ML20112K046

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Statement of Matl Facts as to Which There Is No Genuine Issue Re Wilson Contention 12(b)(3) & Contention EPJ-2
ML20112K046
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 01/14/1985
From: Ridgway D
CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20112J843 List:
References
OL, NUDOCS 8501180457
Download: ML20112K046 (8)
v • d • e


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January 14, 1985 5

9 UNITED STATES OF AMERICA 0%3ETED NUCLEAR REGULATORY COMMISSION

'#5 BEFORE THE ATOMIC SAFETY AND LICENSI Bf JJ P1 :59

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In the Matter of )

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CAROLINA POWER & LIGHT COMPANY )

and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Power )

Plant) )

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON WILSON 12(b)(3) AND EPJ-2 Pursuant to 10 C.F.R. 5 2.749(a), Applicants state, in support of their Motion for Summary Disposition of Wilson 12(b)(3) and EPJ-2, that there is no genuine issue to be heard with respect to the following material facts:

1. For purposes of the Evacuation Time-Estimate, Applicants estimated-that 410 households within the EPZ

'do not own a vehicle. This estimate was based upon the best data available at the time. Twine Affidavit, 13.

2. Since the estimates were prepared for the ETE, more complete U.S. Census data has become available, indi-cating a total of 655 households within the EPZ which do not own a vehicle. A more precise estimate of people

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without transportation specific to the EPZ was prepared, y

utilizing this detailed 1980 U.S. Census data. Twine Affidavit, 114, 6.

3. This more precise estimate includes, a) persons

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who are members of households which do not own.a vehicle, and, b) persons in households in which the vehicle is not at home. This estimate was prepared for three times of day: (1) the evening (non-working) and weekend hours (roughly 6 p.m. to 8 a.m. on weekdays); (2) the hours of 8 a.m. to approximately 3 p.m. during weekdays, when the entire working and school populations are away from home; and (3) the hours of 3 p.m. to 6 p.m. during weekdays, when the working population is away from home, but the school population is at home. It is estimated that be-tween 318 and 555 persons would need official transpor-tation assistance in an emergency, depending upon the time of day. Twine Affidavit, 114-8.

4. For planning purposes, it_was assumed that a maximum of 20 percent of those persons without access to automobiles would need transportation assistance from.ener-gency response officials,.since past emergency evacuation
experience indicates that no more than 20 percent of the population which does not own vehicles would' remain with-out transportation in an emergency. -The others (80 percent or'more) would accept offers of transportation from friends, neighbors, or relatives, or.would be picked up by working O

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members of their households. Twine Affidavit, 116, 7. I

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5. Dr. Wilson's suggested methodology to estimate the number of persons needing transportation assistance is extremely conservative. Such a methodology would normally be used to provide a range of estimates includ-ing a lower as well as an upper limit, thcugh Dr. Wilson discusses only the upper limit. Twine Affidavit, 19.
6. Applying Dr. Wilson's conservative methodology to the calculations outlined in the Twine Affidavit would yield a range of between 322 and 788 persons in the EPZ needing official transportation assistance during the hours of 3 p.m. and 6 p.m. (assuming that 80% of persons without access to their own private transportation would evacuate with friends and family). Sufficient resources exist to accommodate such a range. Twine Affidavit, 19.
7. To verify the capability of EPZ residents to evac-uate via private vehicles, U.S. Census data was reviewed to determine the number of vehicles remaining inside the EPZ at various times of the day. These statistics demon-strate that evacuation by private vehicle would not pose a problem. Even assuming that the entire population of the EPZ evacuated by private vehicle, and only 50 percent of the available private vehicles were used, vehicle occu-pancy rates would nevertheless be only 3 to 3.4 persons per vehicle. Twine' Affidavit, 110.
8. Based on three decades of research and investi-

.v gation, the record is clear with respect to the response of members of the public at risk in times of emergency.

The principles of public response -- well established through decades of research and investigation -- would be applicable in the event of an emergency at a nuclear facility such as the Harris plant. Mileti Affidavit, 12.

9. Emergencies transform communities behaviorally at both the group and individual levels. People abandon personal forms of identification and personal interests, and they identify with the entire human collective.

Mileti Affidavit, 113, 4.

10. Historically, in emergencies where evacuation has been recommended, people without transportation have obtained evacuation transportation from friends, neigh-bors and relatives. This is the case because of the natural tendency of people in emergencies to check on the safety of others, to become altruistic and offer help to those who need it, and to form groups for evacuation.

Therefore, in the event of an emergency at Harris nec-essitating evacuation, regardless of the reason for lack

! of personal private transportation, the vast majority of evacuees without their own transportation would receive l

transportation from other evacuees. Mileti Affidavit, 115, 6.

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11. The number of persons who would need official V

transportation assistance in an emergency can be expected to be well below the number of persons without transpor-tation in non-emergency times. The assumption employed for the Harris EPZ for planning purposes (i.e., that approximately 80% of those without personal private trans-portation would receive transportation from other evacuees) is a reasonable one, based on principles of behavior established through the study of emergencies. Mileti

. Affidavit, 16.

12. Pre-emergency public education materials may acquaint members of the public generally with the way in which official transportation assistance would be pro-vided in an emergency. However, the specific details, such as the locations of pickup points need be included only in the emergency information broadcast to the public at the time of the evacuation. Mileti Affidavit, 16.
13. The emergency public information brochure will include a special needs response card, to elicit infor-mation identifying persons who may need transportation assistance in an emergency. The completed response cards will be analyzed by the four county emergency management 1

agencies, and will serve as a basis for the counties' listings of persons needing official emergency transpor-tation assistance. The list will be expanded (as appro-priate) through meetings with social service and public

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health and safety agencies in each of the four counties.

Pugh Affidavit, 113, 5, 8, 11, 14.

14. Detailed plans for official transportation assistance for Harris EPZ residents who may need such assistance are being developed by the Emergency Manage-ment Offices of Chatham, Harnett, Lee, and Wake Counties.

Pugh Affidavit, 14.

15. In all four counties, all public information will encourage the sharing of rides with persons without transportation. The brochure rer.. Ands pecple to share transportation with friends and relatives. Reminders will also be included in the EBS announcements broadcast at the time an evacuation is ordered, and in media releases disseminated to the public in an emergency. Pugh Affi-davit, 14.
16. In all four counties, an inventory of pickup points is being developed as part of the Standard operat-ing Procedures. The pickup points actually selected for use in an evacuation would depend on the area to be evacu-ated. The pickup points would be broadcast to the public in EBS announcements. No one would be more than one mile i

from a pickup point. Pugh Affidavit, 14.

l 17. In three of the counties within the EPZ, those who identify themselves in advance of an emergency as in need of official transportation assistance would -- in

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. an' emergency -- be picked up at their homes. In these

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. counties, pickup points are used only by those who need 1.

official transportation assistance but failed to iden-tify themselves prior to the emergency. In Wake County, all persons'needing transportation assistance would go to pickup points in an evacuation. Pugh Affidavit, 116, 9, 12, 15.

18. The agency resources (personnel and vehicles) available to provide transportation assistance in an emer-gency have been identified, and evacuee. capacities have

.been calculated. Pugh Affidavit, 116-7, 9-10, 12-13, 16-18.

19. The Standard Operating Procedures now being developed for the counties of Chatham, Lee and Harnett will allocate a portion of the available resources to pick up. people on the list of persons needing official t

- transportation assistance,.and the remaining resources will be allocated to stop at pickup points. Pugh Affi-davit, 116, 9, 12.

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20. The responsible State and local emergency plan-ning officials have. determined that, in an emergency, sufficient resources (vehicles and drivers) will be avail-able to accommodate the estimated maximum number of EPZ l

residents.who may need official transportation: assistance,

e h with sufficient excess capacity to accommodate individ-uals who normally have cars (which are being repaired at the time of the emergency), and other such cases. Pugh Affidavit, 115, 7, 8, 10, 11, 13, 14, 18, 19.

Respectfully submitted,

. m Th mas A. Bakter,' PT C. (

Delissa A. Ridgway SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036

(202) 822-1000 and Richard E. Jones Dale E. Hollar CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated
January 14, 1985

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