ML20238F242
| ML20238F242 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/11/1987 |
| From: | Brock M, Mceachern P HAMPTON, NH, SHAINES & MCEACHERN |
| To: | |
| Shared Package | |
| ML20238F189 | List: |
| References | |
| OL, NUDOCS 8709160041 | |
| Download: ML20238F242 (15) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD t
)
In the Matter of
)
September 11, 1987
)
PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
)
50-444-OL
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Off-site Emergency (Seabrook Station, Units 1 and 2)
)
Planning Issues
)
)
PREFILED TESTIMONY OF DANIEL TRAHAN ON BEHALF OF THE TOWN OF HAMPTON AND SEACOAST ANTI-POLLUTION LEAGUE REGARDING TOH REVISED CONTENTIONS III, IV, AND VI A_ND SAPL CONTENTIONS 16 AND 25 Q:
Please state your name and occupation.
A:
My name is Daniel Trahan.
I am Director of the Seacoast Health Center located in Hampton, New Hampshire.
Q:
Please summarize briefly your professional background.
A:
A statement of my professional background is attached.
Q:
What is the purpose of your testimony?
A:
The purpose of my testimony is to address Town of Hampton Revised Contentions III, IV and VI, and Seaco.ast Anti-Pollution League Contentions 16 and 25, and specifically whether sheltering or evacuation 8709160041 B70911 PDR ADOCK 0500 3
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j of those people with special needs, including residente of the Seacoast L
' Health Center, could be implemented adequately in the. event of a l
radiological emergency at Seabrook Station.
Q:
Briefly describe the Seacoast Health Center, its residents and. staff.
A:
The Seacoast Health Center is an intermediate. care facility located in Hampton, New Hampshire.
The facility services approximately 107 elderly and special needs residents.
Virtually all of these patients have been referred by their physicians to the Health Center for treatment of medical problems.
The patients require varying degrees.of medical treatment and supervision, although all require medication on a daily basis.
While a particular patient's health may vary day to day, typically a number of the patients are forgetful or may become disoriented.
Approximately 10% of the patients at the Health Center are " bedfast patients." This means that these patients require constant attention and assistance from the Health Center's I
trained medical staff.
While on a good day a particular bedfast i
patient may be able to recognize those around him, or even converse, typically all basic needs of these patients, including feeding, washing, changing, medicating and monitoring, must be performed by medically trained Health Center staff.
l The Seacoast Health Center provides 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> nurs.tng service to its patients.
No doctors, however, are employed by the Health y
J Center, and no physicians reside on the premises.
The oreduty staffing I
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at.the Health Center may be summarized as follows:
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MONDAY THROUGH FRIDAY i
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.7:00 a.m. - 3:00 p.m.
3:00 p.m. - 11:00 p.m.
11:00 p.m. - 7:00 a.m.
4 nurses 4 nurses 3 nurses' 11 aides 10 aides 4 aides 4 housekeepers 6 dietary staff (until 6 dietary staff 9:00 p.m.)
l 2 maintenance workers l
10 administration i
WEEKENDS 7:00 a.m. - 3:00 p.m.
3:00 p.m. - 11:00 p.m.
11:00 p.m. - 7:00 a.m.
4 nurses 4 nurses 3 nurses 8 aides 7 aides 4 aides 6 dietary staff 6 dietary staff (until
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9:00 p.m.)
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t Accordingly, the number of trained medical staff at the facility, depending upon shift, varies between 12 and 16 nurses, for the approximately 107 patients of the Seacoast Health Center.
l Q:
Under the New Hampshire Emergency Response Plan (NHRERP), in the event of a radiological emergency the Seacoast Health Center may be advised to shelter or to evacuate.
Do ycu believe that either of these protective responses could be implemented in a safe and adeguate manner in the event of an accident at the Seabrook Plant?
A:
No.
Q:
Why do you believe that sheltering could not be adequately implemented?
A:
First, the NHRERP places almost exclusive reliance upon the staff of the Seacoast Health Center to secure, protect, monitor, and maintain the patients at the facility during the entire time that 3
$HAINES 6 McEACHERN a PROFESS:ONAL ASSOCATION 25 MAPLEWOOD AVENUE R O BOX 300 - PolitT5 MOUTH, N H. OMIO1
sheltering may be ordered.
(' See, e. g., Volume 18A, Seacoast Health Center pages 6-8.)
In my opinion, however, upon notification of an emergency most of the staff would leave the facility in order to care for their own children, elderly relations, or other dependents or members of their families.
I base this opinion upon the fact that, as I understandlit, none of the staff are required by law to carry out their duties as assigned under the NHRERP.
Second, I base my opinion on informal discussions with my staff where we candidly discussed whether or not the staff would remain ~with the patients following notice of an emergency at Seabrook.
Third, even assuming'some' Health Center staff might other-wise remain with their patients during an emergency, a conclusion refuted by the staff's own statements to me, to my knowledge there is no provision in the NHRERP to provide protection to the families of Health Center personnel.
It is therefore both reasonable and under-l standable that the staff would feel compelled to firct look to the security of their own families, who may otherwise be left without protection, if an emergency is declared.
I Fourth, in the event sheltering is ordered, I seriously doubt that adequate food, medical supplies, or physicians can be 1
J promptly transported into the emergency zone to maintain my special
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1 needs patients.
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Fifth, if, for example, the order to shelter, rather than evacuate, is given for the bedfast patients at the facility, a substan-tial portion, if not all, of the full-time contingent of medically
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trained personnel will be required to remain with these relatively few l
patients to ensure appropriate monitoring and adequate medical treat-ment.
Even assuming all on-duty staff were available and willing to remain behind in-the EPZ to care for patients being sheltered, those individuals of course could not also be reliea upon to accompany and care for the evacuating patients.
Alternatively, if all oatients are ordered to shelter, a substantial number of additional medically trained personnel would be required to care for the 107 patients at the Health Center who likely will be subject to increased stress and medical complications under emergency conditions.
There is no provision in the NHRERP which reasonably assures the Health Center will promptly receive this additional trained staffing.
Q:
Do you believe that the plan for evacuation of the Seacoast Health Center under the NHRERP can be adequately and safely imple-mented?
A:
No.
As I have previously testified, most, if not all, of i
the on-duty staff would not remain with the patients if an emergency is declared.
Even assuming that all on-duty staff would remain, however, I still do not believe that an evacuation could be reasonably l
or effectively carried out.
The proposed evacuation of ill, disabled and handicapped individuals represents a massive undertaking, one that i
is far more involved than simply moving wheelchairs or mattresses from i
one location to another.
Patients must be removed from environments designed and equipped to provide care for the ill or disabled, and moved to hallways., buses, vans, and ambulances that are not so equipped 1
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or designed.
Patients must be prepared'for travel, necessary equipment
- and supplies obtained, and many would have to be constantly monitored-
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and' cared'for.
A bedfast patient may need monitoring equipment, intravenous equipment, or various traction or immobilizing arrange-ments.
Even non-critical, wheclchair, or ambulatory patients would
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need assistance during an evacuation,'since pcsition changes, admini-stering medication, and other types of attention would likely be required.
Moreover, in many cases the trauma involved in moving patients would result in their requiring even more attention than they would in their Seacoast Health Center rooms.
It is clear, therefore, that knowledgeable and trained medical, paramedical, and other specially trained personnel would have to be involved in the pre-evacuation as well as the actual evacuation process.
Even assuming the 4 nurses and 11 aides, which represent the maximum of trained medical personnel per shift at the facility, would remain with the patients, in my opinion a substantial number of additional medically and specially trained staff would be required to collect, care for, monitor, transport, and evacuate the 107 patients of the Seacoast Health Center.
The NHRERP makes no provision for such additional personnel, f
and relies almost exclusively on the assumption that staff of the l
Seacoast Health Center will be available, and is adequate, to carry out these emergency functions.
Even assuming, unrealistically, that all of these medically trained personnel were immediately available to assist an evacuation, i
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the: trauma, medical complications, and associated patient problems to be anticipated in an emergency would likely serious.ly and,significantly compromise the health and safety of my patients.
L Q:
In your opinion will the medical staff of the Seacoast Health 1
l; Center be likely to experience a role conflict between their loyalty to their pat'. ants and their duty to their families in the event an evacuation is ordered?
l A:
Yes.
As I previously testified, I believe that most, if not all, of the staff would resolve the conflict by leaving to attend to their family responsibilities.
Q:
In your opinion, in the event the Seacoast Health Center is l
ordered to evacuate, will the medical personnel, support staff and resources be adequate to reasonably and promptly carry out this procedure?
l A:
No.
I base this opinion on several grounds.
First, of the 80 staff employed by the Health Center, approximately 48 live outside-the Town of Hampton.
Even assuming that off-duty personnel agreed or desired to return to the Health Center to assist in evacuation, an unrealistic assumption, I do not believe it is likely that these in-dividuals can make their way through outgoing evacuation traffic in time to' arrive at the facility or participate meaningfully in an evacuation.
Second, I understand that the Teamsters' Union has agreed to i
drive evacuation buses in the event of an emergency at Seabrook.
lIamconcerned, however, that these individuals will lack the training
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'l and skill necessary to attend, monitor, board and evacuate special 1
needs patients from the Health' Center.
Certain of these patients have acute medical problems, the on-duty medical staff, even if all remain on site, cannot perfor_a all of these duties, and necessarily bus
~ drivers would be required to assist in this procedure.
As I have testified, however, I have serious reservations that these individuals are qualified to perform these procedures on special needs patients.
Third, even assuming an adequate number of trained staff, I am seriously concerned that the time estimated by New Hampshire Civil Defense to effectuate an evacuation of the Health Center is grossly understated.
As I understand it, New Hampshire Civil Defense estimates that 40 special needs patients can be aseambled at a bus and fully loaded for departure in 10 minutes, or approximately 15 seconds per special needs patient (NHRERP Volume 6, p. 11-21).
In my experience, even our physically and mentally most capable patients would take a minimum of 1 minute each merely to be boarded on a bus.
Substantial additional time would be required to locate, organize and assemble these patients at the buses.
Those patients in wheelchairs, those who are bedridden, or those who have other more severe physical and mental difficulties, would necessarily take more time to perform these pro-cedures, even assuming there was available a full complement of medically trained personnel to provide assistance.
Fourth, Seacoast Health Center has been allocated four buses to complete an evacuation of the facility, including school buses with conversfou beds and reclining seats.
To my inowledge, these buses are not equipped with lifts or other means to promptly and safely board 8
WiAINES (, McEACHERN. PROFES$10NAL ASSOCIATION 25 MAPLF WOOD AVENUE - P O. BOX PlO - PORTSMOUTH. N H 0300l
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g handicapped or disabled patients.
If this is the case, many personnel
.would be requireo, through substantial time and effort, to raise and
' board even a' single wheelchair bound patient.
Additionally, even assuming lifts or other technical means for boarding patients are provided, typically buses constructed specifically for handicapped patients have extra wide aisles, seating, and other necessary accommo-dations for wheelchair bound and handicapped patients.
To my knowledge, none of the converted buses will be so equipped.
The result of these deficiencies will likely result in a disorganized, inadequate, lengthy and ultimately unsafe attempt at evacuation of those medically most at risk.
Fifth, the Seacoast Health Center has no buses, either J
modified for handicapped or otherwise, or other emergency vehicles to conduct an evacuation.
We would the fore be required to rely, for evacuation, on the inadequate transportation I have described.
Sixth, even assuming the buses allocated under the NHRERP for the Seacoast Health Center are fully equipped for those with l
special needs, and fully staffed with medically trained personnel, I am seriously concerned whether the drivers of these vehicles will actually agree to drive into the emergency planning zone during an l emergency.
Additionally, even if the drivers are so inclined, I have grave doubts that these specially equipped vehicles can maneuver through outgoing evacuation traffic and reach the Health Center in I
reasonably prompt time to effectuate an evacuation.
Seventh, evacuation of those with special needs from the i
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SHAINES Cm McEACHERN PROFE55 TONAL A5500ATC 25 MAPLEWOOD AVENUE. P Q. BOX 360 PORTSMOUTM N H. 03801
Health Center.under emergency conditions will necessarily result in extreme stress to a number of the patients.
I would anticipate a 1
great increase in the need for medical attention and care for these i
i patients than typically experienced at the Health Center.
This in-creased need 'for medical attention will occur precisely at the time I
when there is likely to be the least amount of trained medical per-sonnel available.
The evacuation, as proposed, will necessarily place
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many, if not most, of the Health Center patients at substantial medical risk.
.Q:
Based upon the concerns that you have just described re-garding the NHRERP involving the Seacoast Health Center, do you have an opinion whether that plan will reasonably and adequately protect l
special needs patients, including those at your facility?
A:
My opinion is that the NHRERP will not provide. adequate, j
prompt, or reasonably safe protection for these patientss In an l
actual emergency, and given the logistical and medical problems associated with an evacuation of the Health Center, I would anticipate j
the State of New Hampshire merely ordering the facility to " shelter."
In fact this sheltering would simply leave my patients to fend for themselves, with what limited staff and supplies may be available to them.
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Does this conclude your testimony?
t i
A:
Yes.
Respectfully submitted, TOWN OF HAMPTON By Its Attorneys SHAINES & McEACHERN Professional Association BY Paul McEachern
~m ~,
Dated: September 1987 By
)
Matthew T.
Brock '
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SHAINES 6e McEACHERN PROFE5fdONAL ASSOOATION 25 MAPLEWOOO AVENUE F O. EsOX 360 PO,1TSMOUTH, h M. 03aos
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Daniel P.
Trahan 779 Lefswette R o e <J Hampton, New Hampshire 03842-3601 Married, wifes name Kathleen, three children, Sarah, Hannah. Emily Employed Seacoast Health Center, Inc 22 Tuck Road HamPton, New Hampshire l
Since 1973 Positions Administrator /Vice-President l
l Positions Held Food Service Supervisor SHC Maintenance Supervisor SHC Instructor in Refrigeration and Air Condition Program at Portsmouth Voc Tech College P.i. i 1 H i n g Cnn=trortton Supervisor Convention Chasrman for the Tri-State Health Care Assoc Convention for three years Past-President of The New Hampshire Health Care Association Former Treasurer of the American College of l
Health Care Administrators l
Member of the New Hampshire Air National j
Guard since 1972 - Rank of E-6 l
Commission on the Board of Examiners for Nuestng Home Administrators for the State of New Hampsh2re January 2, 1981 to j
January 2, 1984 l
Member of the Hampton Rotary Club Educations Central High School, Manchester, New Hampshire I
New Hampshire Vocational and Technical College, i
Manchester, New Hampshire - Mechanical Field University of New Hampshire School of Continuing Studies - Dietetic Assistent Program Social Worker Designee - Dartmouth-Mar 9 H1tChCOck Memorial HosPitel Program I heve been involved in the nursing home field since childhood, as my maternal grandparents were pioneers of this great industry.
l When new grand parents retired in 1961, my parents assume the business in Manchester and which later to Hamptnn arpm.
CERTIFICATE OF SERVICE I, Matthew T.
Brock, one bf the attorneys for the Town of Hampton herein, hereby certify that on September 11,~1987, I made service of the following document PREFILED TESTIMONY OF DANIEL TRAHAN ON BEHALF OF THE TOWN OF HAMPTON AND SEACOAST ANTI-POLLUTION LEAGUE REGARDING TOH REVISED CONTENTIONS III, IV AND VI AND SAPL CONTENTIONS 16 AND 25 l
by depositing copies thereof in the United States Mail first class postage prepaid for delivery (or, where indicated, by Express Mail, prepaid) addressed to:
- Helen Hoyt, Esq., Chairman
- Judge.Gustave A.
Linenberger, J c.
Atomic Safety and Licensing Board Atomic Safety and Licensing U.S.
Nuclear Regulatory Commission Board Panel East West Towers Building U.S. Nuclear Regulatory Comm.
4350 East West Highway East West Towers Building Bethesda, MD 20814 4350 East West Highway Bethesda, MD 20814
- Dr.
Jerry Harbour Atomic Safety and Licensing Board
- Atomic Safety and Licensing Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.
]
East West Towers Building Washington, DC 20555 4350 East West Highway Bethesda, MD 20814
- Atomic Safety and Licensing Appeal Board Panel
- Docketing and Service U.S. Nuclear Regulatory Comm.
.U.S.
Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555-Mrs. Anne E.
Goodman William S.
Lord, Selectman i
I Board of Selectmen Town Hall 13-15 Newmarket Road Friend Street Durham, NH 03842 Amesbury, MA 01913 Jane Doughty Rep. Roberta C.
Pevear Seacoast Anti-Pollution League Drinkwater Road i
5 Market Street Hampton Falls, NH 03844 Portsmouth, NH 03801
- Philip Ahrens, Esq.
- Thomas G.
Dignan, Esq.
Assistant Attorney General George H. Lewald, Esq.
Office of the Attorney General Kathryn A.
Selleck, Esq.
State House Ropes & Gray Station 6 225 Franklin Street Augusta, ME 04333 Boston, MA 02110 Robert A.
Backus, Esq.
- Sherwin E. Turk, Esq.
l Backus, Meyer & Solomon Office of the Exec. Legal Dir.
111 Lowell Street U.S.
Nuclear Regulatory Comm.
Manchester, NH 03105 Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814
$HAINES Es McEAChERN - PROFESSIONAL ASSOCIATION 26 MAPLEWOOD AVENUE - P O. BCE 360 PORTSMOUTH. N H. 03801
3 p
hi3 Mr'iAngieJMachiros, Chairman'
'H.
Joseph Flynn, Esq.
p L
. Board of Selectmen Office'of General Counsel LNewbury,.MAi.01950-Federal Emergency Mgmt.. Agency
'500'C. Street, S '. W.
- GeorgeiDana!Bisbee,.Esq.:
Washington, DCL :20472 P
StepheniEe Merrill, Esq.
h
- Office of the Attorney General
-* Carol S. Sneider, Esq.
' State House Annex
. Donald?S. Bronstein, Esq.
ConcordANH-033011 Allan R.. Fierce,'Esq.=
Dept. of the Attorney General l
One Ashburton Place Stanley W.~Knowles-19th' Floor:
JBoard of Selectmen Boston, MA 02108 P.O. Box 710 North Hampton, NH-03862 p
J.
P.
Nadeau, Selectman Richard E. Sullivan Selectmen's' Office' Mayor
'10 Central' Road
' City Hall-1 Rye, NH; 03870.
Newburyport, MA 01950 Alfred V.-Sargent, Chairman Senator-Gordon J.
Humphrey Board'of Selectmen U.S. Senate Town of Salisbury-Washington, DC.
20510; Salisbury,. MA'.
01950 (Attn:
Tom'Burack)
" Michael'Santosuosso,-Chairman Allen Lampert Board of Selectmen Civil Defense Director Jewell St.,-RFD 2
' Town of Brentwood So.; Hampton,'NH-03827 Exeter, NH 03833
' Richard A.
Hampe, Esq.
Gary.W. Holmes, Esq.
Hampe and McNicholas Holmes and Ellis-
~35 Pleasant Street 47 Winnacunnet' Road Concord,aNH 03301 Hampton, NH 03842 Calvin A. Canney, City Manager
' William Armstrong
. City. Ball Civil Defense Director 10 Front Street-126 Daniel Street.
Exeter,-NH 03833 Portsmouth,'NH 03801
.
- Edward A.'
Thomas Sandra'Gavutis Federal Emergency Mgmt. Agency Town of Kensington j
442 J.W. McCormack (POCH)
RFD 1, Box 1154 Boston, MA 02109 East Kensington, NH 03827 Charles'P. Graham, Esq.
- Diane Curran, Esq.
McKay, Murphy &' Graham Andrea C. Ferster, Esq.
100 Main Street Harmon & Weiss Amesbury, MA
-01913 Suite 430 2001 S Street, N.W.
Washington, DC 20009-1125 2
5HAINES & McEACHERN, pnOFE55 TONAL A1500ATON 25 Mapt.CwoOD AVENUE P O-BOX SfnD. PORTSMO',JTH. N.H 038U1
k.
Robert Carrigg, Chairman Senator Gordon-J. Humphrey Board of Selectmen One Eagle Square, Suite 507 l
' Town Office' Concord, NH 03301 l-Atlantic Avenue (Attn:
Herb Boynton)
North Hampton, NH
.03862 Mr. Thomas H. Powers, III' Mr. Peter Matthews Town Manager Mayor
. Town of Exeter City Hall
.10 Front Street Newburyport, MA 01950 Exeter, NH 03833 Brentwood' Board of Selectmen Judith H. Mizner, Esq.
RFD Dalton Road Silvergate, Gertner, Baker, Brentwood, NH 03833 Fine, Good & Mizner 88 Broad Street Boston, MA 02110
\\u v.
MN1N f
Matthew T.
Brock
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