L.11.
- l..k8 Z..L l
d, dd 1 d 2/ss 2 s. _1 1 3 _17 ' " ' _1 _19 ~~_5 ' _15 ~ TOTAt. 3~ 20 g 5 2 3 2 3 3 2 l 2/u 2 D 11 17 7 "T .....a.- 3 ,,,,,J l .,,,,1. 1, __1.
- k. 1
.:. d., ' WA3* 15 4 11 4 11 7 8 ,a .M g 1 1 1 1 -Q ~~ 2/17 2 3 _~,,, 1 ~~'" 7 1T .. ',y TOTAL. 13 2 11 2 11 __ 1 J 3 J 1. d A. l. 2 11 l ' k.~. 9
- t 3
1 2 1 2 1 2 " '."t 2/te 2 ~T ~_T 7 "_T 7 7_ -N 2 ..J-t. 1. f 2. ? 2. t 4.] - TOTAI. _21 _5 _16 _4 _17 _4 _15 ..-} ~ i --J 4 T -+ -+
- 4
- 2n, j
3 ,,_j "T ~T 2. t. 2. 7 q.,,,-- TOTA 4. 15 3 12 3 12 3 12 j g,* I N g A. l 4 l 2/20 2 6 A. A. d 3 J J 2. ,,,,,t,, .,,2. 2. 1. NAI= 13 4 9 4 9 4 9 s, a s l t tctats t 50 12 33 7 43 14 35 4 TOTAL.S 2 E 1M 1@ 1 1TI \\ TOTALS 3 ,,,f.) .11. .2,2,, .12. .12. .12, 1 l t l GRAND TCTAt. 282 51 231 37 245 88 214 I 4 l f
irukuMWW:EmsM51WN53M%#WL2*6?M!!@
- c.w. a~:n r:a, M
,,2 . m y o47s Tous Acc2cerrs m - wo m - no m. no ~] I .1 . 1 A. -.1 1. .A voa .1 .J. 3 1. .1 .:.2. 11 .A , A-1 man. 3 2 32. r 12 . 1. 1. 12 1 _2. .1 A. .1 _A. 1. L 3'c' = 2 1 1 2- _ 1 11 .22. 2. .1 .22.
- s. E 1
s. s. A.; 1 a. 2/oe a .12., s. 2. A. A. A. a. 3 a. A. S. 8. .2L 1A .1 E .1 JL ^ ..7 1 a. A s. A s. .A s. 3 n/o, a a s s 1 5 - #..a 3 2. .1 2. 2. .A .1 TOTA 's I- .L2. .1 12. _L 11. .,1 ll. '~ ..--,~ 2 L 2. 2. 1. .1 1 2. .1 z/so a .la. 2. 2. _A s. A A 3 A. i. 1. .1 .1 - '] LS. 1 .1.A. 1 LA.
- i. la.
1 2. 11 l. l. .l. 1 .i N N l -1 m a. .21. 2. .21.
- 2..22.
. 1 22. 1 2. .l. 2, 1 .,1 1 2 7 'IT via .12. t. A 3 s. .1 2. .1 22 1 Tofu. t .LS. L. 11.
- 2. 15.
- l. la.
I g 3 3 3 3 1 2/13 2 "T T T T ~7" ~ ~ 3 .1.L, t. Z. 1 .L2. t. 1 f, ,11, ,,1 JL 1 21 5 17 g 3 2 1 2 1 3 2/14 a T. A t. A. "T TT ( 3 . 3. .1 .1.9. .12 1E t .u. !..12. .1 A .1.1.1 1 -r s i s 1 5 l 2/13 2 la. L. E 33 2E 3 .1 2. _.1 _1 l TOTE 27 2 23 2A 25 5 22 ,g y. ~. ' 3 ""( J "T ~ "T ""~ 7 4 1 4 4 1 ed z/16 a _t l 3 2, 11 11 11 2.; U..- _10 ,2. 2..,.1 15 l r 1 -_1 3 3 3 _,,,.}t., ~ -i . ~ ~ :? n/sr a .ut TT T T ~. 3 2. 1. 1. 2. 2. .: - s e N AL ,23, , 1 _ 13 1s 2 13 } 2 1 1 1 4 1 1 i g .,,1 3 7 ""I "T ~ 2/te 2 ,M I d-N* ,,,L'-- L L 11 11 3 15 6 9 2 13 5 10 N~ l 1 l 1 1 1 .s i 2/1, 2 1 i 4 4 "T 7 7 + J .3 1 1,,,1 A ,,,,1, 33 c' 1L lA ",,, O g 1 1 1 1 i 2/20 2 3 *. ~~E ""I '""I ~~T "T 7 3 a _1 .,,,,1 .,,,,1 33 ^' TOTA ,}p, 4 4 2 s 4 6 ..~ - .i s TOTALS 1 59 16 43 14 45 19 40 \\ l TOTALS 2 3Q TT ffT ~ fit 2a TOTA 4.5 3 .32 .12 J1 "_"Y 3 "_II _II-1 GRAND TOTAL 250 58 222 37 243 66 214 i I l -4 ,1 e t
- ,
- 5.;gy.m n,:4 e or p/
Aneuumcs Tuu g/,e/cy DATs Tous Acczoswrs vss. NO Yes - . ys3 - NO, 1 .12. i 1 1 _7.- _1 _7. 2/06 r t. i i _L .2 3 a. 1 _a L, _n .18 i.n. i _n i.11
- -l 1
3 1 2 1 2 2 t 4 94 9M44 1
== _n. _.,u __. _25 _2, g 9 1 e 9 1 8 2/ce - 2 3
- 3. 3 33 33 3
707 % _18 _1 _17 18 2 _16 g d 11 11 2 UM 2 4 4 4 1 3 y 4 3 J.J, TOTE 6 1 5 1 5 1 5
- g 3
~ d 1 4 2 2 j 3 1 3 2/10 2 7 7 7 1 7 ~I 7 - ~' 3-1. _a _A _a _1 _a 3
- TOTE
_16 _6 _10 _3 _13 _4 _12 s' ' s
- a e
2/11 2 H 33 3T ~T IT 3 _.g. 1,,,,.i .,a _,,1 ,,,,,1 _,,1 TOTE 30 5 25 2 _28 _5 _25 ~ t 1 1 1 1 2/12 2 Y 7 ,_1 .,,1 1 4 7 3 _3. _1 _1 ,,,,1 ,,,,,1 33 g ,1 ,,,L1 . 5 15 5 15 1 2 2 2 1 1 2/13 2 a _1 1 1.12 3 _.a. _1 __t .22. 1.11 1.11 i.11 1 ~~ 2/14 2 g 4 3 h, 3 33 33 TOT 4 33 6 27 _2 _31 _4 _29 1 s 4 4 4 4 5 3 f 2/13. 2 .i.3 1. k2. L .A2. _.i..LL 3 A l 1 L 12 1 1 TCTE .1,j, .11, ,,Q _{0, to 12 22 l .. r 1 4 4 'f 2/16 2 3 33 4 2 2 l 3 ,1 .,,,1 ,,_i 'd ~ - 7 -'2 T 7_ 7_ TT TeT4 .-S.'s,,: 1 e
- ...j 2/17 I
--,d. 1 --.1 1 1 1 A 3 4. 1 1 A TOTE A _10 _4 _4 '_1 _9 _2 _8 l t
- 2 2
2 1 1 l y,j ve e 2/10 2 i _1 i 1 TCTE
- 20 4
,_16., 1 19 3 17 3 i i 1 1A A.11 l l 1 L 1 L _L 2/19 2 ,,,,,,1, l,_,,,,,1 J ,,,,.1 _1 1 1 3 _t. ,,,,,1 ,,_1 ._1 _,.1 i i, 707 4 13 _2 _11 2 11 1 -12 I 'e.' 'i 1 1 ( j 1 __i 1 _i 1 2/20 2 t. i I 3 I., ,k i _1 _1 1_ 1 707 4 14 2 12 2 12 3 11 b _W 'l .1" TOTA 4.S 1 _R .11 1 .11 i = !st d a s % -E.n i I OM YUIN 292 49 123 42' 250 45 227 I g e E--*4***-'*"*- ~ ~ 4 -... = - - r %.* -
? ge4/w . o,, = om m. Accio. e. m. w;- =. 4 4 l TOTE l _10. 3 .'.? _3 7 3 7-2 S, dE IE d N 2/of aa a a MAL = J Jg 1 46 3 44 .g 2 2 2 2 2/0e 2 ~Il 2X 2E -i a .13 A. L
- 2.. 12.
.22 1 .1.1.
- t. 1 Z.
.l., 2 -c u'* i s 2 LL _2.. Z. - ~'0 3 7 2 8 4 6 1 5
- Ifo, 2 y a
t ~ ~T ~ ~T ~ ~ ~T
- r * '.
TOTE T3 7 7_ ""a* Ti. TT ~ ,s- 'i 1 2/10 2. 3 ~M ~ W. ~ -. I' '. ~ ' - =. g ~_~1* "*T '"Y ~_T ~_~t" g 12 ,2, .it .,2. ' 1 1. .U., NE ~ v.. t 1 4 4 4 4 l 2/11. 2 ,1)
- 2. E 33 7 Y 3
l.1 L. LA. .L2. d 1. NAL= 35 3 _32 _1 _34 _6 _29 g 1 1 1 1 ~ ~ ~ 2/12 2 3 3Y TT 7 7 3 TOTAL. 13 _2 _11 _1 _12 _4 _9 2/13 2 1 1 1 = s. 1. _a NAl-y 3 17 1 17 1 17 -I ._) 3 3 . ]' ]3 ' 2/14 2 .,n 7 ""T ""T 7 j 3 L} .,,,,L .Lt,, 32 7
- T5*
NAl" j _JJ 6 27 4 29' 6 27 t 1 4 1 3 - 1-3 2 2 2/15.. 2 ',1) ,,,,,1. ,,1,1 1. ,,1,1 1. .12. 3 5 1. 4. 1. 1. t. TOTAL. 23 3 _20 _2 _21 4 19 [ t 2 1 1 1 1 2 ' I
- l. * ;
2/16 2 7 7 ,,,,,1, 4 ~~ 3 ,3 k _L L 7 l-TOTA 4. 14 _2 _16 2 6 _"IT -t t _4 JJ 1 3' 1. 3 2/17 2 ,;.2 L .1.L . 11 l 2 .,,,,,,,3 t 1 ,,,,,k L l y-. N* 2s t.12. 1 tt _8 .u. I g 3 1 2 3 1 2 k j 2/18 2 ~L1 ~~l 3 32 7 7 1 4..* . TUTE
- 5 5
to 4 21 7 18 3 . ::J' ~~ _1 1 1 1 L L n- .] 1 _1 1 1 1 l3 3 ~ ~T S 3 ,,,,,Lp 1 L 33 ',3 "."7 2/19 2 ) 'l ~ ,.i 16 5 11 2 14 3 T. .13 NAl* 1 i 2/20 2 [6 3 ~~~i 3 3 )! j - '* ~~I ~T 3 7 t ^* e TOTA 4. 13 3 10 2 11 2 11 e g %e.a. g T0743 1 49 11 38 7 42 15 34 .a TOTALS 2 25 2 El 2- "T5 j TOTALS 3 ,,Lu .23.11 .11 73 GRAND TOTAL. 335 62 273 38 297 45 270 1 l - - * - ~. " ~ - * * ~ - - ~ ~ ~ y-n.a. - - - : . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _}}