ML20082D045
| ML20082D045 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/18/1983 |
| From: | Mcguire P, Eric Michel, Monteith J, Roberts R, Turano M SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20082C880 | List: |
| References | |
| ISSUANCES-OL-3, NUDOCS 8311220301 | |
| Download: ML20082D045 (177) | |
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{{#Wiki_filter:.. - . . . _ I J I l l 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. 5 0-3 2 2-O L-0 3 (Shoreham Nuclear Power Station, )
Unit 1) ) (Emergency Planning)
)
)
DIRECT TESTIMONY OF INSPECTOR RICHARD C. ROBERTS, INSPECTOR JOSEPH L. MONTEITH, DEPUTY INSPECTOR PHILIP MCGUIRE, DEPUTY INSPECTOR MICHAEL J. TURANO, JR., AND CAPTAIN EDWIN J. MICHEL ON BEHALF OF SUFFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTIONS 65 AND 23.H -- EVACUATION TIME ESTIMATES AND EPZ ACCESS CONTROL 3 November 18, 1983 e 8311220301 831118 PDR ADOCK 05000322 T PDR
l . . I DIRECT TESTIMCMY OF INSPECTOR RICHARD C. ROBERTS, INSPECTCR JOSEPH L. MONTEITH, DEPUTY INSPECTOR PHILIP MCGUIRE, DEPUTY INSPECTOR MICHAEL J. TURANO, JR., AND CAPTAIN EDWIN J. MICHEL ON BEHALF OF SUFFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTIONS 65 AND 23.H -- EVACUATION TIME ESTIMATES AND EPZ ACCESS CONTROL I. Introduction Q. Please state your names, occupations and professional backgrounds. A. My name is Richard C. Roberts. I am an Inspector assigned to the Office of the Chief of District, County of i Suffolk Police Department. My name is Joseph L. Monteith. I am the Commanding Offi-cer of the Sixth Precinct, County of Suffolk Police Department. I hold the rank of Inspector in the Police Department. My name is Philip McGuire. I am the Commanding Officer of the Special Patrol Bureau, County of Suffolk Police Department.
- I hold the rank of Deputy Inspector in the Police Department.
My name is Michael J. Turano, Jr. I am the Executive Of-ficer of the Sixth Precinct, County of Suffolk Police Department. I hold the rank of Deputy Inspector in the Police Department. I
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- My name is Edwin J. Michel. I am a Captain assigned to the Office of the Chief of District, County of Suffolk Police i Department. I was formerly the Executive Officer of the Highway Patrol Bureau of the Department.
A statement of our qualifications and experience is At-tachment 1 hereto. Q. Please briefly explain the general organization and structure of the Suffolk County Police Department so that your respective jobs are set in proper perspective. 1 A. The Suffolk County Police Department has approxi-mately 2600 officers, of which about 1800 are assigned to the i Patrol Division. There are three Divisions in the Department
-- Headquarters, Detectives and Patrol. The Headquarters Division provides equipment / logistical support services to the Department and includes the Operations, Communications and Records, and Personnel Bureaus. The Detectives Division j
handles investigations of major crimes (e.g., homicides, nar-i cotics, arson and other felony offenses). In addition to the i Major Crimes Bureau, the Detectives Division includes the General Services and Special Services Bureaus. The Patrol Division is responsible for providing day-to-day police service l l l I I
to the five western townships of the County. These five townships are spread over 540 square miles, with over one million residents. An organizational chart of the Suffolk County Police Department is appended to this testimony as At-tachment 2. Within the Patrol Division, there are six Precinct Commands together with a Highway Patrol Bureau, Marine Bureau and Special Patrol Bureau. The Highway Patrol Bureau has about 125 officers and is charged with patrolling the Long Island Ex-pressway and with providing traffic enforcement of selective roadways within the six Precinct Commands. The Marine Bureau has about 65 officers and is assigned responsibility for pa-trolling selected beaches and the harbors and waterways adja-cent to Suffolk County, including the Long Island Sound. The Special Patrol Bureau has about 90 officers and exercises command over Sections such as the Canine, Aviation and Emergen-cy Services Sections. The Special Patrol Bureau is also re-sponsible for performing special services for the Department; its personnel are issued special weapons and equipment and are trained in areas such as the detection and disposal of explo-sive devices. 1
The Sixth Precinct provides police services to the Shoreham site and the surrounding area, including almost all of the LILCO 10-mile EPZ. The Sixth Precinct's area of responsi-I bility covers 176 square miles in northern Brookhaven township; approximately 225,000 persons reside within this area. Approx-imately 250 officers are assigned to the Sixth Precinct, which is broken down into 21 patrol sectors. The other five Precinct Commands are similarly broken down into patrol sectors and are responsible for providing police service to the rest of the Suffolk County Police District. II. Purposes and Conclusions l Q. What is the purpose of this testimony? A. The purpose of this testimony is to address Emergency Planning Contentions 65 and 23.H, and to discuss concerns regarding the evacuation time estimates set forth in Appendix A 1 to the LILCO Transition Plan, at V-3, and CPIP 3.6.1, Attach-ment 4,l/ and LILCC's proposals to control access into the EPZ.
-1/ We understand that on November 8, 1983, LILCO submitted revisions (Revision 2) of its emergency response plan, including Appendix A. Appendix A describes the traffic control scheme upon which LILCO's evacuation time l estimates are premised and is therefore crucial to the (Footnote cont'd next page)
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LILCO estimates that the time for evacuation will vary from about two to two-and-one-half hours for only the inner EPZ sec-tors, to a maximum of approximately six hours for evacuation of the entire EPZ under adverse weather conditions.2/ We have identified a number of deficiencies and inaccuracies in the traffic control scheme relied upon by LILCO in arriving at the evacuation time estimates set forth in the LILCO Plan, which lead to certain conclusions. We have also identified a number of deficiencies in LILCO's proposals to control access into the EPZ which lead to certain conclusions. (Footnote cont'd from previous page) issues discussed in this testimony. We, however, did not even see a copy of LILCO's revised Appendix A until November 14, when we were shown a copy of Revision 2 pro-vided by LILCO to counsel for Suffolk County. We have at-tempted, where possible, to reflect the Revision 2 changes in this testimony; however, in order to meet the November 18 filing deadline, much of this testimony still address Revision 1 of the LILCO Plan. If, after we have had an opportunity to review and analyze LILCO's revisions to Appendix A, we determine that this testimony should be supplemented or amended to comport with substantive changes in the LILCO Plan, including Appendix A, we will prepare and file such supplemental or amended testimony in accordance with the Board's Memorandum and Order dated November 14, 1983. For the purposes of this testimony, however, unless otherwise indicated, references herein to the LILCO Plan, including Appendix A, are to Revision 1. 2/ See scenarios 16 and 20, Table II, Appendix A, at II-8. See also Table XIV, Appendix A, Rev. 2, at V-3. l
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Q. What are these conclusions and where are they discussed? A. LILCO's evacuation time estimates are inaccurate, unreliable and should be far longer. In our opinion, LILCO's evacuation time estimates are underestimated for a number of reasons. First, as discussed in Part III, LILCO has underestimated the time required for people to mobilize and ready themselves for evacuation, and has ignored the heavy traffic congestion that will be caused by mobilization traffic. Second, LILCO's traffic control plan, which unre-alistically assumes that LILCO personnel can undertake police powers and effectively implement police-type functions, will lead to additional traffic congestion which has been ignored in LILCO's evacuation time estimates. For example, as discussed in Part IV of this testimony, LILCO's Plan prescribes evacua-tion routes and its traffic model assumes that all evacuees will comply with such prescribed routes. This assumption, how-ever, is unrealistic since evacuees will likely refuse to travel contrary to their own perceptions of the most expeditious and safest way out of the EPZ. Those evacuees deviating from LILCO's prescribed evacuation routes will cause
confusion and anxiety on the part of other evacuees, leading to traffic congestion and increasing evacuation times. In addition, as discussed in Part V, LILCO's attempt to
,. " discourage" motorists from moving in a direction contrary to' its prescribed evacuation routes will also impede traffic flow, resulting in additional congestion and further increasing evac-uation times. In fact, LILCO's attempt to control traffic by i
such means as prescribing traffic routes, " discouraging" motor-ists from deviating from those routes, and utilizing various traffic control strategies and mechanisms,3/ may cause aggres-sive behavior on the part of evacuees, resulting in conflicts with LILCO's traffic guides that will lead to traffic block-l ages, confusion, accidents and possibly injuries, all of which increase congestion. These conclusions are discussed in Part VI of this testimony. A further example of LILCO's flawed traffic control plan
-- the direction of traffic by LILCO's traffic guides contrary
- to traffic signals -- is discussed in Part VII of this 3/ In our view, such attempts to control traffic by LILCO are
, unlawful. We understand that this issue will be addressed separately in the context of other Contentions. 2
testimony. In our opinion, these examples lead to the conclusion that LILCO's traffic control plan is inherently flawed and will result in severely disrupted traffic flow and substantially increased evacuation times. Third, LILCO's evacuation time estimates ignore certain factors which increase congestion and thus increase evacuation times. These factors are discussed in Part VIII of this testi-mony and include car accidents and breakdowns, cars running out of gas, the absence of shoulders on roadways, road construction and repair, and the abandonment of vehicles. These factors would, as a practical matter, seriously impact an evacuation. Fourth, we discuss in Part IX of this testimony LILCO's ineffective measures for spotting congested areas so that appropriate measures for evacuees to avoid such congestion can be implemented. Finally, Part X of this testimony addresses Emergency Planning Contention 23.H and discusses LILCO's inadequate measures for controlling access into the LILCO EPZ during an evacuation. In fact, the LILCO Plan virtually ignores access control into the EPZ. As a result, persons could be exposed
i i to, and contaminated by, health-threatening radiation doses. Moreover, the resulting cross traffic and conflicting traffic movements would likely result in additional traffic congestion, thereby increasing LILCO's evacuation time estimates. In summary, based on our experience as police officers, we believe that LILCO's evacuation time estimates are unrealistic and underest'imated. In our. opinion, the real world, likely to occur, practical problems of evacuation would result in evacua-tion times far longer than those assumed by LILCO. o i III. Contentions 65.A and 65.B 1 j Q. Contentions 65.A and 65.B allege that the LILCO evac-i uation time estimates ignore or underestimate the time required for people to mobilize and ready themselves for evacuation. Do you agree with these Contentions? j A. Yes. It is our understanding that LILCO's evacuation time. estimates are derived from a traffic model developed by l KLD Associates ("KLD"). (See Pigozzi testimony). Professor Pigozzi has testified that KLD's model assumes that there will i be a 20-minute " mobilization time" following a recommendation to evacuate, after which all evacuation traffic would begin to - t i l l l l
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s evacuate over a period of about 2 hours. (See Pigozzi testimony; Appendix A, Rev. 2, at V-7). LILCO thus appears to believe that all evacuation trips will have commenced within 2 hours and 20 minutes of the first evacuation advisory. In our opinion, this KLD/LILCO time estimate is unrealistic and seri-ously underestimates the time it will take for the public to I mobilize and prepare for evacuation. J Q. Please explain how LILCO has underestimated mobiliza-tion time. A. We agree with Professors Herr and Pigozzi that, between the time evacuation is recommended and the time evacuees begin to evacuate, traffic within the EPZ will become congested as a result of pre-evacuation trips, i.e., trips that people may take to prepare for evacuation. (See Pigozzi testi-mony; Herr testimony). Pre-evacuation trips would include, for example, travel from work to schools and/or homes and travel from homes and/or work to banks, stores, gas stations, and other such facilities in order to obtain money and supplies. We would expect there to be a substantial number of such pre-evacuation trips by people preparing to evacuate. In fact, Professors Herr and Pigozzi have testified that there could be
as many pre-evacuation trips as evacuation trips. (See Herr testimony; Pigozzi testimony). As a result, traffic within the EPZ will become heavily congested, thereby lengthening the time necessary to complete mobilizt. ion travel and to prepare for evacuation. Q. Is this pre-evacuation congestion taken into consid-i eration by the LILCO Plan? A. No, and as a result the LILCO evacuation time estimates are too short. The LILCO Plan does acknowledge that there will be pre-evacuation trips by some people before they evacuate the EPZ. (See Appendix A, at IV-8; see also Appendix A, Rev. 2, at V-3). However, the effect of such pre-evacuation trips on LILCO's evacuation time estimates is ignored. C. Please explain. A. Under the LILCO Plan, specific evacuation routes are assigned for each of the 19 subzones in the EPZ. Further, l KLD's traffic model assumes that evacuees will not deviate from these routes, and that traffic on the routes will be in the di-rections prescribed by LILCO. (See Pigozzi testimony). Howev-er, according to LILCO, persons who are not in the process of l
evacuating will be permitted to travel along and across these prescribed evacuation routes in any direction. (Appendix A, at IV-8). As a result, evacuating traffic going in the prescribed direction on a LILCO designated evacuation route will come into conflict with pre-evacuation traffic travelling in a different direction, or entering and leaving the route at places different from those designated by LILCO. For example, pre-evacuation traffic will cross evacuation routes, or tura left against the prescribed traffic flow, ei-ther of which will require the evacuating traffic to stop. Whatever particular traffic maneuvers may be involved, the pre-evacuation traffic will cause significant interruptions of the flow of evacuation traffic. Given the large number of pre-evacuation trips anticipated, the times required for people to mobilize and prepare for evacuation will increase, since people attempting to get to homes or other pre-evacuation des-tinations will be slowed by congestion. Evacuation times will therefore be substantially increased. Of course, this increase in mobilization times will delay evacuation from the EPZ, thereby lengthening evacuation times. (See Pigozzi festimony).
Evacuation times will also be lengthened by conflicts between evacuating traffic and traffic already on the roads
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within the EPZ when an evacuation begins. (See Pigozzi testi-mony). As Professor Pigozzi points out, KLD has assumed that this " background" traffic will be moving with the evacuation 1 traffic flow at the time evacuation begins. Based on our expe-rience as police officers, we believe that this is an unre-alistic assumption, since traffic will be moving, as it normal-l ly would be, in all directions. This will lead to interrup-l tions of traffic flow, resulting in further delays for mobili-zation and evacuation traffic, which will further lengthen l evacuation times. l l IV. Contention 65.C.4 Q. Contention 65.C.4 alleges that the LILCO traffic control plan, as described in Appendix A to the LILCO Plan, in some instances directs evacuees to travel contrary to their perceptions of the most expeditious way out of the EPZ. The Contention alleges that this will cause confusion and anxiety on the part of evacuees, leading to traffic congestion which, if taken into account, would substantially increase LILCO's evacuation time estimates. Do you agree with Contention 65.C.4? t
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I A. Yes. Not only has LILCO assigned specific evacuation l routes and destinations to the EPZ population (see Appendix A, at IV-87 through IV-178), but the evacuation time estimates i contained in the LILCO Plan assume that there will be strict adherence to those evacuation routes, without deviation (see Pigozzi testimony). (See Lieberman deposition at 86).4/ In our opinion, the concept of prescribing evacuation routes, cou-pled with LILCO's assumption that there will be strict adher-1 ence with these routes by evacuees, is unrealistic. IndeeQ; in our opinion, the destination assignments and evacuation routing strategy adopted by LILCO will be ignored by many evacuees, thereby increasing substantially the evacuation times assumed by LILCO. Q. tihy do you believe that the evacuation routing strit-j egy adopted by LILCO will not be adhered to: by evacuees? A. People choose routes based on their knowledge of the roads. Direction is not the only consideration; other charac-teristics, such as congestion, the number of traffic lights and 4/ For a discussion of a study by LILCO of a so-called
" uncontrolled" evacuation run, see Pigozzi testimony,
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4 stop signs, and whether a road is familiar, are also considered. During an evacuation, people will have their own 1 perceptions of the "best" routes out of the EPZ. Unless their "best" routes happen to coincide with LILCO's prescribed evacu-ation routes, people are likely to disregard the LILCO routes in favor of their own. For example, people who are familiar with the roads where they live or work avoid travelling the main roads at times when traffic is perceived to be heavy, such as during rush hour, when big events are over, during heavy shcpping times, or around holidays. Instead, they use "short cuts" that are not so heavily travelled. There would be no reason for people to l I deviate from these familiar "short cuts" in the event of an emergency at Shoreham requiring evacuation. However, there would be good reasons for people to insist on travelling along such "short cuts," especially if they perceive LILCO's evacua-tion routes to be contrary to their best way out of the EPZ -- for example, because they perceive the direction of the route to be unsafe (i.e., toward the Shoreham plant) or because they believe that the route will be heavily travelled and thus congested by other evacuees. For example, the Rocky Point
residents north of Route 25A would likely avoid the intersection of Broadway and Route 25A during periods of con-gestion by utilizing the back roads north of Route 25A, such as King Road or Prince Street, to travel at their discretion ei-ther east or west out of the area. Should enough evacuees de-viate from LILCO's prescribed routes and use such "short cuts," evacuation times could be increased due to conflicting traf fic flows. As police officers, we commonly observe that whenever traffic is congested, some motorists will disregard established traffic patterns in an attempt to avoid the congestion. A common example of this occurs whenever traffic is congested on the Long Island Expressway (Rt. 495). Then, many motorists drive along the shoulders in an effort to avoid delays. This occurs even though it is unlawful to drive along the shoulders and despite the fact that motorists know that police officers routinely patrol and actively enforce infractions of this nature along the Long Island Expressway. It is also common for motorists to avoid pre-established routes in order to " find their own way." Examples include shortcutting through residential areas and shopping centers to
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avoid congested intersections. Suffice it to say that whenever motorists perceive an advantage to a "different" route, they are likely to use it. Thus, it is unrealistic to assume that evacuees will adhere to LILCO's prescribed evacuation routes. LILCO's evacuation times are therefore underestimated, since those estimates unrealistically assume uninterrupted, compati-j ble traffic flows, with evacuees, without exception, complying with LILCO's prescribed evacuation routes. (See Lieberman dep-osition at 86). Q. But doesn't the LILCO Plan describe mechanisms for controlling traffic and ensuring that evacuees adhere to pre-scribed evacuation routes? A. The LILCO Plan calls for LILCO personnel to direct traffic in an attempt to " encourage" evacuees to adhere to pre-scribed routes, by using such techniques as mandated turns, blocked lanes, concurrent continuous flow treatments, chan-nelization, barricades and signs, and the conversion of some
- roadway sections to one-way traffic flow (see Appendix A, at IV-5 through IV-79). In our opinion, however, even if it is assumed that such tactics are lawful and capable of being im-l plemented, they still will not enable LILCO to prevent, or even l
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" discourage," significant numbers of evacuees from deviating I from the evacuation routes prescribed in the LILCO Plan. Nor will they prove very successful in controlling traffic and preventing congestion.
For example, LILCO intends to employ channelization treat-ments on selected sections of the evacuation network in order to increase capacity at intersections where turn movements are l significant and traffic demand is high. (Appendix A, Rev. 2, at IV-19; Appendix A, Table IX). Such channelization treat-ments involve adding a traffic lane by using roadway shoulders, channelizing existing lanes, closing existing lanes, and/or adding lanes as " turn pockets" to separate through movement traffic from turning traffic. Signs, barriers, cones and vehi-cles would be used to implement this traffic control technique. (Appendix A, Rev. 2, at IV-19). In our opinion, the traffic channelization strategies de-scribed in the LILCO Plan would likely fail to control traffic flow. In part, this is because there are insufficient traffic guides to carry out this technique. Under the LILCO Plan, 189 traffic guides will be expected to man 143 traffic posts in the event of an evacuation of the entire 10-mile EPZ. (Appendix A, Figure 8).1/ Should traffic guides fail to report to their 5/ Under Revision 2 of Appendix A, there are 138 traffic control posts, and 165 traffic guides. (See Appendix A, Rev. 2, Figure 8).
assigned posts, or should they be delayed in getting-to their posts, there would be insufficient personnel to cover all assigned traf fic posts. Channelization strategies should never be attempted at intersections which are not manned. Q. Doesn' t LILCO's traf fic control plan. require every intersection within the 10-mile EPZ to be mannsd?
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A. No. In fact, in some instances significant intersec-tions where heavy traffic flow would be expected are not y manned. For example, the intersection at Randall Road and North Country Road (Shoreham) and the intersection at Randall Road and Route 25A are not manned by LILCO's traffic guides (see Appendix A, Figure 8), even though " positive control" of traffic flow is required at these intersections. (see Appehdix > l i ., s A, Table V). Nor is the intersection"of Landing Road and Route #
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25A (traffic node 11) manned, despite LILCO's assumption that all southbound traffic will turn westbound onto Route 25A'.It this location. (See Appendix A, Table,XII, at IV-31). ./ $ , _/ It is necessary to understand the difference between LILCO's traffic control posts and traffic nodes. Different traffic strategies and instructions are assumed for such postsr w
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l J and nodes, and, in many' cases, posts and ' nodes represent
.e d fferent geographical locations. Traffic control posts are
'i ntersections where LILCO's traffic guides will be directing
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p strategy. They are identified in Figure 8 of Appendix A. l * , Traffic nodes are locations which may or may not be manned by
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. traffit guides and which were identified by the computer e -
modelers who derived LILCO's evacuation time estimates. The e r
-vastmajorityoftrahficnodesareassociatedwithturnmove-
/ f 'mcats that are prescribed for the LILCO-evacuation routes.
' Son.e traf fic nodes are not located at intersections and some do 6'
not involve prescribed turn movements. Many that do involve p'rescribed turn movements are not manned by traffic guides. Traffic nodes involving prescribed traffic tu.cn movements are Ebentified in Table XII of Appendix A. i e' Q. Are there problems with the traffic channelization strategies described in the LILCO Plan other than problems that
.could arise because, due to the insufficient number of traffic guides, channelization strategies might have_to ,be attempted at
_,s inte:rsect' ions which are not manned? 1 d 4
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i A. Yes. In some instances, the strategies set forth for channelization treatments (see Appendix A, Table IX) conflict I with the strategies to be implemented by traffic guides (see Appendix A, Figure 8). In other instances, the strategies to be implemented for channelization treatments will be impossible or extremely difficult to implement. For example, the chan-nelization treatment to be implemented between traffic nodes 7 and 30 calls for establishing two lanes of traffic westbound and one lane of traffic eastbound on Route 25A from Echo Avenue to County Road 83. (Appendix A, Table VIII, at IV-18; Appendix A, Table IX, at IV-20). Route 25A in this area, however, is a two-lane roadway, with a limited paved shoulder eastbound and almost no paved shoulder westbound. Utility poles stand close to the road surface on both sides of the highway, and the westbound shoulder is further impeded by the curbing of a gas station on the north side, just east of County Road 83. LILCO's channelization strategy would therefore require exten-sive use of cones and the need for westbound traffic to strad-die double barrier pavement markings. It would not be possible to implement this strategy without considerable lead time, and even then, traffic would likely back up and become congested due to the narrowness of Route 25A at this location. l
_- .=_ ._- .- - .. . . - . - .- , _ _ . . - _ - - . . - _ . _ - - . -. ~ I i l 1 ! i In addition, some traffic node strategies would be impos-sible to implement. For example, the strategy to be imple-mented at traffic node 74 (128, 74) (Long Island Expressway, eastbound) provides for all traffic moving west on Edwards ave-
; nue at this location to flow onto the Long Island Expressway, i j with 20 percent of the traffic to move east on the Expressway and the remaining 80 percent of the traffic to move west.
However, at this location, there is no way for traffic to enter the Long Island Expressway eastbound, since there is no access ramp. Thus, all traffic would have to enter the Expressway westbound, or continue on Edwards Avenue. The traffic guide at , traffic post 417, however, is instructed to prevent westbound traffic west of the Exit 71 eastbound exit ramp (see Appendix A, Figure 8), in direct conflict with the traffic strategy for nodes 128, 74. Thus, traffic would never reach the Long Island Expressway, westbound. A further discussion of LILCO's chan-nelization treatments on selected roadway sections (Appendix A, Table IX) is appended to this testimony as Attachment 3. j Moreover, LILCO's use of concurrent continuous flow treat-ments at selected intersections (see Appendix A, Rev. 2, Table i V) would generally fail to control traffic flow. LILCO
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] ; proposes to mandate traf fic movements through these selected i
intersections so that conflicts with other traffic movements
! can be avoided. In this way, traffic movement is to be kept . continuous. LILCO's traffic guides are assigned responsibility for enforcing this traffic control strategy. (Appendix A, at ! IV-9). l However, the concurrent continuous flow treatments man-l dated by Appendix A are often in direct conflict with traffic i control strategies described elsewhere in Appendix A, particu-
! larly those strategies to be implemented by traffic guides at traffic control posts (Appendix A, Figure 8) and those ! strategies regarding prescribed turn movements at traffic node locations (Appendix A, Table XII). For example, the concurrent i j continuous flow treatment for the intersection described by [' LILCO as North Country / Wading River-Manorville Road and Route i j 25A5/ prescribes the following traffic flow movements: If I l 6/ Despite LILCO's designation of this intersection as North Country / Wading River-Manorville Road and Route 25A, this intersection is, in reality, Wading River-Manorville Road and Route 25A. i j ! 4
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- a. Vehicles moving south on North North Country Rd. will be Country ,
routed west onto Rt. 25A. 53/C,0 Road at. 25A b. Vehicles moving west on Rt. J-g 25A will be routed south onto Wading River-Manorville Rd.
- c. Positive control is required a n e assure Wading River- y
- Manorville Rd.
i This flow treatment is in direct conflict with the prescribed turn movements for traffic node 53 (Appendix A, Table XII, at IV-41 and IV-42), which instruct all southbound traffic on ' North Country / Wading River-Manorville Road to continue south, and directs all northbound traffic on Wading River-Manorville Road to turn west onto Route 25A.1/ As a result, rather than continuous flow at this intersection, there will be conflicting traffic flows, resulting in traffic delays and congestion. A further discussion of the inconsistencies between traffic control strategies at traffic posts and traffic node locations and the intersections at which LILCO's concurrent continuous
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7/ This flow treatment is also in conflict with the traffic strategy for traffic post #128 in Appendix A, Figure 8, Revision 2.
flow treatments are to be implemented is appended to this testimony at Attachment 4. LILCO's plan to convert certain roadway sections to one-way flow (Appendix A, Table VIII, at IV-18) in order to in-crease roadway capacity would also face serious problems if im-plemented by LILCO. For example, in order to convert North Country Road to one-way westbound traffic between "Old Miller Place Road"8/ and Shore Road, LILCO would have to block traffic from several side streets that enter onto North Country Road from residential areas. At least 15 additional traffic posts would be required, a fact not recognized in LILCO's plan. In addition, North Country Road is travelled by school buses for all four Miller Place schools. These buses are on the read as early as 7:15 a.m. and as late as 6:15 p.m. Under LILCO's pro-posed conversion to one-way flow, these buses would have to be rerouted, since there is insufficient road capacity (road width) for buses to travel against two lanes of one-way traffic 8/ Despite LILCO's description, this one-way route descrip-tion would run along Lower Rocky Point Road at its inter-section with Beacon Drive west to North Country Rohd, and then along North Country Road west to its intersection with Shore Road (traffic links 2,102 and 102,1). _ _ _ _ _ _ _ _ _ _ . _ _ _ ..______-._________.-____.m____ - _ _ _ . - _ -
i l 5 l flow. A further discussion of the problems that would be i
- encountered by LILCO's proposal to convert certain roadway i
} sections to one-way flow is appended to this testimony as At- ! tachment 5. l i LILCO's reliance on signs -- assuming they even get i installed -- to direct evacuation traffic is also impractical ] and unworkable. (See, e.g., Appendix A, Rev. 2, at IV-70). 4 Such signs may be defaced, turned around, torn down or collect-i i ed by souvenier hunters. In addition, some signs would be de-4 ! stroyed during automobile accidents or by snow plows during snow removal operations. As a result, when the signs were l l needed, they might not all be in place. It is not difficult to imagine the frustration among motorists and the traffic problems that would result should motorists following l vandalized or damaged signs suddenly find themselves facing a 1 i dead-end street, not knowing where to go.9/ l 1 i ! -9/ The Manual on Uniform Traffic Control Devices (MUTCD 1978 edition) devotes a section to " Signing for Civil Defense." l LILCO, however, has removed the " Civil Defense" legend from the signs it plans to install to help direct evacua- { tion traffic. Further, LILCO is without authority to l install such road signs. See footnote 3, supra. i i j
Blocking the merging lanes on limited access highways in order to facilitate access to the highways by traffic from the entrance ramps (see Appendix A, Figure 8.2) might help to control traffic flow, but this technique would also likely cause congestion on the limited access highway to the rear of I the blocked lane (s). In addition, due to driving habits and conditioning, some motorists attempting to enter onto such highways would slow down or even stop because they will antici-pate a need to merge with traffic already on the highways -- even though none might exist. Thus, further congestion would result on the access route as well. Similarly, techniques such as mandating turn movements and otherwise prescribing traffic flow will also lead to congestion and would likely fail to deter motorists from deviating from LILCO's prescribed evacuation routes. In some instances, mo . torists are expected to follow prescribed routes of their own accord. (See Appendix A, Table XII, at IV-29 through IV-51). In fact, there are a significant number of traffic nodes where turn movements are prescribed, but which are not manned by traffic guides. For example, southbound traffic along North Rocky Point Landing Road is expected to turn west onto Route
1 25A at the intersection of North Rocky Point Landing Road and Route 25A (traffic node 11). Turning west onto Route 25A at > this location, however, requires motorists to make an awkward 135 degree turn. Nevertheless, no traffic guides are assigned to this location. See also the turn movements prescribed at traffic node 3 (Sound Lower Rocky Point Road and Lower Rocky Point Road). Moreover, even where LILCO relies upon traffic guides to enforce the traffic flow prescribed by the LILCO Plan, problems will occur. Significant problems, for example, will arise be-cause these traffic guides will not be obeyed by many evacuees. As previously noted, if people decide that it is in their best interests to disregard LILCO's prescribed routes, they will do so, irrespective of the directions / instructions /" discourage-ment" given by a traffic guide. Once one or two motorists decide to disregard a traffic guide and "go their own way," other motorists will quickly follow, and LILCO's prescribed scheme of traffic control will be lost. It requires special training and experience to establish and maintain traffic flow and established traffic patterns; in addition, an intimate knowledge of the local road network is important. (See Suffolk
a County testimony on Contentions 39-41 and 44.D, E and F (Training) and Contention 15 (LILCO's Lack of Credibility)). Even with adequate training and experience, it is not always possible to prevent motorists from deviating from pre-established routes; there are times when the officers under our
- command find it difficult to prevent such deviation. Thus, it is unrealistic to assume that LILCO's traffic guides will be able to establish and maintain the prescribed traf fic flow along the evacuation routes outlined in the LILCO Plan. They will not have sufficient training or experience; nor will they necessarily be even remotely familiar with the local roads. i (See, e.g., J. Barrows deposition at 75-76, where Mr. Barrows, l,
a designated LILCO traffic guide, testified that he has never been within the EPZ or to the Shoreham plant. In fact, he did not even know where the EPZ was located). Other problems must be expected due to inconsistencies between the traffic control strategies to be implemented by LILCO's traffic guides and the strategies prescribed for evacuees at traffic node locations. (Compare Figure 8 and Table XII of Appendix A). For example, traffic node 12 (Rt. 112 and Nesconset Highway (Rt. 347)) corresponds to traffic
Post #50 and is to be manned by two traffic guides. The prescribed turn movements for this node, however, are both in-accurate and in direct conflict with the traffic control strat-egy for traffic post #50. The node discussion (Table XII, Appendix A, at IV-31 and IV-32) is inaccurate because Canal Road does not intersect ei-ther Route 347, a four lane divided highway, or Route 112, a two lane highway. Further, it would be impossible to turn southeast onto Canal Road from " Main Street," as instructed by the node discussion. First, there is no Main Street at this location; the only possible southbound routes are Route ll2/Patchogue-Port Jefferson Road. Second, to turn southeast onto Canal Road at this location would first require crossing Route 347 and proceeding south on Route 112 to Rose Lane, since, as indicated above, Canal Road does not intersect either Route 112 oc Route 347. Further, the instruction in the node discussion for vehicles moving northwest on Canal Road to turn west onto Nesconset Highway (30 percent) or north onto Main Street (70 percent) would also be impossible, since Canal Road does not intersect either Nesconset Highway or Main Street. l l
l The prescribed turn movements for traf fic node 12 are also in direct conflict with the traffic control strategy for traf-a fic post #50, which provides for southbound traffic to turn west onto Route 347 (rather than southeast onto Canal Road). Indeed, the turn movements prescribed for this node also conflict with the strategy to be implemented at traffic post
#54, since the node strategy turns northbound traffic on Port Jefferson /Patchogue Road west onto Route 347, while the traffic guide at traffic post #54 is instructed to redirect this traf-fic southbound.
- Q. Would evacuation times necessarily be increased by evacuees' deviating from LILCO's prescribed evacuation routes?
A. Yes. As noted by Professor Pigozzi, the evacuation modeled by KLD relies upon LILCO's use of prescribed routes.
~
This has allowed KLD and LILCO to avoid on paper as much as possible conflicts between traffic flows and to make optimum use of available roadway capacity. (See Pigozzi testimony). The result of minimizing conflicts in traffic flow and of mak-ing optimum use of road capacities is reflected in LILCO's low evacuation time estimates. h
These time estimates, however, are not based on reality. The reality is that drivers are likely to take whatever routes out of the EPZ that they perceive to be the safest end quickest. As a result, there will likely be significant devia-tion from the evacuation routes prescribed by LILCO. For exam-ple, people may ignore the LILCO routes because they are per-ceived as ill-advised and riskier than their own alternate routes. Of course, there will also be people who deviate from the LILCO routes unintentionally because they will have for-gotten routes or because, as non-residents, they may not be aware of LILCO's routes. In our opinion, this deviation from LILCO's evacuation routes will likely increase LILCO's evacua-tion time estimates, which are based upon this unrealistic as-
! sumption that evacuees will strictly adhere to prescribed routes.
Q. Are there specific routes designated by LILCO as evacuation routes which you believe would be disregarded by evacuees? A. Yes. We believe that people will deviate from pre-scribed routes no matter how sound the traffic strategy. How-ever, several of the routes prescribed by LILCO are illogical l I l
and inappropriate and thus are especially unlikely to be t followed by evacuees. (See Hert testimony). The following examples discuss traffic control strategies which, under the LILCO Plan, are to be carried out by traffic guides at traffic control posts (see Appendix A, Figure 8, at IV-52 through IV-78). In our opinion, the traffic routing
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strategies at these posts are likely to be perceived as con-trary to the safest and quickest route out of the EPZ by a substantial number of motorists. As a result, motorists are likely to disregard the instructions given by LILCO's traffic guides at these locations, resulting in traffic delays and con-gestion. Post 25 - North Country Road at Woodville Road -- This traffic control post is located close to the west side of the Shoreham plant, with the traffic guide instructed to prevent traffic from proceeding south on Woodville Road and to redirect traffic east along North Country Road to Belle Meade Avenue. (Appendix A, at IV-53). This attempt to direct traffic in an easterly direction, toward the plant, is not likely to be per-ceived as a route out of the EPZ and will likely be disregarded by evacuees. _ _ _ _ - - _ _ _ _ _ _ _ _1- ;
i l i Post 46 - Rt. 25A at Ridge Road -- The traffic guide at this post is instructed to direct eastbound traffic south on Ridge Road. (Appendix A, at IV-53). Tnis strategy appears
; sound. However, southbound traf fic from Belle Meade Avenue is to be directed east on Route 25A. (1d.). This attempt to I direct traffic in an easterly direction, toward the plant, is i , not likely to be perceived as a route out of the EPO and will likely be disregarded by evacuees.
Post #9 - Rt. 25 at Ridge Road -- The two traffic guides l at this post are to direct 50 percent of southbound traffic west and 50 percent south; they are to prevent traffic from proceeding east on Route 25. (Appendix A, at IV-54). ., Preventing traffic from proceeding east at this location would, in all probability, lead to confrontations between motorists and LILCO's traffic guides, since the William Floyd Parkway, a i major highway which would be perceived as providing ready ! access south and out of the EPZ, lies less than one mile to the east. Post #13 - Rt. 25 at Rt. 25A -- The traffic guide at this location is instructed to direct southeast traffic on Route 25A to eastbound Route 25, and to facilitate eastbound through i
- t l
l
o . l traffic on Route 25. (Appendix A, at IV-55). These strategies appear sound. However, westbound traffic on Route 25 is to be ! directed northwest on Route 25A. (Id.). Evacuees are unlikely to follow this instruction since they would then be travelling 4 toward the Shoreham plant. Post #14 - Rt. 25 at Edwards Avenue -- The traffic guide i I at this post is to direct all eastbound traffic on Route 25 south on Edwards Avenue. All southbound traffic on Edwards AV-enue is to be directed east on Route 25. (Appendix A, at i i IV-55). Motorists travelling south on Edwards Avenue are like-I ly to disregard the instruction to head east on Route 25 be-cause they would want to proceed south across the intersection, and then continue south on Edwards Avenue, so that they could i enter the Long Island Expressway at Exit 71, or continue south-east on County Road 94 (Nugent Drive), from where they could ! then proceed out of the EPZ. Post #17 - Nugent Drive (CR 94) at Rt. 495, Exit 71, Exit Ramp -- This traffic post is located within sight of the Long Island Expressway. However, the traffic guide at this post is instructed to establish a roadblock to prevent all westbound traffic on Nugent Drive. Traffic is then to be_ redirected i i l
- . . - - , - . . . - . , , , - ~ . ,. - , . . , - , - . , , , . - , - , , - , ~ , - . , . . .
1 eastbound on Nugent Drive. (Appendix A, at IV-56). This traffic strategy therefore requires westbound traffic on Nugent Drive intending to enter the westbound Long Island Expressway (Rt. 495) to make a "U" turn and then to proceed back toward Riverhead. Such a strategy would be disregarded by virtually every motorist. Even though motorists gaining access to the Long Island Expressway would have to travel within the EPZ until Exit 66 (Sills Road) is passed, they would be within sight of the Long Island Expressway at the point of the road-block /"U" turn maneuver, and, without question, the Long Island Expressway would be perceived as the best route out of the EPZ. For precisely the same reasons, the traffic strategy for traf-fic post #19 would likely be disregarded by motorists. At the location of this post (Rt. 25 at River Road) (Appendix A, at IV-56), motorists would not be deterred by the roadblock which
^
is to be established. They would perceive Route 25 or the Long Island Expressway westbound as the best route out of the EPZ and would do whatever was necessary to gain access to one of those highways. Ir Post #22 - Rt. 25 at Roanoke Avenue -- The traffic guide at this post is to direct all southbound traf fic on Roanoke l l
Avenue eastbound on Route 25. (Appendix A, at IV-57). However, many motorists, upon arriving at this location, would want to turn right onto Main Street and then left onto Peconic Avenue, so as to proceed around the Riverhead traf fic circle from where they could head out of the EPZ by travelling south on County Road 51. Any attempt to direct these motorists eastbound on Route 25 would likely be perceived as contrary to the best route out of the EPZ since, by travelling east, they would be heading toward the North Fork of Long Island, from where they would feel trapped. Post #37 - Rt. 25A at Broadway -- The traffic guide at this location is to prevent traffic from proceeding west on Route 25A. Southbound traffic from Broadway is to be directed east on Route 25A. (Appendix A, at IV-61). Preventing traffic from proceeding westbound at this locetion will require motor-ists to make a "U" turn in a congested village. This, as well as the instruction to route southbound traffic from Broadway east on Route 25A, will be perceived as contrary to the best route out of the EPZ, since motorists would be required to travel toward the relatively close-by Shoreham plant.
-Post #39 - Lower Rockv Point Road at Caddy Pl. -- The traffic strategy for this traffic post would likely be disre-4 garded by motorists for a number of reasons. At the location of this post, traffic is to be prevented from going east or west. Eastbound traffic is to be directed south on Caddy Place, westbound traffic must U-turn. (Appendix A, at IV-61).
Motorists, however, would not willingly "U" turn and head back in the direction of the Shoreham plant. Moreover, the "U" turn strategy conflicts with the instruction to the traf fic guide to prevent eastbound traffic by routing any eastbound traffic south on Caddy Place. In addition, the traffic strategy for this post would result in directing traffic south into a maze of residential streets without any direct access to a major east / west evacuation route. i The traffic strategy for traffic post #39 also conflicts with other nearby traffic control strategies proposed by LILCO. For example, the traffic guide at traffic post #140, located only one block east of traffic post #39, will be directing all traffic moving northwest on North Rocky Point Landing Road west onto Lower Rocky Point Road. (See Appendix A, Tables XII and XIII, at IV-49 and IV-79). Directing this traffic west, 1 I l I l I
however, is in direct conflict with the traffic control strategy for post #39, i.e., to prevent westbound traffic. Post 451 -Terryville Road at University Drive -- The traf-fic guide at this post is to establish a roadblock to prevent traffic from proceeding north on Terryville Road. In addition, l traffic is to be redirected eastbound on University Drive. (AP-pendix A, at IV-64). Establishing a roadblock for northbound traffic at this location would likely be perceived as contrary to the best route out of the EPZ, since many motorists would want to turn left at the intersection of Terryville Road with Route 347 and head west -- away from the Shoreham plant. Thus, LILCO's prescribed traffic control at this post would likely break down. For similar reasons, the traffic strategies at traffic post #52 (Jayne Boulevard at Roosevelt Avenue) and traffic post #54 (Rt. 112 at Rose Lane) (Appendix A, at IV-64 and IV-65) would likely be disregarded by motorists. The strategy at post #54 is further complicated by the fact that northbound traffic on Route 112 will be required to "U" turn'in a heavily congested area. Post #54 - Rt. 112 and Rose Place -- The traffic guide at this post is to establish a roadblock to prevent traffic from i l l - I
. . l proceeding north on Route 112. Traffic is to be U-turned and redirected south on Route 112 or east on Rose Lane. (Appendix A, at IV-65). Directing northbound traffic east at this loca-tion will be perceived by many motorists as contrary to the best route out of the EPZ, since it forces motorists to drive toward the Shoreham plant. Some of these motorists will un-doubtedly refuse to follow this prescribed route and will con-tinue north on Route 112 so that they can enter onto Route 347 and travel in a westerly direction away from the plant. It should also be noted that there is no traffic guide provided at the intersection of Roosevelt and Route 112. Evacuees, howev-er, will be exiting Roosevelt onto Route 112 from Terryville Road and Jayne Boulevard. Those evacuees wanting to go north I
to Route 347 will attempt to cross the southbound lane of Route 112 and will be stopped in their northbound travel at Rose Lane, where they will be directed easterly (into the EPZ) or U-turned. This will be a frustrating circumstance, likely to result in confrontations with LILCO's traffic guides. Certain-ly, it will create congestion and reduce traffic flow. ( Post #56 - Rt. 25A at CR 83 -- The two traffic guides at I l this post are to establish a roadblock to prevent traffic from p - w
( l proceeding south on County Road 83. Any. northbound traffic on i County Road 83 is to be directed east on Route 25A, and westbound through traffic is to continue in a westerly direc-tion. (Appendix A, at IV-65). Establishing a roadblock to prevent southbound traffic on County Road 83 will un-questionably be a problem at this location due to the populari-ty of County Road 83 as an access route for the Long Island Ex-pressway. Moreover, directing northbound traffic eastward on i Route 25A will likely be perceived by motorists as contrary to i the best route out of the EPZ, since they would then be trav-elling toward the Shoreham plant. Thus, it is not likely that the traffic strategy at this traffic control post will be obeyed. Similarly, the traffic strategy at traffic post #79 (County Road 83 at Granny Road) (Appendix A, at IV-71) would likely be disregarded by motorists wanting to turn left onto County Road 83 in order to access the Long Island Expressway westbound.lS/ 10/ The traffic control strategy for traffic post #56 is an-other example of the many inconsistencies in LILCO's traf-fic control strategies. In fact, the strategy for this traffic post is in direct conflict with the turn movements prescribed for traffic node 30 (Appendix A, Table XII, at IV-37). Whereas the traffic guide at post #56 is to
; prevent traffic from travelling south on County Road 83 (Patchogue-Mount Sinal Road), traffic at traffic node 30 is instructed to turn south onto this road from Route 25A.
l
'" w - - q$my
I As the preceding examples make clear, substantial numbers of evacuees can be expected to deviate from LILCO's prescribed traffic routes. This will result in conflicting traf fic flows and congestion. (See also Pigozzi testimony; Herr testimony; Saegert testimony). The traffic congestion which will occur will be exacerbated by the inability of LILCO's traffic guides to direct or control traffic effectively. O. Please explain why LILCO's traffic guides will be un-able to direct or control traffic. A. People are generally skeptical about accepting direc-tions from others. They may accept the directions of uniformed personnel, such as police officers, because of the authority they possess and the government institutions they represent. But they will pay far less attention to persons out of uniform, partly because they have no reason to believe that such persons are authorized to regulate the conduct of others, and partly because they have no reason to believe that there is a way for j such persons to enforce compliance with the instructions or directives baing given. 1 l
)
l While motorists are generally willing to accept the direc-tions and instructions of a uniformed police officer directing ! traffic, they are less willing to obey a person who is out of uniform, even if that person happens to be a police officer. a We have all directed traffic while out of uniform and, almost I without exception, there are some motorists who attempt to ig-nore or disregard wnatever instructions are given. Directing traffic is always difficult, but to direct traffic without the i semblance of authority provided to a police officer by his uniform is even more difficult. LILCO's traffic guides, therefore, would face an almost insurmountable task in attempting to direct evacuation traffic along LILCO's prescribed routes. In fact, many evacuees will ' likely identify the traffic guides as LILCO employees and blame them for forcing them to evacuate their homes. (See Saegert j testimony). As a result, whatever directions are given will likely be viewed with skepticism and even hostility, leading to l traffic delays. (See also Suffolk County testimony on Conten-l tion 15 (LILCO's Lack of Credibility)).ll/ i l 11/ Of course, traffic would likely be delayed for other , reasons as well. For example, because traffic guides will l be viewed as LILCO employees, evacuees would likely try to (Footnote cont'd next page) l l 1
I Further, driver behavior is shaped by perceptions of the traffic directions being given. When such directions are con-trary to intended goals and, from a driver's perspective, are ill-advised, drivers may behave aggressively and may deliber-ately disobey whatever directions are given. As discussed ear-lier, many of the turn movements and evacuation routes pre-scribed by LILCO will be perceived as being contrary to the in-terests of evacuees, and they will respond accordingly. At best, evacuees will argue with or attempt to persuade LILCO's traffic guides that a mandated traffic route is not the best way out of the EPZ. This will cause traffic delays and conges-tion as traffic backs up behind upset drivers.11/ Such delays (Footnote cont'd from previous page) solicit information regarding what is happening at the plant, and the degree of danger involved. This would also result in traffic backups and delays. 12/ Revision 2 of Appendix A no longer describes the actions of traffic guides as " preventing" evacuees from travelling contrary to LILCO's prescribed evacuation routes; instead, traffic guides are now described as " discouraging" evacuees from travelling contrary to prescribed routes. Conversely, evacuees are to be " encouraged" to comply with LILCO's prescribed routes and its traffic control l measures, such as channelization treatments, discussed suora. (See Figure 8, Appendix A, Rev. 2). In our opinion, whether described as " preventing" or ! " discouraging" traffic flow, the result will be the same: (Footnote cont'd next page) l
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. o l
I l and congestion may lead to physical confrontations between l LILCC's traffic guides and evacuees and even between evacuees, further delaying evacuation times. Without question, a l substantial number of evacuees will simply ignore the direc-I tions given by LILCO's traffic guides and travel along routes that they believe provide a more direct way out of the EPZ. An analogous situation can be found at places of roadway f construction. Despite advance warning signs advising motorists that an upcoming lane is closed, some motorists will invariably I continue in this lane until they reach the construction site barrier and can go no further. They will then attempt to merge into the adjacent lane, causing delays and congestion. They will also verbally and sometimes physically abuse construction workers, especially the road flagmen, whom they blame for caus-ing the traffic congestion and. delays. (See, e.g., the excerpt from the September 8, 1983 Newsday article, appended to this testimony as Attachment 6). (Footnote cont'd from previous page) there will be traffic delays and congestion as confused and angry motorists are given directions which they will perceive as contrary to their best interests.
This same type of driver behavior, or worse, must be ex-pected to occur should an evacuation of the EPZ ever be neces-sary. In our opinion, this is another reason why LILCO's traf-fic control plan could not be implemented and carried out suc-cessfully. Q. Wouldn't LILCO's training program for the traffic guides alleviate many of the problems you have described? A. No. We have reviewed LILCO's training program for the traffic guides and, in our opinion, it is totally unre-alistic to expect that, based on the training received, LILCO's traffic guides will be able to direct or control traffic with any degree of success, particularly in light of the extreme circumstances and high anxiety that would exist during an evac-uation. (See Saegert testimony). Many specific deficiencies in the LILCO training program will be discussed'in detail in the Suffolk County testimony concerning Contentions 39-41 and 44.D, E and F. Certain matters are pertinent here, however. Classroom training, at best, can only provide the fundamentals of traffic control techniques. However, the abil-ity to direct and control traffic successfully is a skill that i
I i can only be developed through time and experience in the field. For just this reason, rookie police officers, after 18 weeks of intensive training, testing, and graduation from the Suffolk County Police Academy, assume patrol duties under the close su- , pervision of a veteran police officer, who prepares a daily report on the rookie police officer's progress. Curing the first year, rookies are kept on probation status, watched by veteran officers. Only after a year's time is the probation status removed. In fact, for the first six months, a rookie 1 police officer is never sent into the field without the direct supervision of a certified training officer. Despite these precautions, trained police officers will e invariably make some mistakes during the early years of a ca-reer. It is not unusual, for example, for a rookie police of-ficer caught up in his first high speed chase to be involved in an accident. Such " rookie accidents" are part of learning how l to deal with stress and anxiety. Mistakes also occur in the l course of directing traffic which, in some respects, is a difficult task for even experienced police officers. To repeat, traffic direction is a skill. It is a skill which requires the ability to concentrate on a variety of. changing , w y w, -w< m
s t o l facts and circumstances while performing under, at times,
.st essdul conditions. Overcoming the stress, anxiety and frus-tration invariably connected with traffic control duties e e' r' requires c'ensiderable~ experience.
- i ,
, In o r'opinien, LILCO's proposed reliance upon inexperi-
,_ enbed personc, who are not receiving sufficient ongoing t ,
training,'ito perform traffic control responsibilities is im-practical, unworkable, and cannot lead to a traffic control plan capable of being implemented. It will create confusion rather than eliminate it and will likely result in increased traffic congestion and traffic accidents. Nevertheless, LILCO i intends to use just such inexperienced persons as traffic
, . i guides. (See, e.g., J. BarEcws deposition)l13/ LILCO's traf-fic guides are}'LILCO employees. The vast majority are meter readers; the others are persons wit jobs such as customer relations representatives. (See computer printout dated October 27, 1983, entitled "LERO Organization," produced by 13/ For example, during his deposition, Mr. Barrows stated that he was not qualified to be a traffic guide, that he 1
had no experience in directing traffic, and that he had 1 never directed traffic. (Barrows deposition at 25-26, 51-52).. s
\
/
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I r h I A ( l I i 5 , _ _ _ _.
LILCO on November 11, 1983 in response to Suffolk County discovery requests ("LEBC Organization printout")). For the most part, these traffic guides will have never directed traf-fic, even urder training conditions, since the LILCO training program does not include any traffic direction exercises. In fact, the LILCO drills and exercises for traffic guides really consist of little more than familiarization with the mobiliza-tion and briefing procedures that are expected to be imple-mented at the various staging areas. Each traffic guide's
" field experiences," for example, will consist of little more than driving to the location of a traffic control post, where he can observe the post and traffic conditions. (See "Long Is-land Lighting Company Local Emergency Response Organization Traffic Guidance Drill," prepared by Impell Corporation, October, 1983, and produced by LILCO on November 16, in re-sponse to Suffolk County discovery requests). Thus, if LILCO's traffic guides are ever put to the test, it will be during a radiological emergency, under conditions that would severely test even an experienced police officer.
The LILCO traffic guides will face other obstacles as well. Many of them do not live or work in or near the EPZ. In
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l o . fact, more than 55 percent of LILCO's traffic guides live more than 30 miles from the Shoreham plant, and more than 59 percent work more than 30 miles from the plant. (See data regarding approximate distances from the Shoreham plant for LILCO-designated traffic guides, prepared from the LERO Organization printout and appended to this testimony as Attachment 7). These persons, therefore, will probably not be intimately familiar with the area and the traffic posts assigned to them.ld/ Familiarity with the area -- including side roads and established traffic patterns -- is extremely important to the performance of traffic control duties and, like actually
- directing traffic, can only be learned over time through direct l
experience. Even with the best possible advance planning, un-expected conditions will develop requiring immediate decisions and changes in traffic strategies. Without a good knowledge of 14/ For example, Mr. Barrows testified at his deposition that he did not know the boundaries of the EPZ. (Barrows depo-sition at 75-76). Nor could he identify the location of i the Shoreham plant more precisely than "the north shore of ! Long Island." (Id.) This was despite the fact that he had already received his classroom overview training regardinr the LILCO Plan. (Id. at 66). That is, he had been taug.st about the location of the plant and the EPZ, but still could not identify either the plant's location or the EPZ boundaries.
-- - - - - -- - - , - - -~
the area, including familiarity with the local roadways and the locations of emergency and special facilities, more often than not, the decisions made by traffic guides and the changes in traffic strategies that they may be required to implement will not be successful. Coordiration of traffic between the traf fic guides would suffer, very likely resulting in conflicting traf-fic flows and congestion.ll/ For example, traffic may be directed into a heavily congested area, thereby further delay-ing evacuation times. Should a traffic guide not be familiar with the area where he is posted, traffic could be directed contrary to instructions that might be communicated to him while he is at his post, simply because the area is unfamiliar and the streets and roads unknown. Lack of familiarity with the area will also lead to evacuees losing confidence in LILCO's routing strategy, since traffic guides would be unable to answer inquiries from evacuees or to tell them where a particular or alternate route will take them. Of course, 15/ Coordination between traffic guides will, in any event, be limited due to the communications system proposed under the LILCO Plan. Deficiencies in LILCO's communications system will be discussed in Suffolk County testimony ad-l dressing Contentions 28-34 (Communications Among Emergency Workers). l
motorists would also lose confidence in the traffic guides, and this would further undermine the LILCO traffic control strategies that are to be implemented and enforced at other traffic posts and designated intersections. 2 Please summarize the concerns and conclusions you I have made with respect to Contention 65.C.4. A. In our opinion, LILCO's traffic control plan is in-herently flawed. It is a paper exercise, and would not work. It is based on a traffic control scheme with prescribed routes and traffic movements. It therefore lacks the flexibility to deal with problems likely to occur during an evacuation. (See Herr testimony; see also Pigozzi testimony). Moreover, LILCO's plan is based on some unrealistic as-sumptions. It is unrealistic to assume that LILCO personnel can effectively direct and control traffic. It is also unrealistic to prescribe evacuation routes, just as it is unrealistic to assume that evacuees will comply with LILCO's prescribed routes and traffic control strategies, even if those routes and
- strategies are contrary to their perceptions of the most expeditious way out of the EPZ. Nevertheless, LILCO's traffic
control scheme relies upon such unrealistic assumptions. In our opinion, this scheme is therefore unworkable and could never be successfully implemented. V. Contention 65.C.1 0 Contention 65.C.1 alleges that by screening motorists moving in a direction contrary to LILCO's prescribed traf fic routes, traffic guides will impede traffic flow and cause traf-fic congestion, further increasing LILCO's evacuation time estimates. Do you agree with this Contention? A. Yes. We understand that in its recent revision to Appendix A (Revision 2), LILCO has " abandoned" the concept of screening motorists moving in a direction contrary to pre-scribed traffic flows to determine whether each motorist has a
" good reason" for going in that direction. (See LILCO's Reply to Suffolk County's Motions for Delay of Its Testimony Filing, dated November 10, 1983, at 3-4, citing LILCO's " abandonment of forcible evacuation perimeter control measures"). LILCO, how-ever, still intends to " discourage" traffic moving contrary to prescribed traffic flows. (Appendix A, Rev. 2, at Figure 8).
For example, LILCO traffic guides will use cones to channel
traffic onto certain roads or to close one or more lanes to traffic. (Lieberman deposition at 253-54). Other devices, such as barriers and vehicles, will also be used in an attempt to force evacuees to travel along prescribed routes. (Appendix A, Rev. 2, at IV-19). Under the best of circumstances, such traffic control devices will likely disrupt traffic and cause considerable congestion by causing traf fic .to slow down. For example, some personal contact between traffic guides and mo-torists moving in directions contrary to prescribed traffic flow will still be necessary. Motorists will stop to ask questions or to persuade traffic guides to let them go in their intended directions. At the very least, motorists may slow down before going through a barricade or cones set up to
" discourage" them from driving in a particular direction. In short, LILCO's traffic control scheme will cause disruption and, ultimately, congestion because motorists will have to slow down or stop in response to the LILCO traffic controls.
Morever, even with LILCO's abandonment of a formal screening process, there will have to be at least two traffic guides at each traffic post. Otherwise, any time that a traf-fic guide talks to one motorist, several others will likely I - I
take advantage of~the opportunity to proceed along intended routes that might be contrary to the routes or traffic strategies prescribed by LILCO. Of course, motorists who stop because they are confused or because they want to ask questions will block motorists behind them from continuing. This will back up traffic and cause motorists to change lanes, likely re-sulting in further delays in traffic flow. From a practical standpoint, therefore, the traffic control methods proposed by LILCO will only cause additional traffic congestion and delays. The end result will likely be that motorists will travel in whatever direction they wish to travel, but it will take them even longer to get there becacce they will have to deal with LILCO traffic guides or control mechanisms, and resulting delays and congestion, along the way. LILCO's traffic control methods and devices and its ef-forts to " discourage" motorists from travelling contrary to prescribed traffic flows may also lead to confrontations between traffic guides and evacuees. Even under " normal" traf-fic conditions, police must often confront angry motorists who do not wish to obey traffic directions. For example, drivers stuck in congested traffic frequently display anger and
hostility toward police officers if they believe that the officers are doing an inadequate job of directing traffic. Under the conditions that would exist during a radiological emergency, anger and anxieties could quickly escalate into ag-gressive behavior. The fact that LILCO's traffic guides will j not be uniformed or authorized to direct traffic will eliminate constraints that might otherwise prevent many drivers from dis-playing such aggression. As a result, LILCO's traffic guides might be assaulted by enraged drivers. Surely, they will be j ignored by many people. (See Saegert testimony). I In summary, LILCO's proposed methods of dealing with mo-torists who wish to go in directions contrary to the LILCO pre-scribed routes will not work and will, in fact, result in back-ups and delays. (See Pigozzi testimony; see also Herr testimo-ny). VI. Contention 65.C.2 Q. Contention 65.C.2 alleges that LILCO's attempted use of traffic controls will cause aggressive behavior on the part of evacuees and conflicts between evacuees and traffic guides, , resulting in traffic delays and increased traffic congestion. 1 Do you agree with this Conte,ntion? I j l i
A. Yes. There is every reason to expect aggressive behavior by motorists attempting to evacuate the LILCO EPZ. ' Whenever there are heavy, stop-and-go traffic conditions, driv-ers become aggressive and more willing to disregard traf fic i laws. As police officers, we have all witnessed the frequent l lane changing and shoulder riding that invariably occur when traffic is congested. During rush hour traffic on the Long Is-land Expressway, shoulder riding is common, despite intensive law enforcement against this hazardous practice. It is also common for motorists to travel along service roads, which are one-way routes adjacent and parallel to the Long Island Ex-pressway, in an attempt to bypass congestion on the Expressway. During a radiological emergency and subsequent evacuation of ! the EPZ, this would be a particular problem for motorists -- and traffic guides -- unfamiliar with the area, because many of l the Expressway service roads in Suffolk County are incomplete and dead end without warning. The aggressive behavior which must be expected on the part l ( of those attempting to evacuate the EPZ will stem in part from 1 fear of radiation and in part from the confrontations with traffic guides,that will result when motorists decide that it D
is in their best interests to travel contrary to the directions l l of LILCO's traffic guides. (See discussion, supra). Fear affects driver behavior and performance. Fear causes people to take whatever action they feel is necessary to protect themselves and their families. If a LILCO traffic guide were to " discourage" a driver already fearful for his and his fami-ly's safety from driving on a certain road, there is little likelihood that the traffic guide's directions would be obeyed. (See Saegert testimony). If the driver were allowed to take the road, other drivers would likely follow his lead, hoping perhaps that he would l'ead them to a short-cut route that would evacuate them more quickly. The most well-meaning efforts by traffic guides would not be able to prevent this from happen-ing. In our opinion, the aggressive behavior by evacuees which has to be expected during a radiological emergency would leave LILCO's traffic guides powerless to control traffic or to enforce LILCO's traffic strategies. This aggressive behavior would likely result in accidents, traffic backups, and i potential grid-lock. Without question, traffic guides themselves would face the brunt of driver hostility and f i
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aggressiveness. During the gasoline shortages of the 1970's, drivers on Long Island literally fought over positions in gas lines. At least one person was killed when an overly aggres-slve driver drove into him as he was pumping gas into his car. In our opinion, similar aggressiveness could result during a radiological emergency and ensuing evacuation, for then people would face life-threatening fears for their safety. For this reason, it is reasonable to expect assaults and fist fights between motorists and between motorists and traffic guides. i ! In short, there is a very real potential for conflicts l between LILCO's traffic guides and evacuees. Such conflicts would result in traffic backups, confusion, accidents and possibly injuries, all of which would increase traffic conges-tion and evacuation times. (See also Herr testimony; Saegert testimony). The LILCO Plan and time estimates, however, never address such behavior, thus reflecting their lack of validity to the real conditions that would be faced on Long Island. (See Pigozzi testimony).
VII. Contention 65.C.3 Q. Contention 65.C.3 alleges that because LILCO's traf-fic guides will not alter traffic signal lights, the traffic control strategies they implement may be contrary to the direc-tions given by the signals, causing confusion and congestion and further delaying traffic movement. Do you agree with this contention? A. Yes. Attempting to regulate traffic contrary to traffic signals or control devices, such as traffic lights, is extremely difficult and usually proves unsuccessful. It results in confusing motorists. People are conditioned to pay attention to and obey traffic signals by years of habit and driving experience. Moreover, traffic signals are generally much more visible to approaching traffic than is a person standing in the highway or intersection. Thus, any time traf-fic is directed contrary to traffic signals, motorists are i being given mixed instructions as to how they are to proceed. When uniformed police officers direct traffic under these circumstances, the results are not always successful, and there is almost always a problem. LILCO's traffic guides, however, 4
i will experience even more difficulty in attempting to direct traffic against traffic signals. In all probability, motorists will only obey LILCO's traffic guides or traffic signals when, by doing so, they are able to do what they want to do anyway, i.e., go forward. In any event, motorists will become confused, thereby increasing the likelihood of accidents, possibly with injuries, further causing delays in traf fic flow. Q. Couldn't LILCO's traffic guides direct traffic in coordination with traffic signals such as traffic lights? A. No. Many traffic lights are traffic actuated, i.e., they are designed to cycle in accordance with the flow of traf-fic. The sporadic traffic flow and delays that will result from the confusion of motorists approaching intersections where the traffic is being directed by LlLCO's traffic guides will disrupt the normal function of traffic signals, thereby making I it impossible for traffic to be directed in coordination with the cycle of the signals. For this reason, police officers, -l when required to direct traffic against traffic signals, will either turn off the signals or put the signals on flash. In this way, motorists are not confused by conflicting l instructions and the officers can gain control of.the I
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e , situation. However, LILCO's traffic guides are not going to change traffic signals in any way. (Compare Appendix A, Rev. O to Appendix A, Rev. 1). Thus, motorists will be confronted by conflicting instructions, leading to confusion and further increasing traffic congestion and evacuation times. VIII. Contention 65.D Q. Contention 65.D reads as follows: i The LILCO time estimates assume that
'[nlo major vehicle breakdown or other types of incidents [will] occur which block major routes for an extended time." (Ap-pendix A, at V-2). This assumption is un-realistic and leads to an underestimation of the time required for evacuation. Exam-ples of factors which increase congestion and thus increase time estimates, and which should have been included in LILCO's estimates, include:
- 1. Anticipated traf fic accidents and l automobile breakdowns, including running out of gas (for example, the Suffolk County police responded in 1982 to 10,000 incidents such as accidents and breakdowns I on the Suffolk County portion of the Long i Island Expressway, thus indicating the potential for this factor to influence se-l verely evacuation times);
{ ! 2. The absence of shoulders on some primary or secondary routes which will be used during an evacuation; l l l
- 3. Road construction / repair work which can be assumed to be ongoing at any time; and i
- 4. Abandonment of vehicles under emergency conditions.
Do you agree with this Contention? A. Yes. As pointed out in Contention 65.D, Appendix A, at V-2, states explicitly that LILCO's evacuation time estimates do not consider the effects of " major vehicle break-down[s] or other types of incidents" which may block evacuation routes. In our opinion, without considering such factors as accidents, breakdowns, cars running out of gas, the absence of shoulders on some evacuation routes, road construction and repair, and the abandonment of vehicles, the LILCO time estimates are unrealistic and substantially underestimate the time required for evacuation. l l Q. In your opinion, are traffic accidents and automobile breakdowr. likely to occur during an evacuation? A. Certainly. During 1982, the Suffolk County police responded to approximately 10,000 incidents such as accidents and breakdowns just on the Suffolk County portion of the Long Island Expressway, a distance of approximately 43 miles. __ _ ~ _ _
Accidents and breakdowns occur every day, and during the emergency atmosphere of an evacuation, the number and severity of these incidents would likely increase dramatically. (See Polk testimony). Of course, it would not take a major accident or breakdown to cause heavy congestion and traffic backups. During an evacuation, with heavy traffic conditions, interrup-tions in traffic flow would cause congestion. People are re-luctant, in most situations, to drive away from an accident they are involved in and leave their cars where they are, even after a minor accident, until the police arrive to "investi-gate." During an evacuation, people would likely be more willing to move on and worry about the damage later. However, some people would stop and at least engage in conversations and, depending on the circumstances, confrontations with the driver (s) of the other car (s) might result. Some drivers would stop their cars in traffic lanes, blocking traffic behind them. This would cause other drivers to change lanes, increasing the chances of other accidents. Of course, some accidents might result in injuries to drivers or passengers that are severe enough that continuing out of the EPZ would be impossible. ! Further, some cars would be damaged and unable to move. Invariably, drivers passing by the scene of an accident will l l
I slow down and " rubberneck," further slowing traffic. If a vehicle were damaged so as to render it inoperable, it may be impossible to move it to the shoulder of the road (assuming one exists) because, in all probability, the shoulder would be unavailable due to its use as a traffic lane by motorists seeking to get aromad the accident. Other factors also would slow traffic. Even without accidents, breakdowns will occur. (See Polk tes;'.imony). For example, cars will run out of gas and will likely be abandoned.16/ In the heat of summer, slow moving traffic results in some vehicles overheating and stalling in traffic lanes. Fog and heavy rain reduce traf fic flow and can cause congestion. Winter storms, particularly snow or ice storms, also result in reducing traffic flow, causing congestion, as slow moving traffic loses friction with road surfaces. During a snowstorm in 1979, nearly 3,000 vehicles were abandoned in the traffic lanes of the Long Island Expressway when a tractor trailer slid in the snow, blocking the Expressway. 16/ LILCO's plan to dispense fuel from LILCO fuel trucks at c locations (yet undefined) along evacuation routes (Appen-dix A, Rev. 2, at IV-179) will be addressed in Suffolk County's testimony on Contention 66.
l l Q. Where, in your opinion, would most traffic accidents and breakdowns occur during an evacuation? A. It is safe to say that many accidents and traffic problems would occur at traffic intersections. Attached to this testimony as Attachment 8 is a list of the 15 intersec-tions within the Sixth Precinct with the highest number of reported traffic accidents during the year beginning September 1982. Four of these intersections are not designated as manned traffic control posts under Appendix A, even though, for these four intersections, a total of 80 traffic accidents were reported during the last year.ll/ If all the accidents that could affect an evacuation were included in this total, the figure would be substantially higher. All these intersections are located within the Sixth Precinct patrol area inside the 10-mile EPZ. Major highways and heavily travelled roads would also be prime problem areas for accidents and breakdowns. These would 17/ 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 probably not reported.
l include the Long Island Expressway, the William Floyd Parkway, Route 347, Route 112, the Sunrise Highway, Nicolls Road, and Routes 25 and 25A. Traffic flow would be heaviest along these routes and, accordingly, a significant number of accidents and breakdowns would likely occur. Attached to this testimony as Attachment 9 is a chart showing the results of a study prepared i by the Suffolk County Police Department of traffic accidents which occurred during the last year along designated roadway sections of five major highways within the Sixth Precinct (Rt. 25, Rt. 25A, County Road 21, County Road 83, and Rt. 112) relied upon by LILCO as major evacuation routes. (See cenerally, evacuation routes, Appendix A, at IV-89 through IV-177). The roadway sections chosen correspond to traffic I nodes identified in Appendix A. Two traffic nodes were selected for each major highway. Intersecting roads between these nodes and the major highways were identified and surveyed for traffic accidents reported during the last year. A total of 977 traffic accidents were reported at the 126 intersections identified. Of these 126 intersections, only 31 are designated I as manned traffic control posts in Figure 8 to Appendix A.
Many of the roads and intersections in the immediate vi-cinity of the Shoreham plant also provide likely locations for i traffic accidents and breakdowns. Certain roads, for example North Country Road, North Wading River Road, and Randall Road (east), are somewhat hilly and winding and their capacity to , handle heavy traffic flow is severely limited. Nonetheless, these roads are relied upon by LILCO as evacuation routes. (See generally, evacuation routes, Appendix A, at IV-89 through IV-177). Even some of the major highways close to the Shoreham plant, such as Routes 25 and 25A, are intersected by a number of streets and thus become heavily congested very quickly. Q. Would the absence of shoulders on primary or second-ary routes increase traffic congestion and delay traffic flow? A. Yes, and there are a number of roads in the EPZ that either have no shoulders or have inadequate shoulders. In fact, only the Long Island Expressway and the William Floyd
' Parkway have fairly wide shoulders along most of their road surfaces. The other major roadways in the EPZ -- Routes 25 and 25A -- have limited shoulders in substantial areas.
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Many of the secondary roads in the EPZ have shoulders that are not paved, and, in reality, are just strips of sand. These shoulders could not be driven without four-wheel drive vehi-cles; other vehicles would sink into the shoulder area. In addition, many of the roads without shoulders are flanked by wooded areas, embankments, or gullies. Thus, any vehicle l breakdown or accident would block a substantial part of the roadway, severely limiting traffic flow. Along these roads, emergency vehicles would be severely hampered or even precluded from quickly responding to traffic accidents and other emergencies, since there would be no route of access not blocked by evacuating traffic.
! Attached to this testimony as Attachment 10 is a listing of shoulder capacities for roadways in the EPZ.
Q. Would road construction / repair work increase traffic congestion and delay traffic flow? A. Yes. At any given time, there is construction or road repairs taking place on roads in Suffolk County. Road construction and repair or maintenance work impedes traffic flow even under normal conditions. In an evacuation, with
l i increased traffic flow, traffic congestion and delays would be far worse. Moreover, some construction / repair work could not I be stopped so as to allow traffic to proceed unimpeded. For example, cement may be broken open for repair work; these lanes could not be repaired quickly and would be unavailable to traf-fic. Due to the congestion created by road construction and repair work, attempts have been made to close certain roadways during nighttime hours in order to perform repair work with the least disruption to traffic. The Long Island Expressway is an j example of where, despite this approach, heavy congestion at detours and at secondary roads has resulted. In addition, there have been several instances of truck drivers not familiar i with the area who have attempted to bypass construction by en-tering parkways, only to strike overpasses which do not provide sufficient clearance. This has brought about disastrous I consequences: not only is capacity along the Expressway limit-ed, but the secondary parkway road is rendered impassable. Q. Would the abandonment of vehicles increase traffic P congestion and delay traffic flow?
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I A. Yes. When vehicles are abandoned, traffic lanes be-come impassable until the vehicles can be pushed off the road surface or towed away. On roads where there are no shoulders, towing is the only option. Towing a vehicle is a time consuming process even when the emergency equipment is avail-able. Of course, under the congested traffic conditions that would characterize an evacuation of LILCO's EPZ, it is unlikely that tow trucks would be able to quickly get to dis-abled/ abandoned vehicles. People will abandon vehicles for any number of reasons. During adverse weather conditions, for example, the abandonment of vehicles is commonplace. Until another motorist renders as-sistance to remove the vehicle from the road, the dis-abled/ abandoned vehicle will remain in a traffic lane and cause delays and possibly accidents since other motorists change lanes in an attempt to get around the disabled / abandoned vehi-cle. While some people might ordinarily render assistance to a disabled motorist, many other people will merely drive around the disabled vehicle and continue on their way. This would certainly be more likely during a radiological emergency. Then, people would probably only stop to render assistance if l
l they believed that removal of the vehicle from the roadway 6 would provide their only way to continue driving out of the EPZ. IX. Contention 65.H 0 Contention 65.H alleges that LILCO has not provided enough evacuation route spotters to cover the evacuation routes and that, in any event, these route spotters will be unable to move expeditiously through heavily congested traffic. As a result, it is claimed that LILCO will be unable to know about and to implement appropriate measures for evacuees to avoid such congestion, resulting in increased evacuation times. Do you agree with this Contention? A. Yes. There is no doubt that the six evacuation route spotters provided for under the LILCO Plan (Rev. 2, Figure 2.1.1, page 3 of 4) cannot cover the evacuation routes pre-scribed by LILCO, even assuming that there would be no traffic congestion impeding their travel through the EPZ. Of course, there will be such congestion, and LILCO's evacuation route spotters will be subject to the same traffic conditions pre-vailing for other vehicles. Movement through congested traffic
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i . I l conditions will be difficult, if not impossible, at times. To i our knowledge, these route spotters will not be driving vehi-cles recognized by the public as emergency vehicles; nor will these vehicles be equipped with sirens. Further, travel along shoulders, if they exist, will be impeded by other traffic and, in all likelihood, abandoned / disabled vehicles. There is no reason to expect other motorists to yield to these route spot-ters and, as a result, they will travel only as fast as the traffic flow permits. X. Contention 23.H Q. Contention 23.H alleges that the LILCO Plan fails to provide adequate measures at the EPZ perimeter to control access to evacuated areas. Do you agree with this Contention? A. Yes, in our opinion regardless of the technique or tactic used, LILCO's traffic guides will not be able to provide l adequate access control into the LILCO EPZ. In the event of a radiological emergency at Shoreham, some persons will attempt to get to their homes and families and they will not be deterred by the fact that this would cause them to travel into the LILCO EPZ. Other persons would seek access into the EPZ l ; l I
i . for other reasons, including pertaps to loot vacated houses and businesses. In addition, transients and others not aware of an evacuation order might unintentionally enter into the EPZ and thereby be exposed to, and contaminated by, health-threatening radiation doses. Whatever the reason, LILCO's traffic guides l will not be able to control access into the EPZ with any degree of success. This is primarily because the LILCO Plan virtually ignores access control into the LILCO EPZ or portions of the EPZ. (See Attachment 11 to this testimony for a listing of in-tersections that would have to be manned by persons with requi-site authority in order to prevent vehicular traffic into evac-uated areas of the EPZ). Even if LILCO were to provide for adequately manned traf-fic control posts at every route into the LILCO EPZ, traffic guides would not be able to provide adequate access control into the EPZ. LILCO's traffic guides lack the authority and the training and experience to direct and control traffic ef-fectively. Thus, evacuees are likely to disregard whatever instructions are- given to them by these traf fic guides. (See discussion, supra). c
t In our opinion, even trained, experienced police officers 2 would find controlling access into the EPZ to be an exceedingly difficult task. We sometimes have problems keeping people out of restricted areas during emergencies. If people.wish to l enter the area and believe they have good reason for doing so, they will do whatever they can to get into the area, irrespec-tive of the risk to their personal safety. We have all witnessed police officers having to restrain people who believe that their families are trapped from entering 1 burning homes. There is no reason to believe that people would act differently if they believed their families were trapped or otherwise i helpless inside the EPZ. They would do whatever was necessary ! to get into the EPZ. Traffic would be disrupted by traffic congestion and accidents. Disagreements and arguments between i motorists and with traffic guides would occur. Some violence 1 could be expected. l Moreover, without adequate access control into the EPZ, some persons may travel into evacuating areas without even realizing that they have done so. Then, of course,-there would l likely be additional traffic congestion within the EPZ, further increasing LILCO's evacuation time estimates. 4 I i , i- ., ;\
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4 i b . i Q. Do you have any other concerns regarding access ! control into the EPZ? A. Yes. The LILCO Plan fails to provide' adequate measures to control access into the EPZ from the East End of Long Island or'from Long Island Sound. As a result, people evacuating from the East End may cross into the EPZ without even kn,owing that they are travelling into contaminated areas. LILCO apparently recognizes the necessity of preventing traffic originating east of the EPZ from entering the EPZ dur-ing evacuation. For example, at IV-8 of Appendix A, LILCO pro-poses to establish a roadblock at N.Y. 25 and County Road 105 (traffic post #23), in order to " prohibit westbound traffic from. travelling west toward the EPZ, and to redirect them south toward the Sunrise Highway." However, this post is only to be
' manned if an evacuation were ordered on'a weekend during May 1 to October 1. Moreover, it would be necessary to provide road-bl'acks or other traffic control measures at.many \ more than this r
single location in order to reroute westbound traf fic from the East End south toward the Sunrise Highway. Attachment 12 to this testimony sets forth other locations that would have to be manned.
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For example, there are several routes into the EPZ from both the North and South Forks of Long Island. However, as mentioned, the only LILCO traffic control post that would be able to control access from the North and South Forks is traf-fic post #23. On the North Fork, there are no traffic posts along Sound Avenue, Northville Turnpike or County Road 58. On the South Fork, there are no traffic posts along County Road
'104 or State Route 24. In our opinion, LILCO's failure to provide for traffic posts or other measures to control access into the EPZ from the East End is a further serious deficiency of the LILCO Plan which emphasizes LILCO's incapability to devise or implement a workable plan.
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O O 1 i l ATTACHMENT 1
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Attachment 1 1 l j i Statements of Qualifications of ' Suffolk County Police Decartment Witnesses 3 on Emergency Planning Con'tentions 65 and 23.H i Suffolk County hereby submits the qualifications of the j following Suffolk County Police Department officers who will testify on Emergency Planning Contentions 65 and 23.H on I behalf of Suffolk County: 4 i ! Inspector Richard C. Roberts Inspector Joseph L. Monteith Deputy Inspector Philip McGuire Deputy Inspector Michael J. Turano, Jr. Captain Edwin J. Michel i i f i l
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RICHARD C. ROBERTS Suffolk County Police Department ' Yaphank, New York EDUCATION: BA Degree, Criminal Justice Southhampton College, Long Island University Southampton, New York AAS Degree, Police Science State University . Farmingdale, New York - FBI National Academy Quantico, Virginia Successfully completed several in-service training courses, including Criminal Investigation School, Police Supervisor School and executive development seminars, conducted by my employer, the New York State Chief's of Police Association, the FBI Tr'aining Division and the New York State Division of Criminal Justice Services. . EMPLOYMENT: May 1956 to December 1959 Criminal Investigator Distr'ict Attorney's Office County of Suffolk, New Ycrk Conducted investigations of major crimes and indictable offenses, assisted in trial prepara-tion and performed related investigative activities. January 1, 1960 to Present . Inspector Suffolk County Police Department Yaphank, New York As a member of a Department with 2,600 sworn officers and 800 civilian employees, have been assigned to supervisory and managerial positions with progressive levels of responsibility. Performed duties at Squad, Bureau and Division levels, managing personnel engaged in patrol activities and the investigation of all classes of crime. Performed duti'es as a Precinct Commander, respon'sible. for the performance of 235 sworn officers and other , 4
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1 1 auxiliary police personnel. Area of responsibility included managing law enforcement activity in an area 170 square miles with a population of 235,000. , Developed skills as a supervisor, planner and administrator during twenty-six (26) years as a l professional law enforcement officer. l Participated in developing and implementing special j tactical response plans for policing municipal - facilities and industrial complexes, including the 2 Shoreham Nuclear Power Station and Parr Meadows Race . Track. Coordinated police and security activities with j facility and contract security groups representing l large shopping center complexes, industrial sites
- and government facilities.
i l Presently assigned as an Inspector with the Office 1 of the Chief of Patrol, Suffolk County Police Department. l AFFILIATIONS: - New York State Association of Chiefs of Police FBI National Academy Associates National Sheriff's Association American Society for Industrial Security 1 j i i ) m i t i I j - l l i l
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??CFESSIONAL ?AIi!ING. Cer:ificate fecm the ll cran Institute for the Study of Juvenile Delinquency,' St. Laurence University, June 2266 Certificate in Narcotic Lc= Enforcement, The U.S. Dept.
of Justice, Drug Enforcement AMnistration,1hrch 2376-Graduate. F.2.I. National Acaderu. ~ !! arch 2375 (200th Session) Certificates frcm various Lau Enforcement Schcois sponscred by the Suffolk Ccunty ?clice Departmen:. Tne Neu Iork State Chiefs of Folice Association. The Federal Bureau of Investigaticn, and the American Acade~.y for Professional Law Enforcement. Su.?s'oik Countu ?ctice Depar -ent. Zaphank Avenue.
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Ic.chank.Neu Icrk 12250 fune 1962 - Cc:cher 2255 ?:trolman: Ferfor-ci all of the duties of this posi:icn
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Cc:cher 2255 - 2:nuaru 2967 Detective: Juvenile .Aid . . Bureau - Rescensible for invest.
~. cat nc. cr res nvosv:n.c. .versons un:er :ne a.ce os aC
.u.e:rs. cre.carin.c. cases .'cr presen:ction in Edi.u Ccur::
and advising the Coun:y A :ctneu cn the disposition of these cases. Aisc responsible 'cr pericdid inspection cf public places frequented by ycw:g pecple (Licensci
- rem:.ses, ecci Halls, etc.) and :ching enforcement action when Carranted.
January 23E7 - !! arch 1963 Detective: Fifth Scuad - Responsible for the investigatic; of all felonies and certain misdemeanors committed uithin the area of the Fifth Frecinct. Duties included taking statements from complainants, defendants and uitnesses as cell as developing leads, conducting crime scene searches making arrests, and preparing cases for Grand Jury presen tation. ll:r:'h 22C3 - April 22C2 Detective: Criminal Intelligence Scuad, (A 22 member unit
^'ssigned'tc the c'.fice c.' the Chie.' of Cetectives) -
c s Responsible f.or the cc= .~ citation and an:Zysis cf. data concern:n; tne n stcr:es asscc ::ac. novements etc. cf perscns hncun or suscected to have ccnnections eith Crganized Cri=c. .
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vu e::ensive reycrt criting; as reli ac close liciccn uith cther Feder:: S :te. Ci:y and Local Lau Enfcree-i ment Agencics.
- Aprii 2262 ." arch 227i Serceant: Fifth Precina: Du:ies includei the direc: -
l ' supervision o.r 20 pciice o.f.'icers assig".ed to .fcot and motor patrol in a SS square mile area; evaluatina the . perfomances of these officers, enfcrcing the Capar:=ents Rulec and Procedures and assuming control of police . . . . cceratz.ons cur nc a c;ven tcur 0;,auty unen recu:.rea to do so. Y=rch 2271 - May 2272 Cetective Sergeant: Juvenile Aid Eureau^- Eceponsible any-sucervss cr ass:cnzna nc 2 c.e tect:.ves en a tour
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of a.u ty sn a corr:anc :7 tn coun:y-utae respons. c ?ity. . Dutzes sncluc. e a. extensive report urst.ng, evasuct:..cn of personnel and revieu of. ali Fanily Ccurt Cases refore suc.mi.ss on to ta= sty Cour:. Fay 2272 - fanuar.u 1974 Lieutenant: Third Precinct - Over ali responsibility
.for a Fiatcon consisting o.' C Sergeants and 72 Folice Officers. Dudes included assign::=ent of all personnel during a tcur of. duty _. inspecting personnel fcr fitness fcr du:y, n. ana,:ng csus,sen t ecm=.,.aznts a.n.,assu. ming. .
respons ..p:.l: ty s,cr tne overall pc7.ce m:.se:cn :n :ne absence of :he Cc nding Officer cv Ececutive Officer. 2:nuar.u 2274 - June 2276 Detective Lieutenant: Harcotic Squad - Ececutive O.f.ficer
- of the Unit. Recycnsible fcr narcotic drug enforcement in Suffolk County. :u:ies included supervising seven Detective Sergeants c~:i 'i':u De:ectives ucrhing out of t.nree offs.ce locat:cns; c= tens ve report urst.ng.
revieu cf Grand Jury Casec and consultaticn uith members of the District Attorney 's St:ff and U.S. Attorneys Offic During this assigr=ent assisted in the *ctm::icn c.? the a Long Island Drug inforcement Tack Forac a cocperadue effort of the Drug Enfcrecment Administration: Ecu !cPh State Police. :assau and Suffolk County Police Depart-ments and the Dictrict Attc.rney '.s of both coundes to s.n sp.ltretc and neutra,. :e n c. e: level c.ruc. .c' erat.cns
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on icng Island. ~ Junc 227E'- January 1972 Detective Lieuten n:: - Cc~:.:nding Officer Perscnnel
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Bureau (P cmoted to Captain chile in this position in February 7277) - Repordng to a Caputy Chief Inspector. The responsibilities of this posi don included A M nis-trative Control of the processing of all police and civilian employment applicants, preparation and certifi-caticn of payrolis fcr a 2,000 member Department as celt as con. mand responsibility for the Dngloype Relations Unit (Medical Evaluadon Unit - both instituted during ny tenure):The Personnet Investigaticn Unit and the . Ci:colain 's Unit. Other duties included liaison and Cco'rdinadon with the Ccunty cpart=cnt of Civil Service The Count.u Ececutive 's Euicet Os!.! ice as cell as :he . Count.u cpar:=ent c.' ?crecnnel and !.,chcr Relations. e
Page 3 - . . _ , . _ i January 1979 to January 1981 Decuty Inspector: Executive Officer of the Third Precinct - Overall Administrative l responsibility for a unit consisting of 257 sworn and 9 civilian personnel as well as 50 School Crossing Guards in an area with a population approaching 250,000. Duties include enforcement of internal discipline as well as evaluating the overall need for police services and allocating l resources to accomplish the police mission. Cn site inspection of personnel, frequent l liaison with Town and County Officials, cooperation with Civic Leaders and-utili-zation of Community resources are required. January 1981 to Present Inspector: Commanding Officer of the Sixth Precinct - Duties consist of exer-cising control over all members of my, Command . I am held responsible for the accomplishment of the police mission through the effective administration and operation of my Command including, but not limited to, deployment of personnel, discipline and efficiency, departmental property and equipment, comlaint investi-gation, procedure compliance , inspection , etc. TEACHING EXPERIENCE:- State University of New York A & T School at Farmingdale . September 1971 to Present I have served as an Adjunct Instructor and l Assistant Professor. In addition I have ' instructed periodically at the Suffolk County Community College since January 1976. Areas of Experience include: Introduction to Law Enforcement, Police Administration ,
- Juvenile Delinquency, Criminal Investigation and History of Law Enforcement and Criminal Justice.
MEMBERSHIPS: American Association of University Professort Suffolk County Police Benevolent Association Suffolk County Detectives Association (Past Financial Secretary and Treasurer) Suffolk County Superior Officers Association Police Holy Name Society of Suffolk County (Past Vice-President and President) American Association for Professional Law Enforcement F.B.I. National Academy Associates International Association of Chiefs of Police New York State Association of Chiefs-of Polic Patchogue Council 725 Knights of Columbus Sayville Yacht Club
REFERENCES:
Available upon request
. . l POLICE DEPARTMENT COUNTY OF SUFFOLK. NEW YORK N T E r s;.t c RREsFC . E .:E
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5/3/82 T: Police Ccmmissioner Donald J. Dilworth '
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r ; :'? Deputy Inspector Phili McGuire C.O. Special Patrol Br eau, Command 6400 Sus.'EC - RESUME OF SERVICE NAME Philip McGuire DATE OF BIRTH May 15, 1934 . ADDRESS 32 Thornhedge Road Bellport, New York 11713 TELEPHONE # 516-286-0933 The undersigned was appointed to the Babylon Town Police Department on August 1,1956 and served in the capacity of a patrol officer and desk officer until the inception of the Suffolk County Police Department on January 1, 1960 at which - time he was assigned to the First Precinct. After performing patrol duties and administrative duties
~ at the First Precinct, the undersigned was promoted to Sergeant in October, 1963 and assigned to the Second Precinct.
He was reassirned to the First Precinct during 1965 and then promoted to Lieutenant in January,1969 and performed the duties of a platoon commander, supervising the activities of a squad of approximately 70 men. In May, 1972, he was promoted to_ Captain and assigned as the. Executive Officer of the First Precinct, he continued in that assignment after having been promoted to Deputy Inspector j in January, 1974. . i l In January, 1975, the undersigned was assigned as the l Executive Of fic't . of the Legal and Inspection Bureau until February, 1977 when he was assigned as an assistant to the Chief of Dist:.ict. In February, 1979, he was assigned as the Commanding Officer of the Special Patrol Bureau and remains in that assignment to this date. .
. This assignment entails the administration and. direction of the Emergency ' Service Section, the Aviation Section, the Canine Section, the Crime Scene Section, and t'he Courts Section.
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2'- -- - Police Commissioner Donald J. Dilworth 5/3/82 The Emergency Service Section personnel are issued special weapons and equipment and are trained in detection and disposal of explosive devices. This section would have i a major role in the defense and protection of a public utility installation within the County. It is also conceivable that the Aviation and Canine Sections would be deployed in a mission of this type. The undersigned has attended various schools and seminars dealing with police operations, ethics, investigations and re-lated subjects given by the F.B.I., the IACP, New York City . Police Department and the Suffolk County Police Department. Respectfully submitted,
- - kb Philip McGu' ire, Deputy Inspector C.O. Special Patrol Bureau Command 6400 PMcG:if 1
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l Resume of: Michael J. Turano , Jr. l l l PERSONAL DATA: Born: November 17, 1931 Married: Wife, Margaret Children: Laura, Michael, Jeffrey, Richard and Scott EDUCATION: Bachelor of Science Degree in Criminal Justice /Behavorial Science from New York Institute of Technolocy, Old Westbury, New York Graduate - F.B.I. National Academy, December 1976 (107th Session) Certificates from various Law Enforce-ment Schools, Training Sessions and Seminars: Suffolk County Police Department, Municipal Police Training Council, New York City Police Department, Suffolk. County Executive Department, Federal Bureau of Investigation John, Jay College,
- United States Civil Service Commission State University of New York, United States Food & Drug Administration, New York State Traffic Safety Council, Tri-State Organized Crime Council, New York State Chiefs of Police Association.
EMP LOYMENT :
- June 1956 - December 1959 Smithtown Police Department Patrolman
- Performed various duties in i this capacity ie foot patrol, desk duty, motor. patrol, etc.
~ January 1, 1960 NOTE: As a result of a-public referandum f five (5) Western Suffolk County Townships l
i along with other local law enforcement agencies formed the Suffolk County Police Department. January 1960 - October 1964 Patrolman : Assigned to Communications Bureau. Duties including radio dispatching, complaint receiving, teletype' operator, etc.
e s l Page 2 - - - - . . . October 1964 - July 1965 Detective: Juvenile Aid Bureau'- Responsible for investigating crimes involving juveniles (under 16 years of age), preparing cases for presentation in Family Court and conferring with the County Attorney prosecuting these cases. Conduct periodic inspections of public places frequented by juveniles, ie premises licensed to sell alcoholic beverages, etc. and take enforcement-actions whenever warranted. , July 1965 - January 1970 Serceant : Patrol Division - Duties included that of Desk Supervisor, Patrol Supervisor and, at times , Platoon Commander. Supervising 3 to 20 Patrolmen with respon-sibilities toward compliance with Depart-ment Rules & Procedures , training, ev.alua-I ting personnel performance and direct ' involvement / control of incidents when required. January 1970 - July 1973 Lieutenant: Patrol Division - Overall responsibility for a Platoon consisting i of five (5) Sergeants and thirty (30) Police Officers. Duties included assign-ment of all personnel during a tour of duty, handling civilian complaints and assuming responsibility for the overall Police mission in the absence of the Commanding Officer or Executive Officer. July 1973 - February 1977 Captain / Detective Cactain: Detective Division - Member of the Chief of Detectives Staff. Responsibilities varied as need arose, ie review of individual Detectives Criminal Investigations , direct super-vision at scene of major criminal incidents ' until arrival of Division Suparvisor, l ensure administrative and procedural compliance with Departments Rules & Pro-cedures, liaison with District Attorney's Office. Detective Division Training Officer with responsibilities for individual training needs, developed in conjunction with Police Academy Staff, curriculum for Departments Criminal Investigation School. January 1976 - December 1979 Detective Captain: Detective Division - Formulated and commanded Departments Hostage Negotiating Team.' Resnonsible for selections, initial and monthly training of personnel, direct control of negotiations at scene, critique of every incident by those members present.
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February 1977 - July 1978 Detective Captain: Detective Division - Commanding Officer of the Narcotic Squad. Responsible for investigation of Narcotic Law violations in Suffolk County, developed liaison with Federal, State and local agencies including the Long Island Drug Enforcement Task Force, where I had assigned ten (10) Detectives and one (1) Serge ant . Task Force was a cooperative effort of the Drug Enforcement Adminis-tration, New York State Police, District Attorney's Office and County Police Departments of both Nassau and Suffolk i ' Counties to infilitrate and neutralize high level drug operations on Long Island. Maintain files and statistics on known illicit distributors , transporters and addicts. Responsible for activity of forty-eight (48) Detectives and four (4) Sergeants and a sizeable ready fund. July 1978 to Present Deputy Inspector: Patrol Division - Executive Of ficer - Assist Commanding Officer, and in his absence, assume responsibility for accomplishing the. Police mission through effective admin-istration and operation of the Precinct
- in all that it entails, ie personnel, community, tactical, etc. Assigned Precinct personnel consists of 217 Police Officers, eight (8) Lieutenants, twenty-five (25) Sergeants, three (3) Civilians and forty-eight (48) School Crossing Guards, encompassing approximately 190 scuare mile area and servicing a population of approximately 220,000 persons.
FRATERNAL ORGANIZATION Suffolk County Police Benevolent MEMBERSHIPS : Association Suffolk County Superior Officers
-Association Suffolk County Detectives Association Suffolk County Columbian Association Suffolk County Police Conference Suffolk County Police Association j
New York State Association of Chiefs of Police F.B.I. National Academy Associates e 0
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1 e r COUNTY OF SUFFOLK I i$. t 1-I
. n DON ALD J. DILWO RTM POLICE DEPARTMENT RESUME Prepared August 22, 1983 EDWIN J. MICHEL, CAPTAIN Executive Officer, Highway Patrol Bureau Suf folk County Police Department -
POLICE SERVICE EXPERIENCE 7-22-63 - Appointed as Probatianary Patrolman - Suffolk County Police Academy 9-24-63 - Assigned to the Patrol Division, Third Precinct 1-5-70 - Promoted to Sergeant, remained assigned to the Third Precinct I 9-22-75 - Promoted to Lieutenant, assigned to First Precinct 2-21-77 - Transferred to Highway Patrol Bureau as O.I.C. of radar and cycle enforcement i ( l-19-81 - Promoted to Captain assigned to Chief of Patrol i Division's Of fice 3-30-81 - Transferred to Highway Patrol Bureau as Executive Officer I EDUCATIONAL BACKGROUND June, 1959 - Graduated from Islip High School January, 1977 - Graduated Magna Cum Laude from New York Institute of Technology - Major Behavorial Science and-Criminal Justice June, 1982 - Graduated from the F.B.I. National Academy, Quantico, Virginia, accredited by the University of Virginia PERSONAL Health: Excellent Weight: 170 l Age: 42 Height: 5 ' 9 "- Married since July 20, 1963 to June D. Michel, one child Teri Ann, ace 15 Resident of,,Suffolk County and the Town of Islip since 1949 l I 5 { C -_
e 5 ATTACHMENT 2 4
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4 9 ATTACHMENT 3 m M-- - - - - - - - - - - - - - - - -
Attachment 3 SUFFOLK COUNTY POLICE DEPARTMENT ANALYSIS OF TABLE IX, APPENDIX A -- CIIANNELIZATION TREATMENTS ON SELECTED ROADWAY SECTIONS 1! LILCO Description (Table IX) of Proposed Channelization Approach Treatments SCPD Analysis Establish 2 lanes, the inside Rt. 25A and Patchogue/Mt. Sinai (7,30) Rt. 25A, W.B. lane is reserved for left- Road (CR 83): turning traffic onto link The LILCO proposal conflicts (30,13), Patchogue-Mt. Sinai with the traffic control stra-Rd. tegy to be implemented by the two traffic guides assigned to l this location (traffic post L 156), i.e., to establish a roadblock to prevent traffic from proceeding south on CR 83 (Patchogue/Mt. Sinai Road). (13,17) Patchogue-Mt'. Establish a left-turn pocket Patchogue/Mt. Sinal Road (CR Sinai Rd., S.B. for traffic turning south on- 83) and Patchogue Road (Rt. to link (17,21), Patchogue 112): The LILCO proposal con-Road and a right-turn pocket flicts with the traffic control for traffic turning north strategy for the traffic guide onto link (17,82), Route 112. assigned to this location The left-turn volume is sub- (traffic post #59), i.e., to 1! Based on Appendix A, Revision 1.
i Attachment 3 (cont.) , LILCO Description (Table IX) of Proposed i Channelization Approach Treatments SCPD Analysis ! stantiated [ sic], the right- prevent southbound traffic on turn volume is insignificant. Rt. 112 (Patchogue Road). ! Maintain 2 lanes for the dom- i inant through movement. It will probably be necessary to ' narrow link (17,13) northbound on Patchogue-Mt. Sinai Rd. which will service no evacuat-ing traffic. (22,21) Route 25, W.B. Establish a left-turn pocket Rt. 25 and Rt. 112: The LILCO for traffic turning south on- proposal conforms with the l to link (21,68), Rt. 122, a traffic control strategy to be , right-turn pocket for traffic implemented by tha Cour traffic turning north onto link guides assigned to this loca- , (21,17), Rt. 112. Retain a tion (traffic posts 865 and . lane for the through move- 866). Ilowever, it conflicts ! ment, westbound, onto link with the turn movements pre- , (21,106), Rt. 25. scribed for traffic node 21 (Appendix A, Table XII, at IV-35), i.e., southbound traffic to continue south, traffic tra- . velling northwest on Coram (Mill Rd.) and Yaphank Rd. to turn west onto Middle Country Rd. (Rt. 25), and westbound traffic on Middle Country Rd. (Rt. 25) to continue west (70%) or turn south onto Port Jefferson /Patchogue Rd. (Rt. 112) (30%). (Note: LILCO description refers to Rt. 122. This should be Rt. 112). 4 Y
k Attachment 3 (cont.) . LILCO Description (Table IX) of Proposed Channelization Approach Treatments SCPD Analysis (23,22) Route 25, W.B. Establish a right-turn pocket Rt. 25 and Mt. Sinai/Coram for traffic turning north on- Road: Neither the strategy to link (22,18), Mt. Sinai- for the traffic post at this l Coram Rd. location (traffic post #67) nor the prescribed strategy for the corresponding traffic node (node 22) makes any reference F to traffic other than buses turning north onto Mt. Sinai/ Coram Road. (24,23) Route 25, W.B. Establish a left-turn pocket Rt. 25 and East Bartlett Road: for traffic turning south on- This is traffic post #123. The to link (23,133), E. Bartlett LILCO proposal for channelizing Rd. traffic could not be carried out by the one traffic guide assigned to this location. (81,24) Route 25, W.B. Establish a right-turn pocket Rt. 25 and Yaphank/ Middle for traffic turning north on- Island Road: The LILCO pro-to link (24,19), Yaphank- posal conflicts with the Middle Island Rd. traffic strategies for both the traffic control post (post #35) and the traffic node (node 24) at this location, i.e., all westbound and eastbound traffic on Rt. 25 to turn south onto CR 21 (Yaphank/ Middle Island Rd.).
Attachment 3 (cont.) , 1 LILCO Description (Table IX) of Proposed Channelization Approach Treatments SCPD Analysis (75,74) LIE, W.B. Reduce number of lanos from 3 Long Island Expressway west-to 2 by blocking outside lane bound at Edwards Avenue: This upstream of the entry ramp at locat. ion corresponds to traffic node 74, to permit a protected node 74 (128,74)(Appendix A, movement for traffic entering Table XII, at IV-46). LILCO's the expressway from the ramp proposal for channeling traffic link (128,74). onto the Long Island Expressway eastbound cannot possibly be carried out, since there is no access to the Expressway cast-bound at this location. o I 1 3 i t i i
ATTACHMENT 4 [ 9
Attachment 4 SUFFOLK COUNTY POLICE DEPARTMENT ANALYSIS OF TABLE V, APPENDIX A -- CONCURRENT CONTINUOUS PLOW TREATMEllTS A! Description of Flow Pattern LILCO Proposal SCPD Analysis
- a. Vehicles moving south LILCO's proposal will not work, on Landing Road will in part because this intersection be routed west onto is not manned by any traffic Landing Route 25A. guides. Clearly, it is reason-able to expect evacuation Rd. b. No evacuation traffic along Rt. 25A at this traffic along Rt. 25A location. In fact, because a 11/F at this location. significant amount of westbound traffic at traffic control post 337 (Broadway and Rt. 25A) .would 2: - likely refuse to U-turn, as
! required by LI LCO's traffic stra-tegy for this traffic post, evac-Route 25A untion traffic along Rt. 25A could be heavy at this location.
Thus, it is not likely that there will be concurrent continuous flow, as proposed by LILCO. i 1! Based on Appendix A, Revision 1.
Attachment 4 (cont.) Description of Flow Pattern LILCO Proposal SCPD Analysis
- a. Vehicles moving west LILCO's proposal assumes no 23/K,L on Route 25 will either evacuation traffic castbound Middle Country Road, Rt. 25 continue west (50%) or along Rt. 25 or northbound along turn south onto East East Bartlett Road. This, how-jh " Bartlett Road. ever, is in direct conflict with the strategies for the traffic 4 l node (node 23) at this location,
- b. No evacuation traffic as well as node 22 to the west; cast along Route 25 nor both permit traffic moving cast north along East Bart- to continue east. Further, lett Road. LI LCO ' s traffic strategy has East ignored evacuation traffic
, northbound on East Bartlett Road Road from the residential areas to the south of this location. It is very unlikely that the one traffic guide assigned to this location could carry out the continuous flow proposed by LILCO. As a result, it is very likely that congestion would occur.
Attachment 4 (cont.) . Description of Flow Pattern LILCO Proposal SCPD Analysis
- a. Vehicles moving west LILCO's proposal requires Ridge al ng Whiskey Road turn Road to become one-way south-38/B,G south onto Hidge Road, bound, from Whiskey Road to Rt.
left lane. 25. This is consistent with tlie Ridge one-way flow outlined in Table
. Road b. Vehicles moving south VIII, Appendix A (see, however, along Ridge Road con- Attachment 5 for SCPD analysis Whiskey Rd. tinue south onto right of this one-way flow treatment).
I I lanc, llowever, the two traffic guides at traffic control post 19 (Ridge I c. Very light traffic Rd. and Rt. 25) are not instruct-moving east along ed to prevent northbound traffic __ , __ % Whiskey Rd. turn south along Ridge Road. Thus, con-flicting traffic flows will l lI f onto Ridge Rd. likely occur at this location. ; I I
At.t ac hme n t 4 (cout.) , Description of I. I I.CO Proposal SCPD Analysis Flow Patt ern
- a. Vehicles moving south Despite I,ILCO's designation, on Yaphank-Middle this is really the intersection Island Rd. will be of Rocky Point Road and Rt.. 25.
Yaphank- routed west onto Rt. I,II.CO's proposal is in direct Middle- 25. conflict with the inst ructions Island Rd. given to the two traffic guides 24/K,G,L,M Vehicles moving west for this location (traffic post b. 535), since they are to prevent 4 "g on Rt. 25 will be traffic from proceeding west on f routed south onto Yaphank-Middle Rt. 25. Further, southboun during school days. This road has no shoulder capacity and it would be impossible for bus i traffic to travel against r two lanes of southbound traffic. i l
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l I I i i ATTACHMENT 6
Attachment 6 l Excerpt From September 8, 1983 NEWSDAY Article i; ..
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'By Carble Agus l '
! % hen a motorist rr .ts a road crew, l l he i<comes a taxpaye An anpy one. l .. wo: roa$, .n
- contm:v.Ii,n nu: p:ce itbx pressway. as bad b J3richo urnpae. ney
.like the Northern State Parkway. No trucks, for one thing, and the mellower driver who likes the scenic route. Expreenway drivers ar pure vicious.
It's an awasome thing to etop the traffic on the exp easway. To create a work spam in the ce der lane
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- the most d us work situation of al; the one they call'"Itc litornia Wirge" - all th. .a lanes !
must be halted for a few mon.ents. It's like holding - back the Red So, all that surging, anpyyower just ahead, and only a flag for protection. '1he Iaces of the motorists are pure resentment.
" Move to the fr/l!" yel!* Jerry D Grrhy, the flag-
! man. Flagma:; is a rotatingjo'.3, and all the men hate I it. For one thing, there is no companionship for the I flagman, who stands alone with the traffic a few hun-I dred feet ahead of the men. .
"It's berirg" said DeGruchy, as'he listleesly waved his flag. A Camaro pas:4 and a man ctuck his
. head out the wtadaw and be!! awed, 'You're worth-less!" DeGruchy ignored it. "At the end of the day, f . when things atthey're you. ney spitcoming home at you. ney throw from anythingwork, they throw they have handy, anything they can hit you with, yelling and cursing." He did mme cursing himself a little later that day. When they took the lunch orders, they forgot DeGruchy. An hour after lunch was over, he stormed off his poet to raise helt Didn't go back.
Nobody blamed him, either. One day when John Letoe was flagging, a car re-fused to stop. ~I screamed at him,'You stupid F and F ! and F!' He started rimning after me. Ifopped out and , started chaamg me scramming, Tm gonna . kill you!'"
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I. 1 1 1 ATTACIEiENT 7 1 i .l a a I l t
1 I Attachment 7 i I COMPILATION OF APPROXIMATE DISTANCES FROM SHOREHAM PLANT FOR LILCO TRAFFIC GUIDES b! Residences Number of Miles Traffic Guides Percentage 0-5 5 1.5 6-10 7 2.2 11-15 25 7.8
! 16-20 20 6.3 21-25 44 13.8 l 26-30 42 13.2 31-35 24 7.5 36-40 44 13.8 ' 41-45 66 20.7 46-50 23 7.2 i
f Over 50 19 6.0 f 319 100.0% i s I. i !' 1! Based on data supplied by LILCO in response to discovery requests by Suffolk County.
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Work Offices Number of Miles Traffic Guides Percentage 0- 5 0 0.0 6-10 0 0.0 4 11-15 38 12.0 16-20 0 0.0 21-25 40 12.5 26-30 52 16.3 31-35 1 0.3 36-40 72 22.6 41-45 29 9.1 46-50 87 - 27.3 Over 50 0 0.0 319 100.0% i r l l l l ATTACHMENT 8 P
Attachment 8 Intersections Within the Sixth Precinct, Suffolk County Police Department, Suffolk County, New York, With Highest Number of Reported Motor Vehicle Accidents (September 1982-September 1983) LILCO TRAFFIC
-y'f INTERSECTION HAMLETS TOTAL CONTROL POST Route 25A and Rocky Point Rd. Rocky Point. 60
#3'8 Route 25A and Miller Place Rd. Miller Place. 24
#41 Route 25A and County Rd 83 Miller Place. 23
#56 Route 25A and Chestnut St. Mt. Sinai. 20 Route 25 and Rocky Point /Yachand Rd. Middle Island. 29
#34 Route 25 and Homestead Dr. Coram. 20 967 Route 25 and Mt. Sinai/Coram Rd. Coram. 29 Route 25 and Route 112 Coram. 46
#65
#63 Route'25 and County Rd. 83 Selden. 32 County Rd 83 and Route 112 Coram. 23
#59 County Rd 83 and Old Town Rd. Coram. 23 Route 112 and Route 347 Port Jeff Station. 33
#50
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#54 Route 112 and Rose Lane. Port Jeff Station. 24
#35 Rocky Point Rd and Route 25 Middle Island. 25
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Route 112 and Pine Rd. Coram. 17 b! Based on Appendix A, Revision 1.
I - J , . >* J d$ *' I 3s'; I ,E %x , h ,j ' jj* $Ab s. Traffic Total Post # $$ $ $ .
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, 4 3 7 6 7 9 60 Rock y Point Rd' 5 7 5 6 1 1 3 .
38 Rte. 25 A and 7 1 4 3 2A Miller Place Rd 2 1 1 4 1 41 Rte.25A and ' 4 2 3 1 1 '2 23 County Rd 3 2 2 3 56 83 Ete.25 A and. 2 1 1 4 4 6 20 Chestnut St 1 1 Rte.25 an d 7 2 2 2 4 29 3a RockyPoint/Yapank Rd 3 4 3 2 Rte.25 and 4 2 2 1 20 Homestead Dr 3 2 2 3 1 Rce.25 and 4 3 4 4 1 5 29 Mt Sinai/Coran Rd 1 1 2 1 3 67
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Rte.25 and _ 6 2 7 2 7 6 2 7 2 46 Rte.112 2 3 65
' Rte.25 and 2 6 5 4 2 6 3 1 35 63 County Rd 83 1 1 1 County Rd 81 and '
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. County Rd 83 and ~
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4 3 3 1 5 23 Old Town Rd 1 1 5 Rte.112 and 1 4 2 3 .2 2 4 33
. Rte.347 5 7 3 1 50 Ete.112 and 4 5 3 1 2 3 24 Rose Lane 1 1 2 1 1
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1 o . ,, a 9 ATTACHMENT 9 l l l
8 attachment 9 Reported Traffic Accidents Along Roadway Sections of Five Major Highways (Rt. 25, Rt. 25A, County Road 21, County Road 83 and Rt. 112) Within the Sixth Precinct, Suffolk County Police Decartment, Suffolk County, New York (September 1982-September 1983) yj l l j
! Prepared By Suffolk County Police Department l
November 4, 1983 t i 1 l I b! References to LILCO traffic' control posts are from Appendix A, Revision 1. l y - - - p=,y e y
e . Traffic Rta 25A from Randall Rd, Wading River to Rte.347.Mt.Sinai Post # _ d . . .
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Rte.251 1
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! Brookhaven Dr 1 -
2 2 1 1' 3 2 3 2 17 Westchester Dr 1 2 4 1 5 3 2 2 19 North Country Rd I 2 2 1 5 j Hunter Ave 2 1 1 1 1 7 Radio Ave 1 2 1 1 5 T/ler Ave 1 2 2 1 1 1 8 Harrison Ave 1 _ 2 1 3 Parkside Ave 1 1 1 1 1 5 Cakland Ave _ 1 1 Park Ave 4 7 1 4 3 24 41 Miller Place Rd 2 1 1 1 O Sylvan Ave - 1 1 1 5 Pipe Stave Hollow Rd 1 1 57 Echo Ave 1 3 1 1 1 2 1 1 Lincoln Ave ( 2 2 Peach Tree La 1 1 55 Mt Sinal Rd -Coram Rd - 3 2 2 3 4 2 3 1 1 2 23 56 Qounty Road 83
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2' 1 1 4 4 6 20 _ _ . Chestnut St 1 1 1 1 Highland Ave West Gate 1 1 2 1 1 i 7 -l
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. 1 1 Tyler Ave Polk St 1 1- 2 _
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! Southbound (26,125) No ' From Sills Rd. to L.I. (125,33) l Expressway Westbound ' ! Txit 67 l
o . Roadway Section Links Adecuate Shoulder Main Street, N.W. (28,26) No From Yaphank Rd. to Yaphank-Middle Island Rd. Main Street, S.E. (28,48) No From Yaphank Rd. to L.I. Expressway, Eastbound Eyit 67 Yaphank Rd., Northbound (123,28) No Fron . I.E. Ramp 67 to Main Street Sills Rd., Southbound (127,31) No Fror Long Island Ave. to L.I. Expressway Eastbound Entrance Ramp #66 L,I. Expressway Ramp,. Southbound (124,123) Yes From L.I. Expressway Exit 67 to Yaphank Rd. L.I. Expressway Exit Ramp 68, Southbound (119,118) Yes From L.I. Expressway to William Floyd Pkwy. L.I. Expressway Entrance Ramp 69, Westbound (117,71) Yes From Center Moriches Rd. to L.I. Express-way . l Wading River.-Mancr-ville Rd., Southbound (56,59) No From Rt. 25 to Schult: Rd. e e ,,,,,m.
0 * - Roadway Section Links Adecuate Shoulder Schultz Rd., Center Moriches Rd., South-bound (59,107); No From Wading River- (107,117) Manorville Rd. to L.I. Expressway Wading River Rd., Southbound (117,115); No From L.I. Express- (115,97); way to Sunrise (97,63) Hwy. Center Moriches Rd., Northbound (72,60) No From L.I. Expressway Eastbound Entrance Ramp #69 to z Schultz Rd. ,, s Wading River-Manorville \ Rd., Northbound (59,56) g No From Schultz Rd. to i Rt. 25 Wading River-Manorville Rd., Manor Rd., David Terry St., Sou*dibound (61,98) No From Schultz Rd..to Lanes Rd. Lanes Rd., Southbound (61,98) No From David Terry St. to L.I. Exprsssway David Terry St., Manor Rd.,' Northbound (61,108) No From Lanes Rd. to Wading River-Manor-ville Rd. , G
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1 17 - l Roadway Section Links Adecuate Shoulder i Wading River-Manorville Rd., Northbound (108,59) No From Manor Rd. to Schult: Rd. Rt. 25 Exit Ramp, Southbound (113,112) Yes From Rt. 25 to William Floyd Pkwy. Rt. 25 Enurance Ramp, Eastbound (100,111) Yes
, From William Floyd Pkwy. to Rt. 25 s
Rt. 25 Exit Ramp, 1 Southbcund (111,100) Yes { From Rt. 25 to William Floyd Pkwy. Rt. 25 Entrance Pamp, - Southbound (110,99) Yes From William Floyd
- s Pkwy. to Rt. 25 L.I. Expressway, Entrance Ramp 71, Westbound (128,74) Yes From Nugent Dr. to L.I. Expressway Rt. 25A, Eastbound (36,37) Yes From Randall Rd. to
' William Floyd Pkwy.
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Rt. 25A, Eastbound (37,53) yes l From William Floyd '.' - Pkwy. to Wading River-Manorville Rd. 1
9 e f i l l ATTACHMENT 11 l l l 1 l 1 \
\
Attachment 11 I EPZ ACCESS CONTROL POINTS ' (Excluding Access From the North, i.e., From The Long Island Sound) Two Mile Region LILCO Traf'fic Intersections Control Postsb! l Woodville Road & L j (Shoreham Village)gpust St? set l Woodville Road and Briarclif1? Road 2/ l Woodville Road & Ashley Lane 2/ Goodville Road & Suffolk Downsl/ Woodville Road & Valley Way 2/ Woodville Road & North Country Road # 5 Woodville Road & Route 25A Route 25A & Ridge Road #6 Ridge Road & Wading River Hollow Road Ridge Road & Whiskey Road #7 Whiskey Road & Woodbridge Drive Whiskey Road & Bridgewater Drive , i 1I Based on Appen' dix A, Revision 1.
! The two-mile region described in the LILCO Plan presently.
encompasses about,two-thirds of'the Shoreham Village community, and uses Woodville Road as a " dividing" line between zones A-and F. Effective access control would be provided to this area ^ by incitt.ing the entire Shoreham Village community into the same planning zone. Access control-points beginning at Route 25A/ North Country Road and east would then eliminate the need to
. assign access control posts north along Woodville Road.
f
LILCO Traffic j Intersections Control Posts Whiskey Road & Leisure Village (2) f Whiskey Road & Randall Road Whiskey Road & Summmit Drive Whiskey Road & William Floyd Parkway 4 8 Route 25 & William Floyd Parkway #s 138,139,142,143 1 Route 25 & Town Range Road I Route 25 & Montauk Trail Route 25 & Panamoka Trail
; Route 25 & Tarkill Road i
l Route 25 & Wading River Manorville # 10 Road i i (Route 25 & Kay Road) (Route 25 & National Cemetary (2)) Route 25 & Route 25A # 13 Route 25A & Hulse Landing Road # 12 Hulse Landing Road & Sound Avenue # 129 Hulse Landing Road & 21st Street 2/ Hulse Landing Road & 20th Street 3/ Hulse Landing Road & 19th Street 3/ Hulse Landing Road a 18th Street 3/ l 2/ Sufficiently manning an access control post at Hulse Landing Road and Sound Avenue would effectively control westerly access to residential streets north on Hulse Landing Road. However, this would also prevent access to streets east of Hulse Landing Road (which are outside the two-mile region described in'the LILCO Plan.) 2-L l 1
e . I i LILCO Traffic Intersections Control Posts Hulse Landing Road & 17th Street 3/ Hulse Landing Road & 16th Street 3/ Hulse Landing Road & 15th Street 3/ Hulse Landing Road & Park Street 3/ Hulse Landing Road & Breezy Point Road 3/ Hulse Landing Road & Wema Road 3/ Hulse Landing Road & 7th Street 3/ Hulse Landing Road & North Wading River Road 3/ O l l
e e Five Mile Region LILCO Traffic Intersections Control Posts Pipe Stave Hollow Road & North Country Read # 43 Pipe Stave Hollow Road & High Hill Pipe Stave Hollow Road & Hayward Pipe Stave Hollow Road & Milland Pipe Stave Hollow Road & Kettle Knoll Path Pipe Stave Hollow Road & Evans Lane Pipe Stave Hollow Road & Echo Avenue Pipe Stave Hollow Road & Route 25A Route 25A & Sylvan Avenue Route 25A & Miller Place-Yaphank Road # 41 Miller Place-Yaphank Road & Jonah Road Miller Place-Yaphank Road & Whiskey Road # 120 Miller Place-Yaphank Road & Rocky-Point Road # 122 Rocky Point Road & Bayliss Road Route 25 & Rocky Point-Middle Island Road # 35 Route 25 & Apartment Drive Route 25 & Lakeview Drive Route 25 & Curran Road Route 25 & Woodville Road 4_
LILCO Traffic Intersections Control Posts Route 25 & Wading River Hollow Road 4 136 Route 25 & Woodlots Road Poute 25 & Smith Road Smith Road & Cross Road Smith Road & Medford Road Smith Road & Eagle Drive Smith Road & Cemetary Road Smith Road & Longwood Road # 34 Longwood Road & Private Road Longwood Road & William Floyd Parkway # 33 William Floyd Parkway & Long Island Expressway (Exit 68) #s 31,32A,32B Long Island Expressway Service Road
& Upton Road (south gate)
Long Island Expressway & North Street Long Island Expressway & Center Moriches Road (Exit 69) # 27 Long Island Expressway & Ryerson Avenue Long Island Expressway & Port Jefferson-Westhampton Road (CR 111) (Exit 70) Long Island Expressway & Halsey Manor Road Edwards Avenue & Long Island Expressway (Exit 71) Edwards Avenue & River Road Edwards Avenue & Grumann Boulevard # 15
i l . . 1 LILCO Traffic Intersections Control Posts Edwards Avenue & Railroad Street Edwards Avenue & Route 25 # 14 Edwards Avenue & Sound Avenue 4/
-4/ Sufficiently manning an access control post at Edwards Avenue and Sound Avenue would effectively control access to streets west !
off Edwards Avenue, north of this location. However, it would I also prevent access to streets east of Edwards Avenue which are ( outside the five-mile region described in the LILCO Plan. l
- m. _ .
i . . i 1 Ten Mlle EPZ LILCO Traffic j Intersections Control Posts i Broadway & Main Street # 48 Main Street & Wynn Main Street & Maple Place I Main Street & Barnum Avenue Main Street & Old Post Road
- Main Street & Reeves Road Main Street & N. Country Road #s 47, 135 Main Street & Perry Street Main Street & Chestnut
- Main Street & Oakland Main Street & Railroad Station Route 112 & Church Street .
Route 11'2 & Bergen Street Route 112 & Hallock Avenue (Rt. 25A) # 49
. Route 112 & Crescent Route 112'& Oakland Avenue l Route 112 & Wykoff Avenue l
Route 112 & Doris' Avenue Route 112 & Rec Avenue Route 112 & Rt. 347 #.50-Jayne Boulevard & Rt. 347 4 4 7-
. o LILCO Traffic Intersections Control Posts Jayne Boulevard & Roosevelt # 52 Jayne Boulevard & Montclair Jayne Boulevard & Marlboro Drive Jayne Boulevard & Winston Jayne Boulevard & Newport Jayne Boulevard & Erie Street Jayne Boulevard & Greene Avenue Jayne Boulevard & Clinton Avenue Jayne Boulevard & Dillon Avenue Jayne Boulevard & Squires Avenue Jayne Boulevard & Roe Drive Jayne Boulevard & Old Town Road Old Town Road & Bicycle Path Old Town Road & Wedgewood Old Town Road & Hawkins Path # 62 Old Town Road & Hawkins Road Old Town Road & Sonway Old Town Road & Howe Road Old Town Road & Patchogue-Mt. Sinai Road (CR 83)
Old Town Road & Harford Drive Old Town Road & Apartment Road i Old Town Road & Route 112 l
l LILCO Traffic ' Intersections Control Posts Route 112 and Route 25 4 65 Route 112, Grand Smith Road & Mill Road Route 112 & Granny Road 4 68 Route 112 & Commercial Drive Route 112 & Stuyvesam Place Route 112 & Horseblock Road (CR 16) Horseblock Road & Maine Avenue Horseblock Road & Rhode Island Avenue Horseblock Road & Newport Avenue i Horseblock Road & New London Avenue Horseblock Road & Eagle Avenue Horseblock Road & Connecticut Avenue Horseblock Road & Waverly Horseblock Road & Long Island Expressway North Service Road Bellport Avenue & Long Island Expressway North Service Road Long Island Expressway, Exit 66, W/B ramp and North Service Road # 70 Sills Road (CR 101) & Long Island Expressway ! Sills Road & Old Town Road Sills Road & Old Dock Road Yaphank Avenue (CR 21) & Gerrard Avenue # 132 1 ( ,_ l l LILCO Traffic Intersections Control Posts Gerrard Avenue & Crescent Street Gerrard Avenue & Suffolk County Park Entrance (2) Gerrard Avenue & Victory Avenue Victory Avenue & William Floyd Parkway # 90 Victory Avenue & Sunrise liighway (Exit 58) Sunrise liighway (Rt. 27) & Park Avenue Sunrise liighway & Winters Drive Sunrise liighway & Barnes Road Sunrise liighway & Moriches - Middle Island Road Sunrise liighway & Chichester Avenue (CR 25) # 26 Sunrise liighway & Exit Ramp 59 Sunrise flighway & Railroad Avenue Sunrise liighway & Exit Ramp 60 Sunrise liighway & E. Chapman Boulevard / East Moriches-Manor Road Sunrise liighway, Entrance Ramp 61 at llead of the Neck Road (# 25 nearby) Riverhead-Moriches Road (CR 51) & Eastport Manor Road (CR 55) r Riverhead-Moriches Road & Toppings Path Toppings Path & CR 111 Riverhead-Moriches Road & County Center Drive l 1 l ! l l
I I LILCO Traffic Intersections Control Posts Riverhead (Lake) Moriches Road (CR 63) & Pegs Lane Riverhead (Lake) Moriches Road & Woodhull Avenue Peconic Traffic Circle & Nugent Drive (CR 94) Route 25 (West Main Street) & Peconic Avenue # 21 Route 25 (West Main Street) & Osborne Avenue Osborne Avenue & Court Street Osborne Avenue & Library Drive Osborne Avenue & Lincoln Osborne Avenue & Pulaski Osborne Avenue & Harrison Osborne Avenue & Hamilton Osborne Avenue & Marcy Avenue Osborne Avenue & Gregory Place Osborne Avenue & Raynor Avenue Osborne Avenue & Old Country Road (CR 58) Old Country Road & Woodcrest Old Country Road & Harrison Old Country Road & Roanoke Avenue Roanoke Avenue & Middle Road Middle Road & Nadel Drive I ' LILCO Traffic Intersections Control Posts Middle Road & Private Road Middle Road & Northville Turnpike (CR 43) Northville Turnpike & Midway Drive Northville Turnpike & Doctor's Path Doctor's Path & Oakland Drive South Doctor's Path & Oakland Drive North Doctor's Path & Oakland Drive Doctor's Path & Reeve's Avenue Doctor's Path & Sound Avenue e ATTACHMENT 12 e P.--.- _ _ . . _ _
Attachment 12 EPZ Access Control Points -- East End Evacueesb! Appendix A,at IV-8, states that LILCO will " prohibit westbound traffic from travelling west toward the EP7" from the East End by redirecting such traffic " south toward Sunrise Highway." LILCO relies on a single traffic control post -- post #23 (NY 25 and CR 105) -- to perform this function. At a minimum, however, traffic control posts would also have to be provided at the following locations: Sound Avenue and CR 105 CR 105 and Northville Turnpike The two westbound ramps at CR 105 and Hubbard Avenue CR 105 and Riverside Drive CR 105 and Rt. 24 CR 105 and Rt. 104 Rt. 104 and CR 31 CR 31 and Hampton Hill C.C. Road CR 31 and Rt. 27 1! Based on Appendix A, Revision 1.}}