ML20112K082

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Statement of Matl Facts as to Which There Is No Genuine Issue Re Wilson Contention 12(b)(2)
ML20112K082
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 01/14/1985
From: Gaukler P
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 8501180466
Download: ML20112K082 (5)
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Text

a O n ETED

'ssPC January 14, 1985

'F JAN 17 P159 L- ::E Jr -

UNITED STATES OF AMERICA 00CXLI o IEW G 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) )

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON WILSON 12(b)(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)(2), that there is no genuine issue to be heard with re-spect to the following material facts:

1. Carolina Power & Light Company contracted with HMM Associates to prepare an evacuation time study for the l Shearon Harris EPZ pursuant to NUREG-0654; FEMA-REP-1 (Rev. 1, November 1980). The resulting time estimates developed by HMM Associates as well as the underlying analyses and assumptions are. set forth in a formal study entitled, " Evacuation Time Es-timate for the Plume Exposure Pathway Emergency Planning Zone of the Shearon Harris Nuclear Power Plant" (October 1983).

Klimm Aff. 1 3.

i l 8501180466 850114 PDR ADOCK 05000400 G PDR

2. NUREG-0654 and NUREG-1745 set forth guidelines for the preparation of an evacuation time analysis. The guidance found in NUREG-0654 and NUREG-1745 sets forth two assumptions that may generally may be used for estimating vehicle demand for permanent residents. The first is to assume a vehicle occupan-cy factor for permanent residents evacuating the EPZ, usually in the range of two to three persons per vehicle. The second is to assume that one vehicle per vehicle-owning household will be used by permanent residents in evacuating the EPZ. Klimm Aff. 11 4, 6.
3. In estimating the vehicle demand for permanent resi-dents evacuating the Shearon Harris EPZ, HMM Associates used the assumption that one vehicle per household would be used in

, evacuating the EPZ. Klimm Aff. 1 6.

4. HMM Associates has used the assumption of one vehicle per household in the majority of the more than 20 evacuation i

time analyses that it has performed for nuclear power plants throughout the country. All of these studies, except several currently in the review process, have been reviewed and found acceptable by the NRC. Klimm Aff. 1 7.

5. The use of one vehicle per household produces a rea-l-

sonable vehicle demand estimate consistent with both federal l guidance and documented public emergency response phenomena.

. Klimm Aff. 11 6-7; Mileti Aff. 11 2-6.

i 6. The average population of permanent households within

! the Shearon Harris EPZ is approximately 2.7 persons per

(

household. Therefore, the vehicle demand estimate of one vehi-ele per permanent household equates to a vehicle occupancy fac-tor of approximately 2.7 persons per vehicle, which is in the range of that considered reasonable under NUREG-0654. Klimm Aff. 1 9.

7. A clear conclusion of extensive sociological research on public emergency response phenomena is that emergencies transform human behavior at both the group and individual lev-els. People generally respond to emergency situations as a group, placing as their first priority the health and safety of the collective community, including the family, which priority supersedes the value normally placed on material objects in non-emergency times. As a result, in times of an emergency, families will in all likelihood seek to unite, absent sound public emergency information to the contrary, and to remain united rather than to separate for the purpose of protecting physical property. Mileti Aff. 11 2-5.
8. These general principles of public response to emergencies -- well established through decades of research and investication -- would be applicable in the event of an emer-gency at the Shearon Harris plant. Mileti Aff. 11 2, 6-7.
9. It is highly unlikely (although possible in a few cases) that families would separate one member from another into different cars in a health and safety threatening situa-tion in order to move two cars out of the Shearon Harris EPZ rather than one. Additionally, separated families with two or

more useable evacuation vehicles would generally unite in order to evacuate as a unit in one vehicle. Mileti Aff. 1 6.

10. The Intervenor Richard Wilson has stated that his con-cern expressed in Contention 12(b)(2) would be met if it were investigated and demonstrated (even if not e.dopted as the basis for planning) how the evacuation times would vary if the as-l sumption of one vehicle per household were altered to 1.5 or 1.75 vehicles per household. See " Applicants Emergency Plan-ning Interrogatories and Request For Production of Documents To Intervenor Richard Wilson," Interrogatory 12(b)(2)-2 and 12(b)(2)-3 (October 5, 1984) and " Response by Richard Wilson To

. Applicants' Interrogatories on Interrogatories on EPJ-5 and Wilson 12(b)(2) and Wilson 12(b)(3)," pages 1-2 (October 25,

1984.)
11. The Applicants have computed the evacuation time esti-mates that would result from an assumption of 1.5 and 1.75 ve-hicles per household for evacuating the Shearon Harris EPZ and have compared those times with the evacuation time estimates

, resulting from en assumption of one vehicle per household.

i Klimm Aff. 1 12.

i

m

12. The evacuation times resulting from the assumptions of 1.5 and 1.75 vehicles per household are unreasonably conserva-tive and should not therefore be used as the planning basis for determining the protective actions to be undertaken in the event of an emergency. Klimm Aff. 11 11-12.

Respectfully submitted, 61 L Y Thomas A. Baxter, P.C.'

Paul A. Gaukler 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 i

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