ML20205P536

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Applicant Motion for Summary Disposition on Seacoast Anti- Pollution League Contention Number 31 (Sapl 31).* Motion Based on Listed Reasons & Eb Lieberman,Rh Strome & Ds Mileti Affidavits.Statement of Matl Facts Not in Dispute Encl
ML20205P536
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 03/25/1987
From: Dignan T
PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20205L804 List: ... further results
References
OL, NUDOCS 8704030305
Download: ML20205P536 (8)
v • d • e


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l' Dated: March 25, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues

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APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION ON SEACOAST ANTI-POLLUTION LEAGUE CONTENTION NO. 31 (SAPL 31)

Pursuant to 10 CFR 2.749, on the basis of the Affidavit of Edward B. Lieberman re: SAPL Contention No. 31, Affidavit of Richard H. Strome re: SAPL Contention No. 31,.the Affidavits of Dennis S. Mileti entitled: "The General Character of Public Behavior in Emergencies", " Voluntary Public Evacuation" and " Emergency Worker Role Abandonment",

i and for the reasons set forth below, Applicants move the Board to enter a decision summarily disposing of SAPL ,

Contention No. 31 in f avor of the Applicants. +

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G704030305 B70325

, PDR ADOCK 05000443 t O PDR c ,,

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REASONS FOR GRANTING i i: THIS MOTION i

SAPL Contention No. 31 as revised' reads as follows:

The evacuation time. estimate report, as described in Volume 6 of NHRERP Rev. 2 does not-meet the

requirements of 10 CFR 50.47(a)(1), 50.47(b)(10) and NUREG-0654 II.J.2, II.J.lO i, 10 h and 10 1, and  ;

i . Appendix 4 because it fails to account properly-for the

. number of vehicles that would be evacuating the EPZ; J

relies in part upon unsupported assumptions; relies in part upon potentially biased input data; does not rely upon extensive enough empirical. base; relies upon traffic control personnel not shown-to be available; does not appropriately account for travel impediments

! such as flooding, snow, fog and icing of roadways; does.

i not account for the effect of driver disobedience on

! evacuation time estimates (ETEs); does not appropriately deal with topographical features; does not deal realistically with the_-transport of transit dependent

persons; in some instances overestimates roadway capacity and, for all of these reasons, underestimates the amounts of time it would take to evacuate the EPZ j and its subparts (" Regions") under the various scenarios-analyzed.

, This contention was limited to the specific bases 4

proferred in the revision dated November 26, 1987 and i

excepting bases 10 and 16. The earlier version.of this contention, submitted on May 15, 1986 had not been ruled on

by the Board, and will not be considered further by the l Board with the admission of this version.as limited. (Board 2

Memorandum and Order, 2/18/87) i The affidavit of Edward B. Lieberman filed herewith' 1

4 makes clear that within Volume 6'of the NHRERP, (a) the number of evacuating vehicles within the EPZ are properly accounted for; (b) meteorological and topographical factors are appropriately accounted for; (c) input data is unbaised-r .

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and all assumptions are soundly based; (d) the ETE:

- realistically addresses the transit-dependent; (e) with the exception of two specified traffic control points, the overall ETE is not affected by~non-compliance with traffic

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- control measures; and (f)' appropriately considers ~ roadways  !

l-capac[ty.

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The affidavit of Richard H. Strome certifies that (a)

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the ETE, Volume 6 of the NHRERP, will be periodically reviewed and revised, if-necessary, to'accountLfor changes

- in the evacuation roadway network, demography and other pc, variables;;(b) the State will utilize existing procedures E for the dispatch of tow vehicles during an emergency

, L situation; (c) surveys were conducted by.NHCDA to identify the number of transit-dependent persons within the plume' EPZ. In addition, as set forth in the Lieberman Affidavit, i'

a survey has been conducted to verify bus mobilization times.

The affidavits of Dennis S. Mileti provide expert-4 opinion that (a) an evacuating public_would push vehicle-impediments out of the way and that accidents are no more frequent than during non-emergency times, and that during an-

! - emergency, there is an increase in behavior'that brings e people together and help'one another (Affidavit One, "The General Character of.Public Behavior in Emergencies"); (b).

voluntary evacuation would not exceed 25% of the ten mile population surrounding the zone of_ recommended evacuation i

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a during a nuclear plan emergency (Affidavit Two, " Voluntary Public Evacuation"); (c) the functioning of emergency organizations is not hampered by failure of emergency workers (such as traffic control personnel as identified in the contention) to perform their jobs (Affidavit.Three,

" Emergency Worker Role Abandonment").

By their attorneys, ThW G. 'Dicffian, Jr.

R. K. Gad III Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 O

STATEMENT OF MATERIAL FACTS NOT IN DISPUTE

1. NHRERP-Rev. 2 evacuation time estimates within the Plume Exposure Pathway Emergency Planning Zone are reported in Vol. 6 of the New Hampshire Radiological Emergency Response Plan, Revision 2. Also see Vol. 2, Appendix F.
2. An evacuation times assessment study as found in Vol. 6 is prepared in conjunction with a Radiological Emergency Response Plan for the sole purpose to place EPZ evacuation time estimates in the hands of emergency response personnel charged with recommending and deciding on protective actions to be taken during a radiological emergency.
3. No fixed limits or standards are prescribed for evacuation ETE by NRC regulation or regulatory guides.
4. NUREG 0654 has established accepted procedures and methodologies for conducting evacuation times assessment studies and how these might be presented, all of which is set forth in NUREG 0654 Appendix 4, pp. 4-1 through 4-16.
5. The KLD ETE study, as reported in NHRERP Vol. 6, conforms to NUREG Appendix A guidelines as follows:
a. Introductory materials called for in Section I of
Appendix A including Site Location and EPZ identification, are found in Vol. 6, pp. 1-1 to 1 including political subdivision highway and

o geographical location maps which appear in Figs.

1-2 at 1-6, and 1-7. Also see Vol. 6, Appendix K.

b. General assumption and the methodology employed (NUREG 0654 Appendix A Section IB and IC) are identified in Vol. 6, Section 1.3, pp. 1-10, Appendix F and G, Section 1-3, p. 1-12, Appendix C-1, and pp. 4-12 through 4-15. Methods for estimating population appear in Vol. 6, Sections 1.3, 2 and 5.
c. Demand Estimation to provide an estimate of the number of people and/or vehicles to be evacuated in I categories of "A. Permanent Residents", "B.

Transient Populations" and "C. Special Facilities Population" as called for in Appendix 4,Section II are found in Vol. 6, Section 2, pp. 2-1 through 2-27 including Figs. 2-1 through 2-12 and Tables 2-1 through 2-3, Table 11-7, Appendices F, G, H.

d. Section IID sub area evacuation time estimate requirements of Appendix 4 (p. 4-4) appear in Vol.

I 6 in Tables 10-4 through 10-7. Fig. 10-1 shows sub area boundaries while maintaining undivided densely populated areas (see Appendix 4, pp. 4-4.)

i Population and vehicle data by sector is displayed in Figs. 10-5 through 10-9b, and Figs. 2-4 through i

, 2-11. Population maps by evacuation area as l specified under planning element J.10.b are found I

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o in Vol. 6, Figs. 2-4 through 2-12 and 10-4 through 10.96.

e. Traffic Capacity information in the detail called j for in Section III of Appendix 4 including A.

i " Evacuation Roadway Network" appears in Vol. 6, Section 3, pp. 3-1 through 3-14, Appendices I, K, L; also see Fig. 1-3 for a demonstration of evacuation based on radial disperson. (Appendix A 4B Road Segment Characteristics need be given only if roadway segments are not uniform.)

f. Section 4 of NUREG 0654 Appendix 4 establishes a

" Reporting Format" and a Specification of the Nethodology for computing. total evacuation time. A i

f summary of evacuation times is presented in Vol. 6 Tables 10-a-d which are presented in the format recommended (Vol. 6, p. 10-70). Table 10-1 (p.

10-2) describes ten evacuation scenarios and the text accompanying the table pp. 10-12 through 10-18 indicates the critical assumptions which underlie the time estimates, day versus night, workday versus weekend. See Table 5-4 for peak transient versus off-peak and evacuation of adjacent sectors 1

versus non-evacuation.

g. The relative significance of alternative assumptions in the preceding paragraph which Appendix 4 IVA requires be addressed "especially '

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. with regard to time dependent traffic loading of the segments of the evacuation roadway network is l

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covered in Vol. 6 Appendices M and N.

h. Specification of the method for computing total
j. evacuation time is set out in Vol. 6, Fig. 2-1, 1- .

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! Section 4, Table 4-2, Fig. 4-2, Fig. 11-1 and Figs.

10-4a through.10-j. Results of calculations of on-road travel and delay times are found in Figs.' ,

10-2a through 10-2g.

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! 6. NHRERP, Vol. 1, p. 3.3-3 requires that "[ alt least

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annually, the Director of NHCDA will direct that a plan i

j review is performed to ensure that the, plan reflects current i_ emergency preparedness status . . . ."

i j 7. The Director of NHCDA, concomitant with Vol. 1, 4

l 3.3-3, is committed to review the NHRERP Vol. 6 ETE, at f least annually and to revise the ETE, as required, to-i t reflect the result of changes in the evacuation' route

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l network, EPZ demography, notification and other matters of ,

t i significance.

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