ML20214P415
| ML20214P415 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/26/1986 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#486-1710 OL, NUDOCS 8612040191 | |
| Download: ML20214P415 (41) | |
Text
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, o UNITED STATES OF AMERICA COLKETED NUCLEAR REGULATORY CO1NISSION UWEC before the 86 DEC -1 All :43 ATOMIC SAFETY AND LICENSING BOARD GFFIC2 00CKEit!H 4 -> ' M. ~
p a r.
In *.he Matter of PUBLIC SERVICE COMPANY OF Docket Nos. 50-443-OL NEW liAMPSilIRE, ET AL 50-444-OL (Seabrook Station, Units 1 and 2) Off-site Emergency Planning and Safety Issues SEACOAST ANTI-POLLUTION LEAGUE'S CONTENTIONS ON REVISION 2 OF Tile NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN INTRODUCTION:
On Sept ember 9, 1986, SAPL was served with a copy of Revision 2 of the New llamp s h i r e Radiological Emergency Response Plan (hereinafter referred to as " NilRE RP Rev. 2" or "Rev. 2") which consisted of 31 volumes comprising state, local and host community plans , appendices, an evacuat ion t ime es t imat e, let ters of agreement, a packet of public inf orma t ion ma t er ials and a vol ume ent i t l ed "New flampshire Response Actions to RAC Review of State and Local Radiological Emergency Response Plans - Augus t 1986." SAPL cont inues to hold that, despite changes in Revision 2, the New flamp s h i r e Radiological Emergency Response Plan s t ill egregiously f ails to meet the standards set forth at 10 CFR 950.47. Pursuant to 10 CFR 62.714(b), SAPL submits the following contentions for litigation in this proceeding.
8612040191 861126
{DR ADOCK 05000443 PDR Vjo3
9 o First listed is a revised Contention (No. 31) on the evacation time study. This is then followed by SAPL's contentions that have already been admit ted into this proceeding. Amendments to the bases of these contentions are made and additional bases are added where warranted by the Rev. 2 changes. Content ion No. 7 and Content ion No.
18 have been revised as well as their bases amended. SAPL wishes to make clear that it preserves and reasserts all of the bases of all of these contentions as originally asserted except where amendments or deletions are specifically made herein. In other words, all points made.in the original statements of basis are held still to apply to the Rev. 2 plans except where expressly amended or deleted.
SAPL preserves for the record its rights with regard to all content ions that have been dismissed by this Board heretofore. SAPL continues to hold that, though the Board has declin'ed to hear these content ions, the issues raised through them st ill have merit. Without examination of those issues, SAPL holds that there is no reasonable assurance as to the efficacy of off-site emergency response around Seabrook Statlon.
SAPL f ur ther raises additional contentions that NHRERP has given rise to, Contention Nos. 33, 34, 35, 36 and 37.
Additionally, SAPL joints in and adopts the bases of the following Town of Hampton Contentions contained in " Memorandum on 10 CFR 62.714(a)(1) and Contentions of the Town of Hampton to New Hampshire Radiological Emergency Response Plan Revision 2," filed by Town of Hampton on October 31, 1986:
It in Revised ContentionlIII to Revision 2 Revised Con'tention IV to' Revision 2-Revised Contention VI to Revision'2 Revised Contention VIII to Revision 2 SAPL holds that the contentions filed herein cannot reasonably be deemed " late filed" and reasserts the grounds set forth in " Seacoast Anti-Pollution League,. Town of Hampt'on, Town of Hampton Falls and Town-of_ South Hampton--Response To Applicants' Motion for Decision
- on Motions for Summary Disposition and For Hearing Schedule with' Respect _ to' New Hampshire Emergency Planning Issues" dated October 6, 1986. Nonetheless, SAPL-addresses the reasons why-SAPL meets the five. criteria set forth at 10 CFR 62.714(a)(1)
A. Good cause, if any, for failure to file on time.
The' Seacoast Anti-Pollution League was not se,rved with NHRERP Rev. 2 until September 9, 1986. At that time, SAPL was involved in preparation for the hearings on the onsite. safety issues, which were.
held on September 29 and 30, and October 1 and 3, 1986. Subsequent to the hearing, SAPL had to devote considerable time and effort in preparation of proposed findings of f act and conclusions of law and a brief on the very complex onsite issue in which SAPL participated in that hearing.
Further, this Board, by its Memorandum and Order of November 4, 1986 has directed that " late-filed" contentions arising out of the NHRERP Rev. 2 be submi t ted by December 1, 1986. SAPL is filing in advance of the deadline es tablished by that Order, notwithstanding the inconvenience of the proximity of the deadline to the Thanksgiving holiday.
I o Additionally, this.is the third NHRERP served upon the darties to this-proceeding this year, and the fourth revision of the RERP's for the - Towns of Hampton and - Seabrook. The manner in which transportation of evacuees is to be arranged has undergone substantial changes as the plans have been modified. Indeed, the plans have changed markedly.In many other respects as well. SAPL did comply with the Board's original schedule in this case in filing its contentions on February 21, 1986. It is only'because of the State of New Hampshire's failure to provide the parties with a complete and well thought out plan earlier on that the parties are placed in the posture of being " late" with the filing of these contentions.
B. Availability of other means to protect petitioner's interest.
SAPL represents a constituency, i t s members , the preponderance of whom reside within the 17 towns within the New Hampshire emergency planning zone. Only one other intervenor in this proceeding, the New England Coalit ion on Nuclear Pollution, is litigating the issues on an EPZ-wide basis. SAPL's interests are different than NECNP's in that SAPL is an organization that is more locally-based (in Portsmouth, NH, an EPZ town) and a great number of SAPL's members reside in the very towns to be most directly affected. This gives SAPL a unique set of specific interests and concerns with regard to the adequacy of the proposed planning arrangements for each of these EPZ communities. These arrangements affect the lives of many of SAPL's members in a direct and pervasive manner.
f -o C. Extent to which petitioner can contribute to development of a sound record.
SAPL intends to br ing exper t- tes t imony in opposit ion to a number of flawed assumptions and provisions of NHRERP, Rev. 2, including the provisions for decontamination of evacuees, the evacuation time estimates' bases and the adequacy of manpower resources. Among the experts SAPL intends to bring are Dr. Donald L. Herzberg, Director of the division of Nuclear Medicine at the Dartmouth-Hitchcock Medical Center in Hanover, N.H., Thomas J. Adler, President of Resource
. Systems Group and Robert Teicher, a computer systems analyst.
Additionally, SAPL intends to bring several local individuals and of ficials who are expert by way of their personal knowledge of local conditions related to the carrying out of emergency plans.
D. The extent to which other parties will represent petitioners' interest.
As noted above at C, SAPL brings a unique local and EPZ-wide perspective to the litigation of these issues. Though some other i parties may be litigating some of the same issues, it is from a different vantage point. The Town of Hampton, the only other party ,
i to have filed a contention on the evacuation time estimate to date,
! is approaching the issue from the perspective of one town and one town only. Town of Hampton's interests are confined to the manner f
in which those time estimates affect the residents of Ilampton and would not, therefore, necessarily result in the preservation of the interests of a resident of, for example, Portsmouth. Additionally, SAPL is preparing to litigate certain issues that no other party has
r f o.
filed with respect to, as, for example, the adequacy of provisions for decontamination.of evacuees.
E. Broadening and delay of proceeding.
The issues raised in SAPL's contentions on NHRERP Rev. 2 are either-issues that have alaeady been raised in this proceeding or are for the.most part issues that are closely related to issues that have already been raised. SAPL believes that none of the contentions raised herein should result to any significant degree in a broadening or delay of the. proceeding.
CONTENTIONS Revised SAPL Contention No. 31. .
The evacuation time estimate report, as described in Volume 6 of NHRERP Rev. 2 does not meet the requirements of 10 CFR 650.47(a)(1),
050.47(b)(10) and NUREG-0654 II.J.2, ll.J.10.i, 10 h and 10 1, and Appendix 4 because it fails to account properly for the number of vehicles that would be evacuating the EPZ; relies in part upon unsupported assumptions; relies in part upon potentially biased input data; does not rely upon an extensive enough empirical base; relies upon traffic control personnel not shown to be available; does not appropriately account for travel impediments such as flooding, snow, fog and icing of roadways; does not account for the effect of driver d!sobedience on evacuation time estimates (ETE's); does not appropriately deal with topographical features; does not deal realistically with the transport of transit dependent persons; in i
some instances overestimates roadway capacity and, for all of these
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reasons, underestimates the amount of -time it would take to evacuate the EPZ and its subparts ("Regi ns") under the various scenarlos analyzed.
Basis: The basis for SAPL Contention No. 31 as -i t appeared in Seacoast Anti-Pollution League's Fourth Supplemental Petition For Leave to Intervene dated May 15, 1986 is hereby reasserted with respect to Revision 2 to the Seabrook Station Evacuation Time Study (hereinafter "KLD Report") and incorporated by reference herein.
Any modifications needed in regard to that incorporated basis to make it applicable to the Rev. 2 KLD Report are dealt with below.
Where no modifications are made, the basis statements are still applicable as originally asserted.
By way of further basis, SAPL states as follows:
- 1. This latest revision of the KLD Report now notes that 3,000 "through" vehicles will be in the EPZ highway network at the time of the order to evacuate (Vol. 6, pp. 2-27 and 10-3). This estimate of 3,000.through vehicles at any one time is unsupported since in 1985, traffic levels on I-95 alone in New Hampshire exceeded 99,000 vehicles per day, many of which were through vehicles.
The size of the Seabrook Station EPZ is roughly 200 square miles (Vol. 6, p. 4-2), it is clear that the number of vehicles chosen by KLD significantly underestimates roadway demand. This error is particularly serious in the beach areas during the summer season.
The lack of appropriate consideration of cars in the roadway system contributes to the serious underestimate by KLD of vehicles in the beach area. Though the KLD Report states that a total of 300 cars were counted in the roadway f rom aerial films in Hampton Beach, there r
t a is no statement as to when those photographs were taken or by whom they were taken (Vol. 6, p. 10-16). It is not even clear that KLD has f actored the 3,000 estimate into its time estimate calculations since the estimate is found in a sect ion capt ioned "Uncer taint les."
- 2. The KLD Report cont inues to rely upon NRC es t imates compiled in a report by M. Kaltman in February 1981 for estimate of vehicles per dwelling at seasonal housing units (Vol. 6, p. 2-14), the count of overnight accommodation units (Vol. 6, p. 2-17), and numbers of vehicles at campgrounds (Vol . 6, p. 2-20). These numbers are unlikely to have a high reliability given the significant growth that has occurred in the EPZ area over the past 5 years.
- 3. The KLD Repor t has f ailed to make any provis ion f or res ident and employee population growth in the area over the plant's proj ected lifespan. Populat ion redis t r ibut ion in the area could also mar kedly af f ect evacuat ion time es t imates (ETE's) for various regions in the EPZ. At current rates of growth, resident populations will increase over 70% and employment will increase to an even greater degree over this time span. The result will be that the ETE's set out in this report will rapidly be rendered obsolescent, even if one were to assume that they are currently correct.
- 4. The KLD Study continues unrealistically to assume that traffic management and control measures are in effect at the time the evacuat ion is ordered (Vol. 6, p. 10-70 and Appendix I). This is a wholly unrealistic assumption even if one were to assume that all local communities were intending to implement the emergency plan.
Seven towns did not participate in the graded FEMA exercise on February 26, 1986. Under many plausible scenarios, state resources f 'e and manpower, even if adequate, could not be mobilized quickly enough ,
to.be in place in the non-partleipating or even the participating communities before it would be necessary to order an evacuation.
The sensi t ivity calculat ion by KLD that an immediate General Emergency would extend ETE by only 20-30 minutes is non-persuasive and the assumptions employed in doing that sensitivity study are not carefully elucidated.
- 5. The KLD " planning-basis" accident scenario assumes that there are two temporally displaced evacuat ion s tages, i .e. , the res t of the EPZ starts to evacuate 25 minutes after those in the beach areas (Vol. 6, p. 4-17). This is not a realistic-assumption because many people will choose to leave the areas when they see the beach peopla going by, particularly given the heightened awareness of radiation health ef f ects resultant upon the extensi.ve news coverage of the Chernobyl accident. There is no empirical basis shown for the KLD Report's 25 percent spontaneous evacuation rate among those within the EPZ but not ordered to evacuate (Vol. 6, p. 10-3). The KLD Report falls to account for those beyond the EPZ who may spontaneously evacuate, taking up roadway capacity beyond the zone and thereby impeding evacuation progress out of the EPZ.
- 6. The KLD Study relies upon potentially biased input data in that the telephone survey of " heads of households" provides a substantial portion of the data used. This survey involved calls to over 10,000 households, yet resulted in only 1,300 completed responses (Vol. 6, Appendices F and G). Given the low response rate and the fact that no efforts were made to validate the responses, a large non-response bias exists in the completed data sample. There
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~
Lis, therefore,'no reasonable basis for assuming that the notification
' times, estimates of times to commence evacuation trips,- estimates 4
of average person occupancy:of vehicles evacuat ing .the EPZ or other
~ data derived f rom;the survey are accurate (Vol. 6, p. 2-3, Exhibit 2-1 and Chapter 4).
- 7. Further, the " Time to Travel Home" data' derived from the telephone. survey (Vol. 6, p. 4-10) is of limited, if any,-utility.
Question #9 of the telephone survey asked: Approximately how long does it take Commuter #( ) to travel home from work or college?"
This. question as framed elicits a response about how long it' takes the commuter to' return home under normal circumstances. Under the circumstances of an evacuation, however, commuters will.be returning home partly against the direction of evacuating traffic, through intersections with cones blocking desired turning movements,-and partly with the flow of evacuating traffic-in massive queues. The effect of almost 95 percent of the commuting population attempting to return home within 30 minutes of each other (Vol. 6, p. 4-9) would be a massive rush hour even without an evacuation in progress. The assumption that commuting workers can return home in their normal time f rames defies common sense and is insupportable f rom an analytic standpoint.
- 8. The KLD Report still relies upon Traf fic Guides for Traf fic Control Posts (TCP) and Access Control Posts (ACP). 181 local and 10 interstate traffic guides are needed for the TCP, 118 of whom are needed in New Hampshire (Vol. 6, Table 8-6). An additional 130 personnel are needed at the ACP, 28 of whom are needed in New Hampshire (Vol. 6, Table 9-4), bringing the total New Hampshire traffic ti ,_.
personnel requirement to 146. The NHRERP still does-not support a finding that these p'ersonnel will be available in adequate numbers.
9.. The KLD Report still-continues to-assume that all roads will remain passable during evacuation (Vol. 6, p. 10-70). This assumption is insupportable as it denies the realistic potential for vehicle problems either due.to mechanical malfunctions or extremes of t empera t ur e. The KLD Study acknowledges that temperatures in the EPZ range "from well below zero (F) in the winter to as high as 100 degres (F) in the summer r (Vol. .6, p. 1-8) and then ignores the implications of the statement for vehicle reliability. The KLD S t udy assumes that all vehicles with problems can be pushed to the side _of the roadway. This ignores the bridges and other choke points within
'the EPZ, such as.the entry onto Route 51 (a major evacuation route from the beach) which could be totally obstructed by one failed vehicle. In those situations no easy solution could be effected since there is no place to push the vehicle. Even if a vehicle is pushed onto the shoulder, the Highway Capacity Manual estimates that capacity is reduced by one-third because the roadway's perceived width is reduced. The KLD plan unrealistically assumes that no reductions in capacity or increases in travel times will result from these incidences .o f vehicle failure. The KLD plan recommends stationery placement of tow trucks at locations specified in Table 12-1. However, the NHRERP does not reflect this speci f ic ass ignment of tow trucks to specific locations. Further, the KLD Report gives n) estimate of how long it would take a tow vehicle to respond to an incident and then return to its assigned location. Only 2 of the recommended tow truck locations are w bin the EPZ in New. Hampshire (Vol. 6, Table 12-1).
Vehicles could also be-disabled by exhaustion of' fuel supply or accident. The KLD Report assumes that most accidents will involve vehicles traveling.at low speeds and that therefore they will not result in vehicle disablement (Vol. 6, p. 12-3). However, the KLD Report does not assume that all traffic flow is low speed in that-buses are assumed to travel from 40 to 50 MPH (Vol. 6, p. 11-20).
The KLD Report still does not appropriately account for . flooding, excessive snow, fog and icing of roadways. I t now makes only pass ing .
mention of fog (Vol. 6, p. 3-11) and indicates that the capacity reductions for snow and rain are responsive to the problem. The KLD estimates of capacity reduction for rain are, as SAPL stated before, too optimistic. This new version has changed the capacity reduction for snow to 25% from the 30% stated earlier, a-move in the wrong direction. The 1985 Highway Capacity Manual cites detailed studies which show capacity reductions of 8% for a trace snowf all plus 2.8%
for each 0.01 in./hr. water-equivalent snowfall. For a snowstorm accumulating 6" of snow over 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, the corresponding capacity reduction would be over 40%; substantially more than assumed in KLD's analysis. Flooding could render a section of roadway wholly impassible.
- 10. The KLD results rely on the assumptions that evacuees will all travel directly to their assigned host communities. No analysis was conducted to test whether other choices would substantially degrade the evacuation effort. If, for example, Hampton Beach transients chose to evacuate to Massachusetts or Maine rather than e .
the assigned community, the impact on several crowded routes could be substantial.
Further, all of the analyses assume that individuals will find the fastest route to their destination where alternatives exist.
Given the immense degree of congestion that will exist and the fact that many will be traveling to infrequently visited destinations, it is indeed very likely that many will not know which route is fastest. Sensitivity tests are needed to determine how important the user equilibration assumption is.
- 11. The KLD Report now does contain maps including topographical f eatures, but the t ime es t imate s tudy does not account for these f eatures other than to make brief mention of them (Vol. 6,
- p. 1-5). The effect on time estimates of the more hilly topography west of I-95 and the effect of the choke points.at bridges over rivers and streams have been ignored.
- 12. The mobilization time for buses has been modified in this Revision 2 version of the KLD Report. It is now claimed on the basis of a telephone survey of the organizations which own and operate the buses that 50% of available buses (as opposed to the earlier 62%) can be mobilized within one hour of notification and another 30% within the second hour wi th the remainder following in the third hour (Vol.
6, p. 11-19). The survey instrument and the data on the replies are not included in the appendices of the report.
l During off business hours, in particular, the response rate could not reasonably be expected to be anywhere near this f avorable.
- 13. The revised KLD Report now computes the number of persons within the EPZ having no vehicles available and requiring transit
{
i e o services at 2249, or 2.5% of the 91,601 population in the 17 towns i n New llampshi re. Again, KLD has moved in the wrong direction in reducing the prior estimate of 3%. The basis of KLD's calculation was the telephone survey, the problems with which were discussed at
- 6. above. This estimate is now less credible than it was heretofore, in Section VI ofthe "New flampshire Response Actions to RAC Review of State and Local Radiological Emergency Response Plans - August 1986," (hereinafter " Reply to RAC"), the RAC commented that the vehicle ownership data should be compared to census data. KLD responded that though the 1980 census data showed that 5.5% of all households have no car available, a 2.65% estimate is reasonable "in light of the expansion of car ownership during the intervening years."
( Rep l y t o RAC. , p . 3 ) . The RAC rebutted this position with national car ownership statistics and KLD came back with the reply that only site-speci fic data are relevant for planning purposes (Reply to RAC, pp. 4-5 ) . KLD's reply is unpersuasive because of the problems noted with regard to the telephone survey at 6. above. Unreliable site specific data are not better than the natlonal data. KLD attempts to shore up its argument by referring to the NilCDA survey, which arrived at a similar number. The allegedly corroborative data has its own reliability problems. SAPL holds that the number of those requiring transport assistance has been seriously underestimated.
- 14. The revised KLD repor t now estimates the time for loading passengers at special facilities at 45 minutes (Vol. 6, p. 11-21).
They assume that the average elderly or disabled person can board a bus in a 15 second mean headway. SAPL still finds this an unrealistically short period of time for loading special facility
e e o populations along 'with ~their necessary personal effects and
. medications. The estimate of time for loading non-ambulatory persons, previously 0.67 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br />, appears to have been omit ted f rom this revised KLD Repor t . There is still no es timate of the number of non-ambulatory persons outside of'special facilities.
- 15. Though the revised KLD Report states that substantial detail on roadway geometries was collected (Vol. 6, p. 1-10), the rural roads were classified into only 4 crude groups (Vol. 6, p. 3-7 and 3-8). The detailed data collected should confirm that all sections of each roadway included in a given class have minimum widths greater than or equal to those assumed. This has not been demonstrated.
- 16. SAPL holds that additional sensitivity tests should be carried out to demonstrate the effect of one of.more major road blockages due to accident, flooding, road cons truct ion, or a traf fic jam so protracted that people simply abandon their cars.
- 17. The calculation increasing the number of people by 6%
because the average vehicle is out of service 6% of the time is not correct. A proper calculation would increase the number of permanent residents needing transit by more than 6% (Vol. 6, pp. 11-8 and 11-
- 9) based on data in Figures 2-2 and 2-3.
- 18. The simulation model employed by KLD appears to have some serious defects:
- a) It is unclear how traffic control information is handled in the actual simulation aad produced the results in Appendices I and N. As an example, Appendix N seems to imply that 1500 cars can enter node #1 (Vol. 6, p. 1-49) from each of three directions.
_ - - _ . _ _ _ _ _ .__ . 1
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To resolve questions, a sample de.rIvation of 1 ink capacities should be included.for one simple and one more complex link. A sample of actual flow at a crowded intersection, showing all inputs, outputs and queues should also be included.
b) Loading procedures are not~ described in much detail. The full loading results at one major loading point should be included.
c) It appears that a substantial amount of passing has been assumed since a factor of fd = 0.75 x (0.90) = 0.675 is used to get one way from two way capacity.
d) Appendix ! shows light traffic on many roads. It is not clear how, if at all, these light traf fic patterns have been treated in the simulation model.
- 19. The estimate of 2.6 people per vehicle for permanent residents is unrealistic, particularly for the first. hour when people will be returning home or picking up family members (Vol. 6, p. 2-5). The data from the actual counts of vehicle occupancy-collected i in August 1985 and July 4 weekend in 1986 do not support this estimate (Vol. 6, pp. 4-6 and 4-8).
t
- 20. The KLD Report lacks a sufficient empirical base for computing the transient population in the EPZ. KLD should have taken j extensive aerial photographs of the area during the height of the
- beach season. The reliance upon indirect inferences from beach i
l blanket space and parking spaces is indefensible when the real picture i
! could have been taken in a systematic and thorough fashion.
i For all of the above-s tated reasons, the KLD Report in Volume 6 of NHRERP Rev. 2 falls to provide a sufficient basis for a finding
( . _ _ _ _ - __ - - -- -_- _ - _ _ - _ - - _ - - - - - _ - -- --
- s .e of reasonable assurance that.the public_can and will be protected in the event of a radiological emergency.
Revision of and Amendment of Basis and Statement of Additional Basis for SAPL Contention No. 7.
- SAPL reasserts Contention No. 7 and the basis therefor set forth in SAPL's February 21, 1986 filing.
Contention 7:
The New Hampshire State and local plans fall to moet the requirements of 10 CFR 950.47(b)(ll), 450.47(b)(10) and NUREG-0654 K.S.b. and II.J.12. because there has been no showing that the means of radiological decontamination of evacuee or emergency personnel, wounds, supplies and equipment have been es tablished. Further, there has not been a clear showing that adequate means for waste disposal exist.
By way of amendment of the basis and additional basis, SAPL s tates as follows: The NHRERP Rev. 2 now assumes that all moni toring and decontamination of evacuees will be handled by host community personnel under the supervision of DPHS. There are no letters of agreement committing the host community personnel to perform these functions (save that for the American Red Cross) and there are no 1
letters of agreement securing the reception center facilities contemplated for use under the plans. Therefore, the adequacy of personnel and equipment is not assured. Further, there are now two less host community primary reception centers due to the deletion of Nashua and Durham, which will increase the burden on the municipal resources (aersonnel and equipment) for those communitles stil1 participating. According to Rev. 2, the peaksummer midweak populat ion l is 142,929. .A high percentage of the evacu'ating population could require monitoring and decontamination under plausible accident scenarios. Even lesser percentages would overwhelm the facilities l-and personnel available to perform monitoring and decontamination services.
The decontamination centers' procedures and f aellities are now more adequately described than heretofore, though how contaminated areas of the decontamination centers are to be vacuumed or otherwise decontaminated to prevent individuals from becoming contaminated at
- the facility is not well described. There is still no storage l
capability for waste water that will result from the washing of evacuees and their vehicles. The State of New , Hampshire still contemplates dilution as the solution to this hazardous pollution problem. That is not a satisfactory answer and could lead to a public risk for the residents of the host ecmmunities.
The Decontamination Supervisors Pool at Vol. 4A, p. A-2 lists an "R. Letellier" as a possible supervisor for three centers, "E.
Thompson" for two centers and "C. Albano" for two centers, if these are actually the same people listed more than once, as it appears, this creates the false impression that there is a larger pool of potential supervisors than actually are available.
Amendment t o - Bas i s and Statement of Additlonal Bases for SAPL Contentions Nos. 8 and 8A. ._
SAPL reasserts both Contentions No. 8 and No. 8A and the bases therefor set forth in SAPL's filings of February 21, 1986 and April 8, 1986:
Contention 8: '
The New Hampshire State and local plans fall to meet the requirements that there be adequate manpower and 24-hour per day emergency response, including 24-hour per day manning of communleations 1 inks, as required by 10 CFR 950.47(a)(1),
j 150.47(b)(1), 650.47(b)(2), and NUREG-0654 II.A.I.e, II.A.4. and l I!.F.1.a.
l
! Contention 8A:
l The New ilamp s h i r e Compensatory Plan falls to meet the f
l requirements that there be adequate manpower and 24-hour per day l
emergency response, including 24-hour per day manning of :
l communications links, as required by 10 CFR 450.47(a)(1),
l 050.47(b)(1), NUREG-0654 !!.A.I.e., II.A.4., and II.F.1.a.
i By way of amendment of the basis of Contention No. 8, SAPL adds l sections e and d of the lasis from Contention 8A to Contention 8 as well, since the concepts of relying upon (c) sheriff's deputies at staging areas and (d) local liaisons have been incorporated into the i I l
regular plan in addition to their use in the compensatory plan. l l
Names of the local liaisons are now included in the State plan.
[ (Vol. 4, pp. C-16 to 17.) flowe ve r , most are not " local" at all.
} Some must come from as far away as the Concord areas, North Conway i
l and fli nsdal e. They could not, therefore, be reasonably expected to be at their posts given a fast developing accident.
SAPL further incorporates section b of the basis for Contention 8A in Contention 8 as well and adds to the basis for section b as
! follows:
The let ter in Volume 5 of the NilRERP Rev. 2 with Teams ters Local No. 633 does not provide sufficient basis for the assumption that sufficient additional drivers will be available to compensate for i
the lack of drivers identifled by the bus companies. It is rcasonable to expect that most of these drivers will already be committed to driving assignments at the t ime of an accident, the in.dividual drivers have in no way shown their willingness to drive into the EPZ and there is no guarantee that any of the teamsters union members are in the areas that the bus companies are located in or that they can be notIfled in a reasonable perlod of time if they are.
l SAPL further adds to the basis for Contention No. 8 and 8A that a serious conceptual flaw has been introduced into the plans that could potentially result in local emergency workers being removed f rom the area bef ore the populace has been evacuated. Local emergency workers are now to be ordered out of the area once a worker reaches an exposure level of SR on the CDV-730. (See, for example, The Town of flampton RERP at !!-36a.) Ilowever, according to Table 4 in the local plans, mandatory evacuat ion of the general populat ion will not be ordered until the projected whole body dose is expected to range between 5-25 rem. [ Note: A Roentgen corresponds to absorptton of u______
r
> , o I
93 ergs per gram of tissue at the body surf ace, roughly equivalent to L
l a rad, which corresponds to the delivery of 100 ergs per gram of tissue. Rads and rems are roughly equivalent when discussing whole body external exposure. Therefore, for purposes of this discussion, it is f air to assume that whole body external doses in Roentgens and rems would be nearly equivalent. (See also, Vol. 1, p. 2.7-8).]
If projected doses to the population are delivered more quickly than anticipated, it is very possible that local emergency workers could be ordered out of the area at virtually the same time as the l order to evacuate is issued. It is not reasonable to expect that l
the State can supply the trained personnel familiar enough with the Iccal communities to carry out an emergency response effectively because the State already is inadequately staffed for performance of the State's functions alone. .
! By way of additional amendment of the basis of Contention No.
l
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8, SAPL now notes that there is now listed a RADEF of ficer for Newton, N . ll . However, that individual is also listed to perform the Health Officer functions. Further, there are no alternates listed for the
! positions of Transportation Coordinator and Civil Defense Director In Newton, though the primary positions have now been filled.
l l In New Cas tle, though the RADEF f unctions are now to be per formed l by an Assistant Fire Chief, that same individual is the person lis ted to fill in for the Fire Chief should he not be available to perform hIs functlons.
The Town of East Kingston still lacks a RADEF officer, though l
Stratham's position has now been ft!!ed.
l
m Further, the Dover- host facility has- no designated EOC Operations / Planning officer listed in Appendix A.
By way of correction to basis point e of Contention 8A, SAPL notes that the State plan now claims only 444 buses as needed (Vol.
4, p. I-8) and by way of correction to basis point d that 146 personnel are required for traffic control in the New Hampshire portions of the Seabrook EPZ.
Amendments to Basis and Statement of Additional Basis for Redraf ted SAPL Contention No. 15.
SAPL reasserts Redrafted SAPL Contention No. 15 and the-basis for that contention contained in SAPL's filing of April 8, 1986.
Redrafted SAPL Contention No. 15: .
The letters of agreement that have been submitted by the N.H.
Civil Defense Agency in Volume 5 of the State plan fall to meet the requirements of 10 CFR 450.47(a)(1), 650.47(b)(1), 650.47(b)(3),
150.4 7(b)(12 ), Appendix E. II . B. and NUREG-065 4 !! . A. 3. , II .C.4. , and II.P.4. because they do not demonstrate that adequate arrangements o for requesting and ef fectively using assistance resources have been made, that the emergency responsibilities of the various supporting organizations have been specifically established, that each principal response organization has staf f to respond or to augment its initial l
l response on a continuous basis, or that agreements are being reviewed i
and certified to be current on an annual basis as is required, i.
1
. By way of amendment and statement of further basis, SAPL holds i as follows:
i j 2
- 1) Though the Coas t Guard and New Hampshire Towing Association agreements are now signed, the USAF agreement has wholly disappeared. There is thus no assurance that Pease AFB will make its hospital and runway facilities available, which are key in the emergency response effort for Seabrook Station.
Civil Air Patrol flights must be able to fly into Pease for transport of of ficials and radiological samples. The agreement with the Portsmouth Naval Shipyard has also disappeared.
- 2) There are no letters of agreement with the reception centers and mass care facilities in the local communities and letter agreements are missing for certain of the host care f acilities for special facilities in the EPZ (egs. Goodwin's of Exeter, Event ide llome, Seacoas t fleal th Cent er ). The RAC specifical1y asked about these agreements (Reply to RAC, p. 10 of 134).
- 3) Though the N.H. Towing A=sociation letter is now signed, there is still no letter of agreement with Rockingham County to assure that the Dispatch Center can be used. This facility is key in the emergency notification scheme.
e
- 4) Though a letter of agreement has been secured with the Federal Aviation Administration, there is still no letter of agreement with New England Telephone. The November 1985 draft of the NilRERP stated that it was "on file." It has not yet surfaced in the plans.
- 5) The let ter of agreement with Teams ters Local No. 633 does r not provide the requisite reasonable assurance that suf ficient drivers will be available to make up the shortfall of drivers indicated by the letters of agreement with the specific bus companies.lM any of the drivers would have prior commitments to be doing other j bs, the individual members of the union have in no way demonst rated their willingness to per form these f unct ions and there is no indication of how the drivers would be notified or where they are relative to the location of the buses.
- 6) The let ter signed by OMNE Partners II on July 31, 1986 may or may not remain current for a reasonable period of time since OMNE is in a bankruptcy proceeding. Therefore, there is no assurance that this t ranspor ta t ion s taging are.a will indeed be available.
Amendment to Basis and Statement of Additional Basis for Contention SAPL Contention No. 16.
SAPL reasserts Contention No. 16 and the basis therefor set forth in SAPL's filing of February 21, 1986.
Contention 16:
The New llampshire State and local plans do not make adequate provisions for the sheltering of various segments of the populace
- 1. The Berry Transpor tat ion Company provides the mos t glaring example of a shortfall of drivers. Only 9 drivers are available for the 62 buses. This company is particularly important because it is within the EPZ.
In-the EPZ and'therefore the plans fall to meet the requirements of 10 CFR 650.47(a)(1), 650.47(b)(10) and NUREG-0654 II.J.10.a. and m.
By way. o f amendment of the . bas i s , SAPL deletes the second paragraph at p. 20 and replaces that with the following:
'Though an evaluation of the sheltering adequacy of some of the buildings housing special f acilities appears at Table 2.6-3 of Vol.
1 of the NHRERP Rev. 2,2 there is no information given with regard to schools and day care centers.
Revision of and Amendment of Basis for SAPL Contention No. 18.
SAPL hereby revises Contention No. 18 and the basis therefor set forth in SAPL's filing of February 21, 1986.
Contention 18:
The NHRERP Rev. 2 significantly miscalculates the numbers of non-auto owning populat ion for the 17 New Hampshire local communi t ies.
No buses are provided in the plans for the individuals who are not accounted for due to these miscalculations. Therefore, these plans f alls to meet the requirements of 10 CFR 950.47(a)(1), 650.47(b)(8),
NUREG-0654 !!.J.10.g. and NUREG-0654 Appendix 4, p. 4-3.
SAPL deletes the original statement of basis since the numbers cited therein have since been modified in NilRERP Rev. 2.
- 2. SAPL would like to believe that the 125 rem outside projected whole body dose to warrant ovacuation for the Wentworth Home is a
! typographical error and really should be 12.5 rem. SAPL reserves l the right to contest this figure if the 125 rem figure was intended.
i
o .
By way of amended basis, SAPL asserts as follows:
The NHRERP Rev. 2 - erroneously assumes an EPZ wide non-auto owning population percentage of 2.5 percent and it is based upon this percentage that buses needs are assessed. Further, the population on which the percentage calculation is made has been underestimated by a very significant margin (See the basis for SAPL Contention No. 34, incorporated by reference herein). Therefore, there is no reasonable assurance that adequate protective measures are available for the non-auto owning populace.
Reflective of this defect is the vast reduction ir the number of buses the State of New Hampshire now claims are necessary to evacuate the EPZ. The November 1985 version of the NHRERP planned for l
a total of 614 buses. Based on the vehicle needs from each of the local RERPs (see, for examples the Seabrook RERP at .IV-24, the South flampton RERP at IV-21, the Newton RERP at IV-27 and the Greenland l RERP at IV-22), the new plans state the total need for buses (including regular buses, coaches and special needs buses) at 482. This represents a net reduction of 132 buses. [ Note the discrepancy with the " Transportation Resource Requirements" set out at p. I-8 of Vol. 4. That section states the total of buses required at 444.]
The State of New llampshire now claims that bus agreements include i
a surplus of 50% over the number of transport-dependent persons as well as consider the current year enrollment for school children.
i (Reply to RAC, p. 74 of 134.) The November 1985 NHRERP estimated the number of non-auto owning at approximately 8659 persons (Nov.
1985 NHRERP a t Appendix E, p. E-8). The es t imate now is 2106. (Reply l to ilAC, p. 74 of 134. ) This is over a f our-f old reduct ion which SAPL i
holds .is wholly unwarranted and not properly substantiated. The
" excess seat capacity" is simply the flawed product of an unrealistic and inaccurate assessment of need and it is' simply not real.
Amendments to Basis and Statements of Additional Basis for SAPL Contention No. 25.
SAPL reasserts Contention No. 25 and the basis therefor set forth in SAPL's February 21, 1986 filing.
Contention 25:
The New Hampshire State and local radiological caergency response plans do not reasonably assure that the public health and s safety will adequately be protected because the provisions for protecting those persons whose mobility may be impaj red due to such factors as institutional or other confinement are patently lacking.
Therefore, the plans do not meet the requirements of 10 CFR Q50.47(a)(1), 650.47(b)(8) and NUREG-0654 II.J.10.d.
By way of amendment and addit ional bas is, SAPL s tates as f ollows:
The Exeter llospital Radiological Emergency Response Plan contained in Volume 26A of the NHRERP Rev. 2 does not support a finding that there will be adequate care provided for those patients classified as Category 1 (Advanced Care Required) or Category IV (School Bus) because the let ters of agreement with the host hospitals for Exeter llospital do not Indicate that any of these facilities have the willingness or f acilitic s to take these pat ients. Catholic Medical Center and Concord llospital only assert a willingness to
accept Class II and Class III patlents. Hamps t ead Hospi tal's -l'et t er is non-specific in' regard to how many or what category of patients it will accept and does not. support a finding that these patients will be cared for. There is, therefore, no reasonable assurance that these individuals will be adequately provided for.
Fur ther, at page 15 of the Exeter Hospital Radiological Emergency Response Plan, it states:
Patients aged 55 years old or considered too critical for transport should be considered candidates for sheltering rather than evacuation. Coordinate with DPHS.
Despite euphemistic language, this provision is, in SAPL view, nothing less than a discriminatory and insupportable attempt to case the task of evacuating the facility by dumping the responsibility for the lives of those who would be most dif ficult to move. There is ,
no basis in the law for this discriminatory treatment of these individuals.
The plans for the mobility impaired are further deficient in that the host facility agreements for the Seacoast Health Center in Hampton are not in place for the three host facilities expected to take Scacoas t Heal th Center res idents. Goodwin's of Exeter and the Eventide Home of Exeter are also lacking host facility agreements that would provide some assurance that their residents would be provided for. The RAC specifically asked whether there were letters of agreement available for each of the reception and mass care facilltles. The answer provided by the State was wholly unresponsive to the question asked. (Repl y t o RAC, p. 10 o f 134. ) There is not even one let ter of agreement with any of the hos t community reception
- centers or mass care facilities anywhere In the NilRERP Rev. 2.
)
I
L s ,
The NHRERP Rev. 2 does now contain letters of agreement with 14 ambulance services (Vol. 5), though one listed, O'Brien Ambulance of Beverly, Massachusetts, has stated that the company will not be able to participate in any type of response in the Seabrook area.
SAPL will need additional time to check with the others.
Though the State has now devised a system for identifying those with special needs, and the Board has found the system a sufficient basis for summarily disposing of the issue of the adequacy of means of identification of these individuals,3 SAPL wishes to preserve once again for the record its objection to the Board's finding.
SAPL Contention No. 33.
Contrary to the requirements of 10 CFR 650.47(a)(1),
650.47(b)(8), 65 0. 47( b)(9 ), 650.47(b)(10) and NUREG-0654 II.J.12, there is no showing that NHRERP Rev. 2 provides adequately for the '
registration and monitoring of evacuees at reception centers within about a 12-hour period.
Basis: The NHRERP Rev. 2 has reduced the number of hos t communit ies from slx communitles down 1o four communitles in eliminating Nashua and Durham. This has had the resultant ef fect of lessening the base of municipal resources that can be drawn upon to assist the evacuating population and has reduced the likelihood, which was not great before, that all evacuees seeking assistance would indeed by assisted within the time frame set forth in NUREG-0654 as reasonable, i.e., about a 12-hour period. The rate at which evacuees can be processed through
- 3. Memorandum and Order of November 4, 1986 at p. p. 10-17.
the remaining reception and decontamination facilities has not in any f ashion been established in the plans. Therefore, reasonable assurance has not been demonstrated that any significant fraction of the summer midweek population of 142,929 estimated in these plans for the New Hampshire portion of the EPZ could be assured the requisite assistance in the specified time frame.
SAPL Contention No. 34.
The New Hampshire State and local plans do not meet the requirement that there be maps showing the population distribution around the facility as required at NUREG-0654 J.10.b. and Appendix
- 4. Therefore, there is no reasonable assurance that adequate protective measures can and will be taken pursuant to 10 CFR 650.47(a)(1) and 650.47(b)(10). .
Basis: A similar contention to this was originally submitted as SAPL Contention No. 6, which SAPL withdrew. Subsequently, however, the NHRERP Rev. 2 has appeared and it has very significantly and erroneously reduced the peak populations in the EPZ from those that appeared in the November 1985 NHRERP upon which contentions were initially filed. The November 1985 NHRERP stated the peak population for New Hampshire at 191,849. Rev. 2 has reduced this peak number to 142,529 for a summer weekend and 142,929 f or summer midweek. The
..,4
' larger of these two new figures represents a _reduct fon of- 48,920 people from the original: estimate.4 In NUREG-0895, the Final Environmental' Statement for Seabrook Station' dated December 1982, the NRC Staff estimated the resident
_ population for 1983 within 16 km (10 miles) of the site at 99,900 and estimated the 1983 peak transient population within the same area at 130,998, which totals to 230,898. These figures, again, were the estimates for 1983. Table 1 in the Rev. 2 plans-show the total EPZ peak population for 1986 at summer midweek at 229,726, less than the NRC estimate of peak population for 1983, and the peak summer weekend population at 231,292, an increase of only 394 people.
This is patently and plainly absurd. Rockingham County, N.H. is one of the fastest growing areas in the entire country. 1980 census figures showed the Rockingham County permanent populption at 190,345.
The estimate of Rockingham County population for 1985 from the New
' Hamsphire Of fice of State Planning is 214,510. Therefore, the average annual growth rate for Rockingham County as a whole is 2.5%. The area along the coast, where the EPZ towns are located, can be expected to have grown at a rate f aster than the county wide average. Therefore, one must reasonably assume that the EPZ population has increased by a minimum of 16,000 people above the 1983 NRC estimate of 230,898.
SAPL finds particularly objectionable the treatment of the populat ion for the Town of Hampton in the Rev. 2 plans. The November 1985 version of the NHRERP stated the peak seasonal population at
- 4. Note that there are inconsisteneles among the local plans for the summer midweek population for Hampton. Table 1 in the Hampton plan states the number at 34,337, while the East Kingston and Stratham plans, for example, state the number at 31,337.
i -
110,000. The Rev. 2 plans state the peak summer weekend population at 36,635, a reduct ion of 73,365. NUREG-0654 s tates that "Es t imates of transient populations shall be developed'using local data such as peak tourist volumes and employment data for large factories."
(NUREG-0654, Appendix 4, p. 4-3.) The Hampton selectmen notified the State by letter of October 29, 1985 that the peak estimate of 110,000 was "still lower than traffic counts and local business figures indicate." (See Attachment A.) Therefore, the reductions of population in the beach area particularly and the EPZ as a entirety are wholly unwarranted. This leads to the ineluctable conclusions that the population maps in the plans are not accurate and that therefore adequate protective measures will not be provided for the health and safety of the public because the planning provisions in the NHRERP do not provide for the realistic demands that will be placed on emergency response resources, in clear violation of 10 CFR 950.47(a)(1).
i 1
SAPL Contention No. 35.
NiiRERP Rev. 2 does not meet the requirements of 10 CFR 650.47(a)(1), 650.47(b)(7), 650.47(b)(9), 650.47(b)(10) and NUREG-0654 !!.G.1 (and its subsections) and I I . J .12 because the public information material does not instruct the public to go to reception centers for monitoring if there is any danger they have been in the plume exposure area.
Basis: The public information material provided with the NilRERP Rev. 2 does not provide reasonable assurance that the health and
, _ _ _ _ . - _ _ - , . - . , _ , _ - - . , , _ .,. , , , , , _ . , , _ . , _ _ . , , .-.,.,__.____.,___7 , _ , , , .y._,.c. __
safety of the public will be protected because the material does not instruct people to go to reception centers if there is any chance at all that they have been contaminated. The in' formation simply says:
"If you need help, go to your recept ion center." Many people do not understand the nature of radiation contamination and would not know why they should be monitored if the plume has passed over. The public information material further may subtly predispose pet-owning members of the public not to go to the reception. centers because i they are told they can bring their pets along only if they are going to be staying with relatives or friends rather than at a public shelter.
The Affidavit of Donald L. Herzberg, M. D. states as follows:
At the basis of any decontamination program must be the identification of those persons who are and are not contaminated.
Most individuals in the area of potential radiation exposure will have no-way of knowing whether or not they have been
- contaminated.
Therefore-any and all members of the public who may have been exposed
[
must be clearly instructed to go to reception centers for monitoring and-decontamination.
A further problem with the public information materials is that the calendar at page 5 is still incomplete. The sections that are
- l. supposed to detail evacuation routes for each of the 17 New Hampshire towns do not do so. Thus, the plans overall fail to give the public
' the means of knowing this very important information. This reduces i
further the likelihood that all those who ought go to reception centers for monitoring would actually go to them.
SAPL Contention No. 36.
The authorit ies (legal bases), responsibilities and concept of operations between the Town of Salisbury, Massachuset ts and the State of New Hampshire Emergency Response Organization has not been set forth in a written agreement or in any way assured though the New Hampshire plans rely upon response actions by the Salisbury Police.
This is contrary to the requirements of 10 CFR 950.47(a)(1); 10 CFR Part 50, Appendix E, Sections II.A.8 and NUREG-0654-A.2.b., II.A.3 and II.E.1.
Basis: The Hampton and Seabrook local radiological emergency response plans state that the Seabrook Police Department will request the Salisbury, Massachusetts Police Department to establish traffic control at Laf ayette Road and Route 286 (see, for example, the Hampton RERP (Vol. 18A) at pp. 4, 6, and 8). There is no legal authority cited upon which this request would be based, no clear description of the responsibilities of the Salisbury Police that are assumed and no clear concept of how the Salisbury police would be notified.
There is further no letter of agreement with the Salisbury Police.
Given the fact that the Commonwealth of Massachusetts has withdrawn from planning, there is no basis for assuming that the Salisbury Police will indeed feel compelled to complete any such action.
Failure on their part to do so, however, could markedly impair the effort to restrict access to the beaches and could hence lengthen the evacuation' times for removing people from the area.
SAPL'C'ontention No. 37.
The NHRERP REv. 2 fails 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 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 950.47(a)(1), 650.47(b)(3), 650.47(b)(10) and NUREG-0654 II.J.10.g. and II.J.10.~k.
Basis: NUREG-0654 II.J.10.g., which provides a further explication of the planning standard at 10 CFR 650.47(b)(10), states a
that there must be means of relocation of the population in the emergency planning zone. The planning standard at 10'CFR 550.47(b)(3) requires that there be arrangements for requesting and "ef fect ively using assistance resources." (emphasis added.) Neither of these requirements are met because the NHRERP Rev. 2 fails to provide for adequate transportation resources for both those numbers of evacuees in ins t itutions (schools, day care centers, hospi tals, nursing homes) and those not in possession of an independent means of transport.
l l
l l
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The NHRERP Rev. 2 has reduced the number of buses to be provided under the plans to 482,5down f rom a prior 614 planned for in November 1985 version of the NHRERP. The Town of Exeter and the City of Portsmouth are the municipalities most drastically af fected by these reductions. The proj ected need. for buses for the City of Portsmouth is 89 buses less than was provided in the Nov. 1985 Portsmouth RERP.
This situation becomes particular1y serious because the KLD Study shows traffic congestion in the City of Portsmouth throughout the evacuation process. (Vol. 6 at p. 10 and pp. 10-21 to 10-27 and pp.
10-29 to 10-34.) If additional transportation resources must be requested from the State, there could be a significant degree of difficulty in getting buses through traffic to the areas where they are needed. Further, Portsmouth is the location of one of the transportation staging areas (at OMNE Mall). The Town of Seabrook and Hampton Falls are among the towns to be servedby' buses f rom that staging area (Vol. 4, p. 1-10). Portsmouth is in the northmost section of the New Hampshire portion of the EPZ. Hampton Falls and Seabrook are at the southernmost section of the New Hampshire portion of the EPZ.
This provides a good example of the f act that in many instances, buses will need to travel through very congested traffic conditions over a considerable distance before they can get to a point of
- 5. Based on numbers taken from the local plans. See, for example, Greenland RERP at IV-22, Kings ton RERP at IV-12a, and Brentwood RERP at IV-21a).
l
effective use. Given the constraints of personnel and resources faced by the local and N.H. State Police, it is not likely that adequate traffic control measures will be in effect. There will ,
therefore be nothing to constrain evacuees f rom attempting to drive outbound on those lanes that are needed for effective progression inbound of emergency vehicles. The N.H. State Police Troop A only has 35 troopers, not an adequate number to cover the 118 traffic control posts and 28 access control posts in New Hampshire.(FEMA, Final Exercise Assessment, 6/2/86 at p. 46 and Vol. 6, Table 8-6 and 9-4.) In Hampton Falls, for example, there is only one full time and f our part-time police of ficers. Police Chief Christie has stated that he is unable to fulfill the duties designated to him in the plan due to lack of manpower and equipment. The Town of Hampton has only 24 full time officers in the police force. In addition to traffic control, these officers must provide seedrity at various locat ions and per form back-up alerting funct ions in addit ion to their usual functions.
Further, there is no assurance that there will be drivers for even the inadequate numbers of buses and vans provided by the NHRERP, Rev. 2. The letters of agreement in Volume 5 show a total of 574 buses and 510 drivers. The 64 driver shortf all for buses alone, not to mention the vans, does not really show the true magnitude of the problem since the excess availability of a driver or deivers to one i
bus company does not do anything to alleviate a shortage of drivers
- at another company. FEMA stated that " bus-and-driver pairs" should l
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.- - . , _ , . _ ,_ ._. - _ . . . ~ - . . . . . . _ . . - . . . . , . . _ . . . .
be tallied to arrive at the maximum availability of emergency vehicles. (FEMA, Final Exercise Assessment, 6/2/86, p. 39). The letters of agreement in Volume 5 of the plans only demonstrate a to tal o f 445 bus-and-dr iver pa i rs . As stated above, the local plans alone show a need for 482 buses, though the State plan shows that only 444 buses are needed for those communities.
Because the State of New Hampshire has erroneously reduced its estimate of the number of buses that will be needed by reducing population estimates and by reducing the percentage of non-auto owning individuals to be provided for (see SAPL Contentions Nos. 34 and 18), because there are insufficient emergency vehicle drivers and because adequate traf fic control measures cannot be carried out due to personal shortages, there is no reasonable assurance that adequate assistance resources will be provided or tha't those resources that are available can be used effectively.
Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By its attorney, BACKUS, MEYER & SOLO \10N V M.
Robert A. Backus' P. O. Box 516 116 Lowell Street Manchester, N.H. 03105 Tel: (603) 668-7272 DATE: November 26, 1986 I hereby cer t i f y tha t a copy of the wi thin SEACOAST ANTI-POLLUTION LEAGUE'S CONTENTIONS ON REVISION 2 OF THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN has been sent this date, first class, postage prepaid, to the persons on the attached service list.
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350/S Olnniveruary Y...hY.:'"
1636 -1966 October 29, 1925 Honorable Jo'1n Sununu
' '. Q f3 ' 0 l Governor'4 Office State House W +M O '
s S JdNi2i9BS Concord, New Hampshire 03301 Dear Governor Sununu
- The undersigned mcabers of G e Hampton Board of Selectmen wish
- to state Geir reservations about the adequacy of he Radiological Emergency Response Plan. These reservations were publicly presented at a meeting of the Board on October 3, I985, a meeting scheduled
- between new members of *the Board and local department heads, but which was attended by officiaTs from New Hacpshire Civil Defense.
Our original. questions about the plan concerned population estimates.
kt understand that the figure of 85,000 peak population has been revised to 710,000. a move in the rioht direction but still lowen fl'an trallic counts and local business liouncs indicate. Perhaps our best corRment on the population figures is'that they can only be an estinte and they will ve.ry widely from day to day, ekpecially on sunner weekends.
4 Otjer problems remain. Veru serious are the estintes of the number 1
_of pergonnel recuined to cUect an orderlu~ evacuation. Each of oun departr; tnt heads careed &at he lacks suf ficient n1npower to carru out _the l
, l>t each has been told.to request additional help from Ge State.'
advice appears to have been given to each town in the zone; obviously Gere dill not be enough workers to go around. As a collary to de number { required, there are no provisions for securita lor workers' homes end families nor does ~there seen to be provision for specialized equiptrent other than dosbncters. It is unclear if G e count on dosix;ters is a State :atal or a town by tow:1 total, as our radiological -
\ offic{r said &at he could obtain all the equiptnent needed in a matter l of a lieza hours. Is more protective apparatus, such as suits or gloves
- l e or breat.hing apparatus, needed?
\ .
Another serious consideration is the lack ci cormunication and co9AdinaQon in moving school children out af Ge area. On October 3 de statesv.nt uns made that crurt vefense is working with school of ficials; 1
8601230471 s51029 3 DR ADOCK O
- -- ~. ~ ,a r. .....r,s...... . ..
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October i 915 Honorable John Sanunu -
Page Two .
cur ' local mperintendent had received a copy of &c plan the pacvious day.
There are nn;r onoblems; number of buses availabic (for 16 towns),
availability of sufficient taus drivers, traffic probicas caused by ~
parents trying to get to schools to pick up their own children, formt sioned carecments with bus comoanics. An added prcblem saith buscs is -
he numbes of non-auto ownino residents who would need transportation, and TdEtioners who are at the beach wiucut automobiles. :
There seem to be severe inconsistencics in &c amount c1 umn<ng V time cuellabic to accomplish evacuation. Can cotmunitics rett) on de W figurc Gat uns presented in August as the time we would have l i
to act? The mximm ficun_c oiven to move the nomferion out (7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> ;
'and 40 minutesh <s St.ven for a sunner vooulation on a bad weather day; my we suggest that a sunscr population on a very hot Sunday is likely I to be larger and pose potentially more traffic problcms, bon with overheated cars and tempers? 'l
. We are not qualified to coment on the adequacy of mom buildings on ?
Kampton Scach for shcltering, if that should be ne preferred action.
Houxer, the plan completelt) ignores that there my be ucus:nds of beach goers clad only in bething suits during a radiological accident.
Last a.:d vita!!g important is de ornblem of roads leadino out of Hamoton. The Church Strect access to Route 51 and Gence to Route 101 rs inadequate for the "norml" non-panicked population. Route 1 is already cucr-load.cd with daily winter traffic. All towns in the arca will rely on these routes to get to 105; it simply cannot be done ,
safely or quichbj. Nuclear plant cumers and reculators have known for over
- six ycnns that evacuation plans would be neces5ry; during Gat time no schmuswork has been done on Scacoast roads nor do there scca to' be
- plans to improve these roads significantly.
In conclusion, this plan scens to be w:itten prinurity to justify i the requirement Gat a plan exist rather than to mke a serious attempt !
l to evacuate an endangered citizcncry. Uc. have touched on what seem to us , to be prinary and basic weaknesses. Added to u cse is d e general distrust of our citizens towards the owncrs of de plant, occasioned by inconsistencics between promises unde and results delivered during the construction process.
t Nc would respectfully urge Gat you consider not approving this l Pl an; but if you mst, that you do wig Ge understanding dat you are opposing ue recomendation of de mjority of the Hampton Board o f Selectmen. Thank you for your consideration.
~
cc: Richard Strone F 3
[SE4F4IMCC4CIe Gerarld Coogan <
William Cahill , . . ?. A". 6- ^ ~ = .
Robert Preston \ '
jot 1n R. Walker
- State Representatives ',- ,. s gL >),.,a,J Arca Toums t '
Ansell W. Palacr L % a. 2. Gp . u n -u -
Dona R. Janctos
.,,o CERTIFICATE OF SERVICE AND SERVICE LIST p r m.
Joseph Flynn Asst.Gn.Cnsl. Helen Hoyt-~. Chm. , ,ygrhomas Dignan, Esq . :*
Fcd. Emerg. Algmt . Agcy. Admn. Judge Ropes'& Gray 500 C.St. So. ' West . Atomic Safety & Lic Brd. 225 Franklin St.
Washington, DC 20472 USNRC '86 KC 40s#bi43 MA 02110 Washington, DC 20555 Office of Selectmen .Dr. Jerry Harbour * [fkTbi)hcIli tfing & Serv. Sec.c Town of Hampton Falls Admin. Judge BRAOffice of the Secretarg Hampton Falls, NH 03844 Atomic Safety & Lic Brd. USNRC USNRC Washington, DC 20555 Washington, DC 20555
- " ' E9' Dr. Emmeth A. Luebke
- Jane Doughty Office of Exec. Legl. Dr. Admin Judge SAPL USNRC Atomic Safety & Lic. Brd. 5 Market Street Wahsington, DC 20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 Phi 11ip Ahrens, Esq. Paul McEachern, Esq. George Dana Bisbee, Esq.
-Asst. Atty. General Matthew Brock, Esq. Attorney General.'s OFF.
State. House, Sta. #6 25 Maplewood Ave. State of New Hampshire Augusta, ME 04333 P.O. Box 360 -Concord, NH 03301 Portsnouth, NH 03801 Carol Sneider, Esq., Asst.AG Diane Curran, Esq. )Villiam S. Iord One Ashburton Place. Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.
Boston, MA 02108 Washingcon, DC 20009 Amesbury, MA 01913 Richard A. Hanpe,.Esq. Maynard Young, Chairman Sandra Gauvutis New Hampshire Civil Defense Board of Selectnen Town of Kingston Agency 10 Central Road Box 1154 Hampe & McNicholas Rye, NH 03870 East Kensington, MI 03827 35 Pleasant St.
Concord, NI 03301 Edward 'Ihomas Mr. Robert Harrison FEMA Pres. & Chief Exec. Officer 442 J.W. McConnack (POCH) PSCO Boston, MA 02109 P.O. Box 330 Manchester, NH 03105 Roberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, MI 03844