ML20072H545

Contentions on State of Nh Radiological Emergency Response Plan.Certificate of Svc Encl

ML20072H545
Person / Time
Site:	Seabrook
Issue date:	06/22/1983
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8306290521
Download: ML20072H545 (8)

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NUCLEAR REGULATORY COMMISSION 9 *p S -

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ott # ss '

Q In the matter of: ca PUBLIC SERVICE (X)MPANY OF Docket Nos. 50-443 OL-NEW HAMPSHIRE, et al 50-444 OL (Seabrook Station, Units 1 and 2)

SAPL CONTENTIONS ON NEW HAMPSHIRE

_RADIOIDGICAL EMERGENCY RESPONSE PLAN CONTENTION 1 .

The New Hampshire Radiological Response Plan (NHRERP), is '

insuf ficient to provide reasonable assurance that adequate protective-measures can and will be taken in the event of a radiological emergency as r equ i r ed by 10 C.F.R. i. 47 ( a)(1) , in that the plan is incomplete.

Basis: The NHRERP is incomplete in that the town EPZ's have not been set up, state police have not yet received high-band portable .

radios (see page 2.2-6), the line of succession from governor has l s

not yet been established (reference page 2.2-9), radios for field $

j units, especially DPH field monitoring teams are not yet available $

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( see page 2. 2-11), four-channel emergency medical communications and f sys tems have not yet been ins talled (page 2. 2-14 ), a dispatch center for emergency medical mobile units has not been selected (page 2.2-14), reception facilities.have not been designated (page 2.6-28),  :

monitoring locations for the Seabrook Sta t ion EPZ have not yet been  ;

de termined (page 2.5-15), Seabrook S ta t ion recep t ion f aci li t ies have i

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not yet been determined (page 2.6-28). These are only a few of the many incompletions which prevent ~the NHRERP f rom providing a basis-upon which reasonable assurance as required by the regulation 'can be established.

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CONTENTION 2 -

Contrary to the requi remen t o f NUREG-0654 II A 2.b, New I'.ampshi re law does not provide clear authority for the governor to order a l protective response, to include evacuation.

Basis,: NH RSA 107:8.

l l CONTENTION 3 I

Contrary to the requirements of NUREG-0654 11 A 1.b, there is no designation of the role of each organization and sub-organization s

in the NHRERP.

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. l Basis: The plan fails to define the role of the municipal, >

corporations in the plan and fails to acknowledge the lack of town plans.

l CONTENTION 4

! l l The evacuat ion est imate set forth in Table 2.6--7 is unreliable and underestimated.

l l Basis: The evacuation time estimates fail to comply with the j requirements of NUREG-0654 J8'and Appendix 4. This contention is based, in part, on NUREG-CR2-2903, "An Independent Assessment of Evacuation Time Estimates for a Peak Population Scenario in the t  !

l- Emergency Planning Zone of the Seabrook Nuclear Power Station". This contention is also based on the " Dynamic Evacuation Analysis;

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Indspondent Assessments of Evacuation Times From the Plume Exposure Pathway Emergency Planning Zones of Twelve Nuclear Power Stations, February 1981, Federal Emergency Management Agency.

CONTENTION 5 e

The NHRERP falls to make an adequate showing that 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per i i

day capability exists to determine the doses received by emergency i

a personne1 and hence faiis to comply wi th 10 C.F.R. 50.47 (b) (11) j i and NUREG-0654 K3.

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-Basis: 4 There has been no discussion of what equipment will be l

provided at the reception centers for Division of Welfare and Red Cross workers monitoring evacuees. The exposures of the numbers of

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emergency workers who will need to be in the poximi ty of contaminated F

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evacuees cannot be handled by the small amount of equipment described *i L

in Sect ion 2. 7. 2 E The Division to Public Works and Highway's employees n responsible for clearing the roadways, the State Police and all other

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is involved in an emergency response in the EPZ will require dosimeters. E_

There are too few dosimeters and of those there are, too few have b s_

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l the capacity to measure exposures beyond the 20R range. DPH staff 13 will be overburdened with other responsibilities such as analysis $

(e of environmental media, estimation of the total population dose and '

I locating and tracking the plume. There has been no showing that DPfi 5

e has adequate staff to monitor and evaluate worker exposure records, l too.

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CONTENTION 6 The NHRERP fails to meet the requirements of 10 C.F.R. 50.47 (b) (11) and NUREG-0654 K 56 because there has been no showing that .

the means for radiological decontamination of emergency personnel wounds, supplies, instruments and equipment have been established.

Furthermore, there has been no showing that there exists a means for waste disposal.

Basis:

There have been no decontamination centers set up (see page 1.3-10) and no showing that such centers, when and if set up, will 'be adequately staffed and equipped and able to per form the ,

numbers of decontaminations that might be required. No numerical comparison of hospital treatment capacities and emergency workers who might requirement treatment have been made. Waste disposal as described in the NHRERP is not realistic. The Division of Public Health Services will likely be overburdened with other tasks as it  !

b is.

No disposal site for contaminated materials is specified. C CONTENTION 7 The periodic exercises of emergency response capabilities as described in the NHRERP do not satisfy the requirements of 10 C.F.R. 1 50.47 (b) (14) or NUREG-0654 1 b.

Basis:

l NUREG-0654 1 b states that "Some exercises should be unannounced." The NHRERP at page 3.1-4 states that: "The date and time period deseribed ir! the scenario wi11 coincide with the scheduling agreed upon with the utility, with other states in the EPZ, and with NRC and FEMA." The NHRERP does not satisfy the 4

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requircmant for unannounccd exercises. Only under wholly unannounced conditions can the readiness of emergency response organizations be given a true test.

CONTENTION 8 The NHRERP fails to comply with the requirements of 10 C.F.R. 50.47 (b) (10) and NUREG-0654 J 11. The measures for protecting the public f rom contaminat ion through the inges tion exposure pathway are not adequate.

Basis: Maps for recording survey and monitoring data, key land use data, dairies, food processing plants, water sheds, water suply intake and treatment plants and reservoirs have not yet been prepared (see page 2,4-10. The NHRERP states that: "In New Hampshire,

. contaminat ion of dairy f eed is not likely to be a significant problem, since 75-80% of all feed is stored." No provision for the other 20-l 25% of feed is made. No provision is made for the case in which i

I contamination of animal feed occurs before harvest time. A list of all public water supplies does not appear in the Apendix as is stated l at page 2.6-45. Lists of commercial agricultural f acilities for the t

l Seabrook Station EPZ do not appear in the appendix as claimed at page 2.6-45. There has been no showing that there are lists with j t.he names and locations of all facilities which process milk and other food or agricultural products f rom the Seabrook Station EPZ as is required by NUREG-0654 J 11. The Division of Public Health has 1

I f ailed to show that it has adequete s taf fing to perform the monitoring l

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and evaluation of milk, wa ter and other foods as described in Appendix B at XIV.

CONTENTION 9 The NHRERP falls to comply with the requ i remen t s o f 10 C.F.R. 50.47 (b) (10) and NUREG-0654 J 12 as it has made no showing that the means for registering and monitoring of evacuees at relocation centers in host areas exist or that personnel and equipment are available to provide the capability of monitoring all EPZ residents and transients within a 23 hour2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> period.

i Basis: Decontamination of evacuees cannot be provided as '

necessary unless the capability exists to monitor all of the residents

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and transients who have evacuated the EPZ. There are no reception centers designated for the Seabrook Station EPZ.(see page 1.3-18).

There has been no showing that there is provision for adequate trained staf f to run these centers. There has been no showing that the state is in possession of suf ficient equipment and supplies to equip these centers. There are no letters of agreement with the local Red Cross chapters which are, under this plan, responsible for providing food and shelter to evacuees. The local Red Cross directors' names are missing from page 1.3-18. The office of the Division of Welfare [

r_esponsible f or oversight of the opera t ion of the Recept ion Centers t is not named (see page 1.3-22). How the NilCDA IFO controller is to 5

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direct the operations of the reception centers in addition to all 3

5 of his or her other responsibilities is not spelled out. Which s tate c

{r emergency workers and which local emergency workers will be free to h

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,_.,. y conduct-monitring functions at the recep tion centers is never clearly stated. Whether such workers will report to perform these tasks is also in question.

Respectfully submitted, '

Seacoast Anti-Pollution League By its attorneys, BACKUS, SHEA & MEYER By:

R6ber1 K. eackus

, 116 Lowell St., Box 516 Manchester, N.H. 03105 June.22, 1983 Tel: (603) 668-7272 T

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, ,. .. , CERTIFICATE OF SERVICE co G 1

( Deeg..,9 y Mc '\

Helen Hoyt, Chm. Thoms" p Admin. Judge Roper G.y nd Ma fg@ 7;ge nan, Esq.

Atomic Safety & Lic. 225 l' Board - U.S. NRC nk1fn Street ~ _

Bosto Mk' 10:. -

Washington, DC 20555 *-

• 4 Sen. Gordon Ihrnphrey Attn: ' Ibm Burack i {d

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"#Y U.S. Senate Atom c Saf &Lic.

U. S. NRC Wadington, DC 20510 as m gton, DC 20555 ash ngton DC 20555 Sem Gordon W rey Roy P. Lessy, Jr., Esq.

Robert L. Chiesa, Esq.

Herb Boyntm '

Office of Executive 95 Market Street 1 Pillsbury Street Concord, NH 03301 U. C '

Washington, DC 20555 Maynard B. Pearson Phillip Ahrens, Esq.

Asst. Atty. General Jane Doughty '

Rep. Amesbury, MA Field Director State House, Station #6 40 Monroe St. Augusta, ME 04333 SAPL Amesbury, hm 01913 5 Market Street Portsmouth, NH 03801

., Donald E. Q11ck Anne Verge, 01airperson Board of Selectmen Dana Bisbee-

'Ibwn Manager 10 Front Street Town Hall Attorpey General's Office Exeter, MI 03833 So. Hampton, NH 03842 State of New Hampshire Concord, NH 03301 Office of Selectmen Dr. Emmeth A. MeMe David R. Lewis Town of North Hampton Admin. Judge Atomic Safety & Lic. Brd.

Morth Hampton, NH 03862 Atomic Safety & Lic. U.S. NRC - Rm. E/W-439 Board - U.S. NRC Washington, DC 20555 Washington, DC 20555 Anne Verge, Chm. Jo Ann Shotwell, Asst. AG Calvin A. Canney, Board of Selectmen One Ashburton Place, 19th City Mgr.-City Hall

'Ibwn Hall Floor 126 Daniel Street South Hampton, NH 03842 Boston, MA 02108 Portsmouth, NH 03801 ,

John B. Tanzer William S. Jordan, II, Esq. Mr. Angie Machiros, Chnnn.

Town of Hampton Ellyn R. Weiss, Esq. Board of Selectmen '

5 Morningside Drive 1725 I Street, N.W. Town of Newbury Hampton, NH 03842 Suite 506 Newbury, hm 09150 Washington, DC 20006 Edward Meany Dr. Muray'fye, President Sandra Gauvutis a Town of Rye Sun Valley Assoc. Town of Kinsington 155 Wn aington Road  !'

280 Haverhill Street RFD 1 Rye, NH 03870 Lawrence,hn 01840 East Kensington, NH 03827 '

Alfred Sargent, Chm. Letty Hett, Selectnun Richard E. Sullivan, Mayor 3 Board of Selectmen Town of Brentwood City Hall  ;

Tbwn of Salisbury,hm 01950 RFD Dalton Road Newburyport, AM 01950 -

Brentwood, Mi 03833