ML20090C482

Comments on W Eddleman Response to Order Requiring Addl Spec of Contention 215 Re Conservatism in Evacuation Time Estimates.Certificate of Svc Encl

ML20090C482
Person / Time
Site:	Harris
Issue date:	07/09/1984
From:	Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
References
OL, NUDOCS 8407130314
Download: ML20090C482 (11)

Text

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! UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION . ((0 BEFORE THE ATOMIC SAFETY AND LICENSINbod#_tD12 N0 37 In the Matter of ) h .[

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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' COMMENTS ON WELLS EDDLEMAN'S RESPONSE TO BOARD ORDER REQUIRING ADDITIONAL SPECIFICATION OF CONTENTION 215 Introduction In its Further Rulings on Admissibility of Offsite Emer-gency Planning Contentions Submitted by Intervenor Eddleman, at 24 (June 14, 1984), the Board addressed Eddleman proposed Con-tention 215, which alleges that there are numerous conserva-tisms in the Evacuation Time Estimates which may make the esti-mates unrealistically high and thus provide an unsound basis for prctective action decision-making.

The Board admitted Contention 215, but found that in its present form the contention requires further specification, "both to make litigation more valuable and to give the other parties fair notice of the subject of litigation." Id.

Mr. Eddleman was directed to serve on the Board and carties, by 8407130314 840709 '

PDR ADOCK 05000400 v 0 PDR

I June 29, 1984, a list of specific conservatisms in the Esti-mates he wants to litigate. Other parties were afforded the opportunity to file comments on such conservatisms by July 10, 1984.

On June 29, 1984, Mr. Eddleman filed his ". . . Response to Board Order Requiring Additional Specification of Contention

1. 215." Applicants herein submit their comments on the four "conservatisms" identified by Mr. Eddleman.

The contention and the Board's ruling both cite the Li-censing Board decision in Commonwealth Edison Company (Byron Nuclear Power Station, Units 1 and 2), LBP-84-2, 19 N.R.C.

(January 13, 1984), for the proposition that evacuation time estimates should aim for realism, and not employ conservatisms in a way which adversely impacts protective action decision-making. The thrust of Eddleman 215 is to challenge such con-servatisms. The deficiency in Mr. Eddleman's further specifi-cation of Contention 215, however, is that while he identifies assumptions, Mr. Eddleman fails either to explain why the as-sumption is conservative, or to assert that its impact on the estimates is significant (in terms of its influence on protec-tive action choices).

The evacuation time estimate (ETE) report compiled by HMM Associates for the Shearon Harris EPZ is a state-of-the-art analysis of representative evacuation scenarios. The analysis has been prepared using a computer simulation model and the guidance provided by NUREG-0654, Appendix 4. In undertaking

, the computer simulations it is necessary to provide detailed input data. The input data consists of existing statistical information, such as census data and roadway characteristics, and assumptions about activity that will take place during each scenario modeled. The assumptions incorporated into this anal-ysis are consistent with those used by HMM Associates in its compilation of ETE reports for other nuclear power plant sites.

In choosing the assumptions to be input to the evacuation scenarios HMM Associates attempted to be as accurate as possi-ble. However, where the simplifying assumptions in combination have some potential for error, the analysts have attempted to balance the overpredictive versus underpredictive assumptions to compile scenarios that are realistic or may be slightly con-servative (i.e., they include potential errors that may overestimate, slightly, the time required to evacuate rather than underestimate the time required.)

Comments on Specific Assumptions Eddleman Item 1: The assumption of evacuation from home. For certain times of day, this assumption is unrealistic for many persons who will not be at home, but be at work, school, shopping, doctor's office, etc. This could also result in double counting of evacuees for persons who both live and work within the EPZ (6/14/84 Order at 31).

Eddleman Item 4: The assumption in all of the evacuation scenarios that at least one person is at home at all residences. (See Estimates at 1-3, 1-4.)

The number of persons at school, the lakes, etc. varies according to more realistic criteria and these should too.

e In order to compile evacuation time estimates the analyst must consider several aspects of an evacuation scenario. The three major elements that must be considered are: (1) the time required to notify the population of the need to evacuate, (2) the time required for each segment of the population to prepare to evacuate, and (3) the actual travel time required to depart the area being evacuated. Federal guidance provides for considering these elements separately for permanen't residents, transient populations, and special facility population.

i NUREG-0654, Appendix 4, Figure 4.

In compiling the Shearon Harris ETE, it was assumed that the resident population will evacuate from their places of re-sidence. In other words, regardless of the location of the re-sidents of each home in the EPZ when notification is initiated, it is assumed that one vehicle will depart from the residence after notification and preparation for evacuation. Preparation to evacuate (Step 2 identified above), involves the formation of family units and packing of clothing, personal goods and valuables. This step may also require intermediate travel from the place at which notification is received to the residence for formation of family units and other preparation. This phe-nomenon is accounted for in the allotted preparation times, which range from 30 to 150 minutes from the governmental deci-sion to evacuate. ETE at 6-1.

This assumption does involve some double counting of peo-ple, since some workers and recreational patrons are permanent residents. It must be emphasized, however, that evacuation time estimates deal primarily with vehicle movements. This in-tentional double counting of some members of the population simulates implicitly, by adding vehicles to the evacuation routes, the traffic friction on the network due to travel to residences prior to actual evacuation. Consequently, the as-sumption may not mirror population numbers precisely, but it more accurately reflects vehicle activity on the evacuation network.

Eddleman Item 2: The assumption of one vehicle per household (Evac. Time Estimates, e.g. at 3-2/3-3).

Households with 2 vehicles may evacuate in both vehicles rather than linking up.

The assumption of more than one vehicle per household would be a conservative assumption that would tend to overestimate the numbers of vehicles evacuating and, therefore, the resultant evacuation time. Suggesting this more "conserva-tive" approach appears to be in conflict with the thesis of Eddleman 215 (i.e., to avoid unrealistically high evacuation time estimates' created by stacking conservative assumptions).

There are several reasons why an assumption of more than one vehicle per household would be unreasonably conservative:

A. Work and recreational trips are already accounted for in other assumptions as noted in the previous re-sponse.

B. In observations of evacuations from actual disasters auto occupancy has been in the range of 3-4 persons per vehicle. The ETE assumption is that there will be 2.7 permanent residents per vehicle, which is below the observed range. This assumption is conser-vative enough. Assuming more than one vehicle per household (in addition to the double counting inher-ent in transient and special facility populations) would be unrealistically conservative.

C. NUREG-0654 (App. 4 at 4-3) suggests a reasonable I range of two to three permanent residents per vehi-t cle. The assumed value of 2.7 fits within this range.

Eddleman Item 3: The apparent assumption that those households without vehicles will automatically evacuate with neighbors (or can) at the rate of one vehicle per household.

The methodology used in the Shearon Harris ETE assumes that vehicle occupancy rates for the non-auto owning population are similar to those for the auto-owning population: one vehi-cle per household. This is a slightly conservative, but en-tirely reasonable assumption. Such an assumption provides for i

! one vehicle trip to the residence to pick up anyone there. It does not matter, for evacuation time estimate purposes, whether that vehicle is operated by a friend, neighbor or emergency worker. Based on estimates of the non-auto owning population,

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4 at most this assumption could theoretically put 410 extra vehi-cles on the network (versus a total of 7347 required to accom-modate all permanent residents). ETE at 3-2. In practice, however, providing for these extra trips is a reasonable means for accounting for vehicles within the network following inter-nal routes to collect non-auto-owning passengers. Eliminating these vehicles altogether would tend to underestimate the time required to evacuate. This would also be inconsistent with the thesis of Eddleman 215. As a practical matter, the number of vehicles assumed to accommodate the non-auto-owning population is not significant. A reduction of a total of 410 vehicles would not reduce evacuation time estimates appreciably -- i.e.,

a reduction of 10 minutes might be achieved by changing this assumption to include no vehicles to handle the non-auto-owning population.

Conclusion The four assumptions identified by Mr. Eddleman illustrate the point made in the Introduction, supra, that the analysts who prepared the ETE used off-setting assumptions in an effort to achieve realism. Two of the assumptions identified by Mr.

Eddleman (Numbers 2 and 3), if altered to meet the apparent criticism, would result in underprediction of evacuation times

-- the very cpposite effect from the concern voiced in Eddleman 215 and in Byron, supra. In short, they do not support the basis for the contention but, rather, cut against it. The r

o other assumption (Numbers 1 and 4 appear to address the same issue) involves a conservatism, but Mr. Eddleman does not de-scribe how the assumption invalidates, if it does, the utility of the ETE for protective action decision-making. Consequent-ly, Applicants submit that the defects found by the Board in Contention 215 have not been cured and it should be dismissed for lack of specificity.

Respectfully submitted, Thomas A. Baxter, P.C.

Delissa A. Ridgway SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 Richard E. Jones Samantha Francis Flynn Dale E. Hollar CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Counsel for Applicants Dated: July 9, 1984 8

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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Comments on Wells Eddleman's Response to Board Order Requiring Additional Specification of Contention 215" were served this 9th day of July, 1984, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.

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Thomas A. Baxter, P.C.

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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN 1 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

i SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of U.S. Nuclear Regulatory Commission North Carolina Washington, D.C. 20555 307 Granville Road Chapel Hill, North Carolina 275 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Commission P.O. Box 12607 Washington, D.C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C. 20555 Charles A. Barth, Esquire Mr. Wells Eddleman Janice E. Moore, Esquire 718-A Iredell Street 4

Office of Executiva Legal Director Durham, North Carolina 27705 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Richard E. Jones, Esquire Office of the Secretary Vice President and Senior CounsC U.S. Nuclear Regulatory Commission Carolina Power & Light Company Washington, D.C. 20555 P.O. Box 1551 Raleigh, North Carolina 27602 Mr. Daniel F. Read, President Dr. Linda W. Little CHANGE Governor's Waste Management BoaG P.O. Box 2151 513 Albemarle Building Raleigh, North Carolina 27602 325 North Salisbury Street Raleigh, North Carolina 27611

s Brcdicy W. JonGs, Esquiro

' O.S. Nuclear Regulatory Ccmmission Region II 101 Marrietta Street Atlanta, Georgia 30303 Steven F. Crockett, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 ,

Administrative Judge Harry Foreman Box 395 Mayo University of Minnesota Minneapolis, Minnesota 55455 Spence W. Perry, Esquire Associate General Counsel FEMA 500 C Street, S.W., Suite 480 Washington, D.C. 20740 b