ML20148M557
| ML20148M557 | |
| Person / Time | |
|---|---|
| Site: | Green County  |
| Issue date: | 11/07/1978 |
| From: | Martin J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20148M544 | List: |
| References | |
| NUDOCS 7811220065 | |
| Download: ML20148M557 (12) | |
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9 Prepared Testimony of James A. Martin, Jr. on behalf of the U. S. Nuclear Regulatory Commission In the Matter of _ Power Authority of the State of New York (Greene County Nuclear Power Plant) i Q. Please state your name and' address. . A. My name is James A. Martin, Jr. My business address is: l Accident Analysis Branch Division of Site Safety and Environmental Analysis Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, n. C. 20555 Q. Have you prepared a statement of your professional qualifications? A. Yes. A copy is attached as Exhibit 1. Q. Have you been responsible for the review of emergency plans other than the plans for Greene County? A. Yes. Q. Would you identify several of these. A. I have been responsible for the review of the prelimina'ry plans for coping with emer sencies for construction pennits on Skagit, New England, Shearon Harris, and Yellow Creek. I have also been responsible for the review of the energency plans for operating licenses on Hatch, Salem, Suntner, and Zimmer among others. 781122 006( t
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, Q. Are hou familiar with the Connission's requirements for emergency plans at the construction permit stage of review and at the operating license stage of review? -;
A. Yes. Q. What are the requirements for emergency plans as you understand , them? l A. The Commission's requirements for emergency plans are set forth in the 10 CFR Section 50.34 in the section entitled " Contents of applicationst technical information." 10 CFR 550.34(a)(10) requires that the applicant include in its preliminary safety analysis report (PSAR) at the construction l permit stage:
"A discussion of the applicant's preliminary plans for coping with emergencies. . Appendix E sets forth items which shall be included in these plans."
10 CFR 650.34(b)(6) requires that the applicant include in its final safety-analysis report (FSAR) at the operating license ~ stage:
"The following information concerning facility operation:
(v) Plans for coping with emergencies which shall include the items specified in Appendix E." Q. Is there a difference between the requirements at the PSAR stage and those at the FSAR stage? 4 , A. Yes. The requirements at the PSAR stage are quite different from those at the FSAR stage. At the FSAR stage the applicant must provide a complete emergency plan. Because construction takes many years to complete and because no emergency plan would be
i needed until after operation commences, at the PSAR stage only preliminary plans are required and ~I determine whether the , preliminary emergency plans are compatible with the facility design, site layout and site location. The items which the applicant must describe in the PSAR are specifically set forth in ,' the introductory paragraph and paragraphs A through G of Section II of Appendix E to 10 CFR Part 50. A copy of Appendix E is ) attached as Exhibit- 2. Q. Would you describe, in your own words, how you applied the statement in the first paragraph of Part II of Appendix E that reads "The Pre-liminary Safety Analysis Report shall contain sufficient information to assure the compatibility of proposed emergency plans with facility design features, site layout, and site location witn respect to such considerations as access routes, surrounding population distributions, and land use." A. The principal application of this statement involves the review of time-dose-distance plots which are requested of applicants in Chapter 13.3 of Regulatory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power plants - LWR Edition." An example of such plots provided by the applicant are attached as Exhibit 3. These plots are based upon the same accidental re-lease of radioactive materials postulated to assess confonnance to siting dose criteria, the character and magnitude of which are dependent upon facility de. sign features. They also reflect site location through the meteorological dispersion characteristics used to estimate potential exposures. The principal purpose of
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. these plots is to provide a basis for scoping the geographical area _
surrounding a plant for which protective action considerations might be considered warranted. Site layout enters this review i predominantly through the specifications of exclusion area and the , exclusion boundary distance feature so that the reviewer can clearly distinguish between onsite and offsite areas. l Road network and population distribution information are used to estimate evacuation times that might be expected. The primary objective of these estimates is to identify areas where greater attention to planning could provide substantial benefits in mitigating exposures. 2 The upshot of these analyses can be stated very simply: I woul d want more definitive plans laid for the public in those areas for l 1 which U.S. Environmental Protection Agency plume exposure protective action guides (PAG's) of 5 rem whole body and 25 rem thyroid could be reached within about 8 hours after the initiation of the noted accident. Perusal of the applicant's time-dose-distance curves shows that such doses would result only within the low population zone (LPZ), to a distance of about 1,5 miles (i.e., one mile less ; than the low population zone outer radius). 1 1 Q. Did you analyze road network and population data within the LPZ? l
l 1 A. Yes. I calculated times that might be required to effect an evacuation of the LPZ, using a model developed by Dr. R.W. Houston, l Chief, Accident Analysis Branch, USNRC. This required road net- l l work and population data as input data to the model . ! l i Q. What was your basis for your estimates of times required to effect an evacuation of the LPZ? A. Historical record for the most part. The U.S. EPA analyzed data obtained from some 500 evacuations that occurred in the U.S. from 1960 to about 1974 (about one a week). Dr. R.W. Houston, Chief, AAB, USNRC, developed a semi-empirical correlation of this data, l l coupling it to road and traffic capacity information. The resulting mathematical expression and the results for the Greene County site 1 I ] environs were provided on October 16, 1978 to the board in response to 1 k intervenors questions HS-9 (a copy of which is attached as Exhibit 4). Q. What were the results of your calculations? A. My results are documented in the Safety Evaluation Report at ; Ch.13.3 and in response to interrogatory HS-9, attached as Exhibit 4. In essence, calculated evacuation times for the LPZ ranged from 3 m to 4.5 hours. Q. Did you consider areas beyond the low population zone? i l A. Yes, out to five miles, i.e., 2.5 miles beyond the LPZ. Y ., -
1 Q. And what were those results? {
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A. Calculated evacuation times ranged between about 4 and 6 hours, for the five mile radii. Q. What doses would the public receive during these times? A. As illustrated in the time-dose-distance plots, doses would generally be below EPA PAG's even in the absence of protective actions for the most serious accident postulated for the review. l Without protective actions doses could be in excess of U.S. EPA PAG's within a radious of about 1.5 miles. Q. Do you consider the calculated evacuation times to be definitive? A. No, they are more of a scoping nature. They can, I believe, provide some insight into where problem areas may be. Q. Did your analyses identify any areas of special concern? i A. The only situations I identified as of special concern in my SER were the areas to the south and east of the site for which the i calculations indicated that it could take the longest times to effect an evacuation of the LPZ. Q. You did not consider the accesses to Route 9W by adjacent businesses and the village of Cementon of special concern?
A. Not particularly. Early warning would be the key here and there is no obvious impediment to such, quite the contrary in fact. People come and go from these places routinely; they would all be in a limited area so spreads in warning times would be relatively , short.' I would contrast this to the area to the east of the proposed site where homes are spread out along numerous roads. Here the roads are plentiful, but the spread in the warning times could very well dominate the elapsed time to effect an evacuation. In fact, for the case of evacuation of the LPZ, it was for areas to the east that the longest evacuation times were calculated. Q. What was the gist of your conclusions based on these analyses of facility design features, land use, populations and road networks in the area? A. That there is a reasonable probability that protective measures could be taken on behalf of the public in the area in the event of a serious accident and that there were no_ impediments to the development of emergency plans for the area. Q. Describe how you implemented the Commission requirements of 10 CFR 950, Appendix E, Part II, paragraph A in your review of the preliminary plans for coping with emergencies presented in PASNY's PSAR. A. With respect to Appendix E, Part II, paragraph A, I generally look to see if the applicant has proposed an adequate organization , for coping with emergencies. An applicant should plan to use
w. i normal plant personne1Jand chains of command. A major reorganization should not be planned in the initial stages of an emergency. The applicant should plan to use normal means of communications in an emergency, e.g., radio, telephone, plant public address systems, , and plant evacuation sirens. In my review of the Greene County application, I reviewed Section 13.3.1 of the PSAR which describes the PASHY organization for coping with emergencies. In substance, as described in the PSAR the emergency organization will consist of the operating staff at the station when the emergency occurs. The plan will be designed so the normal shift crew, under the direction of the Shift Supervisor, can fully implement the plan. The procedures
- will provide for notification by phone of other members of the PASNY emergency organization and their assumption of duties as they arrive at the plant.
In my opinion, the applicant has adequately described the organization it will use for coping with an emergency and the means for notification in the event of an emergency of persons I assigned to the. emergency organization. Q. Describe briefly how you implemented the requirements of Appendix . E, Part II, paragraph B in your review of the preliminary plans l for coping with emergencies presented in PASNY's PSAR. l l t 9 i l l e- 1
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_g_ A. With respect to Appendix E, Part II, paragraph B, I require that , the principal State and local agencies for radiological matters be identified. I look for a statement by the applicant that contact has actually been made by the utility with the principal State .< agency with respect to emergency planning. I do not expect the l applicant to provide details of its preliminary contacts with State and local agencies at the PSAR stage because of the length of time that must elapse before operation will commence. Instead, I look for an awareness that during the intervening period the necessary arrange-ments must be made. Section 13.3.2 of the PSAR describes the contacts and arrangements made or to be made with local, State and Federal governmental agencies l with responsibility for coping with emergencies, and identifies the principal agencies which might participate in an emergency situation. The New York State Department of Health is identified as the principal responsible agency for public health aspects of ionizing radiation. In response to Staff Question 432.2 PASNY states that it has established lines of communication with public safety officials in Greene, Ulster and Columbia counties. PASNY also identifies the Federal Interagency Radiological Assistance Plan (IRAP) at Brookhaven National Laboratory, Long Island, N. Y. In my opinion PASNY has made sufficient preliminary contacts with public safety agencies for this stage of the review.
Q. Describe briefly how you implemented the requirements of Appendix E, Part II, paragraph C in your review of the preliminary plans -- for coping with emergencies presented in PASNY's PSAR. A. With respect to Appendix E, II.C, I look for a broad discussion of the concept of operations in an emergency, with emphasis on utility--
- offsite agency interactions and responsibilities. In a nut shell, the applicant would be responsible for all on-site actions, notifi-cation of off-site utility personnel and off-site agencies, and monitoring of the environment in the event of an accidental release of radioactive material. Protective actions off-site should be di$ected by cognizant government officials. The pro-tective actions I want identified at this early stage are evacuation and control of contaminated property.
Q. Do these preliminary arrangements include notification of the general public in the event protective actions are warranted? A. The Staff requested that PASNY conunit to an emergency planning objective of improving the ability to provide for the early warning and instruction of the public within the distances where U.S.E.P. A. plume exposure protective action guides might be exceeded. (Staff Question 432.1). In response to that Staff request, PASNY states that radio dispatched vehicles are planned to be used. I also note that in response to Staff Question 422.1 that the applicant discusses its role in notifying the general public through the state public health officials.' L '
Q. What is done at the FSAR stage with regard to notification of the general public? - A. Warning of the public, if ever necessary, would be effected via predetermined channels beginning with the plant operator, . thence through public safety offici'als, ultimately to the public. As required by the Commission's^ regulations in paragraphs IV.C and IV,D to Appendix E, at the FSAR stage of review (if a construction permit is granted), we will require the development of a warning fan-out system and i) criteria for mobilization of offsite forces for assessnent and ii) criteria for initiation of protective measures (i.e. , public warnings) on behalf of the public. Although assessment and pro-l tective actions could be taken on an ad hoc basis at any time, the plans will be laid so that such actions would be mandatory under predetermined conditions. These conditions will be specified in a conservative manner to assure that appropriate l actions would commence in a timely manner, but not so con-servative as to disrupt public authorities and the public un- 1 necessarily. The conditions requiring mandatory warning to public safety officials will be selected to give these officials i the earliest warning possible; where practicable, even before any release of radioactivity from the facility would be predicted, i
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- As to means of warning the public, as a matter of historical record means for early warning of the public that have been used include television, radio, telephone, sirens and lights, public address systems and " door knocking" (see EPA-520/6-74-002, Evacuation: Risks - An Evaluation, USEPA, Washington, D. C. 20460, June 1974). I see no impediment to the use of such means in the Greene County environs or development of plans for their use.
Q. Did you identify any special areas of concerns with regard to notification of the public? A. As I noted in the Safety Evaluation Report (at p.13-4), I identified areas to the south and east of the proposed plant site which, in my opinion, would be deserving of special attention as means for early warning of the public are developed by State and local agencies. Q. Why? A. It was for those areas that my analysis resulted .in the longest calculated times for evacuation of the low population zone. At the FSAR stage of review, the staff will require the identifi-cation, at least by the applicant, of special situations for which immediate notification would be warranted under specified circum-stances (e.g., adjacent major employers, Cementon, Germantown Central School). I see no impediment to identifying such special situations or to notifying such groups. 1
Q. Are you familiar with the following contention by the Shirley A. Brand and Mid-Hudson Nuclear Opponents? -
- 1. Petitioners contend that the applicant's PSAR does not contain sufficient information to satisfy the Commission's construction pennit requirements regarding the measures to be taken in the event of an emergency at the proposed facility requiring evacuation in that: -
(a) there is insufficient information regarding the means of notification to the general public. A. I am. O. Do you agree with it? A. I do not. Q. Why don't you agree with it? A. As I described previously, at the PSAR stage no detailed plans for notification of the public are required. Detailed warning systems will be devised at the FSAR stage. However, the staff has required PASNY to give additional consideration to early warning and instruction of the public and PASNY has agreed to do so. It will do so by con-sidering early warning mechanisms for the agencies responsible for the public health and safety. Q. Did PASNY supply enough information for you to reach an opinion on the adequacy of highways and public transportation to effect an evacuation? A. Yes.
Q. What is your opinion? A. In my opinion the highways and public transportation in the area are adequate to effect an evacuation. Let me give an example to illustrate why, in my opinion, qi tions of road capacities are not - substantive in thiscparticular case--and quite generally as the historical evidence indicates. The example is illustrated in the attached figure, Exhibit 5, in which is displayed road traffic capa-cities in terms of vehicles per hour per lane of traffic, versus vehicle speed. The National Safety Council rule of thumb for safe driving was used to develop the graph, i.e., a vehicle separation of one vehicle length per each ten miles per hour of speed should be used for safe driving. From the graph, even at speeds as low as ! l ten miles per hour over 1200 vehicles per hour per lane of traffic can be easily accommodated. In the EPA study referenced above, it was determined that for enforced evacuations of historical record the average number of occupants per vehicle was four and the average evacuation j speed was thirty five miles per hour. Thus, even using conservative assumptions of 10 mph travel speed and three occupants per vehicle, 3600 persons per hour per lane of traffic can be safely accommodated. With regard to the specific question, then, I can say the following: In Figure 422.1-4 of the PSAR, the applicant shows a number of roads
l available for evacuation within a radius of at least 4.5 miles _ (ut least 2 miles beyond the proposed LPZ). In Figure 2.1.3.1-7 of its PSAR, the applicant shows the projected population in the LPZ and beyond (out to 10 miles) for the year 2020 A. D. (Population in . earlier years would be generally less, e.g. , see Figure 2.1.3.1-2 in the PSAR.) From this figure, the population within 3 miles (encompassing the LPZ) would be 5569 persons in 2020 A. D. Ignoring the more likely situation that only a portion, or sector, of the area would require immediate evacuation it ever necessary, and considering, rather, the case of the complete evacuation of persons within the LPZ, very conservatively only 5569 + 3600 = 1.54 lane-hours would be needed, or less than one two lane road to effect an evacuation. in one hour or less. This would apply only to the case of the spread in warning times being less than one hour, of course. Obviously, the greater the spread in warning times and ingresses to the roads, the less significant would be i the question of road capacities. Thus, I conclude that there i is sufficient evidence in the PSAR to show that roads in the vicinity l of the proposed Greene County Station would not be an impediment to an evacuation even if all persons attempted to use the available roads simultaneously, i.e. a worst case situation. Q. Are you familiar with the contentions filed by Lehigh-Portland Cement Company, Cementon, and Shirley A. Brand and Mid-Hudson Nuclear Opponents with regard to the adequacy of public highways and transportation and specifically with regard to Route 9W? l
A. Yes. , Q. Do you agree with those contentions? A. No. , Q. Explain why you disagree with the contentions. A. In performing the evacuation analysis referenced above, I considered all of the persons within the radius of three miles from the plant including the employees of the Lehigh-Portland Cement Company and the citizens of Cementon. My conclusion that the roads in the area are adequate to effect an evacuation applies equally to Route 9W. Q. Please describe briefly how you implemented the requirements in Appendix E, Part II, Paragraph D and E with regard to the PASNY emergency plant review.
. With respect to Appendix E, Paragraphs II.D and II.E, I perform a review of the proposed health physics program to determine if provisions have been made for first aid rooms, decontamination rooms, and respiratory protection. I also look for a statement with regard to the provisions of means and methods of transportation of in.iured and contaminated individuals from the plant to a hospital.
The transportation could be provid;J by the utility itself, an ambu-lance service, or a hospital. At the FSAR stage, I would confirm that the plans provide for a trained health physicist, or equivalent, to accompany an injured individual.
The applicant described in PSAR Sections 1.3.4 and 13.3.5 plans for _ onsite and offsite first aid, medical and decontamination supplies . 1 and equipment, physicians, hospital arrangements and an ambulance service. In the PSAR the applicant states that first aid and de-contamination rooms will be provided in the employee's area of the Administration building, which will be suitably equipped. The applicant states that its plans include' provisions for services of two trained physicians in the local area, and will pursue arrangements for transportation and treatment of contaminated injured individuals at two local hospitals. PASNY also states that a plant Radiation Protection person would accompany an individual sent from the plant to a hospital. In my opinion PASNY's preliminary plans for first aid, decontamination, medical transportation, and medical services are acceptable for this stage of the review. s Q. Are you familiar with the following contention by the Shirley A. Brand and Mid-Hudson Nuclear Opponents?
"1. Petitioners contend that the Applicant's PSAR does not contain sufficient information to satisfy the Commission's construction permit requirements regarding the measures to be taken in the event of an emergency at the proposed facilility requiring evacuation in that:
(a) there is insufficient information regarding the adequacy of medical facilities for emergency treat-ment." A. I am. I 1
1 Q. Do you agree with the contention? , A. I do not. l Q. Why don't you agree with it? . A. As I summarized above, the PSAR does contain the necessary provisions for this stage of the licensing process. Q. Please describe how you implemented the requirements of Appendix E, Part II, Paragraph F in your review of the preliminary plans for coping with emergencies presented in PASNY's PSAR? A. With respect to Appendix E, II.F, I review the overall training program proposed by the applicant and the training proposed to be provided by the applicant for local support services which may be called upon to provide on-site support, e.g., firemen, ambulance services and physicians. Simple commitments to provide appropriate training suffice at this stage of our review. These : 1 commitments must be described in detail at the FSAR stage. l l The applicant described in PSAR Section 13.3.6 the training and l drills which will be given for on-site and off-site personnel which might participate in a radiation emergency. In my opinion the training described in that section is adequate to meet the requirements of Appendix E, Part II, Paragraph F. l L I L , _- _ _ _ _
e t Q. Please describe how you implemented the requirements of Appendix E, Part II, Paragraph G in your review of the preliminary plans - for coping with emergencies presented in PASNY's PSAR? A. With respect to Appendix E, Part II Paragraph G, I verify that the applicant has proposed to install such common items as emergency lighting and building fire and evacuation alarms. More importantly, I look for connitments to provide for appropriately stocked alternate emergency operation centers. ) l 1 With respect to Paragraph G , the applicant describes in PSAR ! Section 13.3.7 the evacuation and reassenbly procedures for the facil i ty. Features of the facility provided for evacuation and maintain personnel on-site (in the control room) are described ) in PSAR Sections 6. 4, 9. 4.1, 9. 5.1, 9. 5.2 and 9. 5. 3. In Section 13.37 the applicant states that it will provide two suitably equipped reassembly areas stocked with supplies for reentry. I I concluded that PASNY has described adequate features of the facility to be provided to assure the capability for plant evacuation and for facility reentry. Q. Are you familar with the following contention 8.6 by the Columbia County Survival Committee and Arthur L. Reuter?
"B.6. Applicant has not complied with the requirements of Appendix E,10 CFR 50.in that sufficient information has not been provided to assure that emergency plans can be developed particularly with respect to the surrounding population (rewritten as acceptable to the Board - see discussion of unstipulated Contention No. 6, page 7 of this Memorandum and Order)."
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5 1 l 1 A. I am. i l Q. Do you agree with the contention? 1
- A. I do not. '
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l Q. Why do you disagree with the contention? I l i
- A. The contention is directed at whether the applicant has provided sufficient information under Part II, Paragraphs A through G of l 1
Appendix E. As I described in my previous testimony, I have examined PASNY's preliminary plans for coping with emergencies
- and have concluded that they satisfy the requirements of Appendix 4 E, Part II. Therefore, I conclude that the applicant has provided l 1
sufficient information to assure that emergency plans can be developed particularly with respect to the surrounding population. I i 1 j i
EXHIBN1 (Page 1 of 2) 9
> James A. Martin, Jr.
Accident Analysis Branch Division of Site Safety and Environmental Analysis Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission PROFESSIONAL QUALIFICATIONS My job title is Senior Reactor Engineer, presently in the Accident Analysis Branch, Emergency Planning Section of the Division of Site Safety and. Environmental Analysis .NRC. During the past four years at NRC, I have been responsible for reviews of applications (Safety Analysis Reports) ! for'construgtion permits and operating licenses for nuclear power plants
-in the areas of industrial security and emergency planning. For the past two years I have concentrated on emergency planning reviews. In addition to these review matters, I have participated as a lecturer at NRC-sponsored (and other) courses on emergency planning for State and local emergency planning and response personnel. I am a member of an NRC/ EPA Task Force presently preparing additional emergency planning guidance for State and local agencies.
PrehioustomyexperienceatNRCIwasemployedforthreeyearsasa Health Physicist (job title) in the Office of Radiation Programs of the U.S. Environmental Protectico Agency, Washington, D. C. In this position , I was responsible for the development and application of models and com- l puter codes used for the assessment of individual and. population doses l due to the release of radioactive materials to the environment via atmos-pheric and aquatic pathways. I also participated in field studies (moni- l l toring) at nuclear power plants and in the early development of USEPA staff guidance on emergency planning and emergency response for State and local agencies. IntheprehioustenyearsIwasemployedbyMoleculonResearchCorporation, Cambridge, Massachusetts and IBM Corporation, Owego, New York, where I performed tests on electronic systems and components in nuclear weapon and space radiation environments and simulators thereof. Previous to
; this I worked on the Brookhaven National Laboratory neutron cross-section
- ! ccmpilation (the Barn Book), was an instructor in radar and cryptography
- a't the U.S. Army Signal School, Ft. Monmouth, N.J., and developed reactor startup inst'rumentation for nuclear powered submarines.
I earned a B.S. in Physics in 1952 from the University of Scranton, Scran-ton, PA and an M.S. in Physics in 1957 from Temple University, Philadelphia, PA. I have also earned additional graduate credits in Physics and Nuclear Engineering at Pennsylvania State University, University Park, PA
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EXHIBZT 1 (Page 2 of 2) I am a member of the Health Physics Society and the National Physics Honor Society, and am a past member of the American Nuclear Society, -) the Institute for Electrical and Electronic Engineers and the American Society for Testing and Materials. I am the author or co-author of over thirty publications (Health Physics Journal, IEEE Transactions on J Nuclear Science, International Journal of Radiation Engineering, 1 International Atomic Energy Agency) in the areas of radiation
-l transport, dosimetry and radiation effects. 4 l
I've been married once for twenty years now, and I have seven children. l l w
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EXHIBIT 2 "Artsuntz F,--Easzaosuct Plane ros PsopoC* 3 Wrtsten ident1Acation, by po ition of tuncuod. of oth4r employees of sne licensee Tson aaro Urrt.rsattoH Pacters with spectat qua"acauona for coptng with J. introduct103 emergency conditions which may ar St. Other Each applicant for a construction permit ts persons with special quallocations who are - not employees of the 11censee and who may required by 150.34(al to include in its pre. be catted upon for assistance shall also be 11minary safety analysts report a discusaton ident18ed. The spectat quallocations of these of prettminary plans for coping with emar* employees and persons shall be desertbed; gencias. Each app 11 cant for an operating 11* C. Means for deter.nining the magnitude cense is required by 1 $0.3 t(b) to include in of the telease of radioactive .ertals. in. Ita Snal safety analysts report plans for cCp* . ciuding critetta for detertnit g the need ing with emergencies. got nottacation and particip . ton of local - This append 12 establishes minimum re. snd State agencies and the Nuclear Regulatory quirements for emergency plans. These plans commnsion and other Federal agencies, and shall be desertbed in the preliminary safety criterta for determining when pr 3tective analysis report and submitted as a psrt of measures should be considered within and the Onal safety analysts report. Prccedures outside the site boundary to protect health ttsed in the detailed implementation of enier. and safety and prevent damage to propcrty! gency plans need not be dercribed in tbo pre. D. Procedures for notifying, and agree. 11minary or anal safety analysts report. ments reached with. local. State. and Fed. II. The Prelimi'lery Se/ety etnalytta fleport eral od!clals and agencies for the early warn. , Ing of the public and for public evacuation The Preliminary Safety Analysis Iteport or other protective measures should such I shall contain succient information to assure ,gtning, evacuation, or other protective ) the cornpatibility of proposed emergency measures become necessary or desirable. (n. plans with factitty design festures. site lay
- ciuding identincation of the principal om.
out, and alte location with respect to such ctals, by stue and agencies: considerations as access routes. surTounding E. Provisions for maintaining up to date: population distributions, and land use. 1. The organisation for coping with emer. j As a minimum, the following items shall gencies. 2. the procedures for use in emer. . be described 1 gencies, and 3. the lists of persons with a . De organization for coping with ecner* special qual 10cauons for coping with emera genstes, and the means for not1Scatien, in gency cond]tions: i the svent of an emergency. of persons as* F. Emergency afst s!d and personnel de. l algne t to the emergency crgsntzation: contamination facilities. including: l
- 11. Contacts and arrangements made or to e- 1. Equipment at the alte for personnel be made with local. State and Federal go'*
- monitortng; .
ernmental agencies with responsibility for b 2. Factittles and supp11es at the site for coping with emergencies. including ident1* g decontamination of personnel: Scation of the prinetpst agencias: w 3. Facilities and medleat supplies at the C. Measures to be taken in the seent of "o site for appropriate amergency crat aid an accident within and outside the site treatment; boundary to protect health and safety and 4. Arrangements for the services of a I r- prevent damage to property and the es* physician and other medical personnel qual. j pected response in the event of an etner* Lged to handle radiation etnergenctee; and O gency,of ogsite agencies: 5. Arrangements for transportation of in. g D. Features of the facility to be provided jured or contaminated individuals to treat. m for onsite emergency Srst aid and decen* ment fact 11 ties outside the alte boundary: g tamination. and for emergency transporta* O. Arrangements for trestment of indt. tion of individuals to castte treatment viduals at treatment facilit;es outside the factiltles; site boundary; l E. Provisions to be made for ec*ergenc7 E. Prottatons for training of etnployees of l treatment of ladividusts at oEstte factiltles; the licensee who are assigned spectac au. F.The training program for employeen and thority and responalbility in the event of an for other persons. not etnployees of the 11 emergency and of other persons whose consee, whoes services may be required in sasistance may be needed in the event of a coping with an emergency; ,radlauon emergency; O. Features of the facility to be pro * !. Prottstons for testing by periodic drills, vided to assure the capability for plant of radiation emergency plans to assure that evac'.tation and the capability for fact 11tT employees of the 11consee are famillar with reentry in order to mitigate the consequences thett spectac duties, and provisions for par. of an accident or, Lt appropriate, to continue ticipauch in the drills by other persons operation, whose assistance may be needed in the event til. TAs FindJ Jafety Anatyr(s Report of a radiation emergency; J. Criteria to be used to determine when. The Final Safety Analysts Report shall con
- following an accident, reentry of the facility tain plans for coping with emergencies. T3e is appropriate or when operation should be detalls of these plans and the details of conunued, their implementattort need not be included.
but the plans submitted must include a de. The Commission has developed a scrtpuon of the elements set out in section document entitled " Guide To the Prepa-N to an estent sumetent to demonstrate ration of Emergency Plans for Produe that the plans provide reasonable assurance Llan and Utilization Facilities"' to help that approprtste measures can and will b* applicants establish adequate plans re. taken in the event of an emergency to pro
- quired pursuant to 150.34 and this Ap-teet pubito health and safety and prcrent pend 1x. for coping with emergencies, damage to property. =
IV. Confant of gmergency Plans The emergency plans shall contain, but i not necessarily be limited to, the following elements: A. %e organisation for coping with rS* I , distion emergencies. In which spectee au- LDe Oulos 14 available for inspectice at i thorttles, responsibittues, and duties see de- the Commission 3 Public Document RAggt aned and assigned. 6 2d the means of nosi. 1117 E Street NW. and coptes may be een fication. In the event of an emergency, of: tained by addressing a Request to the (1) Persons mastgned to the lleensee s erner. 11untor of Nudear Meactor Regulation or Di-feuor of Nuclear Materials Safety and Safe-gency organization. and (2) appropriate 8,uards. as appropriate. U.S. Nuclear Resutatory state, and Federal agencies with faspon. t ummnsion. Washington. D.C. 20 $ $ $. alblittles for coping with emergenciee: September 1,1978
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EXHIBIT 4 (Page 1 of 6) _, Interrogatory HS-9. Provide a copy of the estimate of "off-site authorities" referred to on p.13-4 of the SER and a copy of the " independent analysis" which allegedly agrees with +his estimate. If these materials are not in. - writing, provide a written description of them including the names and positions of the individuals who made such estimate and analysis and the date and place they were made. Response (JAM) Estimates of accident detection and analysis, and notification and , evacuation times were presented in the applicant's response to the staff's question Q422.1, which was provided by PASNY in supplements one and ten to its PSAR, dated February 1976 and November 1976, respectively. In Amendment 30 to its application, dated July 24, 1978, PASNY submitted Supplement No. 28 to its PSAR which included an extensively revised and more detailed answer to our question Q422.1, but with substantially identical conclusions. The staff's analysis was based on the population distribution projected for 2020 AD and the present road networks, using an empirical model developed by Dr. R. W. Houston (see R. W. Houston, testimony in the matter of Northern States Power, Tyrone Energy Park, Unit 1, Eau Clair, Wisconsin, October 7,1976, Docket No. 50-484). The model is based on data obtained by the U.S. EPA from evacuations of historical record (Evacuation Risks - An Analysis, EPA 520/6-74-002, USEPA Office of Radiation Programs, Washington, D.C. 20460, June 1974 ). In essence,
a i EXHIBIT 4 I (Page2of6) i the model reduce to the deterministic relation: t 0 E = 1.05A .27 g .23 ft 0.5 Where tE = estimate of evacuation time, in hours, . No = population initially in Area A, A = area in square miles, and L = number of roads leaving the area. The staff applies this equation for sixteen 45 degree sector-segments (two adjacent 22.50 sector-segments at a time). The staff does not consider the results of these calculations as definitive, but rather as conserva-tive upper bound estimates of elapsed time to complete evacuations of 450 sector-segments in the absence of advanced planning. These estimates were made by the staff at Bethesda, Md. during the review period. Attached are copies of the work sheets used by the reviewer. l
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ROAD TRAFFIC CAPACITIES ,
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4500 - , 1000 - 3500 - 3000 - 90 - m o s M 2500 - Clu _. ~ i (NATL. SAFETY528COUN i 2000 p0 g _~ (n v+0 1)Lv O - L = VEHICLE LENGTH ( = 20 FT.) I 1500 n = SEPARATION DISTANCE $ '.' T (VEHICLE LENGTH PER MPH) 1000 - i ; 500 - i r i i j ' i i o > 40 50 60 10 20 30 0 4 VEHICLE SPEED, v (mph)
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_ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .}}