ML20235T404
| ML20235T404 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/05/1987 |
| From: | Janetos D HAMPTON, NH |
| To: | |
| Shared Package | |
| ML20235T353 | List: |
| References | |
| OL, NUDOCS 8710130076 | |
| Download: ML20235T404 (9) | |
Text
'
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before-the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
October 5,19 87
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
)-
50-444-OL
)
Off-site Emergency (Seabrook Station, Units 1 and 2) )
Planning Issues.
)
)
i CORRECTED i
PREFILED TESTIMONY OF DONA JANETOS
~ON BEHALF OF TOWN OF HAMPTON REGARDING TQJJ REVISED CONTENTIONS III, IV_,_ y.1 0.
Please state your name and position with the Town' of I
Hampton.
A.
My name is Dona Janetos.
I am Chairman of the Town of Hampton Board of Selectmen, Hampton, New Hampshire.
Q.
Please summarize briefly the' duties of the Board of Selectmen, and the length of time you have been a member of the l
Board.
A.
The Board of Selectmen is the governing body for the Town of Hampton which adopts laws and establishes policies f or the Town.
These laws and policies are enf orced by the Town Manager, and other I
l Hampton administrative officials.
I l
1 Among their other. responsibilities,.the Selectmen are routinely j
required to assess the personnel needs for each town department.
P '% 8L~,
SH AINES & Mc E ACt 1ERN. p.essse.. assoc ve%...o.sr.s
. l;F l
4 Accordingly, the Board must evaluate the; tasks to be performed within each department and determine. the number of necessary personnel.
I have performed a similar assessment in regards to certain provisions of the NHRERP.
I was first elected to the Board of Selectmen in 1985, and elected Chairman in 19 87.
O.
What is the purpose of your testimony?
A.
The purpose of my testimony is to state the position of the Town of Hampton with respect to certain contentions filed by the Town in this proceeding.
These contentions address deficiencies in the New Hampshire Radiological Emergency Response Plan (NHRERP) for the Town of Hampton which was prepared and submitted by the State of New Hampshire to FEMA.
My testimony will focus on whether the Town, l
including Hampton Beach, can be reasonably and saf ely evacuated in the event of a radiological emergency at -Seabrook Station.
1 0.
Briefly describe the Town of Hampton, its location and
-0 seasonal population.
A.
The Town of Hampton is located less than two miles f rom the l
Seabrook Nuclear Power Plant.
The Town' has approximately five miles of coastline, most of which is comprised of the public Hampton Beach.
Coastal Route 1A, a two lane road, runs north / south, immediately I
adjacent to the beach.
Located directly across Route 1A f rom the beach are numerous m ot el s, condominiums, seasonal residences, souvenir shops, eating establishments, and other small' businesses.
2 i
s=~ c s a = c Acsc as.
m..
....a.
-n.
1
{
j During the summer months, tens of thousands of residents, tourists, transients, beachgoers, and others seeking recreation crowd into Hampton Beach.
Extending West and South f rom the beach area, into the Towns of Hampton and Seabrook, lies an area of marsh or wetland where the nuclear plant is located.
The marsh essentially divides Hampton Beach from the muin area of town, creating an island of beaches, summer crowds, and traffic.
There are only a limited number of 4
access roads from the beach, across the marsh, and into town.
In the event of an emergency at Seabrook, therefore, much of the evacuating traf fic must proceed west toward, by, and beyond the power plant.
Many evacuees would be required to move closer towards a damaged reactor, the very thing from which they would be attempting to escape.
l Additionally, as Ham con police of ficers will testif y in this proceeding, the road system in Hampton Beach consists of narrow one-
]
I way streets and two lane roads.
Even the principal access routes into the beach area, Routes 1A and 51, have only two Janes.
A single
- accident, breakdown, or stalled vehicle on one of the limited evacuation routes could freeze a substantial portion of the evacuating traf fic.
Vehicles within sight of the reactor would be unable to move.
l O.
Describe the traffic in the area of Hampton Beach, under l
normal conditions, on a sunny summer day.
l 3
i SH AINES & Mc E ACHERN - weersse,..sw..a.no.,o,
A.
In good weather, traffic is routinely bumper to bumper throughout Hampton Beach.
Typically, traffic must proceed at a slow, stop-and-go pace.
Hampton Beach is extremely congested with pedestrians, parked motor vehicles, and vehicles in transit.
O.
What is the position of the Town of Hampton with respect to the NHRERP prepared by the State of New Hampshire for the Town of Hampton?
A.
The Town of Hampton believes that the NHRERP does not reasonably assure that the Town, including Hampton Beach, can be evacuated adequately, or safely, in the event of an emergency at Seabrook.
We cannot give approval to a plan which we believe is unworkable.
The Town therefore will not train f or, or implement the IERERP in the event of an emergency at Seabrook.
0 Why do you believe that the NHRERP is not workable?
i A.
First, there are not adequate personnel to evacuate the Town, including Hampton Beach, in a radiological emergency.
For
- example, under the
- NHRERP, the Town Manager is assigned responsibility to staf f, coordinate and direct, on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis, all Town departments during an emergency.
(see NHRERP, Vol.18, p.
I I
IV-9).
The Town Manager's entir e support staff, who have no i
experience in emergency management, consists only of one f ull-time secretary, one f ull-time bookkeeper, and one part-time assistant, which we believe is plainly inadequate to monitor and direct a,n evacuation of tens of thousands of residents and tourists from Hampton Beach.
4 l
l SH AINES & McE ACHERN. maewne mat asaoe.4wes enca%rve
__J
Additionally, beyond the briefest outline of. procedures.in the NHRERP, no dctails or guidelines are provided to indicate when the Town Manager should direct a particular emergency response, or what j
priorities should be addressed if as the Town believes, there will not be sufficient resources to meet all emergency needs simultaneously.- How will the Town Manager make these decisions?
The
)
NHRERP is not clear beyond requiring the Town Manager to base his decisions on " input" from the Town's Department Heads.
Accordingly, i
the plan provides no clear direction to the Town Manager on how best to minimize radiation exposure to the largest segment of the public.
Finally, in the Town of Hampton, the Town Manager is also the Civil Defense Director.
As the Civil Defense Director,.he Town Manager is assigned certain additional
- duties, including the reviewing of transportation requirements for the Hampton schools and serving as local contact with New Hampshire Civil Def ense.
(see NHRERP Vol.18, p. IV - 14).
It is not reasonable to expect a single individual, with a limited support staff,. to simultaneously perform all of these duties as assigned under the plan.
As a second example of personnel deficiencies in the NERERP, the Hampton Public Works Director is required, under the plan, to i
coordinate transportation f or special f acilities, schools, and those 1
with special needs, and to " assess the impact of current and I
forecasted weather conditions on the road network," although these i
duties bear no relation to his employment responsibilities.
-(see NHRERP Vol. 18, pp. IV 27, 29).
5 I
i SH AfNES & MC E ACHE RN + pentw.4, as.ociates a"ce=f =.
I 1
Under the NHRERP, the Public Works Director is also required to-i maintain accessibility of emergency evacuation routes in Hampton.
The Department, however, does not own a single tow truck.
How road i
clearance is to be carried out, therefore, and with what resources or j
i personnel, remains unspecified under the plan.
(Id. at IV - 27 ).
j 1
Additionally, although the NHRERP assigns these rcadway clearance and transportation responsibilities to the Public Works 1
Department, a substantial majority of individuals employed by Public Works have no _ raining or experience in performing these functions.
For example, out of a total of 60 in the Public Works Department, 19 members of the Department are routinely employed in waste water l
treatment and sewer maintenance.
24 other Public Works Department l
l employees are " temporary," are only approximately 17 years of age, I
i i
l and who typically perform such duties as dump attendance, trash pick l
l 1
I up and street sweeping.
These employees have no training or j
experience in roadway clearance or traf fic control.
In addition, should an evacuation be necessary during the school year, most of l
these employees will be in school.
j I
The plan, therefore, assigns individuals, whose principa) i l
employment responsibilities are maintenance of Town sewers, road i
l construction, and landfill (dump) management to manage transportation resources for special needs populations and to clear roads without a
{
i j
single tow truck.
l 6
l F.,
h SM AINES 6 MO E A C HE RN. o. ort s,%n.oge t e * % ae
.,r..
lt
s
[
i Q.
Under the NHRERP, the State of New Hampshire has pledged to 1
compensate with State personnel, motor vehicles, and other resources in the event these requirements cannot be met by EPZ towns.
Do you j
believe this compensatory plan will cure the deficiencies in the NHRERP for Hampton that you have described?
j A.
No.
I base this opinion on several reasons.
First, the j
j l
compensatory plan fails to specify how the State's emergency workers l
l l
will be promptly notified, coordinated, or diected to their assignments in the emergency planning zone.
Even assuming prompt notification and direction, most of these persons would be traveling i
from points well outside the EPZ. At the same time, thousands of motor l
l l
i l
vehicles would be attempting to evacuate Hampton Beach from limited i
access roads.
These access roads are the very roads which emergency j
1 i
workers necesarily must use to reach the beach area.
To expect, for j
i I
e x a m pl e, that a two lane road such as Route 51 would remain f reely 1
1 accessible to incoming vehicles while thousands of vehicles are at-
)
i tempting to flee the EPZ, I believe is wholly unrealistic.
The New l
l Hampshire Civil Defense Director, himself, has stated that additional State Police, beyond the limited number of of ficers in Troop A located l
in Epping, would require three to four hours to respond to an emer-l l
gency at Seabrook.
Second, the State showed it could not carry out even a limited j
and preplanned emergency drill for Seabrook.
The Federal Em er gency l
1 i
Management Agency noted "many deficiencies in the State's ability to l
provide evacuation transportation resources in a prompt and I
l l
l i
S H A IN E S & M c E AC H E R N - an y r es ca......ee. v.o...**o.u i
i d
coordinated manner."
(Egg,. Current FEMA Position and' Admitted Contentions on New Hampshire. Plans f or Seabrook, Appendix A',
Page-17.) 1 would also point out that the State's preplanned evacuation was perf ormed in February.
To my knowledge,.Hampton Beach was not t
particularly crowded at that time.
An actual emergency during the summer would present, with the beach population, 'substantially more 1
significant obstacles to.an effective evacuation.
Third, the State's compensatory plan relies heavily upon the Teamsters' Union to provide bus drivers for the evacuation vehicles.
The Secretary of the Teamsters' has stated, however, that in his opinion none of the Teamsters are obligated, and may refuse'for whatever reason, to carry out these duties during an emergency at Seabrook.
I am seriously concerned,.even assuming a significant i
number of Teamsters could be notified at the time of emergency, that
'I a sufficient number of Teamsters would drive into a radiological emergency. Additionally, the training provided to the Teamsters apparently has consisted of only one to two hours of instruction.
I J
f believe it is unrealistic to expect Teamsters to drive school buses, j
or special needs vehicles, when it is likely that most Teamsters have not had experience performing these duties, particularly under emergency conditions.
l During an ems rgency, therefore, the tens of thousands of people on Hampton Beach will be gridlocked on narrow roads, a scene repeated any sunny day at the beach, even under normal conditions.
Em e rgency 8
i
$H AINE S & Mc E ACHE RN. enorg es.cw o..'.or....c
, ance.g,.
..._____.__.__._m___
l i
1 J
l conditions will only magnify the problems.
- Fourth, as the Hampton. Police will testify in this proceeding, we have no confidence the state can or will be able to-timely compensate f or deficiencies in local personnel.
The State of New Hampshire has not shown that the State, itself, has this additional personnel to assist all of the EPZ towns, simul taneously, including providing an adequate number of State Police.
The Town of Hampton therefore has no confidence that the NHRERP can be reasonably or adequately implemented, with or without the training and participation of the Town.
j 0.
Does this conclude your testimony?
A.
Yes.
Respectfully submitted, TOWN OF HAMPT N By Its Att eys SHAINES EACHE 1 l
Profess *o 1 Ase ciat n
i l
By:
curl McEach Dated:
October
, 1987 By.
O
' Matthew T.. Brock l
I I
l 1
i i
9 l
l l
I ss A m e s a m e e a c w e n u.
......,...e,c....
...r..,..
I