ML20238F273
| ML20238F273 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/11/1987 |
| From: | Brock M, Brock P, Mceachern P HAMPTON, NH, SHAINES & MCEACHERN |
| To: | |
| Shared Package | |
| ML20238F189 | List: |
| References | |
| OL, NUDOCS 8709160052 | |
| Download: ML20238F273 (12) | |
Text
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f-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
{
before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
September 11, 1987
)
y PUBLIC SERVICE COMPANY OF
)
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) )
Planning Issues
)
)
PREFILED TESTIMONY OF DONA JANETOS ON BEHALF OF TOWN OF HAMPTON HEGbRDING IQB REVISED CONTENTIONS III, J3L,_ yl Q.
Please state your name and position with the Town of Hampton.
A.
My name is Dona Janetos.
I am Chairman of the Town of Hampton Board of Selectmen, Hampton, New Hampshire.
O.
Please summarize briefly the duties of the Board of Selectmen, and the length of time you have been a member of the Board.
The Board of Selectmen is the goverjiing body for the Town of A.
l Hampton which adopts laws and establishes policies f or the Town.
These laws and policies are enforced by the Town Manager, and other Hampton administrative officials.
Among their other responsibilities, the Selectmen are routinely required to assess the personnel needs f or each town department.
8709160052 070911 PDR ADOCK 05000443 T
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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 testinony 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 a
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,
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including Hampton Beach, can be reasonably and saf ely evacuated in the event of a radiological emergency at Seabrook Station.
O.
Briefly describe the Town of Hampton, its location and seasonal population.
A.
The Town of Hampton is located less than two miles f rom the 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 adjacent to the beach.
Located directly across Route lA f rom the beach are numerous motels, condominiums, seasonal residences, souvenir shops, eating establishments, and other small businesses.
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,y l
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E During the summer months, tens of thousands of residents, tourists,
'. transients, Lbeachgoers, and others' seeking recreation crowd into L.
1Hampton Beach.
l l-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
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nuclear plant is located.
The~ marsh essentially divides Hampton Beach f rom the main area of town, creating an. island of beaches, summer crowds, and traffic.
There are only a limited number of 1
access roads f rom the beach, across the marsh, and into town.
In the
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i event of an. emergency at Seabrook, therefore, much of the evecuating traf fic. must proceed. west toward, by, and beyond the power plant.
l-Many evacuees would be required to move closer towards a damaged reactor, the very thing from which they would be attempting to escape.
Additionally, as Hampton police of ficers will testify 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 IA 'and 51, have only two lanes.
A single
- accident, breakdown, or stalled vehicle on one of the limited evacuation routes could freeze a substantial portion of the evacuating traffic.
Vehicles within sight of the reactor would be unable to move.
Q.
Describe the traffic in the area of Hampton Beach, under 1
normal conditions, on a sunny summer day.
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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.
Q.
What is the position of the Town of Hampton with respect to the NBRERP 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 i
unworkable.
The Town therefore will not train for, or implement the NHRERP in the event of an emergency at Seabrook.
Q.
Why do you believe that the NHRERP is not workable?
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,
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all Town departments during an emergency.
(see NHRERP, Vol.18, p.
IV-9).
The Town Manager's entire support staff, who have no experience in emergency management, consists only of one full-time 1
secretary, one full-time bookkeeper, and one part-time assistant, j
which we believe is plainly inadequate to monitor and direct an evacuation of tens of thousands of residents and tourists from 3
1 Hampton Beach.
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Additionally, beyond ' the briefest outline of procedures in the NHRERP, no details or guidelines are provided to indicate when the Town Manager, should direct a particular emergency response, or what 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?
"'he NHRERP is not clear beyond requiring the Town Manager to base his decisions on " input" f rom the Towa's Department Heads.
Accordingly, 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 1
Civil Defense Director.
As the Civil Defense Director, the 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 Defense.
(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 enample of personnel deficiencies in the NHRERP, the Hampton Public Works Director is required, under the plan, to coordinate transportation for special facilities, school s, and those with special needs, and to " assess the impact of current and forecasted weather conditions on the road network," although these duties bear no relation to his employment responsibilities.
(see l
NHRERP Vol.18, pp. IV 27, 2 9).
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'Un' der the NHRERP, the Public' Works Director is also required to maintain accessibility of_ emergency evacuation routes in Hampton.-
e The Department, however, does not own a single tow truck.
How road clearance is to be carried out, therefore, and with what resources or personnel, remains unspecified under the plan.
(Id. at IV - 27).
Additionally, although the NHRERP assigns these roadway
)
clearance. and transportation responsibilities to the Public Works Department, a substantial majority of individuals employed by Public Works have no training 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 treatment and sewer maintenance.
24 other Public Works Department employees. are " temporary," are only approximately.17 years of age',
and who typically perform such duties as dump -attendance, trash pick up and ' street-sweeping.
These employees have _ no training or experience in roadway clearance or traf fic control.
In addition, should'an evacuation be necessary during the school year, most of these employees will be in school.
4 The plan, therefore, assigns individuals, whose principal employment responsibilities are maintenance of Town sewers, road construction, and landfill (oump) management to manage transportation resources for special needs populations and to clear roads without a single tow truck.
6
Q.
Under the NHRERP, the State of New Hampshire has pledged to compensate with State personnel, motor vehicles, and other resources in the event these requirements cannot be met by EPZ towns.
Do you believe this compensatory plan will cure the deficiencies in the NHRERP for Hampton thei you have described?
A.
No.
I base this opinion on several reasons.
First, the compensatory plan. f ails to specify how the State's emergency workers 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 from at least as far away as Concord, approximately 1-1/2 hours driving time from Hampton Beach under normal conditions.
That is the point.
The conditions would not be normal.
Thousands of motor vehicles would be attempting to evacuate Hampton Beach from limited access roads.
These access roads are the very roads which emergency workers necesarily must use to reach the beach area.
To expect, for i
example, that a two lane road such as Route 51 would remain f reely accessible to incoming vehicles while thousands of vehicles are attempting to flee the EPZ, I believe is wholly unrealistic.
The New Hampshire Civil Defense Director, himself, has stated that additional State Police, beyond the limited number of officers in Troop A located in Epping, would require three to four hours to respond to an emergency at Seabrook.
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Second, the State showed it could not carry out even a limited and preplanned emergency drill for Seabrook.
The Federal Emergency Management Agency noted "many deficiencies in the State's ability to provide evacuation transportation resources in a prompt and coordinated manner."
(Seg, Current FEMA Position and Admitted Contentions on New Hampshire Plans f or Seabrook, Appendix A, Page 17. ) I would also point out that the State's preplanned evacuation was performed in February.
To my knowledge, Hampton Beach was not particularly crowded at that time.
An actual emergency during the summer would present, with the beach population, substantially more significant obstacles to an effective evacuation.
Third, the State's compensatory plan t ? lies 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 number of Teamsters could be notified at the time of emergency, that a suf ficient number of Teamsters would drive into a radiological emergency. Additionally, the training provided to the Teamsters i
apparently has consisted of only one to two hours of instruction.
I believe it is unrealistic to expect Teamsters to drive school buses, or special needs vehicles, when it is likely that most Teamsters have not had experience performing these duties, particularly under j
emergency conditions.
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During an emergency, therefore, the tens of thousands of people g
i on Hampton. Beach wil1~ be.gridlocked on narrow roads, a scene repeated i
i
-anyEsunny day lat the beach, even under normal conditions.
Eme rgency 1
conditions will only' m'agnify the problems.
i Fourth, as the Hampton-Police will. testify tin ~ this proceeding,"
w'e.. h a v e no' confidence the state can or will, be able t'o-timely compensate f or deficiencies in loca1' personnel.
The State of, New
. Hampshire has not shown that the State, itself, has this additional personnel.ito assist. all1 of the EPZ towns, simultaneously, including li providing an adequate number of State Police.
l
.The Town of Hampton therefore has no confidence that the NHRERP l
1 can be reasonably or adequately implemented, with or without the.
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training and participation of'the Town.
O.
Does this conclude your testimony?
.A.
Yes.
Respectfully submitted, TOWN OF HAM ON By Its At neys l
SHAINES-cEACHERN Profes al so n
By:
ul McEachern h N'
' Dated:
September 1987 B :
Brock N
Matthew T.
l 9
i
1 O.
CERTIFICATE OF SERVICE l
l I, Matthew T.
Brock, one of the attorneys for the Town of Hampton l
herein, hereby certify that on September 11, 1987, I made service of l
the following document PREFILED TESTIMONY OF DONA JANETOS ON BEHALF OF l
TOWN OF HAMPTON REGARDING TOH REVISED CONTENTIONS III, IV AND VI by i
depositing copies thereof in the United States Mail first class postage j
prepaid for delivery (or, where indicated, by Express Mail, prepaid) i addressed to:
- He'en Hoyt, 'Esq., Chairman
- Judge Gustave A.
Linenberger, Jr.
Atomic Safety and Licensing Board Atomic Safety and Licensing U.Sr Nuclear Regulatory Commission Board Panel East West Towers Building U.S. Nuclear Regulatory Comm.
4350 East West Highway East West Towers Building j
Bethe.=da, MD 20814 4350 East West Highway j
Bethesda, MD 20814 l
I
- Dr. Jerry Harbour Atomic Safety and Licensing Board
- Atomic Safety and Licensing Panel Board Panel l
U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Comm.
4 East West Towers Building Washington, DC 20555 q
4350 East West Highway Bethesda, MD 20814
- Atomic Safety and Licensing Appeal Board Panel 1
- Docketing and Service U.S.
Nuclear Regulatory Comm.
)
U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 I
Mrs. Anne E.
Goodman William S.
Lord, Selectman j
Board of Selectmen Town Hall 13-15 Newmarket Road Friend Street j
Durham, NH 03842 Amesbury, MA 01913 l
)
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 & Solomon Office of the Exec. Legal Dir.
j 111 Lowell Street U.S. Nuclear Regulatory Comm.
l Manchester, NH 03105 Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814 5H AINES fm McE ACHERN
- SHOFE5SIONA4. ASSOCATON 25 MAPLEWOOD AVENUE P O f40M 360 PORT 5 MOUTH. N.H 03801
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Mr. Angie'Machiros, Chairman H. Joseph Flynn, Esq.
l Board of Selectmen Office of General Counsel l
Newbury, MA 01950 Federal Emergency Mgmt. Agency l
l 500.C Street, S.W.
- George Dana Bisbee, Esq.
Washington, DC 20472 Stephen E. Merrill, Esq.
l Office of the Attorney General
- Carcl S. Sneider, Esq.
]
State House Annex Donald S. Bronstein, Esq.
j Concord,.NH 03301 Allan R.
Fierce,'Esq.
I Dept. of the Attorney General-j One Ashburton Place l
Stanley W. Knowles 19th Floor j
Board of Selectmen Boston, MA 02108 j
P.O. Box 710 North Hampton, NH 03862 1
l J.
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 l
Board of Selectmen U.S. Senate Town of Salisbury Washington," DC 20510 J
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 i
Richard A. Hampe, Esq.
Gary W. Holmes, Esq.
i 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 1
10 Front Street 126 Daniel Street.
l Exeter, NH 03833 Portsmouth, NH 03801 J
j
- Edward A.
Thomas Sandra Gavutis 1
Federal Emergency Mgmt. Agency Town of Kensington f
442 J.W. McCormack (POCH)
RFD 1, Box 1154
{
Boston, MA 02109 East Kensington, NH 03827 Charles P. Graham, Esq.
- Diane Curran, Esq.
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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 l
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s - es a m e e c m. m.
.t...m.1,0~
i 35 M.ALKWOOD AVENUE P O stox peo PortT.MOUTM. 94 H 0580s
Robert Carrigg, Chairman Senator Gordon J.
Humph"ey Board of Selectmen One Eagle Square, Suite-507 Town' Office Concord, NH 03301 Atlantic Avenue (Attn:
Herb Boynton)
North.Hampton, NH 03862 Mr. Thomas H. Powers, III Mr. Peter Matthews Town _ Manager Mayor l
f Town of Exeter City Hall 10 Front Street Newburyport, MA 01950 l
Exeter, NH 03833 i
Brentwood Board'of Selectmen Judith H. Mi ner,.Esq.
{
RFD Dalton Road Silvergate, Gertner, Baker, Brentwood, NH 03833 Fine, Good & Mi ner
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88 Broad Street Boston, MA 02110
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