ML20153E948
| ML20153E948 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/21/1986 |
| From: | Shotwell J MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-170 OL, NUDOCS 8602250211 | |
| Download: ML20153E948 (7) | |
Text
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o 000KE'TED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '86 FEB 24 All :43 0FFICE U in .-
00CKETiw 4 LWii ATOMIC SAFETY AND LICENSING BOARD BRANCH Before Administrative Judges:
Helen F. Hoyt, Chairperson Emmeth A. Luebke Jerry Harbour
)
In the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL PUBLIC SERVICE COMPANY OF )
NEW HAMPSHIRE, et al. )
(Seabrook Station, Units 1 )
and 2) ) February 21, 1986
)
CONTENTION OF ATTORNEY GENERAL FRANCIS X. BELLOTTI RELATIVE TO EMERGENCY PLANNING FOR THE NEW HAMPSHIRE BEACH COMMUNITIES By Order dated January 17, 1986, the Board provided all parties an opportunity to file new contentions on redrafted i emergency plans submitted to FEMA by the State of New l Hampshire. We have reviewed the new plans and find that they ,
1 in no way address or alleviate the concerns which prompted our earlier contention (a copy of which is attached hereto as Exhibit A) regarding the adequacy of emergency planning for Massachusetts citizens present in the New Hampshire beach communities within the EPZ at the time of an emergency. Thus, 8602250211gg@$$443 PDR ADOCK PDR G
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the new plans continue to rely on evacuation and sheltering as the two possible protective actions in the event of a serious accident. See N.H. RERP, at 2.6-5. However, the plans have in no way developed the option of sheltering for the beach populations despite the severe limitations, discussed in Exhibit A hereto,,on evacuation as a protective response for_
those persons.1/
Uhile the Board's Order did not appear to require this we are, in an excess of caution, hereby refiling our earlier contention. Developments since our earlier filing provide additional bases for our contention and will be thoroughly addressed in our testimony. For example, the Applicants' own Probabilistic Safety Assessment contains release sequences which support the need for additional protective measures for the beach area populations. And, as FEMA personnel have 1/ The New Hampshire plan is hopelessly confusing on the question of sheltering for the beach populations, indicating on the one hand that "(s]heltering may not be consicered as a protective action on the seacoast beaches during the summer" and on the other hand that "[t]ransients without access to suitable shelters will be directed . . ., if possible, to seek directions to a nearby public building from local emergency workers." See N.H. RERP, at 2.6-8. Suffice it to say it remains the case, as we stated in the bases for our contention, that Neither the New Hampshire Radiological Emergency Response Plan nor the local community plans contain any analysis of available public sheltering, or its capacity to accomodate the beach populations or to provide sheltering from radionuclides, or any plans for effecting such sheltering. In short, there is at present no basis for (and has not been) any development of sheltering as a potential protective action for the beach population.
I Exhibit A, at 12-13.
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determined, the revised New Hampshire plans fail'to demonstrate that the New Hampshire EPZ communities have sufficient personnel and resources (including communications equipment)'to implement the plansSI or that'certain of the communities (including Ryed! and Hampton,A! two of the coastal towns) even intend to ipplement the plans. See Exhibit C hereto, a_
document prepared by FEMA personnel in response to these latest New Hampshire plans and entitled " Planning Milestones.")1!
In short, there continues to be no " reasonable assurance that adequate protective measures can and will be taken" to protect Massachusetts citizens on New Hampshire beaches at the time of an accident, as required by 10 C.F.R. S 50.47(a)(1).
2/ The plans contain no letters of agreement assuring the provision of necessary resources.
3/ According to pleadings filed with this Board by the Town of Rye, that Town has not even reviewed the plan submitted for it
, by the State of New Hampshire and is not committed at this time to implementing any such plan. For these reasons the Town of Rye has informed FEMA that it will not participate-in an upcoming exercise of the plans and has thus far refused to authorize the installation of sirens necessary to alert the public, and-particularly the beach population, in the event of an accident.
4/ On October 29, 1985, the Hampton Board of Selectmen wrote Governor Sununu (see Exhibit B hereto) indicating, inter alia, that all Town departments lack sufficient manpower to implement the plan.
5/ FEMA notes the need for contingency plans from the State of New Hampshire to cover any communities where the local governments are not committed to' implementing _ plans and specifically criticizes the plans for their failure to address the beach populations.
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n For this reason we respectfully urge the Board's acceptance of our prior Contention attached hereto as Exhibit A.
Respectfully submitted, ATTORNEY GENERAL FRANCIS X. BELLOTTI
( , '_ ,
)
By: ~A _ _ : _ - (nk p Jo Knn Shotwell V' As/is ant Attorney General En ronmental Protection Division Department of the Attorney General One Ashburton Place, Room 1902 Boston, MA 02108 (617) 727-2265 DATED: February 21, 1986
^
o i = EXHIBIT "A" c e J
b, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
4 l
- Helen F. Hoyt, Chairperson Emmeth A. Luebke Jerry Harbour i
J
)
In the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL PUBLIC SERVICE COMPANY OF )
NEW HAMPSHIRE, et al. )
(Seabrook Station, Units 1 )
and 2) ) September 9, 1983 I .
J CONTENTION OF ATTORNEY GENERAL FRANCIS X. BELLOTTI RELATIVE TO EMERGENCY PLANNING FOR THE NEW HAMPSHIRE BEACH COMMUNITIES On August 23, 1983, the Board ordered that contentions relating to off-site emergency planning for any or all of the fifteen New Hampshire communities for which draft emergency plans were recently submitted1/ be filed on or before this date. In accordance with that order, Attorney General Bellotti hereby submits a single contention which relates to off-site 1/ The fifteen communities are Hampton, Newton, Rye, Stratham, Exeter, New Castle, North Hampton, Seabrook, Brentwood, Kensington, Newfields, Portsmouth, South Hampton, East i
Kingston, and Kingston.
4MtBh5r T1 pg.
emergency action in the coastal beach areas of Seabrook, Hampton, North Hampton, and Rye which are frequented by Massachusetts citizens.
CONTENTION:
The draft hradiological emergency response plans for the Towns of Seabrook, Hampton, North Hampton, and Rye do not
- provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at the Seabrook Station, as required by 10 C.F.R. 550.47(a)(1),
because in the e, vent of a severe accident on a summer weekend
! some or all of the beach area transient populations within those communities cannot under many plausible meteorological l conditions be protected by means of evacuation even from early death and because there are not adequate plans or provisions for sheltering the beach area transients within those j communities.
BASES:
The draft emergency response plans for the Towns of i
Seabrook, Hampton, North Hampton, and Rye all rely on evacuation and sheltering as the two options for protecting J
persons present in those communities at the time of a 1
i radiological emergency at Seabrook Station which results in a radiological release to areas within those communities. See, l e.g., Seabrook Plan, at II-I6 - II-I8; Rye Plan, at II-I6 -
! II-I8; North Hampton Plan, at II-I7 - II-20; and Hampton Plan, i
m at II-I7 - II-20.
However, a preliminary site-specific accident consequence analysis performed for the Massachusetts Attorney General has revealed that, given the unusual circumstances associated with dense beach populations, evacuation cannot protect the transient beach area populations '
in the vicinity of the Seabrook site from early death in the event of a PWR 2 release as defined in the NRC's Reactor Safety Study (WASH-1400) v. a summer weekend.
A Seabrook-specific accident consequence analysis is being performed for the Department of the Attorney General by Dr. Jan Beyea, a nuclear physicist with extensive experience in accident consequence modelling and analysis. (A copy of Dr.
4 Beyea's resume is attached hereto as Exhi. bit A and incorporated herein by reference.) Dr. Beyea has advised the Department
' that there are unique considerations involved in the modelling j
and analysis of accident consequences for a site such as Seabrook having a large summer beach area population which have never before been taken into account in generic or 4
site-specific consequence studies. In addition to the obvious effects on accident consequences of the increased population
- and evacuation times associated with summer beach areas and the absence of shielding normally provided by buildings, there are increased consequences due to material deposited directly on the skin and hair of beachgoers and on vehicles in the plume.
The former factor has received no consideration in accident
, - - ., - - , . , --r- - y
e consequence analyses in the past and the latter has received inadequate consideration.
In the work which Dr. Beyea and his assistant Brian Palenik, a graduate student at the Massachusetts Institute of Technology, have performed for this Department to date they have investigated the conditions under which the nearest beach population to this site, at about two miles, might be exposed to doses at a threshold level for early death (200 rem) in the event of a PWR 2 release as defined in the Reactor Safety Study 4
i (WASH-1400). Estimates of the time within which that population would receive a 200 rem dose have been calculated for various weather stability classes and wind speeds using two sets of assumptions. The first set assumes that all persons are inside automobiles when the release occurs and receive only a fraction of the doses they would receive if they.were in the open, exposed directly to a plane of contaminated ground.
These results have been calculated using the assumptions which have heretofore been considered standard in accident consequence calculations. The second set of results goes beyond the standard assumptions, to account specifically for the Seabrook beach situation. Those results assume that some of the population will not have reached their vehicles before plume passage such that there will be a " skin deposition dose" and a " car deposition dose." For each of the two sets of results calculations have been performed separately for high
S and low energy release rates. This division was necessary given the large uncertainty in the height to which the radioactive plume will rise, a factor which is affected by energy. release rates and which is an important determinant of the doses to a nearby population.
Tables 1 and 2, which follow hereafter, contain the results of Dr. Beyea's modelling and analysis as described above. The entries in the last column of each table result from a i
comparison between the time required to reach a 200 rem dose and current estimates of the time-required to evacuate the population within two miles on a summer weekend. See Table 3.
The data set forth in these tables reveal that the summer weekend beach population within two miles of the Seabrook site cannot be protected from early death by means of evacuation under many weather conditions.
It should be noted that neither precipitation nor slow wind speeds have been considered in the analyses set forth in Tables ,
1 and 2. Both such conditions are more severe than those represented in the tables. The frequencies of the Pasquill stability classes reflected in Tables 1 and 2 as reported in the Applicants' ER-OL are given in Table 4. The frequencies of the A, B, and C stability classes increase during the summet months, with C the most frequent of the three. D and E are the
. dominant stability classes. The results discussed herein are not, therefore, based on infrequently occurring or worst-case weather. conditions.
TABLE 1 PROTECTION OF CLOSEST BEACH POPULATIONa)
FROM EARLY DEATH ON A SUMMER WEEKEND DAY HIGH ENERGY RELEASE RATE DI Dose Stabilityc) Wind Speed Scaling d) -Time to Reach Protection *I Class (m/sec) Factor 200 rem of Population A 2 .53 .78 14.5-20.9 Yes A 2 1.0-1.3 9.0-11.5 Yes A 4 .53 .78 )> 24 Yes A 4 1.0-1.3 19.2-25.0 Yes 2 .53 .78 4.6-6.4 No B
B 2 1.0-1.3 3.2-3.8 No B 4 .53 .78 12.2-17.8 Yes B 4 1.0-1.3 7.6-9.6 Yes C 2 .53 .78 2.6-3.4 No 1
C 2 1.0-1.3 1.9-2,2 No C 4 .53 .78 8-11.5 Yes C 4 1.0-1.3 5.1-6.4 No D 2 .53 .78 )> 2 4 Yes 2 1.0-1.3 Yes D )) 24 D 4 .53 .78 6.5-9.2 Yes D 4 1.0-1.3 4.2-5.3 No a) The population two miles from tne plant.
b) Assumes an energy' release rate of 176 x 10 6 Btu / hour.
c) Pasquill stability class.
d) The dose scaling factor range of .53 .78 assumes an individual is in a
,! car within the plume. The dose scaling factor range of 1.0-1.3 assumes an individual _is in a car within the plume, with a dose component from radioactive material deposited on the car and directly.on the individual.
e) Protection of the population from a 200 rem-dose or higher. This assumes an evacuation time'of about five and a half hours. If the evacuation time is longer, the population is not necessarily protected.
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TABLE 2 PROTECTION OF CLOSEST BEACH POPULATION"I PROM EARLY DEATH ON A SUMMER WEEKEND DAY D)
- LOW ENERGY RELEASE RATE Dose Scaling d) Time to Reach Protection e) stability c) Wind Speed of Population?
(m/sec) Factor 200 rem Class
.53 .78 13.8-19.9 Yes A 2 1.0-1.3 8.6-10.9 Yes A 2
.53 .78 Yes A 4 )> 24 1.0-1.3 18.4-23.7 Yes A 4
.53 .78 3.7-4.9 No B 2 1.0-1.3 2.5-3.0 No B 2
.53 .78 9.9-14.2 Yes a 4 1.0-1.3 6.2-7.8 Yes B 4
.53 .78 ZL1 No C 2 1.0-1.3 No C 2 <[1
.53 .78 1.7-2.2 No C 4 1.0-1.3 1.3-1.5 No C 4
.53 .78 <[ 1 No D 2 No D 2 1.0-1.3 <[ 1
.53 .78 <(1 No D 4 No D 4 1.0-1.3 <[1 a) The population two miles from the plant.
b) Assumes an energy release rate of 20 x 10 6 Btu / hour, or an equivalently .ow plume for reasons unrelated to the energ*/ release rate.
c) Pasquill stability class.
d) The dose scaliitg factor range of .53 .78 assumes ar individual is in a car within tne plume. The dose scaling factor range of 1.0-1.3 assumes an individual is in a car within the plume, with a dose component from ;
radioactive material deposited on the car and directly on the individual.
c) Protection of the population from a 200 rem dose or higher. This assumes an evacuation time of about five and a half hours. If the evacuation time is longer, the population is not necessarily protected.
TABLE 3 8)
SEABROOK EVACUATION CLEAR TIME ESTIMATES SUMMER WEEKEND / FAIR WEATHER SCENARIO HMMD ) Vorheesc ) Maguired) .NRCe)
Radius Degrees 360* 4:50 5:10 5:40 ---
0-2 0-3 180* E 5:20 ---
0-5 360* 5:50 5:10-5:40 ---
360* 6:05 5:10-6:10 5:50 11:25 0-10 a) Time (hours: minutes) for the population to clear the indicated area after notification.
b) Preliminary Evacuation Clear Time Estimates for Areas Near Seabrook Station, HMM Document No. C-80-024A, HMM Associates, Inc., May 20, 1980.
c) Final Report, Estimate of Evacuation Times, Alan M. Vorhees & Associates, July 1980.
C.E. Maguire, d) Emergency Planning Zone Evacuation Clear Time Estimates, Inc., February 1983.
e) An Independent Assessment of Evacuation Time Estimates for a Peak Population Scenario in the Emergency Planning Zone of the Seabrook Nuclear Power Station, M.P. Mueller, et al., Pacific Northwest Laboratory NUREG/CR-2903, PNL-4290.
TABLE 4 1
20 '
FREQUENCY OF PASQUILL STABILITY CLASSES AT SEABROOK (Values in % of Time)
B C D E F G Month A 1.27 2.11 3.80 49.65 29.40 7.88 5.91 Apr 1979 May 1.20 2.86 4.82 52.86 26.51 5.27 6.48
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2.92 6.69 12.26 39.83 25.49 6.13 6.69 June 4.90 6.94 11.56 29.12 28.84 12.65 5.99 July 2.91 4.71 9.97 43.07 26.59 7.34 5.40 Aug 1.25 7.64 11.81 30.69 27.36 10.83 10.42 Sep i Oct 0.81 2.96 5.79 39.30 34.05 10.09 7.00 0.00 0.56 4.76 43.92 34.83 9.37 6.57 Nov 0.00 0.41 2.70 47.03 41.35 5.81 2.70 Dec 1.88 6.59 51.88 30.38 5.78 3.36 Jan 1980 0.13 0.44 2.03 5.37 50.36 34.69 5.66 1.45 Feb 10.68 1.64 5.34 43.15 24.66 6.03 8.49 j Mar 2.22 3.37 7.08 43.31 30.38 7.76 5.87 Yearly t
Period of Record: April 1979 - MarchSource:
1980. SB Stability class calculated a) 1&2, ER-OLS, Table 2.3-24.
l using 43'-209' delta temperature.
i i
The size of the beach area population around Seabrook is uncertain. One estimate of this population for 1980 has been made by Public Service Company of New Hampshire and is found in Table 5. Although its accuracy is uncertain, this estimate does indicate that a substantial number of people are located withintwomiNesoftheplant. The number of persons that would be located within a plume obviously varies with wind direction, but it also varies with stability class and distance from the plant. At two miles the plume could be viewed as being between a 29' wedge (A stability class) and a 13' wedge (D stability class) ! compared to the 22.5# population wedges in the table.
In addition to investigating the conditions under which the beach population within two miles of the Seabrook site might be exposed to early death doses, Dr. Beyea and Mr. Palenik have commenced work designed to determine the radius within which early deaths might result in the vicinity of this site assuming an accidental release on a summer weekend. Dr. Beyea has found early death radii ranging from <C2 to 4.3 miles assuming a PWR 2 release as defined in the Reactor Safety Study (WASH-1400), C stability class weather conditions, an evacuation time of 5-1/2 hours, and the two sets of dose scaling factors discussed previously. For weather conditions with overcast skies (D 2/ Wedges are assumed to have plume widths equal to three times the horizontal dispersion coefficient.
4 f
TABLE 5 a) BY SECTOR D) 1980 BEACH AREA TRANSIENT POPULATION ESTIMATE Ring Radii SSE ENE E ESE SE (miles) NE 0 0 0 0 0-1 0 0 1-2 464 14,647 12,780 5,842 129' 23 8,882 0 0 3,905 654 2-3 1,104 608 0 0 0 6,198 3 8,710 0 0 0 0 8,880 4-5 4,344 0 0 0 0 16,597 5-10 5,660 Source: Public Service of New Hampshire, Seabrook Station - Units 1 & 2, Environmental Report, Operating License Stage, Figure 2.1-19.
i a) Estimate of peak transient population found by multiplying the capacity of beach area parking lots (less leased space) by 3.2 persons per vehicle, and contributions from off-street parking users, seasonal residents, and overnight visitors.
b) Each direction in the table is the centerline of a 22.5 degree wedge.
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stability class), or longer evacuation times,3/ the early death radii will be. larger. And the time before. doses reach 200 rem, assuming.a PWR 2 release on a summer weekend evening and a low energy release rate such as that assumed in the draft Seabrook Probabilistic Risk Assessment, is less than four hours
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out to 6-7 miles from the site. Thus, the beach area population within 6-7 miles exposed to the plume would not be protected from early death even if there were a 20-30 percent reductior. in evacuation times from daytime to evening. It should be noted in this connection that at least the Hampton Beach area has a very substantial nighttime population.
l Thus, primary accident consequence data developed for this .
Department reveal that evacuation cannot under a number of plausible weather conditions protect the summer weekend beach area populations in the vicinity of this site from even early death. The results described herein do not account for the less severe consequences of radiation illness and delayed fatalities due to latent cancers. Despite the severe limitations on the utility of evacuation as a protective option for the transient beach population, however, there are currently no provisions for sheltering that population within l
the EPZ. Neither the New Hampshire Radiological Emergency 3/ The Applicants have now provided a 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 5 minutes estimate for summer weekend simultaneous beach evacuation within ten miles of the site. See Applicants' Direct Testimony No. 1, filed July 15, 1983, at 19-20.
Response Plan nor the local community plans contain any analysis of available public sheltering, or its capacity to accommodate the beach populations or to provide shielding from radionuclides, or any plans for effecting such sheltering. In short, there is at present no basis for (and has not been) any .
4 development of sheltering as a potential protective action for the beach population.
Respectfully submitted, FRANCIS X. BELLOTTI ATTORNEY GENERAL Dy: - - - -
JO SHOTWELL As ant Attorney General En onmental Protection Division One Ashburton Place Boston,i1A 02108 (617) 727-2265 k________________________________________________.
"EXHIDIT A" April 1983 EDUCATION:
Ph.D., Columbia University, 1968 (Nuclear Physics)
B. A., Amherst College,1962 EMPLOYMENT HISTORY: ,
1980 to date, Senior Energy Scientist, National Audubon Society, 950 Third Avenue, New York, New York 10022.
1976 to 1980, Research Staff, Center for Energy and Environmental Studies, Princeton University.
1970 to 1976,' Assistant Professor of Physics, Holy Cross College.^
1968 to 1970, Research Associate, Columbia University Physics Cepartment.
CONSULTING WORK:
. Consultant on nuclear energy to the Office of Technology Assessment, the New Jersey Department of Environmental Protection; the Offices of the Attorney General in New (ork State and the Correnwealth of Massachusetts; the state of lower Saxony in West Germany; the Swedish Energy Commission; and various citizens' groups in the United States.
PUBLICATIONS CONCERNING ENERGY CONSERVATION AND ENERGY POLICY:
" Comments en Energy Forecasting," material submitted for the record at .
the Hearings before the Subccnmittee on Investigatiens and Oversights of the Cormittee on Science and Tecnnology, U. S. House of Pepresentatives; Cormittee Print, June 1, 2, 1981 L No. 14 _f.
'The Audubon Energy Flan Technical Report," Peterson, Beyea, Paulson and Cutler, National Audubon Society, April 1981.
" Locating and Eliminating Obscure but Major Ener;j Losses in Residential H:using." Harrje, Dutt and Beyea, ASF;;E Transactions, 85, Fart II (1979).
Winner of ASHRAE outstanding paper award.)
" attic Feat Loss and Conservation Policy," Cutt, Beyea, Sinden. ASME Tecnnology and Society Division paper 78-TS-5, Hosston. Texas,1978.
" Comments on the proposed FTC trade regulation rule on laceling and adver-tising of thermal insulation," Jan Beyea and Gautai Dutt, testimony before the Federal Trade Commission, January 1978.
" Critical Significance of Attics and Baserents ir. the Energy Balance of Twin Rivers Townhouses," Bejea, Dutt, hoteki, Enerce and Buildings, Volume I (1977), Page 261. Also Chapter 3 of Saving Enercy in tne Home, Ballinger,1978.
"The Two-Resistance Model for Attic Heat Flow: helications for Conservation Policy," Woteki, Dutt, Beyea, Energy--the International Journal, 3, 657 (1978).
" Energy Conservation in an Old 3-Story Apartment Complex," Beyea, Harrje, Sinden Energy Use Management, Fazzolare and Smith, Pergamon 1977, Volume 1 Page 373.
" Load Shif ting Techniques Using Hoire Appliances," Jan Beyea, Robert Weatherwax, Energy Use Managenent, Fazzolare and Smith, Pergamon 1978, Voluine !!!/ly, Page 121.
PUBLICATIONS CONCERNING ENERGY RISKS:
- Articles:_
" Containment of a Reactor Meltdown," (with Frank von Hippel).
Bulletin of the Atomic, Scientists, 38, Page 52, December 1982.
"Second Thoughts (about Nuclear Safety)," in Nuclear Power: Both Sides, W. W. Norton and Co. (New York, 1982).
" Indoor Air Pollution," Commentary in the Bulletin of the Atomic Scientists, 37_, Page 63, February 1981.
"Er.ergency Planning for Reactor Accidents " Bulletin of the Atomic Scientists, 36, Page 40 December 1980. (An earlier version of this article appeared in German as Chapter 3 in Im Ernstfall hilflos?, E. R. Koch, Fritz Vahrenholt, editors, Kiepenheuer & Witsch, Cologne,1980.)
[. " Dispute at Indian Point." Bulletin of the Atomic Scientists, 35, Page 63, I May 1980.
I Published Deoates:
ine Crisis of Nuclear Enercy, Subject No. 367 on Williar Buckley's Firing Line, P.B.S. Television. Transcript printed by Southern Educational Communications -
Association, 928 Wcodrow Street, P. O. Box 5966, Columbia, 'Shuth Carolina,1979.
ju_clearReactors: Hoa Safe Are They?, panel ciscussion sponsored by the Acacerj Forum of The National Academy of Sciences, 2'.01 Constitution Avenue, Wasnington, 3. C. 20418, May 5, 1980.
Reports:
"I plicatiers for Mortality of "eakening tne Clean Air Act," (with G. Steve Jordan), Naticnal Audubon Society Environrental Policy Analysis Cepartment Report No.18 May 1982.
"Some Long-Term Consequences of Pypothetical Major Releases of Radioactivity to the atmospnere from Three Mile Island," Report to the President's Council on i Environmental Guality, Decetter 1980.
. " Decontamination cf Krypton 85 from Three Mile Island Nuclear Plant," (with Kendall, et.al.), Report of the Union of Concerred Scientists to the l
Governor of Pennsylvania, Ma/ 15, 1980.
"Some Comnents on Consequences of Hycothetical Peactor Accidents at
! the Philippines Nuclear Power Plant" (with Gcrdon Thompson), National Audubon Society,
) Environmental Policy Analysis Department Report No. 3, April 1980.
" Nuclear Reactor Accidents: The Value of Improved Containment," (with Frank von Hippel) Center for Energy and Environmental Studies Report PU/ CEES 94, Princeton University, January 1980.
"The Effects of Releases to the Atmosphere of Radioactivity from Hypothetical Large-Scale Accidents at the Proposed Gorleben Waste Treatment Facility," report to the Governnent of lower Saxony, Federal Republic of Germany, as part of the "Gorleben International Review," February 1979.
I Reports (Cont'd.):
" Reactor Safety Research at the large Consequence End of the Risk Spectrum "
presented to the Experts' Meeting on Reactor Safety Research in the Federal Republic of Germany, Bonn, September 1,1978.
s,e A Study of Some of the Consequences of Hypothetical Reactor Accidents at Barseback, report to the Swedish Energy Commission Stockholm, 05 1 1978:5, January 1978.
Testimony:
j
- 1 i
"Some Consequences of Catastrophic Accidents at Indian Point and Their Irnplications for Emergency Planning," testimony and cross-examination before the i
Nuclear Regulatory Com.iission's Atomic Safety and Licensing Board, on behalf of i the'New York State Attorney General and others, July 1982.
"In the Matter of Application of Orange and Rockland Counties, Inc. for Conversion to Coal of Lovett Units 4 and 5," testimony and cross-examination on the health impacts of eliminating scrubbers as a requirement for conversion to
- coal; Department of Environmental Resources, State of New York, November 5,1981.
" Future Prospects for Con ercial Nuclear Power in the United States," before i tne Subcomr.ittee on Oversight and Investigations, Conr.ittee on Interior and
- Insular Affairs, U. S. House of Representatives, October 23, 1981. >
i " Stockpiling of Potassiu- Iodide for the General Public as a Condition for j Restart of TM1 Unit *.o.1 " testimony and cross-exa inatien before the Atomic Safety and Licensing Board on tehalf of the Anti-f.; clear Group Representing i iork, April 1931.
I j "~dvice and Recon encations Concerning Changes in Reactor Design and Safety 3
Analysis which should be Recuired in Light of the Accide'it at Three Mile Island,"
i staterent to the Nuclear Regulatory Cortrission ccncerning the proposed rulemaking 1 hearin) on degraced cores. December 29, 1980.
I j ' Alternatives to the Indian Point Nuclear Reacto"S." Statement before the
- ' Environ ental Protection Comittee of the New iork City Council, December 14, 1979.
Also before the Comittee, "The Impact on f.ew York City of Reactor Accidents at
- Indian Point," June 11, 1979 Also " Consequences of a Catastrophic Reactor
) Accident," statement to the New York City Board of Healtn, August 12, 1976 (with Frank von Hippel).
" Emergency Planning for a Catastrornic Reactor Accident," Testimony before the California Energy Resources and Developnent Co:" mission, bergency Response and Evacuation Plans Hearings, November 4,1973, Page 171.
"Short-Term Effects of Catastrophic Accidents on Comunities Surrounding the Sundesert Nuclear Installation," testimony before the California Energy Resources and Development Commission December 3,1976.
" Consequences of Catastrophic Accidents at Jamesport." Tes timony before the New York State Board on Electric Generation Siting and the Environment in the Matter of Long Island Lighting Company (Jamesport Nuclear Power Station, Units 1 and 2), May 1977.
i i
-__l--_--.__--__---_----___--___._--__.---__-_-_____-____.__--_--___-____-_-__
o
- 4-4 Miscellaneous:
" Consents on WASH-1400," Statement to the Subconnittee on Energy and the Environment, Oversight Hearings on Reactor Safety, June 11, 1976, Serial No. 94-61, a Page 210.
" Upper Limit Calculations of Deaths from Nuclear Reactors," Bull. Am. Phyt.
Soc. 21. III (1976). ,
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- EXHIBIT "B" PLANNING MILESTONES SSBR&SBBESSES333333 New Hampshire
- 1. We have not received a compiete submission of New Hampshire P1ans. We understand that work is being completed on these sections:
- Letters of Agregment, including those referenced in appendix C of the local plans.' These letters, particularly for transportation, -
are necessary so we will know what facilities we will visit as part of the exercise. We need your proposal as to how you propose to demonstrate your exercise objectives so we can formul ate our observer strategy.
- Evacuation Time Estimate. We understand from reading the progress reports the updated ETE will require greatly increase personnel resources to staff traffic control posts.
- A & N Design Report, as referenced in state and local pl ans .
- needed to determine if local resources and training are sufficient to carry out all functions which may be assigned.
- 2. The pl ans do not show sufficient personnel resources at the local l evel s:
- personnel for emergency positions.
- provide for transit dependent populations as stated in the plan.
- proper number of dosimeters for the emergency workers.
- 3. Contingency P1ans
- With respect to an exercise, we were informed that the following communities are not going to participate:
- Rye
- South Hampton
- Hampton Falls
- Hampton (possibly)
- We do not have contingency plans from the State of New Hampshire which show what they plan to do in the event that local government (s) does not perform the required emergency functions in the event of an accident at Seabrook 4 The plans for those towns with a beach population and some state agencies procedures need to be revised to reflect their recponsibil-ities to assist in protecting that population in the event of en accident.
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- 5. Local Plans are not specific as to how they will meet the needs of the transit dependent population, including mobility-impaired and institu-tional populations, such as hospitals and nursing homes. We, therefore, cannot evaluate the plans. We are also concerned that the local plans are excessively cumbersome as designed.
- 6. Actual installation of at least minimum communications equipment.
- 1. Formal submission of plans from Massachusetts.
MXHIBIT "C"
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'86 J?N 21 p4 ;;9 350/S ]lnniversary &":'C.'
1638 - 1988 Januaty 16, 1986
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. . . . . . . ..._&',_0 , Q l EO - W Y dL Henry G. Vickers, Regional Director Federal Emergency Management Agency Region I, J. W. McCormack Post Office 5 Court House , J O t? $06 Boston, MA. 02109
Dear Mr. Vickers:
The Hampton Board of Selectmen has requested in a separate letter that any public hearings held by your agency be held in the Seacoast area.
The Emergence) Evacuation Plans for the Seabrook Power Station were foruuraea zo ucur aaency uiithout the acceovat of the Hampton Board.
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On a 3-1 \I absent) vote, a Ketter pointing out weaknesses in the plans aus sent to Governor Sununu and Richard Strome, the State Civil Defense Directot, on October 29, 1985. No response was received until December 2nd and no changes in the plans are made then; the repitj aus simply that our concerns were not valid. We understand that the plans were forwatded to FEMA on December 9th, hardlij leaving tjour board tbne for further response.
We also understand that the plans were foruarded bij FEMA to the NRC on ,
Januaty 8th, as reviewed bat not approved. The Tcwn is vert) concerned as to uhat this transmittal means in terms of our being able to re-port to our citizens that at have worked to get the best evacuation plan possible.
As the plans were sent without local board's approval, we feel that they should be returned for further work and not submitted until local communities think that they are. workable.
Sincetelt),
,./FyRTHEBOAR0CFSELECTMEN
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' John R. Walker ORJ/cb l, Chairnun overnot Sununu; letter from Governor Sununu; and Eness Copies of letteA letterfromDirectorStrome 136CCs Idinnacunnel U.S. Nuclear Toad Rega (][a btorij commissionlon, Olew ][ampsSire 03342 Jef
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330/S ]nniversary 1636 - 1968 N ll-l ~~
October 29, 1985
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Honorable John Sununu ^ ". . '
Governor *s 0ffice U$ kYY' bL '
State House Concord, New Hampshire 03301
Dear Governot Sununu:
The undersigned members of the Hampton Board of Selectmen wish to state their reservations about the adequacy of de Radiological Emergency Response Plan. These rese.vations were publicly presented at a meeting of the Board on October 3, I985, a meeting scheduled between new members of'the Board and local department heads, but dich a s attended by officials from New Hampshire Civil Defense.
Our original questions about the plan concerned population estimates.
We understand that the figure of 85,000 peak population has been revised to 110,000, a move in ue. right direction but still lower than traf fic counts and local business figures indicate. Perhaps our best comment on the population figures is that they can only be an estimate and Gey will vary widely from day to day, especially on sunner weekends.
Other problems remain. Very serious are the estimates of de number of personnel required to effect an orderly
- evacuation. Each ol ouq - '
deavttunent heads agmd that he lachs sulticient mann~ci to cannu out _the -
plan, but each has been in!d in umst additional help from the State.
Such advice appears to have been given to each town in the zone; obvictisfy there will not be enough workers to 90 around. As a collary to the numbers required, d ere are no provisions for securitu lor workers' homes and families nor does there seem to be provision for specialized equipment other than dosimeters. It is unclear if he count on dosimeters is a State tot,al or a town by town total, as our radiological .
of ficer said that he could obtain all ue equipment needed in a matter of a few hours. Is more protective apparatus, mch as suits or gloves or breathing apparatus, needed?
Another serious consideration is the lack of communication and coordination in moving school children out of the area. On October 3 the statement as made dat Civil Defense is working with school of ficials;
~ 136 I)innacunnel 'Euad( hmplon, Yeas hmpsSite 03HZ .7el 603-926-6766
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' October 29, 1985 Honorable John Sununu .
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i our ' local superintendent had received a copy of the plan the previous day.
There are many problems; number of buses available (for 16 towns), ..
availability of sufficient bhs drivers, traffic problems caused by ".
parents trying to get to schools to pick up their own children, formal l signed agreements with bus companies. An added problem with buses is
- j the number of non-auto owning residents uho would need transportation,
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and vacationers who are at be beach without automobiles.
There seem to be severe inconsistencies in de amount of unrning time availabk 'to accomplish evacuation. Can connunities rely on the 18-hour figure that was presented in August as the time we would have to act? The maximum figure given to move d e population out (7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />
'and 40 minutes) is given for a sunner population on a bad weather day; may we suggest that a sunner population on a very hot Sunday is likely to be larger and pose potentially more traffic problems, bou with cuerheated cars and tempers?
We are not qualified to connent on the adequacy of most buildings on Hampton Beach for sheltering, if that should be the preferred action.
Howver, the plan completely ignores that there may be thousands of beach goers clad only in bathing suits during a radiological accident.
Last and vitally ixportant is the problem of roads leading out of Hampton. The Church Street access to Route 51 and thence to Route 101 is inadequate for d e " normal" non-panicked population. Route I is already cuer-loaded with daily winter traffic. All towns in the area will rely on these routes to get to 1-95; it simply cannot be done safetyorquickly. Nuclear plant owners and regulators have known for over six years that evacuation plans would be necessary; during dat time no seriouswork has been done on Seacoast roads nor do there seem to be plans to improve these roads significantly.
In conclusion, this plan seems to be written prinarily to justify the requirement that a plan exist rather than to make a serious attempt to evacuate an endangered citizenery. We have touched on what seem to us to be primary and basic weaknesses. Added to dese is the general distrust of our citizens towards the owners of the plant, occasioned by inconsistencies between promises made and results delivered during the construction process.
We would respectfully urge that you consider not approving this plan; but it yerr must, that you dn with the understanding that uou are opposing the recommendation of the maiority of the Hampton Rnand n f:
SeCectmse Thank you foryourconsideration.
Very sincerely, cc: ' Richard Strome Gerarld Coogan William Cahilt ,fb.. .L, A . 6. -
\ JcTtn R. Walker
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Robert Preston A a T 's l ELIO bO &
Ansell W. Palmer
~m AWA. 0 hr.cM J Oona R. Janetbs f
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UNITED STATES OF AME NUCLEAR REGULATORY COMM ,E In the Matter of T RB 24 ml 43 PUBLIC SERVICE COMPANY OF NEW ) Docket No.(s) 50-433/444-OL HAMPSHIRE, ET AL. OffjCE U: ..
(Seabrook Station, Units 1 and 2) 00gMElj.,- I.n m,
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CERTIFICATE OF SERVICE I Jo Ann Shotwell heteby certify that on February 21, 1986 I made service of the within document by mailing copies thereof, postage prepaid, to:
' Administrative Judge br. Emmeth A. Luebke Helen Hoyt, Chairperson Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 jfDr.JerryHarbour h hobert G. Perlis, Esq.
Atomic Safety & Licensing Board Sherwin E. Turk, Esq.
U.S. Nuclear Regulatory Office of the Executive Legal Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
)lkdosephFlynn, Esq. MkStephenE. Merrill, Esq. j Assistant General Counsel Attorney General Office of General Counsel George Dana Bisbee, Esq.
Federal Emergency Management Assistant Attorney General Agency Office of the Attorney General 500 C Street, S.W. 25 Capitol Street Washington, D.C. 20472 Concord, NH 03301 4hbocketing and Service Paul A. Fritzsche, Esq.
U.S. Nuclear Regulatory Office of the Public Advocate Commission State House Station 112 Washington, D.C. 20555 Augusta, Maine 04333
$h BY EXPRESS MAIL
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o Roberta C. Pevear Ms. Diana P. Randall State Representative 70 Collins Street Town of Hampton Falls Seabrook, New Hampshire 03874 Drinkwater Road Hampton Falls, NH 03844 Atomic Safety & Licensing Robert A. Backus, Esq.
Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, D.C. 20555 Manchester, NH 03106 Atomic Safety & Licensing Jane Doughty Board Panel Seacoast Anti-Pollution "eague U.S. Nuclear Regulatory 5 Market Street Commission Portsmouth, NH 03801 Washington, D.C. 20555 Paul McEachern, Esq. Maynard L. Young, Chairman Shaines & McEachern Board of Selectmen 25 Maplewood Avenue 10 Central Road P.O. Box 360 Rye, NEw Hampshire 03870 Portsmouth, NH 03801 Ms. Sandra Gavutis Mr. Calvin A. Canney The Town of Kensington City Manager RFD 1 City Hall E. Kingston, NH 03827 126 Daniel Street Portsmouth, New Hampshire 03801 Senator Gorcon J. Humphrey Mr. Angelo Machiros U.S. Senate Chairman of the Washington, D.C. 20510 Board of Selectmen (Attn: Tom Burack) 25 High Street Newbury, Massachusetts 01950 Senator Gorcon J. Humphrey Mr. Peter J. Matthews 1 Pillsbury Street Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Donald E. Chick Town Manager's Office Town Manager Town Hall Town of Exeter Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 Brentwood Board of Selectmen Ga r'; W. Holmes, Esq.
RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH 03841
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l o Philip Ahrens, Esq. Diane Curran, Esq.
Assistant Attorney General Harmon & Weiss
! Department of the Attorney 2001 S Street, N.W.
General Washington, D.C. 20009 i State House Station #6 Augusta, Maine 04333 (jjk Thomas G. Dignan, Esq. i Richard A. Hampe, Esq. I R.K. Gad III, Esq. Hampe & McNicholas Ropes & Gray 35 Pleasant Street i 225-Franklin Street Concord, NH 03301 Boston, MA 02110. .
Beverly Hollingworth $lIEdward A. Thomas 209 Winnacunnet Road Federal Emergency Management Hampton, NH 03842 Agency 442 J.W. McCormack (POCH)
Boston, MA 02109 ,
William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter South Hampton, NH 03827 10 Front Street Exeter, NH 03833 Stanley W. Knowles, Chairman Mrs. Anne E. Goodman, Chairperson Board of Selectmen Board of Selectmen P.O. Box 710 13-15 Newmarket Road North Hampton, NH 03862 Durham, NH 03824 Allen Lampert Civil Defense Director i Town of Brentwood 20 Franklin Street Exeter, NH 03833
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JoAnn Ehotwell sf '
Posistant Attorney General w .--
hhI BY EXPRESS MAIL jhjlIBYHAND L