ML20149N066

FEMA Evaluation of State of Nh Response to FEMA Supplemental Testimony.* Urges FEMA to Consider New Info Developed During Hearings on State of Nh Radiological Emergency Response Plan Re Evacuation Time Estimates.Related Correspondence

ML20149N066
Person / Time
Site:	Seabrook
Issue date:	02/23/1988
From:	Fierce A MASSACHUSETTS, COMMONWEALTH OF
To:	Flynn H Federal Emergency Management Agency
References
CON-#188-5692 OL, NUDOCS 8803010088
Download: ML20149N066 (14)

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, M THE COMMONWE ALTH OF M ASS ACHUSETTS

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j g {J DEPARTMENT OF THE ATTORNEY GENERAL L

',tj kM [ .lOHN W. McCoRM ACK STATE OFFICE BUILDING

?' i ONE ASHBURTON PLACE. BOSTON O21081698

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1E FEB 26 P4 :01 glA'IED CORRESPO_NDJEN

1. 1. " "~ "

JAMES M. SHANNoN --

ATTommer orwenat V**';.

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Feoruary 23, 1988 H. Joseph Flynn, Esq.

Assistant General Counsel Federal Emergency Management Agency .

500 C Street, S.W.

Washington, DC 20472 Re: FEMA's Evaluation of the 'lew Hampshire Response to :EMA Supplemental Testimony

Dear Joe:

I Jnderstand that FEMA and the RAC are now in the process of evaluating the New Hampsnite Response to FEMA Supplemental Testimony (iew Hampshire Response") and that on :tarch 14, l 1983, FEMA vill announce its updated position on the so-called l l

oesch/shelteting contentions at issue in the '1HR**?

litigation. Because FEMA's ptevious position statement on

.nese is.nes relied, to some extent, on the evacuation time estimates ('ETEs') contained in Volume 6 of Revision 2 of the 1

N M R F,R p , I am writing now to ensure that FEMA does not tely on those same ETEs as it te"lews the New Hampshire Response. The sunnet weekend ETEs contained in Volume 6 are no longer accurate, if they ever wete, and the Applicants ntke this clear in updated (longer) ITEs submitted as part of their direct 0

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4 pre-filed testimony on the ETE issues in the NH9ERP litigation. See Applicants' Direct Testimony do. 7'(Evacuation Time Estimate and Human Behavior in Emergencies).(' Applicants No. 7") at 41-44-(attached heteto as Attachment.l's.1!

tioteover, during the course of the NHRERP litigation, the Intervenors submitted substantial evidence that.(1) an orderly

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, vehicular evacuation of the Seabrook EPZ beach areas may not be -

oossible when the beaches are crowded and (2) even if an i

orderly vehicular evacuation were achievable, the realistic ~- -

l summertime ETEs for days when the beach area vehicular population is at capacity (Scenarios 1 and 2)'are at least j 50-100% longet than the times presented in the Applicants' l 1 i opdat.sd ETEs. See generally the direct testimony of Thomas Adler, Avishai Cedet, and Albert Luloff, and the rebuttal testimony of Edwin Oliveta. Thus, while what the ,

1 cuttent tealistic ETEs for Seabrook are is a natter of serious dispute, no one at the hearings has contended that the Volume 5  !

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1 1/ These updated ETEs are presented in four tables, each for an evacuation from "within" a given area (the 2, 5, and 10 mile rings and the EPZ boundary itself). These areas are depicted on the map attacned as Attachment 2, a map taken from the NHRERP Rev. 2. For each table, ETEs are listed for Scena:ios 1 l and 2. These are both summer weekend full-besch ETEs, the i first for an evacuation which occuts during good weather, the second for an evacuation during and after a sudden rain. The definition of the Vatious evacuation Scenarios fron Volume 6 is attacned heteto as Attachment 3. Each of the four tables lists, for Scenarios 1 and 2, the ETEs fot Regions'l-9 and j 11-13. Regions 1-9 are identified in Tacle 10-2 in volune 6, i attached hereto as Attachment 4. ~ Regions 11, 12 and 13 are j identified on p. 41 of Applicants' No. 7 (contained in Attachment 1). The ERPAs used to identify the various Regions  !

1 are themselves identified in Table 10-3 in Volume 6, attached hereto as Attachment 5.

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ETEs for the summet scenarios vete realistic for he 1937-1938 time period.

Given that the state of'the ITE tecord has changed gignificant'.y since FEMA last. stated its "cuttent position" tegarding the btach/ sheltering issues, what FTEs if any should FEMA and the.RAC use now in assessing.the New Hampshire Response? The Intervenots utge FEMA and the RAC to considet carefully the whole ETE tecord developed in the NHRERP hearings before drawing conclusions about whether orderly vehicular evacuation is possible and, if so, what ETEs are most realistic and should be applied in reviewing the New Hampshire Response.

In out view, the whole tecord demonstrates that a set of realistic ETEs for the beach areas have yet to be calculated.

Oat expett, Dt. Adler, presented substantial evidence showing that Applicants' ETEs are much too low, and he testified that the Scenario 1/ Region 1 ETE is over 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, but he did not compute a conplete set of ETEs. See Testimony of -

Tnomas J. Adler (following Tr. 3847) at 52-53 (atta:hed hereto as Attachnent 6). We believe the Applicants should ce directed t'o re-compute the ETEs in the mannet which out experts, Dr. Adlet and Dr. Cedet, have tecommended, and we would encoutage FEMA and the RAC to support this effort. In any event, as they review the New Hampshire Response, FEMA and the RAC should not do any of the following at this time:

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1. FEMA anc the'RAC should not assume that an orderly,. s efficient vehiff atlevacution from the Seabtook EPZ beach ateas ^

can'be achieved when the beaches are crowded. IThe testimony presented by a nunber of-intervenot' witnesses has painted a ,

t very chilling pottrait of whatsthe traffic situation will be like aftet the beach areas are ordeted evacuated on days when these areas are crowded. At best, the traffic flow will be i what tne traffic engineers call "Level of Settice F," that-is, extremely conge'sted flow in which long queues are formed an'd

stop-and-go operations result. Traffic congestion will be so i

sevete, and will last for so long, that many evacuees will likely abandon their cars, finding it faster to walk than to j drive. See, e.g., Testinony of Thomas J. Adler (following Tt. l 3347) at 15-18 (contained in Attachnent 6). See also Testimony 1

of Albert E. Luloff (following Tr. 3203) at 14-15 (attached i

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hereto at Attachment 7). The traffic situation Vill be fat worse than that which exists when the beach areas enpty on busy days. Adlet Test, at 13-14 (see Attachment 6). Because traffic delays will be so lengthy, drivet frustration will tesult in traffic disorderliness that will further jeopardi:e j

an orderly, efficient evacuation. See, e.g., Rebuttal l

J Testimony of Edwin J. Olivera (following Tt. 9433) at 5-8 (attached hereto as Attachment 3). Taken together, this

testimony is compelling and cannot be ignored. FEMA and the RAC nost at least acknowledge that serious, credible doubt exists about the feasibility of an orderly vehicular evacuation from the beach ateas when they are etowded.

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2. FEMA and the RAC should not reference the

' unrealistically short sunner weekend ETEs contained in Volume 6 of the NMRERP, ETEs which no witness at the '!9RER? otoceedinqs l

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estified wete realistic for the beach population in'the sur.9et t t

of 1937 As noted above, the Applicants'themselves have submitted updated (longer) summer weekend ETEs as part of theit-prefiled testimony in the NHRERP litigation. (See Attachnent ,

1.) These updated ETEs are longer than the Volume 6 ETEs because a number of the input variables to the IDYNEV compu't'et ,

model were increased. First, as a result of aetial photos ,

taken by the Applicants on one day last sunner the nunbet of c beach area vehicles used to calculate the summer weekend ETEs

was increased by alnost 4000 vehicles, from 25,470 in Vol. 6 to j l

4 29,293 for the updates. There were many more cars seen parked (

in the beach area in these photos than in the photos taken in l August 1985 which formed the basis for the beach atea vehicle  !

1 estimates used in the Vol. 6 ETE calculations. See general-ly i

j Applicants' No. 7 at 27-38. Another IDYNEV input variable 1

which the Applicants changed in doing their updated ETE calculations is that which describes the extent of voluntary public evacuation. The volume 6 ETEs were based on the single

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] assumption "that 25 percent of the population within the EP3,

! but outside the Region ordered to evacuate, ' fill spontaneously i

! evacuate, contrary to instructions." Vol. 6 at 10-3. In i 1

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calculating ETE updates, however, the Applicants also I

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consideted the effects of a "keyhole voluntaty evacuation" that would include 50% of the population outside of a wedge-shaped subsegment of the E?Z (e.g., the innet north Region -- ER?As A and B -- from 2-5 miles) if that subsegnent were ordered to evacuate. See generally Applicants' No. 7 at 160.

FEMA and the RAC snould keep in nind that Intervenots submitted substantial evidence that the numLat of beach area vehicles used to compute these updated ETEs is still much too low, and tnat concentric voluntaty evacuation will be highet than Applicants have now assumed. Nevertheless, the point is that no one considers the Volume 6 summer weekend ETEs to be realistic at this time.

3. FEMA and the 9AC should not reference the Region 10 ETEs when discussing the times to "evacuate" or "clear" the beach areas. This snould be easy to do since even the l l

Applicants nave eliminated Region 10 ETEs from their updated I 1

l ETE tables. (See Attachnent 1.) As was nado clear from the l ctoss examination of Applicants' witnesses Callendrello and I l

Lieberman (Tr. 5715-5722), the "becch areas" encompassed by l

Region 10 include only those pottions of the battier islands immediately adjoining the beaches but not the nain exit toads (Rt. 51, Rt. 236, or Rt. lA west from Salisbury Beach) from these areas. Thus, Mr. Liebetman described a car in Hanpton Beach as being outside the Region 10 beach area once it had left Highland Avenue and enteted Rt. 51 westbound, a point only 6-

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about three or four blocks west of the beach-(Rt. lA). ,

-Lieb'etman, TL.-5716. This is not a neaningful or televant  ;

point'ftom which.to calculate ETEs ot "cleat

• times for the

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oeople in the beach areas. The telative safety of-the mainland is still-some distance away across the marshes, and beach area i traffic will nove only very slowly along t.he main evacuation toutes (Rt. 51, Rt. 286, Rt. lA) toward the mainland. New 'l 4

t Hanpshire has no cuttent plans which contemplate an evacuation f

-of only Region 10. . Tt. 5719.

j Perhaps nost importantly, unlike the outet boundaries fot  !

all the other ETE Regions, the ' boundary

• of Region 10 does not describe any fixed distance from the nucleat plant. For .

! l i example, after leaving Region 10, the traffic exiting the beach area on Rt. 286 actually moves closer to Seabrook Station, crossing back into the 2 mile ring for a couple of miles. See [

Fig. 1-3 on p. 1-13, Vol. 6. Thus, Region 10 ETEs have no l 3

value for FEMA or the RAC in assessing the adequacy of the -

i j 'RRER?. As with the ETEs for other portions of the EP2, the i 4

i only televant evacuation tines for people in the beach areas j l

aie those referenced by theit ultimate passage out beyond the 2 i i

[ mile, 5 mile, and 10 mile rings and through the Ep2 boundary -

itself. For almost all these people, the 5 mile ting is the first televant ring. Only the closest beach areas on Seabrook i Beach and Hampton 3each are less than 2 miles from the plants i

most of New Hampshire's beaches are between 2-5 miles from 1

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Seabrook Station. Thus, as the people in these beach ateds travel out the evacution toutes to points which are furthet away from the nuclear plant than when the evacuation began, the (itst televant ETE neasurement point teached is the 5 nile ting. If Table 2 in the Applicants' ETE updates is referenced (ETEs "ftom within 5 miles"), the Scenatio 1/ Region 9 ETE is stated to be 6:20. If larget areas are ordered to evacuate (Regions 5-3), the ETEs for clearing the 5 mile ting ate as nich as 6:35.

In sum, the Intetvenots oelieve that the Region 10 ETEs have no televance. Nevertheless, should PEMA and the RAC still sish to reference the Region 10 ETEs, we encourage you to examine Figures 1 and 2 of the Adler Testimony, at lla and 16a (Attachment 5). Tnese figures reflect the Region 10 ETIs Dt. Adlet has calculated.

4. FEMA and the RAC should not assume that the Acolicants' updated ETEs are equivalent to the times needed to "clear the beaches." In fact, all of the Applicants' ETEs (the old and the new) are referenced from an order to evacuate which, pursuant to the planning basis used by Mt. Lieberman in conducting his IDYNE7 tuns, occurs 25 minutes after a ' beach closing

• announcenent. See Lieberman, Tr. 5655-5674; see also volume 6 at 4-1, 4-2, 10-12, 10-13. The assunption utilized for the planning basis is tnat the number of people who will 1

choose to leave the beach areas upon heating the beach closing I 1

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announcement is sufficient to quickly saturate the exit toads.

Lieberman, Tt. 5671, 5673. Thus, to determine how long the Applicants contend it will take to "cleat" an area (2, 5, or 10

.giles ting or the EP: boundary) after the first notification to beach-goers that generates outbound toad saturation from the beach areas, then you must add 25 minutes to all the Applicants' ETEs. For exanple, in Table 2 of the Applicants' updated ETS tables, Applicants' Ditect Testimony No. 7 at 42 (included in Attachment 1), the Scenario 1/ Region 9 ETE for'an evacuation from within 5 miles is listed to be 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 20 minutes. This 6:20 is the time that it take s af ter an order to evacuate (or "OTE") for the last car to pass through the 5 mile ting. However, since the beach closing announcement occurred 25 minutes cefore the GTI and generated enough outbound traffic to satutate the exit roads, the time to "cleat" the 5 mile ring (i.e., time from first notification until the area is cleated 1

of all evacuating vehicles) is really 6 houts and 45 minutes, using Applicants' tables.

I FEMA and the RAC should not assume that the Acolicants' 5.

updated ETEs are "conservative," "pessimistic," or ' worst case."

While KLD Associates has indicated in the past that the ETEs it l l

calculated wete based on a number of conservative assunptions aoout "uncertainties," at the NHRERp heatings Mt. Lieberman of XLD insisted that his estinates were not conservative but were teslistic. No party or witness at the hearings has assetted

. . .. a that KLD's updated ETEs wete conservative (untealistically long). Instead, Intervenots presented substantial evidence that both the Applicants' 1986 and updated ETEs are overly

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, optimistic, i.e., considerably shortet than can tealistically i be achieved, because they are based on a number of ettoneous critical assumptions. See especially the pre-flied testimony f of Dt. Adler and Dt. Ceder. One such assumption, recogni:ed by I the NRC's own witness, Dr. Utbanik, is that the Anglicants' TTE updates were calculated using an unrealistically small beach stea vehicle population because 1500 cars seen noving on the beach toads on the Applicants' 1987 beach photos were ignored.

See Utoanik, Tr. 7374. In addition, Intervenots have pointed i l out that in counting beach vehicles for the ETE updates, the L

! Applicants have also ignoted approximately 2000 additional ,

i vehicles nidden from aetial view parked in garages, catpotts, I and in under-building parking areas. See Rebuttal Testimony of !

Ot. Thonas J. Adlet at 14-15 (attached heteto as Attachment.

9). If the Applicants had considered these 3500 vehicles (1500-

plu; 2000) in addition to the 29,293 parked vehicles that were considered in conducting their updated ETE analyses, there is no question that their updated ETEs for the sunnet scenatios I

would have been longer.

! Another fact, presented by a seniot officer f or the 'lew Hampshire State Police, also casts serious doubt on the notion that Applicants' ETEs are ' conservative" (i.e., likely to be shorter than stated). Captain Sheldon Sullivan stated that the

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9.H. State Police. on whom the plans tely for 74 troopets to staff Traffic Control Points ('TCPs") and Access Control Points '

('ACPs") thtoughout the New Hampshire pottion of the EPO) (see

able 3.1-1 of the Summary of Personnel Resource Assessment for the NHRERP, Aug. 87, Applicants Exhibit No. 1-A, ff. 7t. 4685),

l can ptovide only 4 troopers within the first 15 minutes after ,

notification to them, Tt. 4704, and 3 more within the next 45 minutes, Tr. 4714. Only 6 additional troopets can report to I

conttol points within the next hour, for a total of 13 troo' pets teporting within the first two hours aftet notification to the j State Police. Tr. 4715. Thus, unless notification to ths ,

i State Police occurs well before an OTE, there will be 2

l late-staffing of most of the ACPs and TCPs in New Hampshire.  !

Obviously, .one of these ACPs and TCPs are more important than i others, and these have been designated "Priotity l' posts. But r

a total of 46 troopets are needed just to staff the "Priority l' ACPs and TCPs used to facilitate an evacuation of the entire EP: on a summer weekend in good weather. See N.9. State Police Manning sequence, attached as Attachment-10.

Clearly, if a fasc-breaking accident occurs at Seabrook Station during the summer, FEMA cannst assume that all Priority 4

1 posts will be staffed before the beach closing announcement or even the OTE is made. Even the Applicants believe that late staffing could lengthen theit updated estimates of evacuation times, depending on how fast the Route 51 overpass of I-95 is d

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staffed. Applicants' No. 7 at 44-47 Intetvenots believe this i

late staffing will, at best, tesult in~a-less efficient and .

I otdecly evacuation of the beach ateas that will take longer ,

than Applicants' updated ETEs would suggest. Rebuttal Testimony of Dr. Thomas J. Adlet at 2-4 (Attachment 9). At 4 worst, this late-staffing creates a situation quite.similat-to an unplanned evacuation -- traffic control personnel-present in the early hours are too few and may be too-far apart to ensure orderly traffic flow. Traffic chaos may develop eliminating l any teasonable expectation that an orderly vehicular evacuation can occur. But whatevet conclusions FE'iA and the RAC draw r regarding the late-staffing of posts by the N.H. state police, at least FEMA should agree that Applicants' updated ETEs are .

quite unlikely to be ovetly conservative (shortet than i tealistically can be obtained) for the beach population during l t

l telatively fast-bteaking accident situations, j

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. Conclusion ,

FEMA's present assessment of the New Hampshire Response obviously must take into account the extensive evidentiary record regarding ETEs which has been developed to date in the J

i NHRERp litigation. That record contains a number of critical considerations that beat on whether the New Hampshire Resoonse l 1

ptovides adequate protection to the beach population.  ;

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P Foremost among these considerations is that an orderly, vehicular evacuation from the New 9ampshire beaches2 / 3g,pyy ,

may not be possible when the. beaches are crowded. To discount ghe serious, credible-doubt which exists about the feasibilitv 1

of an ordetly, vehiculat evacution would be grossly inptudent.

Finally, even were FEMA somehow assured that a' vehicular _

. evacuation from the New Hampshire beach areas will always proceed in an orderly fashion, in light of the evidence

presected in the ETE portion of the NHRERP heatings FEMA an&

! the RAC must also recognize that, on summer weekends when the i

beaches are at capacity, if a fast breaking, serious accident ,

t were to occur at Seabrook Station, an evacuation of the 5 mile

ting could noc occut tapidly. In good weather, it will take

,1 from 6:45 (App!icants) to over 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (Intervenots) to cleat  !

i j the 5 mile ting from the time the first notification is given to the beach population (assuming that the beach closing ,

announcenent occuts within 25 minutes of the OTE). Applicants

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now contend that it will take 7:30 (7:05 plus 0:25) to cleat  !

, the full EFJ under such conditions (see Attachment 1);  ;

I*ntervenots' expert Dr. Adlet, has testified that this will take over 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. (See Attachment 6, p. 52.) If a sudden

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tain occurs when the beaches are full, even the Applicants 1

2/ The Attotney General believes that the situation for Salisbuty Beacn in Massachusetts will be much worse, and that vehicular evacuation from this beach when it is nost crowded is in fact not possible, but we have not presented all the

evidence on this point because we have been litigating only the

] NHRERP so far.

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i believe that it will take a minimum of 8:10 (7:45 plus 0:25) to clear the 5 mile ting and 10:30 (10:05) plus 0:25) to clear the

. full EP:. In sum, there is simply no credible way to. describe.

ps "relatively short,' as Dr. Bores did on p. 8 of his June 1987 tevised RAC position paper, the times needed to nove all those people in the-beach areas of seabtook and Manpton Beach to coints more distant from Seabrook Station (beyond the 5 mile' ting) than they were before starting theit trips.

The Massachusetts Attorney General-strongly urges FEMA *and ,

the RAC to take this fresh important information, developed during the hearings on the NHRERP's ETE contentions, into full consideration as they proceed with their review of the 'lew Hanpshite Response.

Very ttuly yours, i t -

. y __

Allan R. Pierce Assistant Attorney General -

Nuclear Safety Unit Department of the Attorney General Commonwealth of Massachusetts _

(617) 727-2220 .

Enclosures  ;

cc: Service List (letter only) l l

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