ML20112J959

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Affidavit of Rd Klimm Re Eddleman Contention 215(3). Assumptions Incorporated in Evacuation Time Study Consistent W/Hmm & NRC Approved analysis.Nonauto-owning Household Would Evacuate at Rate of One Vehicle/Household
ML20112J959
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 01/14/1985
From: Klimm R
CAROLINA POWER & LIGHT CO., HMM ASSOCIATES, INC., NORTH CAROLINA MUNICIPAL POWER AGENCIES
To:
Shared Package
ML20112J843 List:
References
RTR-NUREG-0654, RTR-NUREG-654 OL, NUDOCS 8501180432
Download: ML20112J959 (10)
v • d • e


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9 January 14, 1985 C:'JETCO UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

~65 JM 17 P1 :57 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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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) )

AFFIDAVIT OF ROBERT D. KLIMM ON EDDLEMAN 215(3)

County of Middlesex )

) ss.

Commonwealth of Massachusetts )

ROBERT D. KLIMM, being duly sworn, deposes and says:

1. I am an Associate of EMM Associates, Inc. My respon-sibilities at HMM Associates include the management and super-vision 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 nucle-ar 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). That study is entitled " Evacuation Time Estimates for i

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.- the Plums Exposure Pathway Emcrgency Planning Zone of the Shearon Harris Nuclear Power Plant" (October 1983) (hereinafter referred to as 'ETE"). I am also responsible for all transportation-related computer analyses conducted by HMM Asso-ciates. I was involved in the system development of the NETVAC evacuation model, which is a state of the art computer evacua-tion simulation model. The NETVAC model has been used to esti-mate evacuation times for approximately 20 nuclear power plant sites. I co-authored the NETVAC model users manual. In addi-tion, I have provided training to various groups on the use of the NETVAC model. A current statement of my professional qual-ifications 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 be-lieve them to be true and correct. I make this' affidavit in response to Eddleman Contention 215(3).

2. The purpose of this affidavit is to explain that the assumption in the ETE that non-auto-owning households would evacuate at the rate of one vehicle per household is not a

" conservatism" that results in an overestimate of evacuation times. Rather, the stated assumption is a practical means of l simulating the evacuation traffic which would be generated in l

l the provision of transportation assistance for non-auto-owning

( households in the event of an evacuation of the Harris EPZ.

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4 9 3. The Harris ETE utilizes a state-of-the-art computer simulation designed to 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 assump-tions about activity that will take place during the scenarios modeled. The joint NRC/ FEMA criteria document on emergency plans, NUREG-0654/rEMA-REP-1 (Rev. 1 November 1980), recognizes that some such assumptions must be made. 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-0654 at 4-2, 4-7. For the Harris ETE, HMM Associates, Inc. attempted to use assumptions that are as realistic as possible and sup-portable. The assumptions incorporated into the Harris ETE are consistent with those used by HMM Associates in its compilat, ion of similar analyses for other nuclear power plant sites. Most of the more than twenty evacuation time analyses prepared by HMM Associates already have been found acceptable by the NRC; the remaining analyses are currently under review.

4. The assumptions used to develop the evacuation time estimates presented in the Harris ETE (including the methodolo-gy used to estimate vehicle demand of permanent residents) were

r y d:veloped b: sed upon (1) i n f o n... discussions held with state and county emergency preparedness officials throughout the course of the study;1/ (2) reviews by HMM Associates, Inc. of empirical data on past evacuations; (3) knowledge and experi-ence obtained by HMM Associates in conducting similar evacua-tion time studies for more than 20 nuclear pow 9r plant sites throughout the country; and (4) federal guidance (NUREG-0654, Rev. 1, Appendix 4).

5. The ETE used the best data available at the time of the study to estimate the number of households within the EPZ which do not own vehicles and, accordingly, would need some type of transportation assistance in an evacuation.2/ The methodology used in the ETE assumes that vehicle occupancy rates for the non-auto-owning population are the same as those 1/ The State and County emergency preparedness officials were involved with and provided key input to the ETE, including many of the site-specific variables which must be consid-ered in such a study (such as reasonable preparation and mobilization times, evacuation procedures, assumptions on evacuation characteristics associated with the various population segments, etc.).

2/ The ETE figure of 410 house' holds was based on data from the 1980 Census of Population, Advance Estimates of Social, Economic, and Housing Characteristics. The ETE estimates of this population were refined (based on later, more detailed Census data indicating 655 households), for the purpose of assessing the transportation resources available to evacuate persons needing official transporta-tion assistance. See " Affidavit of Kevin Twine on Wilson 12(b)(3) and EPJ-2." The refined figures would have no discernibic impact on the evacuation times presented in the ETE.

7. . -.
for the auto-owning population; that is, one vehicle per house-hold.
6. In the event of an actual evacuation due to an emer-gency at the Harris plant, transportation for all non-auto owning households would be furnished through rides with friends, neighbors, or relatives, or through coordinated ef-forts by state and county emergency preparedness officials.

The exact number of vehicles necessary to evacuate this popula-tion category would vary based upon several factors, including the type and numbers of transportation resources available at the time of the evacuation.

7. The assumption that non-auto owning households (like auto-owning households) would evacuate at the rate of one vehi-cle per household was specifically reviewed with the local emergency preparedness officials and determined to be appropri-ate as the most realistic means of representing the evacuation traffic which would be generated in the provision of transpor-tation assistance (by friends or family, or emergency response personnel) for non-auto-owning households.
8. Thus, in practice, the assumption that non-auto-owning households would each generate the traffic associated with one vehicle is a reasonable means of simulating traffic along the roadway network, following internal routes to collect non-auto-owning passengers. (This traffic could range from cars or vans going to individual homes to pick up evacuees,l/

i 1/ For purposes of estimating evacuation times, it does not matter whether such vehicles are operated by friends or (Continued next page)

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r x y to largsr vehicles -- such as buses -- traveling from one pickup point to another to pick up evacuees.)

9. As a practical matter, for purposes of estimating evac-uation times, the type and number of vehicles used to evacuate the non-auto-owning population within the EPZ are relatively in-significant, because that population category is a relatively small percentage of the total population within the EPZ. A re-duction of a total oi 410 (or 655) vehicles would not reduce evacuation time estimates appreciably -- i.e., a reduction of 10 minutes might be achieved by changing this assumption to include no vehicles to handle the non-auto-owning population.S/ The re-sults of the ETE (see Section 7) indicate that the primary factor influencing evacuation times for most cases is the preparation and mobilization time period. The total evacuation times are less sensitive to vehicle demand than they are to these prepara-tion and mobilization time periods. Variations in the number of vehicles used to evacuate the non-auto-owning population would not significantly affect the evacuation times.
10. In summary, the methodology for the Harris ETE utilized a state-of-the-art-computer simulation that has been used (Continued) family, or by emergency workers. The effect of such traf-fic is the same.

4/ However, eliminating these vehicles altogether would tend to underestimate the time required to evacuate; this would be inconsistent with the thesis of Eddleman 215.

4 i-at numerous nuclear sites throughout the country and that has previously been approved by the NRC; and the assumptions incor-porated in the Harris ETE are consistent with those in HMM's other NRC approved analyses. As explained above, the assump-tion that non-auto-owning households would evacuate at the rate of one vehicle per household was employed as a practical means of simulating the evacuation traffic which would be generated in the provision of transportation assistance (by friends or family, or emergency response personnel) for non-auto-owning households. For the reasons explained herein, the assumption is fully justified and results in realistic estimates of the evacuation times for the Harris EPZ. The assumption is not a

" conservatism" that results in an overestimate of evacuation times.

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~ Robert D. Klimm Subscribed and sworn to before me this /17" day of January, 1985. ,, i i

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ROBERT 0. KLIMM

', Education * ,.

M.S. Civil Engineering (Transportation), Northeastern University, 1979 8.5. Civil Engineering, worcester Polytechnic Institute, 1975 Summary of Excerience- ~

Mr. Klimm spe'cializes in transporta tion engineering and emergency prepareccess/ evacuation planning. He has served as Project Manager or Technical Advisor on most of the evacuation time estima te analyses concucted by HMM. He also has been responsible for numerous emergency preparedness tasks for nuclear power plants including: the development of school facility evacuatior plans and procecures; the development of evacuation and population data for CRAC2 and CRACIT consequence moceling; and the develocment of evacustion routings and time estimates for special facilities.

Mr. Klimm was involved in the system development of the NETV AC evacuation simulaticn model, which has been used at 20 nuclear power plant sites througncut the country. He has provided training to groups that have been licensed to use the NETVAC

[ mocel, anc was responsible for concucting an Evacuation Time Estimate of New Jersey.

Workshop for Public Service Electric and Gas Ccmpany Professional Excerience

. 1980 - HMM Associates. Mr. Klimm serves as Project Present Manager and/or Principal Engineer for projects involving emergency preparecness planning anc emergency evacuatien. Recent experience incluces the follcwing:

o Principal Engineer for the development oc evacuation time estimates for the Suscuenanna Steam Electric Statien (Luzerne County,

. Pennsylvania, 1981).

o Project Manager for the prepara tion of supplemental evacuation time estimates for the Micland Nuclear Power Plant (Midlanc, Michigan,1983),

s o Project Manager for the development of evacuatien time estimates fo r t h e O . C . C c c'<

Nuclear Plant (Serrien County, Michigan, 1964).

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, ROSERT 0. XLIMM Page 2

'. o Project Manager for the development of an Evacuation Traf fic Manactment Plan for the

' Micland Nuclear Power Plant Plume Exposure EPZ (Miciana, Michigan, 1983).

o Principal Engineer for the preparation of e evacuation time estimates for the Shearon Harris Nuclear Power Plant (Wake County, North Carclina, 1983).

o Project Manager for the develocmint of an .

Evacuation Traf fic Management Plan for the primary Plymouth S tation Evacuation Relocation Center (Hanover, Massachusetts, 1983). '

o Principal Engineer for the development of populaticn ano evacua ticn da ta for CRACIT raciologic'al consecuence moceling within the,

' Seatreck Statien EPZ (Seabrook, New F Hampshire, 1983).

. o Project Manager for the development of an

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Evacuatien Traf fic Management Plan for the Seabrook Sta tion Plume Exposure EPZ, (Seabrcck, N ew H amp sni.re , 1962 ) .

o Project Manager for the preparation of evacuaticn time estimates for the Grand Gulf

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Nuclear Station (Claircorne County,

. Mississippi, 1981).

1977-1980 Fay, Spof ford & Therncike, Inc. Transporta ticn Engineer.. Respcnsible for traf fic operations analyses; traf fic centrol cesign, sp e cifica tien s anc cost estimates; transpo rta ticn envircnmental

(

l impact analyses; highway safety analyses; truck circula tien s tudies, anc traffic circulaticn

, plans for private and public developments.

1975-1977 C$ntral Massachusetts Regional Planning Commissicn. Transporta tion Engineer / Planner.

Rescensible for transporta ticn corricor planning stucies, transportation systens management, l traffic operaticns analyses, anc ccorcinaticn of the re plan. gicnal transacrtation air quality contrel

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ROGERT D. XLIMM

, pag, 3

~

Other Professional Data

~ Affiliations: Transportation Research Board:

Acacemy of Sciences National '

Institute of Transporta tion Engineers American Society of Civil Engineers Boston Society of Civil Engineers Papers /

Publica tions : . o Klimm,'R., " Comparison of Optional Cycle Lengths for an Urban Arterial Signal System using Maximum Sancwidth and Minimum - -

Vehicle Delay Criteria," Northeastern University, 1979 f

, *o Klimm, R., " Fringe Parking and Intermocal Transporta CMRPC, 1976 tion Sys tem--Feasibility S tudy,"

o Klimm, R., She f fi, Y., Mahnassani, P owell, W. , NETVAC2 USER H.,

MANUAL," HMM A s so cia t e s , 19 62. p r'.-

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