|
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M8771999-10-25025 October 1999 Requests That Industry Studies on long-term Spent Fuel Pool Cooling Be Provided to R Dudley at Listed Mail Stop ML20217M4331999-10-19019 October 1999 Submits Rept 17, Requal Tracking Rept from Operator Tracking Sys. Rept Was Used by NRC to Schedule Requalification Exams for Operators & Record Requal Pass Dates ML20217F5841999-10-13013 October 1999 Requests Revocation of License OP-11038-1 for GE Kingsley. Individual Has Been Reassigned to Position within Naesco ML20217F5811999-10-13013 October 1999 Forwards Insp Data & Naesco Evaluation of a EDG Exhaust Insp Conducted on 990407.Insp Ensured That Unacceptable Wall Thinning Will Not Occur During 40-year Design Lifetime of Sys ML20217C7321999-10-0808 October 1999 Forwards Copy of Seabrook Station Videotape Entitled, Completion of Seal Barrier Installation. Videotape Documents Process of Selecting,Designing & Installing Seal Deterrent Barrier to Preclude Entrapment of Seals ML20217B8621999-10-0505 October 1999 Forwards Rev 28,change 1 to EPIP Er 1.1, Classification & Emergencies, Per 10CFR50.54(q).Rev to Procedure Does Not Decrease Effectiveness of Seabrook Station Radiological Emergency Plan ML20217B7471999-10-0101 October 1999 Provides Notification of Change in PCT of More than 50 F,Per Requirements of 10CFR50.46(a)(3)(i),(ii).Tabulation of Large Break LOCA PCT Margin Utilization Applicable to Seabrook Station,Encl ML20212J8271999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Seabrook Station. Staff Conducted Reviews for All Operating NPPs to Integrate Performance Info & to Plan for Insp Activities at Facility Over Next Six Months.Plant Issues Matrix & Insp Plan Encl ML20216J2381999-09-30030 September 1999 Responds to Re Enforcement Discretion for Nuclear Plants During Y2K Transition.Nrc Expects All Licensees to Operate Nuclear Facilities Safety IAW NRC Regulations & Requirements ML20216J2421999-09-30030 September 1999 Responds to Card Received in Aug 1999,providing Comments on NRC Interim Enforcement Policy Re Enforcement Discretion for Nuclear Plants During Y2K Transition.Informs That Naesc Reported Seabrook as Y2K Ready Prior to 990701 ML20216J2471999-09-30030 September 1999 Responds to Which Provided Comments on NRC Interim Enforcement Policy Re Enforcement Discretion for Nuclear Plants During Y2K Transition.Informs That Naesc Reported Seabrook as Y2K Ready Prior to 990701 ML20212K7921999-09-30030 September 1999 Confirms 990922 Telcon with J D'Antonio & T Grew Re Arrangements Made for NRC to Inspect Licensed Operator Requalification Program at Seabrook Facility ML20212J0301999-09-24024 September 1999 Forwards Insp Rept 50-443/99-10 on 990726-30 & 0809-13.No Violations Noted.Insp Discussed ML20212G5071999-09-21021 September 1999 Submits Complaint to NRC Re NRC Failure to Cite Seabrook Station NPP Operators for Failing to Periodically Calibrate & Establish Adequate Measures to Insure That Relay Equipment Met All Required Calibration Settings Prior to Installation ML20212C1881999-09-20020 September 1999 Ack Receipt of Which Raised Concerns Re NRC Enforcement Actions at Plant & Issuance of NCVs ML20212D1401999-09-17017 September 1999 Forwards SE Accepting Request to Use Proposed Alternative to Certain Weld Repair Requirements in ASME Boiling & Pressure Vessel Code ML20212B9511999-09-17017 September 1999 Forwards NRC Form 396 for MG Sketchley,License SOP-10685, Along with Supporting Medical Exam Info.Nrc Form 396 Has Been Superceded by Revised Version Dtd 971222,which Was Previously Submitted to NRC on 990812.Encl Withheld ML20212C3621999-09-15015 September 1999 Forwards Rev 34 to Seabrook Station Radiological Emergency Plan & Rev 85 to Seabrook Station Emergency Response Manual, Per 10CFR50,App E & 10CFR50.4 ML20212B5021999-09-14014 September 1999 Forwards Licensee Responses to EPA Questions Re Plant Seal Deterrent Barrier.Util Completed Installation of Subject Barriers on All Three Station Offshore Intake Structures on 990818.Barriers Will Preclude Entrapment of Seals ML20211Q8521999-09-0808 September 1999 Informs That Rl Couture,License SOP-11027,terminated Employment at Naesco on 990907.Revocation of License Requested ML20211N8781999-09-0303 September 1999 Forwards Response to 990820 RFI Re NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20211J9291999-09-0303 September 1999 Forwards mark-ups & Retypes of Proposed Conforming License Changes Required in Connection with Transfers Being Sought in 990615 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests ML20211M3221999-09-0202 September 1999 Responds to NRC Re Violations Noted in Insp of License NPF-86 & Proposed Imposition of Civil Penalty. Corrective Actions:Conducted Prompt Review of Layoff Decision to Determine Relevant Facts DD-99-10, Informs That Time Provided by NRC Regulation within Which Commission May Act to Review Director'S Decision (DD-99-10) Expired.Commission Declined Review & Decision Became Final on 990830.With Certificate of Svc.Served on 9909021999-09-0202 September 1999 Informs That Time Provided by NRC Regulation within Which Commission May Act to Review Director'S Decision (DD-99-10) Expired.Commission Declined Review & Decision Became Final on 990830.With Certificate of Svc.Served on 990902 ML20211J8811999-09-0101 September 1999 Forwards Comments on Seabrook Station Review of Reactor Vessel Integrity Database (Rvid)(Version 2).Minor Discrepancies Were Noted.Proposed Changes Are Encl in Order to Correct Discrepancies ML20211J8411999-09-0101 September 1999 Forwards Updated NRC Form 396 for E Decosta,Nrc License OP-10655-1.Without Encl ML20211G9191999-08-27027 August 1999 Informs NRC That Name of New Company, Ref in Order Approving Application Re Corporate Merger Is Nstar Which Is Massachusetts Business Trust ML20211J0401999-08-26026 August 1999 Responds to 990819 Request,On Behalf of Gr Pageau & Williams Power Corp,For Addl Time in Which to Reply to Nov,Issued on 990803.Response Due to NRC by 991008 ML20211H0651999-08-25025 August 1999 Forwards Insp Rept 50-443/99-05 on 990621-0801.One Violation Re Failure to Include Multiple Components within Scope of ISI Test Program Was Identified & Being Treated as NCV, Consistent with App C of Enforcement Policy ML20211G7761999-08-24024 August 1999 Expresses Great Concern Re Lack of Enforcement Actions Against Seabrook Station Despite Citations NRC Has Issued for Violations of Seabrook Operating License ML20211J2171999-08-23023 August 1999 Expresses Disappointment with Lack of Enforcement Action Against Seabrook Station Despite Repeated Safety Violations ML20211J4971999-08-21021 August 1999 Submits Comments Re Violations Cited in Early Mar & 990509 Insps ML20211H8361999-08-19019 August 1999 Submits Concerns Re Violations at Seabrook Station ML20211F2681999-08-19019 August 1999 Discusses Former Chairman Jackson & 990602 Predecisional Enforcement Conference Re Findings of Ofc of Investigations Involving Allegations Raised by Contract Electrician.Determined That Allegations Not Supported ML20211J3241999-08-15015 August 1999 Expresses Disappointment in Apparent Failure of NRC to Cite Seabrook Station NPP for Recent Violations of Safety Regulations Uncovered During Recent Insps in Mar & May ML20211J1831999-08-15015 August 1999 Submits Concerns Over Serious Deficiencies at Seabrook Station That NRC Has Declined to Take Enforcement Actions Against ML20210T1601999-08-13013 August 1999 Informs That as Result of Staff Review of Licensee Responses to GL 92-01,rev,supp1 1, Reactor Vessel Structural Integrity, NRC Revised Info in Reactor Vessel Integrity Database & Is Releasing It as Rvid Version 2 ML20211J2071999-08-13013 August 1999 Expresses Concerns Re Violations Occurring Recently at Seabrook Nuclear Power Station.Requests Effort to See That Measures Taken to Stop Flagrant,Continuing Violations That Hold Danger to Workers & Community ML20210S9611999-08-13013 August 1999 Informs That NRC Received Encl Ltr from Pb Johnston Expressing Concern About Certain Impacts on Shareholders of New England Electric Sys with Respect to Nees Proposed Merger with Natl Grid Group ML20210S9511999-08-13013 August 1999 Responds to to Collins Expressing Concerns with Certain Terms of Proposed Merger Between New England Electric Sys & National Grid Group.Nrc Has No Authority to Interject Itself in Nees Merger with National Grid Group ML20210S2001999-08-12012 August 1999 Forwards NRC Forms 398 & 396 in Support of Applications for Renewal of Operator Licenses for Individuals Listed Below. Without Encls ML20210R8401999-08-11011 August 1999 Forwards Response to NRC Second RAI Re GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves ML20210S7331999-08-11011 August 1999 Submits Third Suppl to 980423 Application to Renew NPDES Permit NH0020338 for Seabrook Station.Suppl Provides Addl Info on Input Streams & Requests Increased Permit Limit for Chemical Used in Makeup Water Treatment Sys ML20210R9581999-08-11011 August 1999 Forwards ISI Exam Rept of Seabrook Station, for RFO 6, Period 3,for Insps Conducted Prior to & During Sixth Refueling Outage Concluded on 990510 ML20210Q7441999-08-11011 August 1999 Forwards Order Approving Indirect Transfer of Control of Canal Interest in Seabrook Station Unit 1 as Requested in Application & SER ML20210R7931999-08-10010 August 1999 Forwards Cycle 7 Startup Rept for Seabrook Station, IAW Requirements of TS 6.8.1.1 ML20210N9421999-08-0505 August 1999 Informs That North Atlantic Suggests Listed Revisions to 990730 Draft Revisions to Committee Rept & Order.Further Revs Consistent with What North Atlantic Proposed at 990608 Hearing ML20210N5721999-08-0303 August 1999 Discusses Investigations Rept 1-98-005 Conducted by OI at Naesco,Seabrook Station & Forwards NOV & Proposed Imposition of Civil Penalty - $55,000.Violation Re Failure to Promptly Correct Incorrectly Terminated Cables of Control Bldg Air ML20210P3361999-08-0303 August 1999 Discusses Investigation Rept 1-98-005 Conducted by Region I OI at Naesco,Seabrook Station & Forwards Nov.Violations Re Electrical Wiring in Control Panel for Control Bldg Air Conditioning Sys ML20210P3161999-08-0303 August 1999 Discusses Investigation Rept 1-98-005,conducted Between 980129 & 0527 at Seabrook Station & Forwards Nov.Violation Re Discrimination of Williams Power Corp,Contractor of Naesco,Against Electrician for Raising Safety Issues 1999-09-08
[Table view] Category:EXTERNAL CORRESPONDENCE
MONTHYEARML20217C7321999-10-0808 October 1999 Forwards Copy of Seabrook Station Videotape Entitled, Completion of Seal Barrier Installation. Videotape Documents Process of Selecting,Designing & Installing Seal Deterrent Barrier to Preclude Entrapment of Seals ML20212B5021999-09-14014 September 1999 Forwards Licensee Responses to EPA Questions Re Plant Seal Deterrent Barrier.Util Completed Installation of Subject Barriers on All Three Station Offshore Intake Structures on 990818.Barriers Will Preclude Entrapment of Seals ML20210S7331999-08-11011 August 1999 Submits Third Suppl to 980423 Application to Renew NPDES Permit NH0020338 for Seabrook Station.Suppl Provides Addl Info on Input Streams & Requests Increased Permit Limit for Chemical Used in Makeup Water Treatment Sys ML20210N9421999-08-0505 August 1999 Informs That North Atlantic Suggests Listed Revisions to 990730 Draft Revisions to Committee Rept & Order.Further Revs Consistent with What North Atlantic Proposed at 990608 Hearing ML20210H7591999-07-30030 July 1999 Submits Rept of Seal Entrapment at Seabrook Station,Iaw Paragraph 6(i) of Natl Marine Fisheries Svc (NMFS) Ltr of Authorization to Take Small Number of Seals Incidental to Intake Cooling Water Sys Operations at Plant ML20195D8451999-06-0707 June 1999 Submits Correction to Minor Error in One Comment Provided in Re North Atlantic Comments on Rept & Order for Ndfc 98-01 & Provides Addl Comment to Resolve Potential Problem with Funding Schedule for Yr 2000 ML20195D5551999-06-0202 June 1999 Forwards Original & 10 Copies of Affidavit of Publication ML20195C0431999-05-25025 May 1999 Describes Util Plans to Install Seal Deterrent Barrier on Seabrooks Station Three Offshore Intake Structure Summer of 1999 to Preclude Entrapment of Seals ML20206E3951999-04-26026 April 1999 Forwards Revised Funding Schedule That Provided Info,Per First Suppl Order ML20196E5871998-11-25025 November 1998 Repts Discovery of Seal Remains at Seabrook Station.Remains Were Removed from Station Screen Wash Debris on 981124 & Consisted of About Ten Pounds of Hide,Flesh & Bones.Encl Contains Seal Entrapment Rept as Requested ML20197C2721998-09-0808 September 1998 Forwards Order of Notice Specifying Times & Locations of Upcoming Hearings Before Nuclear Decommissioning Financing Commission ML20151U8551998-09-0202 September 1998 Forwards Rebuttal Testimony by Callendrello,Rebuttal Testimony by Laguardia & Opening Statement of North Atlantic ML20236U5031998-07-20020 July 1998 Forwards Direct Testimony Submitted on Behalf of Campaign for Ratepayer Rights for Presentation Before Decommissioning Finance Committee in Ndfc 98-1 ML20236T2291998-07-20020 July 1998 Forwards Testimony of Js Robinson on Behalf of intervenor- Applicant New England Power Co in Captioned Proceeding. Copies of Filing Have Been Served on All Parties on Attached Svc List ML20236Q1251998-07-13013 July 1998 Forwards New England Power Co'S Motion to Intervene Separately in Seabrook Nuclear Decommissioning Fund ML20217H7361998-04-23023 April 1998 Forwards Application for Renewal of NPDES Permit NH0020338 for Seabrook Station.Application Contains Completed EPA Forms 3510-1,3540-2C & 3510-2F & Other Supporting Info. Page 2-2 in Tab 6 Section of Incoming Submittal Not Included ML20199E9551997-11-18018 November 1997 Provides Clarification to Response Stated at 971106 Meeting of Nuclear Decommissioning Financing Committee on Impact of Proposed Decommissioning Funding Schedule on 1998 Funding ML20199E9511997-11-18018 November 1997 Informs That G Gram Will Replace B Romer as North Atlantic'S Representative on Nuclear Decommissioning Financing Committee.Resume of G Gram,Encl ML20140H7711997-06-13013 June 1997 Submits Application Requesting Small Take Exemption Permit for Incidental Lethal Taking of Small Number of Seals as Result of Plant Operations ML20137N2011997-04-0101 April 1997 Forwards Tables I & II of Seabrook Station Annual Decommissioning Update,March 1997 Which Were Inadvertently Omitted at Time of Printing ML20116A3301996-07-19019 July 1996 Provides Set of Matls in Support of Project W/Gds Assoc in Marietta,Ga ML20069L1341994-05-31031 May 1994 Submits Update of Decommissioning Study for Seabrook Station Unit 1,in Accordance W/Requirements of Procedural Order 6 ML20065C9501994-03-31031 March 1994 Forwards North Atlantic Energy Svc Corp Seabrook Nuclear Decommissioning Financing Fund Investment Performance Summary for Yr Ending 931231, Dtd 940328.W/o Encl ML20063E1401994-01-25025 January 1994 Informs That Since Recipient Will Incur Expense of Utilizing Svcs of Outside Consultant in Present Proceedings,North Atlantic Proposes to Submit Update of Plant Decommissioning Study & Funding Schedule in Accordance W/Listed Schedule ML20057C8121993-09-22022 September 1993 Discusses North Atlantic Objection to Proposals Made in OCA Re Retaining Consultant for Committee. Suggests OCA Not Be Granted Relief ML20101S1831992-06-22022 June 1992 Forwards Summary of State of Nh Puc 920602 Meeting Re New England Telephone Co Motion to Postpone Hearings on Docket, Order Establishing Hearing Date on Increases in Decommissioning Costs & Revs to Second Rate Tariff ML20096E0151992-05-0707 May 1992 Forwards New Hampshire Yankee Response to Seacoast Antipollution League Motion to Join in Appeal of Ofc of Consumer Advocate Filing Before State of Nh Supreme Court During Mar 1992 Session ML20096D6551992-05-0404 May 1992 Forwards Motion of Seacoast Anti-Pollution League to Join in Appeal of Ofc of Consumer Advocate for Filing W/Court Re Useful Life of Plant ML20099E9931992-03-26026 March 1992 Forwards New Hampshire Public Utilities Commission (Nhpuc) 920319 Rept & Order 20,416 in Docket DF 91-193 Approving Step Two Financing Jointly Filed on 911118 by Psnh & Neut & North Atlantic Energy Corp ML20092F2681992-02-0707 February 1992 Forwards Response to 920109 Request for Written Info Re 910930 Release of Radionuclides from Facility.No Radionuclides Released to Atlantic Ocean in Excess of Limits Stipulated by NRC & OL ML20087E4161992-01-13013 January 1992 Urges Reconsideration of State of Nh Position Re Proposed Decommissioning Finance Plan for Facility.Wf Boyle Recommendations Encl ML20087D1461992-01-10010 January 1992 Forwards Affidavit of Publication Re 920117 Public Hearing to Take Testimony Re Proposed Plan for Updating Nuclear Decommissioning Financing Fund ML20087B8491992-01-0606 January 1992 Forwards TS Laguardia 911230 Affidavit Re Unit 1 Capacity to Store Spent Fuel on Site.Present Spent Fuel Storage Capacity Is 17 Cycles or 18 Yrs on 13-month Cycle Base ML20086S7861991-12-24024 December 1991 Forwards New Hampshire Yankee 911224 Objection to Motion for Hearing from Ofc of Consumer Advocate on Grounds That Motion Premature.Objection Filed W/State of Nh Nuclear Decommissioning Financing Committee ML20083D4051991-09-10010 September 1991 Forwards Testimony of TS Laguardia on Behalf of Util Re Data Requests ML20083D3871991-09-10010 September 1991 Forwards Supplementary Response of IE Canner to Data Request IEC-1 Re Payment Problems Anticipated Due to Bankruptcies of New Hampshire Electric Cooperative,Eua Power & Psnh ML20082P9751991-09-0909 September 1991 Forwards Responses to Requests for Info Re Facility Decommissioning Plan ML19333A6581991-09-0404 September 1991 Forwards AL Spitzer Responses to Data Requests from State of Nh Ofc of Consumer Advocate (Set 4) & IE Canner Responses to Suppl Data Requests (Dtd 910821) of Ofc of Consumer Advocate Re Decommissioning Fund ML20082M4121991-08-30030 August 1991 Informs Committee & Parties That J Dunn,Left Ropes & Gray & Will Not Be Testifying in Person in Proceeding.Al Spitzer Will Testify in Her Place ML20082K5351991-08-21021 August 1991 Forwards Supplemental Testimony of VP Wright & Supplemental Response of IE Canner to Data Request IEC-1 of Ofc of Consumer Advocate Set 1 for Filing ML20082N3701991-08-21021 August 1991 Forwards Data Requests of Ofc of Consumer Advocate for New Hampshire Yankee ML20082P1531991-08-20020 August 1991 Forwards Suppl Discovery Requests on Behalf of Seacoast Antipollution League Covering Number of Gallons of Fresh Water Required for Decommissioning Processs ML20082J2661991-08-0707 August 1991 Forwards Data Responses to New Hampshire Yankee ML20081L0311991-06-24024 June 1991 Forwards New Hampshire Yankees Reply to Nelkens Response to Objection on Discovery Requests ML20079C8461991-06-10010 June 1991 Forwards Ofc of Consumer Advocate Addl Data Requests ML20077D8621991-05-31031 May 1991 Forwards New Hampshire Yankee Objection to Certain Data Requests, from Nelkens to State of Nh Nuclear Decommisioning Financing Committee ML20079C8531991-05-27027 May 1991 Forwards Ofc of Consumer Advocate Second Set of Discovery Requests Re Facility Witnesses,Ts Laguardia & Gj Caine ML20006D3031990-01-26026 January 1990 Forwards Addl City of Newburyport Brief on Appeal of Partial Initial Decision of Spmc LBP-89-32 & Statement of Issues Presented Re Appeal of LBP-89-32.W/o Encls.Related Correspondence ML20012E1631989-12-26026 December 1989 Forwards Results of Evaluation of Corporate Support & Monitoring of Facility Conducted on 891002-06.Written Status Rept Requested by June 1990 ML20005G1211989-12-0404 December 1989 Forwards Commonwealth of Ma,Necnp & Seacoast Anti-Pollution League Petition for Review of ASLB 891113 Order LBP-89-32. Svc List Encl 1999-09-14
[Table view] Category:EXTERNAL LETTERS ROUTED TO NRC
MONTHYEARML20006D3031990-01-26026 January 1990 Forwards Addl City of Newburyport Brief on Appeal of Partial Initial Decision of Spmc LBP-89-32 & Statement of Issues Presented Re Appeal of LBP-89-32.W/o Encls.Related Correspondence ML20012E1631989-12-26026 December 1989 Forwards Results of Evaluation of Corporate Support & Monitoring of Facility Conducted on 891002-06.Written Status Rept Requested by June 1990 ML20005G1211989-12-0404 December 1989 Forwards Commonwealth of Ma,Necnp & Seacoast Anti-Pollution League Petition for Review of ASLB 891113 Order LBP-89-32. Svc List Encl ML20248J0161989-09-27027 September 1989 Expresses Displeasure W/Actions Taken by Recipient Clients at Newington Town Hall on 890927.Restricting Access to Public Facility Deemed Inappropriate & Discriminatory. Related Correspondence ML20248B5671989-05-30030 May 1989 case-returning Commuters.* Forwards Work Place Table from Adler to Aid Kld in Further Assessment of Returning Commuters within EPZ from Work Places within Epz. Related Correspondence ML20246J4021989-05-11011 May 1989 Requests Confirmation,As Followup to 890510 Telcon,That Town of Newbury No Longer Asserting Listed Bases & Still Intends to Litigate Basis H in Light of Fact That Map Objected to Has Been Withdrawn from Spmc.Related Correspondence ML20246J4391989-05-10010 May 1989 Confirms That Town of Amesbury Does Not Intend to Litigate Joint Intervenor Contention 2 as Long as Applicant Adheres to Present Plan of Not Routing Traffic Across grassy-median at I-95/Route 110.Related Correspondence ML20246J4961989-05-0909 May 1989 Advises That Matl Requested in Re Applicant Rebuttal Testimony 16 Has Been Assembled & Sent to Adler as Requested.Related Correspondence ML20246H2211989-05-0808 May 1989 Confirms 890505 Telcon Re Applicant Incorrect Impression That Seacoast Anti-Pollution Leauge (Sapl) Was Withdrawing Testimony of C Breton & J Van Gelder Re Sapl Contention EX-12.Related Correspondence ML20246H7141989-05-0404 May 1989 Informal Discovery Request Re Applicant 16.* Requests Computer Readable Listings & Paper Copies of All Idynev Assignment,Evacuation Time Estimates & Sensitivity Runs Mentioned in Testimony 16.Related Correspondence ML20246H2251989-05-0303 May 1989 Forwards 10 of 16 Documents Sought by Commonwealth of Ma 890405 Motion to Compel Production of Documents.Brief Accounting of Documents in Dispute Also Encl.W/O Documents. Certificate of Svc Encl.Related Correspondence ML20244C9281989-04-14014 April 1989 Confirms That Commonwealth of Ma Atty General Will Withdraw Joint Intervenor Contention 38,MAG EX-17 & Ji 27,Basis E Which Were Omitted from Commonwealth 890411 Trial Brief,Per 890412 Conversation.Related Correspondence ML20246M4751989-03-17017 March 1989 Supplemental Response to Commonwealth of Ma Atty General Informal Request for Production of Documents Re 1988 Seabrook Graded Exercise.* W/O Stated Exercise Evaluation Documents.Certificate of Svc Encl.Related Correspondence ML20236D8381989-03-16016 March 1989 Confirms That Author Will Depose N Pishon,Employee of State of Nh,On 890320 at State of Nh Ofc.Related Correspondence ML20206N0341988-11-23023 November 1988 Forwards Documents Ref in RW Donovan 881109 & 10 Deposition, Including Forms on Which Results of Interviews Verifying Ltrs of Agreement Recorded.W/O Stated Documents.Certificate of Svc Encl.Related Correspondence ML20154A0551988-09-0101 September 1988 Offsite Emergency Planning Issues.* Advises That FEMA Will Respond to Applicant First Set of Interrogatories & First Request for Production of Documents Re Seabrook Plan After 881014.Related Correspondence ML20207E3831988-08-10010 August 1988 Lists Corrections to Applicant Response to New England Coalition on Nuclear Pollution (Necnp) Third Set of Interrogatories on Necnp Contention I.B.2.W/Certificate of Svc.Related Correspondence ML20151M7321988-07-25025 July 1988 Demands That Massachusetts Municipal Wholesale Electric Co, to Rescind Votes Not to Make Payments to Facility Project & Take Firm Steps Towards Reducing Debt Burden on Participants & Consumers ML20151N9901988-04-0707 April 1988 Forwards Exhibit 1,consisting of Transmittal Ltr That Accompanied Amend 3 to Seabrook Plan for Ma Communities. Timely Notification of Parties Re Major Revs Requested. W/O Encl.Related Correspondence ML20196G5421988-03-0303 March 1988 Ack Receipt of Strong Ltr to Vickers Transmitting Document Supplemental Analysis of Potential Shelter Capacity of Seabrook EPZ Beach Areas, for Review.W/O Encl ML20147H8721988-03-0303 March 1988 Forwards Comments of Commonwealth of Ma Attorney General Jm Shannon in Opposition to NUREG-0654/FEMA/REP-1 Rev 1, Suppl 1, Criteria for Util Offsite Planning.... Certificate of Svc Encl.Related Correspondence ML20012E1571988-03-0202 March 1988 Forwards Trip Rept of 880125-29 Site Visit Providing Technical Expertise During Emergency Preparedness Performance Assessment.Briefing Scheduled for 900309 to Discuss Visit ML20149N0661988-02-23023 February 1988 FEMA Evaluation of State of Nh Response to FEMA Supplemental Testimony.* Urges FEMA to Consider New Info Developed During Hearings on State of Nh Radiological Emergency Response Plan Re Evacuation Time Estimates.Related Correspondence ML20236W3611987-10-20020 October 1987 Expresses Concern Re Use of Premises as Shelter in Support of Plant Emergency Response Planning.Requests That Premises Be Removed from List of Shelters Developed as Part of Emergency Response Plans.Served on 871028 ML20237J3831987-08-20020 August 1987 Clarifies Apparent Misunderstanding as to Atty of Record for State of Vt,Dept of Public Svc in Facility Decommissioning Fund.Author Should Be Listed as Atty of Record,Not K Janson ML20234D0461987-06-17017 June 1987 Requests Withdrawal from Participation in Development of Plant Evacuation Plan & Deletion from Publications Outlining Emergency Plan.Desire to Participate W/State of Ma Ofc of Civil Defense & FEMA in Disasters Noted.Served on 870630 ML20234D0251987-06-16016 June 1987 Forwards Order Voted Unanimously by Board of Selectmen on 870614.Decision May Be Appealed within 14 Days of Receipt. Served on 870630 ML20215D6601987-06-10010 June 1987 Confirms That Deposition of E Thomas Scheduled for 870615, Will Be Postponed Until Later in Summer ML20214W5261987-06-0303 June 1987 Advises That Deposition of D Laughton of Teamsters Local 633 Will Be Taken on 870616.Certificate of Svc Encl.Related Correspondence ML20214W5561987-06-0303 June 1987 Advises That Deposition of a Calandrello Changed from 870609 to 870612.Related Correspondence ML20214P3281987-05-29029 May 1987 Public Svc Co of Nh (Offsite Emergency Planning) Depositions of D Mileti & E Lieberman.* Confirms 870528 Telcon Re Depositions of D Mileti & E Lieberman on 870611 & 29, Respectively.Certificate of Svc Encl.Related Correspondence ML20214S0581987-05-28028 May 1987 Confirms Results of 870528 Telcon Re Deposition of Rh Stone. Commonwealth Agrees to Postpone Deposition Indefinitely to Date After 870620.Certificate of Svc Encl.Related Correspondence ML20214S1441987-05-26026 May 1987 Confirms Discussion Indicating Author Requesting Dates for Deposition of a Calandrello.Suggests 870609 at Author Ofc. Certificate of Svc/Svc List Encl ML20215B2871986-09-18018 September 1986 Objects to Violation of State Law Re Lack of Scheduled Payments Into Decommissioning Fund & Relevant Info Available for Public Review ML20199G5111986-06-0404 June 1986 Forwards Rev 1 to State of Nh Radiological Emergency Response Plan & E Lieberman Re Differences Between Encl Draft Final Rept & Seven Progress Repts of Evacuation Time Estimates & Mgt Plan Update.W/O Plan ML20198E0391986-05-13013 May 1986 Forwards Town of Exeter,Nh Answer to Interrogatories & 1980 Civil Defense Basic Master Emergency Plan.Firm Has Not Filed Appearance for Town But Assisted in Preparing Encl Answers. Related Correspondence ML20203Q1601986-04-29029 April 1986 Discusses Support for Plant,Emergency Evacuation Planning & Storage of Spent Nuclear Fuel ML20140B1621986-01-16016 January 1986 Informs of Concerns Re Emergency Evacuation Plans for Facility.As Plans Were Sent W/O Local Board Approval,Return for Further Work Requested.Served on 860122 ML20137H9021986-01-0909 January 1986 Requests That FEMA Be Notified That Local Emergency Plan Submitted to Hg Vickers on 851209 Was Not Authorized or Approved by Hampton Falls Community.Explanation Re Submittal Also Requested.Served on 860117 ML20137H9031986-01-0707 January 1986 Advises That Radiological Emergency Response Plan Submitted by Rh Strome on 851209,purportedly on Behalf of State of Nh & Local Communities,Is Not Recognized by Rye,Nh.No Plan Exists That Can Assure Resident Safety.Served on 860117 ML20140A9501985-12-0606 December 1985 Responds to Re Preparation of Radiological Emergency Response Plan.Attachment Addresses Each Question Raised.First Draft of Plan Submitted in 1983 & Updated in 1984.Served on 860122 ML20140B1721985-12-0202 December 1985 Ack Receipt of Ltr Re Details of Planning Effort within Emergency Planning Zone.R Strome Will Respond Directly to Questions.Served on 860122 ML20138B4371985-11-25025 November 1985 Ack Receipt of 851119 Request for Disclosure of Confidential Privileged Data Re Facility OL Proceeding.Request Denied Based on Confidential Nature of Info.Related Correspondence ML20140B1681985-10-29029 October 1985 Expresses Opposition to Radiological Emergency Response Plan.Plan Inadequate & Makes No Serious Attempt to Evacuate Endangered Citizenry ML20129A1291985-06-28028 June 1985 Discusses Concerns Which Costello Communicated to NRC Chairman,Nrc & Governor of State of Ma Re Indictment of J Padavano & Discrepancies in Summer Evacuation Time Estimates.Served on 850712 ML20088A1951984-04-0505 April 1984 Notifies That Installation of Emergency Notification Sys Prohibited Until Emergency Response Plan Approved by Town Meeting ML20082S4951983-12-0808 December 1983 Forwards Responses to New England Coalition on Nuclear Pollution Interrogatories on State of Nh Radiological Emergency Response Plan.W/O Encl.Related Correspondence ML20082L0941983-11-22022 November 1983 Ack Receipt of Re Nuclear Plant Evacuation &/Or Emergency Preparedness Plan.Installation of Public Alerting Sys Not Presently Allowed in Town of Hampton Falls,Nh ML20082D5861983-11-16016 November 1983 Forwards Response to Limiting Scope of Interrogatory 2.FEMA Is Not Party to Proceeding & Is Not Required to Respond to Interrogatories Served Under 10CFR2.740b or to Produce Documents.Related Correspondence ML20078H0761983-10-0606 October 1983 Lists QA Procedures Approved for Implementation & Available for Insp at Station.Svc List Encl 1990-01-26
[Table view] |
Text
- - - - - - - - - - - - - - - - - - - - - - - - -
I . L. :C$A:$ $~ 0
, M THE COMMONWE ALTH OF M ASS ACHUSETTS
-e s - , . . . . . . .
j g {J DEPARTMENT OF THE ATTORNEY GENERAL L
',tj kM [ .lOHN W. McCoRM ACK STATE OFFICE BUILDING
?' i ONE ASHBURTON PLACE. BOSTON O21081698
'...+'
1E FEB 26 P4 :01 glA'IED CORRESPO_NDJEN
- " "~ "
JAMES M. SHANNoN --
ATTommer orwenat V**';.
00c8t. 9 . ! I
. F u. .
Feoruary 23, 1988 H. Joseph Flynn, Esq.
Assistant General Counsel Federal Emergency Management Agency .
500 C Street, S.W.
Washington, DC 20472 Re: FEMA's Evaluation of the 'lew Hampshire Response to :EMA Supplemental Testimony
Dear Joe:
I Jnderstand that FEMA and the RAC are now in the process of evaluating the New Hampsnite Response to FEMA Supplemental Testimony (iew Hampshire Response") and that on :tarch 14, l 1983, FEMA vill announce its updated position on the so-called l l
oesch/shelteting contentions at issue in the '1HR**?
litigation. Because FEMA's ptevious position statement on
- .nese is.nes relied, to some extent, on the evacuation time estimates ('ETEs') contained in Volume 6 of Revision 2 of the 1
N M R F,R p , I am writing now to ensure that FEMA does not tely on those same ETEs as it te"lews the New Hampshire Response. The sunnet weekend ETEs contained in Volume 6 are no longer accurate, if they ever wete, and the Applicants ntke this clear in updated (longer) ITEs submitted as part of their direct 0
R es 900223 0 M 05000443 PDR SM"
_ v. _ _ - ..u m. 1 _ _ _
4 pre-filed testimony on the ETE issues in the NH9ERP litigation. See Applicants' Direct Testimony do. 7'(Evacuation Time Estimate and Human Behavior in Emergencies).(' Applicants No. 7") at 41-44-(attached heteto as Attachment.l's.1!
tioteover, during the course of the NHRERP litigation, the Intervenors submitted substantial evidence that.(1) an orderly
~l
, vehicular evacuation of the Seabrook EPZ beach areas may not be -
oossible when the beaches are crowded and (2) even if an i
orderly vehicular evacuation were achievable, the realistic ~- -
l summertime ETEs for days when the beach area vehicular population is at capacity (Scenarios 1 and 2)'are at least j 50-100% longet than the times presented in the Applicants' l 1 i opdat.sd ETEs. See generally the direct testimony of Thomas Adler, Avishai Cedet, and Albert Luloff, and the rebuttal testimony of Edwin Oliveta. Thus, while what the ,
1 cuttent tealistic ETEs for Seabrook are is a natter of serious dispute, no one at the hearings has contended that the Volume 5 !
1 i
1 1/ These updated ETEs are presented in four tables, each for an evacuation from "within" a given area (the 2, 5, and 10 mile rings and the EPZ boundary itself). These areas are depicted on the map attacned as Attachment 2, a map taken from the NHRERP Rev. 2. For each table, ETEs are listed for Scena:ios 1 l and 2. These are both summer weekend full-besch ETEs, the i first for an evacuation which occuts during good weather, the second for an evacuation during and after a sudden rain. The definition of the Vatious evacuation Scenarios fron Volume 6 is attacned heteto as Attachment 3. Each of the four tables lists, for Scenarios 1 and 2, the ETEs fot Regions'l-9 and j 11-13. Regions 1-9 are identified in Tacle 10-2 in volune 6, i attached hereto as Attachment 4. ~ Regions 11, 12 and 13 are j identified on p. 41 of Applicants' No. 7 (contained in Attachment 1). The ERPAs used to identify the various Regions !
1 are themselves identified in Table 10-3 in Volume 6, attached hereto as Attachment 5.
5 i
'2-4
ETEs for the summet scenarios vete realistic for he 1937-1938 time period.
Given that the state of'the ITE tecord has changed gignificant'.y since FEMA last. stated its "cuttent position" tegarding the btach/ sheltering issues, what FTEs if any should FEMA and the.RAC use now in assessing.the New Hampshire Response? The Intervenots utge FEMA and the RAC to considet carefully the whole ETE tecord developed in the NHRERP hearings before drawing conclusions about whether orderly vehicular evacuation is possible and, if so, what ETEs are most realistic and should be applied in reviewing the New Hampshire Response.
In out view, the whole tecord demonstrates that a set of realistic ETEs for the beach areas have yet to be calculated.
Oat expett, Dt. Adler, presented substantial evidence showing that Applicants' ETEs are much too low, and he testified that the Scenario 1/ Region 1 ETE is over 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, but he did not compute a conplete set of ETEs. See Testimony of -
Tnomas J. Adler (following Tr. 3847) at 52-53 (atta:hed hereto as Attachnent 6). We believe the Applicants should ce directed t'o re-compute the ETEs in the mannet which out experts, Dr. Adlet and Dr. Cedet, have tecommended, and we would encoutage FEMA and the RAC to support this effort. In any event, as they review the New Hampshire Response, FEMA and the RAC should not do any of the following at this time:
3-
.= .
lN
. .m ,
t 4
- 1. FEMA anc the'RAC should not assume that an orderly,. s efficient vehiff atlevacution from the Seabtook EPZ beach ateas ^
can'be achieved when the beaches are crowded. IThe testimony presented by a nunber of-intervenot' witnesses has painted a ,
t very chilling pottrait of whatsthe traffic situation will be like aftet the beach areas are ordeted evacuated on days when these areas are crowded. At best, the traffic flow will be i what tne traffic engineers call "Level of Settice F," that-is, extremely conge'sted flow in which long queues are formed an'd
- stop-and-go operations result. Traffic congestion will be so i
sevete, and will last for so long, that many evacuees will likely abandon their cars, finding it faster to walk than to j drive. See, e.g., Testinony of Thomas J. Adler (following Tt. l 3347) at 15-18 (contained in Attachnent 6). See also Testimony 1
of Albert E. Luloff (following Tr. 3203) at 14-15 (attached i
i '
hereto at Attachment 7). The traffic situation Vill be fat worse than that which exists when the beach areas enpty on busy days. Adlet Test, at 13-14 (see Attachment 6). Because traffic delays will be so lengthy, drivet frustration will tesult in traffic disorderliness that will further jeopardi:e j
an orderly, efficient evacuation. See, e.g., Rebuttal l
J Testimony of Edwin J. Olivera (following Tt. 9433) at 5-8 (attached hereto as Attachment 3). Taken together, this
- testimony is compelling and cannot be ignored. FEMA and the RAC nost at least acknowledge that serious, credible doubt exists about the feasibility of an orderly vehicular evacuation from the beach ateas when they are etowded.
i 4-
I I
1
- 2. FEMA and the RAC should not reference the
' unrealistically short sunner weekend ETEs contained in Volume 6 of the NMRERP, ETEs which no witness at the '!9RER? otoceedinqs l
~
- estified wete realistic for the beach population in'the sur.9et t t
of 1937 As noted above, the Applicants'themselves have submitted updated (longer) summer weekend ETEs as part of theit-prefiled testimony in the NHRERP litigation. (See Attachnent ,
1.) These updated ETEs are longer than the Volume 6 ETEs because a number of the input variables to the IDYNEV compu't'et ,
model were increased. First, as a result of aetial photos ,
taken by the Applicants on one day last sunner the nunbet of c beach area vehicles used to calculate the summer weekend ETEs
- was increased by alnost 4000 vehicles, from 25,470 in Vol. 6 to j l
4 29,293 for the updates. There were many more cars seen parked (
in the beach area in these photos than in the photos taken in l August 1985 which formed the basis for the beach atea vehicle !
1 estimates used in the Vol. 6 ETE calculations. See general-ly i
j Applicants' No. 7 at 27-38. Another IDYNEV input variable 1
which the Applicants changed in doing their updated ETE calculations is that which describes the extent of voluntary public evacuation. The volume 6 ETEs were based on the single
]
] assumption "that 25 percent of the population within the EP3,
! but outside the Region ordered to evacuate, ' fill spontaneously i
! evacuate, contrary to instructions." Vol. 6 at 10-3. In i 1
i j
calculating ETE updates, however, the Applicants also I
l l
s-
consideted the effects of a "keyhole voluntaty evacuation" that would include 50% of the population outside of a wedge-shaped subsegment of the E?Z (e.g., the innet north Region -- ER?As A and B -- from 2-5 miles) if that subsegnent were ordered to evacuate. See generally Applicants' No. 7 at 160.
FEMA and the RAC snould keep in nind that Intervenots submitted substantial evidence that the numLat of beach area vehicles used to compute these updated ETEs is still much too low, and tnat concentric voluntaty evacuation will be highet than Applicants have now assumed. Nevertheless, the point is that no one considers the Volume 6 summer weekend ETEs to be realistic at this time.
- 3. FEMA and the 9AC should not reference the Region 10 ETEs when discussing the times to "evacuate" or "clear" the beach areas. This snould be easy to do since even the l l
Applicants nave eliminated Region 10 ETEs from their updated I 1
l ETE tables. (See Attachnent 1.) As was nado clear from the l ctoss examination of Applicants' witnesses Callendrello and I l
Lieberman (Tr. 5715-5722), the "becch areas" encompassed by l
Region 10 include only those pottions of the battier islands immediately adjoining the beaches but not the nain exit toads (Rt. 51, Rt. 236, or Rt. lA west from Salisbury Beach) from these areas. Thus, Mr. Liebetman described a car in Hanpton Beach as being outside the Region 10 beach area once it had left Highland Avenue and enteted Rt. 51 westbound, a point only 6-
-- =:.= :=..x.c_=._ .
I
{
I .
about three or four blocks west of the beach-(Rt. lA). ,
-Lieb'etman, TL.-5716. This is not a neaningful or televant ;
point'ftom which.to calculate ETEs ot "cleat
~
oeople in the beach areas. The telative safety of-the mainland is still-some distance away across the marshes, and beach area i traffic will nove only very slowly along t.he main evacuation toutes (Rt. 51, Rt. 286, Rt. lA) toward the mainland. New 'l 4
t Hanpshire has no cuttent plans which contemplate an evacuation f
-of only Region 10. . Tt. 5719.
j Perhaps nost importantly, unlike the outet boundaries fot !
all the other ETE Regions, the ' boundary
- of Region 10 does not describe any fixed distance from the nucleat plant. For .
! l i example, after leaving Region 10, the traffic exiting the beach area on Rt. 286 actually moves closer to Seabrook Station, crossing back into the 2 mile ring for a couple of miles. See [
Fig. 1-3 on p. 1-13, Vol. 6. Thus, Region 10 ETEs have no l 3
- value for FEMA or the RAC in assessing the adequacy of the -
i j 'RRER?. As with the ETEs for other portions of the EP2, the i 4
i only televant evacuation tines for people in the beach areas j l
aie those referenced by theit ultimate passage out beyond the 2 i i
[ mile, 5 mile, and 10 mile rings and through the Ep2 boundary -
- itself. For almost all these people, the 5 mile ting is the first televant ring. Only the closest beach areas on Seabrook i Beach and Hampton 3each are less than 2 miles from the plants i
most of New Hampshire's beaches are between 2-5 miles from 1
h 4
Seabrook Station. Thus, as the people in these beach ateds travel out the evacution toutes to points which are furthet away from the nuclear plant than when the evacuation began, the (itst televant ETE neasurement point teached is the 5 nile ting. If Table 2 in the Applicants' ETE updates is referenced (ETEs "ftom within 5 miles"), the Scenatio 1/ Region 9 ETE is stated to be 6:20. If larget areas are ordered to evacuate (Regions 5-3), the ETEs for clearing the 5 mile ting ate as nich as 6:35.
In sum, the Intetvenots oelieve that the Region 10 ETEs have no televance. Nevertheless, should PEMA and the RAC still sish to reference the Region 10 ETEs, we encourage you to examine Figures 1 and 2 of the Adler Testimony, at lla and 16a (Attachment 5). Tnese figures reflect the Region 10 ETIs Dt. Adlet has calculated.
- 4. FEMA and the RAC should not assume that the Acolicants' updated ETEs are equivalent to the times needed to "clear the beaches." In fact, all of the Applicants' ETEs (the old and the new) are referenced from an order to evacuate which, pursuant to the planning basis used by Mt. Lieberman in conducting his IDYNE7 tuns, occurs 25 minutes after a ' beach closing
- announcenent. See Lieberman, Tr. 5655-5674; see also volume 6 at 4-1, 4-2, 10-12, 10-13. The assunption utilized for the planning basis is tnat the number of people who will 1
choose to leave the beach areas upon heating the beach closing I 1
l 1
1 J
announcement is sufficient to quickly saturate the exit toads.
Lieberman, Tt. 5671, 5673. Thus, to determine how long the Applicants contend it will take to "cleat" an area (2, 5, or 10
.giles ting or the EP: boundary) after the first notification to beach-goers that generates outbound toad saturation from the beach areas, then you must add 25 minutes to all the Applicants' ETEs. For exanple, in Table 2 of the Applicants' updated ETS tables, Applicants' Ditect Testimony No. 7 at 42 (included in Attachment 1), the Scenario 1/ Region 9 ETE for'an evacuation from within 5 miles is listed to be 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 20 minutes. This 6:20 is the time that it take s af ter an order to evacuate (or "OTE") for the last car to pass through the 5 mile ting. However, since the beach closing announcement occurred 25 minutes cefore the GTI and generated enough outbound traffic to satutate the exit roads, the time to "cleat" the 5 mile ring (i.e., time from first notification until the area is cleated 1
of all evacuating vehicles) is really 6 houts and 45 minutes, using Applicants' tables.
I FEMA and the RAC should not assume that the Acolicants' 5.
updated ETEs are "conservative," "pessimistic," or ' worst case."
While KLD Associates has indicated in the past that the ETEs it l l
calculated wete based on a number of conservative assunptions aoout "uncertainties," at the NHRERp heatings Mt. Lieberman of XLD insisted that his estinates were not conservative but were teslistic. No party or witness at the hearings has assetted
. . .. a that KLD's updated ETEs wete conservative (untealistically long). Instead, Intervenots presented substantial evidence that both the Applicants' 1986 and updated ETEs are overly
~
, optimistic, i.e., considerably shortet than can tealistically i be achieved, because they are based on a number of ettoneous critical assumptions. See especially the pre-flied testimony f of Dt. Adler and Dt. Ceder. One such assumption, recogni:ed by I the NRC's own witness, Dr. Utbanik, is that the Anglicants' TTE updates were calculated using an unrealistically small beach stea vehicle population because 1500 cars seen noving on the beach toads on the Applicants' 1987 beach photos were ignored.
See Utoanik, Tr. 7374. In addition, Intervenots have pointed i l out that in counting beach vehicles for the ETE updates, the L
! Applicants have also ignoted approximately 2000 additional ,
i vehicles nidden from aetial view parked in garages, catpotts, I and in under-building parking areas. See Rebuttal Testimony of !
Ot. Thonas J. Adlet at 14-15 (attached heteto as Attachment.
9). If the Applicants had considered these 3500 vehicles (1500-
- plu; 2000) in addition to the 29,293 parked vehicles that were considered in conducting their updated ETE analyses, there is no question that their updated ETEs for the sunnet scenatios I
would have been longer.
! Another fact, presented by a seniot officer f or the 'lew Hampshire State Police, also casts serious doubt on the notion that Applicants' ETEs are ' conservative" (i.e., likely to be shorter than stated). Captain Sheldon Sullivan stated that the
)
9.H. State Police. on whom the plans tely for 74 troopets to staff Traffic Control Points ('TCPs") and Access Control Points '
('ACPs") thtoughout the New Hampshire pottion of the EPO) (see
- able 3.1-1 of the Summary of Personnel Resource Assessment for the NHRERP, Aug. 87, Applicants Exhibit No. 1-A, ff. 7t. 4685),
l can ptovide only 4 troopers within the first 15 minutes after ,
notification to them, Tt. 4704, and 3 more within the next 45 minutes, Tr. 4714. Only 6 additional troopets can report to I
conttol points within the next hour, for a total of 13 troo' pets teporting within the first two hours aftet notification to the j State Police. Tr. 4715. Thus, unless notification to ths ,
i State Police occurs well before an OTE, there will be 2
l late-staffing of most of the ACPs and TCPs in New Hampshire. !
Obviously, .one of these ACPs and TCPs are more important than i others, and these have been designated "Priotity l' posts. But r
a total of 46 troopets are needed just to staff the "Priority l' ACPs and TCPs used to facilitate an evacuation of the entire EP: on a summer weekend in good weather. See N.9. State Police Manning sequence, attached as Attachment-10.
Clearly, if a fasc-breaking accident occurs at Seabrook Station during the summer, FEMA cannst assume that all Priority 4
1 posts will be staffed before the beach closing announcement or even the OTE is made. Even the Applicants believe that late staffing could lengthen theit updated estimates of evacuation times, depending on how fast the Route 51 overpass of I-95 is d
i i
staffed. Applicants' No. 7 at 44-47 Intetvenots believe this i
late staffing will, at best, tesult in~a-less efficient and .
I otdecly evacuation of the beach ateas that will take longer ,
than Applicants' updated ETEs would suggest. Rebuttal Testimony of Dr. Thomas J. Adlet at 2-4 (Attachment 9). At 4 worst, this late-staffing creates a situation quite.similat-to an unplanned evacuation -- traffic control personnel-present in the early hours are too few and may be too-far apart to ensure orderly traffic flow. Traffic chaos may develop eliminating l any teasonable expectation that an orderly vehicular evacuation can occur. But whatevet conclusions FE'iA and the RAC draw r regarding the late-staffing of posts by the N.H. state police, at least FEMA should agree that Applicants' updated ETEs are .
quite unlikely to be ovetly conservative (shortet than i tealistically can be obtained) for the beach population during l t
l telatively fast-bteaking accident situations, j
I
. Conclusion ,
FEMA's present assessment of the New Hampshire Response obviously must take into account the extensive evidentiary record regarding ETEs which has been developed to date in the J
i NHRERp litigation. That record contains a number of critical considerations that beat on whether the New Hampshire Resoonse l 1
ptovides adequate protection to the beach population. ;
1 !
! i l
T
.. .- u _ .:; . -- - - -
P Foremost among these considerations is that an orderly, vehicular evacuation from the New 9ampshire beaches2 / 3g,pyy ,
may not be possible when the. beaches are crowded. To discount ghe serious, credible-doubt which exists about the feasibilitv 1
of an ordetly, vehiculat evacution would be grossly inptudent.
Finally, even were FEMA somehow assured that a' vehicular _
. evacuation from the New Hampshire beach areas will always proceed in an orderly fashion, in light of the evidence
- presected in the ETE portion of the NHRERP heatings FEMA an&
! the RAC must also recognize that, on summer weekends when the i
beaches are at capacity, if a fast breaking, serious accident ,
t were to occur at Seabrook Station, an evacuation of the 5 mile
- ting could noc occut tapidly. In good weather, it will take
,1 from 6:45 (App!icants) to over 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (Intervenots) to cleat !
i j the 5 mile ting from the time the first notification is given to the beach population (assuming that the beach closing ,
announcenent occuts within 25 minutes of the OTE). Applicants
? :
now contend that it will take 7:30 (7:05 plus 0:25) to cleat !
, the full EFJ under such conditions (see Attachment 1); ;
I*ntervenots' expert Dr. Adlet, has testified that this will take over 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. (See Attachment 6, p. 52.) If a sudden
]
tain occurs when the beaches are full, even the Applicants 1
2/ The Attotney General believes that the situation for Salisbuty Beacn in Massachusetts will be much worse, and that vehicular evacuation from this beach when it is nost crowded is in fact not possible, but we have not presented all the
- evidence on this point because we have been litigating only the
] NHRERP so far.
1 1
13
('
i believe that it will take a minimum of 8:10 (7:45 plus 0:25) to clear the 5 mile ting and 10:30 (10:05) plus 0:25) to clear the
. full EP:. In sum, there is simply no credible way to. describe.
ps "relatively short,' as Dr. Bores did on p. 8 of his June 1987 tevised RAC position paper, the times needed to nove all those people in the-beach areas of seabtook and Manpton Beach to coints more distant from Seabrook Station (beyond the 5 mile' ting) than they were before starting theit trips.
The Massachusetts Attorney General-strongly urges FEMA *and ,
the RAC to take this fresh important information, developed during the hearings on the NHRERP's ETE contentions, into full consideration as they proceed with their review of the 'lew Hanpshite Response.
Very ttuly yours, i t -
. y __
Allan R. Pierce Assistant Attorney General -
Nuclear Safety Unit Department of the Attorney General Commonwealth of Massachusetts _
(617) 727-2220 .
Enclosures ;
cc: Service List (letter only) l l
14 - 1 l
1