ML20245J296
| ML20245J296 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/26/1989 |
| From: | Urbanik T NRC OFFICE OF THE GENERAL COUNSEL (OGC), TEXAS TRANSPORTATION INSTITUTE, TEXAS A&M UNIV. |
| To: | |
| References | |
| CON-#289-8529 OL, NUDOCS 8905040087 | |
| Download: ML20245J296 (12) | |
Text
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Q2f 4/26/89 KELATED CORRESPonggggg ggggg77g e,
Vanc UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION
'89 APR 27 P4 :16 o
BEFORE THE' ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of
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Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
)
50-444 OL NEW HAMPSHIRE, et al.
)
Off-site Emergency Planning
)
(Seabrook Station, Units 1 and 2)
)
TESTIMONY OF THOMAS URBANIK II ON BEHALF 0F THE NRC STAFF ON JOINT INTERVENOR CONTENTIONS 1-3 (SPMC)
Q.1.
Please state your name and occupation.
A.1.
My name is Thomas Urbanik II.
I am a Research Engineer associated with the Texas Transportation Institute of the Texas A&M University System College Station, Texas.
Q.2.
Have you a prepared statement of your qualifications?
A.2.
Yes. A statement of my professional qualifications is attached to my testimony filed in the NHRERP phase of this proceeding and is bound in the transcript following Tr. page 7372.
Q.3.
What is the purpose of this testimony?
A.3 The purpose of this testimony is to address three contentions concerning evacuation time estimates (ETEs) ar. thcy relate to the Seabrook Plan fcr Massachusetts Communities (SPMC). Specifically, this testimony addresses Contention JI-1, which alleges that no ETE study has been done for the Massachusetts portion of the EPZ; Contention JI-2, which alleges
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2-that the ETEs contained in the SPMC are unrealistic; and Contention JI-3, which alleges that a real-time monitoring and ETE calculation system i
should be installed.
0.4.
Have you reviewed the ETEs contained in the SPMC?
A.4.
Yes. ETEs are set forth in the SPMC at IP 2.5, Attachment 4.
I have also reviewed Volume 6 of the New Hampshire Radiological Emergency.
Response Plan (NHRERP), which provides much of the documentation on the l
ETEs; and I have reviewed the Applicants' NHRERP and SPMC testimony concerning ETEs for Seabrook Station, as well as the Licensing Board's Partia1' Initial Decision on NHRERP issues, dated December 30, 1988.
j Q.5.
Please identify the regulatory standard or guidance criteria against which ETEs are evaluated.
A.S.
ETEs are required to be provided by an Applicant pursuant to 10 C.F.R. Part 50, Appendix E, 9 IV, and are addressed in NUREG-0654, i II.J.10.
In p rticular, NUREG-0654, Appendix 4, provides guidance as to what is to be included in an evacuation time estimate study and how it might be presented.
Q.6.
Do you agree with the assertion that an evacuation time estimate study has not been done for the Massachusetts portion of the Seabrook EP2, j
and/or that a new study needs to be done to comport with the guidance of NUREG-06547 A.6.
No. KLD Associates has performed an ETE study for both Massa-chusetts and New Hampshire portions of the Seabrook EPZ, which was 3
i 1
. l published in Volume 6 of the NHRERP. Additional consideration was afforded Massachusetts portions of the Seabrook EPZ in the Applicants' NHRERP ETE testimony and the Licensing Board's Partial Initial Decision on NHRERP ETE issues.
In addition, KLD has performed a series of further I
studies for the Applicants, which are described in Applicants' Rebuttal Testimony No. 16. These studies include consideration of the Massachusetts I
portions of the Seabrook EPZ.
Q.7.
Have KLD's further studies, which are discussed in Applicants' i
i Rebuttal Testimony No. 16, been published as part of either the SPMC or
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i the NHRERP?
A.7.
No. These studies and the resulting ETEs are provided in f
Applicants' Rebuttal Testimony No. 16, but have not yet been incorporated into either of the two emergency plans.
Q.8.
Do the KLD ETEs account for the specific circumstances, difficulties and delays which might exist in conducting an evacuation in Massachusetts due to a radiological emergency at Seabrook Station?
A.8.
Yes.
KLD has considered Massachusetts-specific circumstances in its study published in Volume 6 of the NHRERP, and in its later analyses as set forth in Applicants' Rebuttal Testimony No. 16.
Q.9.
Is there any significance to the fact that the SPMC ETEs differ from KLD's ETEs of August 1986 (published in the NHRERP) and those in Applicants' Rebuttal Testimony No. 167 1
A 9.
No. The emergency planning process is intended to be ongoing, with revisions made as appropriate to reflect changing conditions and new 1
information. The revised ETEs in Appendix D of Applicants' Rebuttal
. Testimony No.16 are part of this ongoing refinement of the plans.
It is of no consequence that the SPMO ETEs differ from the prior NHRERP ETEs and l
those presented in Applicants' Rebuttal Testimony No. 16; however, the SPMC ETEs should be formally revised to incorporate the modifications set forth in Applicants' rebuttal testimony.
Q.10.
Do the ETEs fail to account for less than full staffing of traffic control points (TCPs)?
A.10.
No. As I indicated during the NHRERP hearings, ETEs need not reflect delayed staffing of TCPs; if any such delay should occur, that fact may be considered by the decision-makers, along with the ETEs, in selecting an appropriate protective action.
In addition, however, KLD has performed sensitivity studies for a variety of scenarios, including delayed staffing and no staffing of traffic control points in Massachusetts (see p. 46 of Applicants' Rebuttal Testimony No.16). No further consideration of this issue is necessary.
Q.11.
Are the SPMC evacuation time estimates unrealistic?
A.11.
No.
I have reviewed KLD's methodology and assumptions, and I am satisfied that they afford appropriate consideration of all significant factors.
KLD's ETEs represent the results of many years of study and refinement, and they represent realistic evacuation time estimates.
KLD's ETEs are also generally consistent with the results of previous analyses
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perfonned by myself and others for the NRC Staff es reflected in NUREG/CR-2903.
Q.12.
Do the Applicants' ETEs adequately consider the removal of road-blockages by tow trucks?
i A.12.
Yes. The accommodation of vehicle breakdowns and accidents is largely an issue of resource availability and deployment. The Applicants have provided for the removal of road blockages and impediments by tow j
trucks. Nonetheless, if any unusual and protracted road blockages should occur, that is the type of fact which would be taken into consideration by decision-makers at the time of an emergency and dealt with accordingly.
In addition, however, the Applicants here have conducted sensitivity studies with respect to various road blockage scenarios, as set out on
- p. 63 of Applicants' NHRERP Direct Testimony No. 7.
No further consid-eration of this issue is necessary.
Q.13.
Assuming that notification of a precautionary beach closure in Massachusetts is delayed, such that beach closure occurs simultaneously with an order to evacuat.
. N ssachusetts, what effect would there be upon the Applicants' ETEs?
A.13.
There may well be little or no effect on the ETEs, depending upon what events and circumstances have transpired prior to issuance of the order to evacuate in Massachusetts.
Even if the ETEs do increase, however, the resulting ETEs would be no greater than 25 minutes longer than the ETEs calculated by KLD.
l L_____-__________
Q 14.
Is there any reason to believe that an orderly and efficient traffic flow will not take place, due to the existence'of deficiencies in SPMC planning?
A.14.
No. Appropriate planning has taken place to mitigate any uncertainties which might otherwise affect an orderly and efficient traffic flow.
Q.15.
Have the Applicants made any incorrect assumptions concerning the number of vehicles that will use roads, intersections, and ramps in Massachusetts, or in estimating the number of vehicles that may be evacuating from and through Massachusetts?
A.15.
No. The number of evacuating vehicles have been estimated using a systematic process that has been extensively examined. The ETE assumptions and inputs are set out in Applicants' Rebuttai Testimony No. 16.Section V.
There is no reason to believe that any significant errors exist.
Q.16.
Is there any reason to believe that Massachusetts drivers will be confused by potentially different emergency messages due to the existence of multistate jurisdictions?
A.16.
No. The existence of more than one state (or local) juris-diction in EPZ emergency planning is not unusual and is not likely to create unique problems.
Q.17.
Are the Applicants' ETEs based upon any traffic management plans in Massachusetts which overestimate traffic flow rates?
A.17 No. Appropriate traffic flow rates have been used with respect to Massachusetts traffic management plans.
Q.18.
' Do the traffic management plans for Massachusetts adversely affect returning traffic at TCPs and access control points (ACPs)?
A.18.
No. The traffic management plans have been developed in a way to encourage efficient evacuation. The ETEs for returning commuters are unlikely to be greater than the ETEs already calculated for Massachusetts residents.
Q.19.
Has adequate consideration been given to special facility ETEs?
A.19.
Yes. The critical issues in special facilities planning are identification cT the locations of all such facilities, the number of persons to be served, and the necessary resources available for this purpose; this has been reviewed and found to be adequate by FEMA. The remainder of the process involves a determination of the overall time 1
required to respond; this has been done sufficiently to demonstrate that the ETEs are similar for the general population and persons in special facilities. KLD's method of calculating special population ETEs is included in NHRERP Volume 6, pp.11-1 to 11-27.
Q.20.
Have the Applicants supplied sufficiently realistic ETEs for consideration by decision-makers with respect to the Massachusetts l
portions of the EPZ, for a wide range of times and conditions?
A.20.
Yes. The Applicants have provided sufficient time estimates for use by decision-makers, to enable them to make informed decisions under a
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8 wide range of conditions, including situations not specifically addressed in the ETE study. Decision-makers would not be aided by the generation of still more evacuation time estimates, because ultimately they must use some Judgment in deciding upon a protective action. The fundamental philosophy of.NUREG-0654, Appendix 4, is that evacuation time estimates should provide an understanding of the sensitivity of the ETEs to a variety of conditions; NUREG-0654 does not suggest that there should be an enumeration of countless alternatives to account for an infinite array of possible evacuation scenarios, nor would the provision of such additional ETEs be of any practical utility.
Q.21.
Are the traffic cones and/or barricades provided for in SPMC l
traffic management plans likely to delay or block vehicles seeking to cross or travel against the evacuation traffic flow, such that the ETEs will be longer than are currently calculated?
A.21.
No. See my testimony concerning JI Contention 4.
Q.22.
Do you believe a real-time computer-based data collection and ETE calculation system could produce more useful evacuation time estimates than those calculated by KLD?
I A.22.
No. The current state of the art in evacuation time estimates l
and real-time data collection suggests that the current system of estimating ETEs in conjunction with sensitivity analyses is the most reasonable approach.
For instance, with respect to varying beach popu-lations, KLD has done a series of sensitivity runs which would provide sufficient information for use by decision-makers at the time of an
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emergency.
Furthermore, there does not appear to be any reason to believe L
that emergency planners could better use a real-time ETE than the evacuation time estimates which are currently available.
l Q.23.
Have you reached a conclusion concerning the adequacy of the 1
l ETEs for Massachusetts portions of the Seabrook Station EPZ?
A.23.
Yes. A very large number of ETEs have been developed for Seabrook Station over a period of years. The evacuation time estimates developed by KLD have been prepared in a manner consistent with the guidance of NUREG-0654, and are responsive to a large number of issues.
However, there is a need for an organized presentation of the ETEs which have been prepared by KLD, including assumptions and methodology, that could readily be useo 'oy decision-makers at the time of an emergency.
With the exception of the need for such an organized presentation of the ETEs, the evacuation time estimates which have been provided by the Applicants are fully responsive to the guidance of NUREG-0654, Appendix 4, and satisfy all applicable regulatory requirements.
I l
uta nc UW UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'89 APR 27 P4 :16 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-In the Matter of
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IS$[i,.
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)-
Docket Nos. 50-443 :0IN? '
PUBLIC SERVICE COMPANY OF 50-444 OL NEW HAMPSHIRE, et al.
Off-site Emergency Planning (Seabrook Station, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of " TESTIMONY OF THOMAS URBANIK II ON BEHALF OF THE NRC STAFF ON JOINT INTERVENOR CONTENTIONS 1-3 (SPMC)" in the above captioned proceeding have been served on he following by deposit in the United States mail, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Comission's internal mail system, this 26th _ day of April 1989:
IvanW. Smith, Chairman (2)*
Philip Ahrens, Esq.
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Comission State House Station Washington, DC 20555 Augusta, ME 04333 Richard F. Cole
- John Traficonte, Esq.
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Comission One Ashburton Place, 19th Floor Washington, DC 20555 Boston, MA 02108 Kenneth A. McCollom Geoffrey Huntington, Esq.
Administrative Judge Assistant Attorney General 1107 West Knapp Street Office of the Attorney General Stillwater, OK 74075 25 Capitol Street Concord, NH 03301 James H. Carpenter, Alternate
- Administrative Judge Diane Curran, Esq.
Atomic Safety & Licensing Board Harmon, Curran & Tousley U.S. Nuclear Regulatory Comission 2001 S Street, NW Washington, DC 20555 Suite 430 Washington, DC 20009 Thomas G. Dignan, Jr., Esq.
Robert K. Gad, III, Esq.
Robert A. Backus, Esq.
Ropes & Gray Backus, Meyer & Solomon One International Place 116 Lowell Street Boston, MA 02110-2624 Manchester, NH 03106 l
r
. 4 H. J. Flynn, Esq.
Judith H. Mizner, Esq.
Assistant General Counsel 79 State Street i
Federal Emergency Management Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Rober Carrigg, Chairman Board of Selectmen Paul McEachern, Esq.
Town Office Shaines & McEachern Atlantic Avenue 25 Maplewood Avenue North Hampton, NH 03862 P.O. Box 360 Portsmouth, NH 03801 William S. Lord j
Board of Selectmen Charles P. Graham, Esq.
Town Hall - Friend Street McKay, Murphy & Graham Amesbury, MA 01913 100 Main Street Amesbury, MA 01913 Mrs. Anne E. Goodman, Chairman Board of Selectmen Sandra Gavutis, Chairman 13-15 Newmarket Road Board of Selectmen Durham, NH 03824 i
RFD #1, Box 1154 Kensington, NH 03827
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Kensington, NH 03827 Hon. Gordon J. Humphrey Calvin A. Canney United States Senate City Hall 531 Hart Senate Office Building 126 Daniel Street Washington, DC 20510 Portsmouth, NH 03801 Richard R. Donovan R. Scott Hill-Whilton, Esq.
Federal Emergency Management Lagoulis, Clark. Hill-Whilton Agency
& McGuire Federal Regional Center 79 State Street 130 228th Street, S.W.
Newburyport, MA 01950 Bothell, Washington 98021-9796 j
Allen Lampert Peter J. Matthews, Mayor Civil Defense Director City Hall Town of Brentwood Newburyport, MA 01950 q
20 Franklin Exeter, NH 03833 Michael Santosuosso, Chairman Board of Selectmen William Armstrong South Hampton, NH 03827 Civil Defense Director Town of Exeter Ashod N. Amirian, Esq.
j 10 Front Street Town Counsel for Merrimac Exeter, NH 03833 145 South Main Street P.O. Box 38 Gary W. Holmes, Esq.
Bradford, MA 01835 Holmes & Ellis
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47 Winnacunnet Road Barbara J. Saint Andre, Esq.
Hampton, NH 03842 Kopelman and Paige, P.C.
I 77 Franklin Street Boston, MA 02110
Ms. Suzanne Breiseth J. P. Nadeau Board of Selectmen Board of Selectmen
" Town of Hampton Falls 10 Central Street Drinkwater Road Rye, NH 03870 Hampton Falls, NH 03844 Atomic Safety and Licensing Robert R. Pierce, Esq.*
Board Panel (1)*
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Ms. Elizabeth Weinhold 3 Godfrey Avenue Atomic Safety and Licensing Hampton, NH 03842 Appeal Panel (5)
U.S. Nuclear Regulatory Commission Washington, DC 20555 Docketing and Service Section*
Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Richard ~G. Eachmann Counsel for NRC Staff
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