ML20154P346

New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl

ML20154P346
Person / Time
Site:	Seabrook
Issue date:	09/21/1988
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	Atomic Safety and Licensing Board Panel
References
CON-#488-7134 OL, NUDOCS 8810030035
Download: ML20154P346 (9)

Text

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _

4 I i

e 7/dh! l I

September 21, 1}gggg thhht UNITED STATES NUCLEAR REGULATORY COMMISSION TB 9P 23 P2 :28 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD co v. c -

Cucn.; l . .i,

) '

In the Matter of )

)

Public Service Company of )

New Hampshire, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 & 2) ) OFFSITE EMERGENCY

) PLANNING

__)

NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S AND TOWN OF HAMPTON'S CONTENTONS REGARDING THE 1988 EXERCISE OF OFFSITE P!ANS AND PREPAREDNESS FOR THE SEABROOK EMERGENCY PLANNING ZONE

~

Introduction The New England Coalition on Nuclear Pollution and the Town of Hampton jointly sub. nit the following contentions regarding the emergency planning exercise conducted on June 28-29, 1988. These contentions are based on the Federal Emergency Management Agency's Exercise Report (September 1, 1988), FEMA's draft Exercise Report (August 2, 1988), news releases from the State of New Hampshire and the New Hampshire Yankee Offsite Responso Orga-nization, and observations made by Intervonors stationed at Newington on Day 1 of the exercise.

Contentions TOH/NECNP EX-2 and TOH/NECNP EX-3 are presented below. Contention TOH/NECNP EX-1 has been filed separately by the Town of Hampton. These conteations demonstrate fundamental flaws in emergency planning for Seabrook.

1 Contention TOH/NECNP EX-2): The exercise demonstrated that there is no reasonble assurance that adequate measures can and l

b j 'g OO O P O

will be taken to protect school children during a radiological eLorgency et Seabrook.

Basist During the exercise, Applicants and the State of New Hampshire demonstrated an inability to successfully carry out and integrate protective actions on behalf of the school children in the Seabrook Emergency Planning Zone ("EPZ"). Instructions to the public regarding care of school children were confusing and inaccurate, bus drivers were unable to complete their assignments without assistance, protective action ("PA") decisions regarding school children were made and carried out too late and too t slowly, and the State of New Hampshire failed to follow through  !

on protective actions for school children. The process by which the State of New Hampshire ("NH") and the New Hampshire, Yankee 4

offsite Response Organization ("OR0") arranged for care of school children wa; one that would have created chaos and confusion in a l real accident.

EBS messages, summarized in Table 8 of the Draft and Final .

Reports, lack sufficient information for parents to obtain assurance or make informed decisions about the protection of their children. At 1045, NH announced that it had closed the beaches (NH Advisory $2), and at 1101 NH beach sirens were ,

sounded. Nothing was said at that point about the status of school children, even though beach residents whose children were in school needed that information in order to make decisions about protecting their family members.

l l

Less than an hour later (1152), the State mada a decision to keep school children in school buildings until 1700 (5 p.m.)

That decisior, was not even conveyed to the public until 1242 (NH Advisory # 4), almost two hours after the beaches had been closed. Thus, parents who were evacuating the towns of Seabrook and Hampton were likely to go to school to get their children, in contravention of the State's procedures for orderly protective fictions.

To complicate matters further, Portsmouth and Brentwood ordered protective actions that differed from the State's. Final Exercise Report at p. 173; Draft Report at p. 231.

In Massachussetts, ORO issued a News Release (#06) at 3 p.m.

telling Salisbury and Amesbury residents to evacuate, while at the same time stating that school dismissal would be "delayed."

No instructions were given to parents regarding whether or when to retrieve their children. It is difficult to conceive that parents in Salisbury and Amesbury, having been told by this announcement that it was advisable to leave the area, would just leave their children to await some later "dismissal."

The next News Release issued by ORO (#07 at 3:12) was also confusing. Amesbury and Salisbury residents were told to evacuate immediately. The press release also contained the con-tradictory statements that schools were being evacuated (p. 2) and that "children are currently being safely maintained at school, where they will be kept until it is determined that they

I i can be safely moved." (p. 5) The underlying message conveyed to

]

j parents by that press release was that if they wanted to assure that their children would leave the EPZ immediately, as the  ;

l parents had been told was advisable, they should go to school and I

5 t get them.

I i

With so many different protective actions being ordered for different groups of people (i.e. beaches closed while surrounding i 4

communities told to take no action, some communities told to 3

evacuate while others told to shelter), and with the constant changes in those instructions 1, parents had a strong incentive to l '

1 "hedge their bets" by fetching their children from school.2 For 1

! instance, it is reasonable to expect that parents, hearing at the '

) Alert or Site Area Emergency stage that beaches had been closed, l

would go to school and get their children so that they would be f ready to evacuate when the order came. It is also likely that fi j

l l

1 Table 7 shows two different "waves" of evacuations of the NH EPZ: EH PA # 3 (evacuation of 0-5 miles), and NH PA # 4 (evacua-I tion of ERPA F) . In the first wave, an EBS message at 1435 told some towns to evacuate vhile others sheltered. In the second j wave, an EBS message at 1640 told some of the towns that had been ordered to shelter in the previous EBS message that they should j now evacuate. The FEMA report does not contain sufficient detail l

to evaluate whether schools in each of those towns were also

evacuated promptly and successfully, as they should have been.

2 The discrepancies in protective instructions extended across both community and state lines -- within the same state, some communities were ordered to evacuate while others were ordered to shelters and beach closure was ordered in New Hampshire over an i

l hour before it was ordered in Massachussetts.

[

l l . .. . _ , . . . _ , _ - , . . . ,- .

parents who had been ordered to shelter at the General Emergency stage while other cowns had been ordered to evacuate, would fetch their children from school. The poor timing of protective action decisions and the confusing media announcements prepared by NH and ORO encouraged these responses from parents. Moreover, NH and ORO failed to demonstrate any recognition of or attempt to deal with the problem. Had this been a real accident and not a simulation, the schools in both the NH and Massachussetts por-tions of the EPZ would have been jammed with parents trying to rescue their children.

Finally, once it had initiated protective actions for school children, the State of New Hampshire simply forgot about them.

This was clearly apparent to Intervenor observers on the first day of the exercise, when protective actions for schools were carried out. For example, it wasn't until 5:45 p.m. that the State EOC asked the IFO when the towns had been or would be evacuated. At that point, the status board showed only Seabrook as having completed an evacuation -- a complete fiction, since Seabrook had withdrawn from the exercise early in the day. At that time, the status board also showed only the estimated time of arrival of buses at reception centers, and not the actual 1

arrival times.

At 6:30 p.m., a half hour before the exercise onded, it also became apparent that NH officials had forgotten that a sig-nificant number of children were still in school awaiting late I

• e- .g *: . . e i og

dismissal (i.e. those children in NH towns that had been ordered to shelter). Intervenor observors heard conversations between various officials who were unsure how many children were left in the schools and whether they would be bused or picked up by their parents. Nine minutes before the scheduled 7 pm dismissal, Intervenors heard the IFO call the State EOC and ask what trans-portation arrangements had been made ror these children; the EOC responded that arrangements had been made, but EOC did not know what they were.

NH's news releases reflected the confusion over the status of children held in schools. At 1334, NH News Advisory # 6 stated that children would be held in school until 5 p.m. Noth-ing was said about how the children were to get home. At 4:01 p.m. (NH News Advisory # 11), NH changed the dismissal time to 7 p.m. for children who were still being held at their schools.3 At that point, parents were told that they could, if they wished, pick up their children before 7 p.m., but they were not told how the children would get home if they were not picked up by their parents. Less than an hour later, the same parents were told "not to call the schools or other institutions nor to drive to 3 Given that thare were several waves of evacuation in New Hampshire (see note 1), and the lack of information as to whether schools were evacuated concurrently with the general population of towns in which they were located, it is not clear what schools were still awaiting 7 p.m. dismissal at the end of the exercise.

schools to attempt to pick up their children." (News Advisory i 12).

The actual evacuation of school children was beset with problems, gas Draft Exercise Report at pp. B B-95. As demonstrated at pp. 225-231, a numbar of bus drivers got lost or needed controller intervention. Maps were poor. One driver took almost 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to run a route between the East Kingston Local Staging Area and the Portsmouth Transportation Staging Area (Draft Exercise Report at p. 225). Some time estimates are so short is to appear to be incorrect: for instance, at pp. 227 and 229 of Ats Draft Report, FEMA states that a number of buses took only one or two minutes to travel between locals staging areas and schools. In Massachussetts, only 7 buses were dispatched for the 29 schools and 78 nursery schools and day care centers. Even with such a small test, bus drivers experienced difficulties.

Final Report at 225-26.

Finally, NH did not show an ability to swiftly make and carry out protective actions. As discussed above, NH was slow to recognize and resolve the problem of transporting the school children who remained in the EPZ. The State of New Hampshire also delayed in making and implementing other PA decisions. For instance, Intervenors observed that at 1:39 p.m., NHY recommended evacuation. The State did not concur until 2:09, even though it would take at least 45 minutes to get traffic control personnel in place.

s i.

l l Contention TOH/NECNP EX-3): The exercise showed a lack of i

severo coordination between New Hampshire and the New Hampshire Yankee ORO, resulting in a failure to provide adequate protection i.

to the public health and safety.

Basist The order to close New Hampshire beaches was given an

! hour and twenty minutes before the order to close Massachusetts beaches. It is reasonable to expect that visitors to Massachu-1 sets beaches would hear and respond to the advice given to New 4

4 Hampshire beachgoers that they should evacuate the beaches. p Under these circumstances, an evacuation from the Massachusetts beaches would'have begun long before it was planned, and long I before any traffic control or other personnel were in place to  !

t t

direct the evacuation.

s Respectfully submitted on behalf of NECNP and Town of Hampton,

( w -

! Diane Curran

) HARMON & WEISS j

! 2001 "S" Street N.W. Suite 430 i Washington, D.C. 20009  ;

, (202) 328-3500

• j September 21, 1988 r I i CERTIFICATE OF SERVICE j 1 I certify that on September 21, 1988, copies of the forego- i

! ing pleading were served by hand, overnight mail, or first-class '

i mail on all parties to this procce , as de ignated on the j attached service list. (ds, , ~

j Diane curran  ;

O

' SEAliROOK SERVICE LIST Offsite Licensing Board y i. W

' fir :.

Stanley W. Knc=les Matthew T, Drock, Dq.

len W, Smith, Chairman " Ibard of Selectmen Shaines & McCachern Atomic Safety and 1xensing Doard P.O. Boa 710 P.O. Ibn 3M *gg sEp 23 P2 :28 US Nuclear Replatory Commission North flampton,511 OM26 Mapie=M Avenue Washington, D.C 20$$$ Ponsmouth.NII 03801 a-J P. Nadeau .

Dr. Je rry lla rbour " Tomn of Rye Sandra Gavutis gn , 5 'dI Atome Safety and Ikensing Board 133 Washington Road RfT) 1,Ibn 1154 EP1 W US Nuclear Replatory Commisanon Rye, New flampshire 03870 East Kensington, Nil 03&27 Washington, D C 20$$$

Senator Gordon J. liumpt. rey Robert A. Dachus, Dq.

Gustat unenberger " US Senate Itackus, Meytt & Solomon Atomic Safety and Lxtnsing Daard Washiegton, D C 20$10 lit tomt!! Street US Nuclear Replatory Commisson (Atta. Tom Durack) Manchester, S11 03105 Washington, D C 20$$$

Richard A. Itamp, Dq Sherwin IL Turk,02q "

Robert R. Pierce, raq. " llamp and McNicholas Office of General Counsel Atome Safety and lkensing Ibard 35 Pkasant Street US Nuclear Reptatory Comminion U.S Nuclear Reptatory Comminion Concord, Nil 03301 Washington, D C 20$$$

Washington, D C 20$$$

Gary W,llotmes, F2q. II. Joseph flymn, raq.

Atome Safety end 14 censing iloimes & Dhs Office of General Counsci lu d Panel 47 Wannacunnent Road II.MA US Nuclear Regulatory Commiunon llampton, Nil 0M42 $00 C Sireet S.W, Washington, D.C 20$$$ Washington, D C 20l*2 Witham Armstrong Dc::Leting and Seroce Branch CMI Defense Director George Dana D#te, Faq.

U1 Nuclear Reptatory Commiunon 10 Front Streei Geoffrey M. Iluntinpon, bq.

Wcshington, D C 20$$$ beter, Nll OM33 Office of the Attorney Grneral State llouse Anne Witham S. terd, Selectman CaMn A. Canney Concord, N11 03301 Toma llau - Fnend Street City Manager .

Amesbury, htA 01913 City liait R. Scott liill Whition 125 Daniel Strett lagowhs, Cla rk, Ilill.%1tilton Mrs. Anne [L Gondman Ponsmouth, Nll OM01 and McGuire Ibard of Selectmen 7) State Street 1313 New Market Road Edward A.Domas Nestvryport, MA 01950 Durhtm, N11 OM42 TDtA 442 J.W McCormack (POCl1) Diana Sidebotham Seattor Gordon J. llumphrey Ikuton, MA 0217) RJ1) # 2 Do 12to 1 Dgle fquare, Sie $07 Putney,\T C$346 Concord, N11 03301 Oarles P. Graham, Lq McKay, Murphy and Graham 10 chard Doncun Michael Santcaumao, Oairman 100 Main Street IU(A Iktd of Sclectmen Amesbury, htA 01913 442 J.W. McCormack (POCll)

Jestu Street, RIT) # 2 Ikston, MA 02109 fouth flampeon, Nll OM42 Alfred V. Sargent, Chairman Ibard of Scicetmen Jane Doughty Jeth II. M a>ic t, bq Tc=n of Sahsbury, MA 01950 SAPL SAtrglate, Gertner, et al. 5 Market Street 14 DruaJ Strett Rep. Rcceria C Pesta* Portsmosth, Nil 03801 Ikuton,MA 02110 Dnnhnter RoaJ llampioe ians, Nll OM&4 Domas G. Dignan,124 "

R K. GaJ !!, bq Phdhp Ahrtas, bq " Ity mt rnight delm.r>

Ropes A Grey Auistant Attorney General 223 Freekhn Street State llouse, Station #6

[kstoa, MA 02110 Augusta,ME 04333 Ccrcl S. Sneide r, Falwre Allen lampert Austant Attorney General Crol Defense Director 1 Ashbertoo Ptact,19th floce Toen of DitatmM lbton, htA 00108 Deter, N11 OM33

., ... m .