ML20248G943

Testimony of Tj Adler on Behalf of Jm Shannon,Atty General for Commonwealth Ma Re Contention JI-13 (Traffic Guide Training).* Related Correspondence

ML20248G943
Person / Time
Site:	Seabrook
Issue date:	04/10/1989
From:	Adler T MASSACHUSETTS, COMMONWEALTH OF, RESOURCE SYSTEMS GROUP
To:
Shared Package
ML20248G923	List: ML20248G919 ML20248G925 ML20248G930 ML20248G934 ML20248G943 ML20248G946 ML20248G960 ML20248H161 ML20248H205 ML20248H267 ML20248H319 ML20248H661 ML20248H688
References
OL, NUDOCS 8904140010
Download: ML20248G943 (10)

Text

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litELAT ED CORRESPONikin e.h EO .E,gI[0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '89 APR 11 P5 :58 ATOMIC SAFETY AND LICENSING BOARD p. r :

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Before the Administrative Judges:

Ivan W. Smith, Chairman Dr. Richard F. Cole Kenneth A. McCollom

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In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP)

OF NEW HAMPSHIRE, ET AL. )

)

(Seabrook Station, Units 1 and 2) ) April 10, 1989

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TESTIMONY OF DR. THOMAS J. ADLER ON BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS, CONCERNING CONTENTIONS JI-13 (TRAFFIC GUIDE TRAINING)

Department of the Attorney General Nuclear Safety Unit Public Protection Bureau One Ashburton Place Boston, Massachusetts 02108 (617) 727-2200 8904140010 890410 PDR ADOCK0500ggj3 T

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judges:

i Ivan W. Smith, Chairman 1 Dr. Richard F. Cole l Kenneth A. McCollom l

)

i In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP) l OF NEW HAMPSHIRE, ET AL. )  !

)

(Seabrook Station, Units 1 and 2) ) April 10, 1989

) l 1

v n 't - ,e TESTIMONY OF DR. THOMAS J. ADLER ON l BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL FOR I THE COMMONWEALTH OF MASSACHUSETTS, CONCERNING l CONTENTIONS JI-13 (TRAFFIC GUIDE TRAINING)

I I.

SUMMARY

OF TESTIMONY  !

In this testimony, Dr. Adler explains his opinion, in agreement with JI-13, that the SPMC's prerequisite experience (none) and training for Traffic Guides do not provide reasonable assurance that the SPMC's traffic and access control functions can be adequately implemented by the Traffic Guides.

He describes three critical areas in which the content of the l

l SPMC's training for Traffic Guides is deficient: (1) the 1

absence of instruction on methods for efficiently directing traffic, (2) the lack of detail in describing essential aspects of the traffic control function, and (3) the insufficient guidance on how to deal with routine physical needs.

II. IDENTIFICATION OF WITNESS Q.l. What is your name and current occupation?

A.l. My name is Thomas J. Adler, and I am President of Resource Systems Group of Norwich, Vermont.

l Q.2. Are your professional qualifications as set forth in the testimony and attachments filed for this case on September 14, 1987 and summarized in testimony submitted on February 21, 1989? l 1

A.2. Yes, they are.

III. TESTIMONY  !

l Q.3. Have your reviewed training material prepared for I traffic and access control guides under the Seabrook Plan for L

Massachusetts Communities ("SPMC")?

A.3. Yes, I have. I reviewed several versions of a training module titled, " Emergency Planning Mass E - Plan, l Traffic and Access Control, Lesson Plan No. EM10 llc. The i i

module comes with both an " Instructor Guide" and a " Student i Handout." The most recent revision that I was provided is dated 3/8/88. I also reviewed a series of three exams accompanying EM010 llc. Finally, I reviewed answers provided by j the Applicants to the Massachusetts Attorney General's (" Mass AG") First Set of Interrogatories and the Mass AG's deposition

, of the NHY ORO's Evacuation Support Coordinator, Gil Cahill.

l Q.4. Have you also reviewed Joint Interveners' Contention JI-13?  !

I A.4. Yes, I have. The contention states in part that the

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prerequisite experience required for and the training provided to ORO Traffic Guides "are inadequate to provide reasonable i l 1 I

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g assurance that'the ORO can and will implement adequate

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protective' measures in the event of a radiological emergency'at.

Seabrook Station." q Q.5. Do you agree with.that contention? -l A.S. Yes, I do. With the prerequisite experience ,

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1 required (none) and'what appears to me to be a training-program {

l lacking. adequate content, in my opinion there is no reasonable {

assurance that the NHY-ORO can' implement effective traffic'and" .i

' access control in the manner contemplated by the SPMC. I am

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also'in' agreement with Basis A'of JI-13 (as' stipulated), which j

states as follows: 1 1

A.

The SPMC states that no prerequisite experience is required for the-position _of Traffic Guide. Traffic. Guides will be dispatched to key intersections to set up traffic cones and direct traffic in a manner that produces the most efficient evacuation'possible. They may be, i required to direct extremely' congested traffic l under adverse weather conditions and deal.with  ;

thousands of disorderly, frustrated, and i frightened drivers, many of whom may have been in I traffic queues for six or more hours seeking to distance themselves from Seabrook Station. Many of the drivers will recognize.that these Traffic l Guides are not state / local police,1but agents of the owners of Seabrook. It is inconceivable that' Traffic Guides would not be required to have some

l. substantial prior experience directing congested traffic. The training provided by the SPMC (see Plan, Table 6.3-1) is not adequate to compensate for this deficiency.

0.6. Would you please describe why you believe that the prerequisite experience and training for Traffic Guides are inadequate?

A.6. In the SPMC, Traffic Guides perform a pivotal function in translating a protective action decision'to i

evacuate into the actual routing of vehicles out of the EPZ.

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i The Evacuation Time Estimates ("ETEs") included in the SPMC a Ip .2.5 Attachment 4 assume that Traffic Guides facilitate traffic flow with high levels of efficiency. To the extent j that the guides are unable to operate at this high level of efficiency, the evacuation will be impeded and the evacuation L

times will be lengthened. The SPMC training provided to j Traffic Guides does not address important issues related to the efficiency of the task nor does it recognize the overall complexity of the task.

The U.S. Department of Transportation's publication, A I

Guide for Highway Traffic Regulation in an Emergency, centains I l

general guidance for emergency highway traffic regulation I

("EHTR"). While the publication deals primarily with traffic regulation following a nuclear attack, it does discuss in some detail the complexities of establishing and maintaining  ;

traffic / access control posts. Characterizing access control functions, the publication states:

Even in peacetime, and even then if all drivers were amiable and docile, the job would still be complicated; witness the traffic jams before and after big athletic and entertainment events. In an emergency, and dealing with anxious and distraught drivers, it is going to be perhaps the most taxing, both in planning and execution, of the EHTR operations. In addition to managing and directing traffic, there may occasionally be need for police

, action against recalcitrant drivers.

Traffic Guides are, in effect, on the front line and must perform their functions in a way that both commands respect of evacuees and promotes an efficient movement of traffic.

Adequate training and experience are necessary pre-requisites l

l to acceptable performance.

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i Q.7. Would you describe specifically the areas in which the SPMC training for Traffic Guides is deficient?

A.7. There are three critical areas in which I believe I

the training is deficient: 1) absence of instruction on methods for efficiently directing traffic, 2) lack of detail in (

l describing essential aspects of the traffic control function, '

and 3) insufficient guidance on how to deal with routine l

physical needs. As mentioned earlier, the SPMC assumes that Traffic Guides operate control posts with a high degree of j efficiency. The ETE analyses assume, for example, that Traffic l l l Guides at locations where two or more streams of evacuating I traffic merge or cross will interrupt conflicting streams on a 75 second interval (" cycle"), with the time allocated so as to I i

l allow competing streams to clear at approximately the same j j time. Longer cycle lengths would be acceptable, assuming driver impatience in the interrupted stream did not lead to 1

l disruption of the evacuating flow. Cycles shorter than 75 l 1

seconds, however, would reduce the efficiency of the evacuation flow. The allocation of time among conflicting streams has a direct effect on the amount of time taken to evacuate certain l ERpAs. Nowhere in the printed material that I reviewed, l however, are the assumed cycle length allocations revealed to the Traffic Guides, nor are guides equipped with timepieces to monitor flows. Similarly, except for a brief drill in which guides set up mock intersections and direct some traffic through them ( an exercise which does not include the realism of actual intersections and heavily congested traffic flows),

l the guides are provided no real-life hands-on experience with 1

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m traffic control. There is no apparent formal instruction in now to use hand motions, the whistle provided, and other movements and gestures to stop, hold, expedite or maintain traffic flows. Given that there is no prerequisite experience required to be an ORO Traffic Guide, this is a major failing.

In my opinion, both classroom instruction and hands-on experience directing traffic at real intersections are needed l to build the necessary understanding of how the function can be j l

accomplished an'd to develop a physical sense for how to l implement it.

l The second-listed concern, that Traffic Guides are not provided with appropriate information regarding details of the function of their assigned control post, is also related to l

efficiency of operations. Guides are r.ot provided written ,

information on how long it is expected to take before traffic clears the post and whether tneir post is a " bottleneck" to the evacuation. At some locations, efficiency of control post j l

operation will be directly related to overall evacuation times. At other locations which are not bottlenecks, the speed with which vehicles are processed is less important, and it may 1

be appropriate for the guides to serve a guide-type function, answering questions where possible of those.who do not have car f I

radios, who need simple routing instructions, or who have '

special needs. Even though Traffic Guides will be the first l j

SPMC personnel encountered and thus constitute the first opportunity for evacuees to obtain " live" information, guides are not told specifically how to respond to such questions, l l

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O other than to instruct evacuees to listen to ELS messages.

Guides are not advised as to the effect, at their particular location, of allowing a driver to hold up traffic while-seeking an answer to a question.

Two other important details that are somewhat specific to each control post include procedures for placing traffic cones and for reporting impediments. While the ACP/TCP diagrams show I 1

the general configuration of traffic cones, they do not contain I sufficient detail on the spacing of-the cones, particularly at taper sections where traffic is channeled to ara one side of the roadway.

There is no written instruction on how to space the cones and/or handle a line of cones in order to direct vehicles moving at particular speeds nor on what spacing is 1

l required to avoid interruption of buses (the required spacing i l

is greater at locations that serve turning vehicles). Nowhere I

in the training or the procedures are these specifications detailed.

Only one radio which can be used to report road impediments is provided for each ACP/TCP location. There is no direction given in the training for communicating the details necessary to constitute an accident report sufficient for decisions to be made on what, if any, equipment to dispatch to the scene. At several TCPs and ACPs, guides are located outside hearing range from each other. Should a guide '

observing an impediment vacate the assigned post to carry the l information to.the guide holding a radio? Proper guide training should cover these and all reasonably foreseeable circumstances so that the evacuation's efficiency is not compromised by inappropriate guide responses to such circumstances.

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Finally, and again related to the overall efficiency of the j

traffic control function, guides are not specifically instructed as to whether and how they can take breaks during their shift to eat, rest or accommodate other physical needs.

l An uninterrupted shift longer than four hours could not be expected for this type of task, even in accommodating weather conditions. There are seven traffic control posts ("TCPs") in the SPMC which are designated as Priority 1 for which only one guide is assigned. Are :he guides at these locations free to 1

vacate their posts to get food, water, rest and/or to locate a bathroom and, if so, for how long and how should they secure the TCP/ACP which they vacate? There is little, if any, redundancy in the staffing of other Priority 1 TCPs and access control posts ("ACPS"). Guides at these locations are not instructed as to which positions are most essential to the evacuation and as to how they might rotate breaks to preserve  !

i the post's most important functions.

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0.8. Is it important that these details be specifically I incorporated into written mate: tals discussed with and provided to Traffic Guides as part of their training?

A.8. Yes. Any detail which could be described as a policy should certainly be in writing. Unless they appear in

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j printed training materials and/or manuals, there is no  !

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assurance that instructors will cover those details and, even  !

if they do, that trainees will retain the information. If state and local police become involved in the evacuation, they y too will require printed materials and/or detailed briefings i

that describe all of the policies and protocols specific to the  !

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I SPMC, as they have not participated in the formal ORO training. Similarly, second-shift personnel from Yankee Atomic who do not have the benefit of either ORO or standard police training must be trained on-the-spot by ORO staff and/or ]

guides. Formal printed procedures and handout materials'will l be especially import ant in providing such training to those Yankee Atomic staff assigned to relieve. Traffic Guides. Absent.

such materials, as is the case now, there is no assurance that the second-shift guides will be adequately trained by the j

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first-shift guides. Even with these materials, the first-shift guides must be given specific training on how to train the i second-shift guides under the conditions which could  ;

k exist--heavy traffic congestion, adverse weather, nighttime, "

etc.

Q.9. Do you believe that classroom instruction combined i l

j with mock intersection exercises directing traffic constitute I sufficient or adequate training for evacuation traffic guides?

A.9. No. I belive that the task is one which requires at least some practice directing traffic flows at real congested intersections, in addition to the classroom instruction, drills, and exercises.

Q.10. Does that conclude your testimony?

A.10. Yes, it does.

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