ML20235N164
| ML20235N164 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/24/1989 |
| From: | HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20235N111 | List: |
| References | |
| OL-5, NUDOCS 8903010073 | |
| Download: ML20235N164 (21) | |
Text
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'89 FEB 27 All:56 UNITED STATES OF AMERICA
'?,/
NUCLEAR REGULATORY COMMISSION'"I
)-
Before the Atomic Safety and Licensing Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-5R
) (EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)-
LILCO'S REBUTTAL TESTIMONY ON CONTENTION 18
-(COMMUNICATIONS EQUIPMENT AND RECEPTION FAILULES)
)
)
Hunton & Williams
)-
707 East Main Street P.O. Box 1535 Richmond, Virginia 23212
)
February 24,1989 89030100738%$22 PDR ADOCK O PDR T
l y
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
)
Before the Atomic Safety and Licensing Board
. In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-5R
) (EP Exercise)
(Shoreham Nuclear Power Station,
)
)
Unit 1)
)
LILCO'S REBUTTAL TESTIMONY ON CONTENTION 18
)
(COMMUNICATIONS EQUIPMENT AND RECEPTION FAILURES)
)
)
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212
)
February 24,1989 3
)
l 3
1
LILCO, February 24,1989 l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the A tomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-5R
) (EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S REBUTTAL TESTIMONY ON CONTENTION 18 (COMMUNICATIONS EQUIPMENT AND RECEPTION FAILURES) 1.
Q.
Please identify yourselves.
A.
[Crocker] My name is Douglas M. Crocker, Manager of Nuclear Emer-gency Preparedness for the Long Island Lighting Company.
[ Schwartz] My name is Perry L. Schwartz. I am President of Intertech Associates, Inc., a firm of communications and electronics consulting en-gineers.
[Siegel] My name is Richard M. Siegel. I am Manager of Electric System Operations for LILCO.
)
2.
Q.
Please summarize your prof essional qualifications.
A.
[Crocker] Mine are summarized in LILCO's written rebuttal testimony on Contention 1, the " scope" contention.
)
[ Schwartz) I am a licensed professional engin
- r. I hold a national first class engineering license with master endorsements in wire and radio
)
communications. I am a senior member of the Institute of Electrical and
)
. Electronic Engineers. I have taught electrical engineering at the City
)
College of New' York and telecommunications at Rutgers University. I have served as communications engineer for more than 35 municipal and.
coimty government agencies for the purpose of designing radio and tele.-
)
phone facilities for police, fire, and public safety functions.
[Slegel] The Protection Division / Communications Section is responsible.
for all radio commiudcations on the LILCO system, including the LERIO radio system. This includes design, licensing, procurement, testing, and maintenance functions. This division reports directly to me as Manager of Electric System Operations; as a result, I have general knowledge and re-y sponsib' ility for all activities in this area.
I. Contention 18 (Eauipment and Reception Failures) y 3.
Q.
Contention 18, as admitted by the Board, states as follows:
NRC regulations require that LILCO demonstrate that provisions exist for prompt communications between
)
and among emergency personnel and the offsite emergency response organizations.
10 C.F.R. S 50.47(b)(6); NUREG-0654 S ILT.
In an attempt to meet this essential element of emergency planning, LILCO has issued radios to its field workers so that
)'
they can communicate with personnel managing _the emergency response, and has further installed tele-phones and other such communications equipment at various iacilities irom which an emergency will be managed. See Plan, S 3.4; OPIP 3.6.3 at 3d. The Ex-ercise revealed that this communications system is not reliable, as many LILCO personnel were unable to
)
communicate with other personnel due to malfunc-tioning equipment or other problems.with reception or transmission.
This pattern of communications breakdowns, which were numerous, widespread and pervasive, constitutes a fundamental flaw, as it would
)'
severely impede an adequate response by emergency personnel in the event of an actual emergency at Shoreham. LILCO has therefore failed to satisfy EOC Objective 4, FA Objective 4 and BHO Objective 4, and
)
\\
-3.
F '
L it has further f ailed to comply with the foregoing reg-ulatory requirements, thus. precluding a finding of i
reasonable assurance that adequate protective mea-sures'can and will be taken in the event of a ra-
. diological emergency at Shoreham, as required by 10
[
C.F.R. S 50.47(a)(1).
l Equipment problems such as those noted below might L
. ordinarily ' be viewed as day-of-the-exercise type problems-which are easily correctable.. For Shore -
l.'
ham, however, no such finding is possible. Since the 1986 exercise and the results of the training drills conducted af ter the 1986 exercise, LILCO has been on notice of' the importance of. effective communica-l tions. The fact that so many equipment-related prob-lems arose in 1988 is illustrative of the failure of LILCO.to devote necessary attention to the details of-communications..
These problems are likely cor-rectable but not e:tsily. Rather, the numerous break.
l~
' downs in the LILCO communications system indicate that LILCO must review and revise that system ex-tensively before the communications failures revealed by the Exercise can be remedied. Substantial training y
of LILCO personnel will also be required.
~
The fact.that FEMA found no deficiency relating to p'
these matters is not dispositive. Not only did FEMA not address many of these problems, the problems it did address were looked at in isolation, rather than collectively. When looked at collectively, the prob-lems addressed in this contention, if established,
)'
would preclude a reasonable assurance finding and re-quire a finding that. LILCO's Plan is fundamentally flawed.
Examples of communications, equipment and recep-tion problems during the Exercise were as follows:
p B.
Between 11:00 a.m. and 11:20 a.m. on Day 1 of the Exercise, LILCO lost all radio contact with field
[
workers in the vicinity of Port Jefferson. Heavy stat-ic af terward further impeded effective communica-i, tions and unnecessarily delayed ' a receipt of the
)-
first free-play message and consequently delayed the I
response to that message. See FEMA Report at 42.
E.
At times, radio traffic on the evacuation sup-port communications frequency was so heavy that no further message traffic could be handled. This would
)
have had the potential in a real emergency of delay-ing the transmission and receipt of priority messages.
y
1 G.
- LILCO documents'also appear to indicate that
. the RECS (dedicated) telephone system did not func-tion properly in some instances.
Are the three examples cited in the contention evidence of! pervasive or -
widespread breakdowns in the LERO communications system?
A.
[Crocker] No.
4.-
Q.
- Why not?
A.
[Crocker] The first " example" given in the contention, subpart B, is a minor, a_d hoc problem that was easily and quickly_ corrected during the Exercise. Moreover, the alleged problem did not adversely affect LERO's
. performance during the exercise.
The second " example," subpart E, is nothing more than speculation.
by Interveners that has no basis in what actually occurred during the Ex-ercise and that fails to take into account that LERO demonstrated its -
ability to compensate, as necessary, for occasionally heavy radio traffic.
Subpart G does not describe an equipment f ailure at all.
Basis G: The RECS Line
)
5.
Q.
Let us start with subpart G then. Are you saying that during the exercise the RECS telephone system did, in f act, function properly?
A.
-[Crocker] Yes.
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6.
Q.
Then why do Interveners claim that LILCO documents " appear to indi-cate" that the RECS did not function properly in some instances?
A.
[Crocker] The only LILCO document that references any alleged problem with the RECS (Radiological Emergency Communications System) is the EOC RECS Communicator's Log for Day 2 of the Exercise, which is the Attachment to this testimony. fhe log states that during the RECS test q
at 0815 " EOF RECS phone not ringing but they will monitor all day, We h
i L
b r
can hear & speak to each other however,".In fact, EOF procedures call for the EOF RECS communicator to continuously monitor the RECS line; i
he' or she opens the line and basically does not hang up for the. duration.
The EOF communicator has a head phone and a speaker phone arrange-F ment in' addition to the conventional telephone instrument.. This is be-cause RECS. messages for the most part originate from the EOF rather than come in to the EOF. When other people with RECS phones want:to N
talk to the EOF, they lif t the line and the EOF RECS communicator, since '
he continuously monitors the line, answers immediately. The line cannot -
.3 ring because it is already " answered." Thus, during the Exercise the RECS d
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system was working as it should.
' 7.
Q.
How is it that you are aware of what these specific procedures require?
' A.
[Crocker] I am. the manager of Nuclear. Emergency Preparedness for
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' LILCO, and I am responsible for both onsite and offsite emergency plan-ning for Shoreham. As such,I am generally knowledgeable about the plans and procedures used by emergency workers in the various emergency f a-
).
cilities. In addition, I serve as the Emergency Planning Advisor #1 in the LILCO Onsite Emergency Response Organization. This position is as-signed to the EOF and is responsible for advising the Response Manager on jf The RECS Com-plans, procedures, and resources during an emergency.
i municators report to me. My post in the EOF is near the RECS Communi-
)
cator, and I have directly observed his actions many times.
Basis B: Static and Loss of Radio Contact
'8.
Q.
With respect to subpart B of the Contention 18, is it true that for 20
)
minutes during Day 1 of the Exercise LERO lost "all radio contact with.
field workers in the vicinity of Port Jefferson?"
4
.,___.__.____m It
-g.
A.
[Crocker] It is not entirely true. The problem affected only-the Traffic Guide radio frequency for those Traffic Guides dispatched out of the Port-Jefferson Staging - Area; not all the field workers are dispatched from there.
< 9.
Q.
Does LILCO know what caused the Traffic Guide radio problems that.oc-
- curred during the exercise?
A.-
[Crocker] Yes. There was a malfunction of a piece _of equipment called
- a " duplexer."
- 10..
Q.
What is a " duplexer"?
A.
[Crocker]
The Port Jefferson Traffic Guide ' frequency and the
. Downwind Survey Team frequency share a common base station antenna on the meteorological tower at Shoreham.
The " duplexer" is located
~
there. The duplexer is a piece of equipment that takes two transmitted signals from the-two base stations and cdmbines them into one so that both can be transmitted over the same antenna. Conversely it splits re-ceived signals from mobile radios into two signals to the applicable base y
stations.
11.
Q.
What happened to the duplexer on the first day of the exercise?
A.
[Crocker] During the morning of Day 1 of the Exercise the duplexer malfunctioned and sent out a signal on the Traffic Guide frequency that manifested itself as a buzz or static on some of the Traffic Guide mobile
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radios and the Port Jefferson and EOC base stations. At first it was rela-tively unnoticeable, but it became intermittently worse and apparently started to affect radio traffic adversely.
l
_ _ _ _ 12.
Q.
Did LILCO fix this problem during the exercise?
E A.
[Crocker) Yes. When the LERO communications technicians who moni-tor radio communications realized the problem, they immediately con-tacted the EOC.
A' radio technician was dispatched to the transmitter,.
F where he diagnosed the problem as beh g the duplexer. He went to the duplexer and changed it over to the back-up unit, which sits next to the -
primary unit. The process consisted of changing the input and output ca-T bles.
13.
Q.
How long did it take to fix the problem?
A.
[Crocker]
The radio technician recalls that it took him about 10 to 15 -
minutes to switch from one duplexer to the other. Radio communication on that frequency was essentially stopped while the duplexer was being replaced.
14.
Q.
Did the problem recur during the exercise?
A.
[Crocker] No. The back-up unit functioned well during the rest of the I
exercise.
15.
Q.
Did fixing the problem as you described require any change or revision to the LILCO Plan?
y A.
[Crocker] No.
16.
Q.
To your knowledge, had this problem ever occurred before the exercise?
J-A.
[Crocker] No.
17.
Q.
To your knowledge, has the problem occurred since the exercise?
A.
[Crocker] No.
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2
_m
(
.-8--
i 18._
Q.
Is is true that' even af ter' the problem was corrected, " heavy static" led to a delay in LERO's response to a free play impediment message?f e
[. Crocker] No. Although there was a static problem with one Traffic A.
Guide radio where the impediment was introduced, this appears to have been an isolated incident due to a " dead spot"in radio coverage. When the
)
Traffic Guide moved his car, the static subsided enough to get the mes-sage through.
Certainly the static problem caused no delay in the handling of the
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impediment. _ The impediment was introduced in the field by the FEMA Controller / Evaluator at 1125. The information was radioed in to the EOC at approximately 1128, and the response started immediately. The situa-
)
tion was explained to the simulated Suffolk County Police at 1145.'
Rerouting directions were given to the Traffic Guide at Traffic Control Post 47 at 1154. LERO Road Crews and Route Spotters arrived at 1212 to clear the impediment.
19.
Q.
What did FEMA say about this?
)
A.
[Crocker) With respect to the EOC msponse, the FEMA Report at 42 says the following:
Direct radio communications with field workers in
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the vicinity of the Port Jefferson staging area was lost between approximately 1100 and 1120 hours0.013 days <br />0.311 hours <br />0.00185 weeks <br />4.2616e-4 months <br />. The Evacuation Support Communicator for staging areas indicated that the secondary system of dedicated telephones to the staging area and of radio to the field workers was being implemented. For some time
).
thereaf ter, significant static caused a delay of 10-15 minutes in the receipt of the first free play impedi-ment message and verification of that message to the satisf action of the Traffic Control Coordinator.
With respect to the field response, the FEMA Report at 76 says the fol-lowing:
J-
'4.
y
-9.
Initially, the ~ personnel' at the-TCP had difficulty in
~l communicating the details of the impediment to the-
~ LERO EOC because of an apparent dead spot in the u
radio coverage. After the vehicle equipped _with the-l radio was relocated (a short distance away, but still at the site of the impediment), the message was trans-mitted to the LERO EOC.
Instructions were re-ceived, and communication was. completed without j
F any further difficulties.
FEMA did not give any ARCAs or ARFis for this minor problem in mes '
f sage receipt and verification. FEMA had no a'dverse comments at all with'
]
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respect to LERO's response.to the impediment or to the amount of time
]
1 LERO took to respond.
l Basis E: Heavy Radio Traffic
-j
).
Under the LILCO Plan, who uses the " evacuation support communications 20.
' Q.
irequency" referred to in Contention 18.E?
A.
[Crocker]
This frequency is used by LERO Road Crews, Evacuation
)
Route Spotters (including the Route Spotters in helicopters), and one of j
the Evacuation Support Communicators (base station) in the EOC.
. 21.
Q.
Subpart E of Contention 18 says that at times radio traffic was so heavy
)
that "no further message traffic could be handled" and that this "would have had the potential in a real emergency of delaying the transmission and receipt of priority messages." Do you agree?
A.
[Crocker) No. Although radio activity was heavy on the Road Crew fre-quency when LERO was responding to three impediments, LERO's radio system is capable of working during a wide range of radio traffic. Also, LERO workers are taught to prioritize messages - for example, impedi-1
' ments are generally given first priority - s.nd to use proper radio protocol and etiquette. Also, back-up methods of communication are available to transmit and receive messages between field personnel and the EOC, in-
)
cluding commercial telephones and other field worker frequencies. The f
.n s 1 l allegation that additional radio traffic "would have had the potential" to L
delay' priority messages is pure conjecture. In fact,' priority : messages.
1 were not delayed during the Exercise.
22.
Q.-
. What'did FEMA say about this?
)
A.
[Crocker]- The' FEMA Report at.42 says the f011owing:-
, Between 1300 and 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />, when all three evacua-tion impediments were active, traffic on the radio of the Evacuation Support Communicator ' for road F
crews, road spotters, and helicopters was very heavy.
The involved staff responded appropriately by giving -
priority to communications concerning the _evacua-tion impediments.
Additional. impediments might
~ have resulted in delays in some priority messages. In.
extreme situations, route spotters could communicate
).
with the LERO EOC via commercial telephone.
23.
Q..
_ Did FEMA give any ARCAs or ARFIs with respect to this observation re-garding "very heavy" radio traffic?
A.
[Crocker] No.
24.
Q.
Do the results of the exercise suggest that a significant reassessment and revision of LERO's communications procedures and equipment are neces-sary?
)-
A.
[Crocher] No. In fact, the system worked as it was designed to do. In those minor instances where repairs or modifications were necessary, the system allowed LERO personnel to fix the problem promptly and return
)
0-the system to full operation. There is no need to significantly revise LERO's communications plan, procedures, training, or equipment..The minor problems gave LERO the opportunity to demonstrate the reliability
)
of its communication network and its ability to respond to unanticipated events.
1 J.
F
,-11 ~
II.' Improvements in Communications E
25.
'Q.
What improvements have been made to the LERO radio system since the 1986 exercise?
A.
[Crocker] Several types of changes were made to the system after the 1986 exercise.~ We reallocated frequencies and restructured the paths by
)'
which information is passed between the field and the EOC.
26.-
Q.
Please explain what you mean by " reallocating frequencies."
)
A.
[Crocker] Transfer Point Coordinators formerly communicated on the same frequencies as the Traffic Guides. Now they communicate on a dif-ferent frequency, thereby reducing the number of people on the Traffic
)
Guide frequencies by 12. The frequency assigned to the Transfer Point Coordinators will normally have only 12 users.
27.
Q.
Please explain the phrase " restructured the paths by which information is '
)
passed between the field and the EOC."
~
A.
[Crocker] In Revision 6 of the LERO Plan, which was the plan exercised in 1986, communications from Traffic Guides and Transfer Point
)
Coordinators were relayed through the appropriate Staging Area to the EOC. Similarly, messages from the EOC went first to the Staging Area and then were relayed to the Traffic Guides or Transfer Point.
)
This approach was changed before the 1988 Exercise.
Traffic Guides now communicate directly with the EOC. The Staging Area Com-munications Staff monitor the transmissions but are not active unless they j1 are needed as a backup. Similarly, the Transfer Point Coordinators com-municate directly with the EOC on their own frequency, as explained above.
y J
-12 '
' Communications between the-field and the EOC are-much im-
- proved by the elimination of the middle step in the communications net
- -
communications are quicker and more accurate.
m
' 2 8.-
Q.
What other improvements were made to the LERO radio system? ;
A.
[Crocker, Siegel] All'the field worker radios _ (Traffic Guides, Transfer Point Coordinators, Evacuation Route Spotters, and Road Crews) were re-placed with new radios purchased from General Electric. Features of these radios include tone-coded squelch, a "30-second time-out," weather-proof speakers that are mounted on the outside of Traffic Guide vehicles,.
l improved power cords, and new antennas.
29i Q.'
What is the "30-second time-out" feature?
. A.
[Crocker, Siegel] It is a timer that does not permit a radio to transmit I
for more than 30 seconds without rekeying the transmit button on the mi-crophone. This is a standard feature on LILCO radios. Interveners claim l
in their testimony (Int. Test. (Cont.18) at 37) that accidental prolonged 1
keying of the radio microphone will render a radio channel inoperable.
L l
The 30-second time-out feature in the LERO radios ensures that this could happen for at most only 30 seconds. 'If someone must transmit a m'essage longer than 30 seconds, he must momentarily release the key, press it in again, and resume broadcasting his message. LERO personnel are trained.
i l
l.
to operate the radios this way, and it works quite smoothly.
)-
30'.
Q.
What other improvements were made to the LERO radio system af ter the
]
1986 exercise?
h A.
[Crocker, Siegel] New base station transmitters were installed at L
)
e
-13 '
1 1
1.'
. Shoreham for Transfer Point Coordinators; L
2.
Brentwood, Hauppauge, and Riverhead for. Road Crews and Route Spotters; and 3.
Brentwood and Patchogue for Traffic Guide radios.
}l 31.
Q.
Is the description of the'LERO radio system presented in Interveners' tes-timony accurate?
A..
[Crocker, Siegel] Some corrections need to be made. Interveners de.
T scribe the Port Jefferson Traffic Guide radio channel as being transmitted-from Patchogue and suggest that this location is partly or wholly responsi-ble for the alleged radio problems (Int. Test. (Cont.18) at 43). In f act, the i
)
' channel is broadcast from the antenna on the meteorological tower at-Shoreham.' And, contrary to Interveners' suggestion (Int. Test. (Cont.18)'
at 43), this transmitter is properly licensed.
32.
'Q.
Do you have any other comments on Interveners' written testimony?
A.
[Crocker, Siegel] Yes. Most LERO transmitters have a backup transmit-ter next to them. All that is required to switch to the backup transmitter is to turn on the power and switch the antenna output cable from one to the other. This redundancy makes it very unlikely that a channel will fall for any significant period of time. Furthermore, new transmitters were
)_
purchased just this year and have proven to be quite reliable. The possi-bility of complete channel failure hypothesized by the Interveners (Int.
)-
Test. (Cont.18) at 22, 37, 38) is therefore very unlikely.
33, Q.
Is the LERO radio system similar to any other system used by LILCO?
A.
[Crocker, Siegel] Yes. The radio system used by LERO is similar to the 1
).
system used daily by LILCO in the course of its normal business. On the 21
' ~
m i
) -
l i
'LILCO' system, many vehicles are' assigned to a single channel. LILCO
.uses a total of 14 channels.to; coordinate many radio-equipped vehicles.
)
E J
For example, one such channel is the Hicksville Electric Lines channel, which services 50 units typcially and up to 123 units in emergencies such
).
as storm restoration. LILCO responds both to routine business calls and to 1
emergencies using these radio systems. The systems have performed ade-
]
. quately.
);
4 34.
Q.
What other actions, aside from physical improvements, did LILCO take to assure that its radios function properly?
A.
[Crocker] LERO training was updated to include the following subjects:
)
1.
good operating practices,.
- 2..
emergency messages, 3.
radio communications protocol, and
)' '
4.
corrective actions in response to radio problems.
35.
Q.
What is the significance of this training?
A.
[Crocker] It teaches the LERO field workers how to use their radios to l
j best advantage; how to minimize radio use and keep messages short, con-sistent with completeness; and how to interject priority and emergency
)
messages.
j
.36.
Q.
Have people in the EOC received improved training designed to improve lateral communications?
)
A.
[Crocker] Yes. The trainers now emphasize the need to pass on all im-
)
portant information to the appropriate people. This includes both verti-cal and lateral communications. We make a point of teaching them that
)
y information they may have will be needed by other groups within LERO.
We also teach them that if they perceive that another group has l
I J
l l
i -
information they may need but ; cannot get' for whatever reason,' they.
should go to their own supervisor and ask for help in getting the informa-L tien.
37.
Q.
Were there " lateral" communications during the 1988 Exercise?
-A.
' [Crocker] Records generated during the Exercise show that a good many lateral communications within the EOC were involved in clearing the road impediments. There were at least 13 recorded messages from the Traffic y
Engineer to the Traffic Control Coordinator, one from the Traffic Engi-
- neer to the Traffic Control Point Coordinator, three from the Traffic i
Control Point Coordinator to the Control Cell, two from the Traffic Con-y trol Point Coordinator to the Emergency Preparedness Advisor, and one from the Road Logistics Coordinator to the Emergency Preparedness Ad-f visor. There was, in short, a significant amount of lateral communication in the EOC about the traffic impediments.
38.
Q.
The Suffolk County witnesses appear to favor the Suffolk County Police
)
communications system over the LERO system. What do you think about this?
A.
[Crocker] The County has a very good communications system. In a real eniergency, in contrast to an exercise, the County system 'would be avail-
):
able to the Police as they responded to the emergency. Both the LERO and the County systems would be available, would complement each other, and could serve as backups to each other.
)
III. Lateral Versus Vertical Communications 39.
Q.
Mr. Schwartz, why are you testifying here?
)-
A.
[ Schwartz) I was asked by LILCO to provide an independent assessment of the LERO communication system, insofar as it is challenged by Suffolk County's written testimony.
)
' 4_
m
. :.y
~
0 '
t i
Can you explain the concept of vertical versus lateral communications as -
40.
-Q.'
it applies to the task of responding to a Shoreham emergency?
e
'7 "A.
(Schwartz] ' The fundamental difference between vertical and lateral communications has'to do with the purpose'of the communications. The L.
primary conceptual difference is between a precision' military-like op-:
eration with 'a single objective and a police function with many varying ;
objectives.
In the precision military operation the objective is well-defined:
the participants are instructed in detail as to the individual functions, and
-strict discipline and adherence to detail are required. This type of op.
eration requires no lateral communications and minimal vertical commu-nications. Although LERO is not a structured military organization, the,
procedures used by LERO generally fit this type of operation.
In a police communication system or even a regional public safety communication system (and I have designed more than'35 such systens),
communications must function both vertically and laterally. The testimo-ny offered on Contention 18 by Suffolk County Police is limited to the-
)
functioning of communications systems in a police-type operation.
41.
Q.
Do you have an opinion on the police testimony about channel lockup?
A.
[ Schwartz]
The police's criticism based on the possibility of channel lockup by activation of the microphone switch is incorrect. All new radio equipment is supplied with a device known as a " time-out timer," which
)
af ter 30 seconds or less disables the unit's transmitter. This device pro-tects any radio system from this type of open transmitter hangup.
1 3
p
_17. --
-42..
Q.
Please comment on channel congestion.
~.
[ Schwartz] Channel congestion is a function of the operating concept.-
A L
' A standard public safety radio system (police function) of ten operates with 40 to 50 mobile and portable radios on a single channel._ It is not the -
)
.-number of total users on a channel that.is so important, but rather the need for them to communicate with the central dispatcher. If they can -
function in a preplanned manner with advisories from dispatch, the sys-L tem will never be overloaded.'
- 43. -
Q.
Please comment on the possibility of battery fallure.
A.
[ Schwartz] Mobile radios are designed to function off the 12 VDC of an automobile. The current drain of these radios is in the' milliamp range
.(1/1000 of an amp or 10-3 amps) in the standby position and one or more' g
amps when. transmitting. An automobile battery when charged with the:
engine off is capable of providing approximately 80 amperes or more for-one hour without the engine running. This would enable a mobile radio to transmit on a continuous basis for more than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> and still provide
)-
sufficient power to start the vehicle.
Police mobile radios also operate on car battery power, but police I
)
vehicles typically have heavy-duty batteries to support the lights, flashers and radios with the engines off.
44.
Q.
Is the range of the LERO radios sufficient?
)
A.
[ Schwartz) The power output of the portables and mobiles is adequate to cover a talk back to a repeater within 15 miles and talk out from base / repeater sufficient to reach portables and mobiles on a 90% basis
)
(90-90) over a 15-mile radius.
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A
-_ t 45.
.Q.
Are there enough dispatchers?
L-A.
[ Schwartz] On a continuing basis two dispatchers nandle 60,000 tele-phone calls per year and eight radio channels in at least four of my cli-ents' systems. In the case of a Shoreham emergency we are dealing with a
)-
single accident over a relatively short period of time. A single dispatcher j
should easily handle four radio channels.
46.
Q.~
Does this complete your tes:imony?
A.
[ All] Yes.
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I ATTACHMENT
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TO LILCO'S REBUTTAL TESTIMONY ON CONTENTION 18 (COMMUNICATIONS EQUIPMENT AND RECEPTION FAILURES)
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