ML20078A047

Contentions 1-13 Re Radiological Emergency Response Plan. Point-by-point Analysis of Plan Reveals Major Deficiencies

ML20078A047
Person / Time
Site:	Seabrook
Issue date:	09/19/1983
From:	Cross C, Tanzer J HAMPTON, NH, SHAINES & MCEACHERN
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20078A024	List: ML20078A023 ML20078A047
References
NUDOCS 8309220214
Download: ML20078A047 (16)

Text

r- . .___m . _ _ .

i.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00CKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARDSNRC l83 SEP 21 P2:14 In the Matter Of: Public Service Company of New Hampshire et al Dogket, g h 'f %

Seabrook Station, Units 1 and 2 COMETm >?.i.

TOWN OF HAMPTON - CONTENTIONS ON THE RADIOLOGICAL EMERGENCY RESPONSE PLAN The Town of Hampton, designated as an interested municipality, hereby submits the following contentions to the Radiological Emergency Response Plan (the " Plan") prepared for the Town.

1. The Plan is based upon inaccurate or misleading information, compiled primarily from secondary sources and thus cannot assure that

~~

the public will be protected in--the event of a radiological emergency.

Basis: There are numerous factual i.naccuracies in the Plan.

2. According to a report by Alan M. Voorhees & Associates, prepared for the NRC (hereinaf_ter the Voorhees Report), local officials feel that the numerical _ strength of the police forces as stated in the local plan i_s invalid.

b. The Plan states the projected resident population of Hampton in 1985 to be 11,650 people with a "mean peak" seasonal population of 61,500. The Plan fails to state how this figure was derived and the Town believes that this figure substantially understates the number seasonal, of people who may be in the Town of Hampton on a permanent, and transient basis on any given summer day when the Hampton beaches and beach front properties and businesses are filled to capacity.

~

~

8309220214 030921, PDRADOCKC5000g C

SHAINES. MADRIGAN & MCEACMERN e PROFE.sssONAL ASSOCIATION 2S MAPLEwOOD AVENUE P O BOX 360 PORTEMOUTM NM 03801

I

c. The Plan incorrectly characterizes the nature of Town government in Hampton (Plan, p.I-15) as the Town of Hampton has a Town Manager form of government and the Town Manager is in administrative control of the Town. Police, fire, and public works chiefs report to the Town l

Manager.

d. The assignment of public health functions to the building inspector (Plan, p.I-18) is entirely inappropriate as the building in- '

spector has neither responsibility nor expprtise for public health matters. ,

e. In the Appendices, the lines of succession for the police chief, fire chief, and public works director are incomplete (Plan, p.A-2). The police iny.entory is also inaccurately stated and potentially misleading if the inclusion of -"Special Of ficers" in the total figure is intended to represent those- available .in the event of an emergency.

Special Of ficers in the Town of Hampton are used mainly in the summer and their effectiveness and response rate in the event of an emergency is questionable _. - -

2. Tha Plan does not" assure that "each principal response organ-ization has staff to respond and to augment its initial response on a continuous basis", (C.F.R. Section 50.47(b)(1), in the following respects: .

a. There ,is no assurance that necessary police and fire department personnel will be reachable or capable of responding promptly in the event of a radiological emergency.

Basis: According to the Voorhees Report, at any given time

~$MAINES, M ADRIGAN & McEACHERN . PROFESSONAL ASSOCdTION

2. M APLE*000 AVENUE P O BOR 360 - M)RTSMOUTH NM 03801

much of the police force and fire department will be unreachable or out of the area, and thus incapable of responding promptly to an emergency. In addition, the utility has, itself, solicited fire department employees to go to the site and assist during an emergency.

Thus, they and any policemen who respond to this solicitation will be unavailable to fulfill their responsibilities under the Plan.

b. Under the Plan the highway department is responsible for assuring a successful and smooth evacuatio by clearing roads of snow, stalled cars, and accidents and otherwise assuring that th'e roads remain open for evacuation. The local highway departmerit does not have sufficient personnel or resources to fulfill these responsibilities and co,mmon arrangements for ad hoc assistance by private contractors are insuf ficient to assure that these responsi-bilities will be meet. -

Basis: The Town highway department consists of 36 persons, 19 of whom are sewer personnel. Th4s simply is not sufficient staff for l

adequate perfor,mance of_ the . tasks assigned by the Plan to highway de-partment personnel. In ad~ition, d the road agent is to report to the EOC during an emergency, so he maybe delayed or unable to perform his evacuation route maintenance responsibilities. Finally, ad hoc re-liance on private contractors would be misplaced due to the un-certainty of response, ths number of such contractors available, and the lack c5 pre-existing arrangements.

c. Under the Plan, the local fire department is responsible for such tasks as assisting in monitoring for evacuation, for decontamination of affected individuals, for operating and maintaining

.ss4,~cs.m' .o e. ~ . uce cse=~ . ,=orcsso~.c associaro~

2s uartewooo avt~ut . e o som seo. ro=TsuouTH ~w ossoi I

l the EOC or public alert system (PAS), and assessing emergency transportation needs. The Hampton fire department does not have sufficient personnel or resources to fulfill this responsibility.

Basis: Hampton has 36 firefigthers with 15 on call. The utility has solicited fire department personnel to assist at the site in the event of an smergency, so they may not be available to fulfill their planned responsibilities. To the extent that ,the Plan relies on volunteers, there is no assurance that fthe personnel will be reached or available in the event of an emergency. Even if the volunteers r.espond, however, the personnel and resources will be in-adequate to perform their tasks. The fire chief in Hampton has re-viewed the tasks which~.'the Plan has assigned to the fire department and has stated that his resourhes are inadequate to meet those responsibilities. The Voorhees Report reflects the fact that other officials have stated concern over the insufficient number of firemen,

d. There is no assurance # that' local emergency response personneli will be reachab~le or th'at ,th'ey will be able to respond soon ufe enough to as'sure protection of the public health and safety.

Basis: The Selectmen are given a great deal of responsibility under the response Plan, yet they are only part-time of ficials who may have other full-time jobs outside of those in Town government. The c

Selectmen are elected annually which potentially destroys continuity and hinders effective education and training for responsibilities under the Plan.

e. The Plan does not provide for adequate backups or

_4_

SM AIPoES. M ADRG AN & MCE ACHERN

• P*OFU.~ eat AS%CATON

alternates for important positions in the event that the assigned personnel are not available.

Basis: In many positions set forth in Appendix A, no alternates or backups have been listed for the Town Manager, Civil Defense Director, Police Chief, Fire Chief, RADEF officer, Puolic Works Inspector, Building Inspector, Town Clerk, School Superintendent, or Principal of HAJHS.

3. The Plan does not adequately proyide for " notification by the licensee of state and local response organizations and for noti-fication of emergency response personnel by all organizations" (10 C.F.R. 50. 47(b) ( 5 ) ) , min the following respects :

a. Under the Plan, key personnel are to be contacted in most cases by telephone, which'will be unreliable in the event of an accident. Back-up provisions for radio contact are also insufficient because they cannot assure tha.t the personnel can be reached. In each instance, there must be a: dedicated telephone line from the initial contact point to locations where the relevant key personnel

'will definitely be available.

Basis: In Hampton, the only communciations between the police dispatcher and key personnel is by undedicated telephone line. Non-d dedicated lines simply are not reliable in emergency si,tuations since past experience, as at Three Mile Island, indicate that these lines jam up during an emergency.

Also, much of the communications system on which the Plan is based does not exist and there is no plan to put those communications SHalNES. M ADRIGAN & McE ACHERN . PROFES$aONA'. ASSOCuTION 25 MAPLEWOOO A VENi>E - P O box 36C - PORTSMOUTM. NH 03801

S in place. For example, the Plan provides for and EOC network which does not yet exist. There is no public address / audible siren system.

There is no tone-activated radio /walkietalkie system for all key personnel. There is no mobile public address system. There is no intergrated command / control net to direct the Plan or equipment for radio communication between EOC and the various Town departments, Seacoast Nursing Home, the five local schools, the State Police and Rockingham Dispatch, and the network in general.

4,. The Plan does not provide adequate procedures for early noti-fication and clear instruction to the general public within the

" plume exposure pathway" EPZ (10 C.F.R. 50.47)(b)(5)), in that the primary means of notify,ing the public, the public alert system (P.A.S.)

which is to consist of sirens," mobile address systems, and activated radios, has not yet been designed and thus cannot possioly support a finding of compliance. It is. impossible to determine the range or effectivness of the equipment-that will be employed to determine whether the sirens will- be installed in an appropriate locations or

~

' provide adequate coverage under all conditions, including adverse w weather.

The public alert (audible) siren / system is at the heart of the communication system. The lack of such an acceptab,le alert system means that there might not only be an inefficient evacuation, but also an unwanted evacuation. Likewise, there also exists no acceptable portable system capable of a range of 300 to 500 feet.

b. There has been no attempt by any of the emergency response

'5HalNES, MADRIGAN & McEACHERN Ps*0FESSONAL ASSOCtATON 25 MAPLEWOOD AVENUE - P O BOX 360 PC*T5wouTH. NM C1301

organizations to determine or estabJ ish th . time required for notifying and providing prompt instructions to the public within the plume ex-posure pathway EPZ as required by NUREG-0654 II.E.6.

c. The Plan does not provide for bilingual messages for the large number of French-speaking individuals who are often in the area in large numbers.

Basis: The seasonal population of the Town of Hampton varies dramatically, with 2 large influx of tourists, both on a seasonal r

and transient basis during the summer months. A -large proportion of these tourists come from French-speaking Quebec, Canada and past experience has shown th'at a serious language barrier exists to the

~

extent that many of these tourists can neither read a menu nor order a meal in English, muc$-less respond to an emergency notification.

The language barrier not only presents a problem for notification of French-speaking people, but their lack of notification and understand-ing of any emergency which might arise would, in turn, interfere with theemergencyresponseinthehublicatlarge, rendering an orderly and

~

safe evacuation much more , difficult.

At minimum, all relevant communication and information material s should be in both English and French. Emergency response personnel who may have to deal with non-English speaking people must be fluent in French, and all such personnel must be trained in hahdling the behavioral dif f-iculties that may arise as a result of the language barrier. In short, while NUREG-0654 requires prompt instructions to the public, the failure to take into account the existence of large French-speaking population in the Town of Hampton, especially during the summer months, is a major deficiency in the Plan.

5. The Plan does not provide for an adequate range of protective SH AFNES. M AORIG AN & MCEACHERN . PaOFE$$CNAL ASSOCIATON h3 MAPLEWOOo AvtNut . P O BOA 360 PORTSMOUTM. NH C3801

\ . l actions (10 C.F.R. Section 50.47(b)(10) because it contains no pro-visions for relocation or other protection of persons with special needs, witho'ut private transportation, who are confined to institu-tions or elsewhere for health or other reasons, and for school child-ren. The resources now available to the Town for these purposes are inadequate to provide a reasonable assurance that the public will be protected it in the event of an accident. .

I Basis: The Plan wholly lacks provisions for. relocation or.other protection of those with special needs. The Plan simply states that internal procedures will eventually be developed to deal with this ,

~

problem and that the transportation deficiencies will be taken care of. ~'.

Providing a telephone number for those without private trans-portation in~need of relocation assistance is inadequate not only be-cause of the vulnerability of telephone systems in the event of such emergency but also because thEUe is no assurance that the essistance

~ '

will be available even if the call can be completed.

There a're not enough school buses to allow evacuation within a reasonable time as the buses are provided by a private company in shif ts, and there is no provision for the use of the buses or the number of shifts that will be needed in the event of an evacuation.

The lack of special transportation arrangements is particularly important because -of the large number of elderly persons in Hampton, particularly in the Seacoast Nursing Home and the elderly housing development, and the large number of one-car families where one spouse and children are at home with transportation during the day.

~ '

-sw mcs 4on.ca~ . uct.c-r =~ . Ortsso~.t .ssm.vo~ i 2*s M APLE*OCO .vtNUE P O BOm 360 PORTSMOUTH ~*4 C ipot

t

6. The Plan does not contain adequate guidelines for the choice between protective actions or information on which the choice of protective actions can be based in the event of an emergency. 10 C.F.R. .Section.50.47(b)(10).

Basis: The Plan contains no information concerning the ef-fectiveness of various proteccive actions for difficult accident situations. In particular, the Plan provides no basis for judging the f There is no~in-effectiveness of sheltering as a protective action.

formation concerning the ability of the various types of structures to provide shelter against radiation exposure, the conditions under which some structures would be acceptable and others would not, or the conditions undei which sheltering must be abandoned in favor of evacuation. There is also no _ assessment of the Town's ability to

- shelter those without easy access to any form of shelter, particuarly transients in recreation areas .: and on the beaches.

7. The P1,an f ails _ to meet the requirements of 10 C.F.R. Section 50.47(b)(10). in that:

a. It contains no maps of evacuation routes, predictions of the time required for evacuation, or location of relocation centers or shelter areas. .

b. It does not make' adequate provision for notifying and providing follow-up information to those segments of the popu-lation that are in recreation areas or otherwise without easy access to the television or radio.

I c. There has been no attempt to estimate or project traffic capacities for different routes for evacuation under various conditions and in various seasons.

_9_

"5M AINES, M ADRIGAN & MCEACHERN - PROFESSCNAL ASSOCIATON 25 MAAEWOOO AVENUE P O. Box 360 PORT 6MOUTM. NM 03801

~ - ,

___-_m_.. - _ _ _ _ _ _ _ _ _

l

d. The Plan fails to designate any traffic or access points for traffic control. Thus, it is not possible to determine either whether the traffic. control plan is sufficient, and it is not possible to determine the numoer of personnel needed to implement the plan.

e. The Plan does not adequately provide for registering or monitoring evacuees..

Basis: NUREG-0654 II. J. 10. c. requires that the locality have the means for notifying all segments of t e transient resident popu-lation. The Town of Hampton does not have that capability and the Plan does not specify how this is to be done. 10.d req'uires the locality to have the-means for protecting those persons whose mobility may be impaired due to_,such factors as to institutional or other con-finement and, again, the Plan does not specify how this is to be done and the Town does not have such a transportation system. 10.k. re-

~

quires identification of and means for dealing with potential impedi-ments to the use the evacuation routes and contingency measures. The Plan, again, do,es not address this issue in the context of the Town's

~

situation, especially during the summer when access roads are fre-quently blocked due to the influx of tourists to the Town and its beaches. A State coordinated route plan is required to avoid inevitable conflict between the various authorities in an emergency evacuation. ,

The Plan looks at Hampton in a vacuum and deals with it as a closed system. The highway capacities are shown in both directions leading a conclusion that an evacuation of Hampton could be possible within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 20 minutes on a summer weekend. The Town believes that this conclusion is based on false assumptions and is highly unrealistic.

~

3,J ~ts$.on.c ~ . oc racsc=~ - P.Oross,0~.t ssOc..T,o~

2S M.PLEWCOD .VENUC P O box MO PORT 5MouTM Nw 0380 t

8. The Plan does not adequately provide for requesting and ef-fectively using assistance resources, including private resources, as well as resources of other governmental. entities. 10 C.F.C. S50.47(b)(3i.

Basis: Although the Plan provides thtt the Town may seek outside assistance for various purposes, including transportation and material deficiencies, there" has been no assessment of the scope and extent of aid that may be needed, nor are there any explicit written agreements to confirm the arrangement and the availability of resources. Although the Town will rely on the New Hampshrie Civil Defense Agency to fulfill many of these needs, there are no specific agreements to that effect,

~

and there has been no delineation of how the agency will fulfill this role. According to th'e Voorhtes Report, the local officials do not view reliance upon mutual aide agreements with surrounding localities to be of any use because all localities will be faced with the same diffi-culties and will be unable to ' provide the requested assistance.

9. The local Plan does bbt fulfill the requirements of 10 C.F.R.

j S50.47(b)(7) in' that it do,es not identify "the principal points of con-tact with the news media for dissemination of information during an emergency," including the physical location or locations for such con-tact.

10. The Plan fails to take into account behavioral

• issues that will affect the ability of the public to respond in an orderly and efficient fashion:

SM AINES. M ADRK3 AN & MCEACHERN - PRC#ESSONAL AssociatsON e

• 25 MAPLEWOOD AVENut P O nom 360 PORTSMOUTH, Net 03801

P Basis: a. There are many different activities in the recreational areas of the Town of Hampton, including beach activites, shopping, and the myriad of amusement attractions existing both in the Town and along Hampton Bech. Families often split up to pursue their separate interests, agreeing to meet later. However, it is not likely the parents will depart- without gathering their families together. Likewise,,

children who attend schools throughout the area, oft,en will be sent to relocation centers different from those of their parents. Parents can be rea,sonably expected to attempt to pick up their children from the schools, or to return t.o the EPZ from the relocation center when their children do not show tp, although this would disrupt an orderly evacuation.

The Plan thus fails to,take into account the psychology of distraught parents in a highly distressful' situation.

b. Many of the evacuation routes ate narrow and would be blocked by an accident or a stalled car. Route 51, which is the main access road from Route 95 to HamptonrBeach, is a two lane road where the shoulder is commonly used by traffic during busy periods. Since there

~is no place -for a car to go if there is an accident or a breakdcwn, the road could very easily become clogged. Route 51 also suffers from a serious bottleneck at the Tide Mill Bridge. Police traffic control is necessary at the intersection of Route 51 an.d 1A, along the shoulder of Route 51, and at the intersection of 51 and Landing Road.

Similar problems exist with respect to the two other routes from Hampton Beach. Again, public behavior must be taken into account. In order to assure a safe, prompt, and orderly evacuation in case one is ultimately called for, the Plap must provide for notification of all

- "$HAINES, MADRIGAN & McEACHERN PROFESSONAL ASSOCiATON 2-. MAPLfwOOD AVENUE P O BOK 360 PORTsuouTH. NM 03801

~ - .

e.- , s . _ . .

C. ,

emergency response personnel and implementation of traffic control measures coi.ncident with a public announcement of an event at the reactor that falls into any of the emergency action levels. Experience at Three Mile Island demonstrated that public evacuation would begin soon after an announcement of an unusual condition at the reactor, even when the utility and the Commission are attempting to assure the public that the reactor posess no danger. A premature evacuation could occur before traffic control measur(s where implaced, clogg ing the evacuation routes and making it difficult for traffic control personnel to reach the -control point and implement the controls,

~

thereby delaying or preventing the implementation of the controls and significantly hindering _ the evacuation.

An orderly evacuation depends upon the public being willing to respond to traffic controls and other directions by public officials.

Under ordinary circumstances, drivers often disobey such controls, with the result being " gridlock" in downtown rush-hour situations and near collapse of automobile ' transportation networks.

These driving habits arise from the determination of the driver to assure his or her own advantage regardless of the damage to'othere. The presence of only a few such drivers would hamper seriously an evacuation by disrupting traffic controls and increasing the likelihood of accidents.

11. The P,lan does not contain adequate arrangements for medical services for contaminated injured individuals. (10 C.F.R. S50.47(b)(12)l as the Town must rely on hospitals that are either within the plume exposure emergency planning zone or in Boston.

Basis: The Plan provides- for care for ill or injured persons who are suspected or known to be contaminated at the Portsmouth Hospital,

.- SMAINES. M ADRIG AN & McE ACHERN . PROFESS 8Oh AL ASSOCIA TION 25 MAPLEwOOD AVENUE P O.207 360-PORTSMOUTH. NH C3001

the Exeter Hospital, and Brigham and Womans Hospital. The first two hospitals are located within the plume exposure emergency planning zone and can reasonably be expected to close down and transfer their own patients and staff somewhere else during an emergency. The Brigham and Womans Hospital is located over 50 miles away in Boston and trans-portation to this remote location with attendant tra.fic congestion and delay would seriously jeopardize the effectiveness of the Plan of ,

medical services to be provided. [

E,xcept for emergency medical technicians, medically qualified tourists, and local pro.fessionals, Hampton has no organized medical .

facility. Hampton is host to a nursing home and an elderly care residence. These occupants require unusual care and special transportat:.on.

~~

A simple statement in the Plan that " provision of busses will be coordinated by the state" does not solve the problem of time, distance, and the quantity of service as. is necessary in order to successfully execute the Plan evacuation.  :

12. The Plan fails to'take into account the lack, on a local

' level of personnel, finances, and a communication system to carry out the locality's responsibility under the Plan as set forth in NUREG 0654.

Basis: a. NUREG 0654 II. A.1.e. provides that th.e locality shall provide for 24-hour per day emergency response, including 24-hour per day manning of communication lines. However, the personnel to whom responsibilities have been delegated under the Plan would be simply overwhelmed by the enormity of the tasks with which they are confronted. Even if the Town yere capable of handling the emergency on a short-term basis, it lacks the capability for continuous 24-hour operations for a protracted period.

_ SHAINES. M AO'HGAN e McEACHERN . NESSCNAL ASSOCIATCH

, 25 MAPLE *000 AVENUE P O BOA 350 PORTSwouTM NH 0300t

b. The Town also lacks suf ficient personnel to comply with the requirements of II.C.2.a. which provides for the locality to dispatch representatives to the licensee's near-site emergency operations facility. To the extent that this would decrease the number of per-sonnel available to actually deal with the emergency, it would further reduce the Town's capacity for handling that emergency.

c. The Town also lacks sufficient personnel, transportation and organization to comply with II.I.8. whichfrequires methods, equipment, and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiogical hazards through liquid or gasous release pathways, including activation, notification means, field team compositiong transportation, communication, monitoring equipment and estimated deploym'nt e times.

13. The Plan f ails to provide for satisf actory meanc for veri-fication of initial and follow-up messages as required by NUREG 0654 r

II.E.

Basis: II.E.I. re' quires a means for verification of messages

'trasmitted through the communications system for the purposes of the local response organizations, including emergency response personnel, and the general public. As has already been noted, due to the lack of dedicated telephone lines, the telephone cannot be cons.idered a reliable instrument for conveying communications in an emergency situation. The use of radio as a primary or backup means of communi-cation is fraught with difficulties due to the possibility of jamming, whether intentional or unintentional due to the highly intensive use, the possibility of conflicting. messages from divergent authorized personnel or unauthorized persons, and the dif ficulty of reliable

. SM AINES. M ADRIG AN & McE ACHERN . PROFES$80NAL. ASSOCIATION

. 25 MAPLEWOOD AVENUE P O Box 3Co PORT 5pOUTH. hM 03801

i ,

transmission of information up and down the chain of command. In short, the Town is not satisfied that a workable plan for reliable communications has been established for communications within the ranks of response personnel and from authorities to the public means of dis-semination such as commercial radio, the press, and television.

Respectfully submitted,

$[$thANNbkOhs, -

r SHAINES, MADRIGAN & McEACHERN Professional Association By: [

Charles Cross v[( N 25 Maplewood Avenue Portsmouth, NH 03801

{)l

-~

Tel. (603) 436-3110

~ Interested Mun* pality Representative for the Tow Hampton

. p y- ~~

[nB. zef DATED: September 19, 1981 e

e W

Gr m +

SH AINE$. M ADRIG A N & McE ACHERN - NESSONAL A550CPATaON

, , 25 MAPLEWWOOD AvtNut P O Box 360 PORTEMOurH. NH 03P01