ML20215N604
| ML20215N604 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/31/1986 |
| From: | Brock M HAMPTON, NH, SHAINES & MCEACHERN |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#486-1371 OL, NUDOCS 8611070067 | |
| Download: ML20215N604 (37) | |
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UNITED STATES'OF AMERICA N01r NUCLEAR REGULATORY-COM!!ISSI OI9864 6 b i e Before'the Muclear Regulatory Comm jon q\'
% 4 In-the matter of- Docket Nos. 50-44 50-444-OL PUBLIC SERVICE COMPANY OF MEW HAMPSHIRE Seabrook Station, Units I and II MEMORANDUM ON 10 CFR -E2.714 f a) f1) AND
' CONTENTIONS OF~THE TOWN OF HAMPTON TO NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN REVISION 2 The CONTENTIONS OF THE TOUN OF HAMPTON TO NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN REVISION 2, filed herewith, should not.be deemed " late filed" on grounds set forth in SEACOAST ANTI-POLLUTION LEAGUE, TOWN OF HAMPTON, TOUN OF HAMPTON FALLS, AND TOWN OF SOUTH HAMPTON RESPONSE TO APPLICANTS' MOTION FOR DECISION ON MOTIONS FOR
SUMMARY
DISPOSITION AND' HEARINGS AND' SCHEDULES WITH-RRRPECT TO NEW HAMPSHIRE EMERGENCY PLANNING ISSUES, dated October 6, 1986, and on grounds set forth in TONN OF HAMPTON MOTION TO ESTABLISH
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HEARING SCHEDULE, FOR ADDITIONAL TIME TO FILE CONTENTIONS AND FOR INCORPORATION OF CONTENTIONS, dated October 8, 1986. Both of these 8611070067 861031 PDR ADOCK 05000443 g PDR p .SHAINES M ADRIGAN & McEACHERN - PoortsscNat assooanoM 25 MaPLEwoOO AVENUE Po Oct 360 PORT 5WouTM NM C3eC8 L ,.----w n. .--., .. . , ,. _ ,~. .- n.-- w.~...---- --.-n.nn-.-_. - . . - . . . . . - - - - - , _
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Motions are still pending before this Board. By way of further support that the_ Contentions filed herewith should not-be deemed " late filed," the Town of Hampton relies upon MEMORANDUM ON 10 CFR 612.714 f a) (1) . AND REVISED CONTENTION III OF THE TOWN OF'HAMPTON TO EVACUATION TIME ESTIMATE REPORT BY KLD ASSOCIATES, INC., dated May 23, 1986, and previously filed with this Board. Without waiving any issues, grounds, or relief requested by said Motions, and in anticipation of Applicant's objection on this issue, the Town addresses the late filed requirements of 10 CFR S2.714 (a) (1) .1 TOWN OF HAMPTON MEMORANDUM IN SUPPORT OF " LATE FILED" CONTENTIONS OF THE TOWN'OF HAMPTON TO NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN REVISION 2 Good Cause.. " Revision 2" represents the fourth Hampton Radiological Emergency Response Plan served upon the Town by the State since January of this year. These repeated and major revisions to the Hampton RERP, three of which were served upon the Town after this Board's February 24,.1986 deadline, necessarily have precluded the 1 The NRC Staff's response to " Town of Hampton Motion to Establish Hearing Schedule and For Additional. Time To File Contentions and For Incorporation of Contentions," dated 10/27/86, provides that "the Staff supports the Town of Hampton's request that the Board establish December 1, 1986, as the date for filing contentions on NHRERP Revision 2." Id. at p. 6. This Board, however, has not yet ruled on this issue. The Town of Hampton therefore submits the contentions filed herewith, reserving the right to file or join in additional
. contentions if further time for filing is granted by the Board.
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Town from complying with'this Board's original schedule. The State's
' failure to. timely provide a substantially complete NHRERP was recognized by the Board at the preliminary hearing, see 3/26/86 hearing transcript pp. 2313, 2318, 2336-2343, and apparently served as the basis for this Board's continuation of the' August licensing hearings. See TONN OF HAMPTON MOTION TO CONTINUE LICENSING HEARING, June 20, 1986. Additionally, although the Town of Hampton received Revision 1 to the NHRERP on or about June 9, 1986, at that time the State of New Hampshire had already determined that Revision 1 would be superceded by a comprehensive Revision 2, which the State indicated would be made available sometime in October, 1986. See-6/3/86 letter of Richard Strome, New Hampshire Civil Director, to Henry G. Vickers, Regional Director, FEMA, attached hereto. Accordingly, the extent to which Revision 1 represented the. operative NHRERP could not be determined until the Town of Hampton was served- with Revision 2, on September 9, 1986. The Town of Hampton thereby and additionally has good cause to submit these." late filed" contentions since:
- 1. The State is solely responsible for failing to provide the Town with.a substantially complete NHRERP to permit the Town to-comply with this Board's' deadline for filing contentions.
- 2. .The Town of Hampton was only served with Revision 2 on September.9, 1986.
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- 3. The_ Town of Hampton is filing contentions on Revision 2 within a reasonable time in view of the wholesale and major changes to the NHRERP set forth in Revision 2, in view of the fact that Revision 2 represents the fourth RERP for Hampton served upon the Town since the beginning of the year, in view of the need for the Town to appropriate additional monies to continue its participation in this' proceeding as specified 'in TOWN OF HAMPTON MOTION TO ESTABLISH HEARINC SCHEDULE AND FOR ADDITIONAL TIME TO FILE CONTENTIONS AMD FOR 4
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INCORPORATION OF CONTENTIONS, and in view of Applicant's failure to object to the Town's request for alternative relief in said Motion, to establish a deadline of December 1, 1986 for filing contentions on Revision 2. See Applicant's MOTION'TO TOHN OF HAMPTON MOTION TO ESTABLISH HEARING SCHEDULE AND FOR ADDITIONAL TIME TO PILE CONTENTIONS AND FOR INCORPORATION OF CONTENTIONS, dated October 20, 1986.2 Other Means To Protect Petitioner's Interest. The Hampton RERP necessarily and uniquely concerns the Town of Hampton. No other Z The Town of Hampton takes issue with the Staff's response to TOW 1 OF HAMPTON MOTION TO ESTABLISH HEARING SCHEDULE AND FOR ADDITIONAL TIME TO PILE CONTENTIONS AND FOR INCORPORATION OF CONTENTIONS to the extent the NRC Staff claims that the Town's deliberations, and subsequent authorization, for additional legal expenditures in this proceeding, provides " insufficient support for its request" for a December 1, 1986 filing deadline. The Staff thereby fails to consider that the State of New Hampshire has served the Town of Hampton with four Radiological Emergency Response Plans for the Town within the first 9 months of this year, has thereby required the Town to expend substantially more in legal fees than could reasonably be anticipated at the time the budget was established at town meeting in early 1986 and, given the economic and political impact of the Seabrook controversy in the Seacoast, has required the Town of Hampton to expend adequate time to permit full public debate and comment before voting.to appropriate additional legal funds in this case on October 2, 1986. The realities of town government in New England, the magnitude of the Seabrook controversy, and the major and unanticipated cost to the Town to participate in this proceeding as a result of the State's late filings, therefore as well as the " Good Cause" for " late filed" contentions set forth above, provide reasonable and substantial ground for the filing deadlines previously requested by the Town from this Board.
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5 4-intervenor or participant in this proceeding can reasonably be expected to protect Hampton's interests. The Town is uniquely qualified to assess the deficiencies in the Hampton RERP, and related portions of the NHRERP, which impact upon Hampton, including provisions on whether Hampton's extensive beach population can be adequately protected in the event of radiological emergency.
Extent To Which Petitioners can Contribute To Development Of A Sound Record. With respect to the development of a sound record, the Town of Hampton hereby incorporates TOWN OF HAMPTON IDENTIFICATION OF NITNESSES AND
SUMMARY
OF TESTIMONY, dated June 4, 1986 and previously served upon this Board. By way of further support for the Town on this issue, the Town intends to introduce expert testimony in opposition to numerous unreasonable assumptions and conclusions contained in the NHRERP, including EPZ road capacities, effect~of adverse weather conditions on ETE, and the increased effect of ETE from evacuating commuters and through vehicles. Additionally, the Town of Hampton intends to call certain employees and representatives of the'Hampton schools, including Jane Walker, Hampton School Board, Nick Hardy, Principal, Centre School, Nancy Andrews, Principal, Marsten School, Steve Bauford, Principal, HAJH School, Marie Matthews, Teacher, Centre School, Vincent Massi, Teacher, HAJH School, Sheila 6
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Nudd, Teacher, HAJH,' Herbert Moyer, Winnacunnet High School; Hampton personnel Jack Furbish, Hampton Public Works Department, and Victor DiMarco, Hampton Police Department; and Daniel Trahan, Administrative Director, Seacoast Health Center. The above-named individuals will offer testimony on those issues previously set forth in TOEm OF HAMPTON IDENTIFICATION OF WITNESSES AND
SUMMARY
OF TESTIMONY, and will provide additional testimony on those issues enumerated in the contentions previously filed or filed herewith, including _ lack of adequate transportation, personnel, and equipment to reasonably and promptly evacuate the Hampton schools and the Seacoast Health Center, and to provide testimony on the unique issues associated with the special needs populations, including issues of age, health, medical-related problems, and Town's special needs transportation requirements. The Town of Hampton.hereby lists, and incorporates by reference, all witnesses so designated by any other party, intervenor, or participants to this proceeding. The Town of Hampton reserves the right to call additional witnesses to support its position on all issues pending before this Board.
The Extent To which other Parties Will Present Petitioner's Interest.- This factor is " closely related" to the second factor set forth in S2.714 (a) (1) , in the matter of Commonweath Edison Company 7
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(Braidwood Station Units 1 and 2), Docket Hos. 50-456, 50-457, 4/24/86 at p.4, and the Town of Hampton theref. ore believes it has fully and adequately addressed this factor as set.forth above.
The Extent To which The Petitioner's Participation Will Broaden The Issues or Delay The Proceeding. The issues raised in the Town of Hampton's contentions on Revision 2 are substantially related to the contentions previously filed by the Town of Hampton on the lack of personnel, equipment, transportation, and related matters, which render the UHRERP, as presently constituted, an unworkable plan.
These contentions should therefore not significan'tly broaden the issues for decision by this Board, since these issues have been consistentl raised by the Town throughout this proceeding.
CONTENTIONS OF THE TOWN OF HAMPTON TO NEW HAMPSHI'IE RADIOLOGICAL EMERGENCY RESPONSE PLAN REVISION.2 INTRODUCTION:
On September 9, 1986, the Town of Hampton was served with a copy of the New Hampshire Radiological Emeraency ResDonse Plan Revision 2 (hereinafter referred to as NHRERP or Revision 2) including an RERP for the Town of Hampton and other municipalities located within the EPZ. The Town of Hampton hereby submits the following contentions in 1
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opposition to. Revision. 2,- which is based upon inaccurate ..and unreasonable assumptions, incomplete or biased data, and otherwise fails to provide reasonable assurance that adequate protective measures can and will be implemented in the event of radiological emergency at Seabrook Station. 10 CFR 550.47 (a) (1) and (b).
CONTENTIONS I, II, V, VII Contentions I, II, V, VII of the CONTENTIONS OF THE TOWN OP HAMPTON TO RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR THE TOWN OF HAMPTON, NEW HAMPSHIRE, NOVEMBER, 1985,'previously filed by the Town of Hampton'with this Board, and bases for same, are hereby realleged and incorporated by reference herein.
REVISED CONTENTION III TO REVISION 2 The Evacuation Time Estimate Study (ETE) prepared by KLD
- Associates, Inc., Revision 2, Volume 6, is based upon inaccurate and biased factual data and unreasonable or misleading assumptions, fails to comply with NRC regulations, and fails to provide reasonable assurance that adequate protective measures can and will be taken, or that adequate facilities, equipment, or personnel will be provided to 9
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the Town of.Hampton, in the event of radiological emergency. 10 CFR 5 50. 47 (a) (1) , (b)(1)(10); NUREG-0654, App.4.
BASIS: The basis for Hampton Revised Contention III set forth ir MEMORANDUM ON 10 CPR 42.714(a)(1) AND REVISED CONTENTION III OF THE TOWN OF HAMPTON TO EVACUATION TIME ESTIMATE REPORT BY KLD ASSOCIATES, IllC. is hereby' realleged and incorporated by reference herein.
By way of further. basis:
(A) Population Estimates.
KLD lacks adequate data to compute the permanent and transient.
population for . the Town of ~ Hampton since KLD computes' beach populatior, capacities by examining only the beach above the high. tide line, Vol.
6, p. 2-12; counts parking spaces rather-than motor vehicles, including vehicles in transit, Vol. 6, p. 2-1; counts beach blankets
- rather than people,~ Vol. 6, p. 2-12; utilizes a vehicle occupancy rate of 2.4 based upon two " field surveys" performed on weekends of frequent rain and poor beach weather, Vol. 6, p. 1-10; and counts ,
beacb populations using a limited number of photographs, of unspecified date or time,.although KLD concedes the beach populations vary widely depending on weather, time of day, and day to day. Vol.6, i
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p.2'-10. KLD_they;ebp unreasonably reduces the actual population for the Town 'of Hampton and distorts this " critical" factor in coraputing ETE. Vol.6,p.2-l[
(B) Weather Condii. ions.
While-recognizing that weather represents a " major factor" aft'ecting ETE, Volun.e 6, p. 3-1 and 2, KLD concedes that it has .
-" limited empirical data 'on the effect of adverse weather conditions to reduce ETE." Vol. 6, p. 3-1. - KLD proceeds to arbitrarily reduce the ETE for rain and snow conditions for the Seabrook EPZ by 20 and.25 percent respectively, Vol. 6, p. 3-11, although KLD lacks any site specific-data on the estent of delay caused by these road hazards.
KLD.acknowlsdges th'e " issue o'f ceAn. fog," yet fails to provide any data'on the impact of fog on ETE,.Vol. 6, p. 3-11, and fails to respond to RAC concerns regarding wind changes, which may require contingencies for the redirection of evacuation vehicles, Hex Hampshir.ec Respgnse - Actions to PAC Review, Auaust, 1986,Section VI, pp. 7, 12, (hereinafte'r RAC Review, Auaust, 1986) with additional delay to traffic and an increase'in ETE. KLD does not even estimate the~effect of ice storms on ETE.
(C) RoadiCupacities.
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- When computing the " major factor" of road network capacity, and-its impact on the time required to effectuate an evacuation, Vo'1 9 6,
- p. 3-1, KLD makes numerous and unsupported assumptions including:
- 1. All roads will remain passable during evacuation. Vol. _
6, p. 10-70. 'This assumption ignores the obvious and anticipated vehicle breakdowns, gas shortages, overheating of vehicles, roadways i becoming impassable from snow or ice storms, gridlock between i
evacuating private vehicles, commuters, and emergency vehicles f-attempting to enter the EPZ, and snowplow operators who either refuse to plow during radiological emergency or are unable to' reach their designated routes due to evacuation traffic congestion.
- 2. KLD assumes that,the " recommended traffic control-tactics are in effect." Vol. 6, p. 10-70. This assumption is unsupportable in view of the avowed position of the Town of Hampton, and other towns within the EPZ, not to implement the NHRERP if called upon to do so. The assumption is further unsupportable following n Exercise Assessment and Review of the NHRERP which " cast (s) doubt" on the State's ability to provide adequate evacuation transportation.
RAC Review, August, 1986,Section VI, p. 9. Finally, the State has failed to demonstrate an ability to provide sufficient law enforcement and traffic control personnel, FEMA, Final Exercise Assessment, 6/2/86
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at p. 46, to compensate for non-participating towns. Accordingly, KLD's reliance upon the State to supply adequate equipment and personnel for traffic control management is without reasonable foundation.
- 3. KLD assumes that 3,000 "through" vehicles will be traveling through the EPZ at the time of notification of an emergency.
Vol. 6, p. 10-3. No support is provided for this assumption, which is rendered absurd by KLD's own calculation of " peak hourly flow" on I-95 of 6,912 veheles. Vol. 6, p. 3-11. Since I-95 represents only one ro'ad within the 200 square mile EPZ, the 3,000 "through" vehicle estimate represents a gross distortion of roadway demand.
- 4. ;KLD concedes that its " estimates of available capacity may overstate the actual accessible capacity." Vol. 6, p. 10-70. KLI a thereby admits tha' its highway capacities relied upon to compute ETE,
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and which represent a " major factor" to caleulate thu-time required I
for evacuation, Vol. 6, p. 3-l', would generate an unreasonably low ,
i ETE, and would not reflect actual conditions. '
- 5. KLD bnreasonably assumes that 25 percent of the EPZ s
population will spontaneously evacuate, Vol. 6, p. 10-3, and estimates Hampton employees who work at the beach, both during the l
week and on weekends, Vol. 6, p. 5-6, apparently by simple guess l l
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work. KLD thereby lacks adequate data to compute road demand for
!!ampton employees during evacuation or to compute ETE when only partial evacuation of the EPZ is ordered.
- 6. KLD fails to adequately account for the impact of disabled vehicles on reducing ETE. Given the thousands of vehicles tc be evacuated, numerous disabled vehicles must be anticipated. KLD's claim that such vehicles will simply be pushed aside by evacuees, without impacting on ETE, is unsupportable. Vol. 6, p. 12-4.
' (D) ETE Preparation Time.
Without statistical support, KLD assumes that 90 percent of the EPZ population will be notified of an emergency within 15 minutes, Vol. 6, p. 4-8, assumes t' hat beachgoers will be able to leave the beach and access their cars within 30 minutes, Vol. 6, p. 4-12, although KLD concedes it has "no empirical data to support this distribution," Vol. 6, p. 4-11, fails to allow for " staging area ,
p' reparation time" as recdmmended by the RAC in c mputing ETE, BAC Review, August. 1986,Section VI, p. 10, and grossly underestimates the adverse impact on ETE of 95 percent of workers returning home, within 30 minutes, to prepare for evacuation following notice of radiological emergency. Vol. 6, p. 4-9.
(E) Growth.
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KLD recognizes the "significant growth" in employment within the Town of Hampton between 1980 and 1984. Vol. 6, p. 5-1. It is also common knowledge that the southern New Hampshire population, includinc the population of the EPZ, is one of the fastest growing in the country. In computing ETE, however, KLD has wholly failed to account for this reasonably anticipated and substantial growth in population and motor vehicles within the EPZ, has failed to obtain any data on projected changes in population distribution within the EPZ, and has otherwise presented a plan which, even assuming its accuracy at.the pre'sent time, will soon be outdated and will not serve as a reasonable basis for emergency planning.
(F) Choice of Host Locations.
KLD unreasonably assumes that evacuees will choose to evacuate tc s \
their assigned liost communities. The assumption is unsupportable, particularly in view of the large number'of beachgoers and transients within the EPZ during the summer who may be wholly unfamiliar with-such host communities as Dover or Manchester. But see Vol. 6, p. 10
(" virtually all drivers" familiar with EPZ roads). Indeed, during the evacuation exercise, even bus-drivers under letter agreement
" consistently experienced problems in getting to where they should be 15 SH AINES. M ACRIGAN & McEACHERN estortssioNat association 25 MAHEWOOO AVENUE . P O Son 360 - PoetsMOUTM NM C3801
4 needed," FE!!A, Final Exercise Asssesment, 6/2/86 at p.43, and the RAC has recommended that'KLD increase ETE to allow for " drivers getting lost or misdirected." RAC Review. August, 1986,Section VI, p. 12.
1Accordingly, if Hampton Beach transients chose to evacuate to Massachusetts or to Maine (as might be more logical) rather than to Manchester (a's assigned),'already crowded evacuation routes would be rendered impassable by the additional traffic and ETE thereby would .be substantially increased. KLD.has thereby selected a theoretically optimal, yet unrealistic, model to minimize ETE.
REVISED CONTENTION IV TO REVISION 2 Revision 2 fails to provide for adequate emergency equipment, fails to demonstrate that adequate protective responses can be implemented in the event of radiological emer'gency, and fails to correct deficiencies in emergency response capabilities apparent from the emergency exericse. 10 CFR S50.47 (1) (8) (10) (14) .
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BASIS: The bases for Contention IV set forth in. CONTENTIONS OF THE TG1N OF HAMPTON TO' RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR THE TONN OF HAMPTON, NEW HAMPSHIRE, NOVEMBER, 1985, and revised Contentior IV set forth in CONTENTIONS OF-THE TG1N OF HAMPTON TO REVISED RADIOLOGICAL EMERGENCY RESPONSE PLAN AND TO COMPENSATORY PLAN FOR THE TOWN OF HAMPTON, NEW HAMPSHIRE are hereby realleged and incorporated by reference herein.
By way of further basis:
.(A) Emergency Resources and Equipment.
Revision 2 fails to allocate adequate buses or EMS 'vehiclt s to the Town of Hampton.to reasonably support an evacuation on grounds including:
- 1. The State indicates that the' bus companies under Letter Agreement will provide 553 buses and 496 drivers to support an evacuation'in the event of radiological emergency. Vol. 4, App.I-l and 2. These figures are inaccurate and misleading.. Many of the buses to be provided by a particular bus company lack sufficient drivers and, conversely, other bus companies are prepared to. provide drivers, but have no buses for them to drive. Id. FEMA correctly notes that only " bus-and-driver pairs" under agreement should be counted to determine the maximum number of emergency vehicles 17~
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available to support an evacuation. FEMA, Final Exercise Assessment, 6/2/86, at p. 39. The state, however, can only demonstrate 431 bus-and-driver pairs, Vol. 4, App. I-1 and 2, or 13 bus / driver pairs less than the 444 necessary minimum required to carry out an evacuation, Vol. 4, App. I-8, even using the State's own unreasonably low EPZ population figures.
- 2. The bus-and-driver pairs under Letter Agreement with the State represent an " absolute maximum," FEMA, Final Exercise Assessment, 6/2/86, at p. 39, and do ng.t provide reliable figures to measure available evacuation buses or personnel. FEMA, Final Exercice Assessment, 6/2/86, App. I at p. 233. Botf1 common sense and conversations between FEMA and the bus companies indicate that in fact the actual bus-and-driver availability would be substantially less than as specified in the Letter Agreements, id, which could reasonably be expected to be. reduced by reason of bus breakdown, driver unavailability, drivers who may get lost enroute to the EPZ, or who may become imbedded in outgoing evacuation traffic thereby substantially delaying or prohibiting a driver from timely reaching the EPZ. RAC Review. August, 1986,Section VI, p. 12.
- 3. In an apparent effort to address P9MA's concerns on the inadequacy of available personnel and transportation resources, the 18 SH AINES. M AORIGAN & McEACHERN - peortssoNat associaMN 25 Ma*LEWOOD AVENUE P O BOX 760 PO*4WouTM NM 038CM
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e State has entered into an agreement with the Teamsters Union, apparently for the purpose of providing additional bus drivers for evacuation. Vol. 4, App. I-11. Revision 2, however, fails to demonstrate that the Teamsters under agreement are in fact adequately trained to drive the school buses and emergency vehicles for the mobility impaired to properly effectuate an evacuation, fails to specify how these backup drivers promptly will be notified and coordinated with available buses, and fails to support the purported agreement with the Teamsters with Letter Agreements executed by the individual members of this union.
(B) Emergency Exercise.
The February 26 exercise only confirmed the consistent position of the Town of Hampton and other intervenors that evacuation of the EPZ around Seabrook Station is not feasible and that the personnel and equipment allocated to support an emergency response are inadequate.
For example, the State'could not satisfy even the limited demand for buses of communities participating in the exercise, FEMA, Final Exercise Assessment, p.40, could not provide adequate EMS or ambulance service, FEMA, Final Exercise Assesment, pp. 42, 44, no buses were allocated for summertime employees, RAC Review. August 1986,Section VI at p. 9, the State failed to demonstrate that adequate backup buses 19 l
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were available to support an evacuation, FEMA, Final Exercise Assessment, 6/2/86, p. 42, and the State did not allocate transportation for those individuals who may have a vehicle in the household, yet the vehicle may be unavailable at the time of an emergency. RAC Review, Auaust 1986,Section I, p. 71. Revision 2 fails to correct these and related deficiencies. Additionally, if the State was unable to reasonably carry out a limited and preplanned evacuation exercise, with no requirement for coordination with Massachusetts, and in the dead of winter, an actual evacuation of the summertime beach population is wholly unrealistic and unworkable.
(C) Special Needs Population.
Revision 2 calculates the special need population for the Town of Hampton based upon an " annual survey." Vol. 18, p. II-30. This
" annual survey" is in fact a mere " postage paid mail back card" sent out by the State purportedly to all persons residing within Hampton.
Id. Less than 2 percent of the Town responded. Vol. 18, p. IV-34.
The survey is a grossly inadequate vehicle to compute the special needs and transit dependent populations of the Town of Hampton and unreasonably places the burden upon handicapped, mshility-impaired, and other transit dependent or special needs individuals to affirmatively request transportation or be ignored under the State's 20 SH AINES. M ADRIG AN a McEACHERN *portss owat assooanow 25 Marttwooo avtNtt ro son 360 PoptSuouTu N** 03n05
emergency plan. The State itself recognized the inadequacy of its owr
~
survey since it increased by 50 percent the transportation allocation for the special needs populations for all towns, in view of the."small sample sizes" received from each community. RAC Review, Auaust.
1986,Section VI, p.'6. As the RAC pointed out, however, no statistical justification has been provided by the State for this 50 percent increase. Id at p. 5. The special needs populations for the Town of Hampton, and for other EPZ towns, therefor represent an unknown quantity for evacuation planning.
(D) Compensatory Plan.
FEMA has. recommended that the State Compensatory Plan be revised "to anticipate the non-participation of any of the local jurisdictions in the Seabrook plume EPZ." FEMA, Final Exercise Assessment, 6/2/86,
- p. 44. Based upon the FEMA recommendation, and from the avowed non-participation of the Town of Hampton and numerous other towns within the EPZ'to implement the NHRERP, the State has promulgated a compensatory plan consisting of only five pages. Vol. 2, App. G. As presently drafted, the Compensatory Plan wholly fails to allocate adequate personnel, equipment, or resources to implement an evacuatior on grounds including:
- 1. The plan erroneously assumes the cooperation and participation of Hampton school officials,-although no letter 21 ss Amts. u4onicas a uce acscas . P. ort..c~.< .. soc..no~
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agreements confirming this participation have been obtained. Vol. 2, App. G-2.
- 2. Aside from vague reference to the coordination of " law enforcement activities and traffic control," Vol. 2, App. G-3, the compensatory plan wholly fails to specify where this additional law enforcement personnel will be obtained to make up for those local police who will not participate in the implementation of the NHRERP, including tne Hampton Police Department. Either the plan erroneously assumes local participation in the face of the express vote of the Town of Hampton not to so-participate, or the plan relies upon the inadequate number of personnel in State Police Troop A to carry out local law enforcement duties. With its 35 troopers, however, Troop A does not even have sufficient personnel to staff access control pointt for the EPZ, as required under Revision 2, let alone take over the traffic management and security duties presently assigned to Hampton and other local police departments. FEMA, Final Exercise Assessment, 6/2/86 at p. 46.
- 3. No letter agreements have been obtained from the bus drivers who have primary responsibility for transporting the 1
22
$H AINES. M ADRIGAN & McEACHERN enorESSCN AL ASSOCianoN S WAPLEwo00 AvFNut .O Son 160 PONTsuoytme Nw 03 sos
population, including school children, out of the EPZ in tl:2. event of
. radiological emergency.
On its face, therefore, the five page Compensatory Plan offered by~the State.in response to FEMA's recommendation for a plan to anticipate the non-participation of any or all of the EPZ towns is vague, inadequate, and unworkble.
(E) Transit Dependent Individuals.
Revision 2 adopts a " concept of pre-designated bus routes" to evacuate transit dependent residents and transients without private transportation. RAC Review. August, 1986,Section I, p. 73.
Appparently this procedure has been adopted to purportedly increase the speed of evacuation, by eliminating the need for door to door pick ups of transit dependent individuals as provided in the prior NHRERP.
These pre-designated bus routes, however, will require individuals, including the " mobility-impaired," to leave their homes during a radiological emergency, to locate the pre-designated bus routes, and to remain outdoors subject _to increased radiological exposure, awaiting evacuation buses which PEMA has already indicated may reasonably be expected aht to arrive. FEMA, Final Exercise Accesament, 6/2/86 at p. 40. This procedure unreasonably compromiset l
l 23 SHAINES. M ADRIG AN & McEACHERN PeoFE55CN AL ASSOCsaM 29 warttwoOO avtNut 80 SOM 3 0 po#75poufM NM 0380s
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.the public health and will not adequately protect the Hampton-population from radiation injury. Additionally, the transportation.
allocated for the Town of Hampton under Revision 2, Vol. 18, p. 34, does not include buses for the substantial number of transients, including the beach population. Vol. 4, App. I-8.
REVISED CONTENTION VI TO REVISION 2 Revision 2 fails to demonstrate that adequate personnel are available j to respond, or to augment their initial response on a continuous basis, in the event of radiological emergency. 10 CPR l S 50.47 (b) (1) (10) .
(
BASIS: The bases for Contention VI set forth in CONTENTIONS OF l THE TG1N OF HAMPTON TO RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR THE l h TG1N OF HAMPTON, NEW HAMPSHIRE, NOVEMBER, 1985, and revised Contentior l
VI set forth in CONTENTIONS OF THE TGiN OF HAMPTON TO REVISED RADIOLOGICAL EMERGENCY RESPONSE PLAN AND TO COMPENSATORY PLAN FOR THE TG1N OF HAMPTON, NEW HAMPSHIRE, are hereby realleged and incorporated by reference herein.
By way of further basis:
(A) Revision 2 provides that 28 local traffic guards are required for the Town of Hampton and Hampton Beach, Vol. 6, p. 8-11, 24 SH AfNES. M ADRIGAN & McEACHERN * **ortsscNat assc panoN 29 Martswooo attNut . Po son wo Po#Tswoutw Nw osem
although the Hampton Police Department only has a total of 24 full time officers in the entire force. Vol. 18, p. IV-41. Even adopting the State's implicit, and unreasonsable, assumption that the entire Hampton police force would be immediately available to respond to a radiological emergency, the force simply does not have adequate personnel to man the traffic control points, Vol. 6, p. 8-11, Vol. 18,
- p. IV-43, to provide EOC security, Vol. 18, p. IV-42, to provide security patrols throughout the Town, Vol. 18, p. IV-43, to provide those people within Hampton at the time of emergency with backup public alerting, Vol. 18, IV-41, or to close and patrol the town beaches. Vol. 18A App. G-3.
(B) In an effort to compensate for.the lack of local personnel to adequately respond to a radiological emergency, Revision 2 provider that the New Hampshire State Police will provide " assistance to local police departments for law enforcement and traffic control." Vol. 1,
- p. 1.3-20. State Police Troop A is the only State Police force in reasonable proximity to the EPZ. Since Troop A, however, has only 35 troopers, and 44 officers are required to staff the access control points for the EPZ, FEMA has properly concluded that Troop A does not even have sufficient personnel for access control, FEMA, Final Exercise Assessment, 6/2/86, p. 46. Necessarily, Troop A has no 25 SH AIN ES M ADRIG AN & McEACHERN PoortssoNat associarc%
25 MaPLEWOOO avtNe t Po som 160 PostgwaytH NM C3RO'
_ _-l_ _-____--- . --
additional personnel to assist local municipalities, such as Hampton, Vol. 1, p. 1.3-20, lacks resources to-provide any traffic control beyond access control within the EPZ, will be unable to respond to requests from DOT to provide road barriers, signs, or road clearance during evacuation, or otherwise to perform the excessive number of
~
duties assigned to the State Police under Revision 2. Vol. 2, p.
1.3-20 and 21. FEMA has therefore properly noted that "even with help from other troops, the State Police force could be seriously depleted and law enforcement possibly impaired." FEMA, Final Exercise Assessment, 6/2/86 at p. 46.
(C) Revision 2 additionally fails to provide reasonable assurance that adequate personnel are available to implement the NHRERP in the event of radiological emergency on grounds including:
/
- 1. The Hampton Public Works Director is responsible for transporting transients out of the EPZ, Vol. 18, p. II-28, although it is unclear where this additional transportation may be obtained;
- 2. The Hampton Town Manager is responsible for~ insuring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing of all town departments during an emergency, Vol. 18, p.
IV-9, although Revision 2 fails to specify what personnel is available to insure an adequate personnel pool; l
26 f
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- 3. The Public Works Department is required to keep evacuation routes free during evacuation, Vol. 18, p. IV-27 to 33, although most members of the Public Works' Department are not trained for, and.have no experience in, traffic control management. Vol. 18, App. C-3.
- 4. There is no showing that the Rockingham County
~
Sheriff's Department has adequate manpower to carry out its duties under Revision 2. See e.g. Vol. 18, p. II-16a.
- 5. There are no letter agreements with Hampton. school personnel, many of whom have indicated, understandably, that in the event of evacuation, their first duties would lie with their families, and not in carrying out their duties under Revision 2.
REVISED CONTENTION VIII TO REVISION 2 Revision 2 fails to provide adequate emergency equipment, facilities, or personnel to support an emergency response and fails to demonstrate that adequate protective responses can be implemented in the event of radiological emergency. 10 CFR 50.47 (1) ( 8) (10) .
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BASIS: .The bases for Contention VIII set forth'in CONTENTIONS OF THE TOWN OF HAMPTON TO RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR THE TONM OF HAMPTON. MEW HAMPSHIRE,-NOVEMBER, 1985, and Revised Contention VIII set forth in CONTENTIONS OF THE TONN OF HAMPTON TO REVISED RADIOLOGICAL EMERGENCY RESPONSE PLAN AND TO COMPENSATORY PLAN FOR THE TOWN OF HAMPTON. NEN HAMPSHIRE, are hereby realleged and incorporated by reference herein.
By way of further basis:
l The Seacoast-Health Center is a residential facility for the elderly located in Hampton, New Hampshire. The State has indicated that evacuation.of handicapped and special needs individuals is a
" municipality responsibility." RAC Review, August, 1986,Section I, l
- p. 66. Since Hampton will not implement Revision 2 if called uponito do so,.and, as evidenced by the exercise, the State is unable-to provide local communities with adequate bus transportation, FEMA, Final Exercise Assessment, 6/2/86 at p. 40, Revision 2 fails to provide reasonable assurance that the 107 elderly residents of the Seacoast Health Center will be properly and timely evacuated in the l
1 l
\
28 SHAINES M AORtG AN & McEACHERN . PayttscNat associavon as waPLtwoop avthot Po Don po PoetswouTM hw oseot
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event of radiological emergency. Vol. 18, Attachment B-1.
' Additionally, the State assumes that 40 special facilities individuals, including residents of the Seacoast Health Center, may be boarded on an evacuation bus, with personal belongings, medical supplies, and related items, within 10 minutes.3 RAC Review, August, 1986,Section VI; Vol. 18A, Seacoast Health Center, pp. 13, 14, irrespective of time of day, time of year, variations in staff depending on shift, or number of residents which may happen to be bedridden for medical reasons. The proposition is absurd. Finally, the State relies upon an unspecified " technical assessment" of the sheltering capabilities of the Seacoast Health Center, which will form the basis for ordering protective actions, including ordering staff and residents of the Health Center to shelter, while the general population evacuates.4 Vol. 18, p. 15. Absent further 3 A similarly erroneous assumption is made to compute evacuation times for Hampton schools. Since school children will be evacuated by bus only if their parents have not already picked the children up at school, Vol. 18A, App. F, p. 1-5, a major traffic jam at the schools must be anticipated.
4 Revision 2 is unclear whether a similar " technical assessment" for Hampton schools has been compiled, as part of emergency planning.
29 SH AINES M ADRIG AN & McEACHERN . ewertsgemat assoc avoN 29 warttwooo avtmut Po sou ?co PomqwCum Nw 03em
documentation in Revision 2, such a procedure would appear to' avoid the inherent and substantial difficulties in evacuating this special needs population, by relying on the expediency of sheltering, notwithstanding the increased threat of radioilogical exposure to the residents.
Dated: October 31, 1986 Respectfully submitted, SHAINES & McEACHERN Attorneys for the Town of Hampton m >
By: V \ <-
Matthew T. Brock 30 SH AINE S M AORiG AN & Mc E'ACHERN - **ortsscNAL assoccA*0N g? waPLEWOOD AstNot # O BCu 160 PCe4Moum NH C380'
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4 e t
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STATE OF NEW HAMPSHIRE EXECUTIVE DEPARTMENT 9
g-Mr. Mempebee G.8 Defenee Agency F Seese OHae Pe4 Seveh 107 Messene5seees Conseed, New Mempebee 03303 h*'-
3 28CMamo M. STROt#E Onee,.,
JAast5 A. SAGGIOTES Desvry Ovecier June 3,1986 Mr. Henry G. Vickers, Regional Director Federal Emergency Management Agency Region I J.W. McCormack Post Office and Courthouse Boston, Massachusetts 02109
Dear Mr. Vickers:
We are pleased to inform you that New Hampshire Civil Defense Agency has completed Revision 1 to the New Hampshire Radiological Emergency Response Plan (t+iRERP) package. We are in the process of distributing the Revision 1 changes to the holders of controlled copies of the plan and to other key people and agencies.
The next step in the process includes developing a work plan for compiling Revision 2 to the New Hamoshire Radiological Emergency Ratnan=* Plan. It is our intent that the work plan wm outune eneswa to be made in response to the RAC review, to the FEMA exercise report, to observations noted in contentions offered by intervenors to the ASLB hearings process, and to changes suggested by various members of New Hampshire emergency response
- organizations. It is our intent to have the work plan completed by July 1, 1986 with Revisinn 2 to in11nw. nrnhahlv in nr4nhec_ 1986. We have arranged specifically to have the work plan available well'in advance of the scheduled Atomic Safety Licensing Board (ASLB) Hearings so that FEMA and all other interested parties will see what work is being undertaken to respond to comments outlined in the various reports cited above.
- It is essential that we meet not later than mid bne to expedite preparation of the work plan. In such a working level meeting, we would expect to outline the plan changes we anticipate in response to each coment.
We would expect, in return, to receive some expression of concurrence that the proposed changes would be responsive to the RAC or exercise comment. In addition, for several cocnents, some dialogue is required before we can respond formally to the RAC. There are several corsnents that we do not understand, or for wnich the nature of the required improvement is not clear to us. Discussion with the authors of the coments would be most helpful in I these cases. Could you please provide us with a firm date for tnese l discussions to take place.
Emergency Management for New Hampshire
-m, _ . - , _ , , _
. _a - - - - -
_ = ___.. _ _ . _ . _ _
__ ___ - . - --- ----- - - - - - ~
Mr. Henry G. Vickers, Regional Director Page Two
.Ane 3, 1986 Thank you for your assistance in this matter.
Sincerely, Q2= %
Richard H. Strome Director RHS/sje 3457B 9
i e
e f
4
..,,,.y-q47NewawFF*'f"N"'"'" ^
UNITED STATES OF AMERICA Q NUCLEAR REGULATORY COMMISS' g ,
NOV -
BEFORE THE ATOMIC SAFETY AND LICENE kG In the matter of g
/
/
PUBLIC SERVICE COMPANY OF Docket Nos. 50-4 ., __./
NEW HAMPSHIRE, et al. 50 444 OL_,
(Seabrook Station, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of. MEMORANDUM ON 10 CPR 8i2.714(a)(1) AND CONTENTIONS OF THE TONN OF HAMPTON TO NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN REVISION 2 in the above-captioned proceeding have been served'on the following by deposit in the United States mail, or as otherwise indicated, on this 31st day of October, 1986.
- Helen Hoyt, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission East West Towers Building Fourth Floor 4350 East West Highway Bethesda, MD 20814
- Dr. Jerry Harbour Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Dr. Emmeth A. Luebke Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
$H AINES. M AORIGAN & McEACHERN - P ortsscNat associato%
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- Atomic Safety and Licensing Appeal Board Panel-U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C. 20555
!!rs. Anne E. Goodman Board of Selectmen 13-15 Newmarket Road Durham, NH 03842 William S., Lord, Selectman Town Hall Friend Street Amesbury, MA 01913 ,
Jane Doughty Seacoast Anti-Pollution League 5 Market Street Portsmouth,2NH 03801 Rep.'Roberta C. Pevear Drinkwater Road Hampton Falls, NH 03844 Philip Ahrens,.Esq.
. Assistant Attorney General Office of the' Attorney General State House Station 6 Augusta, ME 04333 Thomas G. Dignan, Esq.
R.K. Gad II, Esq.
Ropes & Gray 225 Franklin Street Boston, MA 02110 Robert A. .Backus, Esq.
Backus, Meyer & Solomon 111 Lowell Street Manchester, NH 03105
- Robert G. Perlis, Esq.
Sherwin E. Turk, Eq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Tenth Floor 7735 Old Georgetown Road Bethesda !!D 20814 l
1
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Mr.-Angie Machiros, Chairman Board of Selectmen Newbury, MA- 01950
- H. Joseph Flynn, Esq.
Office.of General Counsel Federal' Emergency Management Agency
- 500 C Street, S.W.-
Washington, D.C. 20472
- George Dana Bisbee, Eq.
Stephen E. Merrill, esq.
Office of the Attorney. General State. House Annex Concord,.NH 03301 Carol S. Sneider, Esq.
Assistant Attorney General Department of the Attorney General-One Ashburton Place 19th Floor Boston, MA 02108 Stanley.W. Knowles Board of Selectmen P.O. Box 710 North.Hampton, NH 03826 J.P. Nadeau, Selectman Town of Rye i 155 Washington Road-i Rye, NH 03870 Richard E. Sullivan, Mayor City Hall Newburyport, MA 01950 -
' Alfred V. Sargent, Chairman
' Board of Selectmen Town of Salisbury, [1A 01950 Senator Gordon J. Humphrey 4
U.S. Senate
. Washington, D.C. 20510 (Attn. Tom Burack) l l Michael Santosuosso, Chairman i Board of Selectmen Jewell' Street RFD 2 South flampton, N!! 03842 i SHAINES. M ADRIGAN & McEACHERN . enottsschat ateociatiose 39 wartrwoco avtsegg . po non Sao . Post 1Mou?H NM 01ece
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' Allen Lampert~
Civil Defense Director Town of Brentwood Exeter, NH 03833
- Richard A. Hampe, Esq. .
Hampe and McNicholas 35 Pleasant Street Concord, NH 03301 Gary W. Holmes, Esq.
Holmes & Ellis 47 Winnacunnet road Hampton, NH 03842 William Armstrong Civil Defense Director 10 Front Street Exeter, NH 03833 Calvin A. Canney City Manager City Hall 126 Daniel Street Portsmouth, NH 03801
- Edward A. Thomas Federal Emergency Management Agency 442 J.W. McCormack (POCH)
Boston, MA 02109 Sandra Gavutis Town of Kensington RFD 1, Box 1154 .
East Kensington, NH 03827 Charles P. Graham, Esq..
McKay, Murphy & Graham 100-Main Street Amesbury, MA 01913 l
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O Diane Curran, Esq.
Harmon & Weiss 201 S Street N.W.
Suite 430 Uashington, D.C. 20009 k 1 Matthew T. Brock
- By Federal Express SH AINES M ADRIGAN & Mc EACHERN p=OFE5scNat aSSOClat'ON 29 M APLEWOOO avENuf
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