ML20247M532
| ML20247M532 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/27/1989 |
| From: | Fierce A MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20247M539 | List: |
| References | |
| CON-#289-8378 OL, NUDOCS 8904060076 | |
| Download: ML20247M532 (9) | |
Text
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USNnC UNITED STATES OF AMERICA 3;
NUCLEAR. REGULATORY COMMISSION
'89 mR 30 A11:02 ATOMIC SAFETY AND LICENSING BOARDyrgn
' GCCl4i o,..
Before the Administrative Judges:
i N Ml '
Ivan W.
Smith, Chairman Dr. Richard F. Cole Kenneth A. McCollum l
)
In the Matter of
)
Docket.Nos. 50-443-OL
)
50-444-OL PUBLIC SERVICE COMPANY
)
(Off-Site EP)
OF NEW HAMPSHIRE, _ET_ _A_L.
)
).
(Seabrook Station, Units 1 and 2)
)
March 27, 1989
)
MASSACHUSETTS ATTORNEY GENERAL'S RESPONSE ON THE ISSUE OF RETURNING COMMUTERS AND THEIR IMPACT ON EVACUATION TIME ESTIMATES In issuing its PID on the New Hampshire Radiological Emergency Response Plan ("NHRERP"), the Board reserved jurisdiction over the issue of-returning commuters and the impact they would have on evacuation. time estimates ("ETEs").
PID, 59.60.
Subsequently, the Board elected to receive further written submissions from the parties first from the Applicants and then from the Massachusetts Attorney General
(" Mass AG").
On January 25, 1989, the Applicants filed an affidavit of Edward Lieberman ("Lieberman Affidavit") and a legal memorandum arguing that returning commuters would have no significant impact on evacuation times for the Seabrook EPZ.
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LIn response to the Lieberman Affidavit, the Mass AG files h'erewith the " Affidavit of-Dr. Thomas J.
Adler Regarding the Interaction o'f Commuter Flow and Evacuation' Traffic Flow Within The Seabrook'EPZ"-(the'"Adler Affidavit").
In.this Affidavit,-
'Dr.-Adler both (a) responds to some'of the comments made byfthe i.;
Board in its'PID and (b) refutes all the arguments in the Lieberman Affidavit.
He also reasserts his opinion that the reliable evidence indicates that if a fair-minded effort were L
made to explicitly model returning commuters there could be-a l
.significant impact (as much as several hours) on the ETEs for a number of " regions" (the sub-parts of the EPZ for which PARS are made) under a number of different scenarios.
Based on Dr. Adler's affidavit and the other evidence now available, the Mass AG makes the following argument:
1.
The Board is simply not correct in concluding, as it did in S9.52.of the PID, that." commuters working at the beach, during the peak summer season, would clearly constitute a major portion:of,the problem."
The problem. lies elsewhere and concerns. thousands of returning commuters, not from~the' I
beaches, but from other locations within and outside the EPZ when an emergency occurs on a weekday any time _of the year.
See Adler Affidavit, 124.
2.
One must keep in mind, as Mr. Lieberman does not, that the NHRERP's Volume 6 contains dozens of ETES for different Regions and Scenarios.1!
See Volume 6, Tables 10-4 through 1/
The different Regions and Scenarios are described in Tables
~
10-1 and 10-2 of Volume 6 (attached hereto as Exhibits 1 and 2). - _ _ _ _ _ - _ _ _ - _ _ -
t F
10-8.One must'also keep in mind.that protective action recommendations are evaluated and'made,on an ERPA by ERPA basis.2/
- See, e.g., NHRERP, Volume'4,.SF.
This means that' it is. nearsighted'and misleading to focus one's analysis of the impact'of returning commuters on only1 the "overall" ETE'(i.e.,.
' Region 1 -- the entire EPZ) or on the:" critical paths".for just the beach-evacuees.
Yet this is what Mr. Lieberman does.
This ignores, for example, the " critical paths" for the City of Portsmouth (in ERPA-G) in'the wintertime, paths which thousands of returning commuters from within and without the EPZ are likely to enter and/or cross during a mid-week, mid-day emergency.
The impacts of returning commuters on each of these ERPA-specific. critical paths needs to be explicitly modeled in order to have.an accurate set of ETE tables for the mid-week /mid-day scenarios.
Figures.10-3b.and 10-3c of Volume 6, attached to Dr. Adler's Affidavit, display dozens of congested roads throughout the EPZ (and especially in the Portsmouth and Newburyport areas) at only 1 and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after-an Order to Evacuate for Scenario 5 (off-season, mid-week,.
mid-day, good weather).
It is along these roads that the impact of returning commuters needs to be carefully assessed by explicit modeling.
3.
The 15% capacity reduction factor was programmed into the IDYNEV model simply to obtain an approximate service volume 2/
ERPAs are " Emergency Planning Response Areas".
A map delineatiniating the Seabrook EPZ ERPAs is contained in Volume 6 (Figure 10-1).
(That figure is attached hereto as Exhibit 3.)
l for congested LOS F traffic, see. Volume 6 at'3-4, not to 1
-account for counterblow or other commuter traffic.
See Adler
[
'This was not'a " conservative" estimate of the 118.
LOS F. service volume either.
Dr. Ceder, a much-more qualified-expert in the-field of transportation science, testified-that' LOS'F-service volume should be reduced 25%, not 15%.
- Ceder, fol..Tr. 5169 at 16-19.
There is no " conservatism" in this reduction' factor to slop over and rescue Mr. Lieberman here.
Even if there were,-Applicants should not be permitted to use it'in the arbitrary way Mr. Lieberman does, as this would violate the principle that holds:
Conservatism and margins for' error in such calculations must be footed to some extent in reasonable, scientific ground.
Conservatism upon conservatism can distort technical data to the point where it no longer meaningfully describes the mechanism at issue.
Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), ALAB-819, 22 NRC 681, 736-737 (1985).
To be
" footed to some extent in reasonable, scientific ground,"
l estimates of the impacts of returning commuters must be based on some reasonable attempt at explicit modeling.
4.
Mr. Lieberman ignores the significant commercial strip, t
growing every year, along Route 1 in Seabrook and Hampton l
Falls.
This strip caters to tourists and residents alike and is busy on weekends, not just in the summertime, but throughout the year.
Employees and local shoppers living to the north, west, and even to the south would likely seek to use Route 1 and Route 101C in significant numbers to leave this commercial strip and return home.
1 5.
' Explicit modeling of commuter trip is'only a modest i
extension of the.modell'ng work' completed to date,-is necessary for an accurate estimation.of'ETEs for all regions, and'could be done for.a-reasonable cost without undertaking an extensive telephone survey.
See Adler~ Affidavit, 126.
CONCLUSION The' Board shculd enter an order finding that until there
'has been a fairminded effort to explicitly model the returning commuters'. trips, there can be no reasonable assurance that the NHRERP's ETEs, especia11y'for the weekday. scenarios and the j
less-than-full EPZ evacuations, are sufficiently realistic to aid protective action decision-makers in making informed decisions about protective actions for the non-beach areas.
I This is not to say that every commuter trip needs to be modeled.
Instead, some. reasonable effort to model the
. returning commuters needs to be made, along the lines suggested oy Dr. Adler.
Because this modeling effort could be attempted in various ways, and because the Applicants have not only resisted undertaking this effort but think it to be unnecessary, the l
Board needs to ensure that the task is completed in a fair, thorough, and workmanlike manner. -To that end, the Board should order that when (and if) the Applicants complete this modeling effort and offer up its results to the State of New Hampshire for incorporation into the ETE study (Volume 6),
a copy of the results, including all relevant IDYNEV runs and other data analyses, must be provided to the Interveners, who
- . k will then:have~30 days to challenge the-results by filing an affidavit detailing.their objections, if any, with the Board..
The Board should retain. jurisdiction.;of this issue.
L..
Respectfully submitted, COMMONWEALTH OF MASSACHUSETTS JAMES M.~SHANNON ATTORNEY' GENERAL d
Allan R.
Fierce Assistant Attorney General Nuclear Safety Unit
. Department of the. Attorney General.
l One Ashburton Place Boston, MA 02108-1698 (617) 727-2200 DATED:
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EXIIIBITL 2 -
Table 10-2.
Identification of the Seabrook Station Emergency Planning Areas (ERPA)
Recion Seatial Extent IEEA Designation 1
To EPZ'bdry.
A-G Entire EPZ l
2 To EPZ bdry.
A, D, G Entire North Region 3
To EPZ bdry.
A, C,
F Entire, West Region i
4 To EPZ bdry.
A, B, E Entire South Region 5
To Five Miles A,
B, C,
D Entire Five-Mile Region 6
To Five Miles A, D Inner North Region 7
To Five' Miles A,' C Inner West Region-8 To Five Miles A, B Inner South' Region 9
To Two Miles A
Entire Two-Mile Region 10 Beach Areas Portions of Beach Areas A,B,D,E,G NOTES:
1.
All beach areas are always completely evacuated'in S cenario,% 1-4, including those outside the Region ordered to evacuate.
It is assumed that beaches are closed at the Alert stage of the Emergency and that evacuation of the beach areas begins 20 minutes before the order to evacuate a specified region.
2.
It is assumed that 25 percent of the population within the EPZ, but outside the Region ordered to evacuate, will spontaneously evacuate, contrary to instructions.
It is'also assumed that an additional 3,000 "through" vehicles, not otherwise counted, are on the highway when the Alert is announced.
See f A q : Re se. x gterad-wlere.1" f40
{'137'TheouterboundariesofRegions5-9aregenerally town boundaries which extend, somewhat, beyond the indicated distances from Seabrook Station.
Thus, for each of :hese regions, the indicated radius is an aceroximstion and should not be interpreted
,literallt.
10-3
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l Figure 10-1.
Map of CPZ Dolincating all Emergency nesponce Planning Arcos (CRPA) 10-4 I