ML20154E992
| ML20154E992 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/06/1988 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | |
| Shared Package | |
| ML20154E974 | List: |
| References | |
| OL, NUDOCS 8805230054 | |
| Download: ML20154E992 (40) | |
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t May 6, 1988 C0(.KE iE 0 UiNPC UNITED STATES NUCLEAR REGULATORY COMMISSION 88 tiAY 12 P6:24 BEFORE THE ATOMIC SAFETY AND LICENSI!4G BOARD
) 0FFICE S i. r i ,. e -
) 00CKEim A .. ev!cf.
In the Matter of NNM
)
Public Service Company of )
New Hampshire, et al. ) Docket Nos. 50-443 OL
) 50-444 OL (Seabrook Station, Units 1 & 2) ) OFFSITE EMERGENCY
) PLANNING I
l NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S l
PROPOSED FINDI;1GS OF FACT AND CONCLUSIONS OF LAW l REGARDING PERSONNEL ADEQUACY AND TRAllSPORTATION AVAILABILITY IN THE NEW HAMPSHIRE RERP, REV. 2 The New England Coalition on Nuclear Pollution ("NECNP")
submits the following proposed findings of fact and conclusions of law regarding the issues of personnel adequacy and transporta-tion availability in the New Hampshire Radiological Emergency Responso Plan, Rev. 2 (hereafter "RERP"). NECNP also adopts and incorporates by reference the proposed findings submitted by the Seacoast Anti-Pollution League, the Town of Hampton, and the Com-monwealth of Massachussetts.
- 1. BACKGROUND
- 1. t . With the exception of Proposed Finding ("PF") 1.10, NECNP does not dispute the findings in Applicants' Background and Introduct an Section.
- 3. RESPONSE PERSONNEL ADEQUACY 3.1. Findings of Fact 3.1.1. NECNP does not dispute Applicants' findings of fact in PFs 3.1.1 - 3.1.3.
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3.1.2. In support of their testimony regarding the
. adequacy of personnel to respond to an accident ~at Seabrook, Applicants offered a document entitled "Summary of Personnel Resource Assessment for the New Hampshire Radiological Emergency Response Plan," dated August, 1987- (hereafter "Summary"). The Summary described a personnel curvey conducted by Applicants.
Applicants' Exhibit 1, as corrected by Applicants' Exhibit 1A, appearing Post Tr. 4685.
3.1.3. The Summary purported to establish a) that the local governments in the Seabrook Emergency Planning Zone h
("EPZ ") have sufficient personnel to adequately respond to an emergency at Seabrook; and b) that the State of New Hampshire has adequate personnel to provide assistance to local governments, as L discussed in Volume 2, Appendix G of the New Hampshire Radiologi-cal Emergency Response Plan ("RERP"), Revision 2.
3.1.4. Intervenors offered the testimony of Clifford J. Earl regarding the Summary. Earl Dir. Test, Post. Tr. 3776; 4
Earl Rebuttal Test., Post Tr. 8915. Mr. Earl is an experienced, quali.ified expert in the field of personnel resource planning.
Ncitner Applicants nor the NRC Staff challenged Mr. Earl's L
i qualifications or cross-examined him regarding his testimony.
l l While Mr. Earl is not an emergency planner, his expertise in the field of personnel resource management makes him highly qualified to evaluate and testify on the adequacy of Applicants' Summary.
It should be noted that Applicants had no special expertise in
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personnel resource planning; in fact, the testimony showed that the survey was conducted in part by trainees. Tr. 3257.
3.1.5. Mr. Earl testified that he found four serious weaknessos in the Summary: (1) failure to provide definition of the key term "availability;" (2) failure to quantify the workload for each position to be filled; (3) the ambiguity of the "walk-through" procedures performed by Applicants for the purpose of assessing staffing requirements; and (4) the apparent lack of consideration-of potentially critical variables, such as the amount of time required to implement protective actions. Earl Rbtl. Test. at 2, Post Tr. 8915.
3.1.6. Mr. Earl's evaluation and conclusions were ,
confirmed by Applicants' testimony, which also revealed the lack of consistent data sources, and a weak managerial and supervisory
. structure for conduct of the survey, which further undermined the reliability of the Summary. Id. at 3.
3.1.7. In preparation of the survey, the techniques used did not meet even the minimum standards employed by resource planners to predict perconnel resource needs or availability.
These minimum standards include (1) use of consistent data sources, (2) the definition of key terms, (3) the definition of key assumptions, (4) clear and consistent definition of the meth-odology to be used, and (5) the use of controls to assure the consistency and accuracy of data collection and analysis. Id. at 4-5.
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3.1.8. Mr. Earl also stated that he does.not believe that the methodology used to gather.the data,is defined well enough that it can produce reliable results in the' future, when Applicants have testified that it will be used to update-the per-sonnel data and possibly form the basis for decisions during a radiological emergency at Seabrook. Li. at 3.
3.1.9. Based on these observed weaknesses, Mr. Earl found_ unreliable the Summary's principal conclusions that a) the local governments in the Seabrook Emergency Planning Zone ("EPZ")
have. sufficient personnel to adequately respond to an emergency +
at Seabrook, and b) the State of New Hampshire has adequate per-sonnel to provide assistance to local governments, as discussed in Volume 2, Appendix G of the New Hampshire Radiological Emer-gency Response Plan, Revision 2. Id. at 2.
3.1.10. Mr. Earl noted that his criteria do not include complete accuracy of data obtained. As Mr. Strome noted during the proceedings, the numbers are unlikely to ever be ;
"totally accurate." Tr. at 3336. The key considerations are whether the numbers are sufficiently reliable to (1) predict per-sonnel resource needs and availability in the event of a i radiological emergency, and (2) permit decision-makers to make an l
l informed judgment. Earl Rbtl. Test. at 7.
3.1.11. When asked during the hearing to define the I
term "available," Applicants' witnesses gave definitions that were ambiguous and subject to varying interpretations -- or i
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to misinterpretations. Mr. Renz, the person responsible for'assem-bling the Summary and partially responsible for the conclusions, stated the definition from an emergency planning perspective:
" ...the-term denotes persons that are candidates for fulfilling, or are on hand for fulfilling emergency response positions." Tr.
3254. On the other hand, Mr. Callendrello, who had general supervisory responsibility for the survey and Summary, testified that "[t]he definition that we used is those personnel that are at hand; those personnel that are within the organizations that we identified as potential personnel resource pools." Tr. 3314. -
3.1.12. Mr. Earl testified that there is significant room for variation in the interpretation of the terms used by Mr.
Renz and Mr. Calendrello. Earl Rbtl. Test. at 9-10. "On hand"
'I or "at hand" could mean any number of things, including people who are physically present at the site of the emergency, people who are capable of eventually being present, or simply the total number of people in a given employee population, regardless of location. Similarly, the term "candidate" could mean someone who meets the qualifications for a task, or simply someone who might conceivably meet them. It is notable in this context that another witness, Mr. Bonds, expressed uncertainty regarding the qualifications of laboratory workers to fulfill their .
responsibilities under the New Hampshire RERP. Tr. 3438.
3.1.13. In their proposed findings, Applicants now claim that in preparing the Summary, they identified the person-1
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a nel resources that are "available" to fill the emergency response positions in the New Hampshire RERP. No. 3.1.48. However, Applicants also state that "the survey does not attempt to deal with availability in the temporal sense; it is implementation of the plan that is designed to ensure that people are at hand to perform their functions when they need to be performed; the sur-vey assumes people will be available; the survey deals with how many people it takes to perform each of the various plan func-tions and also who can be made available to do them..." PF 3.1.34. (emphasis added) Thus, rather than establish actual availability of personnel, the survey addresses potential availability.
3.1.14. Applicants also claim in their proposed find-ings that "the survey viewed as 'available' any person who was a full or part time employee or volunteer serving the town in certain positions as defined for each town in the survey," and that a similar approach was taken for state personnel. PF 3.1.56. There is no evidence in the record that Applicants took into consideration any other factors affecting the availability of emergency response personnel, including such issues as whether people are aware of, qualified, or trained to fulfill their responsibilities; whether they are available only during their work shift or whether they can be relied on during off-shift hours; whether they can be reached during off-shift hours; and whether, if reachable, they are capable of performing their
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s 1 assigned tasks (i.e. whether they have transportation, whether they have responsibilities at home that' might prevent the- from responding).
3.1.15. Applicants incorrectly claim that "the issue of whether_ people will be there (at their emergency response posts during an emargency] is an issue of planning and implemen-tation, not personnel resources." PF No. 2.1.34. The number of people required to perform a task efficiently and effectively is necensarily influenced by the fector of when each individual can begin working on the task.
3.1.16. No written definition of the term "available" or "availability" was provided to the parties gathering or com-piling data for the Summary. Tr. 3253. No definitica of the term is given in the survey materials that Applicants apparently ]
used to interview state and local officials regarding the availability of their employees to perform emergency response functionc. Earl Rbtl. Test, at 8.
3.1.17. Many different people were responsible for gathering and evaluating the data assembled in the survey. Tr.
3201. These responsibilities included a) gathering staff availability data, b) providing staff e'/ailability data to reviewers, c) compiling staff availability' data, and d) assessing staff availability data. At each of these stages, and by each individual participating in the survey and Summary preparation, a different concept of the term "availability" might be applied.
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Earl Rbtl. Test, at 8-9. The lack of a common understanding of the term would apply equally to situations where every person participating in the assessment process had extensive staff assessment or emergency planning experience. Id. at 9.
3.1.18. Mr. Earl also testified that personnel rosters were used for some towns but not others, and off-shift availability was not considered. Earl Rbtl. Test. at 10. The assessment personnel relied heavily on verification meeting dis-cussions for confirmation of assessment findings. For example, Mr. Callendrello was asked if full-tine employment was the uniform criterion in defining the term availability. He stated "No, that was not." Tr. 3315. Subsequently, he stated that
"[i]t varied from organization to organization. In some cases, the entire pool of personnel were utilized if the emergency response individuals indicated .that they would normally use them.
For c; ample, volunteer fire fighters...if consistent with that community's wishes, those were listed as available resource pool for the purposes of emergency response." Tr. 3315-16. While the witnecses stated that an effort had been made to identify persons with potentially conflicting commitments, ti.ere was only a limited effort to determine leave or disability status. Tr.
3318.
3.1.19. Twenty-four temporary employees, most of whom are high school stadents employed to pick up trash, are consid-ered "available" to perform emergency response functions of the
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Hampton Public Works Department. Tr. 3341. Mr. Strome testified that he considered reliance on the students acceptable if it was consistent with the wishes of the Hampton Director of Public Works. Tr. 3341-42.
3.1.20. Mr. Earl testified that in placing substan-tial reliance on a community's "wishes", or on the opinions of "knowledgeable persons," without applying any independent critiera, Applicants demonstrated a failure to apply a consistent definition of terms. In effect, they allowed local officials to determined the meaning of "available" on a case-by-case basis.
Such an ad hoc and inconsistent approach cannot be expected to yield reliable information. Earl Rbtl. Test. at 11.
3.1.21. Mr. Earl testified that the Summary fails to quantify the work load involved for each position to be filled.
Earl Dir. Test. at 4, Post Tr. 3776; Earl Rbtl. Test. at 14, Post Tr. 8915. The Summary's description of the assecsment methodol-ogy used for all local municipalities states that the determina-tion of specific numbers of personnel required to implement each local plan was made via a review of each plan and its associated procedures, and that "building upon the review and revision of each plan, a walk-through of each implementing procedure was then conducted to identify, by position and functional responsibility, all of the tasks required to be performed in fulfilling the con-templated emergency response functions." Summary at 2-1. App.'s Exh. 1 at 2-1, Post Tr. 4685.
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.3.1.22. The Summary asserts the completion of a
" a walk-through of each implementing procedure...to identify, by position and functional responsibility, all of the tasks. required'to be performed in fulfilling the contemplated emergency response functions." Summary at 2-1. However, the authors of the Summary have not defined the term "walk-through" clearly enough to determine if they actually calculated the amount of work involved in each task and position, or merely matched up tasks to responsibilities and respcnsibilities to positions. In this particular case, at a minimum, a walk-through should include calculation of work load for each position. Earl Dir. Test, at 4-5.
3.1.23. Contrary to Applicants' assertions in PF 3.1.57, the record does not show that workloads were fully taken into account in the walk-throughs. First, in some instances, for example telephone calling, the amount of time taken by a given task was assumed rather than calculated. Tr. 3271-75. Second, arrival times were not taken into consideration. Tr. 3271, 3282-
- 86. The survey assumed that people were already at their emer-gency response posts because they had been called in at an ear-lier emergency classification. Tr. 3286.
3.1.24. Mr. Earl testified that the Summary does not contain sufficient information to either support the basis for this assumption, or to demonstrate that either local or state compensatory staff could, in fact, arrive at their assigned posts
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O in time to fulfill their responsibilities. Earl Rbtl. Test. at 17.
3.1.25. The survey's failure to adequately consider arrival times was highlighted by Mr. Strome's response to a ques-tions posed by Mr. Brock during the proceedings concerning the availability of State Police personnel. While Mr. Strome alleged that some personnel that are within a "reasonable distance," he conceded that "I'm not sure that I have a clearly defined empiri-cal standard for reasonable distance." Tr. 3372.
3.1.26. Even where they had been estimated during the underlying survey, the Summary also failed to show consideration of mobilization times. For instance, while the Summary states that 185 State Police will be available during a Seabrook emer-gency, the survey documents provided to NECNP during discovery in December show that on an average day, only 100 will be available within the first three to four hours. Earl Rbtl. Test. at 17.
3.1.27. In Mr. Earl's opinion, notification and mobilization times are critical factors which would affect the quantification of workload and therefore personnel needs in an emergency response. Earl Rbtl. Test. at 15. The Summary gives no explar.ation of why these factors were not considered. More-over, there is no means of determining in what instances i
mobilization and travel times actually were considered. Id.
Although the survey materials show that for some functions, Applicants attempted to deterrmine mobilization and travel t1mes,
they did not do so for all functions. See, for example, Tr.
3282. In addition, it is impossible to determine whether and to what extent mobilization and travel times were considered in per-forming walk-throughs and other personnel needs calculations.
3.1.28. Mr. Earl testified that a sound staff resource methodology would involve prediction of the number of staff needed for each position based on a calculation of the amount of work required to fulfill the responsibilities associa-ted with each position. Otherwise, it cannot be reliably con-cluded that persons filling specified positions can perform all of their required tasks effectively. Earl Dir. Test, at 5.
3.1.29. Mr. Earl also stated that unless work load is incorporated into the staff needs calculation, the Summary does not support the assertion in Section 4 that "the Summary identified the specific needs for... personnel." Earl Dir. Test.
at 5.
3.1.30. Applicants relied substantially on so-called "walk-throughs" to quantify personnel needs for an emergency response at Seabrook. Mr. Earl found, however, that Applicants' testimony demonstratedno basis for concluding that (a) there was a common understanding of the term "walk-through," (b) that the walk-throughs were consistently executed, or (c) that the proce-dures would in fact produce the intended results, i.e. reliable quanitification of the number of personnel needed to fulfill emergency response tasks. Earl Rbtl. Test, at 12.
3.1.31. The lack of a common understanding of the term walk-through was made clear in the testimony. The term was not defined in writing, and there were no written procedures for comp'leting the walk-throughs for the staff persons conducting the assessment. Id.
3.1.32. According to Mr. Renz, "not having written instructions on how to perform a walk-through is not out of the ordinary." Tr. 3252. However, there seems to be some sig-nificant variance in the term as used by these emergency plan-ners. Earl Rbtl. Test. at 12. According to Mr. Callendrello, an emergency planner, the basis for assuring a common understanding, and presumably execution, of the walk-through procedure was that
" ...each of the ptrsons who were working through these procedures are emergency planners, and they are used to dealing with a pro-cedure in this manner. That is, to look at the step, perform an evaluation of either somebody is needed to perform this step or not. And if there is a function that needs to be performed, assessing whether more than one individual is needed to perform that function.... all somebody needs to do is read the step and evaluate whether the person whose procedure it is can perform that step alone." Tr. 3277.
3.1.33. Mr. Renz, an experienced emergency planner, defined "[a] walk-through in the procedure, one goes through the procedure to see if it works...." Tr. 3252.
3.1.34. This testimony showed two fundamental prob-lens with the Appliennts' concept of a "walk-through." Earl
Rbtl. Test. at 13. First, Mr. Callendrello and Mr. Renz appar-ently differed in their understanding of what constitutes a "walk-through." Reading a procedure is not the same as going through a procedure to see if it works. On might analogize the difference to the distinction between reading a recipe to see if it will yield a satisfying cake within a certain amount of time, and going through the steps of making the cake. Obviously, the second approach yields a far more reliable result. In this case, the testimony showed that the emergency p?anners responsible for the personnel survey did nct necessarily share the same concep-tien of the term "walk-through." Id.
3.1.34. Mr. Earl observed that the second major prob-lem is that a "read-through" is an inadequate means for determin-ing staffing needs for an activity as complex as an emergency response to a nuclear accident. It cannot reveal such factors as the time necessary to prepare to implement a procedure, to make communications links, to marshal resources necessary to carry out a procedure, or to effectively carry out a procedure. Earl Rbtl.
Test. at 13-14. Moreover, while a "read-through" may be an appropriate way to discover whether procedures appear to follow each other logically, it cannot be used effectively to determine whether procedures actually work. Id. See also FEMA testimony, Tr. 4607-10.
3.1.35. Mr. Strome's testimony demonstrated the potential for variability and unreliability of results that are
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inherent in Applicants' failure to apply a consistent definition of the term "walk-through." Earl Rbtl. Test. at 14. For cxam-ple, with respect to the one person in the Town of Hampton RERP' i who was assigned multiple positions, Mr. Strome testified that "I would prefer that separate individuals assume those responsibilities." Tr. 3347. Although Mr. Strome was not per-forming a walk-through (i.e., read through) at the time, it appears that there is some room for variations in interpretation of the number of personnel required to perform emergency response I
functions even among experienced emergency planners. Earl Rbtl.
Test. at 14. l 3.1.36. Mr. Earl also testified that Applicants' ,
testimony showed that they made unreasonable assumptions in con-ducting walk-throughs of the emergency plan. Earl Rbtl. Test, at 14-15. In his opinion,the methodologies, and the resultant data, L
were influenced and rendered unreliable by these planning assump-
!' tions. [
3.1 37. The unreasonableness of Applicants' assump-I tion that emergency response workers would be at their posts when <
j an emergency begins is discussed above.
! 3.1.38. Applicants also assumed that everything would
! go according to plan if the procedures were implemented in full.
Tr. 3288. Mr. Earl stated that such an assumption is unreasonable, and certainly it is not a rational basis for determining resource requirements. It does not encourage the I
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kind of detailed analysis which is necessary to produce reliable data. Earl Rbtl. Test. at 15-16.
3.1.39. The irrationality of these assumptions was borne out in Mr. Earl's review of the Final Exercise Assessment, Joint New Hampshire State and Local Radiological Emergency Response Exercise for the Seabrook Station Nuclear Power Plant",
dated February 26, 1986. Earl Rbtl. Test. at 16. The result of the exercise -- that many of the required functions were not suc-cessfully fulfilled -- would reasonably lead a resource planner to assume that in any given accident scenario, not all emergency personnel would be where they were needed when they were needed, and the emergency response would not go according to plan. This is the opposite of what Applicants assumed.
3.1.40. Mr. Earl testified that Applicants' testimony demonstrated a failure to manage the conduct of the survey in such a way as to achieve reliable results. The techni-ques used by Applicants to determine staff requirements are rudimentary and subjective when compared to the techniques which could have been used. In order to assure the reliability of data, Applicants should have taken steps to (1) assure a common
. understanding of key terms used in the survey, (2) assure the l
- appropriateness and consistency of data sources used for all f
l organizations, (3) assure that personnel are sufficiently experi-1 i enced in staff assessments, (4) assure that staff conducting the study are effectively supervised, (5) assure that the analysis i
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and interpretation of the data is consistent, and that the results are objectively verifiable (i.e., different persons utilizing the methodology would produce the same results). Earl Rbtl. Test. at 18.
3.1.41. Applicants' testimony showed that none of these important steps were taken to assure the reliability of the-personnel data collected. As a result, there is no assurance that staff availability data produced by the survey are rel <ble.
Id.
3.1.42. The testimony showed a lack of coordination in the managerial and supervisory structure for the conduct of the survey. Id. Mr. Callendrello directed and supervised the resource assessment program. Tr. 3198. He supervised the gathering of the information presented in the Summary by direct-ing the activities of the lead individuals who were responsible for assembling the material in the Summary. Tr. 3198. These lead individuals (planners), in turn, provided subsequent super-vision of staff level people. Tr. 3198.
3.1.43. For example, for the people who did the local interviews, Mr. Callendrello stated that "[t] heir activities were directed by their normal supervisor." Tr. 3203. According to Mr. Callendrello, their normal supervisor "...would have been the supervisor within the New Hampshire Yankee Emergency Preparedness Department." Tr. 3203. That is Mr. Frechette "[r]eporting directly to me." Id.
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3.1'.44'. Mr. Frechette said that he was the supervisor of the people who went and gathered the information. Tr. 3204.
Mr. Frechette said "I supervise those individuals who work either directly or are consultants for New Hampshire Yankee. There were individuals who worked for the State of New Hampshire involved in this program as well. And I do not have supervisory capabilities for those individuals." Id. This was. confirmed by Mr. Strome.
2 Id. According to Mr. Strome, state survey perronnel were super-vised by Mike Nawoj, Chief of the Technological dazards Division.
Tr. 3205. It is thus. clear that direct supervisory responsibil-ity for the entire group of personnel conducting the ascessment ,
surveys was divided between two supervisors, Mr. Frechette inr f New Hampshire Yankee and consulting personnel; Mr. Nawoj for the :
State personnel.
3.1.45. Mr. Nawoj was not consulted by Mr. Prechette p-about (1) the methodology to be used, (2) any common assumptions, ;
. or (3) procedures to be used in the interviews with' local offi-cials. Tr. 3206. Mr. Callendrello indicated that he did not .
I consult with either of the direct supervisors to determine whether those individuals who were responsible for conducting the interviews were using the same proceures and the same understand-i e ings of terms. This was also true for the walk-through approach i
used for determining staff requirements. Tr. 3207.
3.1.46. According to Mr. Callendrello, Mr. Enoch, a .
private consultant, was responsible for "... assuring that those l f
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people collect the data that is needed to provide the input'into the program. The data being the personnel' resources which is gathered by a survey...." Tr. 3246 (also for the walk-throughs). ,
It is not clear from the< testimony how Mr. Enoch-(1) provided instructions to the persons gathering information or (2) how they were supposed to accomplish the task. According to Mr. Cal-I lendrello, "I think that it was a cooperative effort between Mr.
Enoch and the planners in determining the types of information that was needed to be gathered....he has no direct supervisory responsibility over those people. That responsibility rests with Mr. Frechette." Tr. 3246, 3247. When asked how Mr. Enoch actually (1) supervised a process, involving approximately 25 staff persons from different organizations, and (2) assured that every one of those 25 people had a consistent understanding of what it was that they were supposed to do, Mr. Callendrello stated that he did not know. Tr. 3247.
3.1.47. The Panel was asked if anyone else knew how Mr. Enoch managed the process. According to Mr. Renz, an inde-pendent contractor for Aidikoff Associates and the person responsible for compiling the Summary (Tr. 3246), "my under-standing from working with Mr. Enoch is that early on in the pro-cess, he sat down with several different emergency planners and developed a methodology...on the local and on the state level for going out and compiling and gathering information...." (this also applies to needs assessment) Tr. 3247. According to Mr. Cal-
i lendrello "...at least in the case of the survey form, that meth-odology is written down and is documented by the survey form itself. So that is the end result of the determination of the methodology. It culminates in a development of a survey form."
Tr. 3249. Furthermore, Mr. Callendrello indicated that he felt that the various steps were adequately described in the personnel survey to support a conclusion that accurate data were generated.
Tr. 3251.
3.1.48. Mr. Earl testified that the survey forms used by Applicants do not adequately document the existence of an adequate or consistent methodology for conduct of the survey.
Earl Rbtl. Test, at 21-22. The key term "availability" is nowhere defined, although it is used throughout the materials.
There is thus no indication that the interviewers who used the forms, or the people that they interviewed, shared a common, clear, and consistent understanding of the term; or that the planners who analyzed the data obtained by the interviewers had the same understanding as the interviewers and the interviewees.
Motarover. there is no reference whatsoever to "walk-throughs,"
which allegedly constituted the principal means of determining staffing resource needs. Id.
3.1.49. In addition, Mr. Earl observed that the sur-vey forms provided no comprehensive methodology for the gathering of information; in fact, most of the personnel resource questions asked by the survey forms were quite selective, and appeared
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designed only to' confirm information already gathered by some other, unspecified, means. No criteria'are provided for compar-ing the previously gathered information to'the information pro-vided in the local interviews. Thus, there is no means for evaluating the reasons why some of the data provided-in the Sum-mary differs from the data provided on the survey forms.
3.1.50. Finally, the survey forms fail to provide ;
interviewers or evaluators with meaningful criteria for defining the type of information they are to obtain. Id. at 22-23. For example, Question # 2 on the survey form entitled "Resource Anal-ysis, Requests / Questions for EPZ and Host Towns," instructs ,
interviewers to Ensure there are primaries and alternates for each EOC
- position. designated in the plan as 24. hour staffing.
Attach a list / roster identifying positions which
-require primary.and alternate staffing. (Interviewer j to obtain 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing information. Refer to Sec- ,
i tion III, Selectman's Emergency Preparedness Responsibilities and Appendix A.) :
There is no instruction to the interviewer as to how to obtain 24 [
l hour staffing information, how to determine staffing needs for >
i each position, or what it means to "ensure" the existence of [
J primaries and alternates for each position. Absent any instruc-tion, there is great room for variability in the conduct of these tasks. Moreover, there is no means for assessing whether the steps chosen by the interviewers were adequate to provide reli-able information. Id.
3.1.51. It also appears from the testimony that a i
- significant portion of the staff responsible for conducting the C
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survey may have been inexperienced i.n the field of personnel resource planning. While Applicants' witnesses are emergency planners, none of them have any special expertise in personnel resource planning. Moreover, according to Mr. Strome, some state trainees were used to perform the survey. Tr. 3257. Although Mr. Strome's answer is not clear as to how many, if any, of the State personnel were very experienced, somewhat experienced, or entry level trainees, it is possible that some of the persons participating in the surveys were at or near entry level. Earl Rbtl. Test. It 23.
3.3.52. It is clear that (1) the individual who was responsible for the overall assessment program did not personally take steps to assure a common understanding of either the terms applied or the methodology used among the direct supervisors of the staff conducting the survey, and (2) the direct supervisors did not consult to assure a common understanding of either the key terms or the methodology. Earl Rbtl. Test. at 24. Further, l
the consensus of the Panel was that the terms were not reduced to writing. Given the large number of people performing the survey, and the inexperience of some of them, there was an especially high potential for variability of survey methods and.results.
The lack of managerial and supervisory control over the many l
individuals participating in the study, as well as the many levels at which data were accumulated and assessed, renders unreliable the meaning and accuracy of the numbers obtained in l
i
u
- 23 -
l the survey. Id.
3.1.S3. The RERP gives teachers the responsibility of accounting fer'their students, remaining indoors with them during a sheltering protective action, or supervising them unt!.l_ buses o
arrive if an evacuation is ordered. During an evacuation,
. teachers are directed to accompany students on buses to reception centers and to remain with them until they are picked up by their F,
parents. Applicants' Exhibit 5, Local Community Plans, App.
School Plans.
3.1.54. Teachers' responsibilities under the plan are purely voluntary. fr. 3348, 3387. Mr. Strome testified that in reaching the determination that there were adequate personnel, he did not consider whether teachers were available. Tr. 3365.
3.1.55. The Summary does not address the numbers of teachers required or available to implement the RERP. Tr. 4105.
3.1.56. A number of teachers testified that they would not carry out their responsibilities under the RERP, and would instead attend to their families or other personal commit-monts. Pennington, et al, Dir., Post. Tr. 3945 at 5-9 and Tr.
3947-50. EPZ teachers signed a petition that stated that fley would not accept the responsibilities assigned to them under the plans. Pennington, et al, Dir., Post. Tr. 3945 at 6 and Tr.
3936-38 and Hampton Exh. 10. Fuerther, surveys of their respec-tive schools (a total of 15 schools) by certain of the teachers on the panel resulted in a very low percentages of teachers will-
)
ing to remain and implement the plans. Pennington, et al, Dir.,
Post. Tr. 3945 at 6-8 and Tr. 3973-3985.
3.1.57. FEMA testified that the unavailability of teachers to participate in an emergency response is an inadequacy in the RERP. Tr. 4076. Moreover, compensatory measures to deal with the unavailability of teachers do not currently exist. Tr.
4075-76, 3387.
3.1.58 Based on its review of the New Hampshire RERP, FEMA has concluded that the State of New Hampshire has not demonstrated that it has sufficient personnel resources to com-pensate for the non participation of local governments in emer-gency planning for Seabrook. EEMA Direct Test., Post. Tr. 4001, at 3.
3.1.59. FEMA also concluded that there is no assurance that there exists the capability to staff local emer-gency response positions for an initial response, and to augment that response on a continuing basis, since there are numerous positions in the local emergency response organizations which do not have alternates. FEMA Direct Test., Post. Tr. 4051, at 13, 3.1.60. In preparing its prefiled testimony on the adequacy of emergency response personnel, FEMA did not have the opportunity to review the Parsonnel Resources Assessment Summary prepared by Applicants. Tr. 4053. FEMA further testified that "until New Hampshire develops this information as a part of its planning base, FEMA has no basis to change its determination that
the State has not demonstrated that it has adequate personnel ecaources to compensate for the non-participation or aupplemental needs of the EPZ communities." FEMA Direct Test., Post Tr. 4051, at 17.
3.1.61. At the time of the hearings, FEMA had con-ducted a preliminary review of the Summary. Tr. 4081. FEMA stated that it considered the Summary to be just a step on the way to meeting the inadequacies that are cited by FEMA in the area of personnel resource adquacy. Id. Although FEMA consid-cred the Summary to constitute significant progress toward meet-ing FEMA's concerns, substantial additional steps are required before FEMA can fully evaluate the adequacy of personnel resources for the New Hampshire RERP. Tr. 4083.
3.1.62. FEMA testified that personnel rosters for a number of state agencies, submitted as part of Rev. 2, were incomplete. Tr. 4058. For example, personnel rosters were inadequate for the Rockingham Sherriff's Department, and for local liasons. Tr. 4055-56, 4059. Staffing rosters would have a list of names for at least two shifts, or three shifts depending upon the particular local or state government that is involved.
Tr. 4056. The missing information was considered significant.
Tr. 4058, 3.1.63. FEMA stated that New Hampshire must submit and and FEMA must evaluate personnel rosters and alerting plans in order to to remedy the personnel resource inadequacies and
deficiericles identified by FEMA and the RAC (Regional Assistance Committee). Tr. ( #0. These rosters and lists are not contained in the Sutmary. Id.
3.1.64. The 1986 graded exercise showed an inadequate numler of local liasons to carry out the RERP,* in Rev. 2, the number of liasons was increased. Tr. 4054-55. FEMA stated that an exercise and personnel rosters are necessary before it can conclude that there are adequate 11asons to staff the com-pensatory plan. Tr. 4056.
3.1.65. The normal precess by which FEMA finds out that people understand their duties and are willing to carry them out is through the process of identifying, staff, training them, and observing their participation in drills. Tr. 4088.
3.1.66. While FEMA considered the submission of the Summary to ccnstitute substantial progress toward remedying the RERP's deficiencies trith respect to personnel resources, FEMA cannot coruplete its evaluation of the adequacy of personnel resourcer until rosters and equipment lists are completed and plans and procedures are revised and updated. Finally, an r
exercise of the plan must be conducted. Tr. 4109-10, 4174-77, ,
4196.
3.1.67. In the 36 exercise of the New Hampsbire RERP, FEMA found 55 deficiences, or demonstrated and observed inadquacies that would cause a finding that off-site emergency preparedr.ess was not adequate to provide reasonable assurance
4 taht appropriate protective measures can be taken to protect the health and safety of the public living in the vincinity of a nuclear power facility, in the event of a radiological emergency.
Tr. 4182. These deficiencies precluded a reasonable assurance finding with respect to the Seabrook emergency plans. Id. FEMA considered this high a number of observed deficiencies to be "unique." Tr. 4183.
3.1.68. FEMA concluded that the State of New Hamp-shire has not shown the capability to staff a 24-hour response over a protracted period. Tr. 4072. In order to evaluate the adequacy of emergency response staffing, FEMA and RAC would need to conclude the ongoing technical assistance review of the resource assessment, and provide comments to the state. The state would then make whatever changes are necessary and provide rosters of personnel. Following that, the state would make whatever changes are necessary in the parts of the plan that deal with mobilizing emergency workers, and they would conduct table top exercises and drills on that. Finally, the State would con- .
duct a full-scale exercise, which would be evaluated by FEMA.
Tr. 4073.
3.1.69. In order to reach a reasonable assurance finding on the adequacy of personnel resources, FEMA requires that the state demonstrate that emergeacy response personnel understand their responsibilities under the plan and are willing to carry them out. Tr. 4073.
f . - _
3.1.70. The evaluation of understanding and willing-ness to perform emergency response functions is based on a number of factors. First, in the state's annual certification, it pro-vides information on training that emergency workers have undergone. Willingness to respond is evaluated by looking at who comes to training sessions, who comes to drills, and who turns out for exercises. FEMA also looks at whether there is a suffi-cient pool of people at various locations who are ready, willing and able, to respond to an accident. Tr. 4073-74.
3.1.71. FEMA testified that the primary way the state can demonstrate that people are trained to perform their emer-gency response functions is during the course of a full-scale exercises. No full-scale exercise of Rev. 2 has been made. Tr.
4074-75.
3.2. RULINGS OF IAW 3.2.1. The NRC may not issue an operating license for a nuclear power plant unless it finds that "there is rea-sonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency." 10 CFR 5 50.47 (a) (1) . This regulation embodies the concept that state and local governments must show preparedness to recpond to a radiolcgical emergency. The NRC's emergency planning require-ments also specifically require Applicants to demonstrate that "cach principal response organization has staff to respond and to augment its initial response on a continuous basis" 10 CFR 5
- 28 -
3.1.71. The evaluation of understanding and willing-ness to perform emergency response functions is based on a number of factors. First, in the state's annual certification, it pro-vides information on training that emergency workers have undergone. Willingness to respond is evaluated by looking at who comes to training sessions, who comes to drills, and who turns out for exercises. FEMA also looks at whether there is a suffi-cient pool of people at various locations who are ready, willing dnd able, to respond to an accident. Tr. 4073-74.
3.1.72. FEMA testified that the primary way the state can demonstrate that people are trained to perform their emer-gency response functions is during the course of a full-scale exercises. No full-scale exercise of Rev. 2 has been made. Tr.
4074-75.
3.2. RULINGS OF LAW 3.2.1. The NRC may not instm an operating license for a nuclear power plant unless it finds that "there is rea-sonable assurance that adequate protective measures can and vill be taken in the event of a radiological emergency." 10 CFR S 50.47(a)(1). T'r.is regulation embodies the concept that state and local goyernments must show preparedness to respond to a radiological emergency. The NRC's emergency planni.tg require-monts alsc specifically require Applicants to demonstrate that "each principal response organization has staff to respond and to augnent its initial response on a continuous basis" 10 CFR 5
50.47 (b) (1) . The regulations also require drills and exercises to evaluate and maintain skills ( 5 50.47 (b) (14) ) and radiological emergency response training (5 50.47 (b) (15) ) . See also Appendix E to Part 50, 5 F.
3.2.2. NRC regulations require that a full-scale emergency planning exercise must be conducted within two years before issuance of an operating license. Appendix E to Part 50, 5 F.
3.2.3. With regard to the adequacy of offsite emer-gency planning measures, the NRC must "base its finding on a review of the Federal Emergency Management Agency (FEMA) findings and determinations as to whether State and local emergency plans are adequate and whether there is reasonable assurance that they can be implemented." 10 CFR 5 50.47 (b) (2) . These findings are entitled to a rebuttable presumption. Id.,
3.2.4. While the NRC need not wait for FEMA's final findings on the adequacy of emergency plans, it must postpone hearings until FEMA has had the opportunity to review and testify on a plan that is "sufficiently developed to support a conclusion that the state of emergency preparedness provides reasonable assurance that adequate protective measures can and will be
, taken..." Cincinnati Gas & Electric Co. (William H. Zimmer Nuclear Power Station, Unit 1), AI AB-7 2 7 , 17 NRC 760, 775 (1983).
3.3. CONCLUSIONS l
3.3.1. Applicants have not submitted an emergency plan that is sufficiently complete to provide the basis for a
30 -
finding that personnel resources are reasonably adequate to pro-tect the public during a radiological emergency at Seabrook.
FEMA has yet to conduct a review of major elements of Applicants' emergency plan with respect to personnel resources, including Applicants' personnel resources summary, staff rosters and alert-ing lists, and the results of training sessions and drills. In addition, FEMA has not been able to use its primary tool for evaluating the adequacy of personnel resources, observation of a full-scale exercise of.Rev. 2, because no e>srcise has been con-ducted. The Board and the parties must have the benefit of FEMA's evaluation of these substantial additional emergency plan-ning steps before it can rule on the adequacy of personnel resources for implementation of the New Hampshire RERP.
3.3.2. The Board finds NECNP's witness Clifford Earl to be credible. Moreover, the Board finds that Applicants have failed to overcome Mr. Carl's demonstration that the Personnel Resource Assessment Summary does not demonstrate that there are adequate personnel to respond to a radiological emergency at Seabrook. The Board adopts Mr. Earl's assessment of the Summary'.
We conclude that given the lack of a sound and systematic meth-odology or consistent data sources, Applicants have not produced data sufficiently reliable to support a conclusion that adequate emergency response personnel are available to respond to a nuclear accident at the Seabrook nuclear power plant. For the same reasons, we do not believe that Applicants have demonstrated i l
l
the capability to obtain reasonably accurate data if and when they update the assessment in the future.
3.3.3. Even if the data presented in the Summary could be considered accurate, it is not complete for purposes of supporting Applicants' claim that sufficient numbers of personnel are available to respond to a Seabrook emergency. In addition to a "body count," the concept of availability also entails willing-ness to serve and an understanding of one's responsibilities.
This information is completely absent from the Summary.
3.3.4. It is clear from the Summary, Applicants' testimony, and Applicants' proposed findings, that Applicants consider notification and mobilization times to be irrelevant to any determination of how many people are required to respond to an accident at Seabrook, and that these variables were not fac-tored into Applicants' personnel needs calculations. For pur-poses of calculating personnel needs, Applicants rimply assumed that emergency responders would be at their posts. This assump-tion is unfounded in fact and runs contrary to NRC regulatory requirements. The Applicants must show the capacity to respond to a range of accidents, including fast-breaking ones. NUREG-0654 at 6, 17. Applicanta are simply not entitled to assume that there will be plenty of time for emergency responders to reach their posts before the response must be implemented.
3.3.5. A full-scale exercise is an essential tool for evaluating the preparedness of offsite agencies to respond to
- 32 -
a radiological emergency. It must be conducted within two years before issuance of an operating license. 10 CFR Part 50, Appen-dix E, 9 F. The last full-scale exercise of the New Hampshire RERP was conducted in February of 1986; moreover, the RERP has undergone substantial revision since then. The Board cannot con-clude that personnel resources are adequate to respond to a Seabrook emergency unless and until another exercise is con-ducted.
3.3.6. A significant number of teachers in the EPZ have declared that they are unwilling or unable to participate in an emergency response during an accident at Seabrook. The RERP makes no provision to compensate for them if they are unavail-able. Absent the provision of adequate personnel to care for school children during a radiological emergency, the New Hamp-shire RERP cannot he found adequate to protect the public.
3.3.7. Applicants have not submitted sufficient evi-dence to rebut FEHA's finding that the State of New Hampshire lacks adequate personnel resources to respond to a radiological emergency at Seabrook.
- 4. TRANSNRTATION AVAILABILITY AND SUPPORT SERVICES 4.1. Findings of Fact 4.1.1. FEMA testified that "there is some dis-crepancy in the plan and procedures as to where the buses that evacuate schools report to. For example, the Hampton local plan (Volume 18, page II-29) states that, 'the State Resources Coor-i
e dinator will direct the dispatch of buses from the State Staging Area to the Local Staging Area (EOC) where they will be provided maps and directions to the schools.' A similar description is provided in the Exeter plan (Volume 26, page II-31). Conversely, the State plan procedures for the Director of Pupil Transporta-tion Safety (Volume 4 B, p. 2) states 'have the availabic drivers and buses report to their appropriate schools.' The EOC Resource Coordinatory procedures in Volume 4 of the State plan also state,
'have the Director of Pupil Transportation Safety instruct avaialble drivers and buses to report to their appropriate schools' (page 7-3). FEMA Direct Test., Post. Tr. 4583, at (67).
4.1.2. FEMA concluded that the logistics for mobilizing evacuation buses to the schools naed to be clarified and made consistent in the State and local plans and procedures.
Id. at (67), (68); Tr. 4601.
4.1.3. FEMA's testimony as to the confusing nature of the procedures for deployment of buses was borne out in cross-examination of Applicants' witnesses. In a nunber of respects, the procedures for deploying buses for the transportation of school children are vague or difficult to understand. For instance, the procedures for the state EOC resource coordinator (Vol. 4 page 7-1) provide that when vehicles are inadequate the resource coordinator should "make arrangements" to have addi-tional vehicles "sent to the appropriate schools." Tr. 4256.
Although Applicants' witness stated that the "intent" of the pro-
34 -
cedures was to deploy buses from the state transportation staging area to the towns, that information was not conveyed by the term "make arrangements." Tr. 4257.
4.1.4. In a number of other instances, the written procedures for the RERP were found to be misleading or unclear, n
The intent of the procedures differed from or was not clearly stated in the written procedures. See, e.o., Tr. 4262-64 (not clear to what destination buses are to be dispatched) ; 4265 (con-fusing refe;-ance to nlan appendix) ; Tr. 4269-70 (unclear communi-cation procedures).
4.1.5. FEMA testified that if there is some doubt or dispute about the adequacy of the procedures for mobilization of buses, they should be tested during the course of a drill or exercise. Tr. 4601. Moreover, even if revisions to the paper plans appear to address the problems and resolve them, it would nevertheless be necessary to conduct walk-throughs, drills, training sessions, table-top exercises, and finally a full-scale exercise in order to fully evaluate whether that had been accomplished. Tr. 4601.
4.1.6. The RERP procedures employ a cumbersome num-ber of communication steps in order to determine the need for'and f
to deploy buses. Tr. 4269-79. There are at least seven dif-forent levels of communications that must take place. Id.
Although delays may be mitigated by the fact that some of these communications will be made at the same time, there is neverthe-l less great potential for confusion.
e 4.1.7. If a response must proceed rapidly, Applicants will apply default values in assessing the number of school buses needed, and some of the communications will thereby be eliminated. Tr. 4278.
4.1.8. FEMA testified that the purpose of the default values is that if, for some reason, time does not permit emergency responders to determine specific needs for buses, as listed at the alert stage, the next best thing is for the default values to be selected. Tr. 4604.
4.1.9. The RERP does not establish bus routes for transients without transportation. Tr. 4588.
4.1.10. Transients without transportation apparently will be directed to central locations; however, the means by which this will be accomplished are not entirely clear. Tr.
4589.
4.1.11. FEMA has not received from Applicants funda-mental data regarding the number of transients in the EPZ who may require transportation during a radiological emergency. Tr.
4587, 4591. FEMA's evaluation would depend to a great extent on the size of the transient population requiring special trans-portation assistance. Without this information, FEMA cannot evaluate the adequacy of Applicants' provision for protecting transients without transportation, or what measures would be appropriate. Tr. 4591-92. Id.
o O
36 -
4.1.12. The exercise of Rev. O showed a number of defects in the RERP that were not, and could not have been, dis-covered through simply reviewing the plan on paper. Tr. 4607-10.
4.1.13. FEMA stated that without an exercise, it is unable to conduct a full and adequate review of New Hampshire's planning or preparedness for protecting the transient-dependent population in the EPZ. Tr. 4610.
4.2. Rulings of Law 4.2.1. The NRC may not issue an operating license for a nuclear power plant unless it finds that "there is rea-sonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency." 10 CFR S 50.47 (a) (1) .
4.2.2. The NRC may not issue an operating license for a nuclear power plant unless it finds that "there is rea-sonable assurance that adequate protective measures can and will be taken." 10 CFR 5 50. 4 7 (a) (1) . This regulation embodies the concept that state and local governments must show preparedness to respond to a radiological emergency.
4.2.3. The regulations also require the establish-ment of a range of protective actions for emergency workers and the public, 10 CFR 9 50. 47 (b) (10) . This includes protection of school children and transients without private transportation.
4.2.4. The regulations also require drills and exercises to evaluate and maintain skills [ 5 50. 47 (b) (14) ) and
- 37 -
radiological emergency response training [ s 50.47 (b) (15) ) . See also Appendix E to Part 50, 5 F. A full-scale emergency planning exercise must be conducted within two years before issuance of an operating license. Appendix E to Part 50, 5 F.
4.2.5. With regard to the adequacy of offsite emer-gency planning measures, the NRC must "base its finding on a review of the Federal Emergency Management Agency (FEMA) findings and determinations as to whether State and local emergency plans are adequate and whether there is reasonable assurance that they can be implemented." 10 CFR S 50.47 (b) (2) . These findings are entitled to a rebuttable presumption. Id.
4.2.6. Whil.c the NRC need not wait for FEMA's final findings on the adequacy of emergency plans, it murt postpone hearings until FEMA has had the opportunity to review and testify on a plan that is "sufficiently developed to support a conclusion that the state of emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken..." Cincinnati Gas &_ Electric Co. (William H. Zimmer Nuclear Power Station, Unit 1), A LAB-7 2 7 , 17 NRC 760, 775 (1983).
l l
l 4.3. Conclusions t
4.3.1. The Board cannot reach a finding that there is reasonable assurance that the Seabrook EPZ's transient popula-tion without independent means of transportation can be protected in the event of an accident at Seabrook, because Applicants have not provided FEMA with the critical population data it requires l
in order to evaluate this issue.
l l
t
, S 4.3.2. The RERP's procedures for mobilization of buses to transport school chidren are confusing. Thus, the Board cannot find that these procedures could be carried out offi-ciently or accurately during an emergency. The existence of default values for the number of buses to go to each school does not cure this problem, since a determination of the needs of each school is a more efficient, effective, and preferable means of assigning buses to each school.
4.3.3. The fact that default values are available does not cure the problem posed by the inaccurate and confusing procedures. It is essential that the implementation of an emer-gency response proceed efficiently and effectively, regardless of how much time is available to complete the response. The poten-tial confusion and mismanagement of the emergency response posed by these procedures is not acceptable under any circumstances.
Where the public is at any level of risk, accuracy and efficiency in carrying out an emergency response are of paramount impor-tance.
l 4.3.4. Even were the Board to have concluded that the procedures appear to be adequate as they are written, the mere appearance of clarity is not sufficient to warrant a rea-conable assurance finding. The clarity of the procedures must be evaluated through drills, training sessions, and an exercise of the RERP. The Board must await FEMA's testimony regarding these further evaluations before it can reach any conclusion as to the adequacy of the procedures.
\
ce
%,spectfu y submitted, ane Curran HARMON & WEISS 2001 S Street N.W. Suite 430 Washington, L.C. 20009 CERTIFICATE OF SERVICE I certify that on May 6, 1988, copies of the foregoing pleading were served by first-class mail or as otherwise indi-cated on the parities to the attached service list.
diane Curran l
l J
F 08 L
SEABROGK SERVICE LIST . t WFSITE LICENS!NG BOARD t Isan W. Smith, Chairraan Rye, New llampshire OM70 U.S. N RC (POCil)
Washington, D.C. 20555 Boston, MA 02109 U.S. N RC Washington, D.C. 20555 Richard E. Sullivan, Ntayor City llall Nir. Angie Niachiros. Sandra Gawtis V Dr. Jerry liarbour Newburyport, MA 01950 Chairman RFD 1 Box 1154 U.S. NRC Town of Newbury East Kensington, Nil OM27 Washington, D.C. 20555 Alfred V. Sargent, Chairman Town Hall,25 High Road Board of Selectmen Newbury, MA 01951 Charles P. Graham, Esq.
YGustase Linenberger Town of Salisbury, M A 01950 McKay, Murphy and Graham U.S. I;RC li. loscph Flynn, Esq. 100 Main Street Washincton, D.C. 20555 Senator Gordon J. liumphrey Office of GeneralCounsel Amesbury, MA 01913 U.S. Senate FEMA Atomic Safety and Licensing Washington, D.C. 20510 500 C Street S.W.
Board Panel (Attn. Tom Burack) Washington, D.C. 20472 U.S. N RC Selectmen of Northampton George Dana Bisbee, Esq.
Washingon, D.C 20555 Northampton, New llamp. Geoffrey M. Iluntineton Esq.
Atomic Safety and Licensirm .
s hire O M 26 Office of the Attorney General Appeal Board Panu t State llouse Annex 8% g UX NRC Senator Gorden J. Humphre) Cnneord, NH 03301 Washington. D.C. 20555 1 Eagt: 5quare. Ste 507
,'U%'(' g
, y Concord, Nil u3301 Allen Lampert x ;y Docketing anJ Sersice U.S. N RC Michael Santosuosso.
Chil Defense Director Tow n of Brentowood h.
20:
y IEj Washineton D.C. 20555 Chairnun Board of Sclatraen Exeter, Nil Ob33
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Q Jewell Strect, RFD
- 2 Richard A. liampe, Esq A Mrs. Anne E. Goodman BoarJ of Selaimen South flampton, Nil OM42 llampe and McNicholas ibl5 New Market Road 15 Pleasant Street Durham, Nil UM42 Judit h 11. Miener, Esq. Concord, Nil 03301 Siherglate, Gertner et al.
William S. l.ord, Selatman 33 Broad Street Gary W. liolmes, Esq.
Tow n llall -- Friend Street Boston, MA 02110 llotmes A Ella Amesbury, M A 01913 47 Winnacunnent Road Rep. Roh ria C. Pescar llampton, Nil Ob42 Jane Doughty Drinkwater Road SAPL Hampton, Falk, N11 ok44 William Arms rong 5 Mark,i street Cisil Defente Director Portsmo,.u. Nil Obol Phillip Ahrens, Esq. 10 Front Sin et Assktant Attorney General Exeter, Nil oM33 Carol S. Sneider, Esquin State Hous Station # 6 Auistant Attorney General Augusta. M E 04333 Cahin A. Canney 1 Ashburton Place, loth Flr.r City Manager Boston, MA 021m i Thomas G. Dignan, E;q. City llall R.K. Gad 11. Esq 1:n Daniel Street Stanley W. Knowles Ropes & Gray Portsmouth. NH Obol Board of Selectmen 225 Franklin 5trect P.O. Box 710 Boston, M A 02110 Matthew T. Brock, Esq.
North flampton, NH OM2n Shaines A McEachern Robert A. Backus Esq. P.O. Box %0 J.P. N adeau Backus, Mcycr & Solcmon Mapkwood Ase.
Town of Rse 111 Lowcll Street Portsmouth. NH obol 155 Washington Road Marchester, NH 03105 Edward A. Thomas _.--
? Sherwin E. Turk, Esq FEMA f 3q Wug rM Office of Gcncral Co :n(el 442 J.W, NhCermack
.