ML20215M467

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Motion to Hold Offsite Emergency Planning Proceeding in Abeyance Until Emergency Plans Submitted for Entire Emergency Planning Zone.Supporting Documentation Encl. Certificate of Svc Encl
ML20215M467
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 10/28/1986
From: Curran D
HARMON & WEISS, PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Atomic Safety and Licensing Board Panel
References
CON-#486-1297 OL, NUDOCS 8610300267
Download: ML20215M467 (26)


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," /JL(?17 October 28, 1986 00CMETED USMC UNITED STATES NUCLEAR REGULATORY COMMISSION 16 0CT 29 P3 :39 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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Public Service Company of )

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

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

) PLANNING

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NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S MOTION TO HOLD OFFSITE EMERGENCY PLANNING PPOCEEDING IN ABEYANCE Introduction In January of 1986, the Licensing Board convened a pro-ceeding on the adequacy of radiological emergency response plans for the New Hampshire sector of the Seabrook emergency planning zone ("EPZ"). At that time, it was expected that the Common-wealth of Massachussets would also submit emergency plans for the Massachussets sector of the EPZ. However, given the Governer of Massachussetts' recent announcement that he will not submit emergency plans for the Commonwealth of Massachussetts, and the failure of the Applicants to provide any alternative means of meeting the NRC's rules, there is currently no basis upon which the Applicants can claim to meet the Nuclear Regulatory Commis-sion's ("NRC's" or " Commission's") emergency planning regula-tions. Thus, no valid purpose can be served by continuing to litigate the New Hampshire plans in isolation. Moreover, even if Applicants were to submit their own plan for the Massachussets portion of the EPZ, the New Hampshire and utility plans must be 8610300267 561028 DR ADOCK05000gg3 {Q

litigated jointly, in order to adequately assess their degree of coordination. Therefore, the New England Coalition on Nuclear Pollution ("NECNP") moves the Licensing Board to hold the offsite emergency planning proceeding in abeyance until such time as emergency plans have been submitted for the entire emergency planning zone.

Factual Background In January of 1986, the Licensing Board reconvened the of fsite emergency planning proceeding to consider Revision 1 of the Radiological Emergency Response Plan for the State of New Hampshire. Contentions and summary disposition motions were filed with respect to Revision 1. In July of 1986, the Licens-ing Board suspended hearings scheduled for August, after it be-came apparent that the New Hampshire plans must be substantially reviced and resubmitted.

The State of New Hampshire submitted a second revision to the New Hampshire emergency plans in September. The parties are now awaiting the Board's response to Applicants' September 25, 1986, motion for a decison on pending summary disposition motions and for the establishment of a hearing schedule on New Hampshire emergency planning issues.

Although plans for the State of New Hampshire are under lit-igation, no emergency plans for the Commonwealth of Massachusetts have been submitted. Moreover, the Governer of Massachusetts has explicitly stated that, on the basis of his determination that the Seabrook plume exposure EPZ cannot be evacuated safely, he will not submit emergency plans for the Commonwealth of Mas-sachusetts. Statement of Governer Michael S. Dukakis Regarding

the Seabrook Nuclear Power Station, Se ptember 20, 1986, attached as Exhibit 1. Thus, there is currently no prospect that emergency plans will be submitted by the Commonwealth for the Massachusetts sector of the Emergency Planning Zone, which com-prises approximately a third of the Seabrook EPZ , at any time in' the reasonably foreseeable future. Nor have Applicants at-tempted to demonstrate any alternative means of satisfying the commission's emergency planning regulations.

Argument In order to obtain an operating license for Seabrook, Ap-plicants must submit and the Licensing Board must approve emergency plans for the entire emergency planning zone. Th is re-quirement is is " central" to the development of offsite emergency response plans. Pacific Gas & Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-781, 2 0 NRC 819, 829 (1984). Thus, even if the Licensing Board . approves a set of emergency plans for the State of New Hampshire, Applicants will not be entitled to an operating license unless emergency plans covering that portion of the EPZ within Massachusetts are also submitted and approved. As a result of the Governer of Mas-sachusetts' refusal to submit emergency plans for his state, Ap-plicants cannot even begin to meet the most basic licensing re-quirements for Seabrook.

In the absence of any discernible means by which Applicants can obtain approval of emergency planning for the Seabrook EPZ, no valid regulatory purpose can be achieved by continuing to litigate the adequacy of plans solely for the New Hampshire sec-tor of the EPZ. The offsite emergency planning proceeding should

therefore be held in abeyance until Applicants have demonstrated l

some means by which they might achieve compliance with the regulations.1 Moreover, if there is any truth to the rumors that Ap-plicants plan to submit a "Shoreham" type plan in which New Hampshire Yankee employees would carry out an emergency response in the Massachussets sector of the Seabrook EPZ, it is imperative that this proceeding be postponed until Applicants' plan is sub-mitted, so that the parties can address the planning process for the emergency planning zone as a whole. The vital importance of coordination of emergency planning efforts where a utility has submitted its own offsite emergency plan was recently addressed in Long Island Lighting Co. (Shoreham Nuclear Puser Station, Unit i

1), LBP-85-31, 2 2 NRC 410, 4 28 (1985) . In retaoing to approve LILCO's emergency plan for the Shoreham EPZ , the Licensing Board observed:

To achieve an effective emergency response, the Commis-sion's emergency planning regulations and guidance pro-vide for a cooperative, comprehensive, preplanned, and implementable effort on the part of the utility, the State, and the local government. The Shoreham emergency plan lacks such an integrated approach. He re each entity is free to go its own way during an emergency. This is the antithesis of what the regulatory scheme calls for to achieve a satisfactory emergency response.

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Applicants are entitled to attempt to demonstrate that the total lack of emergency plans for Massachusetts is not a "significant" defect in the license application, or that there are " adequate interim compensating actions," or that there are .

other " compelling reasons" to permit plant operation. See Long l Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1),

C L I- 8 6-13 24, 1986), slip op. at 10, citing 10 CFR S 50.47(c)(1)(JulyIlowever,

. Applicants have made no attempt to satisfy that standard.  !

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The Commission has affirmed this concept, observing that "The emergency planning standards in 10 CFR 50.47(b) a nd Pa r t 5 0, Ap-pendix E are premised upon a high level of coordination between the utility and State and local governments."2 Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), CLI-86-13 (July 24, 1986), slip op. at 10.

If Applicants were to submit their own emergency plans for Massachussetts, the coordination of emergency planning would be no less important an issue than at Shoreham. In fact, coordina-tion of emergency planning would pose even more serious and com-plex problems at Seabrook than at Shoreham. While the Long Is-land Lighting Company must coordinate its planning efforts with only one state and one county government, New Hampshire. Yankee would have to coordinate its efforts between two state go-vernments and more than twenty local governments. Thus, the issue of ' coordination between New Hampshire Yankee, New Hampshire, and Massachussets would assume primary importance in any emergency planning litigation.

It is clear that the New Hampshire plans could not be evaluated in any meaningful way without reference to the issue of l

In Shoreham, the Commission of fered LILCO the opportunity to demonstrate that its own plan could " pass muster" in spite of the lack of governmental cooperation in the emergency planning proc-oss. Slip op. a t 10, citing 10 CPR S 50.47(c) . In this case, New Hampshire Yankee would be required not only to show that its own emergency plan compensated for the lack of cooperation by the Commonwealth of Massachussets, but that its dual emergency response roles for the Seabrook plant and for the Commonwealth of Massachussetts were fully coordinated with the State of New Hampshire's response.

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coordination between all state and local governments and New Hampshire Yankee. For instance, it would be impossible to l

. evaluate the adequacy of support provided by New Hampshire Yankee i

to the New Hampshire emergency response without some understand-ing of the extent of New Hampshire Yankee's responsibilities for i l

an emergency response in Massachussetts. Any evacuation of the Seabrook emergency planning zone would also raise complicated is-1

,! sues regarding the routing of evacuees through two states, the I

response of the Commonwealth of Massachussetts, and the sub-1
stitute response of New Hampshire Yankee. The adequacy of the  ;

i l j New Hampshire plans cannot be determined in isolation, without l l

reference to these issues.

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Conclusion In consideration of the absence of comprehensive plans for the Seabrook EPZ, and of the vital importance of evaluating the capability of planning entities to integrate.an emergency

, response for the entire EPZ, no productive purpose can be served' by continuing to litigate the New Hampshire emergency plans in an isolated setting. NECNP therefore moves that the Licensing Board hold the offsite emergency planning proceeding in abeyance until emergency plans have been submitted for the entire Seabrook EPZ .

Respectfully submitted, Diane Curran HARMON & WEISS 2001 "S" Street N.W. Suite 430 Washington, D.C. 20009 (202) 328-3500 October 28, 1986 i

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ST.\TEME?IT OF GOVER:OR MICHAEL S. DUKAKIS REGARDI!!G TFE SEABROOK !!UCLEAR POWER STATION Sectenber 20, 1996 Under federal statutes and regulations I am called upon as Governor of Massachusetts to play a particular role in the licensing process for the proposed Seabrook Nuclear Power Station. After lengthy and painstaking review of all the pertinent information, and careful analysis of the applicable standards, I have reached a decision, which I an announcing today.

The Historical and Regulatory context

  • The Commonwealth's involvement in the licensing of Seabrook actually extends back very far. In 1975, when the construction license for Seabrook Station was under consideration, Attorney General Frank Bellotti, appearing in opposition, issued ustninas that have proved prophetic. F first told the federal regulators and then the federal courts that siting a nuclear power plant at Seabrook ignored considerations of public safety. Pointing to the proposed plant's proxinity to the crowded beaches at the :tew Hampshire and Massachusetts border, the Attorney General argued, as he has for nearly twelve years, that the lack of shelter for the beach population and the o inadequate highway system in the area nade protection of the public in th case of a serious accident a near 1. possibility.

To prevent huge financial resources from being irretrievably committed to a plant that might never be licensed, he urged the federal authorities not to proceed. Despita the Commonwealth's strenuous argument that the choice of site was a monumental e

error in judgment, construction was permitted.

At the time, prior to the 1979 nuclear accident at Three Mile Island, the local health and safety concerns raised by the Attorney General were,. at best, peripheral factors in the federal licensing equation. Three Mile Island, however, brought a long overdue, rude awakening. It became clear that federally mandated planning for an emergency was wholly inadequate, and that health and safety were being seriously jeopardized.

One outgrowth of the accident was reassessment of the prospects for nuclear energy itself in light of the risk. No new plant has been approved for construction since Three Mile Island. Only the few plants already in construction in 1979, of which Seabrook is one, remain to be considered for final operational licensure. It is by now beyond question -- given the escalation in cost and controversy -- that if we were to be given a second chance to avoid construction altogether, no e prudent person would in hindsight choose Seabrook.

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For those plants already in operation and those approved for construction, the federal governnent responded to Three Mile Island by r.aking off-site energency planning a prinary statutory requirement. On this issue, the inportance of state and local participation was explicitly acknowledged by Ccngress with the requirenent that "there nust exist a state, local or utility plan which provides reasonable assurance that publ.:

health and safety is not endancered by the operation of the facility."

In the words of the  ::uclea r Regulatory connission, "no operating license . . . will be issued unless a finding is nade that there is reasonable assurance that adequate protective

, neasures can and will be taken in the event of a radiological energency'." Federal agencies look first to the state through its Governor to make this determinatien. I must judge whether a plan can be devised which "in the opinion of the state is adequate to protect the public health and safety of its.

citizens living within the energency planning zones" -- a radius typically of ten miles -- by providing " reasonable assurance that state and local governnents can and intend to effect appropriate protective reasures offsite in the event o f-a radiolocical enercency." The standard for the Governor, as ,

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it should be, is thus not only one of intent but of tha feasibility of proposed protec- le neasures.

The Applicable Standards i

To assist in a state's approach to energency planning, federal agencies responsible for nuclear plant licensing have set forth comprehensive standards and guidelines. It is those rules that I an obliged to follow in exercising my judgment u Governor. To begin with, it is clear from the guidelines that several factors which have a significant relation to health and safety are beyond the purview of the Governor. Such on-site factors as design of the reactor, strength of the containnent vessel, quality of management, and quality of reactor operator training are all important to protection of the public.

Nonetheless, under federal law these are questions exclusively for the !!u cle a r Regulatory Conmission. My judgment is not to be influenced by the evidence on these issues. Indeed, the statistical probability of a serious nuclear accident as distinguished from the adequacy of the response is not a proper part 'of the state's deliberations.

Instead, I an mandated to bas,e my judgnent regarding health and safety on several assunptions stated in the federal c guidelines. As a general matter I am directed that no single specific accident sequence should be isolated as the one for which to plan because each poten-'al accident could have

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state, "the as the guidelines Rather, zero consequences. starting with a Jifferen: is very large,

. to planning for the fange for planning purposes all . .

low requiring no planning at its extremely of of point regardless accident, federal guidelines worst possible um, Uithin this mandated spectrthings that an accident likelihood." assune among other minutea, to thirty dieect Governors release within with offsite 1hile the could occ:: within two hours.

radius of five niles specificsily a assumed is not reaching to he of of the release a release seriousness include appear to the assumptions at Chernobyl, without stated, to that caterial similar radioactive e of the release.

regard to the particular caus ht of emergency clanning is t a the central tenet federal process In summary, in the occur.

My limited role to deal with an accident can energency response plans attempt to devise is to does happen.

such an event if it

. for my review and Cherno5vl is the context for of the in general terms assistance This with the a Last spring, weeks of reaching planning. a ~ few was within on state Then, Attorney General, I '

emergency plans.

offsite Chernobyl !!ucle a r submission 'of at the decision on occurred 'the accident which constituted April 26, 1986, an Ukraine, in the Soviet Power Station

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world's first actual nuclear power catastrop';, with substantial loss of life, widespread exposure to radiation, and serious danage to the environment. We have learned that the i

radioactive release at Chernobyl was several million times e

greater than Three Mile Island. Until Chernobyl planning and judgment relating to major accidents were essentially based on computer nodels and mathematics. Chernocyl represents real experience, a test of the experts' predictions and an opportunity to derive potentially important lessons about i planning for Seabrook.

O I asked Dr. Albert Carnesale of Harvard University's Kennedy School of Government, president Carter's nominee to I head the t*uclear Regulatory commission, to analyze the Chernobyl accident, and to advise ne regarding the applicability of the Chernobyl experience to Seabrook.

Dr. Carnesale has devoted several nonths, without compensation, 4 to this task. All citizens of Massachusetts owe him a debt of gratitude for his careful objective analysis.

As it turns out, there are fundamental lessons to be learned fron Chernobyl, directly applicable to ay decision on

.ceabrook. As Dr. Carnesale has told me, in a field as y l

intensely studied as this, uhat is to be learned is not entirely new, but tends to tell us more directly than computer

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r models ever could which factors could prove pivotal in an accident and where emphasis must be placed in planning.

It has been debated as to whether Chernobyl offers any lessons for design of nuclear plants, in light of the fact that the Chernobyl reactor reflects a design philosophy far different from and inferior to those used in this country. But under federal guidelines, that debate is not relevant to y decision. It is the aftermath of the accident -- the impact of the radioactive release and the hunan response to it -- that we nust analyze for guidance. And in this realm Chernobyl has-nuch to say. As Dr. Carnesale has put it, the . accident confirns beyond question that adequate offsite planning is essential and must be taken very seriously.

The overriding characteristic of the Chernobyl accident is that, as bad as it was, it could ha. been far worse. First, the geographical and weather conditions at Chernobyl reduced.

"he threat to life by dispersing the release over a renarkably large' area, extending in diffuse form to places remote from the plant, rather than depositing lethal concentrations in population areas close to the plant. The flatness of the-Ukrainian plains where Chernobyl is located, and the hot, dry .

climatic conditions prevalent in that area tended to keep the radioactive debris aloft for relatively long periods of tine.

Second, the nature of the explosion and the theracdynamic effects of a graphite reactor fire as occurred at Chernobyl meant that the altitude reached initially and thereafter o

maintained by debris coming out of the reactor was quite great, about 4,000 feet. This contributed independently to the subsequent dispersion of radioactive material over a wide area. Because graphite is absent from its design, it is expected that serious releases from a plant like Seabrook till rise to and be naintained at lower altitudes and therefore be deposited over a snaller area, even under favorable geographic and weather conditions.

3 Third, the combination of clear, constant weather and a high altitude release permitted Soviet authorities to predict the direction of the radioactive plume and to execute a j well-timed, coordinated usage of sheltering and evacuation of 135,000 residents within 18 miles that would prove virtually impossible in circumstances where time is short and the path of the plume uncertain.

Fourth, Chernobyl makes absolutely plain tha; adequate sheltering is essential to emergency planning. The 45,000 c residents living in the immediate vicinity -- within two miles received relatively low dosages of radiation bec,ause of the 4

9-superior protection provided by the concrete block construction of their homes, during the hours that authorities were monitoring the pathway of the plume and mobilizing their forces a

for efficient evacuation. Some area residents who were not 's o e

fortunate to live in the concrete block cone:ruction of Pripyat, even though farther away from the accident, suffered far higher dosages, at levels considered unacceptably high for planning purposes by federal agencies. Thus, even in the even:

of a catastrophic accident we learn fron Chernobyl that immediate evacuation may not be a proper response, particularly where the path of the plume is unpredictable. What may well be needed is temporary sheltering throughout the emergency planning zone, followed by evacuation away from the plume.

Perhaps the most humbling lesson of C.ernobyl is that the human factor defies logic and computer modeling. Despite the time available to mobilize for evacuation, and despite the totalitarian efficiency with which the evacuation was executed-(the town of Pripyat was evacuated in two and a half hours) it nonetheless took up to a week to evacuate thousands of persons within a radius equivalent to the federal emergency planning zones, because authorities had, not counted on people's' unwillingness to leave their farms and livestock and their e refusal to cooperate despite the risk.

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There are other useful dinensions of the Chernobyl experience, but these in particular help light our way. The single overriding lesson is that hunan catastrophe can be 8

avoided only if circunstances permit ad quate energency planning and response. Virtua11v every element of the offsite energency response called for in federal regulations was utilized at Chernobvl, and nost of then proved effective --

whether by luck or by good planning.  ?:onetheless, ds . spite *"o

. quality of the resconse, it was only because of the additional natural or fortuitous circunstances such as weather, geography, ,

and altitude of the plume, that note extensive inmediate an?

long tern injury was avoided. Chernobyl was in nany ways a "best case scenario" for energency response.

Fonetheless, even under these conditions, thousands of residents within five miles of the plant suffered radioactive dosages at least eight times greater than the threshold set forth in federal guidelines for innediate evacuation and 200 tines greater than nornal annual background exposure. Also, the mitigating circunstances that acconnanied the accident and its inmediate aftermath did not spare the countryside around Chernobyl fron distressing long-tern effects. Evidence <

suggests that areas conprising hundreds of square miles nay remain uninhabitable for four years. '"h e inpact of such depopulation on public health and safety, not to mention the

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l area's economy and its basic community fabric, are beyond l l calculation.

Seabrook Turning to Seabrook, the question is whether, taking into account conditions of nature and other related conditions over which we have no control, our emergency response could, if executed competently,-prove adequate to avoid serious and real endangerment of the surrounding population. Certainty on this score is, of course, impossible. He must nake our best judgment on the available evidence.

Conditions at Seabrook, viewed through the Chernobyl lens, compel me to conclude that, under the federally imposed 1

assumptions, adequate plans cannot be devised. At Seabrook,.we need not speculate about weather conditions. They are at the Winds other end of the spectrum from Chernobyl. are not constant, but rather constantly changing, influenced by land and sea. Winds are generally prone to change direction in less than

  • an hour at any time. Moreover, the climate is not dry, I but marked by extended periods of precipitation during the 1

year. Since, as Dr. Carnesale advises, we can expect a much-lower plume altitude than occurred at Chernobyl, the exposure ,

of the immediate population foreseeably could be far higher, and rather than moving out quickly, the plume foreseeably could r

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churn in the immediate area for a substantial time. :n rainy conditions the situation could only worsen and among other thincs nake evacuation itself very difficult.

I The changing weather takes its toll not only in immediate exposure to radioactivity but also in the difficulty of monitoring the plume, in predicting its co .se and in executing evacuation plans so as to nove the population away from the plume rather than into it. Thus, it can be foreseen that, u ue wait to deternine proper evacuation pathways, exposure will be heavy in the immediate area. Yet if we evacuate quickly to avoid that heavy exposure, we may well nake matters worse.

These factors combine to suggest that staying within the emergency planning zone may, on balance, prove less harmful than evacuating, at least for a period of several hours.

Taken together, these considerations could well require us to place great reliance on temporary sheltering in the immediate vicinity, just as was done at Chernobyl. Yet it is very' clear that the extent and quality of sheltering is inadequate a"t Seabrook. Whereas the concrete block residences in Pripyat were apparently ideal, the woodframe residences that are typical around Seabrook sare far from ideal. This, in my ,

view, presents a serious problem year r..nd. However, sheltering is beyond question inadequate in the summer months, 1

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when the extensive non-resident beach population comes within the emergency planning zone. For them the absence of shelter is disastrous, e

All these factors make particularly important expert testimony prepared by Attorney General Bellotti which shows that if a major release occurred at low altitude and under weather conditions common to the Seabrook site, and if evacuation time were over five hours, many persons within two miles of the plant could suffer exposure to life-threatening dosages of radiation as they sat in their cars, and widesoread exposure to such dosages could occur in a radius extending beyori four miles.

Under' favorable conditions it is estimated that evacuation of the Seabrook emergency planning zone would in fact take over five hours at a minimum, during which time potentially lethal radiation exposure would be occurring, and sheltering would be-inadequate. If underlying conditions were less favorable and evacu'ation faltered, the toll could only worsen. This in my view is not a hypothetical worst case, but a foreseeable situation under the initial set of assumptions I am told to' make. .

s, Mention must also he made of the human factor. Certainly, the reluctance of many Ukrainians to be evacuated by authorities after Chernobyl has no innediate parallel at

. Seabrook. But in a general sense it underscores how inportant cooperation is if we are to translate plans into actual operation. On this score it is relevant that the towns in

  • !assachusetts within the emergency planning zone are against licensing, for reasons which even proponents of licensing nus respect as honest and sincere. I have continually taken the view that these residents' views must he considered. I have also made clear that if adequate plans could be developed, I would feel myself chligated to subnit then despite local opposition. However, such plans rely on previously trained local residents and nunicipal employees working efficiently and with detailed knowledge of their assigned roles in the evacuation process. In circumstances uhere : an in serious doubt about whether adequate plans are possible, these doubts are only compounded by questions about wheth?t the necessary singl,eminded execution, which is absolutely essential for even marginal sucgess of the best of plans, can be achieved at

.ieabrook. The unpredictability of the hunan factor in this instance weighs against the ability to achieve an adequate plan. It leads me to a belief that apart from all other problems, efficient evacuation is not likely.

conclusion Ultimately, the questicns of whether reasonable assurances can be given is a natter of judgnent. I must nake my best judgment based on knouledge and good conscience. In due course the truclea r Regulatory Commission will make its judgment, and alnost inevitably, whatever the Cornission's decision, federal judges will be called upon in sone nanner as well. All the evidence I nossess tells ne that while there is room far reasonable disagreement on details, the unshakable fundamental truth is this: if a serious accident occurs as I am told to assume it would, the conbination of conditions at Seabrook --

including principally weather, inadequate sheltering and exit toutes, and the altitude of the radioactive plume' -- either individually or more likely in combination. create a foreseeable likelihood of high dosages of radioactive intake, against which energency planning and evacuation cannot adequately protect.

Under such circumstances I do not believe I as Governor can responsibly submit emergency plans, since they could not constitute appropriate orotective measures adequate to protect the oublic health and safety in the event of a radiological energency, as federal law requires. I therefore do not intend

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to do so.

Future Energy Needs_

The decision I have made today is based, as a natter of i federal law and regulation, on one factor alone --

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assessment of the adequacy of emergency plans for the t

Massachusetts portion of the Seabrook emergency planning zone.

Nonetheless, having made my decision, I cannot ignore the concerns which the potential non-licensure of the Seabrook station may pose for the future of its owners and investors, the energy picture in New England, and our region's economy.

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tassa chuset t s stands ready to assist the owners of Seabrook and the State of New' Hampshire to explore fully and creatively the option of converting either of both Seabrook units to a fossil fuel base. Such conversions are now well into the planning stage at the Midland plant in Michigan and the Zinner plant in Ohio. Without question, serious issues of economic

, feasibility and accessibility of fuel supply would face any Seabrook conversion. But preliminary indications are that the engineering itself is' feasible, and the potential resource of 1500-3000 megawatts is well worth the effort to fully det ermine its overall feasibility.

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Moreover, as Chairman of the New England Governors, I have

.cined my colleagues in a full review and update over t.:e past nine months of energy forecasts and policies for our six-state

Jion. It is o u r-- intention to produce, as early as our meeting of this coming December, a comprehensive plan for e w England's energy future. Within that approach I expect that we will emphasize such power sources as the purchase of additional power from Canada; the building of a number of smaller, gas-fired generating plants; the creation of new power through cogeneration and so-called "small power" facilities; conservation and land management; and the retrofitting of existing facilities currently slated for retirenent.

I am confident that, working together, the economic and governmental leadenhip of New England will build a strong energy future that need not rely on the operation of Seabrook as a nuclear generating station.

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CERTIFICATE OF SERVICE I certify that on October 28, 1986, copies of NEW ENGLbNQit:.

COALITION ON NUCLEAR POLLUTION'S MOTION TO HOLD OFFSITE EMERGENCY PLANNING PROCEEDING IN ABEYANCE were served on the following by first-class mail:

  • 26 m:I29 P3@0 Helen F. Hoyt, Ch airman Rep. Roberta C. Pqyp,ar c ,. , r Atomic Safety and Licensing Board Drinkwater Road 00CKET mG . M "VII.

U.S. Nuclear Regulatory Commission Hamp ton, Falls, NH 0 3 8'4'4NC" Washington, D.C. 20555 Phillip Ah rens, Esq.

Dr. Jerry Harbour Assistant Attorney General Atomic Safety and Licensing Board State House, Station # 6 U.S. Nuclear Regulatory Commission Augusta, ME 04333 Washington, D.C. 20555

, Thomas G. Dignan, Es q .

Dr. Emmeth A. Lu ebke R.K. Gad II, Esq.

Atomic Safety and Licensing Board Ropes & Gray U.S. Nuclear Regulatory Commission 225 Franklin Street Washington, D.C. 20555 Boston, MA 02110 Atomic Safety and Licensing Board Robert A. Backus, Es q .

Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory Commission 111 Lowell Street Washington, D.C. 20555 Manchester, NH 03105 Atomic Safety and Licensing Appeal Ro be r t G . Perlis, Es q .

Board Panel Sherwin E . Turk, Esq.

U.S. Nuclear Regulatory Commission Of fice of the Executive Legal Washington, D.C. 20555 Director U.S. Nuclear Regulatory Commission Docketing and Service Washington, D.C. 20555 U. S . Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Angie Machiros, Chairman Board of Selectmen Mrs. Anne E. Goodman Newbury, MA 01950 Board of Selectmen 13-15 New Market Road H. Joseph Flynn, Esq.

Durham, NH 03842 of fice of General Counsel

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Federal Emergency Management Agency William S. Lord, Selectman 500 C Street S.W.

Town Hall -- Friend Street Washington, D.C. 20472 l

Amesbury, MA' 01913 l George Dana Bisbee, Es q.

l Jane Doughty Stephen E. Merrill, Esq..

S AP L - Of fice of the Attorney General 5 Market Street State House Annex i Portsmouth, NH 03801 Concord, NH 03301

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o o a Carol S. Sneider, Esquire Allen Lampert Assistant Attorney General Civil Defense Director Department of the Attorney General Town of Brentowood 1 Ashburton Place,19th Floor Exeter, NH 03833 Boston, MA 02108 Richard A. Hamp e, Esq.

Stanley W. Knowles Hampe and McNicholas Board of Selectmen 35 Pleasant Street P.O. Box 710 Concord, NH 03301 North Hampton, NH 03826 Gary W. Holmes, Esq.

J.P. Nadeau, Selectman Holmes & Ellis Town of Rye 47 Winnacunnent Road 155 Washington Road Hampton, NH 03842 Rye, New Hampshire 03870 William Armstrong Richard E. Sullivan, Mayor Civil Defense Director City Hall 10 Front Street Newburyport, MA 01950 Exeter, NH 03833 Alfred V. Sargent, Ch airman Calvin A. Ca nney Board of Selectmen City Manager Town of Salisbury, MA 01950 City Hall i 126 Daniel Street Senator Gordon J. Humphrey Portsmouth, NH 03801 U.S. Senate Washington, D.C. 20510 Matthew T. Br o ck , 'Es q .

(Attn. Tom Burack) Shaines & McEachern P.O. Bo x 3 60 Selectmen of Northampton Maplewood Ave.

Northampton, New Hampshire 03826 Portsmouth, NH 03801 Senator Gordon J. Humphrey Edward A. Thomas 1 Pillsbury Street Federal Emergency Management Concord, NH 03301 Agency 442 J.W. McCormack (POCH) l Michael Santosuosso, Ch airman Boston, MA 02109 Board of Selectmen Jewell Street, RFD # 2 Sandra Gavutis South Hampton, NH 03842 Town of Kensington l RFD 1 Box 1154

( East Kensington, NH 03827

! Diane Curran

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