ML20235M819
| ML20235M819 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/21/1989 |
| From: | Mangan M, Paolollo J MASSACHUSETTS, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20235K640 | List: |
| References | |
| OL, NUDOCS 8902280438 | |
| Download: ML20235M819 (39) | |
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., UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l ATOMIC SAFETY AND LICENSING BOARD l
7- Before the Administrative Judges:
., Ivan W. Smith, Chairman l Dr. Richard F. Cole Kenneth A. McCollom
)
In the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP)
OF NEW HAMPSHIRE, EI AL. )
) '
(Seabrook Station, Units 1 and 2) ) February 21, 1989
)
TESTIMONY OF MAUREEN MANGAN AND JOHN PAOLILLO, ON BEHALF OF ATTORNEY GENERAL JAMES M. SHANNON, REGARDING THE ACTUAL AVAILABILITY OF THE SPMC'S MANNED VERICLES AND DRIVERS I.
SUMMARY
OF TESTIMONY In this testimony two investigators from the Massachusetts Attorney General's Office describe the results of their recent investigation of the actual availability of the manned vehichle being relied upon by the SPMC to support an emergency response.
These two investigators recently contacted each of the bus, ambulance, and tow companies which the Applicants, in responding to discovery requsts have stated that they will be 8902280438 890221 PDR ADOCK 05000443 T PDR
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relying on"to supply vehicles to support the SpMC's evacuation plan. In other words, this testimony examines the " supply" side.of th_e manned vehicles issues.
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In this testimony the investigators will present, company by company, the results of their investigation, summarizing their results to the~ extent possible. .For most bus companies willing to speak with them, it is not possible to say definitively how raany manned vehicles will, with reasonable assurances, be able to respond on the day of an emergency. The numbers vary greatly, depending on time of day, day of week, and even time of year. What is certain, however, is that on many occasions the number of buses, vans, and other vehicles that will,'with reasonable assurance, be able to respond, is substantially less than the numbers set.forth on the SpMC's letters of' agreement ("LOAs"). These are all "up to" agreements, i.e., they set forth maximums, not minimums, in many cases, this.is not the number of vehicles which the managers / owners of the companies expect to respond.
As to ambulances, it appears that no more than 51 ambulances and ambulettes can be counted on, with reasonable assurance, to respond. In addition, more than half of these i can not be counted on to' drive into contaminated areas.
There is only one tow company participating, and it will likely supply 3 large tow vehicles, 3 carriers, and 9 standard wreckers.
II. IDENTIFICATION OF WITNESSES Q. Would you please state your names and business addresses.
A. (Mangan) My name is Maureen Mangan, and I am employed as an Investigator for the public protection Bureau of the
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' Massachusetts Attorney General's Of fice. My. business address is One Ashburton Place, Boeton, Massachusetts.
(Paolillo) My name is John Paolillo and,'like.Ms.
'Mangan, I.am employed as an Investigator for the Public Protection Bureau.of the Massachusetts Attorney General's Office. I have the same business address. ;
Q. Briefly summarize your educational background experience as investigators.
A. (Mangan) 'I have a B.S. in Business Administrate' ion fromLSalem State College in Salem, Massachusetts. I.have worked as an investigator for the Public Protection Bureau of the Attorney General's Office since March 1984. The Bureau includes six " divisions" (Antitrust, Civil Rights, Consumer Protection, Environmental Protection, Insurance, and Public Charities) and two special " units" (Nuclear Safety Unit and Special Litigation Unit). I have conducted a wide variety of types of investigations over the past five years. Many.have i
involved ascertaining facts by locating and interviewing l-individuals. Others have involved performing asset and f
corporate records checks, conducting audits, and analyzing financial records. When requested to do so by Assistant Attorneys General, I appear in court proceedings and testify on the results of my investigations.
(Paolillo) I have a B.A. in Mathematics from Boston College. After graduating in 1987,I was a research assistant for the Middlesex County (Massachusetts) Court System. I came
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to the Att6rney General's Office in December 1988 and have been working as an investigator for the Public Protection Bureau since that,date.
III. THE NATURE OF OUR INVESTIGATIDH Q. Would you briefly describe the investigation that you were asked to conduct with respect to the Seabrook Plan for Massachusetts Communities ("GPMC")?
A. (Both) Yes. The attorneys in the Nuclear Safety Unit informed us that in the course of litigating the adequacy of the SPMC they wanted to know whether, and to what extent, certain private bus, ambulance, and tow companies, and their drivers, were actually committed to responding in the event of a nuclear emergency at Seabrook Station. Specifically, they provided us with a list of companies and asked us to contact the owners or managers and inquire about their commitment to partic:pate.
Q. Do you know where this list came from?
A. Yes, actually it was a series of pages from answers to interrogatories provided by Seabrook's owners (the Applicants). These answers were provided in November 1988 in response to interrogatories submitted to them by attorneys from our office asking the Applicants to identify each of the companies currently being relied upon by New Hampshire Yankee's Offsite Response Organization ("ORO") for buses, vans, ambulances, and tow vehicles in the event of a radiological
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_g emergencyfst Seabrook Station. The name of one additional' i- ambulance. company was.also'provided by the Applicants in late January 1L89.
Q. When did you conduct'.this investigation?
A. (Both) It was done in January and early February 1989.
Q. Had you contacted any of these companies ~previously?
A. (Mangan) Yes. About a year ago, another investigator
.from our office, Brian Taylor, and I contacted a. number of these companies and. inquired about their intent to provide vehicles and drivers to New Hampshie Yankee in-th'e event that there was an emergency at Seabrook Station and the area.around the-nuclear plant needed to be evacuated.
Q. Whatsdid you ask the company owners or managers when
-you contacted them at this time?-
A. (Both) We inquired first whether they had in fact agreed to provide vehicles and drivers to New Hampshire Yankee in the event of a radiological emergency.at Seabrook. If the owner / manager responded affirmatively, we then inquired about
' numbers: How many vehic-*es? What types of. vehicles and how many of each? How many drivers?- We asked if they had signed any letter or other agreements with NHY and, if so, we asked them for their understanding of what those letters or agreements meant. We asked them whether the number of vehicles they had agreed to supply was a minimum or a maximum number.
(In almost all cases it was the latter.) We then inquired about potential problems that might exist in mobilizing all the
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l promised vehicles and drivers. In many instances the owners / managers explained that, depending on the time of day, the day o_f the week, or the month of the year, they would expect to have fewer vehicles and drivers available than the maximum number that had been offered to the ORO.
Q. Would you please review your findings for each of these companies.
A. (Both) Certainly.
A. AMBULANCE CQfEJMIEE
- 1. Rockingham Regional Ambulance Company Nashua, New Hampshire (Mangan) I interviewed Chris Stawasz, the Operating Manager, a year ago on March 23, 1988. At that time he indicated that Rockingham had a Letter of Agreement with ;
Seabrook's owners to provide three (3) ambulances, but he had subsequently signed a contract to provide only "up to" two (2), He indicated that he could not guarantee that all his ambulances (4) would be available at all times, but two were usually available. He also said that he has made it mandatory for his EMTs tnat they make themselves available for I
participation in a Seabrook emergency, but he admitted that contacting them all in an emergency was dependent on such factors as time of day and day of week.
(paolillo) On February 10, 1989 I contacted Rockingham Regional Ambulance by telephone.
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i Ro~ekingham Regional Ambulance ("Rockingham") has )
I agreed to respond, under contractual agreements with New i Hampshire _ Yankee ("NHY"), to a disaster at the Seabrook Nuclear power plant. In return for Rockingham's agreement to !
participate, Rockingham has been provided a financial reward.
He said that they will receive additional compensation for i their participation during an evacuation. Mr. Stawasz told me that Rockingham has agreed to make all ambulances available at the time of a disaster. These vehicles are not all ambulances, however, some of them are ambulettes. An ambulette (according to Mr. Stawasz) is similar to an ambulance; however an ambulette has a larger capacity for passengers (6) and does not have as much medical equipment stored within its cabin. All these vehicles are parked at one specific location (not furnished), and they provide daily service pursuant to state and municipal contracts.
The drivers of the vehicles involved in the evacuation have received training, and they are aware of the possibility of driving into a radiation plume during the time of a disaster. The company contact person is Mr. Stawasz, and he advised me that he can always be reached during the time of an emergency. Mr. Stawasz stated that Rockingham has a 24-hour dispatcher who would help Mr. Stawasz contact all the drivers in the event of a Seabrook emergency. The drivers involved would be told to report to the yard and then would drive into
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an assigned area. Mr. Stawasz ended our interview by advising me that this is a volunteer effort on the part of the drivers and that._all of these drivers live within the Nashua, New Hampshire, area.
(Both) Based on the information from both of our interviews, it appears that there is a reasonable assurance that in the event of an emergency at Seabrook Station, Rockingham Regional Ambulance Company will be able to provide the two ambulances (with drivers) which the company has contracted to provide. Rockingham ..ay be able to provide one or l
two additional vehicles, but there is no real assurance of this.
- 2. Cataldo Ambulance Service '
Somerville, Massachusetts.
(Mangan) Brian Taylor and I initially interviewed John G. Mansfield, the Operating Manager of Cataldo Ambulance Service, a year ago on March 24, 1988. At that time he informed us that Cataldo had agreed to provide two (2) ambulances and accompanying drivers. He said they might be able to provide additional ambulances if more were available at the time.
4 (Both) When we contacted Mr. Mansfield again on February 13, 1989, to see if he was still participating, he again said Cataldo would provide a minimum of two ambulances, as they had contracted to do. He indicated that he had been advised by people from Seabrook Station not to speak to us, and refused to answer further questions, referring us instead to Ropes & Gray.
1 Bated on the information we obtained from both these
- interviews, it appears that there is reasonable assurance that, in the eva,nt of an emergency at Seabrook Station, Cataldo ,
I Ambulance Service will be able to provide the two ambulances )
i (with drivers) they have been contracted to provide.
- 3. Dereck's Ambulance Service, Inc.
Manchester, New Hampshire (Mangan) Brian Taylor and I initially contacted Mark and llenry Dufresne, the owners of Dereck's Ambulance Service on March 23, 1988. We knew only that they had signed a letter of agreement to provide three (3) ambulances and four (4) ambulettes. When contacted, however, they refused to answer our i questions.
(Paolillo) On February 13, 1989, I spoke with Mr. Hank Dufresne (owner) of Dereck's Ambulance Service, Inc. Mr.
Dufresne advised me that he refused to comment about his company's involvement in the Seabrook evacuation plan. Mr.
Dufresne referenced me to the law firm of Ropes & Gray regarding any question in this matter.
(Both) We have no reason to doubt that in the event of l a Seabrook emergency, Dereck's Ambulance will provide three ambulances and four ambulettes, with drivers.
- 4. Medec Ambulance Pottland, Maine
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(Faolillo) On February 7, 198?, I spoke with Mr.
f Patrick Shaw, the Assistant Manager of Medec Ambulance. Mr.
Shaw provi_ded me with the following'information regarding~Medec Ambulance's involvement in the Seabrook-Evacuation plan.
Medec Ambulance has signed a contract agreeing to provide two (2) ambulances to assist in an evacuation at the time of anLemergency. Medec also has up to four (4) crews to.
operate the ambulances. Mr. Shaw pointed out that because1of the small number of ambulances Medec has contracted to provide, he foresees no problem in actually finding two ambulances available in a real emergency.
Mr. Shaw continued by stating that either he or'the l
. manager would be the contact person at the time of an emergency. He did not elaborate on how the drivers would be i
contacted or the amount of time it would take to contact them.
His personal opinion is that it would not be a problem contacting the drivers needed for the evacuation.
There appears to be reasonable assurance that Medec will be able to provide two ambulances in the event of an i emergency at Seabrook. !
- 5. Stavis Ambulance Service Brookline, Massachusetts.
(Mangan) I originally contacted Bernard Leitzig, the Manager at Stavis, on March 31, 1988, and he told me they had signed a letter of agreement to provide one (1) ambulance. I
O re-contacte'd him by telephone on. February 16, 1989, to' confirm the information he gave me previously. He did confirm that' Stavis'-.ls_tter of intent is still' valid,.and they will provide one' ambulance (with EMTs) in the event of a Seabrook emergency. He said that New Hampshire Yankee had requested that'he commit "up to" all sixteen (16) of his ambulances, but' he refused, because he could guarantee only one (1). Stavis has also' refused Seabrook's offer of compensation. He indicated that 15-20 of'his EMTs have signed up to participate in the training being offered by New Hampshire Yankee. It is ..
his understanding that the EMTs would decide for themselves at the. time of the incident whether or not they wish to respond or enter a contaminated area. Seabrook's owners have represented that Stavis' EMTs would be sent to a secondary zone, not"the primary zone where the contamination has occurred. Mr. Leitzig also stated that he estimates it would take his ambulance, depending on traffic, approximately 60 minutes or more to arrive at the Staging Area in Haverhill from the time they had left Brookline.
Based on my conversations with Mr. Leitzig, it appears !
that there is reasonable assurance that Stavis will provide one (1) ambulance, with EMTs, in the event of a Seabrook emergency, but there is no reasonable assurance that the EMTs will drive i it into a contaminated area.
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- 6. Front Line Ambulance Company ~
Lawrence, Massachusetts.
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(Both); Frontline is a new addition to the' list, j having-been first announced by the Applicants in late ~ January j 1989. On February'2, 1989, . we interviewed Robert Shuman, owner of Front I.ine. Ambulance, concerning his contract with NHY to
-provide emergency. service in the case of a radiological disaster at Seabrook Station.
According to Mr. Shuman, in December 1988 he signed a contract with NHY to provide "up to" 15 ambulances and 15 wheelchair vans in the event that an evacuation is undertaken in response to a nuclear disaster at Seabrook. In return, his employees are to be paid $250 annually plus an hourly rate for any training sessions they attend. Front Line is being paid
$2,000 annually for participating, $750 per ambulance, and $100 per wheelchair van. Mr. Shuman understands "up to" as meaning as many ambulances and wheelchair vans as are available at the time they.are called but not to exceed 15 of each. He added that at no time would~he. strip all ambulances from the four (4) towns he contracts with to provide ambulances in a Seabrook emergency. Therefore, he would never send more than 11 l
ambulances in the event of a disaster.
Mr. Shuman firmly stated that it is not his understanding with Seabrook's owners that he would send his ambulances, vans, and drivers into a contaminated area. That is something he would not agree to do.
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Based on our conversation with Mr. Shuman, it appears-
'that there is no assurance that Front Line will provide more-than 11 ambulances and 15 wheelchair vans in the event that-E there.is a need-to evacuate the area around the Seabrook nuclear plant in an emergency there. In addition, there i.s no assurance that these vehicles will-enter a contaminated area.
- 7. Bay _ State Ambulance
.(various locations including Springfield, Massachusetts)'
(Mangan) I did interview the Director of Operations of
-Bay State, Mr. Jay Sylvain, back in March 1988. Because of recent developments at Bay State, however, most of what he told me then is now out of.date.
(Both) On February 14, 1989, we interviewed Jay Sylvain, Operating Manager of Bay State Ambulance,.at his office located at 867 Boston Road, Springfield, Massachusetts. We discussed Bay State's contract to provide ambulances and wheelchair vans to Seabrook in the event of a radiological disaster.
Mr. Sylvain first advised us that Bay State Ambulande was currently negotiating to sell the part of their ambulance l
company that services the North Shore area of Massachusetts. He -
anticipates that the sale will occur sometime after April 1, {
1989. After this sale, Bay State will have only their (Massachusetts) Gouth Shore and Springfield area offices. As a result of this sale, he believes Bay State Ambulance will only
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be'able'to" provide about 13 ambulances, not 22.as stated in-their contract. Mr. lvain has notified. representatives of Seabrook..pf this'pending change and of the need to amend his contract. He told them that at this point he could not guarantee them a specific number of ambulances. He said that a representative of Seabrook responded that they do not care if EMTs and ambulances show up in an emergency; they only need numbers on paper. Mr Sylvain broke down the locations of his remaining inventory of ambulances as follows:
Quincy 06 Weymouth 05 Braintree 03 Holyoke 02 Springfield 1H Total 26 However, at least 13 of these ambulances would n21 be available to respond in the event of a nuclear disaster because of prior commitments.
According to Sylvain, none of his EMTs have officially signed up with Seabrook or been trained. He has left it solely up to Seabrook to recruit Bay State EMTs.
When Mr. Sylvain asked the representative of Seabrook to provide him with some information from their disaster plan, his request was denied. He was mainly interested in reviewing :
the chain of command and how long the estimated ambulance I
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i response t rue was. A representative of Seabrook.did tell Mr.
Sylvain.that they.were looking:for companies that would be able I 1
to respond in two hour or less. Mr. Sylvain estimates that j after' contacting the EMTs from his Springfield location, he could-have three crews ready.to respond in 15-20 minutes and it would take approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 40 minutes for them to get as far north as Lowell. He estimates that it would take his South Shore ambulances approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to get to.Lowell under normal circumstances. However, if they were called during rush hour, it would take much longer than one hour.
Mr. Sylvain states that it was his understanding that his ambulances and EMTs would not be entering a contaminated area and that at no time would they enter New Hampshire and probably would not go any farther north than Haverhill. He believes that his-EMTs would not enter a contaminated area unless they were provided a protective suit similar to those provided if they were responding to a chemical disaster, as many of his EMTs have.in the past.
In conclusion, we conclude that there is no reasonable assurance that Bay State Ambulance will be able to provide more than 13 ambulances in the event of a tuture emergency at j l
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Seabrook Station. Because none of Bay State's EMTs have signed I
up or been trained yet, it may not be prudent to count on that many. In addition, there is no assurance that these vehicles will enter a contaminated area.
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- 8. Marlboro-Hudson Ambulance Hudson, Massachusetts l
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'(Mangan) A year ago, in March 1988, I interviewed Arthur J. Breau, the manager of this company about its participation in an evacuation in the event of an emergency at Seabrook Station. For all intents, what he told me then he repeated.for us again when we interviewed him this year; so I need not detail what he said back in 1988.
(Both) On February 7, 1989, we interviewed Arthur Breau, the General Manager of Marlboro-Hudson Ambulance Company. According to Mr. Breau, if there is a Seabrook emergency, Marlboro-Hudson has agreed to provide up to 11 ambulances, up to 8 wheelchair vans, and up to 3 critical care units if available at the time. This is the company's entire inventory of vehicles. But Marlboro-Hudson Ambulance is under contract with the City of Marlboro and the Town of Hudson to provide emergency ambulance services 24. hours a day. Therefore, since one ambulance must be reserved for each, at no time would he have more than 9 ambulances to respond to an emergency at' Seabrook. Mr. Breau added that all his prior commitments come first, meaning that if his vehicles were being used for regular contract service, like transporting patients from a hospital to their homes or to a nursing home, these contracts would have to be fulfilled before he. would release these ambulances to Seabrook.
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' M f; Breau has stated these conditions. clearly to Seabrook's representatives. However, their only concern, he said, was_to get the figures on paper.
They never questioned i
the realities'behind this."up to" contract. Mr. Breau freely i admits that the'only reason his company signed the contract was for the financial gain provided to the company and employees. j He described these payments as " free" money.
According to Mr. Breau, a total of 60 drivers ha've been' l
trained by Seabrook to respond in an emergency, but he feels that 90% of them are involved only to receive the financial re9ards. If an actual emergency occurred, he does not believe ;
his EMTs would leave a " safe" area and dr;>e into a contaminated i
area. He has already heard some of his drivers state, "If there is a~ disaster, you wouldn't get me up there "
In the event of an emergency, Mr. Breau is the contact person at Marlboro-Hudson. Upon being notified, he and the dispatcher are to begin contacting his drivers. He feels that he could t.ach 90% of them, but he believes only a small number would actually respond. If an emergency occurred during the day, he could contact and mobilize twelve crews right away (assuming they agreed to respond). However, if the emergency occurred at night, it would take considerable time since some of his drivers live in Fitchburg and other towns west of Worcester. Marlboro-Hudson stores some of its vehicles in j Clinton, Worcester, Marlboro, and Hudson. Their normall/ daily a
l runs are between Framingham and Worcester.
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'Once the drivers are mobilized, it would take.
approximately 45 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to arrive at the Staging Area in Haverhi11, as long as the roads were clear.
Mr. Breau does not know where the drivers will be sent, but it is his understanding that they could be sent into a contaminated area.
However, the drivers would decide at the-time of the emergency whether or not they would go into a contaminated area.
Based on what Mr. Breau told us, there is no reasonable assurance that Marlboro-Hudson can ever provide more than 9 ;
i ambulances, 8 wheelchair vans, and 3 critical care units, and these numbers may well be optimistic, given his comments about his drivers.
- 9. General Ambulance Needham, Massachusetts (Mangan) On February 20, 1989, I telephoned Mr.
Bedigan, the President of General Ambulance, regarding General's contract with Seabrook to provide emergency service in the event' of a radiological disaster.
Mr. Bedigan advised me that they are currently negotiating with Seabrook for a new contract. He has not decided whether or not he will renew. His previous contract has expired. He pointed out that he has reduced the size of his I company. General now only has one location and few ambulances.
Therefore, any new contract (if he signs) will be for less than four (4) ambulances. He would not give an estimate of the L
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l number he might agree.to provide if he does decide to; sign a new contract.
, Eased on this information, it would not be prudent to
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count on; General Ambulance to provide any ambulances in the event _of a radiological emergency at Seabrook Station.
- 10. B&L Ambulance Portland, Maine (Mangan) On January 30, 1989, I interviewed, by telephone, Leo Bouchard, the owner of B &'L Ambulance regarding B.& L's contract to provide NHY with emergency ambulance services in the event of a radiological disaster.
Mr. Bouchard stated th9t he has agreed to provide eight ambultnces and one' wheelchair van, each with at least one driver, to evacuate hospitals and nursing homes prior to any 1
In return, NHY would keep his meltdown at Seabrcok Station.
drivers aware of the danger, and his driver could leave at any time during the evacuation. As he understands B & L's commitment', at no time would his drivers be driving into a radiation plume. Drivers that choose to stay if the danger level was high are to-be issued protective gear, he said.
Mr. Bouchard states that his entire staff of 50 have signed on to participate with NHY and have been trained and paid.
Mr. Bouchard is the contact person at B & L who would receive a call from Seabrook in the event of an emergency. The dispatcher would then use pagers to contact the drivers on duty, and he would telephone the ones off duty. Mr. Bouchard
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estimates ft would take. approx!.mately 10~ minutes-to contact enough drivers to man his vehicles. However, he'could.not guarantee _,that they a11'would.show up. He. estimates it would take between-10-30 minutes'for the drivers to assemble in Portland. He'would instruct the drivers who a're on the road .l carrying passengers to take them to their destinations before .
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-they report to Portland. In a drill, it took'one hour for his drivers to report'from' Portland, Maine, to the Salem, New Hampshire,-Staging Area. l Based on-this information, there appears to be reasonable assurance that B & L will offer eight ambulances and one wheelchair van in the event of a Seabrook emergency. But there is-no assurance that the B & L drivers would drive into contaminated ~ areas or stay on duty throughout the emergency. q l
Summary of Ambulance Company Investigation j The following data emerges from our investigation:
- 1. There can be no~ reasonable assurance that more than 51 ambulances, 4 ambulettes, 24 wheelchair vans, and 3 critical I care unites will be offered by these ten ambulance companies in the event of a radiological emergency at Seabrook. I I
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As-many.as 331 o'f the ' ambulances: and 16 of'.the
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wheelchair vans can not be counted on to drive'into contaminated areas. ___
B. BUS / VAN COMPANIES'
- 1. . Weagle Bus Company
, .Shrewsbury; Massachusetts-(Mangan) Brian Taylor..and I interviewed. Alan Weagle, the President of Weagle Bus Company, on March 11, 1988. At that time, according to his letter of agreement and Appendix M of the SPMC, Weagle had agreed to provide:
76 School buses 11 Half-size school buses-08 Vans 04 Wheelchair vans 1 01 Wheelchair bus He told us Weagle was exclusively a contractor for schools. He indicated that they had signed a contract with Seabrook's.
owners. In the event of a Seabrook' emergency, he said they would-have to first finish delivering the children onboard' their. buses to their homes or. schools. Then they would have to assembls their buses and drivers back at the bus yard. He realizes that they are located some 60 miles away from Salisbury, but he anticipates that from Shrewsbury, it would take his buses less than an hour to get to the EPZ in an emergency.
7 (60th) On February 7, 1989, we went to Shrewsbury to speak to Mr. Weagle in order.to verify or update.information hei had provid_ed a year earlier. This time he declined to speak with us, and we were directed to present our questions to Fopes
& Gray.
We therefore have no reason to doubt that Mr. Weagle still intends to offer his vehicles and drivers, as he indicated a year ago.
- 2. Fox Bus' Lines, Inc.
Millbury, Massachusetts (Mangan) A year ago, on March 21, 1988, I interviewed q Mr. Brian Fox, the Vice President of Fox Bus Lines. At that.
time they had a letter of agreement to provide 15 charter / tour buses to-assist in an evacuation of the Massachusetts towns near the Seabrook nuclear plant in the event of an emergency there. 'But he was not sure he was going to carry through on that agreement. Shortly before I spoke with him, he had received a' check from Seabrook's owners'for his annual retainer under the agreement. But the check he had just received had
" bounced"; so he felt he had no obligation. )
i (Paolillo) On February 13, 1989, I called Fox Bus Lines and spoke with Mr. Brian Fox. I wanted to confirm the status of their agreement to assist Seabrook's owners in '
evacuating the area around the Seabrook plant in the event of an emergency there. Mr. Fox declined to answer my questions, i however, and referred me to Ropes & Gray.
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(Both) As to this company, we have to assume from their refusal to speak to us that they finally did get paid and do intend._to provide the buses specified in the agreement.
- 3. Dee Bus Company Concord, Massachusetts (Mangan) Brian Taylor and I interviewed Mr. George Dee, Manager of Dee Bus Company, a year ago in March 1988. At that time he confirmed a letter of agreement with Seabrook's owners to supply 20 school buses from its bus yard in West Acton, Massachusetts. He indicated that his school contracts have a priority; the school children would have to be brought home before reporting to Seabrook. He said he wet told by representatives from Seabrook that it would be very unlikely that his buses and drivers would have to drive into.a contaminated area, because they will have enough warning, before contamination happens, to evacuate everyone, (paolillo) On February 16, 1989, I called Dee Bus Company and spoke with Mr. George Dee. He told me that Dee had contracted to provide up to 21 buses, but he declined to answer any of my additional questions, referring me instead to Ropes &
Gray. :
(Both) It appears that Dee is committed to provide 21 buses, but there is no reasonable assurance that these buses and drivers will travel into contaminated areas.
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- 4. MGGregor-Smith Bus Company Merrimac, Massachusetts' (Mangan) A year ago, in March 1988, Brian Taylor and I interviewed Mr. Stephen Gadd, Vice President of McGregor-Smith Bus 1 Lines. At that time he indicated that he had signed a letter of agreement back in 1987' indicating a willingness to provide up to 120 buses, but he said that Seabrook's owners had subsequently. tendered a contract asking
.him to commit to send this number of buses, and he had decided not to sign it or make this commitment.
(Paolillo) On February 9, 1989, I contacted the McGrsgor-Smith Bus Company located in Merrimac, Massachusetts.
I spoke with their Vice President, Stephen Gadd, and he advised I me that McGregor-Smith is not under contract to respond to a radiological emergency at the Seabrook Nuclear Power Station within the State of Massachusetts. He continued by stating McGregor-Smith will not offer any buses or drivers.to the evacuation plan on the Massachusetts side. Mr. Gadd ended our conversation by telling me that at this time McGregor-Smith will not-sign a contract to participate within the state of Massachusetts in the Seabrook evacuation plan. !
(Both) The McGregor-Smith Bus Company should not be counted on to provide any buses or drivers to aid in evacuating the communities in the Massachusetts EPZ.
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- 15. . Marathon /Weybridge ;
Shrewsbury, Massachusetts m
_,(Mangan) In March 1988 I contacted the Marathon Bus-Line in.Framingham,-Massachusetts, and confirmed that they had signed a
-letter of agreement'to ' provide up to 36 buses. However, when'I attempted to contact them again in early February 1989, I found that their telephone was disconnected. I then determined that they were no longer in business at the previous Framingham location. .It appears that Marathon is.no longer in business.
In February 1989 I also sought to contact the Weybridge Bus Company. According to the Applicants' answers lto interrogatories, the company is located on Hartford Pike in Shrewsbury. When John Paolillo and I went to the listed address, we found that the company was no longer located at 1 this location. Phone numbers had been disconnected. J There is no assurance whatsoever that the Marathon /Weybridge Bus Company currently exists or that it will provide any buses in the event an evacuation'is called in response to a Seabrook emergency.
- 6. Hudson Bus Lines Medford, Massachusetts (Mangan) A year ago, on March 18, 1988, I spoke with Mr. Kenneth Hudson, Sr., the President of Hudson Bus Lines. He said Hudson runs a series of commuter bus routes between Boston and a number of other Massachusetts communities north of
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1 Boston. He~ admitted'that he had provided Seabrook's owners 1
with a letter stating his. agreement to dispatch all his available-Auses (up to 25) in the' event'of a need to evacuate people due to an emergency at the Seabrook nuclear power plant. He had not signed a contract to provide these vehicles, as he did not want to commit to provide any set number. He said his regular contracts are his top priority; so he could not guarantee that 25 buses would be available. He informed me that Hudson was not being paid a retainer.
(Both) On February 13, 1989, we visited the Hudson Bus Lines-office in Medford and spoke with Mr. Kenneth Hudson, Jr., the company owner. He said he thought Hudson had signed a letter of agreement to provide "up to" 50 buses depending on the time of day, in the event of an emergency at the Seabrook nuclear plant. He explained that not all of his buses are parked at the Medford lot: 40 are in Medford and 20 more are ,
1 parked in Nashua, New Hampshire. In all cases, he said his buses would first complete their daily duties before proceeding with participation in the evacuation effort. He also said that his drivers have yet to be trained by Seabrook's owners, and he says his drivers have not been told they might have to drive into a radiation plume to evacuate people during an emergency.
As to his commitment to provide "up to" 50 buses and drivers, he said that if the emergency evacuation is declared during the commuter rush hours (6:30-8:30 a.m. and 4:00-6:00 p.m.), then I
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f l the amount"of buses he would have available to contribute right away to the evacuation' effort would tx3 limited. His buses
. would firs _t' have to finish their normal daily routes before !
they could participate in the evacuation plan. Mr. Hudson did- l not know how long.it would take all of his drivers.to report to the bus: yards'after being contacted.
Based on the information we have:been provided, it i appears that if buses are needed between 6:30-8:30 a.m. or i 4:00-6:00 p.m., Hudson Bus Lines may only be able.to provide a fraction of the 50 buses it could otherwise.make available.- At such times, they should not be counted on to provide more than about 10-15 buses. !
- 7. Buckingham Bus Service Groton, Massachusetts (Mangan) A year ago,.in' March 1988,. Brian Taylor and j i
I contacted the Buckingham. Bus Company in Groton, Massachusetts, and spoke with the office secretary, Linda Leibig. At that time, Buckingham had signed a letter of agreement agreeing to make available up to 14 buses and 2 vans to assist in an emergency response plan to evacuate the area around Seabrook Station in the event of an emergency. Ms. Leibig confirmed ,
this agreement, and she said a contract had been signed. She indicated that because this is a charter bus company, some of l 1
their buses and drivers could be out on a charter at the time 1
of an emergency. She said that Seabrook's owners had agreed to provide their drivors with protective equipment when needed.
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e (Paolillo) On February 16, 1989, I called the Buckingham Bus Company in Groton, Massachusetts, and spoke with Mr. Paul-Touiney, the manager, regarding Buckingham's participation in an evacuation plan for the Seabrook nuclear plant. Mr. Touiney declined to answer any of my questions and referred me to Ropes & Gray.
(Both) Based on the information we have, Buckingham will provide "up to" 14 buses and 2 vans in the event of a Seabrook emergency. But there is no reasonable assurance that a full 14 buses will be provided. Some of the buses could be out on charter at the time of an emergency. Probably no more than 10 buses should be counted on initially.
- 8. Big W Transportation, Inc.
Ashland, Massachusetts (Mangan) Big W is a company that was not being relied upon by the SPMC a year ago; so I had no reason to interview the owner / manager until now.
(Both) On February 7, 1989, we contacted Robert P.
Winterhalter at the Big W office. He advised us that he had contracted to provide buses in the event of a Seabrook emeraency, however, he did not wish to discuss this matter with us and declined to answer our questions.
(Mangan) On February 15, 1989, I contacted Mr. James Sleeper, a part-time bus driver for Big W. Mr. Sleeper had contacted our office on his own a year earlier for information
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about Seabrook, at a time when he had just been through I
Lry Seabrook's bus driver training and was evaluating whether to pa r t icip at_e f u r ther . Mr. Sleeper informed me that he believe Big W has ~ontracted to supply 35 buses and drivers. However, he expressed a number of concerns about the reliability and the timeliness of Big W's response in an emergency. First, he explained that assembling'the drivers may take some time. In his case, it would take him 1 to 1-1/2 hours to get from his l home to the Big W bus yard in Ashland. Then, because of the distance from Ashland to the Massachusetts EPZ, it would take the buses an additional 1-2 hours to get to the EPZ, depending on traffic. Second, he has concerns about the mechanical reliability of the Big W buses. He does not believe that they are properly maintained and says that at any time 10 buses may be broken down. When he was participating as a driver for Big W in the Harvard graduation week activities in June 1988, he
.had to drive 4 or 5 different buses because the buses kept breaking down.
According to Mr. Sleeper, when Seabrook's people were recruiting bus drivers, they inferred that they were only interested in obtaining the drivers' commitment (for which they are paid a stipend) to participate in training and drills. Mr.
Sleeper was left with the understanding that it would be up to the individual drivers and companies to decide whether to respond, or not, to an actual emergency.
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Based on1this information, it appears that in the event of a Seabrook' emergency, fewer-than 35 Big W buses can be counted on,to respond, due to the likelihood of. mechanical
. problems that may prevent some of the 35 offered vehicles from respo'nding. If five are broken down,.that would mean that'30 are mechanically fit.to go.
- 9. Parent Bus Andover, Massachusetts (Mangan) A year ago, in March 1988, Brian Taylor and I interviewed Mr. James Naticchioni, the Manager of Parent Bus. At that time he indicated that Parent had agreed in.a letter to offer up to.30 buses, 5 vans, and 3 wheelchair vans to Seabrook's owners to assist in evacuating the area around
-the Seabrook nuclear plant in the event of an emergency there.
(Both) On February 2, 1989, we interviewed Mr. James Naticchioni-again. He is still the Manager of Parent Bus Company. He informed us that Parent has signed a contract with New Hampshire Yankee ("NHY") to provide NHY "up to" 31 buses in the event of a radiological emergency. He explained that they no longer have the vans and wheelchair vans which he had offered previously. He also explained that he understood "up to" to mean that he will provide as many buses (up to 31) as he can get, with drivers, at the time. Currently only 19 of Parent's drivers have been trained, but he expects that he could get about 25 who would drive the buses in the event of an
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emergency. -However, Mr. Naticchioni stated that servicing Parent's regular school contracts will always be his first i
priority._ They currently contract with North Reading and Andover, Massachusetts. In the event of a Seabrook emergency, i school children in those school districts would be serviced before his buses would respond to assist in a Seabrook evacuation. During normal morning and afternoon school bus !
hours, 24 of Parent's buses are out on jobs and only 8 are left parked in the bus yard.
He also stated that when his buses did respond to j assist in an evacuation, the Parent buses were to be dispatched to the Merrimac and West Newoury area exclusively. It was his understanding that they would not be sent to at contaminated area.
One concern Mr. Naticchioni has is that he has a high driver turnover rate, and New Hampshire Yankee has not requested that NHY be informed when drivers who have been trained to participate resign.
In conclusion, Parent has no vans or wheelchair vans to offer, and there is no reasonable assurance that Parent can ]
ever supply more than about 25 buses in the event of a Seabrook emergency. Even then, they cannot be counted on to send buses into any of the Massachusetts EPZ towns except Merrimac and West Newbury. In the event that Parent buses are requested during the normal school bus run hours in the mornings and l
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afternoons, parent cannot be relied upon to have more than 8 buses available.
- 10. -Denise Inc. d/b/a Travel Time Bus Company peabody, Massachusetts (Both) On February 2, 1989, we interviewed Richard Cowdell, Manager of Denise Inc. d/b/a Travel Time Bus Company, regarding their contract to provide emergency service to Seabrook in the case of a radiological disaster.
Mr. Cowdell stated that Denise Inc is under contract to provide up to 135 buses (various sizes) and 15 wheelchair vans and drivers in the event of an emergency. He explained "up to" as meaning as many as he could mobilize at a given time. Denise Inc.'s regular school contracts would be their top priority. If an emergency occurred between 6:30-9:00 a.m.
or 1:45-3:45 p.m., 80% of their buses would not be able to respond until their normal contracted routes had been completed. ;
It is Mr. Cowdell's understanding that the buses would be driven into contaminated areas; however, all drivers would be provided with a dosimetry meter and the drivers could pull out when they read a dangerous level of radiation. Mr. Cowdell states he attended a training seminar at Seabrook at which time they played down the possibilities of reaching a high level of radiation. They pointed out that people have contact with radiation each day. They also stressed that they would be advised when they reached a high level.
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According to Mr. Cowdell, it is not spelled.out who their contact' person was in the: event of an emergency. He assumes th_at the answering service would contact him and the owner, and'they would then contact the drivers. If an emergency occurred during normal business hours, it would take 1-1/2 to.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to contact enough drivers to man all vehicles and 3-1/3 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if an emergency occurred at night.- Only 2/3 of Travel Time's 150 employees work during the. summer. Mr.
Cowdell does not know if he would be able to locate the other 1/3 in the summer.
Mr. Cowdell does not know how many drivers have actually signed up to respond. He was not able to give even an estimate. However, he believes that of the total number signed up, 75% would respond and 25% would be sick or otherwise unavailable. Denise Inc has approximately 150 bus drivers on its payroll. Denise Inc also has a high rate of driver turnover. They provide Seabrook with updated list of their drivers only once a year.
Based on this information, it appears that if an emergency were to occur during normal school bus hours, only 20% of the 135 may be able to respond promptly. This would be 27 buses. We have no information on how many drivers have signed up--the owner did not know, and he expects that only 75%
of those would show. In the summer, when only 2/3 of the drivers are employed, it may not be possible for Denise to 1
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supply more-than 90 buses, even with driver participation.
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- 11. Park Transportation
-Avon, . Massachusetts
, (Both) On February 1, 1989 we interviewed Vincent H.
Savill (President) and Barney Morrissey (Manager) of Park Transportation regarding Park's contract with NHY to ptavide vehicles and drivers in the event of a radiological disaster at Seabrook Station.
According to Mr. Savill, he has agreed to supply as many buses, wheelchair vans, and station wagons as he could in the event of an emergency. He breaks down his vehicles as follows:
20 Wheelchair vans (which hold 4-8 passengers) 06 Buses (each seats 43 adults)75-100 Vans / station wagons (which hold 12-15 passengers)
Park has made it clear to Seabrook that they would only provide the number of vehicles available at the time of an emergency.
They stated that Park's school and state contracts will be serviced first. Park has notified NHY that they would not respond to an emergency which occurs Monday-Friday between 7:00-9:00 a.m. and 2:00-4:00 p.m. They would first instruct all drivers to finish their regular routes. Park's contracts include school districts as far south as Bourne, Massachusetts (near the Cape), and as far north as Somerville, Massachusetts.
They estima'te that only 10% of their vehicles would be l 4 available during these school bus route hours.
Park has a total of 85 bus drivers who have signed up
, to respond and 20 managers and mechanics who also have agreed to respond. Barney Morrissey is the contact person with NHY in the event of an emergency. He estimates he could contact 90%
of his drivers in a period of one hour. They would report to the bus yard in Avon. Those drivers who already have buses north of Boston would immediately report to the NHY Staging Area. Route guides from NHY will then arrive at the bus yard i and supply each driver with a dosimetry to measure the radiation level. The route guide will then guide the buses from Avon to the Staging Area in Haverhill which would .ake approximately 1-1/2 hours. Mr. Savill states that his drivers were aware that they could be driving into radiation, but it was their understanding they had the option to pull out once their dosimetry read a dangerous level.
Mr. Savill stated that Park has a high driver turnover rate. He believes that NHY may have a pool of spare drivers, since they requested to rent Park's buses without drivers.
Park has denied this request.
Based on this information, it appears that if a Seabrook emergency occurred at or near the time of normal school bus hours, Park may be able to provide only 2-3 wheelchair vans, 1-2 buses, and 7-10 vans / station wagons. At
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best, with 105 potential drivers and a likelihood of contacting 90% of~them in the event of an emergency,. Park could supply up
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- to 91. vehicles. -
But given his high turnover rate, this number L
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, appears to be overly optimistic. A safer and more reliable i number to count on.would be 60-70 vehicles total.
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Summary of Bus Company Investigation The following points have emerged from our interviews.with the bus company owners / managers:
- 1. The number of buses school aus companies will provide, in the event of a Seabrook emergency is highly variable and dependent on the time of day, day of week, and time of year.
During typical " school bus hours" most of the school bus companies intend to honor their school contracts first. During the summertime, it is not uncommon for school bus drivers to take other jobs and not be in close contact'with thier companies.
- 2. By agreeing to provide "up to" a given number of buses (and/or vans), the companies generally understand this to mean that they will attempt to provide as many buses as they can..."up to" that number, but many companies readily acknowledge that the number they expect to provide will be less than the "up to" number.
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- 3. The: bus companies seem- to experience a f airly. high -
driver turnover rate. Since NHY asks for an updated list of drivers only annually, this means that thefnumber of trained drivers'each company has varies throughout.the year,.and the total drops by a number equal to the to the total turnover experienced each year.
- 4. The typical off-hours means of contactirig the bus drivers is'by. telephone. This may be an adequate method if the.
emergency at Seabrook is in the middle of the night and the.
drivers ard all at home sleeping. But if the emergency is,
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say, in the late afternoon or early evening, or on weekend j days, when bus drivers may well be away from home, there is no assurance that they can be contacted. A prudent planner should i
not. assume that all the drivers being contacted during these hours. Probably the numbers should be discounted by at least ;
10-20% for this factor alone.
- 5. Some of the companies' managers understand that their buses and drivers will not be assigned to go into contaminated areas, or into a plume of radiation, to assist in the evacuation. Even for companies which do not have this i understanding, they have been led to believe that risks are minimal, and that there would likely be time get the buses in and out to before plume arrival. If the emergency involves a fast-breaking, major release of radiation over large portions of the six Massachusetts communities within the EPZ, the number
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- oftbuses'and drivers that can be counted on to respond needsLto be reduced.
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C. TOW COMPANIES' Federal' Auto-Repair 1.
Byfield, Massachusetts (Mangan) On February 20, 1989, I telephoned and spoke to Alan Whitehead, the owner of Federal Auto Repair. . He informed me that since signing a letter of agreement with Seabrook'in-1987 to-provide "up to" two tow trucks in the event of an emergency evacuation of the area around Seabrook, he has not' received the promised payment. Therefore, his view'is that he is under no obligntion and would not get involved in the event of a radiological emergency.
From this conversation, I conclude'that Federal Auto Repair cannot be counted on to provide any tow trucks in the event of.an emergency at Seabrook.
- 2. Coady's Towing Service Lawrence, Massachusetts (Paolillo) On February.17, 1989, I telephoned and spoke with Ms. Sandy Bouchard, the Office Manager for Coady's towning service in Lawernce, Massachusetts. She stated that Coady's has agreed with Seabrook's owners to supply "up to" all 15 of their tow vehicles, with drivers, to assist efforts to evacuate the area around Seabrook in the event of a radiological m
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[. emergency. -Coady's has the following inventory of tow vehicles:
l 3 Large trucks (able to move large 18-wheel trailer trucks
. 3 Carrier trucks-(transports cars on bed of truck) 9 Small wreckers (normal size tow trucks used for towing cars)
Coady's has 22 drivers, both full and part-time. Drivers who are on-duty would get dispatched immediately to the tow yard.
Off-duty drivers would be telephoned; these drivers, once contacted, could take 1/2 hour to respond.
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