ML20236C088
| ML20236C088 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/16/1987 |
| From: | Machiros A NEWBURY, MA |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20236C087 | List: |
| References | |
| CLI-87-03, CLI-87-3, OL-1, NUDOCS 8710270009 | |
| Download: ML20236C088 (6) | |
Text
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BEFDRE THE UNITED STATES NUCLEAR REGULNIDRY COMMISSION In the antter of
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Docket Nos. 50-443-OL 50-444-OL PUBLIC SERVICE COMPANY OF NEW HAMPS!! IRE,g al.
Onsite Energency Planning
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and
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OHsh hgency Mannhg Seabrook Station, Units 162
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October 16, 1987
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TOWN OF NEWBURY'S ANSWER IN OPPOSTION TO APPLICANTS' MOTION FDR VACATION OF STAY In CLI-87-02, the Commission stated that it " required submittal of a plan in circumstances where "some of the nnterials that normally are essential to support a full power license under our regulations mre missing". ' As further stated in MEMORANDUM AND ORDER CLI-87-03, "It cannot be supposed that the Conmission contemplated that it was requiring anything less than muld be required of any submittal of materials supporting a license application under the regulations." The Town of Newbury will show, in this ANSWER, that the "Seabrook Plan for Massachusetts Cmmunities", which was submitted by the utility as a " bona fide utility plan" is not a bona fide utility plan, as defined by the Conmission, in that it does not adequately " compensate for the lack of governmental participation"(P. 7, CLI-87-03). The Town of Newbury will also I
show that the Seabrook Plan (utility plan) does not show that adequate energency planning is "in the realm of the possible" 0710270009 871016 PDR ADOCK 05000443 0
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You will note upon reviewing the following that a number of that facts that the '10N uses to prove that the utility plan as filed is not a' bona fide utility plan can also be used to prove that emergency planning for Seabrook Station is not "in the realm of the possible".
It would only be repetitious to repeat those facts in both areas of this ANSWFR, so we trust the Cmunission will utilize the facts in both area where applicable.
1 The utility plan is not a bona fide utility.
It does not adequately compensate for the lack of governmental participation in, anong others, the following ways.
All provisions for "special facilities", that is, school plans, hospital plans, etc., are stated to just as they were in the 1985-1986 Massachusetts' state-I developed plans, and to just need " updating, revision and finalization" In actual fact, many of those'special facilities have made it clear, orally and by
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written statement, that they will not participate in any plan involvs3 the Seabrook Station. For example, in late September 1987, Hale Hospital in llaverhill, MA.,-Board of Trustees voted to take themselves out of the plan; Merrimack College wrote long ago to take itself out of the plan; Pingree School was to supply dorm space to evacuating Governor DumTer Academy (Newbury, MA) students, until it was learned by Covernor Dumter that Pingree has, and has never had, n o dormitories. Since this plan was submitted, the city of Newburyport has removed all but two of its warning sirens. Although the utility plan in its cover letter mentions that this may occur, and pranises to compensate, no compensation method is given. Maps to direct evacuees to reception centers and congregate care are not included, but are promised "to cane later"; one specific letter of agreement from the Department of the Interior is also pranised "later"; all the letters of agreenent have been didacted; how can the TON be assured of, or assess the plans fully when such vital information is withheld? According to a phone E__ _ _ _ _ _
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TED @q b-Page Three conversation held with a Seabrook Station spokesperson on Friday, October 9, 1987, the names of the companies supplying the canpensating vehicles - buses, ambulances,etc.-
are proprietary information and would not, in all probability, be released at any tine in the future. Also, wherein these transportation arrangements are supposed to j
" compensatory", and presumably are being provided by private companies, we question l
the degree of comnitnnnt a " letter of agreement" provides, not only for the vehicles '
themselves but for the drivers. We do know that bus drivens of at least one of-these canpanies have been offered a $250. bonus to sign up as drivers in case of an energency at Seabrook, but have told they will never have to go into a con-l taminated area..The compensating " reception center" being used for the Towns of Newbury,CityofNewburyport,andTownofSalisbury(combinedpopulationofapproximatelyj I
29,000 winter, about 70,000-100,000 on a good beach day, is a small Massachusetts Electric Company garage in downtown Beverly, Massachusetts, which, according to the plans will have two showrs (but more are promised, if necessary). The plan counts on 10% of the populace using this reception center. The 70N maintains that this facility absolutely does not compensate in size, location accessibility, or facilities for lack of participation by governmental bodies. Many of the " workers" that the utility plan states are available to canpensate for government participation are noter readers and other such workers who are employees of Massachusetts Electric Canpany. The ION does not believe that these workers, nany of whan are not residents of the area, and all of whan are being paid a $500. bonus to involve themselves in this plan, will in actual fact enter an emergency zone when they are needed, as
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RATEO W Page Four would governrrent workers. School children, in case of evacuation, go to an f
unnamed reception center. The City of flaverhill City Council voted in September, 1987, to disallow use of their downtown area as a staging area l
for buses in case of emergency atScabrook Station. (This staging area is the l
one stated in the utility plan) l l
The Town of Newbury will show that emergency planning for Seabrook Station is not in the realm of the possibic. The inadequacies of our country, two-lane roadways l
in this area make rapid, efficient travel at any time unlikely. Because of our l
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' beach area on Plum Island in the ' ION, and the intervening salt marshes, only one l
two-lane road connects the Island to the mainland. This is always a problem, but l
in sunner beach weather,, with up to 10-30,000 additional people in-the town on the i
beach, it is an insurmountable problem. One important aspect, according to your regulations on development of an emergency plan, in that of sheltering. This utility plan avoids addressing the sheltering question. The recent Stone and Webster study which has been recently served, is not technically part of the Massachusetts 3
utility plan. However, it does prove that there is not adequate shelter in the beach area. The gas station and sub shop, to name only two, listed in Newbury as adequate shelters, would provide the most mininal protect for maybe 50 people.
For these reasons, it is the opinion of the Town of Newbury that the Applicants' Motion for Vacation of Stay should be denied.
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For the Town of Newbury,
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1 NewburyDoard of Selectmen
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NEWBURY, MASS. 01950
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- u.:..,ven TED CERTIFICATE OF SERVICE i
l I, Angie Machiros, certify that the Town of Newbury's ANSWER IN OPPOSITION j
'IO APPLICANTS' M7fl0N FDR VACATION OF STAY has been served on the list.of parties attached, by nailing copies thereof, postage prepaid, first class mail, or as indicated by an asterisk, by Express Mail.
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Lando W. Zech,Chairnnn cc
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Kenneth C. Rogers Angie Machiros Thonns M. Roberts Newbury Board of Selectmen Kenneth M. Carr Prederick M. Berntial U.S. Nuclear Regulatory Conmission 1717 H. Street N.W.
Washington, DC 20555 Allan S. Rosenthal Gary J. Edles lloward A. Wilber Atanic Safety Licensing Appl Board 1717 H Street NW Samuel J. Chilk, Secretary Washington, DC 20555 U.S. Nuclear Regulatory Ccmnission 1717 H Street NW Sheldon J. Wolfe Washington, DC 20555 D.r nneth Loubke Dr. Jerry llarbour Atontic Safety Licensing Board 1717 11 Street NW Washington, DC 20555 1
Page One of Two.
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Ivin W SmithCMr
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Philip Ahrens, Esq.
Brentwood Bd. of Salsctmen n
Atomic St#2ty Lic. Board D2pt. of the Attorney General RFD Dalton Rd.
US NRC Augusta, ME 04333 Brentwood, Nil 03833 j' W dringtod, DC 20555
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'Gu2tave Linenberger Mrs. Sandra Gavutis Gary W. !!olmes, Esq.
Atomic Safety Lic. Board Board of Selectmen llolmes & Ells
.US NRC RFD 1 - Box 1154 47 Winnacunnet Rd.
i Washington,.DC 20555 Kensington, nil 03827 11ampton, Nil 0384 2 I.Dr.-Jerryliarbour Matthew Brock, Esq.
Mr. Edward Thomas Atomic Safety Lic. Board Shaines & McEachern FEMA - Region 1 US NRC P.O. Box 360 442 McCormack POCll Washington, DC 20555 Portsmouth, nil 03801 Post Office Square Boston, MA 02109 Atomic Safety & Licensing Senator Gordon llumphrey Michael Santasuosso Board Panel U.S. Senate Board of Selectmen US NRC Washington, DC 20510 So. llampton, tal 03827 Washington, DC 20555 attn: Tom Burcak Atomic Safety & Licensing Senator Gordon llumphrey Charles P. Graham, Esq.
Appeal Board 1 Eagle Sq. - Suite 507 100 Main Street US NRC Concord, Nil 03301 Amesbury, MA 01913 Washington, DC 20555 attn: lierb Boynton Docketing & Service Section II. Joseph Flynn Ms Jane Doughty Of f. of the Secretary Off. of General Counsel SAPL US NRC FEMA 5 Market St.
Washington, DC 20555 500 C St., SW Portsmouth, Nil 03801 Washington, DC 20472 Robert Carrigg Mr. J.P. Nadeau Roberta C. Pevear Board of Selectmen Selectmen's Office 27 Drinkwater Rd.
Town llall 10 Central Rd.
llampton Falls, N!! 03844 No. llampton, Nil 03862 Rye, Nil 03870 Diano Curran, Eng.
Carol S. Sneider, Esq.
Richard A. Ilampe j
liarmon & Weiss Off. of the Attorney Gen.
Hampe & McNicholas 2001 S St., NW - Suite 430 1 Ashburton Pl.- 19th Fl.
35 Pleasant St.
i Washington, DC 20009 Boston, MA 02108 Concord, NII 03301 l
George Dana Bisbee, Esq.
Calvin A. Canney Judith 11. Mizner, Esq.
j Of f. of the Attorney General City Manager Silverglate, Gertner et al l
25 Capitol St.
126 Daniel St.
88 Broad St.
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Concord, nil 03301 Portsmouth, N11 03801 Bos ton, MA 02110 I
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Shetvin E. Turk, Esq.
Mr. Angie Machiros Beverly llollingworth Off. of the Exec. Legal Dir.
Board of Selectmen 209 Winnacunnet Rd.
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.US NRC Newbury, MA 01951 llampton, N11 0384 2 Washington, DC 20555 l
Robert A. Backus, Esq.
Mayor Peter S. Matthews Thomas Dignan i
P.O. Box 516 City IIall Popes & Gray 116 Lowell St.
Newburyport, MA 01950 225 Franklin St.
.M.incher.t er, Nil 03105 Boston, MA 02110 3J