ML20214P427
| ML20214P427 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/28/1986 |
| From: | Lord W AMESBURY, MA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#486-1711 82-471-02-OL, 82-471-2-OL, OL, NUDOCS 8612040197 | |
| Download: ML20214P427 (8) | |
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/u E Amebury Board of Selectmen Town Hall, Amesbury, MA 01913 Tel. 388-0290 BEFORE THE ATOMIC SX/ETY AND LICENSING BOARD In the matter of
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Docket Nos. 50-443-OL
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50-444-OL PUBLIC SERVICE COMPANY
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(ASLBP No. 82-471-02-OL)
OF NEW HAMPSHIRE, et al.
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Offsite Emergency Planning
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(Seabrook Station, Units 1 & 2)
)
November 28, 1986
'IOWN OF AMESBURY'S CONTENTIONS OF NHRERP VOLUME 6, SEABROOK STATION EVACUATION TIME STUDY (IDENTIFIED AS APPENDIX E IN IDCAL PLANS)._
Contention #1.
The Town of Amesbury (TOA) contends that the NHRERP, Volume 6, Seabrook Station Evacuation Time Study (hereinafter the KLD ETE) as servhil on the parties September 8, 1986, violates 10 CFR 50.47 (a) (2).
Basis. Since the KLD ETE was not adopted by the State of New Hampshire until April 7,1986, and therefore did not exist during the FEMA exercise of February 26, 1986, there was no demonstration of "... reasonable assurance that [the NHRERP) can be implemented...".
j Contention #2.
The TOA contends that the KLD ETE violates the i
planning utandards of NUREG 0654, Appendix 4, II-A.
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Basis. The perminent population estimates as found in KLD ETE are substantially different from the actual perminent population of the EPZ (see population totals / tables in KLD ETE Fig. 10-5; 10-6A,B,C; 10-7A,B,C; 10-8A,B,C; 10-9A,B,C; 10-10; 10-llA,B,C;10-12A,B,C; and 10-13A).
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Contention'#3. The TOA contends that the KLD ETE violates the planning standards of NUREG 0654, Appendix 4, II-B.
Basis. The transient population estimates as found in KLD ETE are substantially different from the actual transient population of the EPZ.
Contention #4.
The TOA contends that the KLD ETE violates the planning standards of NUREG 0654, Appendix 4, II-C.
Basis. KLD ETE fails to accurately estimate the population of all special facilities within the plume exposure EPZ.
Contention #5.
The TOA contends that the KLD ETE violates the planning standards of NUREG 0654, Appendix 4, II-C.
Basis. KLD ETE fails to individually describe the means of transportation for all special facilities within the plume exposure EPZ.
Contention #6.
The TOA contends that the KLD ETE violates 10 CFR 50.47 (b) (14).
TheKLDbTEisamajorportionoftheNHRERPandanintegral Basis.
factor in evaluating emergency response capabilities. The KLD ETE has not been exercised with the other major portions of the NHRERP, and therefore provides no reasonable assurance of its adequacy, or of the adequacy of the NHRERP. Furthermore, the use of the KLD ETE during the exercise would have identified deficiencies in the NHRERP that may or may not be able to be corrected.
Contention #7.
The TOA contends that the KLD ETE violates 10 CFR 50.47 (b) (1), and that primary responsibilities by State and local organizations have n/t been properly assigned or established, and that there are no provisions for response on a continuous basis.
Basis. Section 9, pages 9-3 to 9-11 call for assignment of Massachusetts personnel to various access control pcints and that personnel, cones, I
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TOA, paga 3.
traffic guides and equipment will be available. Since the Governor of the Commonwealth of Massachusetts, on September 20, 1986, es t-ablished the State's position of non-implementation of any RERP, there are no personnel or equipment to fulfill the tasks as assigned in KLD ETE within the Massachusetts portion of the EPZ.
The KLD ETE attempts to integrate all response actions for the entire EPZ, it is impossible to establish a basis for reasonable assurance of plan adequacy when such a significant portion of the KLD ETE has no staffing or available equipment and will not be implemented.
Contention #8.
The TOA contends that the KLD ETE violates 10 CFR 50.47 (b) (10) which calls for a range of protective actions within the plume exposure EPZ.
Basis. The KLD ETE, as adopted by the State of New Hampshire, was not utilized as a factor in selecting protective actions during the February 26, 1986 exercise.
It is therefore impossible to determine with any reasonab'le assurance that protective actions taken based on KLD ETE information will provide for adequate protection of either emergency workers or the general public. Secondly, the KLD ETE calls for specific responses by the Commonwealth of Massachusetts. Those responses were not exercise in February 1986, nor, as outlined in the basis for contention #7, will they be implemented in the future.
Additional bases for contentions 1 - 8.
The road network data base as outline in Appendix N, p. N-1 to N-8, and as input to the computer model is incomplete and inaccurate, leading to gross underestimation of evacuation times. Because the population estimates are inaccurate, the trip generation estimates as shown in Section 2, p. 2-3 to 2-24, are unrealistically low.
Section 4, p. 4-20 describes snow clearance time distributions which are inaccurate and grossly underestimated.
.y TOA, pigs 4 ThD KLD ETE dois not tdks into account that DPW crzws era responsible for both snow removal and posting of traffic contol signs. In the event of an evacuation during a snow storm, either the roadways would not be cleared' or directional signs would not be in place. In either event, the free flow speed reduction as outlined in Section 3, p.3-1, will be considerably lower than as estimated by KLD ETE.
Because of the great number of inaccuracies found in KLD ETE, it is evident that KLD ETE can not be relied on as an effective tool for prescribing protective actions. The KLD ETE over estimates road capacities and at the same time under estimates the EPZ population and generation of trips. The road network computer model causes underestimations of evacuation times which will have a ripple effect on all other protective measures being considered during an emergency.
General Discussion. The TOA feels the above contentions meet the criteria of lateJfiled contentions, as ordered by the Board. The KLD ETE was not adopted by the State of New Hampshire prior to the March 1986 pre-hearing conference and was institutionally unavailable for filing of contentions. Having been served on September 8, 1986, much time and consultation was required for a proper-evaluation of this complex document.
Second, there is no other forum available than this licensing proceeding to determine the adaptability of KLD ETE to emergency response and implementation.
Third, the entire premise of emergency planning is based in the ability to implement. Therefore, the factors of time, population, traffic, raod capacity, etc. are integral to the process of establishing with reasonable assurance that a wide range of responses can be implemented.
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TOA, pags 5.
Fourth, no other party is directly representing the interests of residents, either perminent or transient, within the Commonwealth of Massachusetts, with respect to the facts and issues proffered by the KLD ETE.
Finally, the number of admitted contentions before the Board are very few compared to the number initially filed. The admission of the 10A's contentions should not greatly broaden the issues, nor delay the proceedings.
The TOA intends to introduce expert testimony from Robert T.
Teicher, V.P. Development, CimTelligence Corp.
Mr. Teicher has extensive' experience in computer modeling and statistics and will critique the KLD ETE to substantiate the contentions and bases as filed by the 10A.
For tb Town of Amesbury, (f r//
w William S. Iord Amesbury Board of Selectmen
x ET Amesigyes, Board of Selectmen Town Hall, Amesbury, MA 01913 Tel. 388-0290 vFF._
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.i CERTIFICATE OF SERVICE I, William S. Lord, certify that the 'IOWN OF AMESBURY'S CONTENTIONS OF h'iRERP VOLUME 6, SEABROOK STATION EVACUATION TIME STUDY (IDENTIFIED AS APPENDIX E IN IDCAL PLANS) has been served on the attached list of parties, by first-class mail, this 28th day of November, 1986.
For the own of Amesbury,
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mf William S. Lord Arnesbury Board of Selectmen l
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- f-t SERVICE LIST l Helen ~Hoyt, Chairman Philip Ahrens, Esq.
'ASLB' Dept. of the' Attorney General LUSNRC y
Augusta, ME.04333-Washington, DC-20555
' Paul McEachern, Esq.-
~45 lDr.vEmmeth Luebke (Matthew Brock, Esq.
ASLB-Shaines & McEachern USNRC.
25 Maplewood Ave.
Washington, DC 20555 P.O. Box 360 t
Portsmouth, ~NH 03801- -
Dr.. Jerry Harbour ASLB.
Mrs.' Sandra Gavutis USNRC Board of Selectmen j
Washington, DC 20555 RFD 1 -- Box 1154 Kensington, NH 03827 ASLBP USNRC Senator Gordon Humphrey Washington, DC 20555 U.S. Senate Wishington, DC 20510 ASLAB attn: Tom Burack USNRC Washington, DC 20555 Senator Gordon Humphrey
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1 Pillsbury St.
Docketing & Se-vice Section Concord, NH 03301 USNRC attn: Herb Boynton-Washington, DC 20555 Mr. Thomas F. Powers, III Robert Carrigg Town Manager Board of Selectmen 10 Front St.
-Town Hall Exeter, NH 03833
.No. Hac.pton, NH 03862 H. Joseph Flynn Diane Curran,-Esq.
Office of General Counsel
~Harmon, Weiss'& Jordan FEMA 2001 S Street, NW-500 C Street, SW' Sui e 430 Washington, DC 20472 Washington, DC 20009 Mr. J.P. Nadeau George Dana Bisbee, Esq.
Selectmen's Office Office of the Attorney General 10 Central Rd.-
25 Capitol St.
Rye, NH 03870 Concord, NH 03301-6397 Carol S. Sneider, Esq.
Sherwin E. Turk, Esq.
Assistant Attorney General
. Office of the Executive Office of the Attorney General.
Legal Director One Ashburton Place, 19th Floor USNRC Boston, MA 02108 Washington, DC 20555,
Mr. Calvin A. Canney
-Robert A. Backus, Esq.
City Manager Backus, Meyer & Solomon 126 Daniel St.
116 Lowell St.
Forstmouth, NH 03801 P.O. Box 516 Manchester, NH 03105 Mr. Angie Machiros Board of Selectmen Newbury, MA 10950 4
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SERVICE LIST.
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Mr. Peter S. Matthews, Mayor Richard A. Hampe, Esq.
City Hall Hampe & McNicholas Newburyport, MA 01950 35 Pleasant St.-
Concord, NH 03301 Brentwood Board of Selectmen RFD Dalton Rd.
Judith H. Mizner, Esq.
Brentwood, NH 03833 Silverglate, Gertner, Baker, Fine, Good, & Mizner Gary W. Holmes, Esq.
88 Broad St.
Holmes & Ellis Boston, MA 02110 47 Winnacunnet Rd.
Hampton, NH 03841 Beverly Hollijgworth 209 Winnacunnet Rd.
Mr. Edw. Thomas Hampton, NH 03842 FEMA'--Region 1 442 McCormack POCH Thomas Dignan, Esq.
Post Office Square R.K. Gad III, Esq.
. Boston, MA 02109 h
Ropes & Gray
.w 225 Franklin St.
Mrs. Anne E. Goodman Boston, MA 02110 Board of Selectmen 13-15 Newmarket Rd.
Durham, NH 03824 Michael Santasuosso Board of Selectmen So. Hampton, NH 03827 Charles P. Graham, Esq.
100 Main St.
Old Post Office Sq.
Amesbury, MA 01913 Allen Lampert CD Director Town ofiBrentwood 20 Franklin St.
Exeter, NH 03833 Ms Jane Doughty SAPL 5 Market St.
Portsmouth, NH 03801 Mr. R.J. Harrison fg#*s.
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For th Town of Amesbury, P.O. Box 330 Manchester, NH 03105 hW Roberta C.
Pevear William S. Lord H
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, NH 03844 Amesbury B ard f Sele tmen