ML20206M343

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Seacoast Anti-Pollution League (Sapl) Response to Applicant Motion for Summary Disposition of Sapl Contention 37.* Ltrs of Agreement Signed by Bus Companies Do Not Ensure That Drivers Will Actually Drive Buses in Radiological Emergency
ML20206M343
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 04/15/1987
From: Backus R
BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20206M223 List:
References
OL, NUDOCS 8704200089
Download: ML20206M343 (5)
v • d • e


Text

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  • Dated : April 15,1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKETED before the usHRC ATOMIC SAFETY AND LICENSING BOARD gg 0FFICE N SEu LM"Y In the Matter of ) 00CKLTlHG '. stFVICI.

BRAMM

) Docket No. 50-4I3-OL PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al ) Off-site Emergency (Seabrook Station Unit 1) ) Planning Issues SEACOAST ANTI-POLLUTION LEAGUE'S RESPONSE TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF SAPL CONTENTION NO. 37 Pursuant to 10 CFR S2.749, on the basis of f acts set forth in the Affidavit of Thomas J. Adler the Affidavit of Ann Hutchinson and the Affidavit of Robert A. Backus (marked #II) and for the reasons stated below, SAPL hereby moves this Board to enter an order denying summary motion disposition of SAPL Contention No.

37.

REASONS FOR DENYING APPLICANTS' MOTION SAPL Contention No. 37 reads:

The NHRERP Rev. 2 f ails to provide reasonable assurance of adequate public protection because an adequate number of emergency vehicles are not provided for in the plans and further there is no assurance that effective use of these 8704200089 870415 PDR ADOCK 05000443 G PDR

vehicles will be possible in view of a potential outgoing flow of evacuating traffic.and a significant lack of drivers.

Therefore, these plans do not meet the requirements of 10 CFR 5 50. 47 (a) (1) , S 50. 47 (b) (3) , 5 50. 47 (b) (10) and NUREG-0654 II.J.10.g. and.II.J.10.k.

The RAC Evaluation of State Response in NHREP, Revision 2 ( 8/ 86 p . 7 4-b of 13 4) states as follows:

There are numerous inconsistencies between the transportation requirements worksheets (V. 4, pp.18B-2 to 18B-27) to be used by the-IFO Resource Officer and the aggregated Transportation Resource Requirements table (V.2, p.1-3) . These two sources of estimated needs should agree with one another. Regardless of which estimate of donand is correct, it is evident that the Teamsters would have to provide additional drivers in the event of a complete evacuation of the EPZ.

The bus companies have not agreed to allow Teamsters Union members to drive their buses. Further, the letters of agreement signed by bus company owners do not ensure that the drivers for the company will actually drive the buses in a radiological emergency (Affidavit of Ann Hutchinson) . Additionally, the State of New Hampshire, in responding to SAPL's Interrogatory 941, stated that it does not have information indicating how many Teamsters Union members reside within the geographic region of the bus companies listed in the NHRERP. Furthermore, the Teamsters Union membership has had no survey of its membership nor have the 1

individual members taken a formal vote to commit any particular number of members to respond to a radiological emergency at Seabrook. (Affidavit of Robert A. Backus, marked (II).

Further the 15 Sheriffs deputies available will not be able to distribute dosimetry and directions to buses at staging areas in a timely fashion.

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Due to an insufficiency of Troop A officers, access control to the EPZ will not be instituted in a timely fashion.

The Affidavit of Thomas J. Adler shows that the statement that there "should be little impedence" to incoming emergency vehicles is unsupported. The Adler Affidavit states that the bus

-mobilization survey results cannot be reasonably be accepted, that -

the counterflow and crossflow that would result from commuters returning home from-work were not modeled at all in the evacuation scenarios in Volume 6 and that the impeding effect of outgoing traffic moving around disabled vehicles was not modeled. He further states that identification checks at access control points would cause average incoming vehicle speeds to fall below the assumed 40-50 mph range.

The KLD sensitivity runs on the effects of failure to staff access points ignores an essential function assigned in the NHRERP to traffic control personnel, i . e., the reporting of roadway obstructions to the EOC. In the absence of this reporting capability, major roadway obstructions would likely remain for extended periods and would substantially lengthen the ETE. More

- - complete documentation of these sensitivity runs is needed.

h (Affidavit at 2) .

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GENUINE ISSUES OF MATERIAL FACT IN DISPUTE (SAPL 37)

1. The RAC found " numerous inconsistencies" between the transportation requirements worksheets to be used by the IFO Resource Officer and the aggregated Transportation Resource Requirements.
2. The bus companies have not granted permission for the Teamsters Union members to drive their companies.
3. The State does not know how many Teamsters Union members recide in the geographic region of the bus companies.
4. The letter of agreement with bus company owners and the Secretary Treasurer of the Teamsters Union does not assure that there will be enough bus drivers.
5. There are too few Sherif f 's deputies to dispense ,

dosimetry and route maps to bus drivers at staging areas.

6. Due to an insufficiency of Troop A Officers, access control to the EPZ will not be instituted in a timely fashion.
7. There will be significant impedance of incoming emergency vehicles. The bus mobilization survey results cannot reasonably be accepted, the counterflow and crossflow resulting from commuter traffic was not modeled in the evacuation scenarios in Volume 6 and the effect of outgoing traffic going around disabled vehicles was not modeled. Further, identification checks at access control pcints would cause incoming vehicle speeds to fall below the 40-50 mph range.
8. More complete documentation of the KLD sensitivity runs on the effects of failure to staff access control points and

traffic control points is needed. The KLD ignores an essential function assigned in the NHRERP to traffic control personnel.

Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE by its Attorney BAC MEYER & SOLOMON

. / WWb Dated: April 15,1987

'idib'ert A. Backus 116 Lowell Street Manchester, NH 03105 603=668-7272 I hereby certify that a copy of the within Seacoast Anti-Pollution League 's Response to Applicants ' Motion for Summary Disposition of SAPL Contention No. 37 has been sent this date, first class, postage prepaid, to those listed on the attached i

service list and has been federal expressed to those indicated by an asterick.

M RobertA.Backus

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