ML20102A832

Affidavit of ST Mccandless Supporting Motion for Summary Disposition of Contention B Re Potential Evacuation Route Impediments

ML20102A832
Person / Time
Site:	Perry
Issue date:	01/31/1985
From:	Mccandless S CLEVELAND ELECTRIC ILLUMINATING CO., HMM ASSOCIATES, INC.
To:
Shared Package
ML20102A776	List: ML20102A774 ML20102A784 ML20102A809 ML20102A818 ML20102A832 ML20102A841 ML20102A858
References
OL, NUDOCS 8502080584
Download: ML20102A832 (6)

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t UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION a BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

's r- -f l?0 :15 In the Matter of )  :

) i THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY -) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

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

) ss.

Commonwealth 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 connectign with emergency planning for nuclear power plants,l/ 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.

O O O PDR

e 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 B.

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 note the consideration of evacuation route impediments and the evacuation of onsite construction workers in the ETE.

I. Evacuation Route Impediments

3. The potential for impediments and route closures was specifically discussed with offsite emergency planning authori-ties in a series of meetings held in October 1983, in prepara-tion for commencement of work on the ETE. The consensus of meeting participants was that no evacuation routes would be to-tally obstructed in any credible evacuation scenario. However, system-wide reductions in carrying capacity were deemed appro-priate to, reflect adverse weather conditions -- specifically,

slippery roads and, in the case of snow, encroachment on the roadways. Accordingly, as explained in my Affidavit on Contention A (filed February 1, 1985), the ETE reflects model-ing of two adverse weather scenarios -- capacity and travel speed reductions of 20% (sudden summer thunderstorm condi-tions), and capacity and travel speed reductions of 30% (winter

. snowstorm conditions).

4. In addition, the ETE includes an appendix devoted specifically to consideration of impediments -- Appendix 8, "The Effects of Traffic Accidents and Disabled Vehicles on Es-timated Evacuation Procedures."

II. Evacuation of Onsite Construction Workers s

5. As the ETE itself reflects, HMM considered the. Perry onsite work force (including onsite construction workers) in the development of the evacuation time estimates. See, e.g.,-

ETE SS 2.1 (at 2-1), 2.4 (at 2-8 to 2-10), 3.5 (at 3-8), 6.1

'(at 6-1, 6-6). See also ETE at A3-2, A4-4 to A4-6 (Column 15).

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6. In summary, evacuation route impediments and the evacuation of Perry construction workers have been thoroughly considered.in the development of the Perry ETE.

lv blftt4 2A'I' Scott T. McCandless Subscribed and sworn to before me.this day of January

-1985.

n Notary Public

' My Commission expires:

9 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 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 appeared 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 Experience 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 l

work he supervised included compilation of State and local radiological emergency plans. In New Hampshire the assignment included coordination of drafting

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. procedures for 12 state agencies and for 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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SCOTT T. MCCANDLESS Page 2 c

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 I state-of-the-art computer models for simulating i evacuations after nuclear accidents.

i h Other projects have included management of state EIRs

and federal EISs f or several urban developments in i 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 f

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

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

< In his most recent position he served as manager of I the Environmenal Planning Division. In this position, he served as both a senior project manager and as administrative head of a multidisciplinary l division of environmental professionals including t

i specialists in acoustics, air quality, archaeology, F

economics, geology, landscape architecture, planning, i socioeconomics and transportation planning. During i his tenure at ERT, Mr. McCandless was project manager i f or more than twenty dif f erent environmental

! studies. Among them were the EIS for the SHERCO

~ coal-fired power plant in Minnesota, the EIA f or g POD 3 of the New Town at Battery Park City in Manhattan, an Environmental Assessment for the t Columbia Green Springs SNG plant feedstock allo-cation, Air Quality Studies f or several Washington

METRO System EIS efforts, and an Environmental F Reconnaissance for an ethylene plant site for the it Mobil Chemical Company.

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

j Prepared the Route 2 EIS and the Land Use Plan for  :

I the Manchester, NH Airport Master Plan.

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

E f Professional Affiliations E

i Member, American Society of Planning Officials b

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