ML20072H591

Contentions on State of Nh Radiological Emergency Response Plan,Vol 1.Certificate of Svc Encl

ML20072H591
Person / Time
Site:	Seabrook
Issue date:	06/27/1983
From:	Curran D, Jordan W HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8306290556
Download: ML20072H591 (24)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION tt% g s g pfgl&SE

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ATOMIC SAFETY AND LICENSING BOARD 4

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In the Matter of )

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

)

(Seabrook Station, Units 1 and 2) )

)

NECNP CONTENTIONS ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN, VOLUME I NECNP submits the following contentions on the State of New Hampshire's Radiological Emergency Response Plan, Volume I .

In general, we find the plan to be a cursory and incomplete ,

document, which provides only the barest skeleton of an emergency response plan. The plan is difficult to review because local plans have not yet been submitted, and because major portions are still missing. In areas where the state

( plan delegates authority to the local governments, or omits planning elements in apparent reliance on local governments, it is impossible to determine whether that delegation or reliance is justified.

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• No indication is given, either in the plan or the enclosure letter, of what is expected to be included in " Volume II."

Therefore NECNP treats Volume I as the completed plan for the state of New Hampshire.

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Major omissions from the state plan include designation of r eception and decontamination centers; a design for a public alerting system; preparation of an emergency public information brochure; and designation of radiological monitoring locations for the EPZ. Perhaps the most significant omission from the plan is the volume of Emergency Response Procedures, which must detail the steps taken to implement the state plan, and thus l provides a crucial indication of whether the plan is capable of implementation. According to the Radiological Emergency Response Plan (RERP ) , the New Hampshire Civil Defense Agency

" maintains a complete set" of this volume at the State

( Emergency Operations Center in Concord. RE RP a t 7 . 0 -1. When NECNP attempted to obtain a copy of the procedures through the Assistant Attorney General for New Hampshire, we were informed l

that the procedures were not yet available.

1 Decause of the New Hampshire State Plan's incompleteness and the unavailability of local plans, NECNP notes that it will have the right to file additional contentions on the plan as more materials and information are issued by the state and by New Hampshire localities. Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), ALAB-687, NRC (August 19, 1982) i i

CONTENTIONS i

1. The New Hampshire Radiological Emergency Response Plan violates 10 C.F.R. S 50.47(a)(1) and NUREG-0654 in that it does l

not include detailed procedures for implementing the plan.

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y Basis: Under 10 C.F.R. S 50.47(a)(1), the Commission may not license a nuclear plant unless it finds " reasonable assurance that adequate protective measures can and will be implemented." (emphasis added) NUREG-0654, S II.P.7, requires that each plan contain an appendix listing procedures required to implement the plan. This provision has been adopted a a regulatory requirement by virtue of footnote 1 to 10 C.F.R. S 50.47(b) . Moreover, even if not considered to be a regulation, this provision constitutes a factual basis for the contention that the state plan is inadequate without the accompanying procedures. A mere description of the elements of the plan, as given by the State of New Hampshire in its planning document, does not provide an adequate indication of how it will be carried out. Since the implementation of the plan relies on the coordination of a great number of actions by emergency response personnel, a determination that the plan can and will be implemented is impossible in the absence of a detailed description of the implementation procedures.

NECNP has been informed by the Assistant Attorney General f or the State of New Hampshire that the Civil Defense Agency has not yet released its emergency response procedures for review. When they are completed, they should be served on the parties-to this proceeding for review as to whether they

- satisfy Commission regulations and for the filing of relevant contentions. Unless and until those procedures are finalized,

v however, the plan violates the Commission's regulations and cannot support the issuance of an operating license.

2. The New Hampshire Radiological Emergency Response Plan does not support the " reasonable assurance" finding required by 10 C.F.R. 50.47(a)(1) in that it relies on local emergency response plans that do not exist.

Basis: The RERP states that it " identifies the State, local and private agencies that will respond to an incident with ,

potential effects on off-site locations in New Hampshire."

RERP at lii. The plan identifies towns in the EPZ, but does not describe local emergency response organizations, their functions or capabilities. Instead the plan relies vaguely on the existence of local plans that are to be submitted later.

There is no legal requirement, however, that local plans must be prepared or submitted by the local governments.

Until adequate local plans have been approved by the local governments, and the local governments have committed to

• implement the plans, the state plan, which at this time is the only plan for the Seabrook EPZ, provides no assurance that the public health and safety will be protected in the event of an accident. The following are examples of areas where authority is delegated to local governments without any demonstration

'- that the delegated responsibilities can or will be carried out:

a. local governments are expected to provide "ad hoc" and I

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" supplementary" evacuation transportation. RERP at 2.6-9 No specific information is given regarding the types or numbers of vehicles _needed, the location of the need, or whether the local

! governments are capable of providing it.

i b. The distribution of dosimeters for emergency workers for monitoring of their exposure levels is to be accomplished through the local Emergency Operations Centers, some of which i

have not yet been designated. RERP at 2.7-1, 2,4-8.

c. The state has not identified the host towns for relocation centers that it claims will be part of the i " coordinated offsite emergency response." RERP at 1.2-8.

d. Local governments are given primary responsibility for traffic control and law enforcement during an emergency. The l

4 State Police are to assist the local efforts. The plan includes no discussion of which agencies are expected to perform these functions, their capacity to perform them, or the extent of the need for assitance by the State Police. RE RP a t j 1,3-22, 2.6-12.

l The above examples are provided only for the purpose of illustrating the inadequacy of the state plan. The contention extends to all aspects of the state plan that rely upon or relate to the as yet nonexistent and unapproved local plans.

3. The New Hampshire Radiological Emergency Response Plan i

violates 10 C.F.R. S 50.47(b)(3) as implemented by NUREG-0654 at II.C.1.b in that the state has not specifically identified

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Y area 3 in which it requires federal assistance; nor has it made arrangements to obtain that assistance; nor has it stated the expected time of arrival of Federal asistance at the Seabrook site or EPZ.

Basis: NRC regulations at 10 C.F.R. S 50.479(b)(3) require ,

1 that " arrangements for requesting and effectively using assistance resources have been made" before offsite plans may be approved. NUREG-0654 further provides that each state "must.

make provisions for incorporating the Federal response capability into its operation plan," including " specific Federal resources expected", and their " expected time of arrival,at specific nuclear facility sites." S II.C.1.b The l

l New Hampshire RERP does not comply with these requirements in several respects. First, the RERP does not specifically i identify the state's needs for assistance from the federal l.

government. Section 1.4.5 simply describes general areas of need, such as " accident assessment", " s taf fing" of state l emergency response facilities, and " support for regulating boating activity." This generalized identification of need does not give the Federal government sufficient notice of the state's expectations for assistance. The plan must instead identify the particular functions that the State cannot carry out, and the equipment and number and qualifications of Federal personnel needed to carry them out. Second, the plan speaks of requests for aid as a future task. RERP S S 1.4.4, 1.4.5.

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]  ! There is no indication of the time at which Federal aid is to ,

be arranged for--whether it is sometime<in the near future, or i after an emergency has occurred. NECNP contends that in order to assure that Federal aid will be made availabe promptly upon request, specific types of Federal assistance must be prearranged by written contract with the Federal government.

! The arrangements for Federal aid must include an indication of when the aid is expected to arrive in the EPZ, as required by NUREG-0654 S II.C.1.b. Without these measures, there can be no reasonable assurance that the state plan can and will be implemented.

4. The State of New Hampshire RERP has not provided for

! nor assured the functioning of "... prompt communications among j principal response organizations to emergency personnel," in i

violation of 10 C.F.R. S 50.47(b)(6), and NUREG-0654.

Basis: The RERP's plan f or communication contains the i

! following defects:

a. NUREG 0654, S II.F.1, requires the state to " establish a reliable primary and backup means of communications" for its response organization. (emphasis added) For the National Guard, Civil Air Patrol, State Patrol, Dept. of Fish and Game, and Dept. of Public Works and Highways, the RERP provides a backup radio communication link to the NHCDA's primary telephone link. RE RP a t 2 . 2 -10 . For the rest of the support emergency organizations, including the

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Department of Agriculture,'the Division of Safety Services, (including Boating Safety,), thc Bureau of Emergency Medical Services, the Puhil Transportat! ion Safety Supervisor, and the New England Division of the American Red Cross, the only back-up commu'nication identified is the off-hour telephone

, n umb~er . RERP at 2.2-10. Similarly, the backup communication ,

link between the Local Dispatch Center and the local governments - the main channel of communication between the state emeigency response organization and local communities -  !

is a commercial telephone. Id. Overload and failure of 4

' telephones as occurred at Three Mile Island could result in total cutoff of communication links to these important eleme'ats  :

'o'. the emergency response network. Thus, this backup means ~of

, r communications is not reliable. A backup radio communication

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'or dedicated telephone line link to all agencies in the emergency response organizations must be provided, in order to establish a ' reliable communication systems, j

b. Communication with field personnel is to be carried out via radios that are noc yet available. The RERP supplies no cinformation on-their actual effectiveness, their range, distribution, or updating abd service,

c. The communications system required by NUREG 0654, S II.F.2, for medical emergency services is not yet designed or in place.

1 5. The State of New Hampshire RERP violates 10 C.F.R. S

\ l 'U 47(b)(10) in that relocation centers for evacuees have not (been established.

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Basis: According to the RERP, New Hampshire has yet to establish relocation centers for evacuees from the Seabrook EPZ. RERP at 1.2-8, 2.4-6. Relocation centers in host areas that are at least 5 miles, and preferably 10 miles, beyond the boundaries of the EPZ are required by NUREG-0654, S J.10.h.

Unless and until those relocation centers are established, there is no reasonable assurance that large numbers of people can be effectively evacuated from the Seabrook EPZ, or that those who evacuate will be adequately cared for in the event of an emergency.

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6. The State of New Hampshire RERP does not satisfy the requirements of 10 C.F.R. S 50.47(b)(7), Appendix E, 5 IV.D.2, and NUREG-0654 in that it does not adequately provide that information will be made available to the adult transient population within the EPZ regarding how they will be notified and what their initial actions should be in an emergency.

Basis: The New Hampshire RERP proposes to educate the public regarding emergency plans for the Seabrook EPZ via distribution of an Emergency Public Information Booklet and a' Utility Emergency Brochure; adhesive information labels for homes, schools, hospitals, and recreation facilities; instructions in telephone books; and posters prominently displayed in public places. RERP at S 2.3.2. Of these instruction methods, the information labels, telephone bcok instructions, and posters are directed at the transient population. RE RP , Table 2.3-1

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.The plan does not provide a reasonable assurance that these measures will afford the transient adult population within the plume EPZ "an adequate opportur ity to become aware of the information" regarding how they will be notified and how they i

should respond in an emergency, as required by NUREG-0654, S i II.G.2. For example,

a. The means and targets of distribution of the Emergency Public Information Dooklet, which contains the labels,.is not described in the plan. Therefore it is unclear how the informational labels will reach the " homes, schools, hospitals, and recreation f acilities" where they can be posted, according to S 2.3.2, 1 3.

J b. As discussed in 1 a above, labels are intended to be posted in homes, schools, hospitals and recreation facilities.

Posters are to be hung in state recreation facilities. There is no provision for visible public notice in hotels, motels, campgrounds, or restaurants, where much of the transient population will be. Moreover, the posting of public education notices should be mandatory rather than discretionary, since many Seabrook area merchants and proprieters are unlikely to voluntarily post labels with a discouraging message, such as evacuation instructions for a radiological emergency, on their premises.

c. According to the RERP , posters will be hung in state recreational facilities and distributed to local governments c

v-for posting. This does not provide adequate assurance that posters actually will be hung in all public parks and beaches where the large summer transient population is most likely to be located. The state should take responsibility for the posting of posters and provide a detailed map of all locations where they are~to be hung,

d. The plan does not give any assurance that the posters will be made of durable material that.will remain legible through..a season of wind, rain, and storms,

f. Although a significant proportion of summer tourists in the Seabrook area are French-speaking Canadians, the RERP does not provide for any form of bilingual public instructions.

7. The RERP for the State of New Hampshire violates 10 C.F.R. S 50.47(b)(4) in that it fails to establish means to provide early notification and clear instructions to the populace within the plume exposure EPZ. In this respect, the RERP also violates Part IV.D.2 and 3 of Appendix E to Part 50, and NUREG-0654 Sections E.5, 6,~and 7.

Basis: a. New Hampshire relies for public alerting of an

-- emergency on an initial audible alert consisting of sirens and m.

NOAA tone alert weather radios. RERP at S 2.1.4. However, the state has not completed the design for the Audible Alert System for the Seabrook Station EPZ. Id. Thus, there is no basis for a finding that the audible alert ~ system will function so that all persons within the EPZ can hear the warnings, and there can

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be no finding of compliance with S 50.47(b)(4) or of reasonable assurance that the health and safety of the public will be _

protected during an emergency.

b. The New Hampshire RERP makes no provision for coordination of public alerting between New Hampshire and Massachusetts. In the absence of coordination, the two separate alert systems may conflict, cause confusion, and

thr' eaten the public health and safety.

c. The RERP relies primarily on radio and television for i

communication of emetgency instruction once people have been

! alerted by the sirens. RE RP a t 2 .1-10 . This does not

~ constitute adequate means to address the thousands of people t

who may be at the beaches, parks and campgrounds in the

Seabrook EPZ without ready access to radio and television 1

j during a radiological emergency in the summer. These people i

may have to walk a distance to their cars to hear a radio; they

- may have arrived in buses and be' entirely without radios; and the RERP- does not describe any-ready access to radios and televisions. The RERP must provide for installation of f -loudspeakers at the beaches, parks and campgrounds in the EPZ to broadcast instructions in the event of a summer radiological 4

emergency.

d. A significant proportion of the summer visitors to the Seabrook EPZ are French-speaking Canadians, who either do not l

l speak English or have difficulty speaking and understanding 3

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English. Yet, the New Hampshire RERP does not provide for bilingual emergency announcements. In order to provide a reasonable assurance that the entire transient adult population in the Seabrook EPZ can be properly instructed during an emergency, the RERP must provide for emergency instructions in both English and French.

8. The New Hampshire RERP violates 10 C.F.R. S 50.47(b)(1) in that it does'not adequately demonstrate that "each principal response organization has staff to respond and to augment its initial response on a continuous basis."

Basis: NRC regulations at 10 C.F.R. S 50.47(b)(1) require

" adequate staffing" f c a continuous response to an emergency.

As provided by NUREG-0654, the organizations must be capable of response on a 24-hours basis. S II.A.l.e. The RERP gives many emergency response organizations major tasks without assuring that they have adequate staff to to fulfill their responsibilities, or that they can be carried out on a 24-hour basis. For example, l

a. The Division of Public Health is given the responsibility for all field radiological monitoring and conducting food and water screening, but only 3 two-person teams with 6 monitors are provided for all the ground level monitoring in the entire EPZ and 50-mile ingestion pathway zone. RERP at 2.5-7. It is simply impossible to expect this small number of people to be able to cover such a wide area.

v The staffing of the DPH laboratories is also insufficient to assure operation on a con'tinuous basis. The lab time estimates for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> day contain the cautionary footnote

" presupposing the availabilty of personnel." RE RP at 25-21 (Table 25-4). Unless the availability of personnel is assured rather than " presupposed", the plan is inadequate. The DPH is also given responsibility for running the decontamination centers, but no decontamination centers have been designated, nor have the personnel needs at these centers been assessed, much less assured.

b. The Emergency Medical Services Organization is required by the RERP to coordinate ambulance and hosptial facilities for a variety of needs, such as emergency medical treatment and special services, transportation of contaminated individuals to hospitals, treatment of injured individuals, and evacuation of non-ambulatory individuals requiring ambulance service. RERP at 1.3 14. Yet, no assessment has been made of the number of personnel needed to carry out these functions or the kinds and amounts of equipment needed to carry out the tasks. For instance, there is no discussion of the number of ambulances and ambulance drivers needed to evacuate nonambulatory patients and injured individuals from the EPZ. Tne RERP cites only the names of the ambulance services. Unless the state assesses these needs and provides assurances that these needs will be met, the plan is adequate.

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c. The Pupil Transportation Supervisor is responsible for coordinating bus. evacuations for the school children in the EPZ, as well as assisting the general evacuation. RERP at 1.3-17. No.information is provided on the number of bus drivers available; whether they will be trained in emergency procedures; or whether enough buses'are available to evacuate the children. The bus drivers' other general evacuation responsibilities are too vaguely described to provide any assurance they they can and will l>e carried out,

d. The American Red Cross has been given responsibility

. both to assist at the relocation centers (whose. location.and numerical capacity are'still undetermined) and to operate the long-term mass care centers. The plan provides no basis for assurance that the Red Cross is adequately staffed to perform both these tasks on a 24-hour basis,

e. The Civil Air Patrol is given three major tasks by the RERP: aerial observation of the EPZ; air and ground transportation of key officials in the emergency response organizations; and the transportation of field samples. Yet, there is no assessment of the number of trained pilots available.to perform the tasks, and the plan provides no basis q

for assurance that the CAP will be able to respond adequately on a continuous basis.

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9. The New Hampshire RERP violates 10 C.F.R. S 50.47(b)(7) in that the Media Center is located inside the Emergency i '

l Planning Zone.

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q Basis: The New Hampshire RERP, in compliance with 10 C.F.R. S 5 0.4 7 (b) (7 ) , provides for public communication via the news media. However, the Media Center, from which utility and government public information officials will release

-information to media representatives, is to be located inside the EPZ at the Seabrook Firemen's Association Building. RERP at 2.4-4, 2.4-7. In that location, the Media Center may have to be evacuated and the principal conduit of news to the public thereby cut off. Therefore, the Media Center must be located outside the EPZ.

10. The New Hampshire RERP does not provide a " reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency," as required by 10 C.F.R. S 50.47(a)(1), in that the plan does not provide reasonable assurance that sheltering is an " adequate protective measure" for Seabrook.

Basis: The New Hampshire RERP relies on two principal protective actions for the public: sheltering and evacuation.

The plan, however, contains absolutely no criteria for determing when shelter should be used as opposed to evacuation; evaluation of the sheltering capacity of the Seabrook EPZ; or any analysis of how sheltering is expected to contribute to dose reduction in the event of an emergency. The following examples illustrate the plan's lack of analysis of the adequacy of sheltering, in spite of Seabrook area characteristics which raise considerable questions about the effectiveness of sheltering there.

a. The plan includes no assessment of the capacity to protect the public of sheltering facilities of any sort in the Seabrook area, whether during peak use periods or at other times. Thus, there is no basis for a finding of reasonable assurance that sheltering constitutes an adequate protecting measures for all people who may need it.

b. The REF@ suggest that in order to achieve the greatest protection, " shelter should be sought in the lowest level of the building (e.g., in basements), away from windows." RE RP a t 2.6-6. No assessment is made of the number of structures in the Seabrook EPZ that have basements. In fact, it may reasonably be assumed that an unusually high proportion of Seabrook area houses, many of which are summer homes, do no have basements. Moreover, many of these summer houses do not have the tight construction that is necessary for effective sheltering.

c. The RERP concludes that " generally, sheltering can provide protection for up to two hours." RERP at 2.6-7. The plan does not give any indication of whether two hours is a reasonable period in which to expect passage of a radioactive plume. According to a sheltering study by the Sandia Laboratories, in the absence of data on wind characteristics, the durations of releases is typified by the release durations associated with the 14 categories investigated in the Reactor Safety Study (WASH-1400), which ranged between 0.5 and 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, 39 __. _

with most of the release durations falling between 0.5 and 3.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. Aldrich and Ericson, Public Protection Strategies in the Event of a Nuclear Reactor Accident: Multicompartment Ventilation Model for Shelters SAND 7 7-155 5, January 1978, at

29. The RERP therefore gives no reasonable assurance that the sheltering duration of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is adequate,

d. The RERP makes no attempt to quantify the degree of protection offered by sheltering, concluding only that it "can reduce both whole body and thyroid doses." RERP at 2.2-6-7.

The benefits of sheltering vary greatly, however, with the type of structure used. The Sandia Laboratories have calculated that the " shielding factor" -for airborne radionuclides is only 0.9 for wood houses without basements, as opposed to a factor of 1.0 for outside. (For wood houses with basements, the factor was 0.6; and for large office or industrial buildings, 0.2). Aldrich, et al., Public Protection Strategies for Potential Nuclear Reactor Accidents: Sheltering Concepts With Existing Public and Private Structures, SAND 77-1725, February, 1978, at 15, Table 3. Thus, reliance upon the large number of I wood frame structures without basements in the Seabrook area would be an ineffective means of protection in the event of a j major release of radioactivity. In any event, the State should l

not rely on sheltering until it has been demonstrated to be an ef fective means of dose reduction.

11. The New Hampshire RERP violates 10 C.F.R. S

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5 0.4 7 ( a) (1) and 50.47(b)(10) in that its evacuation time I

estimates do not provide a reasonable assurance that the public can be. safely evacuated during a radiological emergency.

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NECNP also incorporates by reference Contentions III. (12) and III.(13), which challenge the Applicants' evacuation time estimates.

i Basis: The New Hampshire RERP essentially incorporates the Applicants' evacuation time estimates without any of the i discussion of the bases for the ETE's which was included in the i

Applicants' Radiological Emergency Response Plan. See New Hampshire RERP, Table 2.6-7, at 2.6-27. Therefore, NECNP

, reasserts Contentions III.(12) and III(13), on the Applicants' Plan, and their bases. In addition, NECNP offers the following additional bases for this contention:

a. The State RERP contains no analysis of whether there are enough buses and bus drivers to evacuate school children in one shift, or whether the buses must return several times to pick up children from schools.

b. The State RERP contains no discussion of traffic patterns in the Seabrook EPZ, including capacity for traffic control; congested intersection; vehicle mix; or roadway i

capacity.

c. The RERP states that it relies on the assumption that l people will evacuate in private vehicles. RERP at 2.6-9. The plan includes no. discussion of evacuation of people in

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hospitals and rest homes, people without automobiles; or people who have been dropped of f at the beach by buses that have then left the area.

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12. The New Hampshire RERP violates 10 C.F.R. S 5 0.4 7(b) (9 ) in that it f ails to demonstrate that " adequate methods, systems, and equipment for assessing and monitoring acutal or potential offsite consequences of a radiological emergency condition are in use."

Basis:

a. Only 6 persons (three 2-person teams) are to be deployed to determine ground level radiation in the EPZ and ingestion-pathway zone, to assess radionuclide deposition on pastures and in animal feed, and to collect feed, liquid milk, and water samples for analysis in Department of Public Health (DPH) laboratories. RE RP a t 2.5-7, 2.5-15. Monitoring of other crops, orchards, and food processing facilities is to be conducted on an "as needed" basis by " supporting agency personnel" who are not identified. The provision of three teams to perform a large number of monitoring tasks over a 50 mile radius is woefully inadequate to meet the task.

b. The RERP does not establish any monitoring locations, thus there is no reasonable assurance that the EPZ and the ingestion pathway can be adequately monitored.

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c. The RERP does not establish a location for the Incident Field office (IFO), where the DPH representative will coordinate monitoring decisions and gather monitoring information.

d. From the time that a decision is made to deploy the l

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monitoring teams, it will take an estimated one and one half hours before they even report to the IFO. RERP at 1.5-7. Thus, it may be several hours more before they reach a monitoring location and relay tests results back to the DPH. The time for deployment of monitoring personnel must be drastically reduced if the emergency response organization is to obtain the information it needs to make such crucial decisions as whether sheltering is needed and evacuation direction.

e. The DPH laboratories where field samples are to be analyzed are not assured to be available on 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis, in viulation of 10 C.F.R. S 50.47(b)(1) and NUREG-0654 S II.A.l.e. RERP at 2.5-21.

f. The state does not have the capacity to monitor the aerial plume; yet, no arrangements have been made for Federal assistance. RERP at 1.4-4.

13. The New Hampshire RERP violates 10 C.F.R. 50.47(b)(12) in that it does not provide adequate arrangements for medical services for contaminated injured individuals.

Basis: NRC regulations at 10 C.F.R. S 50.47(b)(12) require that " Arrangements are made for medical services for contaminated injured individuals." The New Hampshire RERP simply identifies hospitals that are capable of treating radiation accident patients. The three hospitals identified as principal to the seabrook emergency response are all located inside the EPZ and cannot be relied upon for use during an 2_

emergency. RERP at 2.8-9. Moreover, no information is provided regarding the projected level of need of medical assistance or capacity of the listed hospital to treat injured and contaminated individuals; ambulance capacity; or the number of medical personnel in the area who are trained to handle cases of radiation exposure. Means for communication between the ambulances and the emergency response organizations are not clear. For example, the central dispatching service intended to coordinate medical calls is not yet in place. RERP at 2.2-13.

Conclusion For the reasons stated above, the New Hampshire Radiological Emergency Response Plan does not satisfy the requirements of 10 C.F.R. SS 50.47(a) and (b), and cannot support the issuance of an operating license for the Seabrook Nuclear Power Plant.

Respectfully submitted, Diane Curran f gf -

g William S. ordan, III HARMON & WEISS 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006 (202) 833-9070 Dated: June 27, 1983 NECNP gratefully acknowledges the assistance of Cynthia Smith in preparing these contentions.

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CERTIFICATE OF SERVICE I certify that on June 27, 1983, copies of NECNP CONTENTIONS ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN, VOLUME I were served by first-class mail or as otherwise indicated on the following:

• Helen Hoyt, Esq., Chairperson Rep. Roberta C. Pevear Atomic Saftey and Licensing Board Drinkwater Road Panel Hampton Falls, NH 03844 U.S. Nuclear Regulatory Commission Washington, DC 20555

• Dr . Emmeth A . Luebke Phillip Ahrens, Esq.

Administrative Judge Assistant Lttorney General Atomic Saf tey and Licensing Board State House, Station #6 U.S. Nuclear Regulatory Commission Augusta, ME 04333 Washington, DC 20555

• Dr. Jerry Harbour Robert A. Backus, Esq.

Administrative Judge 111 Lowell Street Atomic Saf tey and Licensing Board Manchester, NH 03105 U.S. Nuclear Regulatory Commission Washington, DC 20555 i

Atomic Safety and Licensing Board

• Thomas G. Dignan, Esq.

Panel R. K. Gad, III, Esq.

U .S. Nuclear Regulatory Commission Ropes and Gray Washington, DC 20555 225 Franklin Street Boston, MA 02110

! Atomic Safety and Licensing Appeal Dr. Mauray Tye, President Board Panel Sun Valley Asociation U.S. Nuclear Regulatory Commission 209 Summer Street Washington, DC 20555 Haverhill, MA 01830 Docketing and Service

• Roy P . Lessy, Jr. Esq.

U.S. Nuclear Regulatory Commission Robert G. Perlis, Esq.

Washington, DC 20555 Office of the Executive Legal Director Maynard B. Pearson U.S. Nuclear Regulatory 4 0: Monroe Street Commission Amesbury, MA 01913 Washington, DC 20555

, Mr. Angie Machiros Anne Verge, Chair i Chairman Board of Selectman

! Board of Selectmen Town Hall Town of Newbury South Hampton, NH 03842 Newbury, MA 09150 l

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~

Jo Ann Shotwell, Esq. George Dana Bisbee, Esq.

Assistant Attorney General Edward L. Cross, Jr., Esq.

Department of the Attorney Asst. Atty. Generals General State House Annex 1 Ashburton Place, 19th Floor Concord, NH 03301 Boston, MA 02108 John B. Tanzer Letty Hett, Selectman Town of Hampton Town of Brentwood 5 Morningside Drive RFD Dalton Road Hampton, NH 03842 Brentwood, NH 03833 Edward F. Meany Sandra Gavutis (

Town of Rye Town of Kensington 155 Washington Road RFD 1 Rye, NH 03870 East Kensington, NH 03827

• David R. Lewis, Esq. Diana P. Sidebotham Atomic Safety and Licensing Board R.F.D.2 U.S. Nuclear Regulatory Commission Putney, VT 05346 Washington, DC 20555 Richard E. Sullivan, Mayor City Hall Newburyport, MA 01950 Alfred V. Sargent, Chairman Donald E. Chick Board of Selectmen Town Manager Town of Salisbury, MA. 01950 10 Front Street Exeter, NH. 03833 Diana P. Randall 70 Collins Street Seabrook, NH. 03874 Senator Gordon J. Humphrey Senator Gordon J. Humphrey U.S. Senate 1 Pillsbury Street Washington, D .C . 20510 Concord, NH 03301 (Attn: Tom Burack) (Attn: Herb Boynton)

Selectmen of Northampton Town of Northampton New Hampshire 03862 Diane Curran

• By Hand e

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