ML20101S884

Affidavit of ST Mccandless Re Evacuation Time Estimate Analysis.Prof Qualifications & Certificate of Svc Encl

ML20101S884
Person / Time
Site:	Perry
Issue date:	01/31/1985
From:	Mccandless S CLEVELAND ELECTRIC ILLUMINATING CO., HMM ASSOCIATES, INC.
To:
Shared Package
ML20101S865	List: ML20101S863 ML20101S877 ML20101S884
References
OL, NUDOCS 8502050694
Download: ML20101S884 (8)

Text

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cA OCCKETED UNITED STATES OF AMERICA Uh?C FMCLEAR REGULATORY COMMISSION

, BEFORETHEATOMICSAFETYANDLICENSINGBOkkD FB -5 A9 50 CFTCE r.= SECias 1 COG;', i'i & SERi : '

l: -In the Matter of )

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l' THE CLEVELAND ELECTRIC Docket Nos. 50-440

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ILLUMINATING COMPANY. ) ~50-441

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF SCOTT T..McCANDLESS-ON CONTENTION A-County of Middlesex )

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Commonwea.lth of Massachusetts )

SCOTT T.-McCANDLESS, being duly sworn, deposes and says:

1. -I am a co-founder, principal, and Vice President of HMM~ Associates, Inc. My responsibilities at HMM Associates in-clude the management and supervision-of evacuation time esti-mate studies. I have participated in a number of the more than 20 evacuation time estimate' analyses conducted by HMM Associ-ates in~ connection with emergency planning.for nuclear power-plants,1/ and have served as Principal-in-Charge.-of eight,

' including the evacuation time estimate study prepared by HMM

~

Associates.for the Perry Nuclear. Power Plant plume exposure-1/_ Most of the more than 20 evacuation time. estimate analyses prepared by.HMM; Associates already have been found accept-able by the NRC; the remaining analyses are currently' under~ review.

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o pathway Emergency Planning Zone ("EPZ"). That study is enti-tied " Evacuation Time Estimates For Areas Near The Perry Nucle-ar Power Plant" ("the ETE"). A current statement of my profes-sional qualifications and experience is attached hereto. My business address is 336 Baker Avenue, Concord, Massachusetts 01742. I have personal knowledge of the matters stated herein and believe them to be true and correct. I make this affidavit in support of Applicants' Motion for Summary Disposition of Contention A.

2. The Perry ETE was developed utilizing a state-of-the-art computer simulation that has been used at nu-clear sites throughout the country, and that has been previous-ly approved by the NRC. The purpose of this affidavit is to explain the involvement of state and local officials in the de-velopment of the evacuation time estimates for the Perry EPZ, and to explain the consideration of adverse weather conditions in the ETE.

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1A I. Involvement of State and Local Officials In Development of ETE

, 3. Offsite emergency planning / response officials have played an important role in the development of the ETE for the Perry EPZ. Indeed, their participation in the process is acknowledged on page 2-2 of the ETE:

Officials from the Ashtabula, Lake and Geauga County Disaster Services Agencies and Sheriff's De-partments have participated in the compilation and se-lection of these preparation and mobilization times.

Further, page 2-2 of the ETE notes, in relevant part:

Vehicle occupancy rates for the various population segments were based upon * * * ,

discussions with county emergency prepared- '

ness officials * * *,

Thus, the participation of these officials went far beyond a mere " review" of the ETE, and -- in fact -- even beyond the de-  !

l termination of preparation and mobilization times and vehicle  !

occupancy rates (expressly acknowledged in the ETE).

4. Before beginning work on the Perry ETE, on October 3 and 4, 1983, HMM personnel met individually with representa-tives of each of the tnree counties, (including the DSA Direc-tors for Geauga, Ashtabula, and Lake Counties), to present the basic methodology of the ETE and to discuss the general input data and assumptions for the computer simulation model to be used in developing the ETE. The model output (i.e., evacuation

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.h time estimates, average travel speeds, queue lengths, etc.) was also described. In addition, the time / weather condition sce-

, narios to be modeled were discussed. All meeting participants were in agreement with the information presented, and future meetings with the officials were scheduled for their review of the validity of the area-specific input data and assumptions for the Perry EPZ.

5. On October 17 and 18, 1983, HMM personnel again met with the officials (including the DSA Directors) of the three counties, to review the area-specific data and assumptions for use in the ETE. The data and assumptions discussed included matters such as evacuation area boundaries, evacuation routes, and adverse weather conditions to be modeled. All those in at-tendance at the meetings concurred in the results to date, as well as the proposed plans and procedures for continued work on the ETE.

6. On March 9, 1984, copies of the March 1984 draft of the ETE were provided to the DSA Directors of each of the three counties, and to the Ohio Disaster Services Agency in Columbus, for review and comment. The agencies' comments will be re-flected in the next revision of the ETE. The comments will be submitted to the NRC with the next revision of the ETE.

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II. Consideration of Adverse Weather In The ETE

, 7_ '. 'The-ETE'for the Perry EPZ includes evacuation time estimatesLfor several: temporal, seasonal, and weather condi-

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tions. As indicated on page.2-3 of the ETE, HMM considered not

_one, but two adverse weather scenarios _in the preparation of

.the evacuation. time estimates. First, HMM considered capacity and travel speed reductions of 20%, to represent sudden summer thunderstorm conditions. Secondly, HMM considered capacity _and-travel speed reductions of~30%, to represent winter snowstorm conditions.2/

8. As discussed above, the adverse weather scenario as-sumptions for the Perry ETE were selected based upon discus-sions with local officials (including the three County DSA Di -

~

rectors). These assumptions are consistent with those used in 2/ These reductions'are extrapolated from data presentedLin "The Environmental Influence of Rain on Freeway Capacity,"

E..Roy Jones and Merrell E. Goolsby, Highway Research Record No. 321, Highway Research Board, 1970; and " Headway

' Approach To Intersection Capacity'," Donald S. Berry and P.D. Gandhi,1 Highway Research Record No. 453, Highway Re--

search Board, 1973.

i NRC-approved. analyses conducted by.HMM for other sites with comparable meteorology.

JDr Scott T. McCandless W

Subscribedandsworntobeforemethis3/ddayofJanuary, 1985.

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SCOTT T. McCANDLESS Vice President ,

HMM Associates, Inc.

Education B.S. Civil Engineering, Worcester Polytechnic Institute M.U.A. Urban Affairs, Boston University Environmental Planning, W.P.I., 1975 Adjunct Assistant Professor i Summary of-Experience Mr. McCandless has extensive experience in environmental planning and management. He has served as project manager or principal investigator for a wide variety of nuclear safety studies, environmental studies and training programs. He has been directly involved in studies for nuclear facilities, urban mixed use developments, transportation projects, and energy development projects. He has aDpeared as an expert witness on emergency planning before an NRC Atomic Safety and Licensing Board. He has assisted with presentations on the same subject before the Advisory Committee on Reactor Safeguards. He has made technical presentations of the use of the NETVAC model for use in evacuation time estimates before the Transportation Research Board.

Professional Exoerience 1978 - HMM Associates; co-f ounder, principal and project Present manager. He has served as principal-in-charge for comprehensive off-site emergency planning assignments in New Hampshire and Indiana.- In each location, the work he supervised included compilation of State and local radiological emergency plans. In New Hampshire the assignment included cooroination of' drafting procedures -for 12 state agencies and f or the Governor and his staff. During this^ effort he coordinated training sessions for the Civil Defense Agency, the Department of Public Health, the State Police, the National Guard and all other emergency response agencies. In addition, he coordinated table-top-exercises, prepared-the State scenario materials, and served as the observer / controller at the State EOC.

Other recent emergency planning projects have included supervision of the development of evacuation time estimate reports compiled for submission to NRC. In total, he has'been principal-in-charge of studies for eight sites; he has participated in evacuation = time estimates at several more sites.

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l 2 1 SCOTT T. MCCANDLESS Page 2 i

Clients have included.TVA, Arkansas Power & Light, Florida Power & Light, Boston Edison and others. He has also been involved in the development of HMM's state-of-the-art computer models for simulating evacuations after nuclear accidents.

Other projects' have included management of state EIRs and federal EISs f or several urban developments _ in Boston, including the first.to be performed under comprehensive new regulations, Massachusetts Environmental Policy Act and the two largest urban commercial developments ever proposed for New

-England. Mr. McCandless has also directed projects with emphasis on noise, air quality and transportation considerations.

1972-1978 Environmental Research & -Technology, Inc. (ERT).

In his most recent position he served as manager of the Environmenal Planning Division. In this position, he served as both a senior project manager and as administrative head of a multidisciplinary division of environmental professionals including specialists in acoustics, air quality, archaeology, economics, geology, landscape architecture, planning, socioeconomics and transportation planning. During his tenure at ERT, Mr. McCandless was project manager for more than twenty different environmental studies. Among them were the EIS for the SHERCO coal-fired power plant' in Minnesota, the EIA for POD 3 of the New Town at Battery Park City in Manhattan, an Environmental Assessment for the Columbia Green Springs SNG plant feedstock allo-cation, Air Quality Studies f or several Washington METRO System EIS efforts, and_an Environmental Reconnaissance for an ethylene plant site'for the Mobil Chemical Company.

1971-1972 Needles, Tammen & Bergendoff,' Staff Planner.

Prepared the Route 2 EIS and the Land Use Plan for the Manchester, NH Airport Master Plan.

1969-1971 Robinson & Fox, Staff Planner. Prepared-tenant selection and Management Plans for proposed MHFA funded housing development in Worcester, MA.

Professional Affiliations Member, American_ Society of-Planning Officials 07130

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CJ: FE7En BEFORE THE' ATOMIC' SAFETY AND LICENSING BOARD e5NAC

'85 F8 -5 !!9 :50 In the Matter of-

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LIFICE GF % guy .

THE CLEVELAND ELECTRIC ) Docket NosP05Q444Q 3tgyic/

ILLUMINATING COMPANY. ) 50 J 4'41CH

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-(Perry Nuclear Power Plant, )

Units 1 and.2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion For-Summary Disposition of Contention A," " Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard on Contention A," and " Affidavit of Scott T. McCandless on Contention A" were served this 1st day of February, 1985,'by deposit in the U.S.' mail, first class, postage prepaid, upon' the parties listed on the attached Service List, except for those parties identified by asterisk who were served by express mail.

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JQ. Silberq~

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Dated: February 1, 1985

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.g UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s

. -In the Matter of )

i )

THE CLEVELAND ELECTRIC. ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

.(Perry-Nuclear Power Plant, )

Units 1 and 2) )

. SERVICE LIST James P. Gleason, Chairman Atomic Safety and Licensing

513 Gilmoure Drive Appeal-Board Panel i Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

, Mr. Jerry R. Kline Docketing and Service Section

Atomic Safety and' Licensing Board Office of the Secretary i U.S. Nuclear Regulatory Commission . U.S. Nuclear. Regulatory Commission

}.

Washington, D.C. 20555 washington, D.C. 20555 Mr. Glenn O. Bright Colleen P. Woodhead, Esquire Atomic Safety and Licensing Board. Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Alan S. Rosenthal, Chairman Atomic Safety and Licensing *

! Terry Lodge, Esquire

Appeal Board Suite 105 l U.S. Nuclear Regulatory Commission 618 N. Michigan. Street l Washington, D.C. 20555 Toledo, Ohio 43624 i

i Dr. W. Reed Johnson Donald T. Ezzone, Esquire Atomic Safety and Licensing Assistant Prosecuting Attorney

! Appeal Board .

Lake County Administration

, U.S. Nuclear Regulatory-Commission Center i Washington,.D.C. 20555 105 Center' Street

. Painesville, Ohio 44077-Gary J. Edles, Esquire Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. .20555 Washington,.D.C. 20555 -

-John G. Cardinal, Esquire

• Ms. Sue Hiatt-

- Prosecuting Attorney 8275 Munson Avenue Ashtabula County Courthouse . Mentor, Ohio 44060.

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