ML20154E986
| ML20154E986 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/05/1988 |
| From: | Traficonte J MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#288-6322 OL, NUDOCS 8805230052 | |
| Download: ML20154E986 (12) | |
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DOCKETED TABLE OF CONTENTS FOR USNRC MASSACHUSETTS ATTORNEY' GENERAL'S CONTENTIONS 18 KW -9 P8 :27 0Fricra: n ain '
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GENERAL OUTLINE Pagn A.
Legal and Threshold Contentions (Contentions 1-6)
.13-43 B.
Organization and Organizational Control
.44-54 3
(Contentions 7-11)
C.
Communications (Contentions 12-24).
.55-74 i
- Communication Systems and Hardware.
.55-57 (Contentions 12-16) i
- EBS (Contention 17).
.57-61 F
- Notification of Response Organizations and Workers.61-64 (Contention 18)
- Sirens (Contention 19)
.64-66
- Public Notification and Communications.
.66-74 (Contentions 20-24) 3 D.
Protective Measures (Contentions 25-63)
.75-167 General (Contentions 25-26).
.75-76 Shel':e r ing (Contentions 27-28)
.77-79
- Evacuation (Contentions 29-46)80-114 Spe,cial Facilities (Contentions 47-55)
.114-159 Decision Criteria (Contentions 56-62).
.160-165 Ingestion Pathway EPZ (Contention 63).
.165-167
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Resources (Contentions 64-79)
.168-202 l
- General (Contentions 64-65).
.168-170 Facilities (Contentions 66-69)
.170-173 j
l
- State Resources (Contention 70).
.173-175 4
- Private Resnurces (Contentions 71-74,
.175-182 Federal Response (Contention 75) 163-185 i-
- Medical Resources (Contantion 76).
.185-187
- Personnel (Contentions 77-79).
.187-202 F.
Training (Co.'tention 80).
.203 G.
Accident Detectitn, Assessment and Prediction.
.204-207 (Contentions 81-82; H.
Human Behavior (Contention 83).
208-210 l
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DETAILED OUTLINE
- Qqe, A.
Legal and Threshold Issues (Contentions 1-6).
.13-43 Contention 1:
The SPMC will not be implemented by the governments and no other plan exists.
13 Contention 2-4:
10 CFR 50.47(c)(1) should not be applied to the SPMC and if it is the permissive presumption will be rebutted.
16, 19, 25 Contention 5:
Even if 10 CFR 50.47(c)(1) is applied, factual and legal uncertainties pertaining to implementation of the SPMC preclude an adequacy finding 29 Contention 6:
No delegation or authorization by the relevant governments would be lawful.
37 B.
Organization and Organizational Control (Contentions 7-11).
.44-54 Contention 7:
Bankruptcy of Lead Owner puts in question source of funds to maintain level of emergency preparedness.
44 Contention 8:
No clear relationships established between ORO and other organizations relied upon..
45 Contention 9:
Utility personnel do not have the requisite autonomy and independence..
50 Contention 10:
No provisions in the SPMC in the event of a strike.,
52 Contention 11:
Corporate policy concerning omergency planning precludes finding that this utility could develop or maintain adequate level of emergency preparedness.
52 C.
Communications (Contentions 12-24).
.55-74 Communications Systems and Hardware (Contentions 12-11)
Contention 12:
Communication systems relied on for mobilization of ORO personnel are not adequate.
SS Contention 13:
Off-site communications systems do not have a back-up power source 55 Contention 14:
SPMC relies too heavily on commercial telephone for key communication links 56
i Contention 15:
No effective horizontal or lateral system of communication 56 Contention 16:
No effective communication with State and local governmental response organizations or private organi ations.
57 4
EBS and Its Activation (Contention L2)
Contention 17:
SPMC's provisions concerning the EBS are totally inadequate.
57 Notification of Response Organizations and Workers (CSDt2Dtion 18)
Contention 18:
Notification and mobilization of response organizations and personnel not adequate.
61 Sirens (Contention 19)
Contention 19:
No adequate public alerting system exists in the Massachusetts portion of the EPZ.
64 Public Notification and Communications (Contentione 20-24)
Contention 20:
Messages to be used are inadequate.
66 Contention 21:
No provision for coordinated dissemination of information.
69 Contention 22:
No adequate information provided to non-participating governments 70 Contention 23:
SPMC provides inadequate rumor control.
70 Contention 24:
Pre-emergency information does not meet regulatory standards 72
1 D.
Protective Measures (Contentions 25-63)75-167 General (CoalcDtions 25-26)
Contention 25:
EPZ should include contiguous towns 75 Contention 26:
No range of protective measures is provided.
76 Sheltering (Cantantions 27-la)
Contention 27:
Decision critoria for sheltering are not adequate.
77 Contention 28:
Trailer parks are ignored as special populations 79 Evacuation (Contentions 29-41)
Contention 29:
Hostility toward Seabrook will prevent adequate emergency response 80 Contention 30:
No snow removal provided by SPMC.
82 Contention 31:
Sector evacuation inappropriate at this site.
83 Contention 32:
No ETE study has been done for Massachusetts that reflects actual conditions and special circumstances 84 Contention 33:
Procedures for use of the ETE-study are inadequate.
86 Contention 34:
No resources provided to make gasoline available to evacuating vehicles 88 Contention 35:
No adequate resources for stalled and cars blocked roads.
89 Contention 36:
Vehicular evacuation from the Massachusetts EPZ not possible.
90 Contention 37:
Traffic management plan inadequate.
93 Contention 38:
Inadequate number of traffic control personnel assigned.
95 Contention 29:
ETEs for Massachusetts portion of EPZ too unrealistic to be utilized.
95
Contention 40:
Maps provided in SpMC are inadequate.
.106 Contention 41:
Time necessary to effect an evacuation is too long for evacuation alone to provide adequate protection
.108 Contention 42:
ETEs are not provided that cover the wide range of times and conditions during the summer months
.109 Contention 43:
State officials consider the SpMC's ETEs too low and will reiect them during an emergency..111 Contention 44:
State officials consider the SpMC's ETEs too low and their ad hac efforts to formulate ETEs will cause substantial delays in r9sponse
.112 Contention 45:
No security is provided in evacuated
.113 areas Contention 46:
Bus routes proposed are unrealistic and impossible.
.114 Special Facilities (Contentions 47-5_i)
> Contention 47:
provisions for school children are
,not adequate.
.114
' Contention 48:
No adequate provision for the evacuation of EpZ hospitals
.125 Contention 49:
No adequate provision for those institutionalized persons who cannct be evacuated
.131 Contention 50:
Special needs populations have not been identified and their particular evacuation needs specified
.134 Contention 51:
provision for the evacuation of the special needs population are deficient.
.136 Contention 52:
Alert and notification systems for the special needs population are not adequate
.141 Contention 53:
pre-emergency information for the special needs population is not adequate.
.142 Contention 54:
No effective protective measures have been developed for those in special facilities.
.143 Contention 55:
Host special facility is inadequate
.153
6 Decision Criteria (Contentions 56-62)
Contention 56:
Decision criteria used in formulating PARS are inadequate
.160 Contention 57:
PAR decision-making is overreliant on computer-generated dose assessment.
.163 Contention 58:
Responsibilities ascribed to Seabrook Station Short-Term Emergency Director by SPMC are not provided for in Seabrook Station Radiological Plan.
.164 Contention 59:
No coordination between SPMC and NHRERP and conflicting PARS will result
.164 Contention 60:
EALs have not been discussed with or agreed upon by relevant State and local authorities
.164 4
Contention 61:
Too few ORO personnel are trained to make PARS.
.165 Contention 62:
No coordination between personnel at EOF and EOC with regard to formulating PARS.
.165 Ingestion Pathway EPZ (Cantention 63)
Contention 63:
Provisions for Ingestion Pathway EPZ are inadequate.
.165 E.
Resources (Contentions 64-79)
.168-202 General (Contentions 64-65)
Contention 64:
No assurance that resources relied upon by SPMC will be available.
.168 Contention 65:
Inadequate resources are provided to handle the numbers of potential injured.
.169 Facilities (Contentions 6 6-63 )
Contention 66:
The EOF and the EOC are not adequate.
.170 Contention 67:
Staging Area in Haverhill is not available.
.171 I l
4 Contention 68:
Media Center is improperly sited.
.171 Concention 69:
Red Cross has not agreed to establish and operate congregate care centers and the host special facility
.172 State Resources I
(Contention 70)
Contention 70:
State resources relied upon by SPMC are not sufficient.
.173 i
Private Resources (Contentions 71-74)
Contention 71:
Sufficient buses, vans and drivers are not available.
.175 Contention 72:
Sufficient ambulances, wheelchair vans and drivers are not available.
.177 Contention 73:
Sufficient tow trucks and drivers are not available.
.179 Contention 74:
No provision made for snow removal during a radiological emergency
.182 Federal Response (Contentions 75)
Contention 75:
No adequate arrangements for requesting or using Federal assistance resources have been made.
.183 Medical Resources (Contention 76)
Contention 76:
No adequate arrangements for medical services for the contaminated injured have been made.
.185 Personnel (CQDtention 77-79) i Contention 77:
The staffing of the SPMC is not adequate.
.187 Contention 78:
No adequate second-shift capability is provided
.191 I
1 -
4 Contention 79:
Prerequisite experience for numerous ORO positions and SPMC training are inadequate to qualify personnel for assigned tasks.
.193 F.
Training (Contention 80).
.203 Contention 80:
Training for ORO personnel and others is not adequate.
.203 G.
Accident Detection, Assessment and Prediction (Contentions 81-82)
.204-207 Contention 81:
Provisions for radiological monitoring are not adequate
.204 Contention 82:
Methods, systems and equipment for assessing and monitoring offsite consequences are not adequate.
.205 H.
Human Behavior (Contention 83).
.208 210 Contention 83:
Three distinct aspects of li >:e ly human behavior in the Massachusetts portion of the EPZ in the event of a radiological emergency have not been recognized and their effects planned for
.208
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s COLKETED UNITED STATES OF AMERICA UiNhC NUCLEAR REGULATORY COMMISSION,g
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In the Matter of
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PUBLIC SERVICE COMPANY OF
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Docket No.(s)
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50-443/444-OL (Seabrook Station, Units 1 and 2)
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CERTIFICATE OF SERVICE I,
John Traficonte, hereby certify that on May 5, 1988, I made service of the TABLE OF CONTENTS FOR MASSACHUSETTS ATTORNEY GENERAL'S CONTENTIONS, by First Class Mail to:
Ivan Smith, Chairman Gustave A.
Linenberger, Jr.
Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Dr. Jerry Harbour Sherwin E.
Turk, Esq.
Atomic Safety & Licensing Board U.S.
Nuclear Regulatory Commission U.S.
Nuclear Regulatory Office of General Counsel Commission 15th Floor East West Towers Building 11555 Rockville Pike 4350 East West Highway Rockville, MD 20852 Bethesda, MD 20814
9
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6 H. Joseph Flynn, Esq.
Stephen E. Merrill l
Assistant General Counsel Attorney General Office of General ~ Counsel George Dana Bisbee Federal Emergency Management Assistant Attorney General Agency Office of the Attorney General 500 C Street, S.W.
25 Capitol Street Washington, DC 20472 Concord, NH 03301 Docketing and Service Paul A.
Fritzsche, Esq.
U.S.
Nuclear Regulatory Office of the Public Advocate Commission State House Station 112 Washington, DC.
20555 Augusta, ME 04333 Roberta C.
Pevear Diana P.
Randall State Representative 70 Collins Street Town of Hampton Falls Seabrook, NH 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, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.S.
Nuclear Regulatory 5 Market Street Commission Portsmouth, NH 03801 Washington, DC 20555 Paul McEachern, Esq.
J.
P. Nadeau Matthew T.
Brock, Esq.
Board of Selectmen Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P.O.
Box 360 Portsmouth, NH 03801 Sandra Gavutis, Chairperson Calvin A.
Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E. Kingston, NH 03827 Portsmouth. NH 03801 Senator Gordon J. Humphrey Angelo Machiros, Chairman U.S.
Senate Board of Selectmen Washington, DC 20510 25 High Road (Attn: Tom Burack)
Newbury, KA 10950 Senator Gordon J. Humphrey Edward G. Molin 1 Eagle Square, Suite 507 Mayor Concord, NH 03301 City llall (Attn: Herb Boynton)
Newburyport, MA 01950
Donald E. Chick William Lord Town Manager Board of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amesbury, MA 01913 Brentwood Board of Selectmen Gary W.
Holmes, Esq.
RFD Dalton Road Holmes & Ellis Drentwood, NH 03833 47 Winnacunnet Road Hampton, NH 03841 Philip Ahrens, Esq.
Diane Curran, Esq.
Assistant Attorney General Haemon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W.
State House Station #6 Washington, DC 20009 Augusta, ME 04333 Thomas G.
Dignan, Esq.
Richard A.
Hamoe, Esq.
R.K.
Gad III, Esq.
Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth Edward 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 Jewell Street, RFD 2 10 Front Street South Hampton, NH 03827 Exeter, NH 03833 Robert Carrigg, Chairman Anne E.
Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-15 Newmarket Road Atlantic Avenue Durham, NH 03824 North Hampton, NH 03862 i
Allen Lampert Sheldon J. Wolfe, Chairperson Civil Defense Director Atomic Safety and Licensing Town of Brentwood Board Panel 20 Franklin Street U.S. Nuclear Regulatory Exeter, NJ 03833 Commission Washington, DC 20555 Dr. Emmeth A.
Luebke Charles P. Graham, Esq.
5500 Friendship Boulevard McKay, Murphy & Graham j
Apartment 1923 Old Post Office Square Chevy Chase, MD 100 Main Street Amesbury, MA 01913
e o
Judith H. Mizner, Esq.
Lagoulis, Clark, Hill-Whilton & McGuire 79 State Street Newburyport, MA 01950 J6hn Traficonte Assistant Attorney General Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 (617) 727-0190 Dated:
May 5, 1988
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