ML20106F529
| ML20106F529 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/25/1984 |
| From: | Wilson R WILSON, R. |
| To: | CAROLINA POWER & LIGHT CO. |
| References | |
| CON-#484-793 OL, NUDOCS 8410300290 | |
| Download: ML20106F529 (7) | |
Text
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g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION m
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
??' q r-In the Matter of
)
I 29 P l :14 CAROLINA POWER AND LIGHT COMPANY AND NORTH CAROLINA EASTERN
)
Docket No. 50-400 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power Plant)
)
Response by Richard Wilson to Applicants Interrogatories on EPJ-5 and Wilson 12(b)(2) and Wilson 12(b)(3)
General Interrogatorie s 1.
I relied on no one 2.
Jan Tedder, a citizen of Apex surveyed local agencies to define the number of people who might need assistance in evacuation.
3.
Undecided 4.
See specific answers 5.
See specific answers 6.
No other sources 7.
Undecided Specific Interrogatories 12(b)(2)-1 1980 Census data (item 123 on STF-3) for the Wake C,unty townships of Holly Springs, White Oak, Buck-horn, and Middle Creek show that the percentages of households with two or more vehicles are, respective-ly, 70%, 67%, 63% and 60%.
In the event of an evacu-ation, I believe any f amily with more than one driver would take more than one vehicle with them to prevent contamination of the vehicle and provide the f amily with transportation flexibility during the time they are away from home.
12(b)(2)-2(a)
The Evacuation Time Estimate should demonstrate how the evacuation times would vary if the assumption of 1-vehicle household were altered to 1.5 or 1.75 vehi-cle s household.
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12(b)(2)-2(b)
Applicants have never cited any empirical data to support their assumption of 1-vehicle household.
Any unsupported assumption should be viewed with caution.
In a traf fic flow simulation, which probably has sudden non-linear behaviors as the capacities of roadways are approached, a worst-case assumption should at 1 cast be inve st igated.
The worst-case does not have to be incorporated as the basis for planning, but it should be considered.
12(b)(2)-3(a)
None (b)
N/A 12(b)(3)-1 I am aware that the ETE estimate of 240 f amilies is for Wake County only.
12(b)(3)-2 The southwest corner of Wake County is more rural and has lower income than the county as a whole.
Evaluation of this area using Census data broken down to the town-ship level provides a more accurate appraisal of the number of households without vehicles.
I have assumed that the EPZ includes all of Holly Springs, Buckhorn and White Oak Townships and 50% of Middle Creek Town-ship households.
My analysis is presented in Table 1.
The first column shows data taken directly from 1980 Census STF-3 item number 121/122: " occupied housing units with no vehicle available".
The second column gives the standard error calculated according to Chapter 6 of the 1980 Census Users Guide.
This accounts for the sampling variability in surveys involving relatively smal? groups.
The third column gives the upper range of the 95% con-fidence level (2 standard errors from the first column).
A standard error adjustment factor of 1.0 was assumed.
For planning purposes this conservative figure should be used to make sure that planning is adequate.
The fourth column gives the percentage of the population of the township that should be considered, for conser-vative planning purposes, to own no vehicle.
The fifth column gives the number of people corresponding to the numbers in the third column, assuming 2.7 persons /
household.
9 TABLE 1 - POPULATION WITHOUT VEHICLES STF-3 Standard Upper Limit Percent of Number of Census Data Error at 95%
Households People Confidence Holly-Springs 95 21.8 139 12%
375 Buckhorn 68 16.8 132 32.4%
356 White 0ak 158 27,
212 9.4%
572
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Middle Creek 153 37.3 190 11.4%
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e 12( )(3)-3(a)
I hava only analyzed Wake County, but I believe that a similar deficiency in the Applicants' analysis exist s for-other counties as well.
(b)
See (a) 12(b)(3)-4(2)&(b)
See answers to 12(b)(3)-3 above.
12(b)(3)-5(a)&(b)
See answers to 12(b)(3)-3 above.
12(b)(3)-6(a)
I assume that 84 in this interrogatory is intended to be 204.
This is not an adequate estimate for planning purposes.
12(b)(3)-6(b)
For planning purposes Applicants should consider there could be 673 households which own no vehicle in the Wake County portion of the EPZ.
See Table 1.
but in 12(b)(3)-7 I have no quantitative basis for this assertion, my experience it is not unusual for people to miss appoint-ment s because of auto break-downs.
12(b)(3)-8 Because the number of households and people that own no vehicle is quite large, the Applicants should bear the burden of demonstrating that these people can all be evacuated within the alleged 236 minutes.
The locations of so-called " pick-up points" and the number of vehicles designated to go to each point should be specified in order to provide assreance that these people can be evacuated.
The capacity of each vehicle and the agency supplying each vehicle should be specified.
There should be some demonstration that people will be able to get to the pick-up points from their homes.
The evacuation time estimate should be revised if dealing with this number of people without vehicles prolongs the time c' stimate for complete evacuation.
12(b)(3)-9 I know of no other changes at this t ime.
EPJ-5-1(a)
I believe that maintaining an up-to-date list of handi-capped (see FEMA Guidance Memo 24 for definition) people is an exceedingly difficult and time-consuming process.
The list must be updated daily to include people recently impaired, just moved into the zone, or just discharged from the hospital.
There must be a mechanism to ident ify people who are no longer on the active caseloads of home-health agencies but continue to be disabled, and people The list must who have never received agency assistance.but at the same be rapidly available to local officials, time privacy and security must be assured.
Since emergency workers from throughout the county will be involved, the list must include directions to the dwellings, and such directions are not easy to obtain or follow for rural areas.
i f
Because this project is a major undertaking the Plan should be precise about the way that each of these goals will be I
achieved and exactly who (position, not just agency) will be responsible for doing so.
1.
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EPJ-5-1(b)
The offsite plans do not need to contain a list, but the production of a list is the only credible demonstration that the Applicants have on effective mechanism for identi-fying homebound people.
Therefore the Board should require that a list be generated and the capacity to keep the list up-to-date be demonstrated before they approve the off-site plan.
Furthermore the list produced for demonstration pur-poses should be available for my inspection and verification prior to the hearing.
EPJ-5-2 ( a)-( f)
I have developed no further information on this issue.
EPJ-5-3(a)
There is no pre-arranged assignment of emergency vehicles for the evacuation of hospital, nursing homes and f amily care homes within the EPZ despite the sovious fact that the Apex and Fuquay Rescue Squads are too small to perform this function.
Secondary notification and an emergency re-sponse at the, Shearon Harris site would be a further drain on emergency vehicles.
There is no evidence what soever in the plan that an adequate number of vehicles from whatever source can be mobilized to achieve evacuation in 236 minutes.
EPJ-5-3(b)
I do not know how many will be available, but I would esti-mate that there are only about 30 Rescue Squad ambulances in Wake County (3 in Apex, 3 in Fuquay, 3 in Cary, 5 in Raleigh which would be the primary responders.
1 of those in the small communities and 2 in Raleigh would have to be reserved for other emergencies).
There are no arrangements with private. ambulance f acilities.
EPJ-5-3(c)
Assuming: 1.
Data from table 3.5 of ETE study 2.
Evacuation to be completed in 236 minutes 3.
Round trip times from zones to shelter as follows: a. NE sector 2-3 mile zone - 90 min.
- b. NE sector 8-9 mile zone - 75 min.
- c. Fuquay area - 90 min.
4.
Each vehicle could make 2 round trips (combine assumptions 2 & 3) 5.
2 non-ambulatory peopic/ vehicle I would estimate the following requirement s Apex-New Hill Area - 10 vehicles Fuquay Area - 30 vehicle s This provides transportation only for hospitals, nursing homes and rest homes.
Homebound people would probably require several times this number of vehicles, although given the uncertainty about the number of these people and their resources this is difficult to estimate and may be many more.
See answer to (d) below.
EPJ-5-3(d)
At this time I will accept the figures given in table 3.5 of the Evacuation Time Estimate study for non-ambulatory people in hospitals, nursing homes, and re st home s.
The number of people at home who will require special assistance is very difficult to estimate.
From surveying h
some local agencies I would estimate 800 homebound mobility impaired people who might require ambulance evacuation 3g (150-200 on active files, 400 who are off active caselo~ ads, 200 who have never received assistance).
In addition there may be 100 people with mental impairments severe enough to i
require specific attention to insure their evacuation was accomplished.
EPJ-5-4 See answers to Interrogatories 12(b)(3)-8 and EPJ-5-1(a) and EPJ-5-1(b)
EPJ-5-5 At this time I know of no other actions.
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dE:.ATED CCn2py0ENCf(
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
,_,g..--
'. lc v BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
(50-400::OL.,M.,,
CAROLINA POWER AND LIGHT COMPANY
)
AND NORTH CAROLINA EASTERN
)
Docket No.
MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power Plant)
)
CERTIFICATE OF SERVICE I hereby certify that copies of Response by Richard Wilson to Applicants Interrogatories on EPJ-5 and Wilson 12(b)(2) and Wilson 12(b)(3) have been served this 25th day of October 1984, by deposit in the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are marked with an asterisk, for whom service was accomplished by Phyllis Lotchin, PM.D.
Judge James Kelly 108 Bridle Run Atomic Safety and Licensing Board Chapel Hill, N. C.
27514 US Nuclear Regulatory Commission Washingt on, D. C.
20555 Dan Read P. O. Box 2151 George F. Trowbridge ale
, N. C.
27602 Shaw, Pittman, Fotts & Trowbridge 1800 M. St. NW Ruthanne G. Miller, Esq.
Washington, D. C.
20036 Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Office of the Executive Legal Director Washingt on, D. C.
20555 Attn: Dockets 50-400/401 0.L.
USNRC Bradley W. Jones, Esq.
Wash ingt on, D. C.
20555 U.S. Nuclear Reg. Com., Region II 101 Marrietta Street Office of the Secretary Atlanta, Ga.
30303 Docketing and Service Station Attn: Dockets 50-400/401 0.L.
Dr. Linda Little Governor's Waste Management Board USNRC Washing ton, D.C.
20555 (3 copies) 513 Albemarle Bldg. 325 N. Salis-aeg,N.
27m by John Runkle, CCNC 307 Granville Road Robert P. Gruber, Exec. Director Chapel Hill, N. C.
27514 Public Staff - NCUC Travis Payne, Edelstein & Payne R1 gh N
27602 Box 12607 Raleigh, N. C.
27605 Spence W. Perry, Esq.
Assoc. General Counsel, FEMA Wells Eddleman 500 C Street, SW, Suite 480 718-A Iredell St*
Washington, D. C.
20740 Durh am, N. C.
27705 g
Certified by A.
// L