ML20031B163

Informs That Reconsideration of NRC 810715 Denial of 810630 Request for Proceeding on Evacuation Feasibility for Facility Emergency Planning Zone Is Not Warranted,In Response to League

ML20031B163
Person / Time
Site:	Seabrook
Issue date:	09/15/1981
From:	Harold Denton Office of Nuclear Reactor Regulation
To:	Merckabeles A SEACOAST ANTI-POLLUTION LEAGUE
References
NUDOCS 8109300431
Download: ML20031B163 (7)

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SEP 151981 q\\8 Y a H* 'B

'2 Anne tierck Abeles, President 2

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SAPL Seacoast Anti-Pollution League v.s..ocua nesumes 5 Market Street Portsaouth, tiew hampshire 03801

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REFERENCES:

us (1) SEA 3 ROOK STATION EVAC'JATION A'lALYSIS, FI!iAL REPORT, JULY 1980 Man M. Voorhees & Associatas (2) EVACUMIO'4 RISK - N: EVALUATI0tl UA-52/o-74-002, U.S. ENVIR0!r1EHTAL FROTECTION Aro:CY, PAGE 45

Dear Ms. Merck-Abeles:

This is in reply to your August 1,1931 letter which requests reconsideration of my July 15,1931 denial of your June 30,19W request for institution of a proceeding on evacuation feasibility for the Seabrook EPZ.

Your letter stated that the following staf f conclusion was in error since the Seabrook analysis performed for FE$iA (1) asstned that effective local preparedness plans were in effect:

" evacuation tines estimated for the Seabrcok site ( provided by FE'1A)...

are based only on currently available cornunications, notification systems and tra f fic management capabilities...".

The staff based their conclusion on the following quote from page 50 of the FE'tA contractor's study:

"For each of the evacuation scenarios carried through the analysis, the forecast traffic volumes were assigned to the system of evacuation routes.

In the absence of a detailed local plan for the management of evacuation traffic, a number of assuaptions raust be made in order to reflect the conditims, reasonable attainable with available local management resources.

Theref _.e, for the purposes of this analysis, it was assumed that overall, traffic facilities would be operated in a relatively normal fashion. That is to say that few instances of special traffic nanagement capability were assumed."

It is obvious that "special traffic nanagement" nay result in evacuation times below those predicted by the FEhA contractor's model.

I8109300431'~810915 PDR ADOCK 05000443 In addition, you stated:

F PDR "Tne " current" situation is that there is no effective plan. FEt1A clearly states that "in the absence of effective preparedness planning, the evacu-atton time estimates given in this report are invalid." Hence, the 6.2 naar u ae i roe i> imaim..

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HRC requires that State and local energency preparedness plans be in place for the area within 10 miles of a site before it will be licensed to operate.

These plans will be reviewed by FEMA for acceptability during the operating license review for Seabrook.

Since in-place emergency plans will be

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required, use of the FEMA figures which assume in-place plans was appropri-ate in my decision.

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Finally, you stated:

"The valid max 1 mum time frame according to FEMA for the " current" sit-uation in which there is little or no traffic control secure 6 by local plans is nearly fif teen hours. At both the beginning and the end of the FEMA study it is stated that an evacuation in which traffic control is generally ineffective, total evacuation times will range from ten hours thirty minutes to fourteen hours forty minutes."

Homver, the FEMA contractor's report on page i states:

"In a Sumer Sunday evacuation, a substantial portion of all evacuating population is delayed by traffic congestion.

In the beach area, this delay ranges up to a maxinum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 15 minutes. 11ost of the traffic caught in congestion is within 5 niles of the Seabrook Station, with a substantial portion within direct sight of the plant. The behavior of drivers under these conditions of delay and proxinity to the Seabrook Station can only be guessed.

However, any breakdown in orderly evacuation traffic flow will result in evacuation times greater than those estimated.

For an evacuation in which traffic control is generally ineffective, total evacuation times will range from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> 30 minutes to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> 40 minutes."

The 10 and 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> evacuation time estimates are based on the FEMA contractor's hypothesis that the evacuating drivers will behave in an abnorual way and disrupt the evacuation. The staff has found no data to support this hypothee's.

In fact an EPA study (2) found:

" Based on the Disaster Research Center report, Inages of Disaster De-havior, peoples' behavior during an energency is characterized by:

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The idea that people will panic in the face of great threat or danger is very widespread.

However, it is not borne out in reality.

Insofar as wild flight is cont.crned, the opposite behavioral pattern in nost disasters is far more likely. People 5

will often stay in a potentially threatening situation rather than nove out of it.

This really should be expected. Human being.c have very strong tendencies to continue on-going lines of behavior in preference to initiating new courses of action.

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i SEP 151981 2.

Just as the panic i:nage of disaster behavior is generally incorrect, so is the view thai; disasters leave victins dazed and disoriented both at time of impact and in the recovery period. Those who experienced disasters are not immobilized by even the most catastrophic of events. They are neither devoid of initiative nor passively dependent or expectant that others, especially relief and welfare workers, w ll take care of i

then and their disaster created reeds.

In fact, disaster victims someti:nes insist on acting on their own even contrary to the expressed advice of the public authorities and fonnal agencies.

The EPA Report (at page 47) goes on to say:

"Although the studies done by the Disaster Research Center and others have dispelled the nyths associated with peoples' behavior during a disaster, if the causative agent of the incident were radiation, would peoples' reactions be substantially different?

The conclusion drawn by many is that because radiation is largely an uqknown quantity, inperceptible to the ordinary senses, inherently, the fear of the unknown and its consequences would Cduse a different behavior pattern--perhaps similar to popular notions. This would, inturn, have a draavatic effect on evacuation involving a release of radioactivity.

"Dr. Russell R. Dynes, Co-Director of the Disaster Research Center, was asked if he thought people would react differently--panic--because of a radiation threat. Dr. Dynes' reply was that there has been an overenphasis placed on the quelitative difference between radiation and other threats by both public officials and anti-nuclear groups,

• What was assumed was that the nuclear advent represented some new juncture in human history and, therefore, it would evoke and donand a quite different level of human behavior.' Dr. Dynes continued,

' As I read history, there is not reason to suggest that because of the presence of a new ' order' of threat that hirnan behavior would disintegrate into ' uncivilized' behavior.'

"The sumation of Dr. Dyes' reply is that there is not reason to expect that people will react any differently because the disaster agent is radiation than they would for a flood, fire, or any other type of causativa agent. This ' normal' behavior is anply documented and does not include panic."

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1. j SEP 151981 In view of the above responses to your concerns, I have detennined that reconsideration of my July 15, 1931 denial of your June 30, 1981 request for a proceeding on evacuation feasibility for the Seabrook EPZ is not warranted.

I reiterate that my decision of July 15th was not intended to finally resolve the adequacy of energency preparedness for the Seabrook Station.

The energency preparedness issue will be addressed in the operating license review for Seabrook and parties to the operating license proceeding will have, of course, the opportunity to raise emergency planning issues. Accordingly, as I indicated in ny July 15th decision, I do not believe it is appropriate to institute an additional proceeding now to consider such issues apart from the operating license proceeding.

Si ncerely.

Of@g sped by H. R. Dtmion HaIold R. Denton, Director Office of Huclear Reactor Regulation cc:

See next page SEE PREVIOUS CONCURRENCE V

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y e f devoid of initiative nor passively dependent or expectadt that L

others, especially relief and welfare workers, will,t3ke care of them and their disaster created needs.

In fact, dfdaster victims sonetimes insist on acting on their own even contrary to the expressed advice of the-public authorities and# formal agencies.

,7 Although the dies done by the Disaster Research Center and others have dispelled myths associated with peoples' behdior during a disaster, if the usative agent of the incident wer'e radiation, would peoples' reactions ' e su5stantially different? TYe conclusion drawn by many is that bec e radiation is largely aqsunknown quantity, imper-ceptible to the ordin senses, inherently, tfie fear of the unknom and its consequences wo d cause a different/ behavior pattern--perhaps similar to popular notio This would, ijfturn, have a dramatic effect on evacuation involving a yease of rad 16 activity.

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Dr. Russell R. Dynes, Co-Dire %ctor of the Disaster Research Center, was asked if he thought people wou1%readt differently--panic--because of a radiation threat. Dr. Dynes' repig was that there has been an over-enphasis placed on the qualitatiyeMiffe ence between radiation and other threats by both public officials andbti-nuclear groups, "Lhat was assumed was that the nuclear pent rehgesented some new juncture in human history and, therefcre, it would c ke and deaand a quite different 0

level of human behavior." j r. Dynes cont ed, " As I read history, there is not reason to suggest that because of t 'gresence of a new ' order' of threat that hunan behavfor would disintegrate to ' uncivilized' behavior."

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The summation of Dr./yes' reply is that there i got reason to expect l

that people will redt any differently because the Msaster agent is radiation than th f would for a flood, fire, or any o%er type of causative 9

agent. This "no al" behavior is aaply documented and (es not include panic."

In view of t above responses to your concerns, I have detem ned that reconsider ton of my July 15, 1981 denial of your June 30,19 request for a hearing n evacuation feasibility for the Seabrook EPZ is not ' ranted.

Sincerely, Harold R. Denton, Director Office of Huclear Reactor Regulation See next/pa h(

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• tilliam C. Tallman Chairman and Chief Executive Officer

' Public Service Ccmpany of New Hampshire 100 Eim Street Manchester, New Hampshire 03105 J:.hn A. - Ritscher, Esq.

E. Tupper Kinder, Esq.

'Repss and Gray Assistant Attorney General 225 Franklin Street

--Office of AtarneyJeneral Ecston, Massachusetts 02110 208 State Fouse Annex F..

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!!ew Hz: ashire House of Representatives

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--Scie.nce, Technology and Energy Co mittee' State House Mr. Bruce -B. Beckley,* Project Manager Concord, New Hampshire 03301 Public Service Company of New Hampshire 1000 Elm Street-Resident Inspector Manchester, New Hampshire 03105 Seabrook Nuclear Pcwcr Station c/o U. S.~ Nuclear Regulatory Commission Ms. Elizabeth H. Weinhold P. O. Box 1149 3 Godfrey Avenue Seabrcok, New Hampshire 03872 Hampton; New Hampshire 03842 Mr. Jchn DeVincentis Rtbert A. Backus, Esq.

Yankee-Ar5=.4c Electric Company O'Neill, Sackus and Spielman 1571 Cercesier Lane 115 Lowell Street Farminir.am, Massachusetts 01701 Manchester, New Hampshire 03105 W

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Ecsten, Massachusetts 02105 General ' Counsel Public Service Ccmpany of New Hempshire 1000 Elm Street Manchester, New Hampshire 03105 i

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$ tate House Annex ATTH: Assistant to the Director Office of Comprehensive Planning Concord, New Hampshire 03301 Office of the First Selectman Town of Seabrook Seabrook, New Hampshire 0387a

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Office of Radiation Programs S. Environmental Protection Agency -

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Deexet File 50-443/444 w/ incoming L.PDR PDR NSIC TERA LB#3 Files Eb0 Rdg.

WDircks HDenton ECase DEisenhut RPurple RTedesco FMiraglia BBuckley LWheeler JLee Attorney, OELD CMiles, PA GErtter EHughes LBerry IE (3)

SCHilk, SECY (3)/ incoming CStephens, SECY LBickwitt, 0GC/ incoming JMurray, OELD (84(4M)

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