ML20247B518
| ML20247B518 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/07/1989 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#389-9158 OL, NUDOCS 8909130059 | |
| Download: ML20247B518 (14) | |
Text
Jr:c
~
~ ', ~ ~ ~ ~ ~
- ~ '
DOCF,EiEO.
USwc September 7, 1989
~69 SEP 11 P3:12 UNITED STATES OF AMERICA l-NUCLEAR REGULATORY. COMMISSION before the ATOMIC SAFETY AND~ LICENSING APPEAL BOARD.
)
In the Matter of
)
)
PUBLIC SERVICE-COMPANY OF
.)
Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
)
50-444-OL
)
(Seabrook Station, Units 1 and 2)
)
(Off-site Emergency
)
Planning Issues)
)
APPLICANTS' RESPONSE TO APPEAL BOARD ORDER OF AUGUST 30, 1989 By an order.of August 30, 1989, the Appeal Board directed the Applicants to furnish certain information g
pertaining to the evacuee loads utilized as a planning basis for the registration centers and radiation monitoring and decontamination facilities in the NHRERP phase of the hearings.
In particular, the Appeal Board's direction called for:-
A.
Numerical figures utilized by the Applicants in the mathematical model for calculating evacuee loads for registration and monitoring in each of the four host communities, including:
1.
The peak population (PP) figures for EPZ communities assigned to each host community; ABRQDIR4.SB 8909130059 890907 PDR ADDCK 05000443
)qo$
c eDn
4 2.
The Special Facilities Population.(SFP) for special facilities in the assigned communities.
3.
The transit dependent (TDP) in_the assigned communities; B.
Citations to the record where the numerical figures are indicated; C.
Descriptions of any calculations or assumptions necessary to arrive at the numerical figures; D.
Population figures (with record citations) and calculations which support the Licensing Board's finding that "the [ evacuee load) planning basis works out to be about 25% of all evacuees."
Set forth below are the answers with respect to each item.
A.
"The numerical population figures for the PP, SFP and TDP values used in the aforementioned mathematical model to obtain the evacuee load for each of the host communities:"
Manchester
[(PP)
(SFP)
(TDP) ) x 0.2 + (TDP) = EL
[47,147 -
297 371 ) x 0.2 +
371
= 9,667 Dover
[(PP)
(SFP)
(TDP) ) x 0.2 + (TDP) = EL
[44,552 -
177 932 ) x 0.2 +
932
= 9,621 Salem
[(PP)
(SFP)
(TDP)) x 0.2 + (TDP) = EL
[30,674 -
0 351 ) x 0.2 +
351
= 6,416 Rochester
[(PP)
(SFP)
(TDP) ] x 0.2 + (TDP) = EL
[31,906 -
457 674 ) x 0.,2 +
674
= 6,829
_2_
!o f
l Y
y
- m
- .k
- t. !-
B. -
"[C]itation to the portion of the record-from-
. which these nonulation ficruram are alman=M Peak Populations ?
4 1:
L o
Manchester East Kingston 1,556
(" Summer 1 Weekend"1popula-t
'Brentwood:
2,039 4 tion set out in App. Ex. 5 Exeter'.
13,361-
~" Populations of. Municipal-Kensington.
- 1,564 ities. Wholly or' Partially Newfieldsj 1,143 Within'10' Miles of.
L
'Stratham' 3,875 Seabrook Station 1986.
L being Table 1.in each of.
Vols.116-32-(hereafter
" Table 1")
-Hampton Beach 23,609 See " Peak Population Explanation" Below 47,147 Dover
' Greenland 2,443
+
New. Castle 749 Table 1 Hampton Falls 2,050-Rye; 11,137 See " Peak Population North Hampton 5,526 Explanation" Below
-Hampton 22;647.
44,552 Salem Kingston.
5,207-Newton 3,802 Table 1 South Hampton 1,367 Seabrook 20,298 See " Peak Population Explanation" Below.
30,674 Rochester Portsmouth 31,906 Table 1 31,906 1
l
4 i
Snecial Facility Populations:
ManchesteI*
1 Exeter Hospital 80 App. Ex. 5, Vol. 4 at Exeter Healthcare 115 pp. 18B being a Goodwins of Exeter 78 portion of an attach-Eventide Home
_21 ment to the IFO Resources 297 Coordinators Procedure.
j Note:
Rockingham County Nursing Home (population 320) (App. Ex. 5, Vol.
4B, Rockingham County Nursing Home Procedure, App. B) and Rockingham Jail (population 100) (App. Ex.
5, Vol. 4E, Rockingham County Jail Procedure, App. B), located in Brentwood, not included.
The effect of not including these facilities is to increase evacuee load by (0.2)
(320) + 0.2 (100) = 84.
This treatment was afforded these two populations at the time the calculations were.done because of existing uncertainty as to the likely protective action recommendation which would be utilized for those populations.
Not deducting them assured error on the side of conservatism (i.g. increased evacuee load)
Dover:
Webster at Rye 70 App. Ex.
5, Vol. 4 at 18B-24 Seacoast Health Care 122 App. Ex.
5, Vol. 4 177 at 18B-8 Salem:
SFP = 0 l
l - - - _
- v C '
18
.e4 a,
Rochester:
p Portsmouth Hospital 2100= App. Ex.:5, Vol.
4-at-18B-21 (last
'LClipper.Home 127. entry)
'Parrott Avenue Home
'22 App. Ex. 5, Vol. 4 Edgewood Center 156 at 18B-22 Wentworth House
_,51 457 Note:
The1special_ facility. population figures-icited above agree with population figures 1 ob m2ned.from the~ individual facilities for inclusion in individual.special facility RERPs.
The RERPs for the above-named facilities"are set forth in App.
Ex. 5,.Vols 18 (Hampton), 20 (Rye), 21
-(Portsmouth), and 26-(Exeter) at Appendix-F.
The population census figures are at B-1 of the special facility RERPs.
Transit Denendent Populations:
Manchester:
y East Kingston 22 App. Ex. 5, Vol. 4, at 18B-3 Exeter 280 App. Ex. 5, Vol. 4, at 18B-4 (actual figure is 279)
Kensington 6' App. Ex.
5, Vol.
4, at 18B-10 Stratham 32 App.'Ex. 5 at 18B-27 Hampton Beach 0
Brentwood 20 See " Transit Dependent Popula-Newfields
_11 tion Explanation" Below 371 3 _ - _ _ _ _ _ _ - - _ _ -
Dover:
Greenland 40 App. Ex. 5, Vol.
4, at 18B-7 Rye.
104 App. Ex. 5, Vol.
at 18B-24 New Castle 16-App..Ex. 5,.Vol. 4, at.18B-15~
North Hampton 28 App. Ex.
5, Vol.
4, at 18E-18 Hampton Falls
-22 App. Ex. 5, Vol.
4, at-18B-9 Hamptcn 722 See " Transit Dependant Popula-tion Explanation" Ealow 932 Salem:
Kingston 79 App. Ex. 5, Vol.
4, at 18B-12' Seabrcok 209-App. Ex.
5, Vol. 4, at 18B-25 Newton 52 See." Transit Dependent Popula-South Hampton
_11 tion Explanation" Below 351 Rochegtgr:
Portsmouth 674 See " Transit Dependent Popula-tion Explanation" Below 1
674 Peak Pooulation Erolanation As testified to by Mr. Callendrello, at the time the testimony, upon wtaich the findings of interest were based, was prepared, the most up-to-date infc;mation then available wasoutilized in doing the calculations for the evacuee loads.
See Tr. 4933.
This-meant that the Table 1 figures were used for the peak (summer weekend) populations of the inland municipalities, new peak population figures were derived from information in the plan together with information from a then recent-(July 18, 1987) set of aerial photographs taken of the beach areas.
App. Dir. No. 4, ff. Tr. 4740 at 4; Tr. 4772.
y
's l
.The? aerial-survey and the methodology used in translating the-cars' counted to populations lare described in App..Dir. No.
7,.
ff 5622-at'12-38.
Basically, cars were~ counted from the aerial; photographs'and' projected to a reasonable peak.
These
. peak vehicle counts superceded.the total number of resident,
-transient and employee vehicles for each beach community'as specifiedLin App. Ex.
5, Vol. 6,' Appendix M at M-1 through M -
- 5..Las~also App.'Ex.-5, Vol 6 at 1-13 for link node diagram.
D Based upon census data a portion of the total number of vehicles in the~ beach areas was assumed to be those of residents to which a person per. vehicle factor of 2.6 was applied and the balance were assumed to be: transients or employees to which a persons per vehicle factor of 2.4 was-applied..For portions of the beach area communities not located in the beach areas, a person per vehicle factor of 1.16.was utilized for employees.
The basis for the 2.4 figure'is described in App. Dir. No. 7, ff. Tr. 5622 at 16-17; the basis of'the 2.6 figure appears at App. Ex. 5, Vol. 6 at 2-5; the basis of the 1.16 figure appears at App. Ex. 5, Vol. 6 at 5-7.-
Table 1 peak population figures for all the EPZ municipalities appear-in the plan; beach area municipality: updates as derived from the aerial photographs do not themselves appear as a matter of record.
The numerical data were never requested or inquired of in cross-p examination or otherwise.
The effect of the adjustments was l -_.2--_____-_-__._.--.
o l(
to increase the~" peak populations" for the beach area towns 2
by 11,710 as shown below:
Town Table 1 Ann. Dir. No. 4 Calc Net Chance
.Hampton 36,635 22,647 Total Hampton (included is Beach in Hampton)
-23,609
+9,621 Rye 9,685 11,137
+1,452
' North Hampton 5,561 5,526.
-35 Seabrook 19.626 20.298
+672 TOTALS 71,507 83,217-
+11,710-The effect of the foregoing was to. increase the evacuee load estimates for all of the reception centers except Rochester, where the evacuee load remained unchanged.
In short, the adjustments resulted in the evacuee loads being higher t'. tan would have been the case using the Table 1 figures.
Transit Decendent Pooulation Explanation:
The basic document relied upon in determining the transit dependent populations and the source of all of the-numbers in this regard which appear at various places in NHRERP, Vol.
4, Attach. 18B is a New Hampshire Civil Defense survey conducted in March, 1986.
Tr. 4934.
After the numbers were placed in Rev. 2 of NHRERP, but before App. Dir.
No. 4 was prepared, subsequent verification revealed that adjustments of the numbers for the Towns of Brentwood, L
Newfields, Hampton, Salem and South Hampton and the City of l.
Portsmoutil were in order.
In keeping with the practice of L:.
),
s.
p-c using the best available data,-the adjusted figures were used in Applicants' Direct No.
4.
The adjustments made were as follows:
Municipality.
NHRERP Ano. Dir. No. 4 Net Chanae Brentwood 30 20
-10 Newfields 17 11
-6 Hampton 664 722
+58 Newton 48 52
+4 South Hampton 12 11
-1 Portsmouth 444 674
+230 The effect of this on the evacuee loads for the centers was:
Manchester:
Brentwood
-10 Newfields
_5 l
-16 (0.8) = -13 Dover
- I Hampton
+5jil l
58 (0.8) = 46 Salem:
Newton
+4
(
South Hampton
-1 3 (0.8) = 2 i
Rochester:
Portsmouth
+2.;LQ 230 (0.8) = 184 i
l As can be seen, evacuee loads for all centers except Manchester increased.
Manchester decreased by 13 which is less by a factor of about six than the additional 84 which were included by virtue of not subtracting out Rockingham l
County Nursing Home (0.2) (320) and Rockingham County Jail (0. 2 ) (100) as special facilities. 1 l
r o
't; C.
"[C] calculations or assumptions that are necessary to arrive at these flaures."
We believe there are no calculations or. assumptions necessary other than those heretofore described.
D.
"[T]he population figures (with record citations) and calculations that support the Licensing Board's finding that, as a result of conservatism in the' applicants' estimate 'the
[ evacuee load] planning basis works out to be about 25% of all evacuees'."
.The evacuee planning load used for each host community was 9,667 (the actual figure derived for Manchester - which had the highest calculated load).
App. Dir. No. 4, ff.
Tr. 4740 at 5.
(9667) (4) = 38,668 The total peak (summer weekend) population for the New
' Hampshire portion of the EPZ as calculated for purposes of Applicants' Direct No. 4 is 154,279 as shown in 5 A above.
Host Community Total Peak (Summer Weekend)
Population of Areas Served Manchester 47,147 Dover 44,552 Salem 30,674 Rochester 31.906 Total 154,279 Plannino Basis 38.668 0.2506
=
Total 154,279 In this connection, it should be noted that between the time Applicants' Direct No. 4 and Applicants' Direct No. 7 were _
- 9 prepared further refinements were made of the aerial survey data.
Use of the numbers as contained in that testimony along with the same census data and assumptions as to per vehicle occupancy would result in an increase of 86 in the total beach area peak (summer weekend) population yielding a figure of 154,365.
If this increased number is used the result is:
Plannina 7 asis 38.668 0.2505
=
Total 154,365 Respectfully submitted,
,,s~n Thottras G7 Digzu ff, Jr.
George-H. Lewaid Jeffrey P. Trout Jay Bradford Smith Geoffrey C. Cook William L. Parker Ropes & Gray One International Place Boston, MA _ 02110-2624 (617) 951-7000 counsel for Applicants 1
L.
s
[ xn iin v2C l 6 l
CERTIFICATE OF SERVICE 89 SEP 11 P3 :12 I, Thomas G.-Dignan, Jr., one of the attorneys for the
-Applicants herein,.hereby certify that on Septembefj7,jl989,>
I made service of the within document by mailing ddsies
" c" ~-
e thereof, postage prepaid, to:
Alan S. Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety.and Licensing Appeal Panel Appeal Panel.
U.S. Nuclear Regulatory.
U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Thomas S. Moore Mr. Richard R. Donovan Atomic Safety and Licensing Federal Emergency Management Appeal Panel Agency U.S. Nuclear Regulatory Federal Regional Center Commission 130 228th Street,'S.W.
Washington, DC 20555 Bothell, Washington 98021-9796
. Administrative Judge Ivan W.
H. Joseph Flynn, Esquire Smith, Chairman Office of General Counsel Atomic Safety and Licensing Board Federal Emergency Management U.S. Nuclear Regulatory Agency Commission c10 C Street, S.W.
Washington, DC 20555 Wuphington, DC 20472 Administrative Judge Richard F.
John P. Arnold, Esquire Cole Attorney General Atomic Safety and Licensing Board George Dana Bisbee, Esquire U.S. Nuclear Regulatory Assistant Attorney General Comrission Office of the Attorney General Washin; ton, DC 20555 25 Capitol Street Concord, NH 03301-6397 Administrative' Judge Kenneth A.
Judith H. Mizner, Esquire McCollom 79 State Street, 2nd Floor 1107 West Knapp Street Newburyport, MA 01950 Stillwater, OK 74075 Diane Curran, Esquire Robert R. Pierce, Esquire Andrea C.
Ferster, Esquire Atomic Safety and Licensing Board Harmon, Curran & Tousley U.S. Nuclear Regulatory Suite 430 Commission 2001 S Street, H.W.
Washington, DC 20555 Washington, DC 20009 i
. h[
- n Adjudicatory File.
Sherwin E. Turk, Esquire Atomic SPfety and Licensing Office of the Executive Legal Board Panel Docket (2' copies)
Director U.S. Nuclear Regulatory U.S.-Nuclear Regulatory Commission-Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission:
P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Mr. J. P. Nadcau
' Assistant Attorney General Selectmen's Office Department of the Attferney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern,' Esquire John Traficonte, Esquire Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue Department of the Attorney P.O.
Box 360 General Portsmouth, NH. 03801 One Ashburton Place, 19th Fir.
Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Kensington, NH 03827 126 Daniel Street Portsmouth, NE 03801 Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whiltor &
Washington, DC 20510 Rotondi (Attn:
Tom Burack) 79 State Street Newburyport, MA 01950 Senator Gordon J. Humphrey Barbara J. Saint Andre, Esquire One Eagle Square, Suite 507 Kopelman and Paige, P.C.
Concord, NH 03301 77 Franklin Street (Attn:
Herb Boynten)
Boston, MA 02110 Mr. Thomas F. Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street
~10 Front Street Amesbury, MA 01913 Exeter, NH 03833
vell
- m; 1.
T
)
(a?
, - Ashod'N. Amirian,DEsquire Richard A..Hampe', Esquire L145FSouth Main Street Hampe and McNicholas
-35 Pleasant: Street P.O'.- Box'38 Bradford, MA: 01835 Concord, NH' 03301
--)
', g <.
' Gary W., Holmes,. Esquire Holmes & Ells 47'Winnacunnet: Road Hampton, NH. 03842
+
G. : PaulL Bollwerk',-: III,- Chairman Atomic Safety and Licensing 4'
Appeal. Panel U.S. Nuclear Regulatory Commission
' Washington, DC 20555:
/
1x; TH5ma(G.". Di(fian, Jr.
f
____--_____-__D