ML20235X278
| ML20235X278 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/28/1989 |
| From: | Callendrello A, Ellis S, Frank C ABB IMPELL CORP. (FORMERLY IMPELL CORP.), PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | |
| Shared Package | |
| ML20235W814 | List: |
| References | |
| OL, NUDOCS 8903130399 | |
| Download: ML20235X278 (14) | |
Text
.
ggcnsd ti C
retgirn
' SHbC 89 tg -3 A10 25 February 28, 1989 nrrut Lt
-, - t"!
UNITED STATES EOF.: m; AMERICA w
NUCLEAR REGULATORY COMMISSION before the
-ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
)
50-444-OL
)
.(Seabrook Station, Units 1 and 2)
)
(Off-site Emergency
)
Planning Issues)
)
APPLICANTS' REBUTTAL TESTIMONY NO. 14 (THE EFFECTS OF A STRIKE BY MEMBERS OF THE NHY OFFSITE RESPONSE ORGANIZATION)
Panel Members:
Anthony M. Callendrello, Manager, Emergency Preparedness Licensing, New Hampshire Yankee S. Joseph Ellis, Manager, Response and Implementation, New Hampshire Yankee Catherine M.
Frank, Emergency Planner, Impell Corporation f
I 8903130399 890228 7
PDR ADOCK 05000443.
1 T
j PDR i-
[
f l
\\
TABLE OF CONTENTS-r I.
INTRODUCTION 1
II.
COMPOSITION OF THE NEW HAMPSHIRE YANKEE OFFSITE RESPONSE ORGANIZATION.
1 III. EXTENT OF UNIONIZATION 2
A.
Strike by All (Two) Unions at PSNH.
4 B.
Strike by All (Three) Unions at MECO.
4 C.
Strike by All (Nine) Unions at UE&C 5
D.
Strike by IBEW at Both PSNH and MECO.
6 E.
Strike by Any One Union at Any One Company.
6 IV.
STRIKE ANALYSIS
SUMMARY
7 V.
VOLUNTARY NATURE OF COMMITMENT 7
Attachment A:
Distribution of Unionized Personnel Within the ORO Attachment B:
New Hampshire Yankee Massachusetts Off-Site Emergency Response Organization Recruitment Form i
) :
l l
I.
INTRODUCTION This testimony addresses Joint Intervenor (JI)
Contention 9, which challenges the adequacy of the SPMC in providing assurance that adequate protective measures can and will be taken by the Offsite Response Organization (ORO) in.
the event of a strike or other form of job action affecting the availability of emergency personnel relied on to staff l
and maintain the ORO.
II.
COMPOSITION OF THE NEW HAMPSHIRE YANKEE OFFSITE RESPONSE ORGANIZATION Contract Drivers for Bus / Van, Ambulance, Tow (22 companies) 46.7%
930 Public Service Company of New Hampshire 15.6%
.311' Massachusetts Electric Company 10.4%
207 New Hampshire Yankee 8.8%
176 Yankee Atomic Electric Co.
8.4%
168 United Engineers & Constructors 7.7%
154 Other companies (15) 2.3%
46 1992 The percentages above are based on the 1/26/89 ORO roster, excluding the positions of Vehicular Alert and Notification System (VANS) Drivers and Helicopter Pilots, which have not yet been staffed.
Exclusive of these positions, forty-two companies supply ORO personnel.
It can be seen from the figures presented above that employees of I
~1-
l New Hampshire ~ Yankee (NHY) constitute only a small fraction of the NHY Offsite Response Organization.
NHY is not unionized.
III. EXTENT OF UNIONIZATION As of January 26, 1989, 211 ORO volunteers belonged to unions, representing 11 percent of the entire ORO.
This 11 percent consists of members of 12 unions at three companies:
Massachusetts Electric Company (MECO), Public Service Company of New Hampshire (PSNH), and United Engineers and i
Constructors (UE&C).
Contracted vehicle drivers, who j
constitute almost half of the ORO, are not unionized.
These 211 volunteers partially staff 17 ORO positions:
Traffic Guides, Route Guides, Dosimetry Recordkeepers, Reception Center Staff, Reception Center Monitoring / Decontamination Personnel, Staging Area Administrative Staff, Staging Area Security, Transfer Point Dispatchers, Bus Yard Dispatchers, Special Vehicles Dispatchers, Evacuation Support Dispatchers, Field Monitoring Team Personnel, Rumor Control Assistants, Radio Operations, Special Population Liaisons, School Liaisons, and Local Emergency Operation Center (EOC) Liaisons.
Attachment A hereto shows the distribution of unionized personnel within the ORO by ORO position and company / union affiliation.
This distribution is based on comparison of union information supplied by UE&C and PSNH in October of 1988 with the 1/26/89 - _ _ _ - _ _ _ _ _ _ _ - _
i
+
roster of the ORD.
Twenty-five personnel from these two companies who may or may not be union appear on the 1/26/89 roster.
These personnel have recently joined the ORO and did
'not appear'on the lists supplied in October of 1988.
The-numbers shown for MECO in Attachment A are arrived at by a process of elimination using the numbers for the other two companies and the summary of unionization of the ORO supplied in October 1988, i.e., UE&C and PSNH numbers on the-summary were adjusted where possible after comparison with the ORO 1/26/89 roster, and MECO was assumed to supplied the balance of personnel shown on the summary.
Inspection of Attachment A hereto shows that there are a number of possible combinations of union and company which could conceivably be affected by a strike.
The worst case, all 211 employees unavailable because of strike activities, requires an improbable coincidence of circumstances:
12 unions striking three separate companies.
Therefore, this case is not analyzed.
The effects of a strike by all unions l
at any one company, by International Brotherhood of 1
Electrical Workers (IBEW) at both MECO and PSNH, and by any one union at any of the three companies are discussed below..
i
9 l
A.
Strike by All (Two) Unions at PSNH This scenario involves 39 persons distributed through 11 ORO positions.
There is no significant impact on ORO operations.
There are sufficient personnel for a full initial response.
Shift change for protracted operations is completely staffed with the exception of one security position at the ORO Staging Area.
An additional officer would be supplied, in this case, from the contract security firm.which supplies personnel for Seabrook Station.
B.
Strike by All (Three) Unions at MECO This scenario would affect 117 people in 16 ORO positions.
With staffing as shown on the 1/26/89 roster, for an initial response there would be a shortfall of about 2 Route Guides.
Post-1/26/89 status however indicates an additional 25 non-union personnel included in the total staffing for this position, which eliminates any initial response shortfall.
At shift turnover the ORO would require an additional five Transfer Point Dispatchers, five Bus Dispatchers, and four Staging Area Security personnel.
Security would be covered by the same source as discussed in I
.Section A above.
There would be sufficient ORO Transfer Point Dispatchers to deploy one to each of the six Transfer Points.
The second position at each Transfer Point could be filled by Massachusetts State Police, who could assist in the dispatch of vehicles from these locations as they would from
( - _ _ - _ - _
the Topsfield Fair Grounds Staging Area.
See Mass AG Answers to NRC Staff's Third Set of Interrogatories and Requests for Production of. Documents. 12/19/88, page 2.
Buses could be consolidated at selected locations, reducing the required number of Bus Dispatchers, or assistance could be requested from the Commonwealth to fill these positions.
C.
Strike by All (Nine) Unions at UE&C This scenario would affect 55 persons who partially staff five ORO positions.
There is no impact on initial response capabilities and all positions, with the exception of three Transfer Point Dispatchers, are covered for shift turnover..
Coverage would'be extended for this position as discussed in Section B above.
It should also be noted that although Transfer Point Dispatchers report to their assigned six locations at a SITE AREA EMERGENCY classification, their dispatch functions are completed when the evacuation of their assigned community is completed.
Therefore, initial responders will be sufficient to cover operations during a fact-breaking emergency.
In a slower paced event, ORO management would have sufficient time to consider the alternative options of releasing initial responders until evacuation is imminent, resting personnel at their locations, or requesting additional personnel from the Commonwealth.
All nine unions at UE&C work at Seabrook Station under the Nuclear Power Construction Stabilization Agreement which l
l _ - - - _ - _ _ _ - _ _ - _
- ~
O contains a "no-strike" clause.
The "no-strike" clause is also incorporated in the General Presidents' Project Maintainance Agreement which becomes effective when Seabrook Station is operational.
D.
Strike by IBEW at Both PSNH and MECO This scenario involves 95 volunteers and 15 ORO positions.
The effects are again negligible, involving only a need for three Transfer Point Dispatchers at shift turnover.
Relief for this position has already been discussed.
E.
Strike by Any One Union at Any One Company In this scenario, the maximum number of ORO positions that could be affected at one time is 12.
This would occur if IBEW struck MECO.
An IBEW strike affecting MECO only would have less impact than the scenario discussed in Section D.
A Utility Workers Union of America (UWUA) strike at MECO would result in the need for four Transfer Point Dispatchers and two staging Area Security personnel at shift turnover.
A position-by-position analysis of the worst case for any one union striking any one company, i.e., the maximum number of personnel affected in each position, yields the same result as a UWUA strike - the need for four Transfer Point Dispatchers and two Security personnel at shift turnover.
Coverage for both positions is discussed above.
t IV.
STRIKE ANALYSIS
SUMMARY
Strikes or other job actions would be directed to the companies by which ORO volunteers are employed, not to the ORO.
The number and distribution of unionized volunteers in the ORO, however, is not large enough or homogeneous enough to preclude operation of this organization in the event of a strike or other job actions.
The numbers presented in this analysis are subject to change as the actual composition of the ORO is subject to fluctuation.
However, there is no reason to assume that the union component of the ORO would undergo significant expansion in the future.
Therefore this analysis is presented as being representative of the ORO over any period of time.
V.
VOLUNTARY NATURE OF COMMITMENT The voluntary nature of an ORO commitment, as well as the fact that response may involve working inside the EPZ, is plainly discussed during recruiting interviews.
Recruiting I
posters displayed at bus companies, for example, plainly state that drivers would be involved in evacuating people near Seabrook Station.
Prospective volunteers are informed that the management of their company has already approved the recruiting of their employees and is aware of and supports the time which volunteers will devote to training and drills.
Each ORO volunteer makes an individual commitment via the ORO _ ___ _ ____-__
- i.
Recruitment Form, Attachment B hereto.
There are no negative repercussions for not volunteering.
While training is generally scheduled during the normal work day, volunteers participating in full-scale, integrated drills may exceed an eight-hour day.
Training-may also be scheduled for weekends or evenings.
ORO volunteers are compensated for training and drill time but the willingness to give up what would otherwise.be personal time _ forms a significant contribution'to the nature of their commitment.
The monetary stipend extended to volunteers is not an ORO
" salary" but rather is a gesture of thanks from New Hampshire Yankee for. volunteering for an intensive program of training l
and drills in support of an effort outside the normal extent of their day-to-day jobs. _ _ _ - - _ _ _ - -
O O
C C
O E
E C
M M
E W
U M
B 8
1 1
r e
C t
n E
i U
a P
1 r
C ne 1
ok E
r r U
I o W
1 la teM 're C
t k E
er E
e o U
hW S
1 g r n e i e C
C O
t n E
E R
ai E
E O
r m U
U e
e n h
pE 1
3 O
t n
r i
h e
t t
i n
C C
W e
p E
E r
U U
le a
n C
2 5
n A
os T
r r
C N
e E
P e
E C
C C
r H
E E
6 h
d o
U E
E E
C e
b U
U U
a 1
A z
T i
L 1
6 1
1 T
n A
o in U
na i
fo c
i C'
n r
o t
E i
c E
e U
tu l
E b
2 ir ts i
C r
E C
D e
E L
et U
E pt U
ii 5
PF 1
2 I
HO I
ED NC O
IGD GI O H
I t
R I
C SE C
PE I C N
M IED l 0 IGD D
I C I
I e0 I
I W
S C
S S
SE S
S
(
S S
E E
P PM P
P B
31
-M I
2 95 1 3 1
1 9 1 5 1
1 4 1 1 1 1 2 2
O O
0 C
O O
O O
O D
D 0
C 0
E C
C C
C C
C E
A E
E M
C 0
E E
E E
E E
E U
M M
M M
M W
6 3
6 1
2 6
5 1
3 1
1 1
re t
C s
E ts E
a U
e T
3 m
r a
r e
n a
d e
e o
e o
ef i
e t
l f
T r
t a
l s
c f
e a
e c
i rf u
d P r t
a p
r r
n r
i r a
A a G
i e
a nt n
ye
.n e
A o
e h e
. n i
t o
rh p
oS o
r e no p
y i
h eh L
gS e
C e c s
i M
t k e c O
gt t
c V c p
n l
f t i
t r ed C e ni a
i n f
e s a D
pe d
mr D
o i r u. t
.t o o l
a a
P s o
gi f
t np e t l
i o
./ i g u cpp cp i
o a m a
u a s s
c n e
s c cn d
a c a ps es
. a h
t d r
o ri u
e e i
o e e o a
t e vui pi pi c
SA T
R TD B
RC F
DR RM R
3wI
- l'
O CE M
N t
1 B
1 r
C e
L t
E n
U ia 1
P C
nr L
oe E
rk U
I r o
1 W
l a
teM re C
t k L
e r E
e o U
hW S
1 g r n e i e C
t n L
ai E
r a U
e n pE 4
O r
e t
n C
e p
E r
U a
C 7
r C
e E
r E
o U
b a
9 L
1 na i
c i
r C
t L
c E
e l
U E
2 C
r L
e E
et U
pt ii 7
PF 1
HO
)X O
NC
(
C S E W
E E
PM W.
E M
M E
B 4 1 B
I 2
1 3 6 I
f o
O C
s E
r A
M e
U b
M 5
m I
4 e
m era r
s e
n t
C a
s L
i m
E c
a U
i e
r T
3 tce le no 1
C s
1 i
n 2
E a
o U
i C
=
L l
rt C
o a
e O
m 's t
t E
u s o
o L
RA T
N 2FOI I
?'
Attachment - B (page: 1 of 2)
PLEASE SEND COMPLETED APPUCATION TO KATHLE ATION 01-14 4-New Hampshire Yankee Massachusetts Off-Site Emergency Response Organization RECRUITMENT FORM
'Please PRINT About you...
SOCIAL SECURITY NUMBER __ _
LAST NAME FIRST NAME -
HOME ADDRESS MI.
CITY -
HOME NUMBER ( _ )_
STATE ZIP CODE WORK NUMBER ( _
) _ _ _._. _ _ _
EXT.
BIRTH DATE Month / Day / Year
/_
/.
About your job...
COMPANY.
WORK ADDRESS CITY STATE SUILDING ZIP CODE
. CURRENT JOB TITLE MAIL CODE DEPARTMENT DEPT. SUPERVISOR COST CENTER / DEPT. CODE NORMAL WORKING HOURS -
PHONE L_ L ___)
EXT.
DAYTIME. REGULAR BUSINESS HOURS.
AMOUNTOFJOS TRAVEL SHIFT, ROTATING HOURS 0%
_25%
_50%
75%
100 %
About your education...
PLEASE CHECK THE HIGHEST LEVEL OF EDUCATION COMPLETED:
SOME HIGH SCHOOL HIGH SCHOOL SOME COLLEGE
_ TWO YEAR DEGREE FOUR YEAR COLLEGE
_ MASTER'S DEGREE OTHER-About your experience...
PLEASE CHECK WHERE YOU HAVE RELATED EXPERIENCE:
EXECUTIVE MGMT PUSUC SPEAKING CLERICAL MGMT/ SUPERVISION MASS CARE PUBLIC INFORMATION TEACHING -
ADMINISTRATE SUPPORT SECURITY TRUCK DRMNG RADIO COMMUNICATIONS FIRST A10 CERTIFICATION NUCLEAR: NAW.
POWER PLANT VEHICLE DISPATCH:
HUMAN SERVICES /
RADIAT10N' MONITORING.
CAB. BUS. ETC.
COUNSELING 00SE ASSESSMENT OTHER APPUCABLE EXPERIENCE; DECONTAMINATION m.--
I
n A
-Attachment'B:(page 2 of 2).
Srm3 additisnelinf rm:ti:n...
PLEASE CHECK THE APPROPRIATE RESPONSE FOR EACH OF T TRAVEL TIME TO...
NEWINGTON, NH HAVERHILL MA (next to Portsmouth)
(northeast of Lawrence)
SALEM, NH FROM HOME FROM WORK FROM HOME'. FROM WORKL FROM HOME FROM WORK "
{
LESS THAN 30 MINUTES l
30 MINUTES TO t HOUR 1 TO 2 HOURS
' MORE THAN 2 HOURS l
I HAVE A VALID DRIVER'S LICENSE.
YES NO I AM ALREADY A MEMBER OF SEABROOK'S EMERGENCY RESPONSE TEAM.
L YES NO IF YES,IN WHAT CAPACITY 7.
l HAVE A VACATION SCHEDULED BETWEEN NOW AND DECEMBER o
YES NO IF YES, WHEN7 HOME TELEPHONE INFORMATION a
- TYPE OF TELEPHONE SERVICE ROTARY O TOUCH TONE O TYPE OF TELEPHONE ROTARYDIAL O PUSH BUTTON O PUSH BUTTON WITH
' OTHER: COMMENTS, SUGGESTIONS 7 1 volunteer to support New Hampshire Yankee's Massachusetts Off Site Respons of Seabrook Station. I am aware of the potential for fede actual response and that my exposure will be monitored by personal dosimetry. I und commitment to participate in training and dellis as well as to respond in the unlikely eve
'amergency at Seabrook Station.
SIGNATURE DATE FOR NEW HAMPSHIRE YANKEE USE ONLY..,
GROUP DESIGNATION:
POSITION ASSIGNED:
SPECIAL NEEDS:
PAGER NO:
POSITION CLASSIFICATION:
PRIMARY SECONDARY ALTERNATE REVIEWED BY:
DATE:
APPROVED BY:
DATE:
INFORMATION ENTERED BY-
'@aSiR:E-
_