ML20112K105

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Affidavit of K Twine on Wilson Contention 12(b)(3) & Contention EPJ-2.Estimate of Number of Members of General Public within Emergency Planning Zone W/ & W/O Available Vehicles in Event of Emergency Accurate & Realistic
ML20112K105
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 01/14/1985
From: Twine K
CAROLINA POWER & LIGHT CO., EBASCO SERVICES, INC., NORTH CAROLINA MUNICIPAL POWER AGENCIES
To:
Shared Package
ML20112J843 List:
References
OL, NUDOCS 8501180472
Download: ML20112K105 (13)
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Text

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L January 14, 1985

' 1Vl3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION --

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c3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 09 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 KEVIN TWINE ON WILSON 12(b)(3) AND EPJ-2 County of Wake )

) ss.

State of North Carolina )

KEVIN P. TWINE, being duly sworn, deposes and says:

1. I am the Manager of Resources Planning at Envirosphere Company, a division of Ebasco Services, Inc. In my position, I am responsible for Envirosphere work related to demographics, land use, and offsite emergency planning. In that capacity, I have participated in offsite emergency plan-ning work at three nuclear power plants in the United States, in addition to the Shearon Harris Nuclear Power Plant. In each of these cases, I have been responsible for estimating resident and transient populations within the 10-mile plume exposure 8301100472 e50114 PDR ADOCK 05000400 0 PDR l

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y o pathway Emergency Planning Zone ("EPZ") surrounding each plant.

In two of these cases, I prepared detailed estimates of the population requiring official transportation assistance, in ad-

.dition to my involvement in other substantive offsite emergency planning work. I hold a Master of Regional Planning degree from the University of North Carolina at Chapel Hill. A cur-rent statement of my professional qualifications and experience is attached hereto. My business address is Two World Trade Center, New York, New York 10048. I have personal knowledge of the matters stated herein and believe them-to be true and cor-rect. -I make this affidavit in response to Wilson contention 12(b)(3) and EPJ~ Contention 2.

2. The purpose of this affidavit is to explain the deri-vation of the estimated number of members of the general public within the EPZ who might need official transportation assis-tance in an evacuation due to an emergency at the Harris plant.

3.. For purposes of the Evacuation Time-Estimate (ETE),

Applicants. estimated that 410 households within'the EPZ do not own a vehicle. As indicated in the ETE report-(at page 3-2),

data'from the 1980 Census of Pooulation, Advance Estimates of Social. Economic, and Housina Characteristics were used to es-timate the number of permanent residents within the EPZ who.do not own a vehicle. The Census Advance Estimates for the four EPZ counties were used to derive percentages of households not owning a vehicle. The percentages.were then applied to the EPZ h

data presented in the CP&L report Democraphic Data for the Shearon Harris Nuclear Power Plant (SHNPP) Evacuation Time Estimate Report (Revision 1, October 1983) (" Demographic Data Report"), to arrive at the estimated numer of households within the EPZ who do not own a vehicle. This estimate was based upon the best data available at the time.

4. Since those estimates were prepared for the ETE, more complete U.S. Census data has become available. Therefore, a more precise estimate of people without transportation specific 1

to the EPZ was prepared, utilizing detailed 1980 U.S. Census data for enumeration districts within the EPZ, and the Demographic Data Report. This estimate includes, a) persons 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 refined estimate is presented by evacuation zone in Table 1 below.

I

'on TABLE 1 ESTIMATED NUMBER OF PERSONS NEEDING OFFICIAL TRANSPORTATION ASSISTANCE, BY TIME OF DAY Zone 1/ Evening Day Time (6 p.m. - 8 a.m.) (8 a.m. - 3 p.m.) (3 p.m. - 6 p.m.)

B- 30 19 31 C 2 1 3 D 1 2 4 E 78 84 156 F 37 35 64 G 131 105 172 Wake County 279 246 430 Total H (Harnett County) 16 18 30 I 3 3 6 J 6 13 22 Lee County Total 9 16 28 K 15 12 19 L 11 7 12 M 14 13 25

'N 9 6 11 Chatham County 49 38 67 Total Total - EPZ 353 318 555

5. The estimated number of people without transportation was prepared for three times of day (as shown'on Table 1):

1/ No members of the public reside'in Zone A.

0

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 pop-ulation is at home.
6. To estimate the veukend and evening population, the number of households without automobiles within the EPZ was taken (a total of 655 households, from the Census) and then multiplied by the number of persons per household (as derived from Census data, and which varied from area to area within the EPZ). For planning purposes, it was then assumed that a maxi-mum of 20 percent of those persons would need transportation assistance from emergency response officials, since past emer-gency evacuation experience (e.o., the December 11, 1982 evacu-ation of 16,000 people in and around Hahnville, Louisiana, due to a toxic chemical accident at a Union Carbide facility) indi-cates that no more than 20 percent of the population which does not own vehicles would remain without transportation in an emergency. The others (80 percent or more) would accept offers of transportation from friends, neighbors, or relatives.
7. To estimate the population without transportation in the EPZ between the hours of 8 a.m. and 3 p.m., the total resi-dent population was adjusted downward to account for school I

o students and people who are at work. Both of thep3 numbers were derived from detailed 1980 Census data. The number of households without cars during the day was then calculated by deducting the vehicles used for transportation to work (from the Census data), taking into account people who walk to work and those who use car pools (also from the Census data). The average number of persons per household durino the day was then calculated (this is somewhat lower than the average persons per household when everyone is assumed to be home), and applied to the number of households without cars during the day, to derive the number of persons without automobiles during the day. As discussed above, a maximum of 20 percent of these persons would need transportation assistance from emergency response offi-cials. The remaining 80 percent or more would receive rides from friends and relatives, or would be picked up by working members of their households. (Residents who work outside the EPZ would be permitted to re-enter the EPZ for this purpose.)

8. To estimate the population without transportation in the EPZ between the hours of 3 p.m. to 6 p.m., the same method-ology as for the hours of 8 a.m. to 3 p.m. was used except that school students were assumed to be at home. Other factors --

such as the number of households without cars during the day, and the number of people at work -- remained the same.

9. Dr. Wilson, in his response to Applicants' interroga-tories on Wilson 12(b)(3), has suggested the use of an

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extremely conservative methodology to estimate the number of 1 persons needing transportation assistance. It should be noted that Dr. Wilson's suggested methodology is normally used to provide a range of estimates including a lower as well as an upper limit. (Dr. Wilson has discussed only the upper limit).

Use of Dr. Wilson's conservative methodology, applied to the calculations outlined in paragraphs 5 through 8 above,2/ would yield, for example, a range of 322 to 788 persons in the EPZ needing official transportation assistance between the hours of 3 p.m. to 6 p.m. Based on my review of the " Affidavit of Jesse T. Pugh, III on Wilson 12(b)(3) and EPJ-2," I have determined that sufficient transportation resources exist to accommodate such a range.

10. To verify the capability of EPZ residents to evacuate via private vehicles, U.S. Census data was reviewed to deter-mine the number of vehicles remaining inside the EPZ at various times of the day. During the evening hours, the approximately 19,832 persons in the EPZ have access to approximately 13,396 vehicles. During the day, the 12,028 people (including school children) estimated to remain in the EPZ have access to approx-imately 6,876 vehicles. These statistics demonstrate that evacuation by private vehicle would not pose a problem.

2/ Assuming that 80% of persons without access to their own private transportation would evacuate with friends and relatives.

e o Indeed, assuming that the entire population of the EPZ evacu-ated by private vehicle, and only 50 percent of the available private vehicles were used, vehicle occupancy rates would nev-ertheless be only 3 to 3.4 persons per vehicle.

11. In summary, the ETE included an estimate of 410 households within the EPZ which do not own a vehicle. Because complete U.S. Census data has become available since the prepa-ration of the ETE, Applicants have prepared a more precise es-timate of people within the EPZ vho do not have access to pri-vate transportation. This estimate considered the fact that most people in the EPZ without access to their own private ve-hicles would accept offers of transportation from friends, neighbors or relatives. There is an ample number of privately owned vehicles within the EPZ to provide such private transpor-tation. After allowing for such private transportation of evacuees from the EPZ, it is estimated that between 318 and 555 persons would remain who would need official transportation as-sistance, depending upon the time of day. This estimate takes into account not only households which do not own vehicles, but also situations where the family vehicle is with a person at work and away from home. It also considers school students, who are home for a part of the day when the family vehicle may i

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not be . In addition, it considers nighttime and weekend sca-narios. Using the best currently available data, this in the most accurate and realistic estir. ate that can he developed for emergency planning purposes.

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Sworn to and subscribed before e.e this I day of January, 1985.

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Page 1 of 4 KEVIN P TWINE Manager - Resources Planning SIMeRY OF EXPERIENCE (Since 1967)

Total Experience - Seventeen years experience including supervision and direction of nunerous projects involving demographic, land use, and socioeconomic inpact and environmental assessment analyses.

Professional Affiliations - American Society of Photogrammetry .

Education - oftP, University of North Carolina,1967 - Regional Planning BA, Wesleyan University, 1965 - History REPRESENTATIVE ENVIROPHERE PROICT EXPERIENCE (Since 1974)

Mr. Twine is currently supervising the technical program to assist Carolina Power & Light Co. In their role to develop the offsite emergency plan in support of the Shearon Harris Nuclear Power Plant. This program has involved close interaction with officials of the State of North Carolina, four counties, and nunerous local agencies to define and resolve problem areas in the emergency plan. Included in this project is the provision of technical assistance to CP&L and their legal counsel to support, with expert analysis and judgement, the ASLB hearing process.

Manager - Resources Planning Responsibilities include management of Envirosphere Staff involved in land use, socioeconomic, aesthetic, and archaeological disciplines; direction of research in these fields; management of projects relating to resources planning; management of Envirosphere's Land Resources Analysis System (LRAS) for satellite imagery analysis and computerized geographic studies; expert testimony before regulatory bodies.

Projects include:

Carolina Power & Light Co. Shearon Harris Nuclear Power Plant. Served as

! technical project manager for licensing support concerning off-site i emergency planning. Work involved extensive contacts with local and l state government officials, utility officials, and legal counsel, as well as demographic analyses and planning for shelter and evacuation.

Battelle Memorial Institute; Salt Repository Program. Canyonlands National Park Impact Report. Directed preparation of analysis of aesthetic, cultural resources, recreational and socioeconomic inoacts of proposed high-level radioactive waste repository upon Canyonlands National Park.

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. Page 2 of 4 KEVIN P TWINE EPRESENTATIVE ENVIROSPFERE PROJECT EXPERIENCE (Continued)

TRC Environmental Consultants, Inc; Data Base for Air Quality Materials

Damage Study. Gathered land use, demographic, and air quality data and incorporated it into a coguterized data base for use in an air quality materials damage study. Data base was organized in two formats
9,000 1-km square grid cells; and 1200 census tracts. Study area was Southern l California Air Basin (Los Angeles area).

Kansas Gas and Electric Company (KG&E); Wolf Creek Nuclear Generating Station. Directed a 3 person field team in a four month comprehensive - .

offsite emergency planning effort for Coffey County, Kansas (location of Wolf Creek Nuclear Plant) and the State of Kansas. Functioned as part of KG&E staff. Prepared witnesses and developed testimony for hearings.

Reviewed, revised and prepared offsite emergency plans and implementing procedures. Interfaced closely with county and state officials.

Louisiana Power & Light Cog any; Waterford 3 Nuclear Generating Station. ,

Directed the preparation of Evacuation Time Estimate, 1980 and 1982; testified in defense of findings at hearings of Atomic Safety and Licensing Board, May, 1982; directed preparation of detailed analysis of large evacuation which took place in Waterford 3 vicinity as a result of an. industrial accident on December 11, 1982.

Consolidated Edison Company of New York; Site Selection Study for Coal Burning Waste Disposal Facility. Directed preparation of demographic, 4 land use, and aesthetic elements of site selection study; performed analysis of satellite imagery on LRAS for input to site selection procedure.

Pennsylvania Power & Light Cog any; Pumped Storage Site Selection Study.

l Directed land use, socioeconomic, aesthetic and archaeological studies and was responsible for assisting a Public Advisory Comittee (PAC) in reaching a decision.

lNew York State Electric & Gas Corp.; Somerset Station Unit No. 1 LLicensing. Directed aesthetic impact studies; estimates of construction worker mobilization; landscape architecture; recreational multiple use plan.

Public Power Corporation of Greece; First Nuclear Power Station. . Site selection studies in southern two-thirds of Greece, including development and analysis of criteria concerning demographic, land use, socioeconomic and aesthetic factors.

Florida Power & Light Com any; St. Lucie Unit 2 Nuclear Generating Station. Directed the preparation of demographic, land use, cultural and aesthetic analyses for the environmental report and safety analysis; 3

testified at ACRS hearings, Oct.1981.

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t Page 3 of 4 KEVIN P TWINE REPRESENTATIVE ENVIROSPtERE PROJECT EXPERIENCE (Continued)

Louisiana Power & Light Company; Waterford Unit 3 Nuclear Generating Station. Directed the preparation of a survey of construction and operational work forces to determine socioeconomic inpacts; performed land use and demographic studies for environmental report and safety analysis.

Directed the gathering and presentation of detailed agricultural information within 50 miles of the St. Lucie 2 and Waterford 3 Nuclear ,

Power Stations.

Directed land use and socioeconomic studies for four synthetic fuels plants in central and south-central areas of U.S.

Analyzed land use and industrial development implications of a major coal conversion project in New York metropolitan area.

Served as project manager for a review of decontamination and deconmissioning methods for radioactive facilities at Oak Ridge National Laboratories; was project manager of an environmental report aid engineering plan for removal of radioactive wastes from the site of the former Kellex laboratory in Jersey City, NJ.

Regional Planner (4 years)

Areas of responsibility included demographic modeling and projections; use of remote sensing techniques land use surveys and analyses; regional economic analysis; socioeconomic impact assessments for large projects; land use surveys and analyses; public services assessment; and comunity planning.

Projects included:

Developed demographic models for projecting population by annular sector within five and fifty miles of the Waterford Unit 3 Nuclear Generating Station for Louisiana Power & Light Conpany.

Developed mathematical models to project construction worker influxes and location patterns at major energy projects, enabling the assessment of socioeconomic inpacts on a town-by-town basis, for the Lake Erie Generating Station, Dmkirk, New York; Niagara Mohawk Power Corporation.

Defended these models at New York Public Service Commission hearings, November 1976 - March 1977.

Directed land use and socio-economic analyses for site-selection studies for large coal-fired generating facilities in British Collabia, Canada, and Washington State.

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  • Page 4 of.4 KEVIN P TWINE PRIOR EXPERIErCE (8 years) (Cont'd)

Directed the preparation of land use and socio-economic assessments for the Philippine Nuclear Power Plant Unit No. 1, Philippine National Power Corporation. Prepared the land usq and socio-economic elements of the environmental report for the Killen Steam Electric Station, Adams County, Ohio, for the Dayton Power and Light Company.

, PRIOR EXPERIENCE (8 years)

- The Fantus Conpany-Consultant (1 year) -

Florida Land Company-Land Planner (2 years)

- Planning Department, City of Portland, Maine-Community Development Coordinator (3 years)

- Gassner, Nathan, Browne - Architects / Planners; Project Manager (1 year)

- Memphis and Shelby County Plaming Commission; Associate Planner (1 year)

PUBLICATIONS AND PAPERS Twine, K P 1983. The Use of Landsat as a Cost-Effective Data Resource:

Land Cover Analysis of Multiple Sites (a Case Study). National Conference on Energy Resource Management, San Francisco, CA, August.

Twire, K P 1982. Using Satellite Imagery and Geographic Information Systems. Presented at Seminar on Environmental Impact Assessment: Its Importance, Methods, and Applications, Santo Domingo, Dominican Republic, October.

Twine, K P 1982. Impact Assessment Methods: Sociocultural Studies.

Presented at Sminar on Environmental Impact Assessment. Its Importance, Methods, and Applications, Santo Domingo, Dominican Republic, October.

Twire, K P, and P H Astor 1979. Ceographic Information Systems In JRiit-Of-Way Management: The Status And uses Of Current Computer Technology. Presented at the Second Symposium on Environmental Concerns in Rights-of-Way Management, Ann Arbor, Michigan, October.

Twire, K P 1978. How tc pick your plant site. Parts I and II, disc.ussing models for projecting socioeconomic impacts of construction workers at a large electric generating facility, in "1he Management Rept:rt," Electrical World, August and September.

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