ML20237E860
| ML20237E860 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/18/1987 |
| From: | Lieberman E KLD ASSOCIATES, INC., LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20237E848 | List: |
| References | |
| OL-3, NUDOCS 8712290229 | |
| Download: ML20237E860 (5) | |
Text
)
LILCO, December 18, 1987 e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensine Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
l Unit 1)
)
l AFFIDAVIT OF EDWARD B. LIEBERMAN IN SUPPORT OF LILCO'S MOTION FOR
SUMMARY
DISPOSITION OF THE HOSPITAL EVACUATION ISSUE l
Edward B. Lieberman, being duly sworn, deposes and says as follows:
1.
I am President of KLD Associates, Incorporated, whose business office is 10-cated at 300 Broadway, Huntington Station, NY 11746. My professional qualifications are bound into the record following transcript page 17,421 as part of LILCO Exhibit 1 in the reception centers remand proceeding.
2.
Under my supervision and direction, LILCO calculated specific evacuation time estimates for the three hospitals in or near the Shoreham 10-mile Emergency Plan-ning Zone (EPZ). They will be contained in Revision 9 of the LILCO Plan, along with a list of the assumptions used in calculating them. I participated in the development of the pro-cedures and assumptions used in the calculations, and have reviewed the resulting time es-timates.
3.
Most of the procedural steps and assumptions used in calculating the hospital evacuation time estimates are identical to the ones used previously to calculate evacua-tion time estimates for the special facilities in the EPZ, including the Suffolk Infirmary.
Those time estimates, and the procedures and assumptions used in calculating them, have already been litigated in this proceeding. They were contained in LILCO's Testimony on Contentions 72.A and E., ff. Tr. 9101, and were discussed in the Licensing Board's Partial Initial Decision (PID), at pages 835-38. Travel speeds for areas west of the EPZ were modified to reflect the updated speeds used in LILCO's testimony in the reception centers kk
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remand proceeding.
See, e_.L. LILCO Exhibit 1 (" Written Testimony of Charles A.
Daverio, Dale E. Donaldson, Edward B. Lieberman, Roger E. Linnemann, Michael K.
Lindell, Dennis S. Mileti, and Richard J. Watts on the Suitability of Reception Centers"),
1 ff. Tr.17,421, at 7.
4.
The only new assumptions used in calculating hospital evacuation time esti-mates concern the reception hospitals used. Specifically,it was assumed that:
a.
Patients were allocated among reception hospitals (listed in the LILCO Plan at OPIP 3.6.5, Att. 5) starting with those located at least 5 miles beyond the Shoreham EPZ boundary.
This assumption arises out of NUREG-0654 S II.J.10.h, which requires emergency plans to include
" relocation centers in host areas which are at least 5 miles, and preferably 10 miles, beyond the boundaries of the plume exposure emergency planning zone."
b.
At LERIO's direction, only reception hospitals capable of handling contaminated individuals were used, c.
Reception hospitals were assumed by LERIO to have 14%
of their total capacity available to accomodate evacuated hospital patients and the homebound handicapped. I un-i derstand that this figure is based on information about na-tional hospital occupancy rates received by a member of the LERIO staff from the American Hospital Association.
d.
Atter delivering evacuees to reception hospitals, the ve-hicle drivers are immediately available for additional trips,if necessary.
5.
The hospital evacuation time estimates, under three sets of conditions, are as iollows:
l
j'o 4
.o
- L Inclement
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Weather Normal Conditions Summer Winter l
l Central Suffolk 12:19 15:52 16:51 Hospital St. Charles
'12:20 16:13 17:14 Hospital John T. Mather 12:00 15:42 16:41 Hospital The foregoing facts are known by me to be true, of my own knowledge. Iam competent to testify to such facts, and would so testify if I appeared as a witness in a.
public hearing on this matter.
Respectfully submitted, m
Edward B. Lieberman 5 tms. o 8: N L 2 " ** M at EL-e uttim u.u L*J"Y g%dag Degber,1987.
Subscribed and sworn before me th W Commission Een %m 8. W My commission expires:
S P
Notary Public I
a
f.
'O LILCO, December 18, 1987 DOCKETED USNRC
'87 DEC 21 M1 55 CERTIFICATE OF SERVICE OFRCE N Sid tie
- DOCK [isNG a SEiniCf.
BRANCH in the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO's Motion for Summary Disposition of the Hospital Evacuation Issue were served this date upon the following by Federal Express as indicated by one asterisk, or by first-class mail, postage prepaid.
(
James P. Gleason, Chairman
- Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline
- George E. Johnson, Esq.
- Atomic Safety and Licensing Richard G. Bachmann, Esq.
Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 7735 Old Georgetown Road East-West Towers, Rm. 427 (to mailroom) 4350 East-West Hwy.
Bethesda, MD 20814 Bethesda, MD 20814 Herbert H. Brown, Esq.
- Mr. Frederick J. Shon
- Lawrence Coe Lanpher, Esq.
Atomic Safety and Licensing Karla J. Letsche, Esq.
Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 M Street, N.W.
4350 East-West Hwy.
Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq.
- Secretary of the Commission Richard J. Zahnleuter, Esq.
Attention Docketing and Service Special Counsel to the Governor j
Section Executive Chamber j
U.S. Nuclear Regulatory Commission Room 229 l
1717 li Street, N.W.
State Capitol Washington, D.C. 20555 Albany, New York 12224 Atomic Safety and Licensing Mary Gundrum, Esq.
Appeal Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission 120 Broadway Washington, D.C. 20555 Third Floor, Room 3-116 New York, New York 10271 L
J
,4
' Spence W. Perry, Esq.
- Ms. Nora Bredes William R. Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Gerald C. Crotty, Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 Martin Bradley Ashare, Esq.
- Stephen B. Latham, Esq.
- Eugene R. Kelly, Esq.
Twomey, Latham & Shea Suffolk County Attorney 33 West Second Street H. Lee Dennison Building P.O. Box 298 Veterans Memorial liighway Riverhead, New York 11901 IIauppauge, New York 11787 Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee Agency P.O. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York 10278 Jonathan D. Feinberg, Esq.
New York State Department of Public Service, Staff Counsel Three Rockeleller Plaza Albany, New York 12223 2 _.
Scott D. Matche t Hunton & Williams I
707 East Main Street l
P.O. Box 1535 j
Richmond, Virginia 23212
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1 DATED: December 18,1987 l
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