ML20235S199

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Questions Emergency Response Planning Process as Established by Congress & as Actually Executed.Five Points Raised, Including Whether Public Svc Co PRA Accepted
ML20235S199
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 12/29/1987
From: Moyer H
AFFILIATION NOT ASSIGNED
To: Asselstine J
NRC COMMISSION (OCM)
Shared Package
ML20235S055 List:
References
FOIA-87-346 NUDOCS 8707210582
Download: ML20235S199 (3)


Text

51 Westside Drive

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i Exe ter, New Hampshire 03833 December 29, 1985 NRC Come.issioner, James Asselstine l

U.S. Nuclear Regulatory Connission l

Washington, D.C. 20555 l

Dear Commissioner Asselstine,

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I have decided to write you only af ter considerable thought and many other cvenues of inquiry that have resulted in dead ends.

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'I am a high school instructor of science, not a local public official or a person of 'any official status in local or state government.The reason I am writing you is to see if some level of government will be responsive to the qJestions I have raised, as an affected citizen, concerning Emergency Response Planning.

As you are no doubt well _ aware,'The New Hampshire State Civil Defense Agency ed consultants, in cooperation with affected local units of government, cre currently developing Emergency Response Plans (ERP's) designed to provide reasonable assurance' of protection of the public's health and safety in the ovent of a radiological accident at Seabrook Station. I have been following the d>velopment of.such plans since the introduction of the 10 mile EPZ in 1980. I have raised what I thought were seriously considered questions of the consultants, State Civil Defense and F.E.N.A..

F.E.M.A., in the person of Mr.

Ed Thomas, has never responded to my inquiries.... and the answers given by the censuttants and State Civil Defense are so evasive and lacking in substance as

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to be meaningless. More recent developments have increased my sense of uneasiness with this entire process.

Consultants hired by State Civil Defense have been meeting with local cHicials of the town (Selectmen) and with School Boards in an effort to solicit their support for the adequacy of existing town plans, which are in their fourth er fif th draf t form. Statements made by consultants and connents from Civil Defense officials.themselves seem to be calculated attempts to discolor the realities associated with various aspects of the planning process and accident scenarios. Following are several examples which are verifiable because the public meetings at which.these comments were made were taped.

Before the Hampton School Board, consultants said... in referring to the cost serious Emergency Action Level described in NUREG 0654...(and I'm paraphrasing) 'A 6eneral Emergency is a condition where a release of radiation is possible but would not go beyond the boundaries of the plant'. At the same coeting they said that the emergency response actions taken at Three-Mile-Island (including evacuation) went very smoothly and that there was no panic, as everyone who was supposed to did their job well.

Speaking before the Exeter School Board a week or so later (earlier this December), consultants said that at T.N.I. no radiation was released beyond that plant's boundaries. They also have repeatedly told public oHic.ia11_that, should an accident occer, the public would have between 12-34 hours advance notice before any radiation was released of f site. State Civil Defense has based these conclusions on the Probabilistic Risk Assessment done for Public Service Co.of New Hampshire by Pickard, 8arrick and Lowe... and on the verification of cccuracy made by a New Hampshire legislative committee appointed by Governor Sununu. Civil Defense has also stated at public meetings and in their correspondence' that Letters of Agreement exist between their agency and bus companies who would provide emergency transportation.

8707210582 870717 ENCLOSURE 1 PDR FOIA CONNOR87-346 PDR l

, Hamitg cpokea to the owner cf one Gf thtse bus compaales listed la

' Heyton'o town plan, I know that no c ch Letter cf Agreement tas eiher expressly giv;a or IIplied to Civil Defense by that company. That particular owner has alsa stated that in his opinion (because many of his drivers are part-time women wh3 have small children of their own) should an order to evacuate be given... he

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tould not expect a large percentage of his drivers to provide the emergency j

transportation that civil Defense is counting on.

It is clear to me (and this is my opinion af ter having carefully followed this' process for the past 5 years) that Civil Defense has no intention of cddressing the hard questions raised by this planning process. Rather, they are trying to get a community's participation in the planning process accepted as

-evidence for a determination of the adequacy of the town's plans.

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It seems there. is a great gap between the intent of Congress by establishing the process of Emergency Response Flanning and the realities associated with the execution of that function. I realize that you are in a difficult position on this issue,but it would be helpful to me and other affected citizens if you could answer the following questions:

1. Has the NRC accepted as final and accurate Public Service Co.'s Pesbabilistic Risk Assessment ?
2. Is it reasonable to assume that the public would have that degree of advance warning time listed in the study rather than the 1/2 to several hour advance notification referred to in NUREG 0654 ?
3. Would the enclosed " Letter of Agreement" be viewed by the NRC as evidence of the emerptncy response comrnitment required by bus companies in the ovent of a call to evacuate ?
4. Is it appropriate to place significant credibility in the stamp of approval which a New Hampshire legislative connittee gave to Public Service Co.'s Probabilistic Risk Assessment ?
5. Is it possible that a r.ommunity's participation in the planning pescess may be interpreted by F.E.H.A. or by the NRC as evidence of acceptance of the plan's adequacy by the town ?

If you cannot answer these inquiries as presented by me, would you answer them if presented by a town or a school official ? If the answer to that question is so, will you please direct me to the branch of your agency whicl* will respond to th2se inquiries. You are seen as a voice of reason on the NRC Commisson.

I appreciate the time you have taken from your utry busy schedule to read the concerns I have raised.

Sincerely, b

Herbert S. Moyer,

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'fr(m.

SURVEY TO PROVICE DCRT.CY TRANSPCP.TATION ASSISTANCE TO TE L

STATE.CF PEW HAWSHIRE Are.you willing to provide transportation assistarce in the event of en energency?

YES NO.

Name and add:ess of transportation Conpany 1.

2. - Contact perscn/ alternate with telephone number, business /2A hour.

3..

Nurr.ber of buses / vans operated.

4 Number of buses / vans available for emergency response.

-5.

Passenger capacities.

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Locations at which buses / vans are garaged.

7 Number of crivers available for buses / vans.

8.

Time required before buses / vans with drivers can be dispatched.

9.

Two-way communications capability of cuses/ vans. If yes, what frequency?

10. Comments or constraints on/to use of buses / vans. (Use reverse side if needed)
11. What is your daily rate when leasing buses?

j Signed Date 1

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UNITE 3 STATES f

NUCLEAR REGUI.ATORY COMMISSION g

I mem=oron.co.m k......

January 9,1986 oFPCE OF THE

- soNER Mr. Herbert S. Moyer 51 Westside Drive Exeter, NH 03833 3

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Dear Mr. Moyer:

l Thank you for your December 29, 1985 letter concerning emergency plan-l ning issues at Seabmok. As a Commissioner, I will have to eventually f

pass judgment on whether Seabrook should be licensed to operate.

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Included in that ultimate judgment will.be decisions on many of the emergency planning issues you raise in your letter. It would be i

improper for me to comment on your questions at this time. However, I l

have asked the NRC staff to respond to your questions.

I have also had I

your letter served on all the parties to the Seabrock proceeding.

Thank you for your interest in this important matter.

l Sincerely, g~

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/

James K. Asselstine

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ENCLOSURE 2

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