ML20238F282
| ML20238F282 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/11/1987 |
| From: | Macdonald D RYE, NH, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | |
| Shared Package | |
| ML20238F199 | List: |
| References | |
| OL, NUDOCS 8709160057 | |
| Download: ML20238F282 (7) | |
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September 11, 1987 1
UNITED STATES OF AMERICA
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NUCLEAR RESULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENR3NG BOARD in the Matter of
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PUDLIC SERVICE COMPANY OF
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Docket No. 50-443 OL-1 e
NEW HAMPSHIRE, et al.
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Off-site Emergency
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Planning Issues (Seabrook Station, Unit 1)
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SEACOAST ANTI-POLLUTION LEAGUE TESTIMONY OF DAVID P. MACDONALD ON SAPL CONTENTIONS 8 AND 8A RELATIVE TO THE TOWN OF RYE Q.1 What is your name and position in the town of Rye?
A.1 My name is David P. MacDonald. I as the Civil Defense Director of the town of Rye.
Q.2 How long have you held that position and what experience in town af f airs do you have to bring to bear on the emergency planning attivities of the town?
A.2 I have held the position of Civil Defense Director since February 24, 1986.
Prior to that I
served as a seaber of the Rye Sounding Board which produced the draft of the new Rye Master Plan, as the chairman of the Rye Water Pollution Control Committee, and as an alternate member of the Rye Board of Adjustment.
8709160057 870911 PDR ADOCK 05000443 T
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-2 0,3 What is.the purpose of your testimony?
A.3 The purpose of sy' testimony is to present the position of the town of Rye concerning the adequacy of the manpower resources available to the town to carry out lthe plan contained in Volume 20 of the NHRERP and prepared and submitted by the New Hampshire Civil Defense Agency, now known as the Governor's Office of Energency Managementin the name of the town of Rye.
0.4 Does the. town then intend to carry out the plan?
A.4 No,.The town does not acknowledge the plan prepared by the state, and believes neither that the plan can. be implemented successfully nor that it J
would provide adequate protection to the people of Rye if it were implemented.
It has been the standing' policy of the selectmen of Rye ano nytelf to refrain from any activity which would further the ultimate issuance of an operating license for Seabrook on the basis of the existing NHRERP Volume 20.
0.5 is your testimony' intended to point out the reasons for the town's position specifically with respect to manpower?
A.5' Yes.
There are a number of other unacceptable areas but I will deal specifically with the issue of sanpower.
0.6 Please describe the nature of the aanpower problems that you have
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identified in Volume 20 of the NHRERP.
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A.6 As I stated earlier the town does not believe that the NHRERP Volume I
20 plan can be implemented successfully. Part of the reason for that is that the 4
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manpower resources forming the basis of the plan are, from a realistic point of view, overstated. An example of that can be found in the road agent's department.
The plan indicates that a total of six personnel are available. The plan calls for one person, yielding an apparent surplus of five. The reality,
- however, is that the six seabers of tne road agent's department are only available between the hours of about seven AM and about four PH. Some of the road agent's crew are not residents of the town, including the road agent himself.
It is uncertain that any of the road agent *s personnel could be contacted, and if contacted, would be able to report for emergency duty.
The road agent's department is only one example of a general situation.
The fire department relies primarily en ' call" members. Of the twenty-six members claimed to be available in the plan only seven are permanent full time esployees, and of those only three are on duty at any ordinary time. Similar situations apply to the police department, the town hall staff, and the board of selectmen. I myself, as civil defense director, as an unpaid volunteer whose availability is improbable.
The April 1987 Personnel Resource Assesment Survey for Rye indicates a requirement for thirty-one individuals to staff emergency operations and shows l
l a total availability of sixty-f our individuals as though they were all standing by night and day to spring into action. The reality is that these are ordinary people who work second jobs, take vacations, fall ill, leave town, take the phone off the hook, and otherwise go about the affairs of crdinary living which make then f requently unavailable on a timely basis f or a f ull-scale emergency.
Rye does not accept the proposition that thirty-one individuals would be l
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i adequate to staff the town's emergency response organization, and certainly does not accept the proposition that thirty-one could be mustered in a timely way from the present roster of town emplyees.
l The emergency situations that we have regular experience with in Rye are J
ones such as house fires, brush fires and auto accidents. They are situations requiring a sinimum of coordination and a small percentage of total capacity.
For almost any situation involving more than half a dozen emergency personnel Rye relies on mutual aid from surrounding communities. The reason for that reliance on autual aid is that we recognize the reality that cnly a small percentage of our total identified manpower can be mobilized at any given time.
That reality goes unrecognized in the NHRERP. In a general regional emergency mutual aid cannot be relied on because each community will be fully occupied with its own operations.
There is also a question of the time required to fully sobilize the emergency response manpower resources. The plan does not deal directly with the mobilization time problem for an emergency which quickly reaches general classification and planning seems to be based on an assumption that the emergency response sanpower required for any response activity will always be on duty at the required mosent. Of course it is unrealistic to assume that 100%
of planned capability is available in zero elapsed time. Notification times could be the same for both the public and the emergency response personnel in a quickly developing general emergency.
The public has only to begin its evacuation whereas the emergency response staf f would need time to activate the various elements of the plan. That f act leads inevitably to an ' evacuation which is substantially underway before the required control and support organization is functional.
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5' Q.7 Please sussaiare the major points of your testimony thus far.
A'. 7 My testimony to this point has been intended to explain the town of Rye's position that the NHRERP for Rye cannot be implemented as written. The two major: reasons are..that there is no assurance that the manpower resources
. identified in the plan will'actually be'available when needed, and that there is no assurance that they could be mobilized in time to support the conclusion thrt the plan provides for an adecuate energency response.
i D.8 Are there any f urther points to be made concerning manpower in Rye?
A.B Yes.
As I stated earlier the town does not believe that the NHRERP-for Rye would provide adequate protection to the people of Rye if it were implemented as written. One simple illustration of the reasons f or that belief is the number of traffic control points planned. The traffic control pcint map included in Revision 2 of NHRERP for Rye indicates three traffic control points.
The April 1987 Personnel Resources Assessment Survey for Rye indicates that these points will be sanned by state police. There are at least seven additional points which are dangerous traffic nodes under ordinary conditions and which would require supervision in an emergency. In each of these locations the likelihood of a collision occuring is significant. Additionally, traffic control would be required at both of Rye's schools in order to ensure that school buser engaged in evacuation of pupils would have freedom of sovement both to and from the schools. The Rye police department employs eight full-time professional officers including the chief.
That number is not adequate to provide both security and traffic control capability.
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In a simple emergency such as a winter stors which is not complicated by the presence of a large transient population the police department is overtaxed in trying to keep the dangerous sections of beach road clear of ordinary traffic.
Experience in Rye shows that vehicle operators do not simply obey instructions even when it is in their own interest to obey. Physical barriers such as police vehicles are needed to control traffic flow. It is critical that i
there be an obvious presence of official authority in the form of a uniformed officer for traffic control to be effective. Untended barriers have repeatedly been resoved to permit traffic to flow in directions which compound the difficulty of responding to the emergency conditions.
Another example of underestimation of manpower required is in the public information area.
In Rye people who are uncertain about what to do in times of emergency have tended to appear at either town hall or the fire station in order to ask questions and get inf ormation. The April 1987 Personnel Resources Assessants Survey for Rye anticipates an EOC staff of eighteen people none of whom are responsible to give inf ormation to the public. There will need to be at least two people assigned to provide information to seabers of the public at both the town hall and the fire station. There will also need to be a uniformed officer available to provide security at the fire station.
An area not considered at all in terms of manoower concerns random requests for assistance from members of the public.
This is an area of uncertainty which will place a particular burden on aanpower because each case will need to be responded to individually.
The most outstanding example of failure to recognize needs in the Rye plan concerns the Isles of Shoals. These islands are approximately six miles out to sea.
The inhabited islands which are a part of Rye include Lunging Island and Star Island. Star Island is a particular problem because it contains
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a resort hotel,- several individual residences and a chapel, all operated by a religious organization which conducts a variety of conference programs on the
' site during the sunser. sonths. The peak population can reach several hundred
. persons. -The islands.are obviously remote and-vulnerable to unfavorable weather.
The only access is by water because the islands are too small to accomodate aircraft.
These islands are not even. mentioned in the plan and no.
resources, including manpower, are allocated to provide for the safety of the inhabitants.
A minimum of six people would be required to provide notification, transportation on both water and land,'and security for Star Island. Lunging I sl an'd is owned and inhabited by a single family who could be expected to make their own way to Star Island to be included in an evacuation, 0.9 Please summarize the major points you have just discussed.
A.9 I have discussed the reasons that Rye believes that the NHRERP Volume u
'20 would not provide adequate protection even if it were implemented as l
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The two principal ' reasons are that the resources identified in the plan are not adequately matched to demands that would realistically be placed
.on them in an emergency situation, and that significant emergency response i -
needs which are unique to Rye have not been recogni:ed and provided for.
l Q.10 Does that cenclude your testimony?
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l A.10 Yes.
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