ML20107A303
| ML20107A303 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/15/1985 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-614 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8502190386 | |
| Download: ML20107A303 (4) | |
Text
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15 Febihary 1985 UNITED STATES OF AMERICA NUCLEAR BEGULATORY COMMISSION 79 G :07 N:C y n :h BEFORE THE AH)MIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al.
(Shearon Harris Nuclear Power Plant, Unit 1)
ASLBP No. 82-h68-01
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OL Wells "ddlenan's Posponse to Sunnary Disnosition Ifotions on Contention 215(1) (Evccuation Time Inaccuracy)
Apolicants submit a notion and affidavit filled with glowing generalities of little substance.
Wh<tt substance the=e is nostly supports the contention.
The Staff adds only an unsunnorted oninion (no facts, except that people do tend to evacuate fron hone, Staff'c affiant believes, citing a source).
Neither Staff nor Applicants' affiants deal with the innact of the back-traffic tio, homes that nust occur in their scenario.
This back-traffic will affect traffic canacities noving out because the back traffic nust make turns (including left turns across evacuation routes) to reach their homes or driveways.
Appliccnts admit (Klinn affidavit, paragranh 8) that their methodology double counts "ennloyees at nafor nieces of emnloynent h
and norsons visiting naJor recreation areas within the Ro7,", yet n
u/
clain that the double counting is "snall".
Staff acknowledges on:
(Urbanik, paragranh 5) that no data exists on the extent of the double a
g$
counting.
Yet if it includes the larges en71oyers' ennloyees, oW and recroational populations, both of which are grouns in the thousands MO3
of persons, double counting is inevitable and could bo quite substantial.
But worse than that, the FTEs make a wrong assunntion: that all the traffic from the enployers' cites, recreation areas, etc. is out of the EPZ along the evacuation routes.
The ETSs sinoly do not account for the trips within the EPZ.
This natter is not dealt with in the affidavits.
t Klinn for Annlicants sort of dodges aro"nd it in hizs cavagraoh 7, where he says a nvenavat'nn/ mobilization time of"up to two hours" was included.
But he doesn't say that it was based on the tine or traffic densities associated with tries back to hone.
He only says it's based on " discussions" (undocunented) with officials, and that it is a tine range that "would be associated" with auch thines as returning home.
He never cones out and says that the figure was arrived at by exolicitly taking into account those trtns, nor does he say that tries hone were discussed with the officials he talked to (see nis uaragranh 5, which only cays "the assunntion of evacuation from hone" was discussed.
It doesn't say how, or whether the tries home were taken into account).
Knowing App'.icants' efforts to state thing, in the cost fsverable light to them, these onissions and skirting of the isnue are significant, and point to a lack of innut.
?here is no evidence the trins hone are included in the ETE traffic load nodeling.
Nor does either affiant refer to such inclus'en.
Por thece reascns, sumnary disposition on 215(1) should be denied.
A listing of facts in discute is annended to this response.
l2 r
n Wells Eddleman b - l b b? b P.S. Concarning Hollar letter for Anolicants of P-1185 re 57-0-3, and his letter of 2-8-85 ve 47-C-13, a senarate Intter of response is also enclosed with this filing.
~
List of Fcets in Dispute on 215(1) 1.
The Harris ETE, contrary to Annlicants' " fact" 2, does not take into account the effects of assuming evacuation from hone in a <;sy that shows the effect of this assumotion on the time estinates.
" State of the art" as a tern for connuter nodeling is irrelevant.
' The ouestion is whether the assunctions are realistic; offsetting errors with other errors is only "attennted" according to the Klinn affidavit, and nay result in connounding errors, esnecially whebe the effect of each error is not known.
No under-credictive assunctions to " offset" this overpredictive assunntion of evacuation fron home 1
are cited in any of the affidavits re this contention.
2.
There are no data on cast nuclear nlant evacuations used by HMM, according to discovery on this contention.
Thus "Fnct" 3 is irrelevant because there is to connarable information used.
3 Persons nay seek to go hone in evacuation conditions even if told not to; however, this is not taken into account by the Anulicants or Staff.
The trips hone are not taken into account in traffic flow nodeling, contracy to " Facts" 2,3 and 6 of Annlicants.
4 The 30 to 150 minute assunction of Klinn et al is not based on any citation or analysis; Apolicants ' " Fact" 8 never addresses the effects of the assunption of evacuttion from hone on this time.
It is obvious it would increase the time required.
But by increasing the time required to initiate evacuation, the estinates err on the high side, thus naking it nove likely that any evacuation would not be ordered (due to insufficient time to connlete it) when it night be a lifessving measure, double counted..
- 5 The Harris clant' double counting"assunes'all traffic noves out, but nost of it will nove through the EDZ, a fact not addressed in
" Fact" 9 of annliennts, which is unrealistic.
The sane p"oblen applies to their " Facts" 10 and 11.
6.
There is nothing but opinion behind " Fact" 12 assuming the ETE evacuation fren hone estinates are realistic.
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UNITID STATES OF AMDtICA NUCLEAR RIGULATORY COMMISSION In tr.e matter of CAROLUA POWER k LIGHT CO. It al. J Docket 50-400 shearon Harris Nuclear Power Plant. Unit 1*
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0.L.
CERTIFICATE 0F SERVICE W Resnonse to sunnary disposition I hereby certify that copies of on P15(1), and letter to the. Board re Hollar letters of P-8 and P-31-85 HAVE been served this 15 day of February igg 5, by deposit in j
the US hil, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are arked with an asterisk, for whom service was accomplished by waitinrt for the roctal rate increant, te become effective. (noteno nsterisks below)
Judges Jates Kelley, Glenn Bright and James Ca nenter (1 copy each)
Atenic Safety and Licenaire Board US Nuclear Megulatery Connission Washington DC 20555 George F. Trowbridge (attorney for Applicants) t Shaw, Pittman, Potts & Trowbridge R.uthanne G. Miller l
1600 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 2055 5 py{d$ cst.SW Spence W. Perry Office of the Executive Legal Director Docke ts 50-400/kO10.L.
l Washington DC 20555 u d Washington DC 20740 Docketing and Service Section (3x)
Dan Read CEATE/TLP Attn Docke ts 50-h00/hC1 0.L.
Office of the Secretary Waleigh,907 Waverons NC 27606 USNRC
[
Washington DC 20555 Dr. Linda V. Little (E plan only) aoy,rnor,s Waste Mst. Bd.
John Runkle Steve Rochlais 511 Albenarle B1dg.
CCNC FEMA-Suite 700 325 N. Salisbury St.
Raleigh, NC 27611 307 Granville Rd 1371 Peachtree St.NE Chapel Hill Nc 2751k Atlanta GA 30309 Bra dley W. Jone s i
Robert Gruber USNRC Region II Travi s Payne Exec. Director 101 Marietta St.
Edelstein & Payne Public Staff Atlanta GA 30303 Rex 12601 Box 991 Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D.
Certified by h
I 729 Hunter St.
Apex NC 27502
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