ML20043B364
| ML20043B364 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/22/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Mavroules N HOUSE OF REP. |
| References | |
| NUDOCS 9005290189 | |
| Download: ML20043B364 (39) | |
Text
e-May 22, 1990 The Honorable Nicholas Mavroules United States House of Representatives Washington, DC 20515
Dear Congressnan Mavroules:
Your letter of March 1,1990, to Chairman Kenneth M. Carr expressing your concerns regarding the evacuation of communities within the Seabrook 10-mile EPZ has been referred to me for response.
As you know, these matters are under adjudication and, hence, the Commission cannot respond to the concerns raised in your request.
However, the NRC staff has set forth its position concerning these matters, based on the record of the hearings before the Atomic Safety and Licensing Board, in comprehensive briefs and pleadings filed with both the Licensing-Board and the Atomic Safety and Licensing Appeal Board.
Enclosed please find a summary of the staff's positions on the issues raised in your letter, and copies of the NRC Staff Proposed Findings for both the New Hampshire portion of the Seabrook emergency plan and the Massachusetts portion of the emergency slan. Also enclosed are copies of the relevant Board decisions in tie administrative litigation and a copy of the decision of the 1st Circuit Court of Appeals decision in Massachusetts v. United States, 856 F.20, 378 (1988).
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I hope these documents respond to your concerns.
Please let me know if I can be of any further assistance to you.
DISTRIBUTION: (w/ encl.1 only)
Original ShEfgply, DocketFiles(w/inc.))
)(w/inc.
ca P n9 James lihlA$[H. Taylor TMurley/FMiraglia Executive Director JGPartlow/ sam for Operations PD1-3 Reading SVarga
Enclosures:
BClayton 1.
" Summary of the NRC Staff Position Concerning BBoger Evacuation of the Massachusetts Portion of the EChan Seabrook EPZ Using the Seabrook Plan for EReis Massachusetts Communities LChandler 2.
NRC Staff Proposed Findings for New Hampshire, JScinto dated August 31, 1989 JTaylor 3.
NRC Staff Proposed Findings for Massachusetts GPA/CA dated August 24, 1989 SECY(CRC 90-0217) 4.
Partial Initial Decision for New Hampshire MBridgers(ED05217)
Radiological Emergency Response Plan, dated CSmyre (w/inc.))
December 30, 1988 VHerses (w/inc.
5.
Partial Initial Decision for Seabrook Plan for MRushbrook-Massachusetts Communities and 1988 FEMA Graded PDI.3 Green Ticket File Exercise, dated Novemk r 9, 1989 6.
1st Circuit Court of Appeals Decision in 7
Massachusetts v. United States, 856 F.2d. 378 (1988) 4
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SUMMARY
OF THE NRC STAFF POSITION CONCERNING EVACUATION OF THE MASSACHUSETTS PORTION OF THE SEABROOK EPZ l
USING THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES i
i In September 1986 the Commonwealth of Massachusetts decided not to participate in further emergency planning for Seabrook.
In response to that decision, Public Service Company of New Hampshire developed and j
submittedtheSeabrookPlanfortheMassachusettsCommunities(SPMC)to provide needed emergency planning to satisfy the requirements of NRC regulations, j
The SPMC is designed to be implemented either in
- Mode 1," which assumes The Commonwealth responds to the emergency and calls upon the utility only for resources and personnel, as needed, or in
- Mode 2 " which assumes that 'ihe Commonwealth delegates full authority to the utility to l
l respond to the emergency and carry out SPMC, or in any other mode lying within the spectrum bounded by Mode 1 and Mode 2.
The utility organization responsible for carrying out the SPMC is the NHY Offsite Response Organization (ORO), an association of volunteers drawn from various companies and callings.
The SPMC phase of the Seabrook licensing proceeding addressed issues raised by Intervenors 1/ n 84 contentions which were resolved by i
1/
The active Intervenors to the SPMC 2hase of the proceeding)were the Attorney General of The Connonwealt1 of Massachusetts-(MAG The l
Seacoast Anti-Pollution League (SAPL), The New England Coalition on l
Nuclear Pollution (NECNP), the Town of Amesbury, Massachusetts (TOA),
the Town of Newbury, Massachusetts (TON), the Town of West Newbury, Massachusetts (TOWN), the Town of Salisbury, Massachusetts (TOS) the City of Newburyport, Massachusetts (CON) and the Town of Hampton, New-Hamphsire (TOH).
i (Footnotecontinuedonnextpage) e-w
~s w
l' O
. settlement or by previous Licensing Board rulings, or litigated and resolved in the Licensing Board's November 9, 1989 Partial Initial Decision (Seabrook Plan for Massachusetts Communities and 1988 FEMA Graded Exercise),LBP-89-32,30NRC
("LBP-89-32").
This Partial Initial l
t Decision was appealed by Intervenors including the Massachusetts Attorney
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General, briefed by all parties, argued and is presently before the Atomic Safety and Licensing Appeal Board (Appeal Board or ALAB).
The NRC staff concluded, and has argued before the Atomic Safety and Licensing Board and the Atomic Safety and Licensing Appeal Board, that the record in the Seabrook licensing proceeding demonstrates that the SPMC satisfies the NRC requirements for emergency planning and provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
With respect to the principal issues raised in administration's litigation on the SPMC, the record shows:
A) FEMA has reviewed the emergency response plans for Seabrock and the 1988 full participation exercise and concluded that the emergency plans and emergency preparedness for Seabrook will be adequate to protect the health and safety of the public.
B) The hearing record demonstrates that the evacuation times estimates (ETEs) for Seabrook -- which cover a range of traffic and weather conditions and range from 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 40 minutes to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 10 minutes -- follow NRC regulatory guidance and provide appropriate evacuation (Footnote continued from previous page)
The Town of Merrimac, Massachusetts (TOM) and the City of Haverhill, Massachusetts (C0H) participated pursuant to 10 CFR 6 2.715(c), but presented no evidence.
1
i 3
time information for emergency response decisionmakers to determine what i
Protective Action Recommendations should be made.
C) The SPMC provides a traffic management plan to ensure adequate i
and efficient evacuation from the area of concern. The SpMC traffic management plan provides traffic control posts to facilitate traffic movement and trained traffic control guides to implement traffic control.
The tre.ffic management plan was modified to reflect concerns of local police chiefs and reflects the contribution of 5 of the 6 ine>mbent Massachusetts municipalities' police chiefs at the time _it was developed.
D) Evacuation of the transit dependent population including school j
children and the special needs population was thoroughly addressed. The record demonstrates that the SPMC would provide adequate buses and other vehicles to accommodate the transit dependent population including school children.
E) The SPMC provides adequate information, procedures and criteria l
to enable decisionmakers to develop appropriate protective action recomendations in the event of an emergency at Seabrook.
It adequately incorporates ETE information into the decision making process and contains l
information on a range of protective actions which may be suitable to the circumstances.
F) As recognized in the Commission's regulations, 10 C.F.R.
l 6 50.47(c), in an actual emergency the Comonwealth and local officials will exercise their best efforts to protect the health and safety of the public. The Court of Appeals in Massachusetts v. United States, 856 F.2d l
l 378, 838 (1st Cir. 1988), in upholding the reasonableness of this l
regulation, stated:
l L
4-It is hardly unreasonable for the NRC to predict that state and local governments, notwithstanding their misgivings about the adequacy of a utility plan or their opposition to a i
particular plant location, would, in the event of actual emerge cy at a plant they were lawfully obligated to coexist with, 0110w the only existing emergency plan.
This prediction is supported by common sense, and also by the uncontested fact -- part of the administrative record of this rule - that state and local governments prefer a planned i
emerge cy response to an ad hoc response. See 52 Fed. Reg. 42082 1987).
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A brief summary of the evidence relating to the SPMC supporting these points is set out below. An ample record supporting the adequacy of.the-emergency plan for the Seabrook station was also developed in the hearings t
relating to The New Hampshire portion of the EPZ. Support for the best effort presumption is continued in the cited 1st Circuit Court of Appeals decision, copy enclosed.
1.
FEMA Review of Emergency Response Plans for Seabrook and the 1988 Full Participation Exercise Pursuant to the t'.emorandum of Understanding between the Nuclear l
Regulatory Commission (NRC) and Federal Emergency Management Agency
[
(FEMA) 2/ and also contemplated by the Commission's regulations at 10 CrR 50.47, the NRC requested and FEMA conducted a review of the offsite rdiological emergency plans for Seabrook, and the graded exercise thereof.
The review was conducted by the Federal Emergency Management Agency, RegionI(FEMAI),withtheassistanceoftheRgionalAssistanceCommittee (RAC). The RAC is chaired by FEMA and has the following members:
U.S.
l DepartmentofAgriculture(USDA);U.S.DepartmentofCommerce(DOC);U.S.
i Department of Energy (DOE); U.S. Department of Health and Human-Services (HHS); U.S. Department of the Interior (DOI); U.S. Department of i
Transportation (DOT); U.S. Environmental Protection Agency (EPA); and the U.S. Nuclear Regulatory Commission (NRC). The RAC functions in l
2/
Memorandum of Understanding, 50 Fed. Reg. 15485,15487(Apr.18, 1985) (M00).
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. accordance with 44 C.F.R. Part 351, " Radiological Emergency Response Planning and Response." This FEMA review and evaluation used NUREG-0654/
FEMA-1, Rev.1, Supp. 1, September 1988, as the basis (planning standards and specific criteria) for determining the adequacy of the New Hampshire Yankee Seabrook Plan for Massachusetts Communities.
FEMA GuidanceMemoranda(GM)andFEMAREP-seriesdocumentswereutilizedto interpret and clarify the criteria contained in Supplement 1.
FEMA concluded that the plans, including the SPMC, were adequate. More specifically, FEMA found and concluded that, subect to the installation of a vehicular alert and notification system (VANS) for the Massachusetts portion of the EPZ, and enhancements to the alert and notification system for the New Hampshire portion of the EPZ, the plans and' preparedness will l
be adequate to protect the health and safety of the public living in the Seabrook EPZ by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiological emergency and i
are capable of being implemented. 3/ O Letter, Peterson to Stello (Dec.
14,1988), App.Ex.43A.
See also ff. Tr. 21653 at 3; Tr. 21651. The RAC 3/
All VANS issues were subsequently decided in Applicants' favor in Public Service Co. of New Hampshire (Seabrook Station, Units 1 and 2),
LBP-89-17, 29 NRC 519 (appeal dismissed (Aug. 1, 1989).
4/
Findings and Determinations for the Seabrook Nuclear Power Station, FEMA, December 1988(App.Ex.43B);ReviewandEvaluationofthe Seabrook Plan for Massachusetts Communities, FEMA, December 1988.
(App. Ex. 43C); Review and Evaluation of the State of New Hampshire Radiological Emergency Response Plan for Seabrook Station, FEMA, December 1988 (App. Ex. 43D); Status of Corrective Actions for the 19P9 FEMA Graded Exercise for Seabrook Station, FEMA.
December 1988.
(App. Ex. 43E); Exercise Report, Seabrook Nuclear Power Station, Prepared by FEMA, Region 1, Boston, MA, September 1,1988.
(App. Ex.
43F).
6-was involved throughout the FEMA review and concurred in all reports filed. Tr. 19092-93.
The FEMA reasonable assurance finding is based on four " legs." These are(1)reviewoftheplanagainstNUREG-0654,Supp.1,asappropriate, (2)testoftheplaninanexercise,(3)verificationthatequipment, personnel and resources are actually there, and (4) verification that the personnel have been traines FEMA thoroughly reviewed all facilities and equipment to be utilized to implement the SPMC.
In addition, FEMA reviewed the results of the graded exercise of the radiological emergency response plans for Seabrook. The overall conclusion reached by FEMA in evaluatin; the June 1988 Seabrook exercise was that the exercise demonstrated that the SPMC and the emergency plans for the State of New Hampshire and the State of Maine can be implemented.
In accord with Commission reguiations, these FEMA findings constitute a rebuttable presumption that all aspects of the Seabrook offsite plans and emergency preparedness are adequate and capable of implementation, except as otherwise specifically noted by FEMA.
Tr.18498-99,18502,19108-09, App. Ex. 43F, passim, Tr. 21651.
FEMA reviewed the SPMC on what is referred to as a " Mode 2 full" basis; that is to say the assumption was that the nonparticipating-governments would only delegate authority, but no resources or assistance l
would be given to the ORO to execute the plan. Tr. 18422.
The graded l
exercise also was conducted on the basis of Mode 2 full.
Tr. 22384-85.
l Because FEMA fcund SPMC to be adequate in this mode, and because it can be assumed that any response which included assistance and/or resources from The Commonwealth would be better than a response by the utility ORO alone,
- FEMA believes, has found, and the NRC Staff concurs, that the SPMC operating in Mode 1 (ORO contributing resources and personnel only), or in any mode between Mode 1 and full Mode 2, would also provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook. Tr. 18432, 18442, 18444-45, 18459-61.
In addition, the graded exercise, conducted as Mode 2 full, demonstrated the implementability of the SPMC in other modes which i
include varying degrees of Commonwealth participation. Tr. 22387-89.
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11.
Evacuation Time Estimates (ETEs)
The Evacuation Time Estimates (App. Ex. 42) are used by decisionmakers at the time of a radiological emergency to determine what Protective Action Recommendations (PARS) should be made based on the accident scenario, meteorological conditions and other factors affecting an evacuation decision. There are no maximum times set by regulation for accomplishing an evacuation. An ETE should reflect realistic conditions, rather than a worst case scenario, so that it is of use to the decisionmakers at the time of an emergency. 5/ The ETE's include reasonable estimates of l-roadway capacity and represent the evacuation conditions expected under-the implementation of the SPMC's traffic control plan.
Ff. Tr. 26681 at 35-36.
See also ff. Tr. 27150, at 3e5, 6-7.
The SPMC's ETEs provide 1
5/
Philadelphia Electric Co. (Limerick Generating Station, Units ~ and 2), ALAB-845, 24 NRC 220, 246 (1986); Philadelphia Electric Co..
(Limerick Generating Station, Units 1 and 2), ALAB-836, 23 NRC 479, i
491 (1986); Philadel)hia Electric Co. (Limerick Generating Station, Units 1and2),LBP-35-25,22NRC101,106(1985).
_g_
all the necessary information and parameters to allow proper selection' of 1-l a representative ETE for determination of PAR's. Ff. Tr. 26681 at 48-49.
j Dr. Thomas Urbanik, of the Texas Transportation Institute of the
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Texas A&M University, while. finding the ETE analyses to be adequate, indicated that an organized presentation of the ETEs, including assumptions and methodology, should be preptred so that the SPMC ETEs l
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could readily be used by decision-makers at the time of an emergency.
o Urbanik Dir. Ff Tr. 27150 at 9.- With the exception of the need for an f
I i
. organized presentation, the existing ETEs satisfy the guidance of NUREG-0654, Appendix 4, and all applicable regulatory requirements.
Id.
I No additional analytical work is required and further, the preparation of j
this organized presentation of ETEs is essentially an editorial or
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" ministerial" task. Tr. 27179-80.
Several subsidiary issues arose as part of the ETE an * ",
c'uding the number of vehicles in the Massachusetts portion of ts-EP;, the l
L effectiveness of trained civilian traffic guides.as oppo" to Elw j
officers at traffic and access control posts (TCPs & ACPsi tN
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configuration of TCPs and ACPs and the impact of: shadow evacuation. After-careful consideration both the Intervenors' expert and the NRC Staff.
4 concluded that assuming the validity of all the expert's concerns and i
factoring in all the time increments, these additions would not have a j
'i significant effect on ETEs and would not affect any Protection Action Recommendations. ' Ff. Tr. 26482 at 20-21; Tr. 26498-502.
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The ETEs, as updated, and subject-to their being published'in~an organized presentation, are adequate for PAR decision making for the following reasons:
1.
The ETEs were calculated using a state of the a n methodology and are'as accurate as reasonably achievable.
2.
The ETEs provided to the-PAR:decisionmakers are for an adequate l
number of scenarios which account for the most predominant conditions and variables normally experienced in-the Seabrook EPZ.
3.
.The ETE scenarios in the SPMC are the same ones used in the NHRERP, which were found adequate after hearing al.1 the evidence on PAR 9
decisionmaking..
t 4.
The ETEs prove to be relatively insensitive to roadway.
impediments and expected variations in beach area population.
j 5.
PAR decisionmakers are alerted to consider emergency-specific:
a conditions which may direct additional-logistical considerations for added ~
. flexibility.
6.
Under most conditions evacuation would be the preferred PAR for the Seabrook EPZ.
Ff. Tr. 26681 at 52; see also ff. Tr. 27150 at' 7-9.
The hearing reccrd contained no evidence to support the argument-that further refinement of the ETEs would make a further contribution to public protection.
The ETE's for special facility ETEs are comparable to those for the p
general. population, thus obviating the need to consider separate PARS for special facility populations. Ff. Tr. 26681 at 63,'64-67, see also Tr.
'l 21231-33, Tr. 22596-97.
Recommending PARS on a group-by-group or facility-by-facility basis is not likely to provide any additional dose
L l
- 10'-
E savings for.special populations.
However, given that the special facilities and special populatio.ns PARS are comparable to those of the general public, the SPMC will provide for special consideration of these groups. The SPMC will be revised to incorporate a priority list for l-allocating evacuation vehicles to all special populations. This-list will h
indicate which population category-should receive resources first and the i
sequence in which facilities within each category will be serviced.
Specifically, schools and'dayJcare facilities would be assigned vehicles
.j first, followed by the. transit dependent general population-routes, j
curbside pickup (homebound)' routes, special facilities and then hospitals.
1 When there are multiple facilities within a category, the ~ facilities which j
are closest to Seabrook would be service'd first followed by those' that are
.l further away. This assignment priority ensures the most efficient use of 1
transportation resources. Thus, the SPMC takes all appropriate steps for anaximizing dose reduction for EPZ special-populations.
Ff Tr. 26681 at 63-64.
l.
For fast-breaking scenarios'(such as are considered in the ETE), the l
3 Applicants will use an expedited bus mobilization proce. dure. -Ff. Tr.
26681 at 65-66; Tr. 27099. The fact is that for Seabrook, because PARS I
will be generated largely based on plant conditions, and because of the uncertainties associated with predicting accident sequences and events, a PAR other than evacuation is unlikely except in a very small number of scenarios.
Tr. 27072-74; Tr. 27126-27. And, indeed, it is doubtful that even a difference of as much as one and one-half hours in an ETE could affect any PAR choice at Seabrook. Tr. 26933-34.
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a i Dr. Urbanik testified that the Applicants' ETEs account for'the i
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specific circumstances, difficulties and delays which might exist in l
conducting an evacuation in the Massachusetts portion of-the Seabrook EPZ.
Ff. Tr. 27150 at 3. - Further, Dr. Urbanik stated that the ETEs are l
realistic, and that no significant errors exist in the ETEs' assumptions as to the number of vehicles that will be using roadways, intersections and ramps in Massachusetts or as to the number of vehicles that may be expected to evacuate from and-through Massachusetts. M. at.4-6.
Based on his review of the SPMC ETEs, and his extensive knowledge of the Seabrook EPZ and of Seabrook ETE modeling efforts which have been made
- i over the past years, see e.g., ff. Tr. 26337 at 2-3, this expert concluded that no further ETEs are necessary. Ff. Tr. 27150 at 2-3 -' 9; Tr.
27167, 27170, and 27180.
Indeed, he stated that "the sensitivity of the Seabrook EPZ [is known] in a way that's unseen any place else in the l
world." Tr. 27170.
III. Traffic Management' Plan While the development of a traffic management plan is not a regulatory requirement, applicants are permitted to develop special traffic. management plans to effectively utilize available capacity.
See NUREG-0654, Appendix 4, at 4-5.
In addition, applicants are. instructed to provide '" specific recommendations for actions that could be taken to-significantly improve evacuation times." M at 4.
The purpose of traffic management planning in conjunction with radiological emergency planning and preparedness is (1) to provide a means to identify and. plan for those-actions which could be taken to significantly reduce evacuation times in e
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- l the event of a radiological emergency, thereby providing the lowest reasonably' feasible evacuation times, and (2) to make the most effective use of available traffic management resources.
Ff. Tr. 2633 at 4; see also Tr. 26456. Such a traffic management plan was; developed here.
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The primary objective of traffic management is-to' support emergency evacuation operations to ensure an adequate and efficient evacuation from.
the area of concern.
To support this objective it is necessary to l'
l reconnend evacuation routes and implementable traffic control strategies-to utilize efficiently the availabic roadway network capacity.
In some-l instances, control strategies which enhance. existing. roadway capacity can significantly expedite evacuation traffic movements.
Since such treatments are frequently resource-intensive, they should be limited to those locations which offer the greatest potential benefits. Thus, a well-designed traffic management plan identifies the most. effective l
control strategies, quantifies the resulting benefits, and balances these
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benefits with the available resources to define the most effective and implementable plan responsive to the stated objective.
Ff. Tr. 17353 at 1.
The SPMC traffic management plan was the result of an extensive recursive and iterative process which the Applicants' witnesses summarized i
succinctly for the record.
Ff. Tr. 17333 at 2-5.
Fine-tuning of the traffic control plan continued until no material improvement in ETEs was l
obtained. M.at4-5.
The Traffic Control Posts (TCPs) in the SPMC are designed to perform g
a number of functions:
(1) facilitate evacuating traffic movements which serve to expedite travel out of the EPZ along the planned evacuation Y
_a routes; (2) discourage traffic movements which permit evacuating vehicles f
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'to travel in a direction which takes them significantly closer to the i
power station; and (3) resolve potential conflicts between traffic streams, at intersections by assigning right-of-way so as to promote safe c.perations and-to keep traffic moving.
Ff. Tr.17333 at 6.
t The number of Traffic Guides assigned to each TCP and access control post (ACP) was determined based upon the complexity of-the point's traffic strategy, the location's general configuration, and the type of equipmentc assigned for use.
Police Chiefs in the Massachusetts EPZ communities were.
requested to provide input on the traffic routing, TCP and ACP. strategies, and how many personnel and what equipment ~would be required to implement t
the desired strategies. Detailed inputs.to the design of the traffic j
control plan were received from five of.the Police. Chiefs (all except that of the Town of Amesbury) during interviews'and through subsequent correspondence.
Ff. Tr. 17333 at 6-7.
See also App. Ex 50; Tr.17451, 17464-66. The number of Traffic Guides at each TCP was minimized to the number required to implement its control strategy in an efficient manner, in order to avoid confusion and conflict between guides. Tr. 17443; see also Tr. 17153-54. The SPMC provides an adequate number of traffic control personnel.
Ff.-Tr. 26337 at 9; Tr. 26449-50; Tr. 26456. Nor is the SPMC traffic management plan constrained by any lack of necessary resources. Tr. 26381-82, Tr. 26456.
For example, the original control policy developed for the intersection of Routes 1,1A, and 110 in the Town of Salisbury was to facilitate both the westbound travel along Route 110 toward I-95 and I-495, and the southbound travel along Route 1.
Ff. Tr.17333 at 7.
The police chiefs in TON and CON, however, objected because they believed that i
S
.. Route 1 would be congested with evacuating traffic from Salisbury Beach to -
the extent that evacuees from these communities would be unduly delayed as a result.- Id. at 7-8;-see also Tr. 16968-69. To respond to these concerns, the traffic control policy at Salisbury Center was revised and i
took its present form, whereby all traffic is routed over two lanes along-l 1
westbound Route 110 to I-95 and -495.- This revised policy was reviewed with the then Town of Salisbury Police Chief (Chief.0livera), who approved f
it and stated that the town police could implement it.
Ff. Tr.'.17333 at 8.
See also, Tr. 16968-69.
All changes suggested by Police Chiefs, were made'only after a traffic management expert ascertained that the effects of the change requested would be either neutral or beneficial to the evacuation time
' estimates for the areas affected and any other areas closer to'Seabrook.
Tr. 17453-54; Tr. 17460-61.
In sunnary, the traffic management plan represents the combined contributions of 5 of the 6 incumbent Massachusetts municipalities police chiefs at the time of development. The plan has been thoughtfully and-h carefully designed to implement effective control strategies to support
]
the evacuation process.
Ff. Tr.17333 at 12-13; ff. Tr. 26337 at 18-19.
The Applicants were responsive to various complaints with respect to the-TCP and ACP diagrams, both of a particularized and a general nature and additional diagram revisions suggested by Dr. Urbanik.
Ff. Tr.17333 at 13-16; ff. Tr. 26337 at 10-11. Applicants have committed that any errors or material improvements in the TCP and ACP diagrams identified i
by the intervenors or through subsequent field surveys as part of the annual update process will be corrected and incorporated into the diagrams.
Ff. Tr.17333 at 17.
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s.
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Further, it is reasonable to expect, under a best-effort response, that State and: local police will be available to assist with traffic and-f access-control-activities'.
Specifically, in addition to TCPs, police will
. assist in establishing and activating access control posts and-in screening vehicles, when offsite response organization guides'are_
d instructed to do-so approximately two hours after issuance of the order to-evac'u' ate.
In.the process, use of the police cruisers' emergency flashing i
lights at access control posts would provide additional conspicuity for
.i alerting approaching motorists.
In. addition, all' State Police cruisers are equipped with microphnnes and loudspeakers which can be used to inform and guide motorists approaching the EPZ./ The location-of the State Police BarracksinTON(offSectlandRoadadjoiningtheinterchange'_withI-95) would facilitate an expeditious response by State Police.
For longer term control, the State Department of Public Works-(DPW)'would be able to provide-additional traffic control devices (e.g. barricades, arrow boards, advisory and warning signs) for ACPs.
If these devices are not in the State DPW inventory, tney can be requisitioned from other sources.
Ff.
1 Tr.17333 at 20-21.
1 The SPMC traffic management plan will assist in lowering evacuation
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times below those that would pertain in an uncontrolled evacuation, and the SPMC has taken advantage of-every available opportunity to. reduce evacuation times to the greatest reasonably feasible extent.
Ff. Tr.
26337 at 12, 18; Tr. 26429, 26430-31.
See also ff. Tr. 27150 at 7.
Personnel at thirty-seven (37) TCPs and at any supplemental ACPs provide a readily available source of feedback information regarding impediments to evacuation traffic along,.escribed evacuation routes
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within the Massachusetts portion of the. plume EPZ. ' These personnel will l
be in place during the evacuation regardless of weather conditions and time of day. Aerial surveillance.of: road. network impediments is available l
j by helicopters during acceptable flight conditions. App. Ex. 42, IP 1'.3, r ; Plan, Appendix C;, LOA f or use of helicopters. Traffic-4 impediment, road construction, and flood information will also be i
available form local police and-road departments via the local Emergency j
OperationCenters(E0Cs). App. Ex. 42 IP 1.8.
The SPMC contains adequate i
and elaborate traffic impediment response procedures provide for the identification, analysis and removal or avoidance of : traffic impediments during on evacuation. Ff. Tr. 17333 at 49-52, 57.
FEMA concludes that the SPMC is adequate'with respect to providing-the necessary procedures and equipment to clear impediments blocking i
evacuation routes. App. Ex. 432 at 67-68.
I In-sum, the SPMC traffic management plan is'one of the most extensive t
in the United States and probably only~one_or two others are even comparable to it. Tr. 26389. The hearing record demonstrated that the-1 plan takes advantage of available opportunities to-reduce evacuation times a
to as great an extent as is reasonably feasible.
Ff. Tr. 26337 at 18.
Further, the SPMC traffic. management plan utilizes appropriate.and sufficient capacity enhancing measures and other traffic control l
strategies; and the SPMC has identified those actions that could significantly improve evacuation times.
-Id.
a IV. Evacuation of Transit Dependent Persons FEMA reviewed and found the procedures for the evacuation of the i
transit dependent to be adequate. The record before the Licensing Board i
- s
l l
contains testimony elaborating on the. development and criteria for the l
l-evacuation bus routes, how the bus transfer points will operate, how the estimates of transit dependent persons were made, how-the~ number of runs l
to be made was determined, the duties of Route Gliides and how the Route 1
L Guides will interface with bus drivers.
Ff. Tr. 17333 at 59-60, 63-67 and 1
-Attachs. I & J.
Evacuation bus routes were initially developed for the six l
L Massachusetts communities by emergency planners under the direction of L
l Massachusetts Civil Defense Agency (MCDA)> with input from EPZ _ planning l
L contacts (e.g., local civil defense directors; selectmen) in each of the
[
l-six Massachusetts communities. 'The routes were designed to' start at the Local Staging Area (i.e., Transfer Point) and extend through the town to form a closed path while generally following the guidelines stated below:
a.
No house would be more than approximately one-half mile'from a bus route; b.
Buses would not back-track on the same route where possible; and c.
Buses, in general, would follow the directions provided at'the l
l Traffic Control Points, in developing the SPNC bus plan, NHY relied on the bus routes developed by MCDA. Once the routes were designed, a field verification was done to ensure the roadways were correctly shown on the map. Due to changes in -
the locations of the transfer points (i.e., local staging areas), the evacuation bus routes were slightly rodified.
Ff. Tr. 17333 at'58-59.
l A comprehensive field study was conducted of the evacuation bus l
1 routes for all six SPMC communities between November 7 and 15, 1988.
Standard full-size school buses were used for field verification of the l
t
C 1
- ' evacuation bus routes. The buses were 9'6" wide with both mirrors I-extended and 7'6" wide with mirrors retracted. Thus, at least 17 feet of road width (pavement plus shoulders) was needed for two buses to pass each i
other. The weight of the bus was 26,600 pounds when empty. A field. study l_
was made consisting of three separate runs.
First, specific roadways where potential problems had been identified through. drill comments, exercise comments, and contention bases were driven with a bus to assess-t the existence or severity of the stated problems.
Road measurements, where appropriate, were taken at the' observed narrowest point ~on roadways-i to determine if the road was wide enough to-accommodate an evacuation bus l
and opposing traffic. Second, all routes were driven with automobiles to I
verify the information on the bus route maps regarding the existence of street signs, landmarks, roadway configuration and correct labeling of-streets. A set of criteria was developed and given to the personnel to direct them in the method which-should be followed when driving the i
routes. Third, all bus routes were driven with buses to verify that a bus could perform all turn movements and to record route distances. As a result of this field survey, 4 out of the 26 evacuation bus' routes were revised and then rerun to record route distances. An analysis was then performed to determine new bus route transit times, total trip completion times and the number of buses to be allocated to each route.
Ff. Tr.
17333 at 60 and Attach. K.
But Route maps were changed and clarified in light of these field surveys.
Ff. Tr. 1733 at 60-63.
Evacuation buses are not expected to encounter undue delays when crossing heavily congesteo evacuation routes. The evacuating vehicles will permit the bus to get through.
The amount'of' time spent by evacuees n
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waiting in personal vehicles for the bus to cross the evacuation route will be minimal.
The backed-up traffic will quickly rejoin the original line of evacuating traffic due to the fact that minimal forward prog'ress 1
would have occurred in the-time span.it took for the bus to cross the-1 evacuation route.
Ff. Tr. 17333 at'68.
To evaluate and provide for the potential for area-wide flooding, flood plain maps were obtained from the Flood Map Distribution Center in Baltimore, Maryland, for TON, CON, TOS,, AND TOWN.. Flood plains are classified into 1-year,10-year, 50-year, 70-year,100-year and 500-year-1 l_
intervals based'on the expected occurrence of a. major flood incident in 1
the respective time period. The ' roadways identified in the Intervenors' l
l contention bases as_ problematic all fall into either the 100-year or l
500-year flood plain intervals. This translates into'the probability of 0.01 or 0.002 that major flooding will occur on these roadways in any year. Therefore, it is highly unlikely that these roadways will be rendered impassable by flooding concurrently with an emergency at.
Seabrook. Ff. Tr.17333 at 69.
In certain weather conditions evacuation buses might encounter sections of road covered by water. An evacuation. bus would generally be able to traverse roads and pick-up transit-dependent evacuees, depending on the level of flooding.
Buses used in picking up transit dependent residents have a clearance of approximately 15 to 20 inches from the road l
surface to the taiipipe. This distance is the limiting factor for buses traversing flooded routes.
If a segment of roadway which appears.to'be impassable due to local flooding or some other obstacle is encountered, the Route Guide is to contact the Transfer Point Dispatcher and, using the
.-.- = -..
20 -
i detailed route map (Ff Tr. 17333, Attach. L), determine alternate.
i roadways available to rejoin'the assigned route. The Route Guides are to
" report' any obstacles, stalled cars, or other impediments to traffic l
flow.... to the Transfer Point Dispatcher... " - App. Ex. 42, IP.
2.10, at 26. SPMC procedures call for the evaluation of constraints such as " road conditions, current weather conditions, and special evacuation -
l
' problems." If a significant rerouting is necessary, Traffic-Goides will l
l be reassigned as necessary. -(App. Ex. 42,.IP 2.11'at 5, step 5.1.7).
Ff.
~
i Tr. 17333 at 69-70.
The evacuation of a school or special. facility is accomplished by dispatching all necessary buses with one_ Route Guide.to the facility.. It is far more efficient to move buses through an intersection in a convoy as '
envisioned in the SPMC than it is to move single. buses.. The competing;
{
l traffic flow is interrupted only once by a convoy instead of multiple 1-times for individual buses.
Ff. Tr. 17333 at 70-71.
The bus routes in the SPMC, with the commitments which the Applicants have made to improve them as reflected in the record of this proceeding, are adequate and can be implemented.
V.
Personnel and Training FEMA concluded that the Offsite Response Organization (ORO) in the SPMC is adequately staffed. App. Ex. 43C at 13; see also Tr. 18836.
Personnel for a second shift would be requested and supplied through Yankee Atomic Electric Cocpany by means of the Yankee Atomic Mutual Assistance Plan. Second-shift staff will be briefed by the personnel they replace to the extent necessary and are capable of performing the required w
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functions. App. Ex. 42'at 2.1-1, IP 2.11,- IP 2.17, IP 3.2, IP 3.5, IP f
2.9; App. J.
FEMA verified that.the. Applicants demonstrated: shift change.
(;;
capability at both reception centers during the emergency planning I
1 exercise, including shift change capability for. evacuation monitoring positions. Tr. 18685, 19163. See also App. Ex. 43F'at 240. ~The L
. replacement shif t was well-trained and. fully knowledgeable ofl their 1
responsibilities. App. Ex. 43F at 239.
FEMA observed from the exercise-that the Yankee Atomic Staff designated as the'second-shift for monitoring positions are as adequately trained as first-shift personnel
!Tr.18686, 18691, 19160.
Personnel provided through.the' Yankee Mutual' Aid Program would be drawn from'a group of people-who already-have pre-identified i
~
skills and knowledge of radiation monitoring equipment and other knowledge necessary to be able to perform designated tasks.. Tr.18688,19126.
Testimony on personnel recruitment and screening indicated prerequisites included experience and training in emergency response. ' Ff. Tr. 27388 at 1-2 FEMA observed that the second shift was able,to step in, receive a=
turnover shift briefing and use the-instruments and. demonstrate ~its proficiency just as the first shift did. Supervisors for the: second shift l
have been pre-identified and trained. -Tr.18687.
VI. Protective Action Recommendation (PAR) Generation j
FEMA concluded that the SPMC is adequate in establishing a capability for implementing protective measures based upon Protective Action Guides-l (PAGs) and other criteria, App. Ex. 43C at 53-58, that the SPMC adequately
)
l describes the basis of choice of recommended PARS during emergency l
conditions, App. Ex. 43C at 69-70, ar.d that the SPMC adequately' describes l
l
l 22 those functions which require state and local authorization'before implementation. App. Ex. 43C at 9-12.
FEMA has found that OR0 has t
1 executed the necessary agreements with r'espect to al_1 support organiza--
tions including the State of New Hampshire, that the agreement for coordination between those two! entities is adequate, App.-Ex.-43C at 12-13, and that Applicants' population distribution information for the permanent population and methodology for estimating the transient population-is adequate.
L Although there is no regulatory requirement that 'a shelter survey be?
4
' included _ in a radiological emergency response plan (RERP), Tr.18576, the decision criteria of the SPMC contains a full range of protective actions o
including a shelter option for the~ permanent population. Tr. 18572-18573.
1 While many structures in the EPZ may provide greater protection, FEMA:
established that the selection in the SPMC of the 0.9 dose reduction factor (drf) is -the most prudent and conservative approach to take; :Tr.
18578; 18587-88, 18590.
EPA draft guidance suggests.that. shelter-is a j
protective action that is viable for only a-limited time equal to less than six hours. Tr. 18593. The fact that an-area may have long evacua-tion time estimates does not mean that there is any greater need to 1
explore sheltering alternatives. Tr. 18590-92.-
During the emergency planning exercise, FEMA verified the reasonable-I 4
ness of Applicants' dose projections using its own~(FEMA's) dose code.
Tr. 18324-28; App. Ex. 43F at 220-221. At the plan review stage, FEMA had i
checked the dose projection assumptions and during the exercise the
'I reasonableness of the results were checked.
Tr. 18328-29.
No evidence l
-i
- was adduced to' contravene the adequacy of the SPMC with respect to the l
generation of protective recommendations.
}
The "METPAC" computer model which was-used to create protective action recommendations (PARS) was particularly subject to test in the l
Seabrook hearings. The evidence showed that the PARS generated by the-t onsite organization to the State of New Hampshire and the NHY ORO were timely and appropriate and that the PAR generating procedures were correctly.followed during-the exercise.
Ff. Tr. 24627 at 8, 14-15; ff.
Tr. 25614_at 91-92, 192-93.
~!
In summary, the SPMC sets forth adequate procedures and criteria-for the generation of PARS, adequately incorporates'ETE information into'the
- ll PAR decisionmaking process, anC contains~ a range of' possiblei protective actions which are suitable to the circumstances of the Seabrook site.
NRC.
Staff P.F. 6.3.1-6.3.4 at-102.
Further, the SPMC contains~ adequate population' distribution informa-tion and contains. adequate procedures to provide'for the notification of" l
PARS to State and local officials and-the' general public, and for-coordi-nation of PARS with the State of New Hampshire, NRC Staff P.F. 6.3.5-6.3.6 1
at 103, and PAR generation and execution during the graded exercise revealed no fundamental flaws in the emergency plans exercised. - NRC Staff P.F. 6.3.7 at 103.
VII. Communications / Notification FEMA concluded that the Applicants have adequately described.the OR0 organization and the areas where it needs legal authorization and that I
d adequate and necessary Letters of Agreement (LOAs) have been executed.
App. Ex. 43C at 10-12.
FEMA further concludes that the provisions in SPMC l
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- 24'-
[
for communications within ORD, with other organizations (including states and local governments), with federal agencies, with the plant, for 1
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activating response personnel, and for communicating with medical support facilities are_ adequate. App. Ex. 43C at 29-34.
There are three methods for notifying schools of the emergency:
telephone, the sirens, and tone alert radios which will be supplied.. Tr._
19015.
Initial notification.of offsite authorities of.an emergency at-Seabrook does not rely on the commercial telephone network. Such notification, including that of Massachusetts governmental entitios,'is-made by Seabrook Station Control Room via the Nuclear Alert System (NAS).
The NAS is comprised of various microwave and leased telephone links and does not rely on commercial telephone line availability. App. Ex. 42, Section 4.1.
The public notification system in Massachusetts does not
- rely on the availability of commercial telephone lines for primary communications.
Initial activation of the VANS operators at the-VANS j
l Staging Areas will be made by the Emergency Operation Center (E0C) Contact Point via the Vehicular Alert and Communications System (VACS) which transmits a radio signal that activates-an alarm system. Subsequent voice communications between the Offsite Response E0C and the VANS Operator is via the OR0 Emergency Radio Network (ERN). App. Ex. 42, Section 4.5.
The
[
graded exercise tested and verified the mechanics for notifying the appropriate parties to activate the siren alerting system. Tr. 18312.
At the time of an emergency, Massachusetts State and local auth0ri-ties will continue to provide the standard functions associated with police, fire and other public safety activities. The NHY'0R0 maintains the capability to communicate with State and local governments via the
[
t
- MAGI (MassachusettsGovernmentalInterface)'radionetwork.
The MAGI L
- network operates on existing radio frequencies which are routinely l
l utilized by Massachusetts State and local response organizations.
Ff.
Tr. 27223 at 13.
l During 1985 and 1986, NHY designed or redesigned, provided and r.
i-y installed many. of-the primary communication systems now in use by many of g
-the Massachusetts Public Safety entities that would be involved with a response-to an' emergency at Seabrook.- The ORO HAGI system was designed to provido a communications-link to these and.other public safety entities.
.i The hardware' components of MAGI were chosen and configured to allow' I
compatibility and integration with these public safety communications J
systems. Accordingly, MAGI can be thought of as a " Gateway" mechanism allowing the MAGI' radio operators at the E0C the ability to monitor the j
public safety. activities taking place 'in Massachusetts.
In the event it-t becomes necessary, due to the failure of primary communications. paths.
between the OR0 and-Massachusetts Public Safety entities, MAGI will also ;
allow a voice communications link to the various Massachusetts state and-local public safety. agencies.
Ff. Tr. 27223 at 13-14.
In summary, by following the SPMC procedures, the OR0 satisfactorily communicated with all appropriate locations, organizations and field' l
t personnel during the 1988 FEMA graded exercise for Seabrook.
NRC Staff:
P.F. 7.1.52 at 115.
The SPMC prvoides methods for the development, dissemination and.
L coordination of emergency information.
Facilities and equipment for the media have been provided at the Media-Center. With re.spect to accommodating the media, it is important to provide them accurate and l
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a
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- 26'-
timely information, as well as reasonable access to authoritative sources of information. The Media Center functions and processes provide this.
i type of information and access to official utility and governmental information without interference with response activities. Widespread dissemination (both local and national) of news is assured because SPMC procedures require news releases to be provided to-AP and UPI wire services. SPMC'at 5.6.7, 5.7.2.
Therefore, local and national broadcast media stations will have access-to all news releases in a timely manner i
since virtually all TV and radio stations receive either or both wire.
services.
Ff. Tr. 27843 at-43.
In an actual emergency, PARS will depend on the risk to the affected l
public. Recommendations to evacuate a specific. population, for example, l !
will depend on the existing and projected risk of exposure. That risk-is -
J t
location and time specific depending ~on meteorological conditions, j
distance from the release, and other. factors concerning the status of response functions. These factors pertaining to risk were built into the 1988 exercise scenario. Thus, communities in New Hampshire might be-evacuated sooner than m a aities in The Commonwealth depending on meteorological and distance factors. The 1988 Exercise scenario required communities in New Hampshire to take protective actions sooner than communities in The Commonwealth based on the plume trajectory.
Conse-quently, EBS messages reflecting the PARS were issued sooner in New Hampshire than in The Commonwealth. This result was consistent with the exercise scenario and found to be adequate by FEMA.
Ff. Tr. 27843 at 54.
EBS messages for Massachusetts are developed by the Public Informa-tion Staff in the E0C and are coordinated with the New Hampshire officials i
(
L
-.. prior to final approval by-the NHY Offsite Response Director. Overall
. coordination of EBS messages is further ensured by the fact-that the Media Cer.ter provides a mechanism and a' facility for representatives of the principal State, Federal.and utility response organizations to coordinate and interact on public information matters.
In addition, representatives of the OR0, the onsite Emergency Response Organization (ERO) and the State j
of New Hampshire review all news releases'and EBS messages at the Joint Telephone Information Center (JTIC) prior to-distributing them to their 4
staff. This provides another process for the review, coordination and correction, if necessary, of EBS messages and, news releases.
Ff. Tr.
27843 at 55-56.
1 Protective Actions for Particular Populations FEMA concludes that the SPMC provisions with respect'to protective J
i actions for schools, hospitals, and special needs populations are adequate. App. Ex. 43C at 38-39, 57, 60-62, 64-65. Emergency planning I
for special facilities was-hampered by the Tact that a number of public-and private institutions, schools, resource groups, hospitals and other-institutions refused to participate in planning out of deference to the l
i stand of the Governor of The Commonwealth against Seabrook.
E.g., Tr.
{
18842-43, 18970, 18974, 19011. Where a nursing home or other facility would not cooperate, the planning basis for special needs vehicles was based upon estimates with the actual transportation requirements to be verified at the time of an actual emergency. Tr. 21369.
A listing in the SPMC of all presently known schools, special facili-ties and special populations in the six EPZ communities is reviewed and updated at least annually. Ff. Tr. 21049 at 3.
Applicants have committed i
t
- to include the intervenor identified special facilities in the SPM0's listing and to update the data on day care centers quarterly due to apparent volatility of this segment of the special facilities universe.
Ff Tr. 21049 at 3-8; Tr. 21637-43.
See also Tr. 21112, 21115; MAG Ex.
86; Tr. 21186-92.
Applicants are to contact all public or private social service /
handicapped advocacy organizations in Northeastern Massachusetts which deal with the various categories of handicapped and seek assistance.
Tr.
21057.- Individuals in an elderly housing project will-be identified through the special needs survey. Tr. 21265-66.
FEMA has thoroughly reviewed a special needs survey done by the Applicants, and has'found the survey went beyond FEMA guidance requirements in' identifying the special needs population. Tr. 18199-18101.
o The SPMC includes notification methods and transportation provisions specifically tailored to the needs of various handicapped popu btions.
Ff. Tr. 21049 at 16-17. Transportation for the handicapped has been sized to assure that there is transport for persons required to accompany such
- )
individuals from their homes or institutions. Tr. 20874-75. The assumption of SPMC is that transportation will have to be provided for a
100% of the population of each facility. Tr. 21267.
In the event a call to verify needs for a special facility or homebound individual is unanswered and the failure to answer is not satisfactorily explained by other facts known to OR0, the default value vehicle or vehicles will be dispatched. Tr. 21073. All pre-identified persons will get the vehicle they need. Tr. 23155.
1 1
L -
1 While not required supporting p1_ans specific to the type of facility (i.e., school, day care center, or nursing home, etc.) were developed..
The plans contain sufficient basic information and instructions to assist j
a facility in implementing protective actions and provide directions _on how to interact with the OR0. ~ The plans also contain spaces to gather specific emergency-related information such as telephone numbers and transportation needs as part of the pre-emergency. planning process.
Ff.,
1 l
Tr. 21049 at 18-19; see also Tr.. 21204-05..Each special-facility identified in the SPMC has been or will be offered a copy of an emergency
~
1 L
plan specific to its type of facility, with an offer of assist'ance from NHY planners in tailoring the plan to reflect the circumstances of each-l facility. These plansL use standard radiological emergency-response plan
-techniques which are in use in The'Coninonwealth for other fixed nuclear sites. Tr. 21203; 21219-20, 21632. The plans which-have been generated would be usable without drills and training; indeed, past history has shown that nursing homes do a good job in most disasters with their own plan. Tr. 21222-23. However, these supporting-plans are not essential.to ensure the protection of health and safety during an emergency'since other mechanisms exist within the SPMC to compensate for the lack of a specific plan for each facility.
Ff. Tr. 21049 at 19; Tr." 21205, 21219-20, 2163F', -
Applicants remain ready to sit down with all special facilities willing to do so and tailor the generic facility-specific plan to their.needs. Tr.
21194, 21204-05, 21632. The supporting plans for all schools and special facilities are intended to-facilitate the implementation of protective actions such as sheltering or evacuation within each facility by the staff-and students / residents. Should an evacuation be recommended, and the 4
I
.I
l
- action concurred with by facility officials, facility staff will fulfill their responsibilities to ensure that'the patients / residents are safely boarded on evacuation vehicles and supervised during and after transport t
to Reception Centers and/or host facilities.
Ff. Tr. 21049 at 22.
k The Generic Hospital and Nursing Home Plans, prepared for, and 3
delivered to, these special facilities in the EPZ, contain_ instructions to I
administrators that during.an emergency they are to ensure that adequate personnel are.available to staff the institutions.. As such, facility
- d
-staffing determinations are made prior to any protective action recommen--
[
q dation for either sheltering or evacuation of the general public.
Ff. Tr.
1 21049 at 24. Moreover, the SPMC contains provisions to supply each of.the r
EPZ hospitals with a sufficient number of ambulances and other g
transportation resources to effect an evacuation of all or part of the.
expected facility' population.
Ff. Tr.'21049 at 30.
Eight EPZ nursing bomes provided'information about their transporta-i tion needs in response to inquiries about_the patient considerations that should be taken into-account. These considerations are reflected in the
--forms ~o[ Evacuation Transportation Resources available under the SPMC.
p, For example, for patients the nursing homes indicated might require-continuous medical treatment during transport, the plan provides for an ambulance. Two nursing homes which declined to provide patient information and the SPMC planners utilized licensed bed patient classification definitions as the basis for determining the types of evacuation transportation resources that would be planned for as the default values for these special facilities, which provided a relatively o
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accurate and stable means for assessing.the needs'oflthose patients.
Ff.
L Tr. 21049 at 30-31.
l The ORO has contracted under Letter of Agreement-(LOA) a total-of 89-
{
. ambulances -- equal to the number called for by the planning basis plus:
L three extra. Tr. 21510-21518, 21583.
The estimated need for 86 ambulances is probably an overestimate inflight of former planning efforts; y
a done by Massachusetts where the needs shown were less. Tr. 21513.
Another.eight ambulances are under. invoice and the companies contracted with have an additional 42 ambulances in their fleets. Tr. 21589.
In
-r addition, there are an additional 187 ambulances:in'the area, and others, controlled by municipalities through fire and rescue. services.- Tr.
4 21369-70, 21386.
q
~
Even if evacuation is the recommended protective action for-an area,.
administrators of. special-facilities may elect to' shelter.in the 'best interest of their patients or residents.
SPMC contains; procedures for facilitating such a decision and for the distribution of. KI should that.be l
authorized by The Commonwealth.
Ff. Tr. 21049 at"33-37.-LThese' include the availability of liaisons for advice. as to where-any needed assistance can be obtained, including health physics advice. 'Tr. 21408-09, 21413-14;.
ff. Tr. 21049 at 36.
The supporting plans developed for use by the public and private schools in a radiological emergency contain detailed instructions for implementing a sheltering recommendation.
Potential sheltering-areas have u
been identified in each EPZ school building based'on a preliminary assess-l.
ment of each facility by a NHY planner, and the information provided in the facility-specific sections of each school plan.
Basic sheltering
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-;2-instructions provided in the supporting plans include directions to close.
l-
. windows and doors, move' children to-interior areas, and turn off all.HVAC systems _during sheltering.
Ff. Tr. 21049 at 44-45.
Should a sch'ool not-have its supporting plan, similar sheltering instructions will be provided by School Liaisons.- Ff. Tr. 21049._at 45.
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The Honorable Nicholas.Mavroules-Congress of the United States.
House of Representatives Washington,-DC 20515
Dear Congressman Mavroules:
Your letter of March 1,1990,.to Chairman K neth M.'Carr expressing your concerns regarding the evacuation'of commu ities'within the Seabrook' ten mile EPZ has been referred to~me for resp nse.
i As you-know, these matters are under ad udication and hence the' Connission-l cannot respond to the concerns raised n your regt;ast.
However,-the NRC'
~
Staff has set forth its position' con erning these matters, based._on the -
-record of the hearings before the' A omic Safety and Licensing Board,;in'/
comprehensive briefs and pleading filed with both the Licensing' Board;and the Atomic Safety and Licensing peal Board.- Attached-please: find a -
1 summary of the Staff!s position on:the issues. raised in your. letter copies of the NRC Staff.Propos d Findings for both the New Hampshire:
portion of the Seabrook emer ncy plan and the Massachusetts portion of l
the emergency plan. Also e losed are copies of the relevant Board-decisions in the administr ions litigation and a copy of the, decision;of s
the 1st Circuit Court of' peals' decision in Massachusetts 1v. United States,.
856F.2d.378(1988).
~Yours truly,.
l James M. Taylor l
Executive Director for pf/. N u. p l~
I Operations i!
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-DOC-DT:~03/01/90 FINAL REPLY:-
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DESC:
ROUTING:
REQUEST ~INFORMATION CONCERNING? EVACUATION ISSUE TAYLOR-AS IT RELATES-TO SEABROOK THOMPSON BLAHA DATE: 03/07/90 RUSSELL-
.SCINTO ASSIGNED TO:
CONTACT:
NRR MURLEY SPECIAL INSTRUCTIONS OR' REMARKS:
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CRC-90-0217 LOGGING!DATE: Mar 17 90 l0 ACTION OFFICE:
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Nicholas Mavroules
. AFFILI ATION:
U.S.
HOUSE OF REPRESENTATIVES >
i LETTER DATE:.
Mar
.1 90 FILE CODE::ID&R-5 Seabrook'
SUBJECT:
Evacuation issue as it related to L Seabrook: Station ~-
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ACTION:
Signa $ure,of~Cha,irman t_
DISTRIBUTION:
OCA to:Ack, RF, DSB,- Cmrs, OGC i
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DATE~DUE:
Mar 21 90-SIGNATURE:
DATE SIGNED:-
AFFILIATION:
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March-1,1990 i
The Honorable Kenneth M. Carr Chairman U.S. Nuclear Regulatory Commission b
Washington, D.C.
20555 Dear Commissioner Carrt
- Today, the Noclear Regulatory Commission's licensing process regarding Seabrook Station, Unit I has been officially completed,
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save for appeals,,with the issuance of an approval for the Public j
Service company of New Hampshire's' full-power operational license.
Regrettably, as far as I am concerned, and as far as thousands of my constituents who reside within the radius of Seabrook's Emergency plannin Zone (hereinafter EPZ)are concerned,- the licensing process,gwhich is in place to address all safety and health issues, has been a failure.
This is so because there remains a substantial uncertainty about the Nuclear Regulatory Commission's, and therefore the Government's ability to protect the public in the
@ the gravity of the potential consequences event of a radiological emergency at the Station.
And because of of such an emergency, s,
g\\'g such uncertainty is simply not acceptable.
&_N g Throughout the course of the licensing process, I have often raised
\\ U questions about the process itself and have viewed the unseemly spectacle of the Nuclear Regulatory Commission and the Federal
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Emergency Management Agency changing the rules of the game as
' @/pk the said process progressed in an apparent attempt to circumvent the express will of the Congress in order to pass favorably on the th D-issuance of a full-power license.
In addition to rules' changes, I 3gg spoke often about the most serious allegations concerning the' f y y quality o
of construction, allegations which have never been iN addressed to my satisfaction.
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But as for rules changes and the quality of construction, the
@#g/o f answers to my questions are of such a technical nature that in the V
last analysis, I am bound to accept the conclusions of the experts.
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t Page 2 As I have said both on and off the record, I do not purport to be i
an -expert myself on nuclear power.
- However, there is one critically important issue on which I
do feel. comfortable and competent to judge, and that is the matter of evacuation..
In dealing with the evacuation issue, all you need to know are the communities within the ten mile
- EPZ, the road network-that y,e threads it's way throughout the Zone, the prevailing weather i[f g( p you should possess a little common sense as we f
patterns and the population counts at any time of the year, and if g
consider yourself an expert.
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Therefore, based on the preponderance of the evidence before me,
& it is my considered opinion that should there be a radiological
,Op' emergency at Seabrook Station, I would be forced to conclude that evacuation from within the boundaries of the ten mile EPZ and
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f(y beyond is not a feasible option.that it would also be impossible to adequately and I am further forced to conclude the public within and without the Zone in the case of such a dire a[f event.
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Using a legal analogy, I write this letter to ask the Nuclear t
g,,O' Regulatory Commission to prepare and submit a brief in which it l
will marshal the necessary technical data, observations, testimony l p d gg?
and all other evidence it has in it's possession to convince me that p
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my conclusions about the evacuation issue are erroneous.
And on a[M behalf of my concerned constituents, I demand that the Nuclear Regulatory Commission so respond in a
timely fashion to my request.
1 Ordinarily, I would not issue a " demand", but in the context of l
Seabrook's licensing process, and the rancor and distrust 'it has occasioned, especially amongst responsible members of Congress, including myself, I don't feel the least bit reluctant about it's usage.
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prove to me and the people of the In point of fact, I challenge the Nuclear Regulatory Commission to
\\g /,P 6th Congressional District of Massachusetts that evacuation is a realistic consideration in the l
l P,v y event of an emergency at Seabrook Station.
If you can meet that
' f challenge, I will accept your decision to grant a full-power license.
l0 If you should fail, then you can anticipate that I will continue to l
do everything in my power to reverse that decision.
For in the l
final analysis, while the need for the power provided by Seabrook Station is beyond question, nothing, and I repeat, nothing takes-precedence over the preservation of the public's health and safety.
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Page 3 I await your brief on the evacuation issue as it relates to Seabrook Station.
Sincerely,
-. m icholas Mavroules Member of Congress NM/mg i
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