ML20247F668
| ML20247F668 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/18/1989 |
| From: | Urbanik T NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| References | |
| CON-#289-8649 OL, NUDOCS 8905300128 | |
| Download: ML20247F668 (7) | |
Text
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UNITED STATES OF AMERICA h
NUCLEAR REGULATORY COMMISSION
'87 my 23 P6 :3ri BEFORE THE ATOMIC SAFETY AND LICENSING BOARD E P J,. *
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In the Matter of Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF 50-444 OL NEWHAMPSHIRE,et,al.
Off-site Emergency Planning (Seabrook Station, Units 1 and 2)
AFFIDAVIT OF THOMAS URBANIK II REGARDING COMMUTER TRAFFIC AND EVACUATING TRAFFIC FLOW WITHIN THE SEABROOK STATION EP?
8 I, Thomas Urbanik II, being duly sworn, state as follows:
1.
I am a consultant to the NRC Staff on evacuation time estimates.
l My background and qualifications are a matter of record in this proceeding.-
2.
I have reviewed the Atomic Safety and Licensing Board's Memorandum.and Order of May 5,1989 concerning the effects of commuter traffic on evacuation times, and the affidavits of Mr. Lieberman and Dr. Adler referred to therein.
This affidavit is prepared in. response to that Memorandum and Order, as discussed in the hearing session held on May 15, 1989.
3.
In a generic sense, returning commuters are not explicitly accounted for in ETE studies because they generally travel in directions opposite to evacuees and are traveling during the time period when the l
general public is assumed to be preparing to evacuate.
l' 4.
A unique aspect of the Seabrook Station emergency plans is 1
l the early closing of area beaches, which results in some evacuation l
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. l routes being used almost immediately.
Nevertheless, I have not seen any data nor analysis which suggests that a problem exists with respect to the effects of returning concuters on evacuation times.
5.
Explicit modeling of returning commuters is not a simple task.
Evacuation modeling involves a very limited matrix of origins (i.e.
ERPA's) and destinations (essentially the roads leaving the EPZ).
To model returning commuters it would be necessary, for example, to have another, larger, matrix of origins and destinations to account for the trips from work to home.
Second, it is necessary to know the likely routes that would be taken by the returning commuters, inasmuch as the commuters may need to perform other activities on the way home (such as carpooling) or may, due to.their intimate knowledge of the area, follow lesser-travelled or more familiar routes than simply the most direct routes between their origin and destination points.
Third, the evacua-tion road network would have to be revised and expanded substantially, to include additional inbound roads and non-evacuation routes which might be used by returning commuters.
Fourth, information would be needed as to the returning commuters' actual hours of employment relative to the hours of significant beach usage.
Fifth, the interaction between returning commuters and evacuees would have to be explicitly modeled, which is not a direct capability of any existing models.
This very large effort would only be appropriate if there was some reason to believe that returning commuters could have a significant impact on the ETEs.
. 2 6.
To affect the ETE, the returning commuters must pass through critical intersections (i.e. those operating at or near capacity) in a manner that could increase evacuation times.
This could only occur with respect to a limited number of intersections.
7.
It should be noted that the critical and near critical inter-sections are known from the ETE modeling effort.
Any analysis of returning comuters, if further analysis is to be performed, should make use of this information in order to avoid the needless analysis of a multitude of trivial cases; that is, non-critical intersections need not be modeled.
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8.
Returning commuters can effect the ETE only if they cross the evacuation path at critical or near critical locations or pass in the same direction as evacuees.
Clearly, the number of returning comuters who will be travelling between job locations near the center of the EPZ and homes which are also within the EPZ is limited in number (note that the vehicles of beach area employees have already been counted in tne beachpopulationestimates).
9.
None of the data available to date suggests that there would be large numbers of returning comuters moving in directions that would impede evacuation.
Also, alternate paths (non-evacuation routes and lesser-travelled roads) exist which would help to avoid bottleneck locations.
9.
The Applicants have presented a number of analyses that suggest the impact of returning comuters is minimal.
Absent any significant new l
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I data, no additional analysis of rr:urning comuters appears warranted, i
i In sum. no further modeling of I DYNEY to account for returning comuters I-is appropriate at this time.
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- Tiiomas Urbanik fl Subscribed and sworn to before me this g of May,1989 l:
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DocketNosP05DE443(,0LpWR LPUBLIC SERVICE COMPANY OF.
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M NEW HAMPSHIRE, et al.
Off-site Emergency Planning-t M
(Seabrook Station, Units 1 and 2) _
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C' CERTIFICATE OF SERVICE F
'I.'hereby certify' theti copies of " AFFIDAVIT OF THOMAS URBANIK -II REGARDING f
COMMUTER ' TRAFFIC AND EVACUATING TRAFFIC FLOW WITHIN THE SEABH00K STATION EPZ" M-in the above' captioned proceeding have been served on the foll.owing by deposit L
in ~ the United States mail, first' class' or, as indicated by an asterisk, by 1
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deposit in the Nuclear Regulatory Commission's internal mail system this 19th
~ day - of May 1989: -
Ivan'W. Smith, Chairman (2)* '
Philip Ahrens, Esq.
U Administrative Judge Assistant Attorney General o
-Atomic Safety and Licensing Board Office of the Attorney General H
LU.S. Nuclear Regulatory Commission 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
~
3U.S. Nuclear Regulatory Commission
.One Ashburton Place, 19th Floor Washington, DC 20555
-Boston, MA 02108-
[
_Kenneth A. McCollom-Geoffrey Huntington, Esq.
E Administrative Judge Assistant Attorney General 1107 West Knapp Street Office of the Attorney General Stillwater,' 0K 74075 25 Capitol-Street Concord, NH 03301 Thomas G. Dignan, Jr., Esq.
Robert K. Gad, III.- Esq.
Diane Curran, Esq.
Ropes & Gray Harmon, Curran & Tousley
,One: International Place 2001 S Street, NW Boston, MA' 02110-2624 Suite 430 Washington, DC 20009 p'#
. Robert A. Backus, Esq.
ii Backus, Meyer & Solomon 116 Lowell Street Manchester. NH 03106 l
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, H. J. Flynn, Esq.
Judith H. Mizner, Esq.
s b,'e Assistant General Counsel 79 State Street L
' ?!L Federal Emergency Management Agency Newburyport, MA 01950 t
500 C Street, S.W.
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Washington, DC 20472 Robert Carrigg, Chaiman ec"'
Board of Selectmen
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l Paul McEachern, Esq..
Town Office.
E.
Shaines & McEachern Atlantic Avenue
,/
f25'MaplewoodAvenue North Hampton, NH 03862
- P.O. Box 360
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Um Portsmouth, NH 03801 William S. Lord
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Board of Selectmen Charles P. Graham, Esq.
Town Hall - Friend Street u
J.
.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 H
Board of-Selectmen Durham, NH 03824 h"
'RFD #1,. Box 1154 Kensington, NH 03827
!Kensington, NH 03827 Hon. Gordon J. Humphrey_
i LCalvin A. Canney.
United States Senate City Hall.
531 Hart Senate Office Building 126 Daniel Street' Washington, DC. 20510
- Portsmouth, NH 03801 Richard R. Donovan lR.: Scott Hill-Whilton, Esq.
Federal Emergency Manageraent
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'Lagoulis, Clark, Hill-Whilton Agency
. '& McGuire; Federal Regional Center 79 State. Street 130 228th Street, S.W.
- Newburyport, MA 01950'-
Bothell, Washington 98021-9796
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iA11en Lampert Peter J. Matthews, Mayor
. Civil Defense Director City' Hall P
. Town.of Brentwood Newburyport, MA 01950 20' Franklin Exeter, NH 03833 Michael Santosuosso, Chairman L
Board of Selectmen L
William Amstrong South Hampton, NH' 03827 i!
Civil Defense Director Town of'Exeter Ashod N. Amirian, Esq.
10 Front Street Town Counsel for.Merrimac p
Exeter, NH 03833 145 South Main Street P.O. Box 38 Gary W. Holmes, Esq.
Bradford, MA 01835 c
Holmes =& Ellis
?-
47 Winnacunnet Road Barbara J. Saint Andre, Esq.
- Hampton, NH 03842 Kopelman and Paige, P.C.
77 Franklin Street Boston, MA 02110 l:
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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 Atomic Safety and Licensing Appeal Panel (5)*
. U.S. Nuclear Regulatory Commission Washington, DC 20555 Docketing and Service Section*
Office of the Secretary l.
.U.S. Nuclear Regulatory Commission
' Washington, DC 20555
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dhoLf /d 3herwin E. Turk Counsel for NRC Staff
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