ML20077J471
| ML20077J471 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/11/1983 |
| From: | Curran D, Jordan W HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8308160435 | |
| Download: ML20077J471 (6) | |
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UNITED STATES OF AMERICA Ojy q 0
NUCLEAR REGULATORY COMMISSION
'83 AUG 15 R2:50 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Ef7 I~ f EEQ t.t.
Maalfj3 & EE.:Vir,
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c4Anco In the Matter of
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443 NEW HAMPSHIRE, et al.
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50-444
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(Seabrook Station, Units 1
)
and 2)
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)
NECNP CONTENTIONS ON RADIOLOGICAL ZMERGENCY RESPONSE PLAN FOR GREENLAND, NEW HAMPSHIRE The Radiological Emergency Response Plan for the town of Greenland, New Hampshire, does not comply with 10 C.F.R.
S 5 0.4 7 (a) (1) in that the town is neither adequately equipped nor staffed to implement the provisions of the plan in the event of an emergency, nor have specific arrangements been made for supplementation of resources from state or federal authorities.
There is thus no reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at the Seabrook Nuclear power plant.
Basis: The town of Greenland lacks adequate equipment and/or staf f to respond to a radiological emergency in the following respects:
a.
Under the Greenland RERP, the police department is responsible for the following:
Ensure that the official notification function has been completed.
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Assist the Civil Defense Director / Fire Chief with the public alerting / notification f unction.
Provide access control on local roads in Greenland and traffic control along evacuation routes in Greenland.
Provide security at Greenland's emergency facilities and for all evacuated areas.
Notify the appropriate officials of an emergency action level declaration.
Maintain incident related emergency communications until the EOC is activated.
RERP at I-18.
The Greenland Police Department has a staff cf 3 sworn officers. RERP AT C-1.
It would simply be impossible for these three people to perform the functions of notification and
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communication; traffic and access control and three major
'I intersections; and providing security at" emergency W
2 facilities.
The plan gives no indication-of how thisrfeat is to be accomplished, nor,does it provide any specific
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arrangements for assistance from other g'overnments.
'3 b.
According to the Greenland RERP, the town has two s
schools; Central School with.276. students /and 30 staff;'and v
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- Traffic and access 1 contraljin Greenland-are important
-functions because a numberlofilmportant evacuation routes and access roads'.to evacuatioh\\. routes traverse the town, including, i
Route.95, Route 101, and Route 151.
There;are three' major
- intersections which are.likely(to require-traffic control in the. event of ang.emergancy:'the'intersectiortsJof Route 101 and Route 151,- the inte'rsection.of Ocean Road and Route '.101; and the intersectih: d of Routie 151 and Breakfast Hill Road.
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Mrs..Gowen's Kindergarten which is pupil and 2 staff members.
Appendix F.
The plan gives no indication of whether the town has sufficient numbers of school buses or other vehicles to evacuate these students in the event of an emergency.
If there are not enough vehicles to transport the students, the plan does not establish whether the town intends to evacuate
. 1 students in several trips or whether it has made arrangements for the supplementation of its bus fleet.
Moreover, it does not' indicate how the need to evacuate children in shifts or to import buses in the event of an emergency could affect evacuation times.
c.
Under the Greenland RERP, the Highway Agent is to 4
" provide resources for emergency maintenance of evacuation routes in Greenland."
RERP a t I-19.
This responsibility involves clearing of snow and removal of stalled or wrecked vehcicles from route I-95, two major state highways and local
, access roads to the evacuation routes.
Yet, the Highway ~ Agent consists of only one individual, with seven others hired on an "as needed" basis.
RERP at C-3.
No indication is given.of how the' assistance of these'other individuals will be assured in an emergency.
The town's snow removal equipment consists of'only
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two snow plogs, and one of the trucks needed.to push the plows
'is rented.
Id.
The town relies on private towing companies I
for' towing of disabled vehicles, but the plan includes no arrangements for the availability of-those trucks in an iL,
. emergency.
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The Greenland RERP violates 10 C.F.R. S 50.47(a)(1) in that it does not provide means or assign responsibility for the protection of individuals whose mobility may be impaired.
NUREG-0654, S II.J.9. d.
Basis: The Gr eenland RERP requires the Deputy Fire Chief to Assess the emergency medical transportation requirements and transportation requirements for special facilities, people without automobiles, and people with special needs (i.e. hearing impaired, mobility impaired, non-ambulatory, etc.)
itERP a t I-17.
It is not adequate fur the plan to simply require that the need for special transportation services be assessed at some time in the future.
The plan cannot provide a reasonable assurance that adequate protective measures can and will be taken unless and until it contains a description of the need for special transportation services; the. capacity of the town to provide the services; and clear establishment.of any supplemental outside services which are needed to carry out the plan.
Respectfully submitted, Q
Diane-Curran William S. Jordan, III HARMON & WEISS 1725 I Street, N.W.
Suite.506 l
Washington, D.C.
20006 (202) 833-9070-l Dated: August 11, 1983 l
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CERTIFICATE OF SERVICE I certify that on August 11, 1983 copies of NECNP CONTENTIONS ON RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR GREENLAND, NEW HAMPSHIRE 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 Attorney General Atomic Saftey 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 Saftey and Licensing Board Manchester, NH 03105 U.S. Nuclear Regulatory Commission Washington, DC 20555 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 William F. Patterson Office of the Executive Legal Director Town Manager's Office U.S. Nuclear Regulatory Town Hall - Fr iend St.
Commission Amesbury, MA 01913 Washington, DC 20555 Mr. Angie Machiros Anne Verge, Chair Chairman Board of Selectman Board of Selectmen Town Hall Town of Newbury South Hampton, NH 03842 Newbury, MA 09150
, 4
[
Jo_ Ann Shotwell, Esq.
George Dana Bisbee, Esq.
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Assistant Attorney General Edward L. Cross, Jr., Esq.
Department _of the Attorney Asst. Atty. Generals General State House Annex l 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 LTown of Northampton New Hampshire 03862 as
_s Diane Curran
- Hand Delivered
- Federal Express l
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