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Testimony of Mc Cordaro,Ja Weismantle & Eb Lieberman on Phase II Emergency Planning Contention 67
ML20086U235
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 03/02/1984
From: Cordaro M, Lieberman E, Weismantle J
LONG ISLAND LIGHTING CO.
To:
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OL-3, NUDOCS 8403070201
Download: ML20086U235 (28)


Text

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LILCO, March 2, 1984 l

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UNITED STATES OF AMERICA i

l NUCLEAR REGULATORY COMMISSION l

l Before the Atomic Safety and Licensing Board 1

(

In the Matter of

)

i

)

1 LONG ISLAND LIGHTING COMPANY

) Docket No. 50-322-OL-3

) (Emergency Planning Proceeding)

(Shoreham Nuclear Power Station, )

Unit 1)

)

TESTIMONY OF MATTHEW C.

CORDARO, JOHN A. WEISMANTLE AND EDWARD B.

LIEBERMAN i

ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTION 67 1

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i Hunton & Williams 707 East Main Street l

P.O. Box 1535 l

Richmond, Virginia 23212 l

(804) 788-8200 l

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B403070201 840302 PDR ADOCK 05000322 T

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LILCO, March 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

) Docket No. 50-322-OL-3

) (Emergency Planning Proceeding)

(Shoreham Nuclear Power Station, )

Unit 1)

)

TESTIMONY OF MATTHEW C.

CORDARO, JOHN A. WEISMANTLE AND EDWARD B.

LIEBERMAN ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTION 67 PURPOSE The purposes of this testimony are to demonstrate that ade-quate provision has been made for bus transportation out of the EPZ for that segment of the general public which does not own or have access to automobiles, and that the allegations of Contention 67 are without basis.

The testimony describes the system for evacuating the non-automotive portion of the EPZ general populace.

It shows the division of the EPZ into zones, each of which is served by one or more bus routes with " route buses" to pick up po-tential evacuees; the use of transfer points through which passen-gers picked up by " route buses" pass, or at which they transfer to

" transfer buses," enroute to relocation centers outside the EPZ; and the coordination of schedules and of capacities of route and transfer buses relative to anticipated demand.

i

I i

)

he testimony shows that the rcute and transfer buses have j

the capacity to evacuate over 13,000 people within about a five f

and one-half hour period, and that the expected demand for this i

capacity, now assumed to be slightly over 11,000, is more i

i realistically about 6500 persons.

It shows how multiple bus runs 1

j are allocated to bus routes to account for expected demand and are 4

spread over a multi-hour period, with route times coordinated to account for traffic congestion.

It shows that transfer points will not be points of congestion and delay; that, indeed, the

]

majority of passengers will never need to debark from their buses; and that passengers will not experience significant exposure j

either to the elements or to radiation at transfer points.

It 1

shows, in short, that Contention 67 is without merit.

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LILCO, March 2, 1984 UNITED STATES OF AMERICA i

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety a_nd Licensing Board In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

) Docket No. 50-322-OL-3

) (Emergency Planning Proceeding)

( S' - eham Nuclear Power Station, )

Unit 1)

)

TESTIMONY OF MATTHEW C. CORDARO, JOHN A. WEISMANTLE AND EDWARD B.

LIEBERMAN ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTION 67 TESTIMONY 1.

Q. Please state your name and business address.

A.

[Cordaro]

My name is Matthew C.

Cordaro.

My business address is Long Island Lighting Company, 175 Old Country Road, Hicksville, New York, 11801.

[Weismantle]

My name is John A. Weismantle.

My business address is Long Island Lighting Company, 100 Old Country Road, Hicksville, New York, 11801.

[Lieberman)

My name is Edward B.

Lieberman.

My business address is KLD Associates, Incorporated, 300 Broadway, Huntington Station, New York, 11746.

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2.

Q. Please summarize your professional qualifications and your role in emergency planning for the Shoreham Nuclear Power i

Station.

A.

[Cordaro]

I am Vice President, Engineering, for LILCO.

My professional qualifications are being offered into evi-dence as part of the document entitled " Professional Qual-ifications of LILCO Witnesses."

am participating on I

this panel to provide the LILCO management perspective on Emergency Planning, and to answer any questions pertinent.

to management.

My role in emergency planning for Shoreham l

is to ensure that the needs and requirements of emergency j

planning are being met, and that the technical direction and content of emergency planning are being conveyed to corporate management.

[Weismantle]

I am Manager of the Local Emergency Response 4

Implementing Organization for LILCO.

My professional qualifications are being offered into evidence as part of the document entitled " Professional Qualifications of LILCO Witnesses."

My familiarity with the issues sur-i l

l rounding this contention stems from work in developing and implementing the Local Emergency Response Plan for Shoreham.

L f

- -. ~ -.

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[Lieberman)

I am Vice President of KLD Associates, Incor-l l

porated.

My professional qualifications are ueing offered into evidence as part of the document entitled "Profes-j sional Qualifications of LILCO Witnesses."

My familiarity 1

I with this 'ontention' stems from work KLD Associates has

l performed for LILCO on evacuation time estimates for the Shoreham EPZ.

t 3.

Q. Please summarize the issues raised by Contention 67.

j A.

[Cordaro, Weismantle, Lieberman)

Contention 67 questions the provision made.in the LILCO Transition Plan for the evacuation of people who do not have access to private automobiles.

Specifically, Contention 67 states:

1 Contention 67.

LILCO assumes that in the event an evacuation is ordered, most members of the population will attempt to leave using their personal vehicles.

However, a substantial portion of the population in the EPZ does not own or have access to an auto-mobile.

LILCO proposes that people who do not have access to an automobile at the time of an evacuation order will be evacuated by buses running special evacuation routes, with bus stops purportedly no more than one-half mile from each such person's home.

(Plan at 3.6-6; Appendix A, at III-35 and III-36, IV-76 to IV-163; OPIP 3.6.4).

How-ever, LILCO's proposal cannot be imple-2 mented, and LILCO's proposed evacuation of people without access to cars would not pro-vide adequate protection for such people, l

because the evacuation would take too long.

As a result of the time necessary to com-plete the evacuation, persons may be exposed i

to health-threatening radiation doses.

Thus,.the LILCO Plan fails to comply with 10 CFR Sectione 50.47(a)(1), 50.47(b)(10) and

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NUREG 0654 Sections II.J.9 and J.lO.

Spe-cifically:

Contention 67.A.

According to LILCO's estimates, approximately 333 forty-passenger i

buses are required to transport those able-l bodied persons who would need transportation out of the EPZ (see Appendix A, at IV-74b; OPIP 3.6.4).

In fact, however, LILCO will either need more than 333 buses or those buses will have to make many more runs than anticipated by LILCO because LILCO has sub-j stantially underestimated the number of peo-ple who will need such transportation:

4 1.

LILCO underestimates the significant 3

number of people who belong to households with automobiles, but who may not have access to such vehicles because at the time of an evacuation order, the vehicles are in use by another member of the household.

LILCO's proposal for evacuating persons without access to transportation must 4

include adequate methods of evacuating the members of vehicle-owning households who may l

not have access to a car.

LILCO's estimates i

of the number of buses required do not ade-l quately take such people into account.

2.

LILCO's estimates also fail to take into account those persons who rely on pub-lic transportation to get into the EPZ but who, in the event of an emergency, may not be able to rely on such means to evacuate.

3.

LILCO assumes that its route buses will be filled to 75% capacity;'however, there is no basis for this assumption.

In fact, the route bus capacity factors are i

likely to be significantly lower than 75%,

which will result in a need'for many.more buses to evacuate people without access to cars.

Contention 67.B.

[ Withdrawn.]

Contention 67.C.

The staggered depar-tures and multiple bus runs necessary under LILCO's. plan to evacuate the' people in each

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i zone (Appendix A, at IV-76 to IV-163; OPIP j

3.6.4, at 11-32), even using LILCO's esti-mates of the number of people likely to need such evacuation, will result in evacuation travel times far longer than those set forth in Appendix A at 8a.

Specifically, the LILCO Plan provides that the bus routes will terminate at designated " transfer points" with each bus in many cases required to make more than one run.

As noted in Contention I

67.D, several transfer points are in the EPZ.

Transfer buses will transport the 3

evacuees from the transfer points to reloca-tion centers.

LILCO's estimated route times begin and end with the assumed transfer points.

(See Appendix A, at IV-76 to IV-163, V-8a; OPIP 3.6.'4).

LILCO's esti-mated evacuation times, however, assume that route buses will be dispatched from transfer i

points and return to the transfer points at f

)

specific intervals (or " headways") and that there will be little or no waiting at the l

transfer points for buses to the relocation centers.

Furthermore, the last transfer buses are assumed to clear the EPZ 15 i

minutes after leaving the transfer points.

j (Appendix A at V-7)

These assumptions are erroneous, however, since-they do not con-sider the severe traffic congestion that j

j will exist, for reasons set forth in Conten-I tion 65 at the same time that the route and transfer buses are attempting to make their trips.

Thus, the route times for each route bus will be longer than estimated by LILCO.

[

In addition, it-is likely to take far longer than 15 minutes for the last transfer buses to clear the EPZ after leaving the transfer l

points.

l Contention 67.D.

The eleven new transfer points designated by LILCO do not appear to have adequate structures which could provide shelter from adverse raciological or weather conditions for evacuees while they are wait-ing to be transferred to relocation centers.

Furthermore, four of the eleven transfer points are inside the EPZ and one is on the EPZ boundary.

In addition, of'the remaining.

six transfer points, three are located b,

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1 approximately one-half mile or less beyond the EPZ boundary, one is approximately one mile from the EPZ boundary and two are ap-proximately two and a half miles beyond the boundary.

Under the LILCO Plan, people are i

likely to be kept waiting for substantial time periods, because of delays, congestion, etc., before they are transported from transfer points to relocation centers.

Leaving people at the eight transfer points within or very close to the EPZ will not provide protection for them.

Leaving them at the other three transfer points, all less than five miles beyond the EPZ boundary, conflicts with the intent of NUREG 0654,Section II.J.lO.h, and could result in these people also receiving health-threatening radiation doses.

As this testimony will illustrate, the bus transportation arrangements for the general public are an important compo-nent of an integrated scheme of protective action measures that are designed to minimize population doses to the general public in the event of an accident.

In their development such aspects of integrated planning as the relative timing of bus evacuation relative to that for the automobile-owning public, the potential for exposure of evacuees by bus, and the functioning of transfer points have been considered.

The factual allegations of Contention 67 are.without basis.

Contention 67.A 4.

Q. Contention 67.A suggests that substantially more buses or bus runs will be needed to service the expected demand of people needing bus transportation.

Do you agree with this assertion?

l A.

(Cordaro, Weismantle, Lieberman]

Mo.

As a general propo-sition, the bus schedules that are presented on pages IV-74a to IV-74x of Appendix A are based on a series of very conservative assumptions.

These conservative assump-tions include both the estimation of the number of people l

who will need bus service and the provision of buses and bus runs to serve that population.

Thus the schedules provide a wide margin of excess bus capacity to serve the general public needing this service.

5.

Q. How did LILCO determine the number of people who would require bus transportation out of the EPZ?

]

A.

[Cordaro, Weismantle, Lieberman)

Three groups of people I

were identified who may require bus transportation out of 4

the EPZ.

These groups were:

I

1. People in households that do not own or j

have direct access to an automobile;

l 1
2. People in households who own or normally

]

have access to one or more automobiles, but who do not have access to those vehi-I cles at the time an evacuation is or-dered; and

3. Transients who have entered the EPZ by j

mass transportation.

In order to calculate the number of people in house-l holds that do not own automobiles, the following data and i

assumptions were used:

1 4

. m m.

. _. 1. Based on the results of the National Cen-ter for Telephone Research (NCTR) survey that was conducted for KLD, a value of 4%

was estimated for the number of house-holds having no direct access to an auto-mobile.

2.

It was assumed that each of these house-holds contained an average of 2.5 people.

This assumption was based largely on judgments about the household structure of people who do not own vehicles.

Gen-erally, it was assumed that a large por-tion of the non-automobile-owning public would be from households composed of elderly, probably retired, individuals.

These households were assumed to contain one or two members.

In addition, it was assumed that the remaining households without cars would generally have fewer members than the average EPZ household (3.5 persons), because as the size of a household grows the need for private transportation increases.1/

3. The projected 1985 EPZ summer population of 160,000, Appendix A, p.

III-2, was used as the population base to which the 4% value from item 1 was applied.

This is a conservative base since this popula-tion includes a large group of "tran-sients" -- approximately 21,000 people that are not included in the " permanent" winter population.

These transients are most likely summer vacationers who will have driven into the EPZ.

Nevertheless, 4% of these households are assumed to need bus transportation.

1/

The conservatism of 2.5 persons / household assumption has since been confirmed using information on household structures contained in the 1977 Nationwide Personal Transportation Study Repe/c NO 2, " Household Vehicle Ownership," US DOT (1980).

If inf; m._lon from Table 7 of that report is combined with house-hold size data for the Shoreham EPZ, an estimate of 2.1 per-sons / household is produced.

l 4.

Finally, it was conservatively assumed that none of the people in these house-

]

holds would obtain a ride from a neighbor i

or friend, or borrow an extra automobile from a neighbor, even though 78% of all households in the EPZ own two or more automobiles.

Instead, all were assumed to require bus transportation.

Based upon these assumptions, 4,500 people were estimated to require bus transportation.

In estimating the number of people from households that own, or normally have access to, a car, but who will not have access to that car during an evacuation, the follow-ing data and assumptions were used:

1. All households with access to one vehi-cle, where the commuter works 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or more from the home, were assumed to need bus transportation.

This represents a more conservative assumption than was made for computing the evacuation time estimates for the automobile-owning pub-1 lic, where it was assumed that commuters within 75 minutes of their homes would return home.

2. Based on the NCTR survey, 7% of all com-muters were estimated to travel more than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to and from their place of busi-ness.
3. Data from the NCTR survey also indicated that 22% of the households in the EPZ have access to only one car; this value was also used.
4. The 1985 projected EPZ summer population of 160,000 was used as the population base.
5. Finally, it was again conservatively assumed that none of these people would evacuate with their friends or neighbors, or borrow a vehicle from them.

l

! l On this basis, it was estimated that slightly more than L

1,700 people would require bus transportation.

To account for any uncertainties in these assumptions and the NCTR i

results, this value was rounded up by approximately 15% to l

l 2,000 people.

l Finally, with regard to transients entering the EPZ by public transportation, it was determined that this was a i

very small group of people and that the earlier use of the l

summer population to calculate the number of people with-out access to cars would account for this small group.

Accordingly, no separate estimate was necessary.

This determination was made as follows:

subsequent to the preparation of the bus schedules that appear in Appendix i

A, a series of calls was made to bus companies and to the Long Island Railroad, that provide the public transporta-tion within the EPZ.

Route timetables were also examined.

l The calls to bus companies revealed that they did not com-1 j

pile sufficiently detailed passenger information to permit computation of the exact numbers of transients entering 1

]

the EPZ daily, but the amount of passengers was generally 4

described as "very few."

As to trains, only three enter i

the EPZ from the east, and three from the west, daily.

Long Island Railroad schedules indicate that there is no commuter-oriented round-trip scheduling to stations _within

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i the EPZ from either east or west.

No trains stop within the EPZ from either east or west, for instance, between 7 and 10 a.m.,

and only one train, eastbound, stops within the EPZ between 4 and 7.p.m.

Normal passenger usage was described by Long Island Railroad personnel as very low on such trains as do stop within the EPZ.

Thus, KLD's computation of the number of people needing bus transportation yielded a value of 6,500.

This value was then compared with the summation of the zone-specific demand values that had been prepared by the Suffolk County Planning Department during the time that LILCO and Suffolk County were cooperating in the preparation of an evacua-tion plan for the Shoreham EPZ.

Those values, which appear in Appendix A and in the second column of Attach-ment 1 to this testimony, contain a total assumed passen-ger demand of 11,097.

Since it has been impossible to contact the members of the Suffolk County Planning Depart-ment to discuss the derivation of this value, out of an abundance of caution this dr. mand value was retained, at least for present purposes, as the basis for the bus schedules that appear in Appendix A, despite the fact that it was over 70 percent higher than the more recently de-termined value that is itself believed to be conservative.

1

- 6.

Q. One of the assumptions used in KLD's computation of the number of people needing bus transportation was that none of those without cars would get rides from neighbors or friends.

Is this a realistic assumption?

A.

(Weismantle]

Of course not.

As is clear from LILCO's Group I testimony people are more helpful to others than usual, rather than acting selfishly, during emergencies.

Evidence of this is contained in the Hans & Sell report, Evacuation Risks -- An Evaluation, EPA-520/6-74-002 (1974), which reports on page 52 that in most evacuations observed, more than 99% of evacuees use private vehicles.

KLD's assumption thus tends to overstate the number of persons who will need bus transportation.

7.

Q. Given this number of people needing mass transportation, how was this value converted into a given number of buses?

A.

[Lieberman]

To provide a complete answer to this ques-tion, it is necessary first to provide a brief explanation

]

of the transit plan that is presented in Appendix A.

The strategy that has been developed to provide transit ser-vices to the evacuating public within the Shoreham EPZ is based on the establishment of 11 transfer points.

These transfer points act as depots from which buses circulate along assigned routes within the EPZ, picking up people 1

i needing transportation.

At each transfer point there will be two categories of buses:

route buses and transfer buses.

Route buses begin their trips from the transfer

.- point, travel to their assigned residential areas, circu-late through those areas blowing their horns and stopping to pick up people, and then return to the transfer point.

At the transfer point, the route bus passengers will either transfer from the route buses to a waiting transfer bus that will then proceed directly from the transfer point to the assigned relocation center, or, if the route bus has completed its final scheduled run, will remain on the route bus -- which can be th<ught of thereafter as a transfer bus -- and proceed on it directly to the assigned relocation center.

(The reason route buses proceed via their transfer points after their last run, rather than proceeding directly to relocation centers, is to pick up any additional passengers who may be waiting there.)

Transfer buses have a single assigned duty, namely trans-porting evacuees from transfer points to relocation cen-ters.

Each transfer bus makes only one trip from a trans-fer point to a relocation center; and upon completion of that trip, transfer buses will not return to the transfer points.

In determining the number of transfer and route buses needed to serve an estimated demand of 11,000 people, it was first necessary to establish bus routes.

As a starting point, each of the 19 zones was assigned at least

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one bus route.

Additional routes were added based on such considerations as population, the distance people would have to walk to reach a bus route, and the time needed to travel a given route.

The results of this analysis are displayed in the zone-specific bus route maps that appear in Appendix A.

Since the exact spatial distribution of the population needing bus transportation was not known, it was decided I

that excess transit capacity would have to be provided to ensure that each zone would have an adequate supply of buses.

Consequently, the number of route buses was calcu-lated using t..e assumption that each route bus would carry 30 passengers, which is a load factor of 75 percent based on a seating capacity of 40 adults, and a load factor of less than 60 percent if standees are included.

In addi-tion, if the number of passengers on a given route were not evenly divisible by 30, then another bus was added to f

the route to service the demand.

For example, if a route had 165 expected passengers then six, rather than five, route buses would be assigned to that route.

These design procedures result in a large enough number of buses to confer significant flexibility in relating passenger traf-fic to bus capacity along bus routes.

Transfer buses were assumed to carry 40 passengers.

i 4 The final facet in the development of an estimate of j

the number of buses was the preparation of a detailed I

schedule of bus runs for each route within each zone in 1

)

the EPZ.

This is set forth in Appendix A, pages IV-74e I

to IV-74x, where it can be seen that there are multiple 1

l bus trips, at intervals of between 10 and 90 minutes (pre-i dominantly intervals (or headways) of 10 or 20 minutes),

on each bus route.

It was felt that this approach might l

yield a somewhat greater number of-buses than would have l

been indicated based on considerations of capacity alone,

)

j since, in addition to providing sufficient bus capacity, a

1 1

transit plan must also provide that capacity at the time the demand occurs.

1 This process resulted in an estimated need for 236

)

route buses making a total of 377 trips, plus 97 transfer buses each making-only one trip., Depending on the length of their routes, route buses have been assigned either one (120 buses), two (93 buses), three (21 buses) or four (2 buses) runs through their routes.

Using the original Suffolk County estimate.of demand (11,097 persons), this l

corresponds to an average seated (40 persons / bus) load factor.of 73%, or an average standing room (52 per-l sons / bus) load factor of 56% on-route buses.

Using the j

more recent KLD estimates of demand (6,500 persons), which i

l 1

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,.w-is believed to be more accurate, this corresponds to an average seated load factor of 43% and an average standing room load factor of 33%.

There exists a similar excess of capacity between transfer points and relocation centers, given the potential adult seating capacity of over 13,000 persons on the bus network.

See Attachment 1.

l This margin is large enough to establish that Conten-l l

tion 67.A is without merit.

Indeed, the excess of buses l

l available to remove persons from the EPZ relative to expected demand is sufficiently great that LILCO is con-sidering the possibility of making some of the buses now being reserved for this purpose available to assist in other aspects of an evacuation.

Contention 67.C 8.

Q. Could you please describe in more detail how the bus schedules used in the LILCO Transition Plan were devel-oped.

A.

[Lieberman]

In addition to the process just described, for each specified transfer point we identified those zones which could be most expeditiously serviced from that location.

For each such zone, one or more bus routes were established depending on the roadway layout and the popu-lation to be serviced.

For each such bus route, we devel-oped what are called " bus runs," a bus run being defined as a round trip made by one bus.

For example, six route buses have been assigned to Zone A; five of these buses make two runs, while the sixth bus makes only one run.

The need for 11 runs for Zone A was based on the estimated number of people needing bus trans-portation within that zone and on the capacity represented by these 11 bus runs.

Furtnermore, the deployment of buses over time for that zone was such that the last bus traveling over that route would not return to the transfer point until three hours after the initial route bus had begun its trip from the transfer point.

Thus, the route will be serviced over a period of approximately three hours.

To understand the operations at a transfer point, let us consider the transfer point located off Princeton Road in Brookhaven National Laboratory (see Appendix A, pp. IV-74i to IV-74j).

Five zones are serviced by this transfer point -- Zones A, B, C,

D and E.

Of these, only Zone C has two routes; the others have one route.

In addition to the 26 route buses assigned for the 40 runs on 6 routes within these five zones, 11 transfer buses are assigned to this transfer point.

These buses do not participate in the transit service until the schedule calls for them to collect passengers from returning route buses at the transfer point and take them to the assigned relocation i

1 1

.. center.

This transfer can take place in either of two ways:

first, as route buses return, passengers on those buses can exit those buses and immediately enter waiting transfer buses; or second, if a given route bus is full, it may be easier simply to switch drivers and make the route bus a transfer bus and vice versa.

9.

Q. Do the bus schedules take into account the congestion that would occur as a result of evacuating traffic?

A.

(Lieberman]

Yes.

Each route bus has three " legs" to its journey.

The first leg is the trip from the transfer point to the area where passenger pickup will begin; the second leg is the trip through the area picking up passen-gers; and the final leg of the journey is the return trip to the transfer point.

The travel time for each leg was calculated by referring to the computer output for Case No. 12, which is the base case evacuatien of the entire EPZ.

Since the DYNEV output provides detailed data for each link on the roadway network it was possible to trace the route of each bus and to estimate the travel times along each link.

Travel time for each leg was defined as the longer of two possibilities:

1. The travel time'as computed by the DYNEV simulation model, or
2. The travel time associated with a specified maximum speed.

i 4 i

i The maximum speeds assumed for each bus were:

25 miles per hour for the trip from the transfer point to the pick-I up area, 7 miles per hour within the pickup area (this speed includes the time required to pick up passengers),

and 20 miles per hour for the return trip.

The last transfer buses to leave transfer points locat-l ed in the EPZ do so either 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 10 minutes or 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 30 minutes after the order to evacuate is given.

Thus, the earliest any of these transfer buses will leave their transfer point is at least 20 minutes after the last car j

has departed the EPZ.

Accordingly, the travel speed for these buses was astumed to be'20 miles per hour.

The longest distances any of these buses will need to travel to reach the EPZ boundary is 5 miles; hence, the assumed travel time of 15 minutes to depart the EPZ.

See Appendix t

A,

p. V-7.

l Contention 67.D.

I

10. Q. Where are the eleven bus transfer points located?

A.

(Cordaro, Weismantle, Lieberman)

The 11 bus. transfer points currently designated in Appendix A are at the fol-i lowing locations:

Brookhaven National Laboratory Miller Place LILCO Right-of-Way Middle Island Shopping Center LILCO Brookhaven Substation Coram Drive-In Theater LILCO Property on Norwood Avenue at Nesconset North Bellport Restaurant Shirley Drive-In Theater LILCO Substation in Eastport Warehouse on Doctors Path, Riverhead LILCO North Patchogue Substation Of these cleven transfer points, four (Brookhaven National Laboratory, LILCO right-of-way in Miller Place, Middle Island Shopping Center and LILCO Brookhaven Substation) are located within the EPZ at distances of approximately 6 1/2 to 7 miles from the Shoreham plant.

The remaining transfer points are located outside the EPZ at distances ranging from 10 to 14 miles from the plant.

It should be noted that the exact locations of various of these transfer points are being, or may be, changed permanently or temporarily, in minor ways.

For instance, the Coram Plaza Shopping Center, adjacent to the.Coram Drive-In Theater, is being used instead of the Coram i

Drive-In.

An A&P Shopping Center located across the street from the Miller Place right-of-way may be used rather than the right-of-wsy, which would require improve-ments subject to local permitting.

Further information on transfer point locations is set forth in LILCO's testimony on Contention 24.I.

None of the relocations effected or l

s

. - ~

i contemplated to date affects the accuracy or logistics of the bus schedules set forth in Appendix A.

11. Q. Under the bus schedules developed for the LILCO Transition Plan, how long are evacuees expected to be kept waiting at transfer points?

A.

[Lieberman]

In almost no case should any person be re-quired to' wait at a transfer point.

At each transfer point, transfer buses are scheduled to depart at times corresponding to arrivals of route buses.

In addition, as has been noted, each route bus will function also as a transfer bus on its final route trip, stopping off at the transfer point enroute to the relocation center to pick up any waiting passengers.

This correspondence can be seen i

by examining the detailed " Bus Schedule" tables at Appen-dix A, pp. IV-741 to IV-74x.

On those tables, the starting times for route and transfer buses leaving trans-fer points for relocation centers are listed under the heading " Evacuate."

Departure times for transfer buses (designated by the legend X, e.g., X1-1) have been sched-uled so as to coordinate their activity with that of re-turning route buses (designated by zone, route and bus

number, e.g.,

Al-1).

There are a few instances where pas-sengers who are discharged from route buses and trans-ferred to waiting transfer buses may have to wait up to ten minutes, if they are unwilling or unable to stand on an earlier transfer bus departing for the relocation cen-ter.

Of the 97 transfer buses scheduled, ten minute waits should occur no more than four or five times.

12. Q. Does the period that evacuees will wait at bus transfer points expose them to " health-threatening radiation doses?"

A.

[Cordaro, Weismantle, Lieberman)

No.

As was just explained, there is a minimal wait for the people who must transfer from route buses to transfer buses, basically equal to the time it takes to unload one bus and load another.

For the majority of passengers who will travel on route buses that will not unload at transfer points, there will be little or no wait.

Since 7 of the 11 trans-fer points are located outside the EPZ, and the remainder are located more than six miles from the plant, any addi-tional dose occasioned by what short waits may occur is highly unlikely to be " life-threatening".

Finally, it must be noted that the recent addition to Contention 67.D -- a statement that suggests that transfer points do not provide shelter from adverse radiological or weather conditions -- is simply inapposite.

As was noted above, evacuees will either make no transfer at a transfer point or will walk to a nearby waiting transfer bus.

In the latter case, they will experience minimal exposure to the weather; in the former case they will experience none

1 1 whatever.

There is no need to erect special facilities at transfer points since there will not be substantial waits there by anyone.

ATTAC&1ENT ATTAC&1ENT 1 Table, Transfer Point Capacity 1

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I i

ATTACHMENT 1 1

i I

f TRANSFER POINT CAPACITY ESTIMATED BUS BUS SEATING PASSENGER DEMAND CAPACITY PROVIDED

  • PERCENT PERCENT TOTAL OF TOTAL OF TOTAL TRANSFER POINT POPULATION NUMBER POPULATION NUMS(R POPULATION Brookhaven 19969 1223 6.1 1440 7.2 National Lab (Zones A,B,C,D,E)

Miller Place 33206 2037 6.1 2360 7.1 LILCO ROW (Zones F, 1/2 G)

Middle Island 4172 314 7.5 400 9.6 Shopping Center (Zone 1/2 C)

Brookhaven 8402 410 4.9 560 6.7 Substation (Zones H, 1, J )

Coram Drive-In 27070 2030 7.5 2400 8.9 (Zone 2/3 K)

LILCO Property -

21465 1768 8.2 1960 9.1 No rwood (Zones 1/3 K, Q)

North Bellport 7223 525 7.3 640 8.9 Restaurant (Zone L)

Shi rley Drive-In 19136 1484 7.8 1800 9.4 (Zones M, N)

Eastport 3358 232 6.9 329 9.5 Substation (Zones 2/3 0)

Wa rehouse -

9054 522 5.8 680 7.5 Doctor Path (Zone 1/3 0, P, S)

N.

Pa tchogue 6905 522 8.0 760 11.0 LILCO Substet.on (Zone R)

TOTAL 159,960 11,097 6.9 13,320 8.3 l

i This capacity can be increased by approximately 25 percent if standees are included.

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