ML20080E751

Contentions Re Emergency Planning for State of Nh & Town of Rye,Nh.Assurance That Adequate Measures to Protect Persons in Rye,Nh in Event of Radiological Emergency Does Not Exist.Certificate of Svc Encl

ML20080E751
Person / Time
Site:	Seabrook
Issue date:	09/08/1983
From:	Chichester G, Nadeau J, Matt Young RYE, NH
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8309140066
Download: ML20080E751 (12)

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UNITED STATES OF AMERICA 00CKETED USN3C

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NUCLEAR REGULATORY COMMISSION - .,. -

13 SEP 13 #1:40 ATOMIC SAFETY AND LICENSING BOARD CTelCE CF SECRETW C OnLimG A SEPV:f.i.

C?:.:.Cn Before Administrative Judges:

Helen F. Hoyt, Chairperson Emrreth A. Luebke

- Jerry Harbour

) Docket Nos. 50-443-01, In the Matter of

) 50-444-OL PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. -

)

-(Seabrook Station, UnTts 1 and 2) ) September 8,~ 1983

)

CONTENTIONS OF TOWN OF RYE RELATIVE TO EMERGENCY PLANNING FOR NEW HAMPSHIRE AND TOWN OF RYE CONTENTION I: The Applicant's Radiological Emergency Response Plan for New Hampshire and the Town of Rye does not satisfy the requirements of 10 C.F.R. 650.47(b)(1), (8), (9) or (12) because it is not authorized by Rye, and; there has been no assessment of the Town's or the State's emergency response needs and resources or satisfaction'of its resource requirements in the following areas: emergency per-sonnel, emergency notification, notification of key response personnel, sheltering,

! exposure cotrol, medical support, education, reception facilities, decontamination, training, radiological monitoring, public information, special needs of children and infirm, special needs of transients, exercise and drills, recovery and reentry, overall

, emergency transportation, transportation for special facilities, schools, and people with special needs or without private transportation, emergency medical transporta-ng3

. tion, medical treatment for contaminated injured individuals, radiological monitoring and assessment equipment, dosemeters and respiratory equipment for emergency work-o .

lg- ers, and manpower for traffic raanagement and access control, emergency transporta-g wo tion and security operations, emergency maintenance of evacuation routes and response IE Ma.o to abandoned. vehicles, traffic accidents, and other obstructions to evacuating traffic flow, and staffing of emergency response facilhies. In the absence of an assessment

.and satisfaction'of'the requirements in these areas, there can be no " reasonable assurance that adequate protective measures can and will be taken" to protect persons present in the Town of Rye in the event of a radiological emergency at Seabrook-Station, as required by.10 C.F.R. 550.47(a)(1).

BASIS FO'R RYE'S CONTENTION 1 THAT:

There'is no reasonable assurance that adequate protective action for the Town of Rye and neighboring populations can and will be taken in the event of certain forseeable kinds ~ of radiological emergencies which can and may occur at the Applicants pro-jected nuclear reactors if they are operated.

Applicants calculations and estimates do not account for: preparation and mobilization

and notification time, power failures affecting criticals systems such as phone and lights, bounds of error in calculation models, dynamic responses of public officials n .d evacuees, adverse weather, directional bias of evacuees, shadow evacuation, role conflicts of emergency personnel, actual evacuation routes, local options and agree-ments, transport resources, road conditions, equipment and facilities, current accurate population counts, back ups and in-depth reosurces, systems and personnel.

Reasonable assurance of adequate protection for Rye would require. in some cases of reactor excursions, events, runaways, scrams, melts, partial melts and other such loss of control, a more or less instantaneous awareness and mobilization of great numbers of willing and able public servants and/or volunteers, and; vast physical resources,

- equipage, transport, roadways, repair, and. safe refuge, and; realistic planning and di-rection. These basic resources,-and such readiness, willingness and ability, do not exist in.the Town of Rye, and as far as is known in Rye, does not exist in the Towns

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- around' Rye. ~ Rye has t arely begun the process of evaluating the. radiological threats to health and safety which exist in the Town's surrounding environment, and those which may exist in the future, such as at Seabrook Station.

' Af ter careful consideration in an ongoing process begun early this year, the Town is finding-(fr'om reports of the Rye Nuclear Intervention Advisory Committee) that: Ne

. are prepared in only the crudest way for only the least kinds of accidents, and; we see no agency or resources which we could call (rely) on in the event of a serious acci-dent (radiological) affecting Rye", and; "The Committee agrees that any meaningful

, emergency response' plan (radiological or other) will he a product of Rye's own planning and resources; that in these matters, if g don't do it, it won't get done", and; that the PSNH/Lomasney- plan fails to assure adequate or timely staff, supplies, assistance, com-munications, coordination, notification, equipment or medical resources for evei, the relatively minor radiological emergencies which it projects (1 to 25 rems whole body

- dose).'

l- The purpose of the Lomasney/PSNH plan, published in the name of Rye, is twice l -

L described and is revealing:

a) in the preface, page -v- "This plan describes the preparation and emergency L

f response required by the Town of Rye to react to a potential radiological emergency at Seabrook Station Nuclear Power Plant" b) in section I-A page I-l PURPOSE "This Radiological Emergency Response Plan L

is designed to provide the Town of Rye with organizational procedures and a descrip-tion of protective action 'to be taken in the event of a radiological incident at the Seabrook Station Nuclear Power Plant"

'It is significant that public health and safety are never mentioned in the statements of purpose, and are mentioned but once in~ the entire 150 page document. The plan does not even begin to' address the needs for medical care appropriate to radiological sickness in a substantial number of people. Rye's population is 4,300. There are no-l appropriate medical services in Rye and only- one physician practicing in Rye.

-The plan made in'the name of Rye is apparently for the purpose of expediting a' license

, but is utterly useless as a tool for meaningful radiological emergency response prepared-ness in that; all other defects aside, it fails to' recognize or address the nature of a radi-ological emergency. Most creatures, humans for sure, are sickened by radiation, even -

small doses, therefore; unless a population successfully evades radiation, it must have medical care. And of a special kind, not ordinarily handy. 10 C.F.R. 50.47(b)(12) mandates it. The. Applicants are oblivious to it. Rye is only interested in. action that protects the public's health and safety. -We' know; that keeping radiation out of our lines is the best protection, that successfully. fleeing from it is next best, and that failing that, swif t sure medical care is the only other protection possible. Rye must and will ~ '

plan all its radiological emergency responses based-on dose-effect relationships of radia-tion and human health, and assured medical care for every citizen exposed, and; rejects out of hand all radiological' emergency planning that doesn't assure such protection. Rye believes the law supports us in our own proper choices in these matters. The Ato'mic

. Energy Act directs-the Nuclear Regulatory Commission to base its decisions only on the protection of the public's health and safety. Under current regulations, the' Federal ,

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Emergency Management Agency (FEMA) must find that a utility's plan has sufficient' local support to work. 10 C.F.R. 2.715(c) allows interested municipalities " . . .

reasonable opportunity to participate and to introduce evidence, interrogate witnesses,

- and advise the_ Commission." New Hampshire's RSA 107-b requires'"The civil defense

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s agency:shall' act in cooperation with affected local units of government". The towns,

'4 Prp in' exercising rights and prerogatives in areas of basic public. protection such as health

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and safety,' could not~be any closer to the bedrock foundations of law. LRye and other .

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'seacoastL New Hampshire towns have seen that the NRC has recently filed bills in the

' United States Congress' H.R.' 2512' and S. 893'which if passed into law, would strip " local

. vetoes" as-Senator Simpson of Wyoming, the bill's point man describes it. New Hamp-i shire's Senator Gordon Humphrey says "I am concerned about the ramifications of these i . .

. . :' proposed, revisions,~ for I have a' fundamental problem with cases of federal preemption .

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of local'res'ponsibilities and prerogatives." See attached discussions. The intention of

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the;^ppl}.V,t can and the record of the Commission's actions and findings is all toward ~

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licensing, but'when involved local governments, after all due deliberations, fir.a l., and 'adviss the Commission of, basic' health and public security presumptions in the li-r , .

e cense application, the Commission has the duty and respor6ibility to deny a. license. --

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9 CONTENTION 2:/ For purposes of planning' radiological emergency responses to protect

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' the-public, the Applicant has insufficient and/or inaccurate and/or undeveloped pio.

tective: action guidelines, and; .has insufficient and/or inaccurate and/or undeveloped

^ ; evacuation t'ime estimates. ;The Applicant treats protective action guidelines and evacu-

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-atlon time ~ estimates as though they are worlds ' apart considerations and in an unlawful n ,

y 7 , l.and unaccepta$le, cursory manner.f No radiological emergency preparation can reasonab-f : #.s _.

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. % . hAalth effects to human populations, which are absolutely and directly related to kinds

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QMof exposure and duration of exposure. .

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. BASIS FOR RYE'S CONTENTION-2:THAT: ~ t

' Applicants planning'is not accurately or directly tied to evacuation times, radiation e'x-y..

posure, and health effects combined, and therefore; can~not reasonably assure the public's m

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' 'e u k7 -5 Applicabts witness: Mcdonald of Yankee- Atomic Company in.testimonf before A.S.L.B.

.in Dover, New--Harnpshire in August 1983 stated: for purposes of planning radiological p

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• "L. . . estimates of evacuation times must be tied to radiological con-3

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(Rye ~firids such apparent wisdom coming-from the Applicant an unusual, but important admission.11t is important because it goes to the heart of the issue of reasonable

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assurance-of protective. action.-' There can be no protective action coming out of the

'[ Applicant's' emergency; response ' plans because .the plans are not based on accurate es-f7 > times'of evacuation: times,- thus duration of-exposures, and; are not based on accurate 3

_ I, I af *taken from handwritten notes rather than the record of hea ings, which Rye does not n

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-.e Lor. realistic e'stimates of .the kinds.of radiation that might occur, th'us the consequences' W .y

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to the public health.

.The' Applicant has ~ factored misinformation into evacuation . time estimates. In parti-f i

' cular: + assumptions that all routing and movements are controlled by local law en- .

. ;forcement' personnel, road clearing personnel,-and equipment of public and private agen--

- r ' : cies, Land; that weather is favorable, .that all evacuees will comply with orderly direc- -

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tions and planned routes,~ that no vehicles will break down or run out of fuel, that no

~ one would attempt entering into the evacuation area, that livestock - would not be

-herded into the evacuation routes, that panic or contrary behavior would not ensue among Levacuees or public officials, that people on the perimeter and outside the evacuation ,

zone would not clog the chosen escape ~ routes, that brigands and looters will not add may-

" hem to confusici, that sufficient feeder roads, main trunk roads,~ traffic control, com--

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, lmunications," coordination and support facilities _ can be identified, can be kept ready,'can :

[ ~ be mobilized.n As yet'all-is speculative and wanting, yet all has been used in the time

' . estimate m'odels, sin short,.the rnodels, scenarios, generic matrixes, and'other formulae .

i used to produce' Applicant's estimates of evacuation times and therefore the Aj)plicant's estimates of evacuation times are critically faulty in that they do not account for, a e

. . host.of needs and problems which can reasonably be known and seen as properly in-

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f cluded in any. basis for. estimating such.

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Analysis of 1983 Nuc; ear Powerplant Lic;nsing " Reform" Legisiction

'B2 Reagan Administration (tnrcan tht Dip;rtment of En:rgy) ena tha Nuclear R;gulatory Commission h:ve both filec ler.s'. ation to "strcamline" the process for lictnsing nuclear powerplants. The bills are nun:ered H.R. 2511 and S. 894 ( Administration / DOE bill) rnd H.R. 2512 and S. 893 (NRC bill).

As you might expect, the nuclear industry -- many large utilities, reactor makers such as Westinghouse and General Electric, and major architect / engineering firms like Bechtel and Stone i Webster -- are putting heavy pressure on Congress to move these bills, hay know that nuclear power is in trouble, because both the marketplace and the public at largo have rejected it in favor of safer, more reliable energy technologies.

No reactor has been ordered since 197P, and all 13 reactors ordered between 1974-8 have been cancelled or indefinitely postponed. At the same time, at least 26 coal-fired powerplants were ordered between 1979-1982. And recent public opinion polls, including one tak:n for the' nuclear industry, consistently show that 55'A of the American people oppose nuclear power while only 335 support it.

-- -However,-this-leg-islat-ion-would ,--if-ariythingy-make-the-industry's problems-worse r by further reducing public confidence in the NRC's ability to effectively regulate this tschnology. As former NRC Commissioner Pet'er Bradford told a Senate subcomittee, "the NRC h: ring process ranks very low among the issues that have brought nuclear power to its prestnt situation. NRC hearings did not cause Bree Mile Island. NRC hearings did not bring about the cancellation and default at the UPPSS units. NRC hearings had nothing to do with the' quality assurance breakdowns at Diablo Canyon and Zimmer. NRC hearings are not causing the Midland containment to sink. NRC hearings are not even at the bottom of the

. cost overruns at Shoreham and Seabrook."

Both the DOE and NRC bills are structured around the same set of regulatory concepts:

restricted backfitting (based on quantitative cost / benefit analysis), "one-step" licensing, hybrid hearings, early site review, and pre-approval of plant designs.

• Both bills introduce, for the first time, the concept of cost / benefit balancing into the Atomic Energy Act. he Act now directs the NRC to base its decisions only on the protcetion of the public's health and safety. Under a cost / benefit standard, any improvement in public protection would easily be $' outweighed" by the cost of , needed rep irs, since the latter can be precisely calculated but the formc.- is necessarily imprecise and speculative.

" Tne DOE bill would make it much more difficult for the NRC to order safety-related upgrcdings - ("backfits") in the equipnent or operations of any reactor that has already received initial NRC approval . NRC now has, and has needed, a great deal of flexibility to respond to the constantly-emerging safety problems that neither the agency nor the industry wsra prepared for. Among other things, the DOE bill:

-- requires the NRC Commissioners to personally approve all backfit orders, a f.;nc:.i;c now largelv handled by staff;

-- restricts the information NRC .can require licensees to submit, thus making it hard;r to investigate emerging safety problems;

-- allows NRC to adopt a lower standard of safety for older plants by directing it to consider the " remaining life of the facility" before ordering repairs;

-- implicitly requires all backfits to be justified by complex quantitative risk asnasments that can easily be manipulated to downgrade the need for expensive repairs.

(De DOE bill proposes these drastic changes, even though DOE," questioned in a House hearing, could not come up with a single example of an unnecessary backfit!)

The NRC bill 'does not go as far, but it does require a higher standard of proof b3 fore backfits can be ordered.

• Bath bills would let the NRC issue a "one-step" license, covering operation as well as construction, but neither bill requires the NRC to resolve all outstanding safety

Astions before constructio:. :egins. 22

- submit a complcto plEnt d:sigr refo e th2 license is issurd!L05 bill coes not even require tha NRC Commissioner Gilinsky has basia cf hia cours2 outline."cbmpared th] "on:-st p" lic:nse to "r.anding cn incoming

• The DOE bill would let a utility ' start site preparation work, including

" safety-related construction activities", before the NRC has issued any license -- in fa before it has approved either the' reactor design or the site. ,

comitment of the utility's resources will inevitably bias the licensingSuch an irrevocable process and add to

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the pressure on NRC to acquiesce in whatever the utility has already done.

• 'lhe DOE bill would repeal the requirement for an adjudicatory hearing, now held whether the plantupon was request of any constructed citizen-intervenor before a plant begins operation, o properly.

' rs t rtrnent s } ir axocsir.g In recent years.

aj:r .i:t:Pos tnd :h:Cy w.r.tr xtir,:i these hearings have been pra Lices at plants lige Zimmer, Midland, South Texas, and Diablo Canyon.

Under the DOE bill, all pre-operational reviews would be left to the NRC staff, which has a very poor record mistakes on its own; there would

-' the utility's peality assurance re:: rds. be no formal outside review or even any public disc Bath bills weaken the public's right which is often the only way to uncover safety problems. to cross-examine NRC and utility experts, Under the bills' provisions for

" hybrid" hearings, the NRC licensing, board will have to decide in each case which will be subject to cross-exanination -- a decision that, unlike more technical sa issues, can often rroceedings. be reversed in court, thus lengthening rather than shortening (he current e Mder the DOE bill, procedures allow each party to cross-examine all witnesses.)

issues are subject to tne !EC Commissioners _themselves would decide, case-by-case, which cross-examination!

These new ;;recedures can be applied in cases dready underway, ootentially changing the ground-rules in the middle of the hearin .

Both bills, but especially the NE till, evidence in ways that make it more difficult fer citizens to pursue serious safety sites effective for long periods of time. Bath bills make the NRC's approval of st 10 years, with a 10-year renewal granted Tne NRC bill makes both approvals effective for almost automatically, he burden of proof is snifted to the public to show that the design does not meet current safety standar rather than standards. remaining with the reactor manufacturer to show that it still meets the for design approvals and site permits. DOE's bill goes even further, allowing an in in'.' obsolet:e designs and questionable sites for decades.The effect of such provisions is to " gra

• Ecth bills defer payment of the application fee for design approvals and site termits until the design or site is actually used, or until the end of the 10 year appr

eriod. oval (The DOE bill waives the fee entirely if the design is never used.)- This anounts General Electric -- hardly the most needy recipients of scarce fed

> wer *Authority, Both bills would delegate to the states, or to federal agencies like the Bonnevi]le and the availability of alternativ ?the responsibility for reviewing the need for the power to be gen i npact analysis mandated by the National Envircnmental Pelicy(NEPA) Actenergy sources

-- without -- ess setting any minimm standards for public participation, and without mandating full consideration of conservation and improved energy efficiency as alternatives to new powerplant construction.

• While the scope of the NRC bill is generally restricted to light-water reactors the DOE bill would also apply to breeder reactors and reprocessing plants -- two new and ,

potentially even more dangerous types of nuclear facilities. The bill's procedural shortcuts and backfitting restrictions are entirely inappropriate when not one breeder reactor or reprocessing plant is operating commercially in this country.

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Respectfully submitted, BOARD OF SELECTMEN l - Gr$/mL J.padrau, Chneman Y/A!%Ybf f/sY/w/r '

13uy ichester, Chairman. /~

-Rye uclear Intervention Maynardf./ Young ' / '

Advisory Committee hmm . w g A J. . . .

Frances 1. Holway A CERTIFICATE OF SERVICE I hereby certify that copies of the " Rye Contentions 1 and 2" in the above-captioned

-proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory

' Commission's internal mail system, this 9th day of September,1983.

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.. Calvin A. Canney, City Manager-City Hall Edward F. Meany 126 Daniel Street .

. Town of Rye, New Hampshire Portsmouth, NH -03801 l 155 Washington Road

-Rye, NH' 03870 Roberta C. Pevear-Town of Hampton Falls, New Hampshire Mr. Robert.J. Harrison Drinkwater Road President and Chief Executive Officer .Hampton Falls, NH 03844-Public Service Co. of New Hampshire-P.O. Box 330 Manchester, NH :03105 William S. Jordan, III, Esq.

. Robert A. Backus, Esq.- Ellyn R. Weiss Esq.-

116 Lowell Street Hannon & Weiss P.O. Box 516. 1725 I Street, N.W.

Manchester..NH 03105 Suite 506 Washington, D.C. 20006

-Brian P. Cassidy Regional Counsel Phillip Ahrens, Esq.

FEMA, Region I .

Assistant Attorney General John W. McConnack Post Office & State House Station #6 "

Courthouse Augusta ~, ME 04333 Boston, MA ~02109 Senator Gordon J. Humphrey ~ Donald L. Herzberger, MD U.S. Senate ~ Hitchcock Hospital Washington,.D.C. 20510 Hanover, NH 03755 (Attn: TomBurack)

Sen. Robert L. Preston Thomas G. Dignan, 'Jr. , Esq. State of New Hampshire Senate Ropes & Gray Concord,.NH 03301

i. 225 Franklin Street.

Boston, MA 02110 Atomic Safety and Licensing Board Panel

• Atomic Safety and Licensing U.S. Nuclear Regulatory Comission-

, . Appeal Panel

• Washington, D.C. -20555 l

U.S. Nuclear Regulatory Comission Washington, D.C. 20555 John B. Tanzer Town of Hampton, New Hampshire Jane Doughty 5 Morningside Drive Field Director Hampton, NH 03842 Seacoast Anti-Pollution League 5 Market Street Letty Hett Portsmouth, NH .03801 Town of Brentwood -

RFD Dalton Road Brentwood, NH 03833

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w Docketing and Service Section*-

- Office 'of the Secretary U.S. Nuclear Regulatory Comission Patrick J.'McKeon Washington, D.C. 20555- .Chaiman of Selectmen, Rye, New Hampshire David R. Lewis, Esq.

10 Central Road Law-Clerk to the Board Rye, NH 03870 Atomic Safety and Licensing Board

U.S. Nuclear Regulatory Comission Anne Verge, Chairperson Washington, D.C. 20555 _ Board of Selectmen Town Hall Dr.-Mauray Tye South'Hampton, NH 03842 209 Summer Street Haverhill, MA 01830 Mr. Maynard B. Pearson-Town of Amesbury, Mass.

Town of North Hampton 40 Monroe Street.

North Hampton, New Hampshire 03862 Amesbury, MA 01913

[ lR.' K. Gad III, Esq. Senator Gordan J. Humphrey-t Ropes &. Gray 1 Pillsbury St.-

225 Franklin Street- Concord,-NH~ 03301~

Boston, MA 02110- (Attn: . Herb -Boynton) i '

o L Helen Hoyt, Esq. , Chaiman*. Dr. Emeth A. Luebke* -

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board l- Panel Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission ~ .

~ Washington, D.C. 20555- Washington,-D.C. 20555 i

! -- - Dr. Jerry, Harbour

• Jo Ann Shotwell, Asst. Attorney i Administrative Judge Office of the Attorney General

, Atomic Safety.and Licensing Board Environmental Protection Division Panel _ .

One Ashburton-Place,- 19th Floor l U.S. Nuclear Regulatory Comission Boston, MA 02108 L Washington -D.C. 20555 L Nicholas J. Costello i Beverly Hollingworth 1st Essex District l 7=A Street Whitehall Road

-Hampton Beach, NH' 03842-Amesbury, MA 01913 Edward L. Cross, Jr. , Esq. Sandra Gavutis

~ ** George Dana Bisbee, Esq. Town of Kensington, New Hampshire l.

' . Environmental. Protection Division RFD 1 Office of the Attorney General East Kingston, NH 03827 State House Annex Concord, NH03301 ./

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