ML19339C523

Comments on NUREG-0625, Rept of Siting Policy Task Force. Use of Fraction to Quantify Transients Not Appropriate Re Planning for Emergency Preparedness.Urges Development of More Realistic Statistic in Determining Transient Factor

ML19339C523
Person / Time
Site:	Seabrook
Issue date:	11/12/1980
From:	Metcalf M AFFILIATION NOT ASSIGNED
To:	Muller D Office of Nuclear Reactor Regulation
Shared Package
ML19339C521	List: ML19339C520 ML19339C523
References
RTR-NUREG-0625, RTR-NUREG-625 NUDOCS 8011180541
Download: ML19339C523 (3)

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One Glassford Lane Durham, New Hampshire 03824 (603) 868 2648 November 12, 1980 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Siting Policy Task Force Daniel R. Muller, Chairman Washington D.C. 20555

Dear Mr. Mullor,

Upon reading NUREG-0625 REPORT OF Tile SlTING POLICY TASK FORCE, I find myself gravely concerned by the casual use of the term "tran-sient population" on page 19, Sec. 2.1.2 7. Practice 1. paragraph

1. 3: " Transient population should be included for those sites where a significant number of people (other than those just passing through the area) work, reside part time, or engage in. recreational activities and are not permanent residents of the area. The tran-sient population should be taken into account by weighting the transient population according to the fraction of time the transients are in the area." and again on page 49, Sec. 3 2.1 Recommendation

1. 1, Population Density and Distribution, last paragraph on the page,,

last sentence: " Transients should be weighted according to their fractional occupancy within this annulus."

I offer this observation:-

When determining a statistic for predicting the demand for some commodity, good or service, the use of a fraction to quantify a

" transient" may be appropriate. Ilowever, for the purpose of plan-ning for emergency preparedness involving the protection of persons and property, the very nature of the population so identified does not REDUCE the problem by a factor, but quite the opposite, indeed, intro duce s a compounding element into the problem.

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Trancisnt Pcpulation November 12, 1980 p.2 I cite examples:-

Tourists and recreational visitors are groups routinely identified as " transients". The number of such persons in an area might be quite stable for a season or on a predictable schedule, but in fact, each of these persons might be in the area for a short period of time, possibly only a few hours, more usually a few days. These individuals are not and have no intention of becoming a part of the community and thus have little incentive to become familiar with community routines. These individuals might well be unaware of the existense of a nuclear fueled power plant in the vicinity and have no idea of appropriate action in case of an emergency. Many of these in-dividuals would be unfamiliar with local highway route numbers, street names, geographic features, community facilities, even com-pass directions. There could be a significant language barrier.

The " transient factor" intecduced by these individuals compounds the problems of emergency planning for the community involved.

Institutional populations (colleges, jails, hospitals) introduce a compounding " transient factor".

The physical structure and the supporting staff are permanent, but the individual students, inmates, patients, etc., introduce to a more or less degree the " transient factor" described above. Although the numbers are stable, the individuals are foreign to the community and thus compound the planning problem, aside from other characteristics of these particular population elements.

Seasonal residents present a different characteristic in that the individual may be " transient" but the property is not. The property is permanent and thus has a constant need for protection.

To the extent that a population is stable, proceedures for communication, patterns of cooperation and support can be establa=hed and maintained.

To the extent that a population is unstable ("trar,ient") such pro-ceedures and patterns become more difficult to establish and maintain.

Thus it would seem to me, " transients" should not be treated as a fraction, but as an exponent. I am not a statistician so I cannot suggest what the quantitative factor (s) should be.

Transient Population November 12, 1980 p.3 The paragraph on p. 19 to which I previously refered, seems to dismiss motorists and commuters as if of no consequence in siting policy standards. For some purposes this might be appropriate, but again for the purposes of emergency planning, it is my opinion, these elements cannot be dismissed, but are very much a part of the problem. It is true that converging traffic could be abruptly halted at the perimeter of the Emergency Planning Zone. However, at the instant such traffic is halted it becomes an obstacle within the adjacent communities, the very communities which are generally assumed will be " resource" communities, " support" communities and/or " host" communities. Thus it would seem that these "enroute transients" cannot be dismissed, but must also be assigned a stastical weight reco5nizing their compounding of the problems.

I urge that you devise a statistic which more nearly realistically addresses the true nature of the " transient factor" in the context of emergency planning and that population density definitions be adjusted appropriately. And that the adjusted definitions be adopted in siting policy.

Mary K. Metcalf Concerned Citizen

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