ML20247B820

Emergency Planning.* Forwards Necnp Proposed Findings of Fact & Rulings of Law,Town of Hampton Brief,Governor Dukakis Statement & Proposed Findings, Sections 1 & 10.W/o Findings & Brief.Related Correspondence

ML20247B820
Person / Time
Site:	Seabrook
Issue date:	09/05/1989
From:	Brock M MASSACHUSETTS, COMMONWEALTH OF
To:	Fraley R NRC
Shared Package
ML20247B740	List: ML20247B732 ML20247B785 ML20247B820
References
OL, NUDOCS 8909130156
Download: ML20247B820 (45)

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.bo THE COMMONWEALTH OF MASSACHUSETTS 4 #- DEPARTMENT OF THE ATTORNEY GENERAL

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- JOHN W. McCoRM ACK GTATE OFFICE BUILDING oNE ASHSURToN PLACE. Boston 021o8-1698 JAMES M. SHANNON anoRNEY Gt96(RAL September 5, 1989 FEDERAL EXPRESS

'Raymond F. Fraley Phillips Building, - Room P- 404-7920 Norfolk-Avenue Bethesda, MD 20814 RE: Seabrook Station Emergenm* Planning

Dear Mr. Fraley:

25, 1989, In response to your letter to me of August .

enclosed please find: .

l.- NECNP Proposed Findings of Facf and Rulings of Law;

2. Town of Hampton's Brief in Support of Appeal of Partial Initial Decision on the New Hampshire Radiological Emergency Response Plan;

.. Statement of Governor Michael S. Dukakis Regarding the Seabrook Nuclear Power Station;~and

4. Proposed Findings Sections 1 and 10 The Massachusetts Attorney General's Office requests that the ACRS consider these enclosures in its review of emergency planning at Seabrook. The enclosures principally focus upon 2, FEMA's and 4); the role in'the Seabrook licensing (Enclosures 1, unique and problematic features of the Seabrook site for emergency planning (Enclosure 2); the impact of the non-participation of the Commonwealth and local governments en planning (Enclosure 4); and, as a consequence of siting problems at Seabrook, why adequate emergency planning is not possible (Enclosures 2 and 3).

These materials are provided at this time to ensure their timely receipt by ACRS. As we agreed, I will fax to you tomorrow a statement on behalf of the Massachusetts Attorney 8909130156 090907 PDR ADOCK 05000443 PDR a L 0 l

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' Mr'. , Fraley.

[  ; September 5, 1989 Page-Two 5 General'sLOffice in response to issues raised 1at the August.417 ACRS. subcommittee meeting'on Seabrook. I understand this will be timely! distributed to ACRS.

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Very:truly yours,

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Matthew T. Brock

Assistant Attorney. General Nuclear Safety Unit Public Protection Bureau One-Ashburton Place, 19th Floor Boston, MA 02108-1698 .

(617) 727-2200 1

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e \TO*E*;'. OF GOVERT:OR M:0HAEL S. D'?? \r :3 REG AR DI:!G T53E SEABROOK tlUCLEAR' POWER STATIOt1

. .. Secterber 20, 1086 Under feder-al statutes and regulations I am called upon as covernor of Massachusetts to play a particular role in the licensing process fer the proposed Seabrook Nuclear Power Station. After lengthy and painstaking review of all the pertinent information, and careful analysis of th. applicable.

standards, I have reached a decision, w h i r'- I am a n nou n'c.i.n g today.

The Mistorical an: Reoulatory Context The Commonwealth's involvement in the licensing of Seabrook a ually extends back very far. In 1975, when the construction

'icense for Seabrook Station was under consideration, Attorney General Frank Bellotti, appearing in opposition, issued warnings ': hat have proved prophetic. He first told the federal regulators and then the federal courts that siting a nuclear power plant at Seabrook ignored considerations of public safety. Pointing to the proposed plant's proximity to the crowded beaches at the New Hampshire and Massachusetts border, the Attorney General argued, as he has for nearly twelve years,

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that the lack of shelter for the beach population and the inadequate highway system in the area nade protection of the punlic in the esse of a serious accident a near impossibility,

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y 2-L To prevent: huge financial resources from neing i r r e t r i e v a c '. .

committed to a plant that might never be licensed, he urged the-federal authorities hot to proceed. Despite the Com.monwealth's strenuous argument that the choice of site was a monu.5 ental error in judgment, construction was permitted.

At- the time, prior to the 1979 nuclear accident at Three

.Mi'e Island, the local health and safety concerns raised by the Attorney General were, at best, peripheral factors in

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-federal licensing equation. Three Mile Island, however, brought a long overdue, rude awakening. It became clear that federally mandated planning for an emergency was, wholly inadequate, and that health and safety were being seriously Jeopardized.

One outgrowth of the accident was reassessment of the prospects for nuclear energy itself in light of the risk. No new plant nas been approved for construction since Three Mile Island. Only the few plants already in construction in 1979, of- which Seabrook is one, remain to be considered for final operational licensure. It is by now beyond question --

given the escalation in cost and controversy -- that if we were to be i

given a second chance to avoid construction altogether, no prudent person would in hindsight choose Seabrook.

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Tor : those plants 'already in operation and those approved for- construction,' -the federal government responded to Three lttile: Islind by maki*ng off-site emergency planning a primary statutory requirement. On this issue, the inportance of state Land local participation was' explicitly acknowledged by Congress with the requirement that -"there must exist a state, local or utility plan which provides reasonable assurance that public; health 'and safety is not eniancered by the operation of the facility." ".

In the words- of the Muclear Regulatory Commission, '"no operating license . . . will be issued unless a finding.is nade that there is reasonable ' assurance that adequate protective measures can and will be taken in the event of a radiological emergency." Federal agencies look first to the stat.e through its Goverr - to make this determination. I must judge whether a plan can be devised which "in the opinion of the state is adequate to protect the public health and safety of. its citizens living within the emergency planning zones" -- a radius typically of ten miles -- by providing " reasonable assurance that state .and local governments can and intend to effect' appropriate protective neasures offsite in the event of 6

a radiological emergency." The standard for the Governor, as

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it .should be, is thus . not only one' of intent but of th feasibility of proposed protective measures.

-he'Apnlicable standards To assist in a . state's approach to emergency __ planning, federal' agencies responsible for nuclear plant licensing have

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set forth comprehensive standards and guidelines. It is those.

rules tha t. -I am obliged to-follow in exercising my judgment as Governor. To begin with, it is clear from the guidelines that several factors which have a significant relation to health and safety are beyond the purview of the Governor. Such on-site factors as ' design of the reactor, strength of the containment vessel, quality of management, and quality of reactor operator training are all important to protection of the public.

7  !!onetheless, under federal law these are-questions exclusively for the t!u cle ? r Regulatory Commission. My judgment is not to be influenced by the evidence on thesa issues. Indeed, the statistical probability of a serious nuclear accident as distinguished from the adequacy of the response is not a proper part of the state's deliberations.

Instead, I an mandated to base my judgnent regarding health and safety on several assumptions stated in the federal guidelines. As a general matter I am directed that no single specific- accident sequence should be isolated as the one for h

[L which .to , plan. because 'ach potential accident could have l

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different consequences. Pather, as the gulielines state, "t.2 range for planning purposes is very large, starting vi:h a zero point of " requiring no planning at all . . . to planning fo: tha worst possible accident, regardless of its extremely low likelihood." tii thin this nandated spectrum, federal guidelines direct Governors to assune among other things that an accident could occur with offeite release within thirty minutes, reaching a radius of five miles within two hours. tih ile the seriousness of the release to be assumed is not spe ci fi ca'1.l y stated, the assumptions appear to include e. release of radioactive naterial similar to that at Chernobyl, without regard to the particular cause of the release.

In summary, the central tenet of emergency olanning is that an accident can occur. My limited role in the federal process is to attempt to devise emergency response plans to deal with such an event if it does happen.

Chernobyl This in general terms is the context for my review and for I state planning. Last spring, with the assistance of the Attorney General, I was wi*hin a few weeks of reaching a I

decision on submission of offsite emergency p1'ans. Then, o1 April 26, 1986, an accident occurred at the Chernobyl Nuclear Power Station in the Soviet "<raine, shich cons.ituted the

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world's first actual nuclear power catastrophe,. with substantial loss of life, widespread exposure to radiation, and serious damage; to t?.e environment. We have learned that the I

radioactive release at Chernobyl was several million times  ;

j greater than Three Mile Island. Until Chernobyl planning -and judgment relating to major accidents were essentially based on computer models and mathematics. Chernobyl represents real .

experience, a test of the experts' predictions and an  !

opportunity to derive potentially important' lessons about planning for Seabrook.

I asked- Dr.-Albert Carnesale of Hat 2 rd University's  !

-Kennedy. School of Government, president Carter's nominee to i

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-head the . t!uclear Regulatory Comnission, to analyze the  ;

i Chernobyl accident, and to advise r.e ' regarding .the applicability of the Chernobyl cxperience to Seabrook.  !

Dr. Carnesale has devoted several months, without compensation, to this task. All titizens cf Massachusetts owe him a debt of gratitude for his careful, objective analysis.  ;

1 As it turns out, there are fundamental lessons to be learned from Chernobyl, directly applicable to my decision on  ;

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Seabrook. As Dr. Carnesale has told me, in a field as  ;

i intensely studied as this, what is to be learned is not

- entirely new, but tends to tell as . ore directly than comput+r

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models which -in

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. accident and'where emphasis must be placed in planning.

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It has been debated as to whether Chernobyl offers any lessons for design of nuclear plants, in light of'the-fact that 1

the Chernobyl . r e a c t o r' reflects a design philosophy far

.different from and' inferior to those used in this country. But under federal guidelines, that debate is not relevant to r.y decision. -It is the aftermath of the accident -- the impact' of

, the radioactive release and the human response to it -- that we must analyze for guidance. -And in this realm Chernobyl has much. to' say. As Dr. Carnesale has put it,> the accident confirms. beyond question that adequ' ate. offsite planning is essential and must be taken very seriously.

The. overriding characteristic of the Chernobyl accident is that, as bad as it was, it could have been far worse. First, the ' geographical and weather conditions at Chernobyl reduced the threat to life ' by dispersing the release.over a remarkably-large= area, extending in diffuse form to places remote from the plant, .rather than depositina lethal concentrations in population ' areas close to the plant. The flatness of the 1' be lv Ukrainian plains where Chernobyl is located, and the hot, dry.

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climatic conditions prevalent in .1at area tended to keep the radioactive debris aloft for relatively long periods of tire.

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r Second,' the nature of the explosion and the thermodyr.anic ef f ects ' of' a ,

graphite reactor fire as occurred at Chernobyl meant that the altitude reached' initially and

, thereafter maintained by debris-coming out of the reactor was quite great, about 4,000- feet. Thi's contributed independently to the subsequent dispersion of radioactive material over a wide.

area. Because graphite is absent from its design, it is expected that serious releases f rom a' plant like Seabrook Gill r'ise to and be . maintained at lower altitudes and therefore be d mosited over-a smaller area, even under favorable geographic and weather. conditions.

Third, the combination of clear, constant weather and a high altitude release permitted Soviet authorities to predict the . direction of the radioactive plume and to execute a well'-timed, coordinated usage of sheltering and evacuation of 135,000 residents within 18 miles that would prove virtually impossible in circumstances where time is short and the path of the plume uncertain.

Fourth, Chernobyl makes absolutely plain that adequate sheltering is essential to emergency planning. The 45,000 residents living in the immediate vicinity -- within two miles received relatively low dosages of radiation because of the

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- of' -their; homes, during the hours that authorities were l

monitorin'g the , pathway of the plume and nobilizing their forces for efficient evacuation. Some area residents who were not so fortunate- to live in the concrete block construction of f

.Pripyat, even though farther away. rom the accident, suffered far higher dosages, at levels considered unacceptably high for planning purposes by federal c Jencies. Thus, even in the event of a: catastrophic accident we learn from Chernobyl that immediate-evacuation may not be a proper response, particularly

-where.the path of the plume is unpredictable. What may'well be needed is temporary sheltering throughout the amergency planning-zone, followed by evacuation away'from the plume.

Perhaps th'e most humbling lesson of Chernobyl is that the hunan - f acter defies logic and corpput er modeliag. Despite the time available to mobilize for evacuation, and despite the totalitarian ef ficiency with which the evacu' tion was executed (the town of Pripyat was evacuated in two anc a heif hours) it nonetheless took up to a week to evacuate thousands of persons within a radius equivalent to the federal emergency planning zones, because authorities had not counted an people's unwillingness to leave their farms and livestock and their refusal te. cooperate despite the risk.

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There are other useful dimensions of the Chernorvi experience, but these in particular help light our way. 75e single overriding lesson is that human catastrophe can be

. avoided only, if . circumstances permit adequate emergency planning and response. Virtua11v every element of the offsite la emergency response - called for in federal regulations was utilized -a t C%ernobvl, and rost of them proved effective --

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whether hy luck or 5y' good olanning. 1:onetheless, desoite t.'o quality of the resconse, it was only because of the additional i

natural-or fortuitous circumstances such as weather, geography, and altitude of the plure, that more extensive inmediate and

'long term injury was avoided. Chernobyl was in nany ways a

, "best case scenario" for energency response.

t:o ne t he le s s , even under these conditions, thousands of residents within five miles of.the plant suffered radioactive dosages at least ei7ht times greater than the threshold set forth in federal guidelines for irrediate evacuation and 200 tines. ' greater than norral annus1 backcround exposure. Also, the mitigating circumstances that acconnanied the accident and tits immediate af err.ath did not spare the countryside around Chernobyl fron distr +Ssing long-tern effects. Evidence suggests that areas corprising Sundreds of square miles may rerain . uninhabitable for four years. ~5e irpact of s;ch depopulation on public heal " snd s a f e t '. not to mention the

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n area's. economy and its basic community fabric, are .beyond

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.l Seabrook Turning to Seabrook, the question is whether, taking into account conditions of nature and other related conditions over which - we . have no~ control, our emergency response could, if

' executed competently, prove adequate to avoid serious and real endangerment of the - surrounding population. Certainty on' this score is, )! . course, impossible. We must make our best judgment on.the available evidence.

Conditions at . Seabrook, viewed through the Chernobyl lens, compel me to conclude that, under the federally imposed assumptions, adequate plans cannot be devised.- At'Seabrook, we need not speculate about weather conditions. They are at the other end of the spectrum f.om Chernobyl. Winds are not constant, but rather constantly changing, influenced by land and sea. Winds are generally prone to change direction in less than an hour at any time. Moreover, the climate is not dry, but marked by extended periods of precipitation during the year. Since, as Dr. Carnesale advisec, we can expect a much lower. plume altitude than occurred at Chernobyl, the exposure of the immediate population foreseeable could be far higher,.

and rather than moving out quickly, the plume foreseeable could l'

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churn in the immediate area fer a substantial t ime. - :n rainy conditions the situation could only worsen and anong other

. things make'evacuatio'n itself very difficult.

The changing weather takes its toll not'only in immediate exposure to radioactivity but also in the difficulty of monitoring the plume, in predicting its course and in executing evacuation plans so as to move the. population away from the

-plume rather than into it. Thus, it can be foreseen that,'as we wait to determine proper evacuation pathways, exposure will be heavy in the - immediate area. Yet if we' evacuate quickly'to avoid -hat heavy exposure, we may wel' nake matters worse.

These factors combine to suggest that staying witihin the emergency planning zone may, on balance, prove less harmful than evacuating, at least for a period of several hours.

Taken together, these considerations could well require us to place great reliance on temporary sheltering in the inredi' ate vicinity, just as was done at Chernobyl. Yet it is

've r y clear that the extent and q u a.1,i t y of sheltering is inadequate at Seabrook. Whereas the concrete block residences in Pripyat were apparently ideal, the woodframe resider.ces that j, y are typical around Seabrook are far from ideal. This, in my view,-- presents a' serious problem year round_. However,

. sheltering ~is beyond question inadequate in the summer months, 4;

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when the extensive non-resident beach. population comes within the emergency planning zone. For them the - absence of shelter

, is disastrou's. '

All these factors make particularly important expert testimony prepared by Attorney General Bellotti which shows that 'a if major release occurred at low altitude and under weather conditions common to the Seabrook site, 'and if evacuation time were over ' five hours, many persons within'two miles of the plant _ could suffer exposure to life-threatening dosages of. radiation as they sat in their cars, and widespread exposure to such- dosages could occur in a radius extending beyond four miles.

Under favorable conditions it is estimated that evacuation V

of the Seabrook emergency planning-zone would in fact take over five hours at a minimum, during which time potentially lethal radiation exposure would be occurring, and sheltering would be inadequate. If underlying conditions were less favorable and evacuation faltered, the toll could only worsen. This in my view is: not a hypothetical worst case, but a foreseeable situation under the initial set of assumptions I am toic to make.

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Mention:must also be made of the human factor. .Certainly,

.the reluctance of many Ukrainians to be evacuated by authorities after Chernobyl has no imnediate parallel at Seabrook. But in a general sense it underscores how important cooperation is if we are to translate plans into . actual operation. On this score it is relevant that the towns in rtassachusetts within the emergency planning zone are against licensing, for reasons which even proponents of licensing nust respect as honest and sincere. I have continually taken 'the view that these residents' views must be considered. I have also made clear that if adequate plans could be developed, I .

would- feel nyself obligated .to submit then despite loca1 opposition. However, such plans rely on previously trained local residents 'and nunicipal employees working ef ficiently and with detailed knowledge of their assigned roles in the evacuation process. In circumstances where I ar in serious doubt about whether adequate plans are possible, these doubts are only compounded by questions abeit whether the necessary singleminded execution, which is absolutely essential for even E narginal success of the best of p1'ans, can be achieved at Seabrook. The unpredictability of the huran factor in this instance weighs against the ability to achieve an adequate

[ plan. It leads me to a helief that apart from all other problens, efficient evacuation is not likely.

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is M Conclusion *

. Ultimately, the questions of whether reasonable assurances can . be fiven ' is a hatter -of judgment. I must nake my best i

judgment based on knouledge and good conscience. In due course the- Nuclear Regulatory Commission will make its judgment, and

alnest inevitably, whatever the commission's decision, federal judges will be called upon in some manner as well. All the evidence- I cossess tells ne that while there is room for reasonable disagreement on details, the unshakable fundame6tal truth is this: if a serious accident occurs as I am told to assume it would, the combination of conditions at seabrook --

including principally weather, inadequate sheltering and~ exit routes, and the altitude of. the radi,oactive plune --

either individua11y'or more likely in combination create a foreseeable likelihood of high icsages of radioactive intake, against which emergency planning and evacuation cannot adequately protect. .

Under such circumstances I do not believe I as Governor can responsibly submit emergency plans, since they could not constitute appropriate protective neasures adequate to protect the oublic health and safety in the event of a radiological emergency, as federal law requires. I therefore do not intend

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Future Energy Needs The decision I have rade today is based, as a natter of

, federal . law .and (egulation, on one- factor alone --

my assessment of' the adequacy of emergency plans for- the Massachusetts portion of the Seabrook emergency planning zone.

Nonetheless, having made my decision, I cannot ignore the concerns which the potential non-licensure of the Seabronk station may pose for the future of its owners and investors, the energy picture in New England, and our region's economy. ,

Massachusetts stands ready to assist the owners of Seabrook and the State of New Hampshire to explore fully and creatively the option of converting either of both Seabrook units to a fossil fuel base. Such conversions are now well into the planning stage at the Midland plant in Michigan and the Zimmer plant in Ohio. Without question, serious issues of economic feasibility and accessibility of fuel supply would face any Seabrook conversion. But preliminary indications are that the engineering itself is feasible, and the potential resource of 1500-3000 megawstts is well worth the effort to fully determine its overall feasibility.

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fio r eove r , as Chairman of the !!e w England Governors, I have joined my colleagues in a full review and update over the past nine months of enerdy forecasts and policies for our six-state,

. region. It is our intention to produce, as early as our meeting of this coming December, a comprehensive plan for New England's energy future. Within that approach I' expect that we will emphasize such power sources as the purchase of additional power from Canada; the building a of number of smaller, gas-fired generating plants; the creation of new power through cogeneration and so-called "small power" facilities; conservation and land management; and the retrofitting of existing facilities currently slated for retirement.

I am confident the., working together, the economic and governmental leadership of New England will build a strong energy future that need not rely on the operation of Seabrook as a nuclear generating station.

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COMPARING EMERGENCY RESPONSE POTENTIAL AT SEABROOK WITH THAT OF OTHER U.S. NUCLEAR PLANT SITES DR. MICHAEL BLACK (With'Research Assistance by Dr. Richard Selove)

April 12, 1988 Prepared for Robert Goble, Clark University and the Massachusetts Attorney General's Office P

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-g-i Table of Contents 4n Section 1: 1 Introduction..................................

3 Section 2: Distinguishing Features....................... 4 2.1 Sizeable and Dense Peak Transient ~

- P o p u l a ti o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.2. Evacuation of Transient Populations....... 5 2.3 Peak Combined Populations 0-5 Miles....... 5 Section 3: Ancillary Features............................ 8 3.1 Indicies of Controversy & Impaired Legitimacy................................ 8 3.2 Intergovernmental Jurisdictions........... 9 3.3 Geographical Position..................... 9 3.4 Meteorological Conditions................ 10 3.5 Sheltering................................ 10

• 3.6 Seismicity................................ 10 3.7 Evacuation Time Estimates................. 12, Section 4: Comparing Seabrook's General Demographic Characteristics With That of Other Nuclear Power Stations................................ 14 Section 5 Promising Future Research..................... 17 Section 6: Bibliographic References...................... 18 Section 7: Maps & Attachments (Back Cover) 1 l

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Table'l. Tra sient Demographic Characteristics 0-2 & 0-5 Miles.... 6  !

1 Table 2. Combined Population Characteristics 0-2 & 0-5' Miles...... 7 Table 3. Generai Population Evacuation Estimates 1 (After Urbanik, 1981).................................... 15 l q

Table 4. select Comparative Demographic Characteristics Among U.S. Plants........................................ 16 2

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Section 1: Introduction j ev 1

This report compares the potential for emergency evacuation at the Seabrook nuclear power station with that of twenty-eight other licensed plants across the United States. Since as many as three plants may inhabit a single site, fourteen locations are represented by our preliminary sample. Of these total assembled sites, five fall .

under the-Nuclear Regulatory Commission's most recent siting regulations (NRC 1980), which require a relatively strict evaluation l of proposed emergency evacuation procedure prior to licensure (*).

These plants include Millstone, Diablo Canyon, San onofre, McGuire, and LaSalle (See Table 4 in Section 6). Whale not definitive, our analysis strongly suggests that Seabrook differs from other plants licensed after (and even before) 1980 in terms of the apparent difficulty of implementing an effective evacuation.

To construct our evaluation, we sought information on nine comparative categories common to Seabrook and other U.S. nuclear power stations. These categories included:

1. Size of peak transient populations at 5, 10, and 20 mile -

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2. Size of peak combined transient and permanent populations at 5, 10, and 20 mile radii

3. Indices of controversy and legitimacy costs

4. Inte rg overnmen tal jurisdictions

5. Geographical placement

6. Meteorological conditions and atmospheric transport

7. Seismicity

8. Sheltering availability

9. Establishing evacuation time estimates.

Once identified, we gathered evidence for each of the preceding categories to, first, document the Seabrook case, and second, to compare these findings--where appropriate or available--with comparable figures at other U.S. nuclear power stations (**).

Using these criteria as probable significant indicators, we sought the best comparative evidence available among a range of pre- and post-1980 plants. The nuclear power plant sites selected were characterize ( by a substantial number of transient and permanent residents, were--like Seabrook--similiarl y situated in complex ,

coastal loc .ns. Relying especially on an NRC- sponsored, comparative ody, we sought the best cross-cutting demographic data available including their estimated, hypothetical emergency evacuation times (Urbanik, Vols I & II, 1980).

• New regulations apply to nuclear power stations licensed since August of 1980. We refer to these sites either as pre- and post-new regulations plants.

• • In subsequent sections, information on Seabrook is gathered within sections labeled "a." Comparative materials with other U.S.

Nuclear Power Stations are found in sections labeled "b."

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Undertaking our comparative study, Section 2 presents findings suggesting "" trook is particularly distinguished by three factors:

2.1) SidB of peak transient populations 2.2) Thn' unpredictable and unique difficulty of evacuating transient populations 2.3) Size of peak combined transient and permanent populations at a radius of five miles and under.

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Section 3 presents analysis of several significant ancillary points which compound the difficulty of achieving an effective emergency evacuation at Seabrook. We view these factors as supplemental to the crucial points presented within Section 2.

Ancillary comparative criteria include:

3.1) Indices of controversy and impaired legitimacy 3.2) Intergovernmental jurisdictions 3.3) Geographical position 3.4) Comparative evacuation time estimates 3.5) Atmospheric transport 3.6) Sheltering 3.7) Seismology. ,

Section 4 contains a somewhat lengthier analysis of comparative demographic characteristics up to fifty miles. What becomes clear is that Seabrook's 0-5 mile population densities are significantly higher than that of other national plant sites. While Seabrook's demographic figures remain' impressive at ten, twenty and fifty miles when compared  !

with other major plants such as Zion and Indian Point, it is especially at closer distances that Seabrook appears unique. This is a crucial difference because populations close to a plant would have the least time to evacuate in the event of a nuclear power emergency. -

Section 5 summarizes the most promising avenues for attaining additional, valuable comparative material for assessing Seabrook's uniqueness.

Section 6 contains a comprehensive list of bibliographic references.

Section 7 contains supp;emental maps, charts and tables of possible use,for continuing analysis and review.

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Section 2: Distinguishing Features We must preface our conclusions with a disclaimer. Defensible comparative data are scarce (as the three separate Seabrook entries shown in Table 1 suggest). This initial methodological problem is compounded by the relative incomparability of data for different plants that have been derived from contradictory assumptions (for erample, see FEMA, 1981). We nonetheless preliminarily conclude that:

2.la) Seabrook is distinguished from all other observed pre- and pcst-new regulations nuclear power stations by the sizeable and dense peak transient populations within five miles from the plant (Urbanik, 1981, 4 l

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Vols'I & II and saith 1985 & 1986)..

4&n of the three available estimates. summarizing transient populations ist Seabrook,'enly one study done for the Wew Hampshire Civil Defense Agency attempted to' offer figures on the estimated two mile: peak transient evacuation requirements. Under " Summer' Sunday" worst-case

- evacuation scenarios, transient population surrounding Seabrook at a two mile radius'is estimated at 40,593 individuals (Maguire, 1983, rigure 3-7). .

Data on transient populations requiring evacuation at five miles are available from two sources. Maguire's five mile estimates is 105,128 individuals. The utility's Final Safety Analysis Report places

, five mile transient. population at 84,366 people (FSAR, 1982, Table i 4.1).

2.lb) Table 1 offers the best available comparative data on transient populations at a two mile and at a five mile radius. The data suggests that at two miles, Seabrook's peak transient' population is 5.3 times that of Pilgrim's and 10.3 times as great as San Onofre's, its next

• runner-up. AtLfive miles--and' depending on which set of data ere used--Seabrook's transient population is 2 - 2.5 times that of next runner up Pilgrim (Maguire 1983, Figure 3-7, FSAR, 1982, Table 4.1).

- Even' accepting the utility's own conservative transient estimates, Seabrook stands out among plants nationwide.

. 2.2) .The' preceding distinction is critical because evacuation of transient populations poses special and indeterminate problems f or those-attempting emergency planning. This is true for two reasons.

First, unique physical and psychological barriers influence transient's. receipt of an explicit-warning. Emergency. planners assume there are more factors preventing people from hearing a warning when they:are away from their familiar environments (Sorensen, 1988).

Second, evidence as to behavior of transients under fast-moving emergency evacuations is best termed anecdotal and is poorly

- understood. (Sorenson and Vogt, 1987, pg. 14) There is very little data available to help us anticipate the nature of future transient evacuations at Seabrook. Fast-moving events such as floeds provide us with-very 1 .ted comparative data. Hurricanes, however, remain our major modelt in some ways we find their comparative use unsatisfac Unlike technological hazards, hurricanes offer a lengthy le . Further, hurricanes--unlike reactor disasters--are a highly publicised natural hazard resulting in certain familiar and predictable consequences.

2.3a) Also noteworthy is Seabrook's peak " combined" population within a five mile radius (consisting of transient and permanent residents).

Population estimates at five miles vary from 138,694 (Maguire, 1983 Figure 3.1 & 3.7) to 119,116 (FSAR, 1982, Figure 4.1 & 4.41.

2.3b) Table 2 shows comparative combined population figures at five miles. Zion is the first runner-up with 94,255 people, (Urbanik, 1981, pg. 102) followed by Millstone with 82,401, (Urbanik, 1981, Vol II, pg.52) and Pilgrim with 62,419 individuals (Urbanik, 1981, tol II, 5

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pg.68). Especting evidence to the contrary, we were surprised to learn that SeabrodSts combined population at this radius was even

'significant1gclarger than Zion..

~

Contrasting sharply with all other new-regulations plants that we have: observed, Seabrook's dense population up through five miles poses special dif ficulties for emergency evacuation procedures. From the plant site outward, high, concentric densities of population could flood the roads, creating a' cumulative c.hallen?e to civil defense planners and personnel. Population within this range is crucial, especially in cases of fast-developing accidents, for evacuees have limited time to get'away before a radioactive cloud might arrive. For populations within 0-5 miles, Seabrook appears to be in a class of=its own. (More general. comparative demographic analysis follows in Section 6)

Section 3: Ancillary Features A number of features further distinguish Seabrook from many other nuclear power stations throughout the nation. Section 2 has , ,

documented the uniqueness of the site vis-a-vis a number of pre- and post- new-regulations sites in terms of the crucial variable: short range peak populations. The following ancillary points supplement and enhance our understanding of the plant's controversial national standing..

3.la) Based on several informal comparative " indices of controversy,"

Seabrook is second only to the crippled plant at Three Mile Island (TMI) in occupying a controversial national media spotlight. In fact, Seabrook stands-out as perhaps the single most contested and controversial nuclear power plant in the United States.'

3.lb) Relying on the "INF0 TRAC" media data base covering 900 national periodicals between 1980 to 1988, we tracked the number of explicit media citations given each U.S. commercial nuclear power plant. TMI was cited 181 times,-and Seabrook came in second with 66. WSPPS was next' with 37, a figure which was skewed toward discussions of its impending bankruptcy. Shoreham earned 35 mentions, followed by Diablo Canyon with'19. These figures should be weighed against an average of 9.8 citation, r plant, with a median of only three.

To red at we believed might constitute a regional reporting bias, we in ly removed from our compilation the only two INF0 TRAC indexed newspapers the New York Times and the Wall Street Journal (melded in from 1984 through the present). Adding their citations brings Seabrook's overall listings up to 97, followed by Shoreham's at

54. The controversy surroundit.g a plant could increase the difficulty of implementing an effective emergency evacuation procedure.

These indices any be significant because of the cost in terms of impaired legitimacy that the contentious Seabrook project may have imposed upon local, state and federal governments. This issue is potentially important because, in the event of a severe accident, whom will members of the transient and permanent populations trust for advice and good, up-to-the-minute evacuation instructions? Or to put 8

l . -

1 J

it another way, who commands sufficient credibility to initiate and manage an o $ rly evacuation?

a It appears as if public confidence is low when it comes to the public utility. One source of evidence is a survey done by the Massachusetts Public Interest Group, conducted three miles from the Seabrook plant on Salisbury Beach, MA, August 23, 1986. This survey l

of 391 Massachusetts and New Hampshire residents reports that "only

! 18% of the total surveyed would trust New Hampshire Yankee to give them good advice and information in the event of an accident at the plant (Shimshak, 1986 pp 580-581). This leaves to the governors of Massachusetts and New Hampshire (and Maine) the primary responsibility of stepping into the credibility gap.

Confidence in the Seabrook plant also appears to be low within traditionally conservative New Hampshire. A recent Washington Post article cites a poll by two University of New Hampshire political scientists in which voters " chose the economy over Seabrook as the most important (forthcoming electoral] issue. However, if the (1988 j New Hampshire Presidential primary] was solely a Seabrook referendum, i the poll showed the plant losing 2 to 1, with 34% undecided" '(Kiernan, 1987). Whether corectly or incorrectly perceived as proceeding under q Republican stewardship, Seabrook invokes a polarizing political effect that reaches deeply into partisan political camps. Conservative presidential hopeful Jack Kemp, for one, has gone on recotd in defense )

of retaining Seabrook's existing ten mile Emergency Planning Zone.

Following the recent New Hampshire presidential primary, Nationa)

Public Radio's commentators observed that Governor Dukakis' presidential aspirations were strengthened by his steadfast opposition to the plant, to its utility company, and to its current political guardians.

3.2) Intergovernmental jurisdictions prove to be a daunting problem for the Seabrook facility as elsewhere in the country. In the Seabrook case, roughly two dozen communities are within ten miles of the plant, six of which fall within Massachusetts' jurisdiction (including West Newbury, Newburyport, Newbury, Amesbury, Salisbury and Merrimac). New Hampshire's jurisdiction takes in a total of seventeen communities (including Brentwood, East Kingston, Exeter, Greenland, Hampton, N n Falls, Kensington, Kingston, New Castle, Newfields, Newton, No ampton, Portsmouth, Rye, Seabrook, South Hampton and Stratham ( diological, 1986, p. 1-5). of this list, only Por tsmouth :Newburyport are populous enough to be counted as cities (see Map 2 & 3 contained in Section 7). Recall, too, that the state of Maine is well within a twenty mile radius. The fact that Seabrook has three states near or within the Emergency Planning Zone places it among a distinct minority of plants nationwide.

3.3) Seabrook's geographical position appears unique in significant.

respects. Only Florida's St. Lucie station has offshore islands that provide crude geographical comparison. Situated two miles inland from a narrow isthmus-like beach, the plant is less than two and one half miles from the whole of Hampton Beach, a summer tanning ground with a reported population density of 31,500 people per square mile (Stever, 1980, p. 60).

9

, . --=

~

4 We have et to observe another post new-regulations plant which exhibits t , constricted, and as tightly drawn an evacuation network (see Maps 1?F contained in Section 7). During a fast-moving crisis, drivers would have no other choice than to negotiate bottleneck-prone, two-lane country roads that--for a significant distance--remain roughly equidistant to the reactor core. As one observer notes, "Two of the four available routes of egress from the [ adjacent] beach require either moving closer to the plant site, or skirting it at roughly the same distance as the beach before moving away from it j (Stever, 1980, p 52).

3.4a) When confronted with the challenge of predicting the atmospheric transport of raftation, Seabrook is among the more intractable national-sites. A near-coastal location, its dynamic meteorological conditions tax present modelling capabilities.

Seabrook's meteorological conditions typify coastal New England.

Winds are characterized by " ordinary periods of offshore and onshore winds . . . with prevailing wind patterns and measurements taken by i

[the utility) showing winds blowing from the plant site toward the beach during most of the year. There is, therefore, a statistically significant likelihood that a radioactive cloud originating from an accidental release at the plant site would move toward the beach during most of the year" (Stever, 1980, p. 52).

3.4b) One distinction can be made between assessing meteorological conditions at Seabrook and other " simpler" plant location sites. For example, if plants are located in flat countryside with no surrounding rolling terrain or complex bodies of water, modelling of atmospheric transport can be somewhat straight forward. However, atmospheric transport is difficult in complex terrains such as that encountered at Seabrook.

The atmospheric transport team at Lawrence Livermore Labs cautions against relying on meterological data gathered at airports and other stations where instruments are observed on the hour (Dicke rson, 19 8 8) .

Instead, plant sites such as Seabrook's require years of continuous data collection, interpreted and analyzed by trained meteorologists.

3.5) The a e of existin information on shelterin is difficult to assess t er er to document (for an overview, see Lindell, et al. 198 wever, two generalizations are possible. First, unwinteris . den beach cottages are the norm for the Seabrook area.

Such structures would provide inadequate protection in the event of a severe radiological accident. Calling the existing structures ". . .

too flimsy--and too few--to keep out radioactive emissions after an accident," FEMA has suggested either shutting down the reactor during the summer months, constructing an adequate number of emergency l shelters, or choosing some other option (Boston Globe, 1987). Second, as noted, current peak transient populations will find it difficult or impossible to discover adequate shelter in the event of an emergency.

3.6a) Seismicity is a significant factor in the Seabrook case. Located within what is--by Eastern standards--a known and active seismic 10

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region, it is somewhat surprising that the utility chose to build the l plant here qpk;all. First, the marshy ground that characterizes Hampton Fla99'made for far more costly construction. Secondly, of the four final site alternatives selected by Jackson and Moreland, (the utility's ori~ginal siting consultants) "the Seabrook site was rated as least desirable" (Shakow, 1988, Chapter 12, p.9).

From the outset, the consultants were troubled by Seabrook's potential for seismic risk. Shakow writes:

The Seabrook site was adjudged a VII zone and the areas immediately to the south of Newbury and Cape Ann Massachu-setts had already witnessed earthquakes of Mercalli inten-sity VIII, the most severe intensity experienced in New England over the past 350 years. In addition, Seabrook was the location for a geologic division or fault line. By contrast, all other [ potential) sites were located in the middle of a somewhat less risky VI zone (Shakow, 1988, p. 24).

Whatever their logic, the utility chose to locate their plant within a few miles of a known, northeastern epicenter. Situa'ted somethat east of Cape Ann, this fault erupted on November 9, 1727 and agaia on November 18, 1755 (Coffmann, et al, 1982, p. 6). Professor John Ebel of the Weston Observatory in Newton judges the 1727 quake as a probable low magnitude V tremor (Ebel, 1988). The 1755 quake, however, measured Intensity VIII (Modified Mercalli scale) with aftershocks as high as intensity V. While the Cape Ann epicenter has been relatively quiet for some time, there has been other activity in the area. Section Seven below, contains a compilation of 422 seismic

" events" that have occurred within 100 KM of Seabrook through June, 1986 (Ebel, 1987). A quake centered off the coast in 1978 was akin to LA's Fall, 1987 earthquake, which had a probable strength of V (Ebel, 1988). There is no way of knowing when the plant's seismic neighborhood might spring' back to life.

Accordingly, the Seabrook plant has been designed with the intention to be able to withstand an earthquake equivalent to the Cape Ann quake of 1755. But is that an appropriately conservative engineering judgement? As one newspaper account puts it, "A U.S.  !

Geological vey map published in 1969 shows a thrust fault extending i from Ports , New Hampshire, through Seabrook and into (

Massachuse Several scientists subsequently contested the adequacy of an int -eight design, arguing instead for intensity nine reinforcing ~(UPI, 1974). l l

Seabrook, located either over or adjacent to the Scotland Road  !'

Fault, is " rated as a zone 3 Risk by the U.S. Department of Commerce

[as] the most dangerous type of earthquake fault in the United States" j (Walter, 1974). According to NRC standards, zone 3 is characterized by "high seismicity, accompanied in most cases by intense, frequent faulting. . . .It is expected that the cost and time required for investigation of site suitability would make it impractical to consider these areas for nuclear energy centers at this time" (NRC, 1976, p. 2-6).

11

1 The actual Seabrook siting decision was made in the latter part of '

1968, prior- adoption of more conservative seismic siting strategies (Shakow, 19 Chapter 12, p.15). Interestingly, this point of vulnerabili lost on site planners Jackson and Moreland for,  !

when commen $'was not tsag on the site's seismic suitability, they wrote: "[The]

fault indication is not considered fatal to the Hampton area but it does indicate that this location would have to be very thoroughly researched and defendpd for licensing" (Shakow, Seabrook, 1988, p.

25). .  ;

3.6b) For our purposes, we can compare seismic risk at the Seabrook site with that of the more active California faults. While there is some instrumental data on New England earthquakes, several scientists with whom we spoke pointed to problems comparing the East with the more seismically active West. For one thing, seismic data in the Norhteast is difficult to find while earthquakes, themselves, pose no less significant risk. Professor John Ebel of the Weston Observatory observes what we record within one year in the West takes the equiva- .

lent of one hundred years in the East to occur. Ebel also notes that  !

it is not uncommon to travel a few miles within the Northeast without coming across an earthquake fault. The challenge is, most f aults have been inactive for hundreds of millions of years (Ebel, 1988). Ar Jay J. Pulli, former director of MIT's seismic network said, "New England earthquakes have large error bars"--meaning that prediction is so inexact that earthquake " frequency can stretch to the next 50 years or 10,000 years into the future" (Pulli, 1988). Where does this lead us?

"The next catastrophic American earthquake could well strike not in California but in the densely populated, highly industrialized and poorly prepared eastern United States," begins a recent NY Times article (Gleick, 1988). The northeast's seismic problem is that usually " faults do not qualify as active in the geologic sense" l (Perkins, 1988). Tremors come so infrequently that scientists are at a loss to construct a seismic model to explain what is going on underneath and why Northeastern earthquakes are occurring at all (Pulli, 1988). There is simply no way of identifying which faults are active versus inactive, underscoring the fact that " seismic prediction is in its infancy everywhere" (Pulli, 1988).

While bo b New Hampshire's Seabrook site and land adjacent to California' amous San Andreas fault are considered a hazardous Zone 3 rati ' predicting an " intermittent, extreme phenomenen that occurs on scales longer than recorded history" blunts a direct comparison ween Eastern and Western seismic conditions (Gleick, 1988).

3.7a) Published evacuation time estimates for Seabrook vary greatly, reflecting competing data and methodological assumptions. There remains far more art than science to divining these outcomes. Consider these two separate worst-case predictions of evacuation times:

Study A. Assuming fifteen minute notification, Seabrook's FSAR counts on a full evacuation of the 10-mile Emergency Planning Zone under summer weekend circumstances requiring 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, 50 minutes. They assume for this hypotheticci 1985 scenario, that an 12 l

_ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ . - - - - - -- _ -- J

m. ,

4

'(

m orderly vacuation takes. place without " unusual" conditions occurri liike vehicle breakdowns, cars running out of gas in

, accidents, etc). Under adverse summer weather h traffic ~

conditions-(rain or fog are specified), they point toward an evacuation time of 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, 50 minutes (FSAR, 1987, pp 76-77).

Study,B. FEMA.also hi9ges its 1980 evacuation estimates on fifteen minute notification. They note that "the evacuation time (of 6

~

hours 10 minutes) is determined almost totally by the rate at .!

.which the beaches can be evacuated. . .(FEMA 1980b, pp:5-6). FEMA l also presents the pessimistic case of a " breakdown" in the orderly

. evacuation. traffic flow. They write, "for an evacuation in which traffic control-is generally ineffective, total evacuation times l will range from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> 30 minutes to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> 40 minutes" (FEMA, 1980b, p. 7).

'l FEMA observers note that " evacuation time for a Summer Sunday case is determined almost totally by the rate at which the beaches can. ,

be evacuated" and that the suddenly overloaded, two-lane, country roads will likely be transformed into a giant traffic jam ( F E M,A ,= 1 9 8 1 ,

pg 46)

~

(see' Map.6, Section Seven, for FEMA's hypothetical rendering). l Due to' the automotive logjam, even a rapid response by transients to evacuation warnings may fail to' result in an efficient evacuation.

Finally there'is the psychological dimension alluded to by

~ evacuation planners when they conclude: "The behavior of drivers who I are caught in' congestion within direct sight of the Seabrook station i can only be guessed at this time. Any breakdown in orderly [and predictable) evacuation traffic flow could result in iattenuated .

evacuation times]" (FEMA, 1981, pg. 46).

This raises, for example, the question of vehicle abandonment  ;

during an evacuation. Professor Albert E. Luloff of the University of NewsHampshire' conducted a comprehensive survey of over 580 beachgoers 1 during mid-July 1987. He asked respondents ". . .how they would react )

l to a situation where they were in their vehicle, attempting to evacuate, and had not moved very f ar: (1) after a period of one hour f and -(2) af ter a period of two hours. After a one hour wait, more than eight out of every ten (814) said thcy would remain with their car while 14.5% said they would abandon it. After a two hour wait, the ,

percentage those indicating they would abandon their cars increased to 38.8t" ( .'ff, 1987, pg. 9).

w~ .

In summary, agreement on probable evacuation times for any particular congested site will remain elusive, bringing us to the question of whether comparisons among different plants' predicted evacuation times are possible 3.7b) One must be exceedingly cautious when comparing one set of evacuation times with another. Vogt and Sorensen's a987 annotated bibliography summarizes the conclusions reached in a 1981 FEMA report by saying: "[The article] provides estimates of evacuation times for 12 reactor sites and compares these with licensee estimates (FEMA, 1981). Because of differing assumptions the two sets of references are'not comparable" (Vogt and Sorensen, 1987).

13

e L

L Using t preceding FEMA comparative report, consider the following 1 ~L evacuation times of fered for plants that reside in high population . as which are thought to require special evacuation ,

considerations.  !

'l Nuclear Power Station EPZ Evacuation Time (Hours)

1. Indian Point 7-9 hours

2. Zion

• 5-6

3. Limerick

• 3

4. Bailly 3-5 "

5. Three Mile Island 3

6. Fermi 2

7. Beaver Valley 4

8. Shoreham 2-3 9, Seabrook 4-15 "

10. Midland 2-3

11. Millstone 3-5 "

12. Maine Yankee 2-6 "

According to this survey, Seabrook weighs in at the longest, j especially under worst-case evacuation assumptions. The fact"is that  ;

FEMA experts place a lonely hyphen between 4 and 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />, 1 corresponding to the best-case and worst-case conditions. This suggests that relative to other plants, Seabrook's evacuation times f are subject to a greater range of uncertainty, and disagreement.

A second, NRC-sponsored survey of emergency evacuation times under adverse conditions is represented in Table 3 (Urbanik, 1981, Vol II).

Evacuation times are hyphenated when different geographical quadrants within 2, 5, and 10 mile ranges require different evacuation times. As with most existing comparative evacuation data, we do not consider the preceding FEMA study and this one to be strictly comparable.

Nevertheless our rule of thumb assertion holds that Seabrook's worst-case evacuation data still leaves it among the lengthiest nationwide.

Section 4: Com3aring Seabrook's General Demographic Characteristics Wits That of other Nuclear Power Stations Sectio monstrates that Seabrook is significantly higher than pre- and w regulations plants when it comes to population densities in two and up to five miles. It is also unparalleled  !

when it comes to numbers of transients. We now turn to the plant's i comparative demographic characteristien at ten, twenty and fifty '

miles.

At a ten mile radius, Seabrook rated 99th out of 111 plants nationwide in 1979's permanent (i.e. non-transient) population statistics (NRC, 1979, pg. T-24). (see Table 4). Ranking in the 90th percentile, only plants at Millstone, Surry and Zion had greater populations within the 10 mile emergency evacuation zone. Of these plants, Millstone's population was roughly equivalent, Surry's was half as ou:h as Seabrook's, while Zion's was one-third greater.

14

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m At twen miles from the plant site, Seabrook (with 323,141) rated 94th out of. 1, only slightly surpassed by MaGuire (510,000), Haddam Neck (510,005), and Zion (530,000) (NRC, 1979, T-25).

At fifty miles, roughly'four million permanent inhabitants surround Seabrook. Rated as 97th out of 112, Seabrook is matched by San Onofre, Pilgrim, Dresden, Haddem Neck, and Zion. Only'Dresden with 6.3 million and Zion 'with 7.1 million inhabitants surpassed Seabrook in actual permasent population numbers. (NRC, 1979, p. T-28)

In short, Seabrook's scale at 10, 20, and 50 miles places it among l the most populated U.S. nuclear power stations. However, at these I radii, one cannot conclude from these comparative statistics that it is unique.

Section 5: Promising Future Research Future research is easily separated into two categories--one that j is promising and relatively easily accessible and a second, where l comparative statistics and documentation will only emerge afte.r substantial effort (i.e., brute force). We turn to the former.

At this juncture we know that Seabrook's site is distinctive because of its high population densities at two and five miles, and  !

because of the potential evacuation difficulties removing large l I

numbers of transients. This study compares Seabrook with five post-new regulations plants, which establishes Seabrook's absolute distinctiveness among these five plants. However, we presently lack crucial data on other post-new regulations plants that document the size of transient populations and their accompanying demographic characteristics.

We need to know if any of the other plants licensed under new regulations share Seabrook's unusual and distinguishing traits (***).

Information exists at the Nuclear Regulatory Commission in Washington, D.C. It would require a trip and a multi-day visit to assemble the remaining comparative statistics, thereby establishing definitively whether or not Seabrook is indeed unique in its radiological evacuation difficulty and risk.

The An y Features within Section 3 are capable of being more fully devel , but this would require far more effort. Establishing comparative- ults would be difficult although not impossible.

Section 6: Bibliographic References (Following)

Section 7: Maps and Attachments i

(***) Data from sixteen additional nuclear power stations appear to be particularly relevant. These include Byron, Callaway, Catawba, Farley, Grand Gulf, Limerick, Palo Verdi, River Bend, Salem / Hope Creek, Shearon Harris, St. Lucie, Summer, Vogtle, Washington N.P.,

Waterford, and Wolf Creek.

Section 6: rences (Adato, et al," 1987)

Michelle Adato, James MacKenzie, Robert Pollard and Ellyn Weiss, Second Safety: The NRC and America's Nuclear Power Plants, The Union of Concerned Scientists, Indiana University Press, Bloomington, pp 51-52, 69-70 (Adler, 1987)

" Testimony of Thomas J. Adler on Behalf of the Attorney General for the Commonwealth of Massachusetts [Regarding the ETE Contentions],"

Docket Nos. 50-443-444-01 (Off-site EP), September 14, 1987 (AIF, 1986)

" Electricity from Nuclear Power: A 1986 Map of Nuclear Power Plants in the U.S.,* Atomic Industrial Forum, Bethesda, MD, 1986 (Aldrich et al, 1978) ,

David C. Aldrich, David M. Ericson, Jr., and Jay D. Johnson, "Public Protection Strategies for Potential Nuclear Reactor Accidents:

Sheltering Concepts with Existing Public and Private Structures,"

Sandia Laboratories for the Nuclear Regulatory Commission, Sand 77-1725, February 1978 (Algermissen, 1969)

S. T. Algermissen, " Seismic Risk Studies in the United States,"

Reprint of the Fourth World Conference on Earthquake Engineering, Santiago, Chile, January 13-18, 1969 (Algermissen and Perkins, 1977)

S. T. Algermissen and David M. Perkins, " Earthquake Hazard Map of United States," Earthquake Information Bulletin, Volume 9, Number 1, January-February 1977 (Algermissen et al, 1982)

Algeraissen, et al, "Probabilistic Estimates of Maximum S. T. f Acceleration and Velocity in Rock in the Contiguous United States," ]

U.S. Geologi Aurvey, Open-File Report 82-1033, 1982 I

)

(Bauman, 1 )

A. Morris and T.R. Rice, An Analysis of Power Plant D. S. Bauman Construction ad Times, Volume I, Analysis and Results, Research Project EA-2880 for the Electric Power Research Institute, Palo Alto, l CA, February 1984 (Berger, 1979)

John J. Berger, "Three Mile Island: The Emergency Response to a Nuclear Accident," Draft Manuscript, 1979 (Boston Globe, 1987)

" Continuing Nuclear Power Battles," Boston Globe, July 5, 1987, pp 21

& 34 1G

l (CA, 1987)

Dennis Suit randum, enclosure " California Nuclear Power Plants,"

Governor's ice of Emergency Services, Sacramento, CA, December 11,1987 3t (Coffmann et al, 1982)

Jerry L. Coffmann, Carl A. von Hake, and Carl W. Stover (ed),

Earthquake History of the United States, National Oceanic and Atmospheric Administration, Publication 41-1, Boulder, CO, 1982 (Dickerson, 1988)

Marvin Dickerson, Lawrence Livermore Labs, Personal Communication with Michael Black, February 4, 1988 (Ebel, 1987)

Professor John Ebel, Weston Observatory Printout of 422 earthquakes taking place within 100 Km of Seabrook, New Hampshire, 1627 A.D.

through June, 1986 (Ebel, 1988) ,

Professor John Ebel, Weston Observatory, Boston College, Personal:

Communication with Michael Black, February 19, 1988 (Ebel and Kafka, 1987)

John E. Ebel and Alan L. Kafka, " Earthquake Activity in the Northeastern United States," Preliminary Version, prepared for Decade of North American Geology, Volume GSMV-1, Neotechtonics of North America, March 15, 1987 (ELC, 1983)

"Seabrook," Draft, ELC, JR./tir, May 9, 1983 (FEMA, 1980a)

" Report to the President: State Radiological Emergency Planning and )

Preparedness in Support of Commercial Nuclear Power Plants," Federal Emergency Management Agency, June 1980, pp III-10-III-15 (FEMA, 1980b)

"Seabrook Station Evacuation Analysis: Final Report," Federal Emergency Ma ent Agency, Prepared by Alan M. Voorhees &

Associates, at 1980 1 (FEMA, 1981) ._ -

" Dynamic Evacuation Analyses: Independent Assessments of Evacuation Times from the Plume Exposure Pathway Emergency Planning Zones of Twelve Nuclear Power Stations," Federal Emergency Management Agency, 1981 (FSAR, 1986)

"Seabrook Station: Radiological Emergency Plan, Final Safety Analysis Report, Public Service Company of New Hampshire, Seabrook, New Hampshire, (GAO, 1984)

"Further Actions Needed to Improve Emergency Preparedness Around 19

_ _ _ _ _ _ _ _ _ _ . _ - - J

i i

Nuclear Powe ants," Comptro21er General's Report to the Congress, i

.GAO/RCED-84 August 1, 1984 1 1

?

(GAO, 1987)

" Nuclear ReguTition: Public Knowledge of Radiological Emergency Procedures," U.S. General Accounting Office, GAO/RCED-87-122, pp 1-13 (Gleick, 1988)

James Glieck, " Eastern U.S. Is Warned About Big Earthquakes," New York Times, March 1, 1988, C-1 (Golding and Kasperson, 1988) 3 Dominic Golding and Roger Kasperson, " Emergency Planning and Nuclear j Power: Looking to the Next Accident," Land Use Policy, Butterworth and j Company Ltd., 1988, pp 19-36 i (Hans and Sell, 1974)

Joseph M. Hans, Jr. and Thomas C. Sell, "Evacation Risks -- An '

Evaluation," U.S. Environmental Protection Agency's Office of Radiation Programs, Las Vegas, Nevada, June 1974, pp. 83-91 ,

l (Hays, 1982)

Walter H. Hays, " Preparing For And Responding to a Damaging Earthquake in the Eastern United States," Conference XV, September 16-18, 1981, U.S. Geological Survey, Open-File Report No.82-220, Reston, Virginia, 1982 (Hays and Gori, 1983)

Walter W. Hays and Paula L. Gori, " Continuing Actions to Reduce Potential Losses from Future Earthquakes in the Northeastern United i States," Conference XXI, June 13-15, 1983, U.S. Geological Survey, I Open-File Report No.83-844, Reston, Virginia, 1983 i (Hays and Gori, 1984)

Walter W. Hays and Paula L. Gori, " Continuing Actions to Reduce Potential Losses from Future Earthquakes in New York and Nearby States," Conference XXIX, December 12-14, 1984, U.S. Geological Survey, Open-File Report No.85-386, Reston, Virginia, 1984 (Infotrac)

"INFOTRAC" Resource Index, 1988 (Kiernan, 1 Laura A. Kle en, " Fight Over Seabrook Shofting to the Last Front:  ;

Opponents Step Up Protest as New Hampshire Nuclear Power Plant Nears i Fuel-Loading Stage," Washington Post, 1987 l l

(Kindinger, 1985)

John P. Kindinger, Analysis of Lead Times and Causes of Delays in U.S. i Nuclear Power Plant Projects Under construction or Completed Since 1980, MS Thesis, Department of Nuclear Engineering, Massachusetts Institute of Technology, May 10, 1985 f (Lindell et al, 1985)

Michael K. Lindell, Patricia A. Bolton, Ronald W. Perry, Gregory A.

20

m- ~-- - -

l4 . -

\

Stoetzel, Jeroes B. Martin, and Cyntbla B. Flynn, Planning Concepts and Decisio 'teria for Sheltering and Evacuation in a Nuclear Power Plant Emer;_ _, Atomic Industrial Forum, AIF/NESP-031, June 1985 (Luloff, 198 E Supplemental Corrected Testimony of Dr. Albert E. Luloff on Behalf of

! the Attorney General of MA [RE ETE and Sheltering Contentions), Docket Nos. 50-443-444-01, December 14, 1987 l (MaGuire, 1983)

C.E. MaGuire, " Emergency Planning Zone Evacuation Clear Time Estimates, Seabrook Nuclear Power Station (Draft), Prepared for the New Hampshire Civil Defense Agency, February 1983 page 3 (Markey, 1986)

" Emergency Planning at Seabrook Nuclear Powerplant," Hearing before the Subcommittee on Energy Conservation and Power of the Committee on Energy and Commerce, Edward J. Markey (Chairman), U.S. House of Representatives, Serial No.99-180, November 18, 1986 ,

~

(NH Radiological, 1986)

" State of New Hampshire Radiological Emergency Response Plan,"

Prepared in Cooperation with New Hampshire Civil Defense Agency and the Technical Hazards Division (Nuclear News, 1987)

"World List of Nuclear Power Plants: Operable, Under Construction, or on Order (30 MWe and Over) as of June 30, 1987," Nuclear News, Volume 30, No. 10, August 1987, pp 83,97-100 (NRC/ EPA, 1978)

H.E. Collins, B. K. Grimes and F. Galpin, " Planning Basis for the Development of State and Local emergency Response Plans in Support of Light Water Nuclear Power Plants," Nuclear Regulatory Commission, NUREG-0396, December 1978, p 1-15 (NRC, 1976)

" Nuclear Energy Center Site Survey - 1975," Part V, " Resource Availability .8ite Screening," Nuclear Regulatory Commission, January 197 /

1976 (NRC,

" Demographic ^ htistics Pertaining to Nuclear Power Reactor Sites,"

Nuclear Regulatory Commission, NUREG-0348, October 1979 (NRC, 1980)

Criteria for Preparation and Evaluation of Radiological Emergency Reponse Plans and Preparedness in Support of Nuclear Power Plants, 0.S. Nuclear Regulatory Commission, NUREG-0654, November 1980 (NRC, 1987a)

Robert Bores Memorandum and Addendum, Nuclear Regulatory Commission,

" Protection of New Hampshire Beaches," January 1986 21

.q (NRC, 1987b) _.

Sherwin E. Memorandum, Nuclear Regulatory Commission, Public Service Com of New Hampshire, et al., June 12, 1987 (openshaw, 19Fs)

Stan Openshaw, Nuclear Power: Siting and Safety, Routledge and Kegan Paul, Boston, 1986, Chapters 6 (" History of Nuclear Siting in the U.S.") & 7, (" Demographic Characteristics of Nuclear Sites in the U.S.

and the U.K.") pp 189-268 (Palladino, 1982)

Nunzio J. Palladino, " Response to Questions Asked by Governor Hugh J.

Gallen of New Hampshire in Letter of October 15, 1981," Nuclear Regulatory Commission, PDR 50-443, April 27, 1982 (Perkins, 1988)

David M. Perkins, Un,ited States Geological survey, Denver, CO, Personal Communication with Michael Black, February 19, 1988 (Perkins, 1974)

David M. Perkins, " Seismic Risk Maps," Earthquake Information*

Bulletin, Volume 6, Number 6, November - December 1974 (Pulli, 1988)

Jay J. Pulli, Radix Systems, Rockville, MD, Personal Communication with Michael Black, February 24, 1988 fi (Pulli, 1981)

Jay J. Pulli, et al., "The Seismicity of New England and the )

i Earthquake Hazard in Massachusetts," Final Report of the Seismic Risk Analysis Subcommittee, Massachusetts Civil Defense Agency, December 1981 1 (Pulli, 1982)

Jay J. Pulli, " Earthquakes of New England and Adjacent Areas,"

Appalachia Journal, June 1982, pp 24-43 (Radiologic al, 1987 7)

" Radiological Emergency Response Plan," State of New Hampshire, Prepared by New Hampshire Civil Defense Agency Technological Hazards Dv1 .

}

l (San Onofre, 5)

"The San Onofre Nuclear Generating Station," Oversight Hearing Before the Subcommittee on oversight and Investigations, Committee on Insular Affairs, U.S. House of Representatives, Ninety-Eighth Congress, j Hearing Held in Santa Ana, CA, July 8, 1983, Serial No. 98-52, Part l

II, 1985 pp 356-398 (Shakow, 1988/ Draft) l J

'; Don Shakow, Seabrook: Genesis of a Failure, Department of Environment, Technology and Society, Clark University, Worcester, MA, 1988, Chapters 1 (" Introduction") and Chapter 12, " Facility Design and Site '

Selection," (Not for quotation without the expressed permission of the author.)

22 E_ __ _ _ _ _ _ _ _ . __ _ __ _. J

t

\

j (Shinshak, Rachael Shi and Michael L'Ecuyer, "On the Beach: A Survey of Massachuset achgoers' Reactions To An Accident at the Seabrook Nuclear Rea , " A Report by the Massachusetts Public Research Group, September 191 " Reproduced in Markey 1986, pp 578-97 (Shleien , 19 83 )

Bernard Shleien, " Preparedness and Response in Radiation Accidents,"

U.S. Department of Health and Human Services, HHS Publication FDA }

i 83-8211, Rockville, Maryland, 1983 i (Silver, 1987a)

E.G. Silver, " Status of Power-Reactor Projects Undergoing Licensing Review," Nuclear Safety, Volume 28, No. 4, October-December 1987, pp z 584-590 ]

(Silver, 1987b)

E.G. Silver, " Operating U.S. Power Reactors," Nuclear Safety, Volume 28, No. 4, October-December 1987, pp 552-558 l 1

~

(Smith, 1985)

" Analysis of Time Required to Evacuate Transient and Permanent Population from Vrrious Areas Within the Plume Exposure Pathway j Emergency Planning Zone: San Onofre Nuclear Generating Plant," Update J for 1985-1988, (Revision 2), Wilbur smith and Associates, May 15, 1987 (Smith, 1986)

Evacuation Time Assessment for Transient and Permanent Population from various Areas Within the Plume Exposure Pathway Emergency Planning Zone: Diablo Canyon Power Plant," (Update), Wilbur Smith and Associates, 1986 (So rensen , 19 8 8 ) q John H. Sorensen, Oak Ridge National Laboratory, Personal l Communication with Michael Black, February 19, 1988 (Sorensen et al,1987)

John H. Sorensen, Barbara M. Vogt, and Dennis S. Mileti, Energy Division Ev tion: An Assessment of Planning and Research, ORNL-6376,' 1987, pp 41-43 (Sorensen t, 1987)

John H. Sor and Barbara M. Vogt, " Emergency Planning for Nuclear Accidents: tentions and Issues," Presented at the symposium

" Nuclear Radiation and Public Health Practices and Policies in the Post-Chernobyl World," September 18-19, 1987 l (Stever, 1980) .

Donald W. Stever, Jr., Seabrook and the Nuclear Regulatory Commission:

The Licensing of a Nuclear Power Plant, University of New England, Hanover, aew Hampshire, 1980, espec. Chapter 3, " Siting and Public Risk," pp 40-79 (Stover et al,1987) .

C. W. Stover, B. G. Reagor, L. M. Highland, and S. T. Algermissen, E -

u j

_ - __ \ r 4 ,

r

" Seismicity .of the State of New Hampshire," U. S. Geological Survey, MAP 1261, Revised and reprinted 1987 (Sylves, 198411 Richard T. Sylves, " Nuclear Power Plants and Emergency Planning: An Intergovernmental Nightmare," Public Administration Review, (Sept /

Oct), 1984, pp 393-401 (UPI, 1974)

"U.S. Warned of Severe Quakes at New Hampshire Nuclear Site,"

Worcester Gazette, March 11, 1974 (Urbanik, 1981, Vol I)

T. Urbanik II, A.E. Desrosiers, An Analysis of Evacuation Time Estimates Around 52 Nuclear Power Plant Sites, Volume I, Nuclear Regulatory Commission, NUREG/CR-1856, May 1981 (Urbanik,1981, Vol II)

7. Urbanik II, P.L. Cummings, and A.E. Desrosiers, An Analysis of Evacuation Time Estinates Around 52 Nuclear Power Plant Sites, Volume II, US Nuclear Regulatory Commission, NUREG/CR-1856, July 1981 ,

(Vogt and Sorensen)

Barbara M. Vogt and John H. Sorensen, " Evacuation in Emergencies: An Annotated Guide to Research," Oak Ridge National Laboratory, ORNL/TM-lO277, February 1987 (Walter, 1974)

"Wiliam B. Walter, " Earthquake Dolly Fights N.H. Utility to Standstill," Boston' Sunday Globe, October 13, 1974, A-3 (World Nuclear, 1988)

"The World Nuclear Industry ilsudbook 1988," Supplement to the 1987 issue of " Nuclear Engineering International," Sutton, Surry, England, 1988 l i

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