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Category:AFFIDAVITS
MONTHYEARML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc ML18016A8191999-02-12012 February 1999 Affidavit of G Thompson Re Application by CP&L for Amend to FOL NPF-63 & NRC Review of Application & Proposes to Determine That Amend Request Involves No Significant Hazards Consideration ML20209A9071987-01-28028 January 1987 Affidavit of JW Mckay.* Provides Minor Corrections to 861017 Affidavit.Corrections Should Be Made to Allegation on Undercut Tolerances for Holes Drilled to Receive maxi-bolt Anchors.Certificate of Svc Encl ML20214S1271986-09-25025 September 1986 Affidavit of Tw Brombach Re Allegations Raised in Ps Miriello 860728 Affidavit Concerning QA Filed in Support of 860915 Motion to Reopen Record.Allegations W/O Factual Basis.Util s to Jn Grace Re Insp Encl ML20214S1051986-09-25025 September 1986 Affidavit of SA Brown Re 860728 Affidavit of Ps Miriello Concerning Radiation Exposure,Filed in Support of Motion to Reopen Record.Allegations Re Exposure to High Levels of Radiation Unsupported ML20210B6471986-09-13013 September 1986 Affidavit of Ps Miriello Re safety-related Welds That Never Received Preservice Insp ML20205F3771986-08-0606 August 1986 Affidavit of Tw Brombach Re Issues Raised in 860702 Request for Institution of Proceeding Per 10CFR2.206,specifically Allegations on Inservice Insp of Piping Welds.Insp Rept 50-400/85-48 Encl ML20210E0171986-07-28028 July 1986 Affidavit of Ps Miriello Re False Dose & Const Records Constituting Threat to Public Health & Safety ML20210B6961986-07-28028 July 1986 Affidavit of Ps Miriello Stating That QA Quality Check Program Not Used as Intended at Facility ML20210U7691986-05-16016 May 1986 Affidavit of Ps Miriello Re Failure to Act on Issues of False Dose Records,Intimidation & Unsafe Radiation Practices Until After Contention W-4 Produced ML20210U7751986-05-15015 May 1986 Affidavit of Ps Miriello Re Health Physics Supervisors Ordering Author to Agree W/False Radiation Rept & to File NRC Form 4 in Agreement W/False Radiation Rept ML20204A4921986-05-0606 May 1986 Affidavit of SA Browne Re Results of Review of Ps Miriello 860403 Affidavit in Support of Conservation Council of North Carolina & W Eddleman Request for Admission of New Contention WB-4 ML20210K7041986-04-0303 April 1986 Affidavit of Ps Miriello Re Falsification of Exposure Records.Related Info Encl.W/Certificate of Svc ML20154N2091986-03-10010 March 1986 Suppl to HR Goodwin Affidavit on Timing of Weather Alerts, Per ASLB Request.Info on Precise Times That Weather Alerts Transmitted Unavailable.Certificate of Svc Encl ML20205K6031986-02-24024 February 1986 Affidavit of RW Fell,Supporting NRC Response to Aslab Question Re Conservation Council of North Carolina Contentions 16,17 & 18.Certificate of Svc Encl ML20137P5991986-01-30030 January 1986 Affidavit of Ti Hawkins,Supporting Nrc/Fema Response to Applicant Motions for Disposition of Eddleman Contentions EPX-2 & EPX-8.Certificate of Svc Encl ML20137F4171986-01-13013 January 1986 Affidavit of W Ethridge Re Contention EPX-2.Minor Highway Patrol Radio & Telephone Communications Delays During 850517-18 Exercise Were Due to Priority Assigned to Messages & Emergency Operations Ctr.Difficulties Being Resolved ML20137J0731986-01-13013 January 1986 Affidavit of Ah Joyner in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys.Certificate of Svc Encl ML20137F4101986-01-13013 January 1986 Affidavit of Dh Brown Re Contention EPX-2.Relay Procedure Is Normal Operating Procedure for Radiation Protection Section Communications & Causes No Significant Delays or Addl Inaccuracies ML20137F6491986-01-13013 January 1986 Affidavit of M Scott Re Contention EPX-2.Chatham County Responded Appropriately & Effectively to Experience Gained During 850517-18 Exercise.Addl Dispatchers Will Assure Response to Radio Traffic Levels.W/Certificate of Svc ML20137F6161986-01-13013 January 1986 Affidavit of Ah Joyner Re Contention EPX-2.Corrective Actions Being Taken to Resolve Communications Problems Experienced During 850517-18 Exercise.Resolutions Expected Prior to Full Power Licensing of Plant ML20137J0591986-01-10010 January 1986 Affidavit of R Capps in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys ML20136F6401985-12-31031 December 1985 Affidavit of Dn Keast Re Correction to 851104 & 05 Oral Testimony on Eddleman Contention 57-C-3.Certification of Svc & Notice of Withdrawal Encl ML20137L7951985-11-26026 November 1985 Affidavit of Wj Hindman Re Info on Age Distribution & Gender of Daniel Intl Corp Employees & First Line QA Inspectors at Facility.Certificate of Svc Encl ML20135H8321985-09-23023 September 1985 Affidavit of SL Burch Re Undercover Drug Operation at Facility.Related Correspondence ML20135H8371985-09-19019 September 1985 Second Affidavit of SL Burch Re Drug Investigation at Facility.Related Correspondence ML20137L6741985-09-0606 September 1985 Affidavit of P Miriello Re Drug Abuse Observed at Facility Const Site.Certificate of Svc Encl ML20134H4261985-08-23023 August 1985 Affidavit of Wp Haass Re ASLB Questions Concerning Whether Public Disclosure of Info Voluntarily Submitted to NRC Would Impair NRC Future Ability to Obtain Similar Info.Notice of Appearance of Ga Berry & Certificate of Svc Encl ML20135C0421985-08-23023 August 1985 Affidavit of Wp Haass Addressing Series of Questions Propounded by ASLB Re Whether Public Disclosure of Info Contained in Certain Applicant Documents in ASLB Possession Would Impair Staff Ability to Obtain Info ML20134E7891985-08-14014 August 1985 Affidavit of Wj Hindman Responding to SL Burch 850731 Affidavit Re Undercover Drug Investigation During Fall 1984 ML20134E7761985-08-14014 August 1985 Affidavit of MW King Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7661985-08-14014 August 1985 Affidavit of DG Joyner Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7831985-08-0909 August 1985 Affidavit of ML Plueddemann Re Fall 1984 Undercover Drug Investigation at Site ML20133A1111985-07-31031 July 1985 Affidavit of SL Burch Re Assertions in King Affidavit & Undercover Operation of Facility Concerning Drug Abuse. Intelligence Indicated Drug Dealings & Abuse Widespread. Certificate of Svc Encl ML20129H1061985-07-11011 July 1985 Affidavit of Nj Chiangi Re Allegation in Conservation Council of North Carolina Contention WB-3.QA Program Provides Necessary Steps to Ensure Safe & Reliable Power Plant.Certificate of Svc Encl ML20129H0941985-07-10010 July 1985 Affidavit of Wj Hindman Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const ML20129H0821985-07-10010 July 1985 Affidavit of Pb Bensinger Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const.Biography Encl ML20129H0911985-07-0909 July 1985 Affidavit of Jd Ferguson Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Cp&L Adopted Drug & Alcohol Interdepartmental Procedure.Resume & Procedure Encl ML20129H0991985-07-0909 July 1985 Affidavit of AR Pannill & Gw Flowers Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Employees Subjected to Preemployment Background Verification ML20129H0871985-07-0909 July 1985 Affidavit of MW King Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Use Widespread & That Mgt Failed to Control Drug Use During Const.Resume Encl ML20128M0401985-07-0808 July 1985 Affidavit of TS Elleman Supporting Util 850709 Application for Withholding Final Rept Shnp QA/QC-Const Inspector Review Panel, Per 10CFR2.790.Certificate of Svc Encl. Related Correspondence ML20128M0331985-07-0808 July 1985 Affidavit of HR Banks Supporting Util 850709 Application for Withholding Documents,Including Quality Check Rept,Concern/ Allegation Followup & Quality Check Procedure Investigation Rept,Per 10CFR2.790.Related Correspondence ML20116N7771985-05-0202 May 1985 Affidavit of Ti Hawkins in Support of Applicant Suppl to Motion for Summary Disposition of Eddleman Contention 213 Re Emergency Planning.Certificate of Svc Encl ML20116D0091985-04-25025 April 1985 Affidavit of Jf Myers Describing Recent Change to Provisions for Official Transportation Assistance for Persons in Emergency Planning Zone Needing Assistance in Event of Plant Emergency.Related Correspondence ML20112K0061985-04-0505 April 1985 Supplemental Affidavit of RG Black on Eddleman Contention 213.Provisions for Alert & Notification of Persons on Harris Lake Obviate Measures Suggested by Contention ML20112K0131985-04-0505 April 1985 Supplemental Affidavit of MR Bassiouni on Eddleman Contention 213.Rept of Proposed Siren Configuration & One Oversize Map Encl.Aperture Card Available in PDR ML20100B1011985-03-22022 March 1985 Supplemental Affidavit of Eh Harris Re Rev of School Evaluation Procedure Which Would Reduce Number of Students Riding Buses & Use of Buses Kept on Property During School Hours.Certificate of Svc Encl.Related Correspondence ML20107M5111985-02-27027 February 1985 Affidavit of Ti Hawkins in Support of Motion for Summary Disposition of Eddleman Contention 30.Emergency Response Plan Provisions Fully Comply w/NUREG-0654 ML20107K0411985-02-26026 February 1985 Affidavit of Ti Hawkins in Support of Applicant Motion for Summary Disposition of Contention EPJ-4(c).Prof Qualifications Encl.Certificate of Svc Encl 1999-04-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] |
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3 a
DXMUE0 UNITED STATES OF. AMERICA "F 0 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BO M 17 P1 :59
(. . y.
In the Matter of )
)
, CAROLINA POWER & LIGHT COMPANY )
and NORTH CAROLINA EASTERN ) Docket No. 50-400-OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant) )
AFFIDAVIT OF ROBERT D. KLIMM IN SUPPORT OF APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF WILSON CONTENTION 12(b)(2)
County of Suffolk )
) ss.
Commonwealth of Massachusetts)
ROBERT D. KLIMM, being duly sworn, deposes and says:
- 1. I am an Associate of HMM Associates, Inc. My business address is 336 Baker Avenue, Concord, Massachusetts 01742. A summary of my professional qualifications and experience is attached hereto as Attachment A. I make this Affidavit in response to Wilson Contention 12(b)(2). I have reviewed this' contention and am familiar with the substance of the allegations contained therein. I have personal knowledge
/
- of the matters stated in this affidavit and believe them to be true and correct.
- 2. HMM Associates is an engineering and planning firm specializing in emergency response planning for the nuclear i 8501180470 850114 PDR ADOCK 05000400 0 PDR ;i
_- ~
industry. HMM Associates offers services in the areas of evacuation studies, radiological emergency response plans, dose projection systems, training, and implementing procedures, among others. My responsibilities at HMM Associates include
'the management and supervision of evacuation time studies. I have served as either Project Manager or Principal Transportation Engineer for many of the more than twenty evacuation time analyses conducted by HMM Associates in connection with emergency planning for nuclear power plants. I am also responsible for all transportation-related computer analyses conducted by HMM Associates. I was involved in the system development of the NETVAC evacuation model, which is a state of the art computer evacuation simulation model. The NETVAC model has been used to estimate evacuation times for approximately 20 nuclear power plant sites. I co-authored the NETVAC model users manual. In addition, I have provided training to various groups on the use of the NETVAC model.
3.- HMM Associates was contracted by Carolina Power &
Light Company to develop evacuation time estimates for the Shearon Harris plume exposure Emergency Planning Zone ("EPZ")
pursuant to NUREG-0654; FEMA-REP-1, Rev. 1, November 1980. The resulting time estimates developed by HMM Associates as well as the underlying analyses and assumptions are set forth in a
' formal study entitled " Evacuation Time Estimates for the Plume Exposure Pathway Emergency Planning Zone of the Shearon Harris Nuclear Power Plant" (October 1983) (hereinafter referred to as
_2
s the "ETE"). I was the Principal Transportation Engineer for the study responsible for the supervision and review of all technical analyses conducted as part of the study.
- 4. NUREG-0654, Appendix 4 and NUREG/CR-1745, Analysis of Techniques for Estimating Evacuation Times For Emargency Planning Zones, US NRC (November 1980) provide detailed guidelines to be used in the preparation of an evacuation time estimate study. They require estimates of the number of vehicles that will be involved in an evacuation, the capacity of the road network to handle these vehicles, and the total estimated time to evacuate under various conditions and assumptions. The-total time to evacuate includes the time required to notify the population of the need to evacuate, the time required for each segment of the population to prepare to evacuate and the actual travel time to depart the area bsing evacuated. Federal guidance provides for considering these elements separately for permanent residents, transient 4
populations and special facility populations.
- 5. An integral part of preparing a time evacuation study is the estimation of the number of vehicles that will be involved in an evacuation. The methodology used by HMM Associates in estimating vehicle demand took into account
! documented assumptions on vehicle occupancy and anticipated evacuation characteristics associated with each individual population category (i.e., permanent residents, transients and special. facilities). The vehicle demand estimates were based l
l :
b.
upon (1) federal guidance found in NUREG-0654, Appendix 4 and in NUREG/CR-1745; (2) knowledge and experience obtained by HMM Associates in conducting similiar evacuation time studies for more than 20 nuclear power plant sites throughout the country; (3) reviews by HMM Associates of empirical data on past evacuations, and (4) discussions with State and County emergency preparedness officials.
- 6. For permanent residents, HMM Associates assumed that for households with automobiles one vehicle per household would be used in evacuating the EPZ. This assumption was used and considered valid for all conditions including evacuation during day or night periods and evacuation during fair or adverse weather conditions. This assumption is consistent with the Federal guidance found in NUREG-0654, which states that:
The number of permanent residents shall be estimated using the U.S. Census data or other reliable data, adjusted as necessary, for growth. (See planning element J.lO.b.). This population data shall then be translated into two subgroups: 1) those using autos and 2) those without autos. The number of vehicles used by permanent residents is estimated using an appropriate auto occupancy factor. A range of two to three persons per vehicle would probably be reasonable in most cases.
An alternative approach is to calculate the number of vehicles based on the number of households that own vehicles assuming that one vehicle per household is used in evacuation. Regardless of the approach used, special attention must be given to those households not having automobiles. The public transport-dependent population must, therefore, be considered as a special
-. .-~
case.1/
NUREG-0654, Rev. 1 at page 4-3. Identical guidance is found in NUREG/CR-1745 at page 21. Additionally, this assumption is consistent with documented public emergency response phenomena indicating that families generally seek to unite and to remain
. united in times of emergency and therefore, as explained in the affidavit of Dr. Dennis Mileti on Wilson Contention 12(b)(2) and Eddleman Contention 215(1), families are likely to evacuate in a single car from their place of residence instead of separating into two or three cars.
- 7. The estimate of one vehicle per permanent household is a simplifying assumption. Some households may in fact
'1/ As reflected in the quotation above, regardless of which of the two assumptions set forth in Appendix 4 is used, the public transport-dependent population is to be consid-ered as a special case and a separate estimation of the vehicles to be used by this subcategory in evacuating the EPZ is required. HMM Associates did a separate analysis for this subcategory here. Following lengthy discussion with relevant state and local emergency preparedness offi-cials, it was determined that one vehicle per household for this subcategory, under the local conditions expected to occur, was a reasonable assumption to account for the traffic generated by the collection and evacuation of the nonauto-owning population out of the EPZ. Accordingly, although the result of different analyses, it happens in this case that one vehicle per household was used for households that do not own automobiles as well as for
=those that do. Wilson Contention 12(b)(2) obviously fo-cuses solely on the estimation of vehicle demand for the
' auto-owning population and therefore my statements in this affidavit are limited'to that analysis. Accordingly, whenever this Affidavit makes reference to permanent resi-dents or permanent households or one vehicle per house-hold, or the like, the unstated limitation is permanent residents owning vehicles or households owning vehicles or the like.
a 4
evacuate with two or three vehicles. On the other hand, however, other residents may be out of the area at the time or may evacuate with relatives, neighbors or friends. Use of one vehicle per household produces a reasonable estimate, consistent with federal guidance, of vehicle demand associated with this population segment based upon what is known about public response to emergency situations. HMM Associates has used the assumption of one vehicle per household in a majority of its more than 20 evacuation time analyses conducted in connection with emergency planning for nuclear power plants.
All of these studies, except for several currently in the review process, have been reviewed and found acceptable by the Nuclear Regulatory Commission.
- 8. In those instances where HMM Associates has used an estimate different from one vehicle per household, it used vehicle occupancy factors of between 2 and 3.2 persons per vehicle to estimate vehicle demand. The use of these factors, which are also consistent with the federal guidance quoted above, was reached after discussions with the relevant state and local officials to account for site specific characteristics.
- 9. Using this alternative approach for calculating vehicle demand in conjunction with the Shearon Harris facility produces a result virtually identical to the assumption of one vehicle per household. The average household size within the Shearon Harris EPZ is approximately 2.7 persons per household.
U Accordingly, the assumption of one vehicle per household translates to approximately 2.7 persons per vehicle, which is in the range of that considered reasonable in NUREG-0654, Rev.
1 and NUREG/CR-1745.
- 10. The primary function of an evacuation time study is to provide a realistic estimate of the time to evacuate the EPZ for the purpose of aiding officials in determining the appropriate course of protective action to follow in an emergency situation. An overly conservative estimate of the time necessary to evacuate the EPZ may result in officials deciding not to evacuate the EPZ when evacuation may in fact be the appropriate protective action to undertake.
- 11. An assumption of more than one vehicle per household (such as 1.5 or 1.75) would be an overly conservative assumption that would tend to overestimate the number of vehicles used in the evacuation of the EPZ and therefore overestimate the evacuation time of the EPZ. There are several reasons why such an assumption would be unreasonably conservative.
- a. First, an assumption such as 1.5 or 1.75 vehicles per household would greatly exceed that deemed reasonable by FEMA and the NRC as set forth in NUREG-0654, Appendix 4. The guidance set forth in Appendix 4 reflects NRC's and EEMA's regulatory judgment as to the assumptions that will in most circumstances a
produce reasonable, realistic evacuation time estimates. There is nothing atypical with respect to the evacuation of the Shearon Harris EPZ that would suggest or dictate differing assumptions here.
- b. Second, assuming that households with 4
more than one car would utilize two or more vehicles in evacuating the EPZ is contrary to the documented public emergency response phenomena referred to above which indicate that families generally seek to unite and to remain united during times of emergency. As explained in the Affidavit of Dr. Dennis Mileti on Wilson Contention 12(b)(2) and Eddleman Contention 215(1), as a result families will in all likelihood use one vehicle to evacuate the EPZ, not two or three as alleged in Wilson Contention 12(b)(2).
- c. Third, an assumption such as 1.5 or 1.75 vehicles per household is contrary to the experience gained by HMM Associates in the more than 20 evacuation time studies that it has undertaken for nuclear power plants throughout the country. In those situations, even though many households owned more than one vehicle (as is typical in the United States) the demand
estimate of one vehicle per household (or a vehicle occupancy factor that produced close to the same overall vehicle demand) was considered to be reasonable by federal and state emergency preparedness officials alike. These officials, who on the whole have had substantial experience both in emergency planning and emergency response, have found the vehicle demand estimates utilized by HMM Associates to be reasonable and to produce what they considered to be realistic evacuation time estimates.
- 12. In his response to Applicants' Interrogatories on Wilson 12(b)(2), Dr. Wilson suggested that a worst case assumption, apparently such as 1.5 or 1.75 vehicles per household, should be investigated even though such a worst case need not be incorporated as the basis for planning protective actions. Utilizing vehicle demand estimates of 1.5 and 1.75 a
vehicles per household, HMM Associates has computed the evacuation time estimates for evacuating the full EPZ under the four conditions evaluated in the ETE: summer weekday (good weather), summer weekend (good weather), late fall weekday (adverse weather) and summer evening (good weather). The results of these computations in comparison with those for a vehicle demand estimate of one vehicle per household are set forth in the following table:
Evacuation Times in Minutes For The Entire EPZ Under Different Vehicle Demand Assumptions 1 vehicle / 1.5 vehicles / 1.75 vehicles /
Household Household Household Summer Weekday 193 226 247 (Good Weather)
Summer Weekend 174 192 210 (Good Weather)
Fall Weekday 236 272 290 (Adverse Weather)
Summer Evening 172 175 191 (Good Weather)
As reflected in the table, the evacuation time estimates are sensitive to assumptions on the number of vehicles per househcid, particularly for the summer weekday good weather case (due to the peak population) and the late fall weekday adverse weather case (due to the reduced roadway capacities).
Variances in the assumption of the number of vehicles per i household, however, are less significant for the summer weekend and summer evening good weather cases where the total vehicle demand in the EPZ would be lower. However, for the reasons stated in paragraph 11, the evacuation times resulting from vehicle demand estimates of 1.5 and 1.75 vehicles per household are unreasonably conservative and should not therefore be used as the planning basis for determining the appropriate protective responses in the event of an emergency.
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- 13. In summary, the assumption of one vehicle per household is used to give a realistic estimate of the evacuation time of the EPZ for use in determining the appropriate protective response in the event of an emergency.
This assumption is in accordance with federal guidance and public response phenomena in emergency situations and has been used and accepted in numerous other evacuation time studies '
for nuclear power plants.
Robert D. Klimm Sworn to and subscribed before me this /CTN day of January, 1985. ,
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No &ry Pu lic My Commission exp* ires:
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- 1 Attachmsnt A ROBERT D. KLIMM E duca tion M.S. Civil Engineering (Transportation), Northeastern University, 1979 B.S. Civil Engineering, Worcester Polytechnic Institute, 1975 Summary of Experience Mr. Klimm specializes in transportation engineering and emergency preparedness / evacuation planning. He has served as
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Project Manager or Technical Advisor on most of the evacuation time estimate analyses conducted by HMM. He also has been responsible for numerous emergency preparedness tasks for nuclear power plants including: the development of school facility evacuation plans and procedures; the development of evacuation and population data for CRAC2 and CRACIT consequence modeling; and the development of evacuation routings and time estimates for special facilities.
Mr. Klimm was involved in the system development of the NETVAC
-evacuation simulation model, which has been used at 20 nuclear power plant sites throughout the country. He has provided gr training to groups that have been licensed to use the NETVAC model, and was responsible for conducting an Evacuation Time lL. Estimate Workshop for Public Service Electric and Gas Company of New Jersey.
Professional Experience 1980 - HMM Associates. Mr. Klimm serves as Project Present Manager and/or Principal Engineer for projects involving emergency preparedness planning and emergency evacuation. Recent experience includes the following: ,
o Principal Engineer for the development of evacuation time estimates for the Susquehanna Steam Electric Station (Luzerne County, Pennsylvania, 1981).
o Project Manager for the preparation of supplemental evacuation time estimates for the Midland Nuclear Power Plant (Midland, Michigan, 1983).
o Project Manager for the development of evacuation time estimates for the O.C. Cook Nuclear Plant (Berrien County, Michigan, 1984).
a ROBERT D. KLIMM Page 2 o Project Manager for the development of an Evacuation Traffic Management Plan for the Midland Nuclear Power Plant Plume Exposure EPZ (Midland, Michigan, 1983),
o Principal Engineer for the preparation of evacuation time estimates for the Shearon -
Harris Nuclear Power Plant (Wake County, North Carolina, 1983).
o Project Manager for the development of an Evacuation Traf fic Management Plan for the primary Plymouth Station Evacuation Relocation Center (Hanover, Massachusetts, 1983).
o Principal Engineer for the development of population and evacuation data for CRACIT radiological consequence modeling within the Seabrook Station EPZ (Seabrook, New '
Hampshire, 1963).
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Project Manager for the development of an Evacuation Traf fic Management Plan for the Seabrook Station Plume Exposure EPZ, (Seacrook, New Hampshire,1982).
o Project Manager for the preparation of evacuation time estimates for the Grand Gulf Nuclear Station (Clairborne County, ,
Mississippi, 1981).
1977-1980 Fay, Spofford & Thorndike, Inc. Transportation Engineer., Responsible for traf fic operations analyses; traffic control design, sp ecifica tions and cost estimates; transportation environmental impact analyses; highway safety analyses; truck .
circulation studies, and traffic circulation plans for private and public developments.
r 1975-1977 Central Massachusetts Regional Planning Commission. Transportation Engineer / Planner.
Responsible for transportation corridor planning studies, transportation systems management, traffic operations analyses, and coordination of the regional transportation air quality control plan.
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ROBERT D. KLIMM Page 3 Other Professional Data Affiliations: Transportation Research Board: National Academy of Sciences Institute of Transportation Engineers American Society of Civil Engineers Boston Society of Civil Engineers Papers / o Klimm, R., " Comparison of Optional Cycle Publications: Lengths for an Urban Arterial Signal System" Using Maximum Bandwidth and Minimum Vehicle Delay Criteria," Northeastern University, 1979.
o K11mm, R., " Fringe Parking and Intermodal Transportation System--Feasibility Study,"
CMRPC, 1976.
o Klimm, R., Sheffi, Y., Mahnassani, H.,
Powell, W., NETVAC2 USER MANUAL," HMM A s socia t e s , 1962.
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