ML20112B288
| ML20112B288 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/03/1985 |
| From: | Klimm R CAROLINA POWER & LIGHT CO., HMM ASSOCIATES, INC. |
| To: | |
| Shared Package | |
| ML20112B261 | List: |
| References | |
| OL, NUDOCS 8501100299 | |
| Download: ML20112B288 (11) | |
Text
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-January 3,1985 UNITED STATES OF AMERICA Q;,,70 NUCLEAR REGULATORY COMMISSION
%Q BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3 @ ~g w:,
00 t;1[fl j 4 In the Matter of
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.c 3 re CAROLINA POWER & LIGHT COMPANY
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4 r
AND NORTH CAROLINA EASTERN
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Docket No.
50-400 OL MUNICIPAL POWER AGENCY
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(Shearon Harris Nuclear Power Plant)
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AFFIDAVIT OF ROBERT D. KLIMM IN SUPPORT OF APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF EDDLEMAN CONTENTION 215(1)
County of Middlesex
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SS:
Commonwealth of Massachusetts
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ROBERT D. KLIMM, being duly sworn, deposes and says as follows:
1.
I am an Associate of HMM Associates, Inc. My business address is 336 Baker Avenue, Concord, Massachusetts 01742. A summary of my professional qualifications and experience is attached hereto as Attachment A.
2.
My responsibilities at HMM Associates include the management and supervision of evacuation time studies. I have served as either Project Manager or Principal Transportation Engineer for many of the more than twenty evacuation time analyses conducted by HMM Associates in connection.with emergency planning for nuclear power plants. I was Principal Transportation Engineer for the evacuation time estimate study prepared by HMM Associates for the Shearon Harris plume exposure Emergency Planning Zone (EPZ). This study is entitled " Evacuation Time Estimates for the Plume Exposure Pathway Emergency Planning Zone of the Shearon Harris Nuclear Power Plant" (October 1983)(hereinafter referred to as "ETE"). I am also responsible for 8501100299 850107 PDR ADOCK 05000400 g
all transportation-related computer analyses conducted by HMM Associates.
I was involved in the system development of the NETVAC evacuation model, which is a state-i of-the-art computer evacuation simulation model. The NETVAC model has been used to estimate evacuation times for approximately 20 nuclear power'[lant sites. I co-authored the NETVAC model users manual. In addition, I have provided training to various groups on the use of the NETVAC model.
6 3.
I have personal knowledge of the matters stated herein and believe them to be true and correct. I make this Affidavit in response to the first subpart of Eddleman 215, which will be referred to as Eddleman Contention 215(1). I have reviewed this contention and am familiar with the substance of the allegations contained therein. I am aware that Eddleman Contention 215(1) challenges the assumption used in the Harris ETE that
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evacuation of the population within the plume exposure pathway EPZ would occur from their homes. According to Eddleman Contention 215(1), this assumption is unrealistic for certain times of the day and could result in double-counting of evacuees who both live and work within the EPZ.
4.
The Harris ETE utilizes a state-of-the-art computer simulation designed to d
project evacuation times as accurately as possible. From a practical standpoint, it is necessary to use certain simplifying assumptions in order to develop input data that can be effectively used for the computer simulation. The input data consist of existing statistical information, such as census data and roadway characteristics, and assumptions about activity that will take place during the scenarios modeled. The joint NRC/ FEMA criteria document on emergency plans, NUREG-0654/ FEMA-REP-1 (Rev.1 November 1980), anticipates that some assumptions will be used. Appendix 4 to NUREG-0654, which contains acceptance criteria for evacuation time estimates, provides that the analyses should indicate the assumptions which underlie the time estimates. NUREG-p
' 0654 at 4-2, 4-7.
For the Harris ETE, HMM Associates, Inc. attempted-to use assumptions that are as realistic as possible and supportable.
The assumptions I
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incorporated into the Harris ETE are consistent with those used by HMM Associates in its compilation of similar analyses for other nuclear power plant sites. Most of the more than twenty evacuation time analyses prepared by HMM Assocates already have been found acceptable by the NRC; the remaining analyses are currently under review. Where the simplifying assumptions have some potential for error, HMM attempted to balance the over-predictive versus under-predictive assumptions to compile scenarios that are realistic.
The important point is that the assumptions in combination result in evacuation times that are realistic.
5.
The assumptions used to develop the evacuation time estimates presented in the Harris ETE were developed based upon (1) informal discussions held with state and county emergency preparedness officials throughout the course of the study; (2) reviews by HMM Associates, Inc. of empirical data on past evacuations; (3) knowledge and experience obtained by HMM Associates in conducting similar evacuation time studies for more than 20 nuclear power plant sites throughout the country; and (4) federal guidance contained in the NUREG-0654, Rev.1. Assumptions used in the ETE, including the assumption of evacuation from home, were reviewed with numerous emergency planning officials. These officials include James Self of the North Carolina Division of Emergency Management; Mark Scott, the Emergency Management Coordinator of Chatham County; Carl Lucas of the Harnett County Emergency Management Agency; Billy Ray Cameron of the Sanford/ Lee County Department of Emergency Management; and J. Russell Capps of the Wake County Emergency Management Agency. Each of these officials concurred in the assumptions used.
6.
The ETE does include the assumption that "[t]he auto owning permanent
[ resident] population segment will evacuate from their places of residence." ETE at 2-2. This assumption is reasonable for simulating the evacuation of vehicles containing permanent residents of the EPZ. It is unquestionably true that the exact locations of people within the EPZ when notification is initiated will vary depending upon such i
factors as the time of day, day of week, and season of the year. For example, during a week day, many permanent residents will be at work either within the EPZ or outside the EPZ and others may be shopping or visiting recreational areas, schools, doctors' offices, etc.
Assuming that these persons will evacuate from their homes is reasonable, however, because evacuation will only take place after the initial notification, i
mobilization and preparation. Preparation to evacuate involves the formation of family
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units and the packing of clothing, personal goods and valuables. For persons who are not already at home, these preparation functions will require intermediate travel from the place at which notification is received to home in order to facilitate the formation of family units and to gather belongings. The tendency of persons to form family units and evacuate together is borne out by the available literature on past evacuations for natural disasters. See Perry, et a_l " Evacuation Planning in Emergency Management" (1981) at 146, which states that " families tend to evacuate as a unit" and that evacuees often attempt to reunite families. Residences are the best and most likely place to form family units. This type of behavior during evacuations is also confirmed by Dr. Dennis S.
Mileti,' a sociologist who specializes in the study of public emergency responses.
According to Dr. Mileti, persons usually seek to unite with family members and evacuate as a group during emergency situations, unless they receive sound directions to the contrary.
The assumption of evacuation from home has been utilized by HMM Associates,'Inc. in each of the more than 20 evacuation time studies that we have prepared for other nuclear power plant sites.
7.
The ETE considered the time required for travel from work to home, stores to home, doctors' offices to home, etc., in developing the evacuation times. As explained in section 6 of the ETE, the methodology used incorporated a range of times associated with preparation and mobilization activity of the permanent residents.
Based _ on discussions with local emergency preparedness officials, it was concluded that, at a minimum, permanent residents. would require 15 minutes to prepare to evacuate following a 15-minute notification period. This minimum preparation / mobilization period
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I would apply to that segment of the population that happens to be at home at the time of notification and would require minimal time to prepare. Thus, the ETE assumed that no vehicles would begin evacuation during the 15-minute alert and notification period and 4
.that the evacuation preparation time for all population segments would be no less than 15 minutes. ETE at 6-1. In other words, no permanent residents would begin to evacuate until 30 minutes following the initial alert.
The majority of permanent residents, however, would require ~ longer periods of time to prepare and mobilize. Discussions with
. local emergency preparedness officials also led to the conclusion that a preparation / mobilization time range of up to two hours would be appropriate for the i
entire resident population. ETE at 6-2. Thus, permanent resident households would begin to evacuate between 30 and 150 minutes after the initial notification. This represents a range of times that would be associated with a number of preparation and mobilization activities,-including leaving work, traveling home and uniting with the family before evacuating, closing places of business and returning home from shopping trips.
8.
The methodology used to develop the total population and vehicle demand estimates within the Harris EPZ does incorporate some double-counting. For example, employees at major places of employment and persons visiting major recreation areas within the EPZ are counted separately. ETE at 3-3. It is reasonable to assume that a portion of the identified employees and visitors to recreation areas are also permanent residents of the EPZ. Employees and visitors who are also included in the permanent population estimates are counted twice. In addition, school children, who are treated as -
an independent special facility category, are also included in the permanent population estimates. ETE at 3-4.
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9.
The evacuation assumptions of the various population components used in the ETE are the basis for simulation of realistic evacuation traffic flow conditions. Double-counting of some segments of the population is done intentionally to implicitly simulate realistic traffic flows on the roadway network. That is, the methodology does over-
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estimate total population somewhat, but more accurately reflects realistic vehicle activity on the evacuation roadway network. The double-counting simulates traffic friction on the network due to travel home prior to the actual evacuation. Vehicles will be evacuating the major recreation areas whether they are destined for homes within the EPZ or traveling directly to areas outside the EPZ. Similarly, during work periods, employees will be departing from their place of employment, destined either for homes within the EPZ or traveling to areas outside the EPZ. When a school child evacuates directly from the school, the rest of his or her family will still depart from the residence but with one less passenger in the car. For these reasons, limited double-counting of some population segments results in a more realistic simulation of vehicle activity during an evacuation. Double counting of these population segments results, therefore, in a more accurate estimated time for encuation from the EPZ.
- 10. The methodology for the Harris ETE utilized a state-of-the-art computer simulation that has been used at numerous nuclear sites throughout the country and that has previously been approved by the NRC.
For the reasons explained herein, the assumption of evacuation from home is fully justified and results in realistic estimates of the evacuation times from the Harris EPZ. The assumption is not a " conservatism" that results in an overestimate of evacuation times.
b ROBERT ~D'. KLIMM i
i Subscribed and sworn to before me M
,,,Jhis day of January 1985.
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Attachmsnt A-C ROBERT D. KLIMM Education 4 -
M.S.
- Civil Engineering (Transportation), Northeastern.
Universit y, 1979 8.S.-
LCivil Engineering, Worcester Polytechnic Institute, 1975 Summary of Experience-
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~ Mr. Klimm spe'clalizes in traNs'portation engineering and emergency preparedness / evacuation planning.
He has. served as Project Manager or. Technical Advisor on most of the evacuation i
. time estimate = analyses conducted by HMM.
He also has been responsible for numerous emergency preparedness tasks for nuclear power plants including:
the development of school facility evacuation plans and procedures; the development of evacuation and population data for CRAC2 and CRACIT consequence modeling; and the develop ~ ment of evacuation routings and time
.. estimates for special facilities.
'Mr. Klimm was invo'lved in the system dev'elopment of the NETVAC evacuation simulation model, which has been used at 20. nuclear power plant sites througncut the country.- He has provided training to grcups that have been licensed to use the NETVAC f
'model, and was responsible for conducting an Evacuation Time Estimate Workshop for Public-Service Electric and Gas Company of New Jersey.
Profe.ssional Excerience 1980 -
HMM Associates.
Mr. Klimm serves as Project Present Manager and/or Principal Engineer for projects involving emergency preparedness planning end emergency evacuation. - Recent experience includes the following:
Principal Engineer for the development oc o
evacuation time estimates for the Susquehanra Steam Electric Station (Luzerne County, Pennsylvania, 1981).
w Project Manager for the preparation 6f o
supplemental evacuation time estimates for s the Midland Nuclear Power Plant (Midland, Michiga n, 1983 ).
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s Pr6 ject Manager for the development of o
evacuation time estima tes for the D.C. Cook Nuclear Plant (Berrien County, Michigan, X
'1984).
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(R0 SERT D. KLI,MM Page 2
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Project Manager for the deve'lopment of an o
. Evacuation Traf fic Management Plan for the Midland Nuclear Power Plant Plume Exposure EPZ (Midland, Michigan, 1983).
Principal Engineer for the preparation of o
evacuation time estimates for the Shearon Harris Nuclear Power Plant (Wake County, North Carolina, 1983).
Project Manager for the development of an o
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- Evacuation Traf fic Management Plan for the
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' primary Plymouth Station Evacuation Relocation Center (Hanover, Massachusetts,
~ 1983 ).
o Principal Engineer for the uevelopment of population and evacua tion data for CRACIT radiological consequence modeling within the-Seabrook Station EPZ Hampshire, 1983).
(Seabrook, New Project Manager for the development of an
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[4 Evacuation Traf fic Management Plan for the Seabrook Station Plume Exposure EPZ, (Seabrook, New Hampshi.re,1982).
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- o Project Manager for the preparation of evacua tion time es tima tes for the Grand Gulf Nuclear Station (Clairborne County, Mississippi, 1981).
1977-1980 Fay, Spofford & Thorndike, Inc.
Transporta tion Engineer.. R esponsible for tra f fic operations analyses; traf fic control design, specification's and cos t es tima tes; transporta tion environmental impact analyses; highway safety analyses; truck circulation s tudies, and traf fic.. circulation l
plans for private and public developments.
CStralMassachusettsRegionalPlanning' 1975-1977 Commission.
.Transporta tion Engineer / Planner.
Responsible for transportation corridor planning
- studies, transportation systems management, traf fic operations analyses, and coordination of the re plan. gional transportation air quality control A
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Page 3 0ther Professional Data 1
Affiliations:
Transportation Research Board:
National
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Academy of Sciences Institute of Transportation Engineers American Society of Civil Engineers.
Boston Society of Civil Engineers
' Papers / ^
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- Klimm, R., "Comparisori of Optional ~ Cycle Publications:
Lengths for an Urban Arterial Signal System Using Maximum Bandwidth and Minimum -
Vehicle Delay Criteria," Northeastern University, 1979
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- Klimm, R., " Fringe Parking' and Intermodal Transportation System--Feasibility Study,"
CMRPC, 1976
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- Klimm, R.,
Sheffi,.Y., Mahnassani H.,
Powell, W., ' NETVAC2 USER MANUAL,",HMM
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A s so cia t es, 1962.
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ado UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
)
AND NORTH CAROLINA EASTERN
)
Docket No. 50-400 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power Plant)
)
CERTIFICATE OF SERVICE I. hereby certify that copies of " Applicants' Motion for Summary Disposition of Eddleman Contention 215(1)," " Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard on Eddleman Contention 215(1)" and " Affidavit of Robert D. K11mm in Support of Applicants' Motion for Summary Disposition of Eddleman Contention 215(1)" were served this 7th day of January,1985 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List.
b-sv Dale E. Hollar Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 Dated: January 7,1985
us.
SERVICE LIST James L. Kelley, Esquire M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U. S. Nuclear Regulatory Commission Post Office Box 12643 Washington, D. C. 20555 Raleigh, North Carolina 27605 Mr. Glenn O. Bright Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U. S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D. C. 20555 Mr. Wells Eddleman Dr. James H. Carpenter 718-A Iredell Street Atomic Safety and Licensing Board Durham, North Carolina 27705
' U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Thomas A. Baxter, Esquire Delissa A. Ridgway, Esquire Charles A. Barth, Esquire Shaw, Pittman, Potts & Trowbridge Myron Karman, Esquire 1800 M Street, NW Office of Executive Legal Directo?
Washington, D.C. 20036 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Bradley W. Jones, Esquire U. S. Nuclear Regulatory Commission Docketing and Service Section Region II Office of the Secretsry 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303
_ Washington, D. C. 20555 Robert P. Gruber Mr. Daniel F. Read, President Executive Director.
Chapel Hill Anti-Nuclear Public Staff Group Effort North Carolina Utilities Commission Post Office Box 2151 Post Office Box 991 Raleigh, North Carolina 27602 Raleigh, North Carolina 27602 i
Dr. Linda Little Mr. Spence W. Perry Governor's Waste Management Board Federal Emergency Management Agency 513 Albemarle. Building 500 C Street, S.W.
-325 Salisbury Street Room 840 Raleigh, North Carolina 27611 Washington, D. C. 20740 Mr. Steven Crockett, Esquire Steven Roch11s
- Atomic Safety and Licensing Federal Emergency Management Agency Board Panel 1371 Peachtree Street, N.E.
U. S. Nuclear Regulatory Commission Atlanta, Georgia 30309 Washington, D. C. 20555 John D. Runkle, Esquire Conservation Council of North Carolina 307 Granville Road Chepel Hill, North Carolina 27514 L
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