ML20151X529

Rebuttal Testimony of B Hollingworth to Applicant Direct Testimony 6 on Sheltering.* W/Certificate of Svc.Related Correspondence

ML20151X529
Person / Time
Site:	Seabrook
Issue date:	04/22/1988
From:	Hollingworth B HAMPTON FALLS, NH, HAMPTON, NH
To:
Shared Package
ML20151X317	List: ML20151X314 ML20151X445 ML20151X529 ML20151X550 ML20151X587
References
OL, NUDOCS 8805040171
Download: ML20151X529 (9)

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UNITED STATES OF AMERICA 0 s'g NUCLEAR REGULATORY COMMISSION Before the APR 251988* -6T DoCXEnNG g s ATOMIC SAFETY AND LICENSING BOARD ii ,

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April 22, 1988 In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Hos. 50-443-OL NEW HAMPSHIRE, et al, 50-444-OL

) Off-Site Emergency

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(Seabrook Station, Units 1 )

Planning and 2) )

REBUTTAL TESTIMONY OF BEVERLY HOLLINGWORTH TO APPLICANTS' DIRECT TESTIMONY NO. 6 (SHELTERINGl

• Ny name is Beverly Hollingworth and I am the New Hampshire State for District 17, representing the towns of Hampton and Representative I Hampton Falls, and have served in this capacity f or eight years.

and am a lifelong have resided in the town of Hampton for 45 years, resident of the New Hampshire Seacoast.

Formerly, I served as President and Director of the Town of and have personally visited or inspected Hampton Chamber of Commerce cottages, hotels, and motels throughout Hampton many businesses, Beach.

At present, I own a motel in Hampton Beach and have been owner or operator in the New Hampsh..re Seacoast 4

employed as a motel since 1956.

In September, 1987, Iany business owners in the Hampton Beach r area contacted me, as their state representative, to express their anger and concern that their businesses had been designated as 1

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potential public shelters in the event of an emergency at Seabrook a study prepared by Stone & Webster Engineering Station, in corporation dated August, 1987. Of approximately 100 individuals who spoke to me on this issue, not a single person was aware that their properties were designated as potential shelters until receipt of a letter from Salmon Falls, who was conducting survey research for the Commonwealth of Massachusetts on the properties identified in the Stone & Webster study. With one exception, each of these individuals requested that their property or business be removed f rom the list of potential shelters. Many of the property owners raised questions as to the legality of listing their properties as potential shelters without permission of the owners. Most of the owners additionally .

expressed the view that, in the event of an actual emergency at Seabrook Station, they would leave the beach area as soon as possible since they did not believe their businesses or homes would protect them, their families, or members of the public from radiation.

I believe that Stone & Webster's designation of potential shelters without the consent of the property owners has exacerbated the atmosphere of fear, disbelief and mistrust that pervades the beach Plant. One population concerning the Seabrook Nuclear Power consequence of circumventing discussions or failing to obtain consent of property owners will be to further discredit the reliability or believability of the owners of Seabrook Station and the New Hampshire Emergency Management Agency. Most of the residents of the Seacoast have an idea of what a radiation shelter should be, and most of the 2

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n' buildings that have been listed do not even approach their expectation of an appropriate shelter. I would, therefore, expect that any ,

instructions to "shelter" in an actual emergency would be ignored by large segments of the population.

i Following the initial communications from my constituents in september, 1987, I personally undertook to investigate a number of the properties designated as potential shelters, and spoke further with many business owners to identify more specifically their concerns.

Based upon this research, I have reached the following conclusions:

1. Certain properties identified by Stone & Webster are not designated at the correct location in that study. For example, the property identified at 31 Ashworth is the Sunset Haven rather than the .

Hollingworth Motor Court, as identified in the Stone & Webster Study.

As a further example, the property identified at 7 A Street as the Motel is in fact the Silver Wave. Similar Hollingworth misdesignations and incorrect locations are found in the Stone &

Webster Study.

2. Stone & Webster's calculations of square footage in certain m proposed shelters were inconsistent with my personal observations and overstated available space.

3. The location of certain potential shelters is virtually impossible to identify. I have lived in the New Hampshire Seacoast my or entire life and have never heard of such streets as Tilton Street in the Stone & Webster study.

Gookin Court, which are cited

4. A number of the potential public shelters, in whole or in .

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i part, are private residences, rather than the "municipal and commercial buildings" claimed by Stone & Webster.

5. Of the approximately 100 owners of designated shelters with whom I spoke, every owner, except one, was clearly opposed to having his property or business utilized as a public shelter in the event of an emergency at Seabrook and requested the property or business be stricken from the list of potential shelters. The reasons provided by the owners for this position include:

a. The owners believe that their typically unwinterized, wood frame rtructures would not provide any meaningful protection for themselves or the public from radiation.

b. Many of the proposed structures have a significant amount of exterior glass walls and windows, which the owners believe would not provide any significant protection from radiation. The owners, therefore, would not permit the public to have access to these premises.

c. Many of the rental unit owners or operators believe ,

that their paring guests, and not the general public, would have final authority to exclude the public from these buildings during a radiological emergency.

d. A number of the businesses identified as potential shelters have garage type or large exterior doors. The owners of these properties believe that, during a radiological emergency, each time such a door opens it would result in extensive additional exposure of radiation to those already inside. For this reason, many i

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of the owners have decided their premises are not safe as shelters and would not permit the public access,

e. A number of owners expressed the view that the proposed shelters are so close to Seabrook Staticn, and many are of wood frame construction and without even basic insulation, that individuals attempting to shelter in these facilities would receive as much exposure to radiation as if they remained outdoors. A number of the potential shelters identified by Stone & Webster have vents to the outdoors, holes in the outer walls, and windows, especially louvered windows, that do not properly close or that are broken. The owners, therefore, expressed the view that these properties would be essentially worthless in keeping out radiation.

6. At least 3 of the potential shelters identified by Stone &

Webster have been torn down, or have been closed by public officials as unfit for occupancy.

7. Stone & Webster appears to count utility rooms, with openings to the outside, as potential shelters. Open stairwells, such as that located in the Nautical Motel, and open spaces under buildings, such as the parking garage under the Ashworth Hotel, apparently have been counted as shelter space.

8. Certain of the basements of the potential shelters identified by Stone & Webster are often flooded. Other basements are constructed above ground, with large windows, utilized for business. Still other owners have advised me that their basements are typically filled with storage materials, including highly volatile materials. Certain other 5

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- it- I basements are also utilized as apartments or owner residences, which would be occupied during the summer months and therefore do not represent the "municipal and commercial buildings" as claimed by Stone

& Webster.  !

9. During the riots that have occurred in Hampton Beach in years ,

past, residents have locked their doors not allowing others to enter.

Many owners recently informed me that they would similarly lock their  ;

doors to members of the public, to avoid greater radiation exposure to themselves and their families.

10. Based upon my numerous communications with owners of properties and businesses designated as potential shelters, my personal observations of those facilities, and my lifetime of experience in the New Hampshire Seacoast, I believe that a substantial majority of those properties and businesses identified as potential shelters for Stone & Webster will not be available to the public for  !

shelter in the event of a radiological emergency at Seabrook Station, a .

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APR 251988*-

Doctrnuas Nr.nYc j CERTIFICATE OF SERVICE ,

Brock, one of the attorneys for the Town k[ g I, Matthew T. on April 22, 1988, I madeMOUGRAN serviceAND JEANe herein, hereby certify thatREBUTTAL TESTIMONY OF THOMAS F.

foregoing documents, GREGG LINCOLN TO APPLICANTS' DIRECTAPPLICANTS' TESTIMONY DIRECT NO. 6 (S, REBUTTAL TESTIMONY OF BEVERLY HOLLINGWORTH TOcopies thereof in the 6 (SHELTERING), by depositing (or, TESTIMONY No.

United States Mail, first class postage prepaid for delivery addressed to:

where indicated, by Express Mail, prepaid)

• Dr. Jerry Harbour

• Ivan Smith, Esq., Chairman Atomic Safety & Licensing Board Atomic Safety & Licensing Board (Off-site)

(Off-Site) U.S. Nuclear Regulatory Comm.

U.S. Nuclear Regulatory Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814

• Atomic Safety & Licensing

• Judge Gustave A. Linenberger, Jr. Appeal Board Panel Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm.

(Off-Site) Washington, DC 20555 U.S. Nuclear Regulatory Commission East West Towers Building

• Thomas Dignan, Esq.

4350 East West Highway George H. Lewald, Esq.

20814  ;

Bethesda, MD Kathryn A. Selleck, Esq.

Ropes & Gray

• Adjudicatory File 225 Frankin Street Atomic Safety & Licensing Board Boston, MA 02110 Panel Docket (2 copies)

U.S. Nuclear Regulatory Commission

• Carol S. Sneider, Esq.

East West Towers Building Stephen H. Oleskey, Esq.

4350 East West Highway Allan R. Fierce, Esq.

Bethesda, MD 20814 Department of the Atty. General One Ashburton Place Philip Ahrens, Esq. Boston, MA 02108 Assistant Attorney General Office of the Attorney General

• Diane Curran, Esq.

State House Andrea C. Ferster, Esq.

Station 6 Marmon & Weiss N.W., Suite 430 Augusta, ME 04333 2001 S Street, Washington, DC 20009-1125

• Sherwin E. Turk, Esq.

OfficeNuclear of General Counsel Regulatory Commission

• Edward A. Thomas U.S. Federal Emergency Mgst. Agency 15th Floor - One White Flint North 442 J.W. McCornack (POCH) 11555 Rockville Pike 20852 Boston, MA 07109 Rockville, MD

Philip Ahrens, Esq. Robert A. Backus, Esq.

Assistant Attorney General Backus, Meyer & Solomon Office of the Attorney General 111 Lowell Street 03105 State House, Station 6 Manchester, NH Augusta, ME 04333 Jane Doughty Mrs. Anne E. Goodman Seacoast Anti-Pollution League Board of Selectmen 5 Market Street 13-15 Newmarket Road Portsmouth, NH 03801 Durham, NH 03824 William S. Lord, Chairman Rep. Roberta C. Pevear Board of Selectman Drinkwater Road Town of Amesbury Hampton Falls, NH 03844 Town Hall, Friend Street Amesbury, MA 01913 R. Scott Hill-Whilton, Esquire H. Joseph Flynn, Esq.

Lagoulis, Clark, Hill-Whilton Office of General Counsel

& McGuire Federal Emergency Mgmt. Agency 500 C Street, S.W.

79 State Street 20472 Newburyport, MA 01950 Washington, DC Stanley W. Knowles Ashod N. Amirian, Esquiro Board of Selectmen 376 Main Street Box 710 Haverhill, MA 01830 P.O.

North Hampton, NH 03862 J.P. Nadeau, Selectman Alfred V. Sargent, Chairman Selectmen's Office Board of Selectmen Town of Salisbury 10 Central Road Salisbury, MA 01950 Rye, NH 03870 Sennter Gordon J. Humphrey Senator Gordon J. Humphrey U.S. Senate One Eagle Square, Suite 507 Washington, DC 20510 Concord, NH 03301 Tom Burack) -( Attn : Herb Boynton)

(Attn:

William Armstrong Allen Lampert Civil Defense Director Civil Defense Director 10 Front Street Town of Brentwood Exeter, NH 03833 Exeter, NH 03833 Richard A. Hampe, Esq. Gary W. Holmes, Esq.

Hampe and McNicholas Holmes and Ells 35 Pleasant Street 47 Winnacunnet Road Concord, NH 03301 Hampton, NH 03842 2

Charles P. Graham, Esq. Calvin A. Canney, City Manager Murphy & Graham City Hall 33 Low Street 126 Daniel Street Newburyport, MA 01950 Portsmouth, NH 03801 Sandra Gavutis Brentwood Board of Selectmen Town of Kensington RFD Dalton Road RFD 1, Box'1154 Brentwood, NH 03833 East Kensington, NH 03827 Robert Carrigg, Chairman Mr. Thomas H. Powers, III Board of Selectmen Town Manager Town Off3ce Town of Exater Atlantic Avenue 10 Front Street No. Hampton, NH 03862 Exeter, NH 03833 Judith H. Mizner, Esq. Beverly Hollingworth 79 State Street 209 Winnacunnet Road 2nd Floor Hampton, NH 03842 Newburyport, MA 01950 Leonard Kopelman, Esquire Barbara J. Saint Andre, Esquire Michael Santosuosso, Chairman Kopelman & Paige, P.C.

Board of Selectmen 77 Franklin Street Jewell Street, RFD 2 Boston, MA 02110 So. Hampton, NH 03827 D- -

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Matthew T. Brock

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