ML20245J402

Revised Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Contention of JI-56 (Monitoring Rate).* Evacuee Load Estimates Will Likley Be Exceeded.W/Certificate of Svc.Related Correspondence

ML20245J402
Person / Time
Site:	Seabrook
Issue date:	06/21/1989
From:	High C MASSACHUSETTS, COMMONWEALTH OF, RESOURCE SYSTEMS GROUP
To:
References
CON-#389-8826 OL, NUDOCS 8907030034
Download: ML20245J402 (11)

Text

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hh, WIND @MQE2fyQSg f f)gU UNITED STATES OF' AMERICA *89 am 26 P4 '14 NUCLEAR REGULATORY COMMISSION

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ATOMIC SAFETY.AND LICENSING BOAR.D_i U Before the Administrative Judges:

t -Ivan W. Smith, Chairperson Dr. Richard Cole Kenneth A. McCollom

)

In the Matter of ) Docket Nos.

) 50-443-OL PUBLIC SERVICE COMPANY OF ) 50-444-OL f-NEW HAMPSHIRE, et al. ) (Off-site EP)

(Seabrook Station, Units 1 and 2) )

) June 21, 1989 l REVISED TESTIMONY OF DR. COLIN J. HIGH ON BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL'FOR THE COMMONWEALTH OF MASSACHUSETTS CONCERNING CONTENTION OF JI-56 (Monitorino Rate) 1 l

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Department of the Attorney General Commonwealth of Massachuse'"'

One Ashburton Place Boston, Massachusetts 02108-1698 (617) 727-2200

(' l 8907030034 890622 PDR T T ADOCK 05000443 I PDR 35 **

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SUMMARY

OF TESTIMONY j i 1 l

In this revised testimony, Dr. Colin High, an expert in the area of air photo interpretation, survey techniques, and b l

statistical methods, uses the "20% formula" set forth in the NHRERP PID at S5.19 to estima*'.e the number of people who, for planning purposes,-can be expected to arrive for monitoring at j the SPMC's two reception centers. This revised testimony is 1

i intended to lay a foundation for JI-56, which challanges the '

SPMC's ability to achieve a monitoring rate that will permit  ;

the ORO to monitor 20% of the total population within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The calculations reported in this testimony have been revised to use certain inputs to the "20% formula" which the I Board has ruled are Las iudicata, i.e., (1) the town clerk permanent residents data and (2) data for the Massachusetts beach area evacuees which is based on an assumption that there are 31,000 vehicles in the EPZ beach areas.

II. IDENTIFICATION OF WITNESS Q.l. What is your name and current occupation?

A.l. My name is Colin J. High and I am a Principal of Resources Systems Group, Inc., of Norwich, Vermont.

Q.2. What are your professional qualifications?

A.2. In addition to my work at Resources Systems Group I am also Research Professor of Environmental Studies at Dartmouth College, Hanover, NH. I hold BS and Ph.D.

I degrees in' Geography and Geology from the University of Bristol, England. I have. received formal undergraduate and graduate training in air photo interpretation, survey techniques and statistical methods. I have been an instructor in geography, air photo interpretation, remote sensing'and statistical methods at the_ university level. I have 23 years experience in the use of air photographs and statistical surveys in' transportation, land use studies, site evaluation and environmental-science. I have received grants'and contracts from l NASA, the U.S. Department of Energy, and the U,S. First Service which involves the use of air photography and statistical analysis. A copy of my curriculum vitate is 3 on file in the proceeding. It is Attachment I to the testimony which I presented to the Board for.the hearing on the NHRERp, December 1, 1987 (Vol. Tr. 6849).

III. TESTIMONY Q.3. What is the purpose of your testimony?

A.3. This testimony is designed to lay-the foundation needed to assess the ability of the_SPMC.to achieve'a monitoring rate that enables the New Hampshire Yankee Offsite Response Organization ("NHY-ORO") to monitor.20%

of the total resident and transient' population within a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period. My testimony provides an estimate of

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r the number of persons that, using the "20% method" described in Section 5.19 of the Board's NHRERP PID, may 4 be expected to arrive at the monitoring trailers at tbe j i

SPMC's reception centers in North Andover and Beverly )

during and after an evacuation of the Massachusetts part  ;

I of the Seabrook EPZ, under peak population conditions, on hot summer days at midweek and weekends. i Q.4. What is the method you used to make this estimate?

i A.4. The mathematical formula used in this case for i estimating the reception center load is that formula j which is described in the Board's NHRERP PID, section I

5.19 at page 74 as follows:

Evacuee Load = (0.20 x (PP -SFP -TDP) + TDP Where: PP= Sum of the peak population for the assigned communities; SFP=Special facilities population 1

of the assigned communities; TDP-Transit dependent population of the assigned communities.

Q.5. Please describe the data used in this calculation.

A.S. The data was obtained in the following way The resident population and summer midweek non-resident (transient) populations assigned to both North Andover and Beverly were calculated from latest available town Clerk derived data provided by the applicants in a memorandum of a record of telephone conversations dated 12/5/88 from Tom Rigney. The l -4 -

summer weekend non-resident population assigned to North Andover and the summer midweek non-resident population assigned to North Andover and Beverly were l

calculated from Table 3.6-1 of Section 6 of the SPMC.

The summer weekend non-resident population of communities assigned to Beverly include substantial number of visitors at the beaches of Plum Island and Salisbury. The estimated non-resident population of the Salisbury beaches and Plum Island beaches which are assigned to Beverly are calculated by using the Board's finding that reasonably expectable peak vehicle population of the beach area of the EPZ for planning purposes is 31,000 (PID S9.12) and then applying.the proportion of the toral vehicles in the EPZ beach areas which are normally found at Salisbury and Plum Island beaches. Using the vehicle counts based on air photography interpretation in beach areas made by KLD and reported in Volume 6 of the NHRERP at E-5 and the counts reported i the testimony of Befort, Adler and High (Vol. Tr. 6849), I calculated that on average 40% of the total number of vehicles in the EPZ beach areas are at Salisbury and Plum Island beaches on hot summer weekends. Therefore, using 31,000 as the maximum EPZ beach area vehicles estimate times 40%, I calculate the maximum number of vehicles at l

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1 Salisbury and Plum Island beaches to be 12,400. Using the vehicle occupancy rate of 2.4 (NHRERp Vol. 6 at I I

2-12), this gives a maximum beach population of 29,760 l l

to be assigned to Beverly. However, in order to I i

eliminate the double counting of residents who re at j j

the beach the beach population is reduced by 7% based 1 on the estimates of residents at the beach given in j NHRERp Vol. 6. The reduced estimate used is 27,677 persons. The non-residents of the assigned communities outside the beach areas are calculated I

from the data given in Table 3.6-1 of Section 3.6 of i the SpMC.

I The transit dependent populations were taken from l

Table 11-7 of Volume 6 of the NHRERP; and special facilities populations of the assigned communities are taken from PSNH Intra-company business memo from B.

Bovino to D. Tai 11eart dated January 13, 1989 (a memorandum obtained through discovery by the Massachusetts Attorney General). That memo appears to use special facility population data which are more current than the data reported in the SpMC (Amend. 6).

Q.6. What are the results of your calculation using the method and data that you have described?

l A.6. The estimates for the monitoring trailer evacuee loads i

reporting for monitoring at the SpMC's reception

I Centers in North Andover and Beverly are given in the following table. Please note that these load estimates are for the monitoring trailers; the special facility populations, who are to be monitored in their vehicles, are not included in these numbers.

Monitorina Trailer Loads at Reception Centgra Peak Peak l Summer Midweek Summer Weekend l

North Andover 7006 5756 l Beverly 12616 12787 Q.7. Do you believe these estimates are the best possible estimates of the evacuee loads at these reception centers?

A.7. No. They would likely be higher for two reasons.

First, I used the Applicants' vehicle occupancy rate of 21.4 for the vehicles at Salisbury and Plum Island beaches. In my opinion, the vehicle occupancy rate is probably higher than that. Surveys conducted of vehicle occupancy on hot summer days at New Hampshire beaches within the EPZ and adjoining the Massachusetts beaches (see volume 6 of the NHRERP at E-4, reporting data collected by the Southeastern New Hampshire Regional Planning Commission) show occupancy rates from 3.0 to 3.5 person per vehicles. If an occupancy rate of 3.0 were applied to the beach area vehicle estimates for a peak summer weekend, then the evacuee load at Beverly would increase to 14,170 people.

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Second, the formula approved by the Board in its I i

NHRERP PID, and used here, assumes that only 20% of the non-transit dependent population will go to be monitored at the reception centers. No evidence, l based on conditions at this site, is given to support l

this assumption. The percentage of the population that choose to be monitored could be much higher than 20%. If that were the case, then evacuee loads at ,

both North Andover and Beverly would be higher.

0.8. Does this conclude your testimony?

A.8. Yes.

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'89 JLN 26 P 4 15 i UNITED STATES OF AMERICA cjqu, ,

NUCLEAR REGULATORY COMMISSION 00CKi i N.i +_ . 1.  !'

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ATOMIC SAFETY AND LICENSING. BOARD i Before the Administrative Judges:

Ivan W. Smith, Chairman i

Gustave A. Linenberger, Jr. i j Dr. Jerry Harbour j

l }

l In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP) l OF NEW HAMPSHIRE, ET AL. )

)

(Seabrook Station, Units 1 and 2) ) June 21, 1989

)

l CERTIFICATE OF SERVICE I, Leslie B. Greer, hereby certify that on June 21, 1989, I made service of the REPLY OF THE MASSACHUSETTS ATTORNEY GENERAL TO THE i

RESPONSES OF THE APPLICANTS AND STAFF TO THE MAY 31 MOTION TO HOLD J

OPEN THE RECORD and the REVISED TESTIMONY OF DR. COLIN J. HIGH ON BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OF '

MASSACHUSETTS"CONCERNING CONTENTION OF JI-56 (Monitoring Rate) via I hand delivery,.as indicated by (*] and by First Class Mail on June.

21, 1989 to:

• Ivan W. Smith, Chairman Atomic Safety & Licensing Board .*Kenneth A. McCollom .

1107 W. Knapp St.

U.S. Nuclear Regulatory Stillwater, OK 74075 Commission East West Towers Buildir.g Docketing and Service 4350 East West Highway U.S. Nuclear Regulatory Bethesda, MD 20814 -

Commission Washington, DC 20555 Il

T

• Dr. Richard F. Cole Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814

• Robert R. Pierce, Esq. *Thdmas G. Dignan, Jr., Esq.

Atomic Safety & Licensing Board Katherine Selleck, Esq.

U.S. Nuclear Regulatory Commission Ropes & Gray East West Towers Building One International Place 4350 East West Highway Boston, MA 02110 Bethesda, MD 20814

• H. Joseph Flynn, Esq. *Sherwin E Turk, Esq.

Assistant General Counsel U.S. Nuclear Regulatory Office of General Counsel Commission Federal Emergency Management Office of the General Counsel Agency 15th Floor l 500 C Street, S.W. 11555 Rockville Pike

! Washington, DC 20472 Rockville, MD 20852 Atomic Safety & Licensing Robert A. Backus, Esq.

Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Board Jane Doughty U.S. Nuclear Regulatory Commission Seacoast Anti-Pollution League Washington, DC 20555 5 Market Street Portsmouth, NH 03801 l

l Charles P. Graham, Esq. Barbara St. Andre, Esq.

Murphy & Graham Kopelman & P& ige, P.C.

l 33 Low Street 77 Franklin Street Newburyport, MA 01950 Boston, MA 02110 l Judith H. Mizner, Esq. R. Scott Hill-Whilton, Esq.

i 79 State Street Lagoulis, Hill-Whilton 2nd Floor & Rotondi Newburyport,- MA 01950 79 State Street Newburyport, MA 01950 Dianne Curran, Esq. Ashod N. Amirian, Esq.

Harmon, Curran, & Towsley 145 South Main Street Suite 430 P.O. Box 38 2001 S Street, N.W. Bradford, MA Washington, DC 20008 01835

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Senator Gordon J. Humphrey Senator Gordon J. Humphrey. I U.S. Senate One Eagle Square, Suite 507 Washington, DC 20510 Concord, NH 03301 i (Attn: Tom Burack) (Attn: Herb Boynton) .

John P. Arnold, Attorney General Phillip Ahrens, Esq.

l j Office of the Attorney General Assistant Attorney General i 25 Capitol Street Department of the Attorney Concord, NH 03301 General Augusta, ME 04333 William S. Lord Board of Selectmen Richard Donovan .

Town Hall - Friend Street FEMA Region 10 l Amesbury, MA 01913 - 130 228th Street, S.W.

Federal Regional Center ]

Bothell, WA 98021-9796 I COMMONWEALTH OF MASSACHUSETTS JAMES M. SHANNON ATTORNEY GEhERAL 1

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Leslie B. Greer W

Assistant Attorney General {

Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 2 (617) 727-2200 DATED: June 21, 1989 4

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