ML20149F128
| ML20149F128 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/25/1988 |
| From: | Urbanik T TEXAS A&M UNIV., COLLEGE STATION, TX |
| To: | |
| Shared Package | |
| ML20149F096 | List: |
| References | |
| OL-3, NUDOCS 8802120036 | |
| Download: ML20149F128 (6) | |
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-e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of
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l LONG ISLAND 1.lGHTING COMPANY
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Docket No. 50-322-01.-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
AFFIDAVIT OF THOMAS URBANIK 11 CONCERNING LILCO'S MOTION FOR
SUMMARY
DISPOSITION OF CONTENTIONS 1, 2 AND 9 1, Thomas Urbanik 11, being duly sworn, do depose and state the following:
1.
I am a
Research Engineer associated with the Texas Transportation institute of the Texas A & M (Iniversity System, College Station, T exas.
My professional qualifications have been admitted into evidence in this proceeding during the reception center hearings as part of Staff Exhibit 3 (Tr.18955).
2.
As stated in my direct testimony admitted into evidence during the reception center hearings (Staff Exhibit 3: Tr.
18955),
I was l
l principal author of NUREG/CR-1745, "Analysis of Techniques for Estimating Evacuation Times for Emergency Plcnning Zones" (November 1980), which described the limitations of several methodologies and some alternatives for determining evacuation time estimates.
I provided input to the development of the current guidance for ETE studies which appears in Appendix 4 to NUREG-0654
( N U R E G-0654 / FEM A-R EP-1, Rev.
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8802120036 880204 PDR ADOCK 05000322 O
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l'. November 1980).
I also appeared and testified on behalf of the Staff during the Shoreham hearings on ETEs..
3.
l have reviewed the "Affidavit of Edward B.
Lieberman in Support of LILCO's Motion for Summary Disposition of Contentions 1, 2 and 9 - Immateriality" which was filed by Applicant as an attachment to "LILCO's Motion for Summary Disposition of Contentions 1,
2 and 9-Immateriality".
4.
KLD has prepared new ETEs (incorporated into Revision 5 to LI LCO's plan) based on a revised network and increased population, which.results in a different distribution of traffic from the previous analysis.
The new analysis indicates the EPZ roadway network is capable of handling evacuating traffic nearly as well without special traffic control measures as with those measures in place.
5.
The term "special traffic control measurcs" does not presume the absence of normal police traffic control to handle normal incidents, such as breakdowns of vehicles or traffic signals.
ETEs cannot reasonably estimate the small number o'
incidents that would occur during an evacuation.
These events are assumed to be handled through routine police procedures.
6.
Mr. Lieberman draws no conclusions from the revised analysis.
He only indicates a reduction in the time differential between controlled and uncontrolled evacuations for the summer normal weather evacuation, it is my opinion that the appropriate estimate for an uncontrolled evacuation would be one that includes some degree of noncompliance with evacuation routing.
Using what I believe to be the upper limit of noncoivpliance,,50%, the revised ETEs, which range from 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, 5
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C minutes to G hours, 25 minutes, are essentially the same as the previous ETEs which ranged from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, 55 minutes to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 30 minutes.
7.
The term "uncontrolled" should not be construed to mean "unplanned".
The presence of a plan results in residents being informed of appropriate evacuation routes, as is the case with Shoreham.
Traffic control personnel implement and support the plan which has also been made known to the public.
8.
In regard to the guidance of NUREG-0654 for complying with the requirement of "a range of protective actions", special traffic control is only suggested as an appropriate action that may be considered.
It is not necessarily a requirement that the ETEs or emergency plans include special traffic controls to enhance capacity.
9.
The intent of NUREG-0654, Appendix D,
is to identify potential traffic control strategies for consideration by local authorities.
There is no intent in the guidance of NUREG-0654 to require local authorities to implement strategies they believe to be inappropriate.
The intent is to identify strategies which are notentially effective in aiding evacuation, and are also within the resources of local authorities.
10.
With regard to the issue of fuel trucks, I do not believe that there is any reason to provide such service based on the small number of vehicles requiring the service and the alternatives for handling such contingencies.
My experience indicates that those individuals who run out of gas would secure rides with others, while the empty vehicle would j
be pushed or towed out of the way, causing minimal impact on evacuation i
l times.
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4 The statements above are true and correct to the best of my current knowledge and belief.
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Tficmas Urbanik Il Subscribed and sworn to before me this Jrth day of January,1988.
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Notary P blic MY/t6gisggggirNdDES I,. j,J,
'! Notary Public State of Texas N MY. Commission E4 ires 2 25-90 4
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tlNITED STATES OF AMERICA
'N FEB -9 M1 :25 NUCLEAR REGULATORY COMMISSION 0FFICE OF Siihr !A6Y BEFORE THE ATOMIC SAFETY AND LICENSING BOARDOCKEhNG A SERVICE BRANCH in the Matter of
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)
LONG ISLAND LIGHTING COMPANY
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Docket No.
50- 32 2-OL-3
)
(Emergency Planning)
(Shoreham Nuc! car Power Station,
)
Unit 1)
)
CERTIFICATE OF SERVICE I
hereby certify that copies of "NPC STAFF RESPONSE TO LI LCO'S '
MOTION FOR
SUMMARY
DISPOSITION OF CONTENTIONS 1,
2, AND 9 - IMMATERI ALITY" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 2nd day of February 1988.
James P. Gleason. Chairman
- Joel Blau, Esq.
Administrative Judge Director, Utility Intervention Atomic Safety and Licensing Board Suite 1020 U.S. Nuclear Regulatory Commission 99 Washington Avenue Washington, DC 20555 Albany, NY 12210 Jerry R. Kline*
Fabian G. Palomino, Esq.
Administrative Judge Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, DC 20555 Albany, NY 12224 Frederick J. Shon*
Jonathan D. Feinberg, Esq.
Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Empire State Plaza Washingtcn, DC 20555 Albany, NY 12223 Philip McIntire W. Taylor Reveley Ill, Esq.
Federal Emergency Management Donald P. Irwin, Esq.
Agency Hunton & Williams 26 Federal Plaza 707 East Main Street Room 1349 P.O. Box 1535 New York, NY 10278 Richmond, VA 23212 Douglas J. Hynes, Councliman Town Board of Oyster Bay
- Town Hall Oyster Bay, New York 11771
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Stephen B. Latham, Esq.
Herbert H. Brown, Esq.
Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.
Attorneys at Law Karla J. Letsche, Esq.
33 West Second Street Kirkpatrick 6 Lockhart Riverhead, NY 11901 South Lobby - 9th Floor 1000 M Street, NW Atomic Safety and Licensing Washington, DC 20036-5891 Board Panel
- U.S. Nuclear Regulatory Commission Jay Dunkleberger Washington, DC 20555 New Yoric State Energy O ffice Atomic Safety and Licensing Agency Building 2 Appeal Board Panel
- Empire State Plaza U.S. Nuclear Regulatory Commission Albany, NY 12223 Washington, DC 20555 Spence W. Perry, Esq.
Martin Bradley Ashare, Esq.
General Counsel Suffolk County Attorney Federal Emergency Management H. Lee Dennison Building Agency Veteran's Memorial Highway 500 C Streat, SW Hauppauge, NY 11788 Washington, DC 20472 Anthony F. Earley, Jr.
Dr. Monroe Schneider General Counsel North Shore Committee Long Island Lighting Company P.O. Box 231 175 East Old County Road Wading River, NY 11792 Hicksville, NY 11801 Ms. Nora Bredes Dr. Robert Hoffman Shoreham Opponents Coalition Long Island Coalition for Safe 195 East Main Street Living Smithtown, NY 11707 P.O. Box 1355 Massapequa, NY 11758 William R. Cumming, Esq.
Office of General Counsel Alfred L. Nardelli, Esq.
Federal Emergency Management New York State Department of Law Agency 120 Broadway 500 C Street, SW Room 3-118 Washington, DC 20472 Docketing and Service Section*
Barbara Newman Office of the Secretary Director, Environmental Health U.S. Nuclear Regulatory Commission Coalition for Safe Living Washington, DC 20555 Box 944 14untington, New York 11743 9
lard G. Bachmann s
Counsel for NRC Staff
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