ML20112K077

Affidavit of Rd Klimm Re Contention EPJ-4(d).Attempt of Parents to Pick Children Up at School Would Not Significantly Affect Evacuation Times Provided in Evacuation Time Estimates

ML20112K077
Person / Time
Site:	Harris
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: ML20112J839 ML20112J852 ML20112J864 ML20112J867 ML20112J876 ML20112J883 ML20112J890 ML20112J898 ML20112J904 ML20112J913 ML20112J928 ML20112J936 ML20112J952 ML20112J959 ML20112J966 ML20112J976 ML20112J980 ML20112J999 ML20112K015 ML20112K038 ML20112K042 ML20112K046 ML20112K054 ML20112K067 ML20112K077 ML20112K080 ML20112K082 ML20112K094 ML20112K100 ML20112K105 ML20112K116 ML20112K118
References
OL, NUDOCS 8501180464
Download: ML20112K077 (7)

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Januaryi;1,4,, 1985 UNITED STATES OF AMERICA '65 JM 17 P1 :58 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSINd BO RD' d  !

(

4 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 EPJ-4(d)

County of Middlesex )

) ss.

Commonwealth of Massachusetts )

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

1. I am an Associate of HMM 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 5ssociates in connection with emergency planning for nucle-l l ar power plants. I.was Principal Transportation Engineer for l

l the evacuation time estimate study prepared by HMM Associates l

L for the Shearon Harris plume exposure Emergency Planning Zone

(_ (EPZ). That study is entitled " Evacuation Time Estimates for l

8501180464 850114 PDR ADOCK 05000400 Q PDR ~

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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 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 EPJ Contention 4(d).

2. The purpose of this affidavit is to explain that even if some parents should ignore the emergency public information broadcast at the time of an emergency and attempt to pick up their children at their schools, such behavior would not affect the evacuation times provided in the ETE.

3. The ETE did not assume an instantaneous evacuation of the.public following notification of an emergency. Rather, as identified in section 6 of the ETE, the methodology used in the ETE incorporated a range of preparation and mobilization times l

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(up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 15 minutes), to account for all cases, including individuals who are already at home at the time an evacuation is ordered and need little preparation time, as well as those with more extensive preparation activities -- e.g.,

leaving work and traveling home to pick up family before evacuating; returning home from shopping trips; and making in-termediate stops on the way home prior to evacuation (i.e.,

stops at gas stations, stores, etc.). Intermediate stops for some vehicles to pick up children at school could also rea-sonably be included in this time period. Thus, although the ETE did not specifically consider the possibility of parents driving to school to attempt to pick up their children, the ETE did incorporate a sufficiently broad range of prepara-tion / mobilization times so that any such activity would not af-fect the evacuation times provided in the ETE.

4. Similarly, the methodology used for the ETE inten-tionally incorporated some double counting of population and vehicle demand estimates, to more appropriately account for traffic friction which would result from vehicles making inter-mediate stops prior to evacuating, such as leaving work and stopping at home prior to evacuating or leaving recreational areas and stopping at home prior to evacuating. The inclusion of some vehicles going to schools to attempt to pick up stu-dents prior to evacuating could also fall into this category.

Accordingly, although the ETE did not specifically consider the

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possibility of some parents driving to school to attempt to pick up their children prior to evacuating, it did implicitly consider the traffic friction which would result from such be-havior. Therefore, while it is unlikely and unexpected that large numbers of parents would drive to schools to attempt to pick up students, even if some parents did travel to schools for this purpose, it would not significantly affect the evacua-tion time estimates presented in the ETE.

5. In summary, the ETE incorporated a broad range of preparation / mobilization times, and simulated the traffic fric-tion on the evacuation roadway network which would be associ-ated with preparation / mobilization activities involving pre-evacuation travel. Therefore, even if some parents should attempt to pick up their children at their schools in an emer-gency, such behavior would not significantly affect the evacua-tion times provided in the ETE.

( ,.Y h .ws -

Robert D. Klimm Sworn to and subscribed before me this llf* day of January, 1985.

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\AotarfPublic My Commission expires:

ykame!am W 'M M ROBERT D. XLIMM Educaticn N.S. Civil Engineering (Transportation), Northeastern University, 1979 B.S. Civil Engineering, Worcester Polytechnic Institute, 1975 Summary of Excerience- -

Mr. Klimm spe'cializes in transporta tion engineering and emergency preparecness/ evacuation planning. He has served as Project Manager or Technical Advisor on most of the evacuation

. time estimate analyses ccncucted by HMM. He also has been responsible for numerous emergency preparedness tasks for nuclear power plants including: the development of school facility evacuatier plans anc procedures; the development of evacuatien and populaticn data for CRAC2 and CRACIT consequence maceling; and the develocment of evacuation routings and time estimates for special facilities.

Mr. K11mm was involved in the system development of the NETVAC evacuation simulaticn model, which has been used at 20 nuclear I

power plant sites througncut the country. He has provided training to groups that have been licensed to use the NETVAC

[ mocel, and was responsible for concucting an Evacuation Time

' . Estimate Workshop for Public Service Electric and Gas Ccmpany of New Jersey.

Professicnal Excerience i

. 1980 - HMM Associates. Mr. Klimm serves as Project l Present Manager anc/or Principal Engineer for projects involving emergency preparecness planning anc emergency evacuaticn. Recent experience l

l incluces the Tc11cwing:

l o Principal Engineer for the development oc l

l

• evacuation time estimates for the Suscuenarna Steam Electric Staticn (Luzerne County,

_ Pennsylvania, 1981).

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o Project Manager for the preparation of supplemental evacuation time estimates for

- the Micland Nuclear Power Plant (Miclanc, Mic hig a n , 1983 ) .

s o Project Manager for the development of evacuaticn time estimates for the O.C. Cc:<

Nuclear Plant (Serrien County, Michigan, 1964).

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, RCEERT 0. XLI,MM Page 2 o Project Manager for the development of an Evacuation Traf fic Management Plan for the Midland Nuclear Power Plant Plume Exposure-'

EPZ (Midland, Michigan, 1983).

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

o Project Manager for the development of an ..

Evacuation Traf fic Management Plan for the -

primary Plymouth Station Evacuation Relocation Center (Hanover, Massachusetts, -

1983).

o Principal Engineer for the development of populaticn ano evacuaticn data for CRACIT I raciological consecuence moceling within the, Seabreck Staticn EPZ (Seatrock, New F Hampshire, 1983).

. o Project Manager for the develcoment of an

(

Evacuaticn Traf fic Management Plan for the

~ Seacrook Station Plume Exposure EPZ, (Seabrcck, New Hamp shire , 1982).

a o Project Manager for the preparation of ,

• evacuaticn time estimates for the Grand Gulf Nuclear Station (Clairborne County,

, Mississippi, 1981).

1977-1980 Fay, Spcf rord & Therncike, Inc. Transporta ticn Engineer.. R espcnsible for traf fic operations analyses; traffic control design, sp e cifica ticn s anc ccst estimates; transpo rta ticn envircnmenta' 1 .

impact analyses; highway safety analyses; truck l- circula tien s tudies, and tra f fic circulaticn

, plans for private and public developments.

1975-1977 be'ntral Massachusetts Regional Planning Commission.

Transporta tion Engineer / Planner.

Responsible for transportaticn corricor planning stucies, transportation systems management, traffic operations analyses, and coordinatien or the regicnal transporta tion air quality centrol

' plan.

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ROSERT D. XLIMM '

, p, , 3 Other Professional Data

• Affiliations: Transporta tion Research Board :

Acacemy of Sciences National '

Institute of Transportation Engineers American Sociaty of Civil Engineers Boston Society of Civil Engineers Papers / .o Publica tions : Klimm,'R., " Comparison of Optional Cycle Lengths for an Urban Arterial Signal System Using Maximum Banowidth and Minimum - -

Vehicle Delay Criteria," Northeastern University, 1979.

f , 'o Klimm, R., " Fringe Parking and Intermocal Transportation System--Feasibility Study,"

CMRPC, 1976.

o Klimm, R., Sheffi, Y., Mahnassani, H.,

Powell, W., NETVAC2 USER MANUAL," HMM A s so cia t e s , 19 62. ,

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