ML20136J470

Responds to Encl 851229 Ltr Re Emergency Planning Issues at Plant.Ltr Submitted to Staff for Comment.Served on 860109

ML20136J470
Person / Time
Site:	Seabrook
Issue date:	01/09/1986
From:	Asselstine J NRC COMMISSION (OCM)
To:	Moyer H AFFILIATION NOT ASSIGNED
References
CON-#186-704 OL, NUDOCS 8601130391
Download: ML20136J470 (4)

Text

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/ 'o UNITED STATES y o NUCLEAR REGULATORY COMMISSION y i WASHINGTON, D.C. 20SSS }] .  ; ,,

1 January 9, 1985

• • • • • ,/

OFFICE OF THE Ji1N -9 p ; 4; COMMISSIONER h"  ;, ,

,d.iAlpy

• f1r. Herbert S. Moyer d 51 Westside Drive Y,

$7 Exeter, NH 03833 6D - t/C/3 CC - ,

Dear Mr. Moyer:

88 Thank you for your December 29, 1985 letter concerning emergency plan-ning issues at Seabrook. As a Commissioner, I will have to eventually pass judgment on whether Seabrook should be licensed to operate.

Included in that ultimate juJgment will be decisions on many of the emergency planning issues you raise in your letter. It would be improper for me to comment on your questions at this time. However, I have asked the NRC staff to respond to your questions. I have also had your letter served on all the parties to the Seabrook proceeding.

Thank you for your interest in this important matter.

Sincerely, j- -, , ,f . g

[ James K. Asselstine cc: Seabrook Service List ,

,c gy;esce Tsox

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--F.. *'y '51 W2stsids Drive 9 Exeter, New Hampshire 03833 i Dace bsr 29, 1985 NRC' Commissioner, James Asselstine thS.' Nuclear + Regulatory Commi ssion

-Washington, D.C. 20555 ,

Dear Commissioner Asselstine,

l'have decidedito write you only after considerable thought and many other avenues of. inquiry that have resulted in dead ends.

g I am a high- school instructor of science, not a local public of ficial or a

- pceson of any official status in local or state government.The reason I am

- wri ting you is to see if some level of government will be responsive to the questions I have raised, as an affected citizen, concerning Emergency Response p Planning.

. As you are no doubt well aware, The New Hampshire State Civil Defense Agency and consultants, in cooperation with affected-local units of government, ,

are currently developing Emergency Response Plans (ERP's) designed to provide

. reasonable assurance of protection of the public's health and safety in the-event of a radiological accident at Seabrook Station. I have been following the dsvelopment of-such plans since the introducton of the 10 mile EPZ'in 1980. I have c.ised what I thought were seriously considered questions of the ccnsultants, State Civil Defense and F.E.M.A.. F . E .M . A . , in the person of Mr.

Ed Thomas,~has never responded to my inquiries.... and the answers given by the consultants and State Civil Defense are so evasive and lacking in substance as tn be meaningless. More'recent developments have increased my sense of J uneasiness with this entire process.

Consultants hired by State Civil Defense have been meeting with local officials of :the town (Selectmen) and with School Boards in an effort to solicit

.their support-for the adequacy of existing town plans, which are in their fourth cr fifth draft form. Statements made by consultants and comments from Civil Defense officials themselves seem to be calculated attempts to discolor the

realities associated'with various aspects of the planning process and accident scenarios..-Following are several examples which are verifiable because the public. meetings at which these comments were made were taped.

Before the Hampton School Board, consultants said... In referring to the cost serious Emergency Action Level described in NUREG 0654...(and I'm paraphrasing) 'A General Emergency is a condition where a release of radiation is possible but would not go'beyond the boundaries of the plant'. At the same teeting -they said that the emergency response actions taken at Three-Mile-Island (including evacuation) went very smoothly and that there was no panic, as everyone who was supposed to did their job well.

Speaking before the Exeter School Board a week or so later (earlier this

, December), consultants said that at T.M.I. no radiation was released beyond that '

. plant's boundaries. They also have repeatedly told public officials that,'should an accident' occur, the public would have between 12-34 hours advance-notice before any radiation was released of fsite. State Civil Defense has based these ,

conclusions on'the Probabilistic Risk Assessment done for Public Service Co.of l How Hampshire'by Pickard, Garrick and Lowe... and on the verification of accuracy made by a New Hampshire legislative committee appointed by Governor

Sununu. Civil Defense has also' stated at public meetings and in their correspondence that Letters'of Agreement exist between their agency and bus

companies who would provide emergency transportation. ,

l

H:vitg cpoken to the own;r cf one cf th o bus comptnien listed in Hampton's town plcn, I know that na cuch Lottcr cf Agreem;nt was olh:r cxpressly given or implied to Civil Defense by that company. That particular owner has also stated that in his opinion (because many of his drivers are part-time women who have small children of their own) should an order to evacuate be given... he would not expect a large percentage of his drivers to provide the emergency transportation that Civil Defense is counting on.

It is clear to me (and this is my opinion after having carefully followed this process for the past 5 years) that Civil Defense has no intention of addressing the hard questions raised by this planning process. Rather, they are trying to get a community's participation in the planning process accepted as cuidence for a determination of the adequacy of the town's plans.

It seems there-is a great gap between the intent of Congress by establishing the process of: Emergency Response Planning and the realities associated with the execution of that function. I cealize that you are in a difficult position on this issue,but it would be helpful to me and other affected citizens if you could answer the fo11a4ing questior.s

1. Has the NRC accepted as final and accurate Public Service Co.'s Probabilistic Risk Assessment ?

2. Is it reasonable to assume that the public would have that degree of advance warning time listed in the study rather than the 1/2 to several hour advance notification referred to in NUREG 0654 ?

3. Would the enclosed " Letter of Agreement" be viewed by the NRC as evidence of the emergency response commitment required by bus companies in the event of a call to evacuate ?

4. Is it appropriate to place significant credibility i n the stamp of epproval which a New Hampshire legislative committee gave to Public Service Co.'s Probabilistic Risk Assessment ?

5. Is it possible that a community's participation i n the planning process may be interpreted by F.E.M.A. or by the NRC as evidence of acceptance cf the plan's adequacy by the town ?

If you cannot answer these inquiries as presented by me, would you answer them if presented by a town or a school official ? If the answer to that question is

~

no, will you please direct me to the branch of your agency which will respond to these inquiries. You are seen as a voice of reason on the NRC Commisson.

I appreciate the time you have taken from your very busy schedule to read the concerns I have raised.

Sincerely, j elf ^, . V

/

Herbert S. Moyer '

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f yt gr- bp. SURVEY TO PROVICE EERGDCY TRANSPCRTATIOr4 ASSISTAtCE TO THE STATE OF NEW HA WSHIRE Are -ycu.willing to provide transpcrtation assistance in the event of an energency? .YES NO

- 1.~ Name and address of. transportation Corpany

2. Contact perscn/ alternate with telephone number, business /24 hour.

3. Nts.ber of buses / vans operated.

_ 4 '. Number of buses / vans available for emergency response.

5. Passenger capacities.

6. Locations at which buses / vans are garaged.

'7 Number of drivers available for buses / vans.

8. Time required before buses / vans with drivers can be dispatched.

9. Two-way communications capability of cuses/ vans. If yes, what frequency?

10. Comments or constraints on/to use of buses / vans. (Use reverse side if needed)

11. What is your daily rate when leasing tuses?

Signed Date I1

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