ML20237E635

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Affidavit of CA Daverio on Lilco Responses to Requests by Local Law Enforcement Officials for Public Safety Assistance.*
ML20237E635
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 12/16/1987
From: Daverio C
LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20237E542 List:
References
OL-3, NUDOCS 8712290101
Download: ML20237E635 (9)
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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-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

AFFIDAVIT OF CHARLES A. DAVERIO ON LILCO RESPONSES TO REQUESTS BY LOCAL LAW ENFORCEMENT OFFICIALS FOR PUBLIC SAFETY ASSISTANCE Charles A. Daverio, being duly sworn, deposes and says as follows:

, I. Qualifications

1. My name is Charles A. Daverio and my business address is Shoreham Nu-clear Power Station, P. O. Box 628, North Country Road, Wading River, New York 11792. I have been employed by LILCO since February,1976.
2. I was awarded a Bachelor of Engineering degree in Mechanical Engineer-ing in Feburary 1972 from Manhattan College, located in Riverdale, New York. In 1974, I attended a special summer program on " Nuclear Power Reactor Safety" at the Mas-sachusett Institute of Technology in Boston, Massachusetts. In February 1975 I earned my Master of Science degree in Industrial Engineering from New York University,10-cated in New York City.

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, 3. In 1972, I was employed by Cosentini Associates, located in New York, New York, where I was assigned to the Field Supervision Department. My primary functions included checking HVAC vendor equipment submittals against specifications.

4. From 1973 to 1974, I was employed by Ebasco Services, Inc., located in New York, New York. I served Ebasco Services, Inc., as a Project Coordinator with re-sponsibility for contract administration and coordination of Ebasco Engineering and De-sign efforts.
5. In 1974, I joined Stone & Webster Engineering Corporation (S&W), located in New York, New York, where I was assigned the position of Licensing Coordinator on the Jamesport Project. In May of 1974, I was assigned to LILCO's office to assist them in their licensing effort on the Jamesport Project. I remained in this position until 1976.
6. From February 1976 to January 1979, I was assigned as an Associate Engi-neer in the Licensing Section of LILCO's Nuclear Engineering Division. I was responsi-ble, except for the legal issues involved, for Jamesport's licensing under NRC regula-tions and rules. In this regard, I testified before the ASLB concerning compliance of the Jamesport site with 10 CFR 100 site suitability requirements.
7. In January 1979, I was appointed Section Supervisor of the Licensing See-tion. I remained in this position until November 1981. In this capacity, I was responsi-

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ble for generic licensing issues as they might affect Shoreham. In January 1980, I was given the additional responsibility of Chairman of the Emergency Planning Task Force and testified before the Advisory Committee on Reactor Safeguards on Shoreham's Emergency Plan. In January 1981, I assumed yet another role as Lead Licensing 1

Engineer for the Shoreham Public Hearings. In this assignment, I was responsible for working with the licensing legal team in the particularization of contentions, discovery, and development of testimony for the forthcoming hearings.

8. From November 1981 to April 1982, I served as the full-time Chairman of the Emergency Planning Task Force, reporting to the Vice President, Engineering. I was responsible for the completion of the Shoreham Emergency Plan, including the de-talled implementing procedures. Further, the Task Force was responsible for insuring proper training of all emergency personnel and for the overall coordination and review of state and local plans to insure that these personnel were prepared for the joint NRC/ FEMA exercise.
9. In April 1982, I was assigned to the Nuclear Operations Support Depart-ment, where I remained until January 1983. In addition to assuming responsibility for special projects in the regulatory area, in this capacity I provided consultation to the Emergency Planning Task Force, particularly regarding the Company's coordination with federal, state, and local officials. I was furthermore responsible for hearing prep-aration on Emergency Planning.
10. In January 1983, I assumed the position of Supervisor, Emergency Planning and Regulatory Services. In this capacity, I acted as the Company's primary contact with industry groups. I was responsible for research and development programs within the Office of Nuclear Operations. I provided support for the functioning of the Nuclear Review Board. Furthermore, my responsibilities included the implementation of LILCO's Emergency Preparedness Program. This involved administering both the onsite and offsite preparedness program.

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. 11. In March 1983,'I received a special assignment, serving as Assistance

~ Manager of the Local Emergency Response Implementing Organization. In this capaci-ty, I provided supervision for thirty professional and four administrative staff person-nel. The end product was the development and implementation of a Local Emergency Response Plan in which utility personnel performed offsite emergency preparedness functions.

12. From July of 1984 to April of 1986, I was Manager of the Nuclear Emer-gency Preparedness Division. In this position, I was responsible for maintaining the Shoreham onsite and offsite emergency preparedness programs. This included proce-dures development, training drills and exercises. Also, I was responsible for budget and schedule control. I had an approved staff of eleven professionals and three administra-

_tive. support personnel. In addition, approximately ten to fif teen consultants were used to support the program.

13. From April to November 1986 I was the Assistant to the Vice President of Nuclear Operations. I provided direct support and assistance to the Vice President for a seven hundred person organization covering quality assurance, engineering, op-erations and all support for the Shoreham Nuclear Power Station. This position re-quired a working knowledge of all facets of the nuclear program. I prepared special re-ports and studies as directed and advised the Vice President on matters requiring his personal attention. I maintained office continuity in the absence of the Vice President and represented the Vice President in both industry and in-company meetings. I man-aged many special projects for the Vice President and interacted directly with senior corporate management. I also provided policy clarification and advice to the personnel within the Office of Nuclear Operations.

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14. In November of 1986 I assumed the position of Assistant Department Man-ager, Nuclear Operations Support Department. This Department is comprised of the l

! following divisions: Security, Emergency Preparedness, Financial Services Licensing and Contract Administration. In September of 1987 I became Manager of the Nuclear Operations Support Department.

15. My training also includes the Westinghouse Electric Corporation's PWR Systems Introduction Course and the Massachusetts Institute of Technology Special Summer Program on " Nuclear Power Reactor Safety."

II. LILCO's Responses to Requests by Local Law Enforcement Officials for Public Safety Assistance

16. Long Island law enforcement officials regularly call upon LILCO employ-ees for assistance in the conduct of law enforcement and public safety duties. Follow-ing are specific instances in which LILCO employees have become involved in public l

l safety activities at the request of locallaw enforcement officials.

A. Civilian Radio Motor Patro_1

17. LILCO vehicles comprise one quarter of the 1,600 radio-equipped vehicles in the Civilian Radio Motor Patrol (CRMP) coordinated by the Nassau and Suffolk Coun-ty Police Departments. The CRMP is a neighborhood watch effort in which drivers of participating vehicles and their dispatchers relay emergency radio messages to police.

LILCO has participated in the CRMP program since January,1986.

18. In 1986, five of the eight CRMP awards in Suffolk County went to LILCO employees. William Smith, a LILCO gas service technician, was commended for in-forming police and a LILCO electric service crew of an accident in wh!ch an

ambulance struck a utility pole. While waiting for police to arrive, Mr. Smith blocked the accident scene with his vehicle and warned passersby to stay away from a fallen electric wire. l

19. LILCO electric emergency serviceman William Coulter was commended for rendering first aid to a man suffering a seizure along a roadside in Sound Beach.

Mr. Coulter radioed for medical assistance and then set out flares and began emergency first aid.

20. James O'Donnell, a LILCO gas serviceman, was commended for helping an injured jogger in Coram. Mr. O'Donnell covered the injured man with his jacket and di-rected traffic while an off-duty nurse assisted the victim until an ambulance arrived.
21. William Fredericks, another LILCO employee, was commended for stopping his overhead lines truck on the Montauk Highway in East Patchogue to assist at the scene of an automobile accident. Mr. Fredericks turned off the ignition of an overturned van leaking gasoline ento the highway and directed traffic away from the accident until police and fire units arrived.
22. The 1986 Suffolk County awards were presented by Suffolk County Execu-tive Peter Cohalan during a ceremony in the Executive Offices of the County.
23. In Nassau County in 1986, two of six CRMP awards went to LILCO teams of field workers and their dispatchers. In 1987, three of nine awards went to Nassau County LILCO teams. LILCO lineman Robert Ennist received one award for pulling his truck in front of two homeless men lying in an intersection in East Meadow. Mr. Ennist I

turned on his flashing lights and set out flares to protect the men until the police arrived.

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B. Electric Emergencies

24. In the following instances, LILCO employees worked with law enforce-

. ment officials to direct traffic and secure public safety around downed power lines:

a) On March 31, 1987, Suffolk County Police reported a service wire down and blocking Third Street in Huntington. A LILCO emergen-cy service specialist was dispatched to the scene. The police re-mained at the scene until LILCO personnel arrived and then re-quested permission from their department to leave. The police lef t the scene before repairs were completed. LILCO personnel main-tained public safety until the job was completed.

b) On October 7,1987, Nassau County Police reported to LILCO a leaning utility pole and low hanging wires over Ludlam Avenue in Bayville. LILCO dispatched an emergency service specialist who determined that the wires had been caught by a passing truck, causing the pole to lean. The LILCO emergency service specialist temporarily elevated the wires using the bucket on his truck, set out traffic cones around the obstruction, and directed traffic while awaiting the arrival of a New York Telephone Company crew to re-place the pole.

Two Nassau County police officers were at the scene when the

' LILCO emergency service specialist arrived. However, the officers lef t the area af ter traffic cones had been set out. The LILCO emergency service specialist continued to direct traffic around the obstruction until repair crews arrived.

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c) At about 10:30 pm on December 2,1987, LILCO received a report from a dispatcher at the Suffolk County Police Department that a vehicle had struck an electric utility pole on Oak Street west of Route 12 in Medford. LILCO dispatched an emergency specialist to the scene. The LILCO amergency service specialist arrived at the scene and reported that the pole was broken 20 feet above the ground and that telephone and cable television wires hung about 9 feet over the roadway.

The LILCO service specialist requested a repair crew and then as-sisted the Suffolk County Police in directing traffic around the downed lines. At about 1:00 am the police notified the LILCO ser-vice specialist that he (the policeman) had been ordered to leave the scene. The police officer placed flares around the scene and left. The LILCO service specialist continued to direct traffic around the downed lines until, at about 2:00 am, a LILCO repair crew arrived.

C. Ad Hoc Assistance

25. On February 13, 1986, the day of the Shoreham FEMA graded off-site emergency planning exercise, two LILCO employees participating in the exercise were requested by the Suffolk County Sheriff's Department to assist in an emergency re-sponse unrelated either to the emergency planning exercise or to LILCO's normal course of business.

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26. A road crew consisting of two Local Emergency Response Organization (LERO) workers in a LILCO wrecker truck had been dispatched from the Riverhead Staging Area to the intersection of Edwards Avenue and Route 25. Shortly af ter arriv-ing at their assigned location, the LERO workers observed a trailer pulling a mobile home turning south onto Edwards Avenue. A tire on the trailer was on fire. The LERO workers used the fire extinguisher on the LILCO wrecker truck to put out the fire. The trailer driver then discovered that the trailer had become stuck in the mud. A Suffolk County sheriff's deputy accompanying the trailer asked the LERO workers to use the LILCO wrecker to extract the trailer from the mud. The LERO workers contacted the LERO Brentwood Emergency Operations Center and received permission to use the LILCO wrecker. ' However, the LERO workers were unable to free the trailer and the sheriff's deputy radioed for a larger wrecker truck.

The foregoing facts are known to me to be true and correct to the best of my knowledge and belief. I am competent to testify to such f acts, and would so testify if I l

l appeared as a witness in a public hearing on this matter.

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Ab'!/)$N Charles A. Daverio Subscribed and sworn to before me this./d> ay of (cmduj,1987.

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