ML20238F265
| ML20238F265 | |
| 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 8709160049 | |
| Download: ML20238F265 (10) | |
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4 ATOMIC SAFETY AND LICENSING BOARD 1
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. In, the', Matter ' of
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September 11, 1987
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.PUBLIC' SERVICE COMPANY OF
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Docket Nos. 50-443-OL NEW HAMPSHIRE,'et al.
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50-444-OL
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Off-site Emergency (Seabrook~ Station, Units 1 and.2)
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' Planning Issues n
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PREFILED TESTIMONY OF ANN HUTCHINSON REGARDING-K TOH-REVISED CONTENTIONS III, IV AND VI
- hND SAPL CONTENTIONS 8, 8A, 15, 31, AND 37 t
1 Q:
Pl' ease state your name and occupation.
f' A:'
My name is Ann Hutchinson.
I am Division Manager of Berry
. Transportation Company, North.Hampton, New Hampshire.
I have been em-
-ployed by. Berry Transportation for 24 years, and the last 9 years in a supervisory capacity.
Presently, I am responsible for overseeing l
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operations for the company, including instruction and training of bus drivers.
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i Q:.
What is the purpose of your testimony?
A This testimony addresses Town of Hampton Revised Contentions III, IV and VI and Seacoast Anti-Pollution League Contentions 8, BA, l
l 15, 31'and 37, and specifically concerns certain deficiencies in the New-Hampshire. Radiological Emergency Response Plan (NHRERP) apparent from.the emergency exercise conducted in February 1986.
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f' Q:
'WhatLrole does the Berry Transportation Company have with
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respect to,the NHRERP in the event'of a radiological emergency at c-C' Seabrook-Station?
d, As-
'The Berry Transportation Company has r,igned a Letter of s
Agreement.with the New Hampshire Civil Defenr,e Agency, which in relevant v
b, part provides:-
The number of buses avai'.able for transportation purposes during an emergency is approximately 62 1
The-number of drivers available for buses and vans dur$ng an emergency response is 9 In the event of an emergency and in coordination with the State, and subject
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to driver. availability, Berry Transportation f
Company, Inc. will make all efforts to deploy its ve'aicles to those local B
. emergency op6 ration centers as requested i"
by-New.Hamprhire Civil Defense Agency.
Q:
In the event of an actual emergency at Jeabrook, do you I
believe that Berry Transportation Company will in fact-be able to
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provide'the nine drivers-specified'in.the letter agreement?
A:
.No.
As the agreement states, whether the company is able to provide th'e nine drivers is " subject to driver availability."
In my I
opinion, therefore, no driver is obligated or required to drive in i
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the-event of an emergency at Seabrook.
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-Based upon my experience supervising the buses and drivers p
for Berry Transportation Company during the February 1986 emergency 1
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l exercise, and upon my discussions with the company drivers, I would estimate that the maximum number of drivers that Berry Transportation Company would have available to respond to an actual emergency at Seab' rook would be approximately six, or only 67% of those specified in-the Letter.of Agreement.
These six drivers represent approximately 10% of the total of 57 drivers employed by.the company.
In my opinion, during an actual emergency, therefore, approximately 90% of the company's drivers would refuse, or otherwise be unavailable, to drive.
I 0:
Please explain your involvement with the February 1986 emergency exercise, and how you formed the opinion that only six drivers would make themselves available to drive in the event of an I
actual emergency at Seabrook.
A:
On February 26, 1986, at approximately 8:30 a.m.,
I received a call from the New Hampshire Civil Defense Agency and was advised that there was an alert / drill in progress for Seabrook Station.
Pursuant to the company's letter agreement, I was requested to contact, and make available, as many of the company's 57 drivers as possible, and to notify the State as soon as the number of available drivers had been determined.
In response to the State's request, I attempted to contact the 57 drivers of the Berry Transportation company with the following results:
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- Unable to contact 15 drivers
- Refused'to participate 16 L
- Agreed to drive only to Brentwood, but no I
further into EPZ 3
- Agreed to drive into Epping only, but not into EPZ 3
- Refused due to illness 3
- Refused due to vacation 3
- Not available due to time / scheduling conflicts 4
- Agreed to drive for purposes of exercise, but not in actual emergency 4
- Agreed unconditionally to drive buses both for exercise and actual emergency 5
- Agreed to drive van 1
Total Drivers 57 Total Available 6
Based upon my experience supervising the emergency response, and my discussions with the company's drivers, I therefore believe that the nine drivers specified in the Letter of Agreement between the company.and the State of New Hampshire represents a theoretical maximum.
During an actual emergency, the number of drivers who would in fact make themselves available to drive would be substantially fewer than agreed.
Q:
How many drivers actually participated in the drill for Berry Transportation Company and what problems, if any, did these drivers have in carrying out their assignments?
A:
Although the State requested that more drivers be made available, the State only requested that three drivers for the Berry i
Transportation Company actually drive a bus for the February 1986 l
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exercise.
Two of these three drivers experienced mechanical problems or delays, or received inadequate or incomplete information from the State Civil Defense-Agency.
As a result of these problems, the exercise was not properly completed.
1 In addition, during the emergency exercise, the New Hampshire Civil Defense Agency stated that a general emergency had been declared and informed me there would be a simulated evacuation of the schools in Seabrock, Hampton and Hampton Falls.
To evacuate these schools would have required that each of the six available drivers of thefBerry Transportation Company to complete at least nine round trips between the schools and the reception center in Dover, or a total of at least 54 round trips.
Under normal conditions, each round trip takes approxi-i mately 1-1/2 hours.
For the exercise, each bus would have needed at s least 13-1/2 hours to complete its runs.
Under actual emergency
,nditions, with increased traffic congestion, this estimate would be likely to increase.
There were not enough drivers available, nor would there be 1
i during an actual emergency.
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i In spite of the lack of available drivers, the State of New
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Hampshire announced that the evacuation of the Seabrook, Hampton and j
l Hampton Falls schools, for purposes of the exercise, had been completed in two hours.
I also was consistently unable to contact New Hampshire Civil Defense concerning the lack of available drivers, since that agency's phone lines were continually busy.
I had to wait for a call in from the State.
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SHAINES & McEACHERN PROFESSIONAL ASSOCIATION F5 MAPLFWOOD AVENUE - P O EBOM 360 - PORTSMOUTH. N.H 0380t l
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9 1-Q:
Based upon your observations and participation in the emergency exercise of February 1986, what is your opinion concerning l
that exercise and the State's emergency preparedness to implement the NHRERP in the event of an actual emergency?
A:
The exercise was only a paper evacuation.
The State re-l quested that drivers be provided, but there were not sufficient drivers available.
The State, however, still claimed that the evacuation of the schools had been completed.
From the exercise, I do not have any i
reasonable confidence that the NHRERP could be implemented in an actual emergency at Seabrook.
Since 90% of my drivers refused or were unavailable to participate in an emergency drill, I would expect that at least as many drivers would be unavailable to drive in the event of an actual emergency.
In addition, in my opinion, the State significantly under-estimated the time required under actual conditions to complete an evacuation of the EPZ schools.
l I believe that the problems to which I have testified regarding the lack of adequate drivers to implement the NHRERP would j
be typical of all bus companies attempting to locate and mobilize drivers to respond to an actual emergency at Seabrook.
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6 SHAlNES is McEACHERN PROFESSIONAL ASSOCATION 25 MAPLEWOOD AVENUE P O DOM 360. PORTSMOUTH. N M 03001 l
k Q:
Does this conclude your testimony?
A:
Yes.
Respectfully submitted, TOWN OF HAMPTON By Its Attorneys SHAINES & McEACHERN Professional ssociation i
By Paul McEachern
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x Dated:
September ll, 1987 By
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Matthew T.
Brock N
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SHAINES (k Mr.EACHERN PRO 1tS$ TONAL ASSOCIATION 25 MAPLFWC.O AVENUE - P O HOM 360 PORTSMOUTH. N M 034D1
CERTIFICATE OF SERVICE I,
Matthew T.
Brock, one of 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 ANN HUTCHINSON REGARDING TOH-REVISED CONTENTIONS III, IV AND VI AND SAPL CONTENTIONS 8, 8A, 15, 31 AND 37 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 r.
Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclen Regulatory Commission Board Panel East West Towers Building U.S.
Nuclear Reqrvlatory Comm.
4350 East West Highway East West Towere 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 l
Board of Selectmen Town Hall 13-15 Newmarket Road Friend Street Durham, NH 03842 Amesbury, MA 01913 J
Jane Doughty Rep. Roberta C.
Pevear Seacoast Anti-Pollution League Drinkwater Road 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.
Backus, Meyer 5 Solomon Office of the Exec. Legal Dir.
111 Lowell Street U.S.
Nuclear Regulatory Comm.
Manchester, NH 03105 Tenth Floor l:
7735 Old Georgetown Road i
Bethesda, MD 20814 5HAINES 6h McEACHERN. PvtOPESSIONAL ASSOCIATION ES MAPLEWOOD AVENUE R O BOK 360 PONTSMOUTH. NH 0380i
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Mr. Angie Machiros, Chairman H. Joseph Flynn, Esq.
' Board of Selectmen Office'of' General Counsel
-Newbury, MA- 01950 Federal Emergency Mgmt. Agency 500 C Street,.S.W.
- George Dana Bisbee, Esq.
Washington, DC 20472 Stephen E.'Merrill, Esq.
q.
Office of the Attorney General
- Carol S. Sneider, Esq.
State House Annex Donald S. Bronstein, Esq.
L Concord, NH 03301 Allan R.
Fierce, Esq.
Dept. of the Attorney General One Ashburton Place Stanley W..Knowles 19th Floor Board of Selectmen Boston, MA 02108 l
P.O. Box 710 North Hampton, NH
.03862
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P. Nadeau, Selectman Richard E.
Sullivan Selectmen's Office Mayor 10 Central Road City Hall 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, NH 03301 Hampton, NH 03842 William Armstrong Calvin A. Canney, City Manager Civil Defense Director City Hall 10 Front Street 126 Daniel Street Exeter, NH 03833 Portsmouth, NH 03801
- Cdward A. Thomas Sandra Gavutis Federal Emergency Mgmt. Agency Town of Kensington 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
$HAINES & McEACHERN. PROFES$iONed. ASSOCIATION 25 MAPLEWOOD AVENUE P O BOX 360 PortTEMOUTH. N M Q3801
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..o Robert Carrigg, Chairman Senator Gordon J.
Humphrey Board of Selectmen One Eagle Square, Suite 507
' Town Office Concord, NH 03301 1
Atlantic Avenue (Attn:
Herb Boynton) j 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
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Brock
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