ML20080S285

Contentions on State of Nh Evacuation Time Study.Certificate of Svc Encl

ML20080S285
Person / Time
Site:	Seabrook
Issue date:	10/13/1983
From:	Curran D, Jordan W HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8310180329
Download: ML20080S285 (10)

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GOCKETED USNRC October 13, 1983 53 NIT 17 Mi:I2 UNITED STATES OF AMERICA CFflCE OF SECP.CU "

NUCLEAR REGULATORY COMMISSION COChETWG & SE9VF.'.

BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

Public Service Company of New )

Hampshire, et al. ) Docket Nos.

) 50-443, -?44 (Seabrook Station, Units 1 and 2) )

)

NECNP CONTENTIONS ON NEW HAMPSHIRE EVACUATION TIME STUDY

1. The New Hampshire evacuation time estimates (ETEs) are inaccurate and overly optimistic in that they are based on an assumption that all persons inst-ructed to evacuate will evacuate.

Basis: Both local conditions and aspects of the emergency plans will result in family members being scattered in various areas. The f amilies will clog the evacuation routes and disrupt the evacuation by attempting to reunite before proceeding to evacuate.

There are many different activities in the recrea.tional areas, including stcying on the beach, swimming, arcades, shops, and the like. Families often split up to pursue their separate interests, agreeing to rendezvous later. Parents will not depart without gathering their families together.

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As reflected in the voorhees Report, parents can reasonably be expected to attempt to pick up their children from the schools, or to return to the EPZ from the relocation center when their children do not show up, although this would disrupt an orderly evacuation. Seabrook Station Evacuation Analysis, Technical Meuorandum #1, Summary of Local Meetings, prepared for FEMA by Alan M. Voorhees and Associates (August, 1980) at

10. This is especially true for the Seabrook EPZ, since the local plans provide for parents and children in school to proceed separately to evacuation centers. Parents may not learn whether their children are safe by going to their relocation centers, because their children may be assigned to other places. In addition, children from one family may attend different schools throughout the area, of ten with relocation centers different from those that their parents would be sent to. This may cause much confusion and pante.

2. The New Hampshire ETEs are inaccurate and overly optimistic in that they assume that public transportation will be available to those who need it. There is no assurance that those responsible for driving the various busses and other forms of mass transportation will actually do so, rather than first assuring the safety of their own families or leaving the area altogether.

Basis: The Voorhees Report indicates that local officials believe that " School bus drivers will refuse to enter or remain in the EPZ becaure of the radiation exposure danger." (at 10)

The plans contain no demonstration that school bus drivers have made commitments to remain in or return to the Emergency Planning Zone during a radiological emergency and transport students, rather than evacuate with their own families. In the absence of any such commitments, there can be no reasonable assurance that they actually will perform this function.

3. The New Hampshire ETns are incomplete in that they do not account for the effects of severe adverse weather conditions in the Seabrook EPZ, such as flooding.

Basis: According to Hampton Police Chief Robert Mark, flooding occurs at least twice a year, especially along the north shore of Hampton Beach. (Testimony of July 15, 1983, 4

Atomic Safety and Licensing Board hearings) Route 286 and Route lA were recently closed near Brown's Fish Market in Hampton due to flooding. Parts of Route 51 and Ocean Boulevard are also subject to flooding.

4. The New Hampshire ETEs are inaccurate and overly optimistic in that they do not adequately account for the crowds at the Seabrook dog track.

Basis: There may be as many as 100,000 people at an event at the Seabrook dog track at the same time as there is a large crowd at the beaches. The dog track crowd would hamper evacuation, particularly along Route 107, where it is often nearly impossible even to get out of a local driveway during heavy traffic.

5. The New Hampshire ETEs are inaccurate and overly optimistic in that they do not adequately account for road conditions impeding traffic flow or vulnerable to blockage.

Many of the evacuation routes are narrow and would be blocked by an accident or a stalled car, and those roads and the available traffic control personnel cannot handle both the traffic that will come from surrounding towns as well as the traffic generated by the town itself.

Basis: Where Ocean Boulevard joins Route 51, Route 51 is very narrow for several blocks. Route 286 is a two lane road where the shoulder is commonly used by traffic during busy periods. Since there is no place for a car to go if there is an accident or breakdown, it would clog either the shoulder or the roadway. The road also suffers from two serious bottlenecks at bridges where two or three lanes funnel into one. Police traffic control is necessary at the intersection

-of Routes 286 and 1A, along the shoulder of Route 286, and at the intersection of Route 286 and Washington Street. In Exeter, Route 101 is extremely narrow for about 10 miles and

.could become extremely congested in an evacuation. These are only a few examples of serious physical impediments to evacuation which are not discussed or evaluated in the local plans. The congested condition of these roads may not only generally impede evacuation, but may prevent effective removal of-accidents or stalled vehicles. For example, on a Sunday af ternoon in July of -1983, it took a Hampton Beach wrecking

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company 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to reach a disabled car a mile away from the gas station, and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to return with it to the gas station.

Finally, the Voorhees Report indicates that local officials believe that local roads and traffic personnel cannot handle the volume of traffic that may come from other towns in the event of an emergency (at 11) .

6. The New Hampshire ET3s are inaccurate and overly optimistic in that they do not account for blockage of evacuation routes caused by vehicles running out of gas.

Basis: Gasoline supplies and availability are limited such that many of the vehicles that run low can be expected to run out, thereby clogging the narrow evacuation routes and hindering the evacuation. There are only three gas stations in Hampton Beach, which are often out of gas, and Route 51, a major evacuation route, does not have any gas stations on it all the way to Route 95.

7. The New Hampshire ETEs are inaccurate and overly optimistic in that they assume that traffic rules and controls will be obeyed.

, Basis: Poor driver behavior under crowded traffic i

conditions is common in the Seabrook area. The Hampton Fire Chief has observed people trying to make four lanes out of two-lane roads when the traffic gets bad, thus making the roads impassable for emergency traffic. He has also observed drivers f who disregard traffic barriers; and especially in the evenings, I

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6-i drunk and rowdy drivers who are likely to cause more traffic accidents and are less apt to follow directions.

Driving behavior deteriorates in the panic caused by an emergency situation. The Hampton Chief of Police has observed that " people can become very emotional during an evacuation, compounding the problem of moving them out." (Testimony of Chief Robert Murk, July 15, 1983, Atomic Safety and Licensing Board hearings) During one evacuation, a person from outside the evacuation zone tried to break through a road barrier in order to rescue his mother after being turned away several times by police. H.

The problem of poor driver behavior will be particularly serious at Seabrook since many of the ' drivers are likely to be from the Boston area, which is notorious for such poor and

selfish driving habits. The presence of only a few such i

drivers would seriously hamper an evacuation by disrupting traffic controls and increasing the likelihood of automobile accidents.

8 The New Hampshire ETEs are inaccurate and overly optimistic in that they assume that major traffic control points will be manned.

Basis: The New Hampshire ETEs do not accours: for failure

! of emergency response personnel to occupy traffic control positions, or delays in arriving at traffic control positions.

.According to the Voorhees Report, local officials believe that *

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some, if not all, police and fire officers will evacuate their families rather than report to their posts. (at 10)

Because many police and fire officers work part time and/or live outside the EP , it may be impossible to contact them about an emergency; and if they are contacted, it may take some time before they can reach their positions. In Kensington, for example, the Chief of Police works part time and lives two towns away, a fifteen minute drive under normal conditions.

More important, he is a full time police officer--one of only three sworn officers--for the town of Stratham, and may have to serve in Stratham when an accident happens. In South Hampton, the Chief of Police lives in East Kingston and works a full shift in Plaistow,' which is 1/2 hour away. Of the remaining officers, one is a selectman who will have other duties in an emergency, the others work in locations from fifteen minutes away to as far as Boston, more than an hour. And Boston is too far away for contact by use of a tone pager. In Hampton, 16 out of 36 permanent fire department employees and 5 out of 20 on-call fire department employees live outside of Hampton. A number of these employees have told the Fire Chief that they would be reluctant to return to Hampton during a radiological emergency. For those who did return, the time necessary to return to Hampton could significantly delay the emergency response.

The lapse of time between the start of an evacuation and the occupation of traffic control positions could also be

exacerbated by an early evacuation. If the public is notified of an emergency at the plant--either through radio announcements, or monitoring of police radios--it is likely to begin evacuation before an evacuation is actually ordered. The clogging of the roadways during a premature evacuation would also hamper the ability of emergency response personnel to reach traffic control positions.

Respectfully submitted, Diane Curran

/k William dan III HARMON & WEISS 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006 October 13, 1983 (202) 833-9070

CERTIFICATE OF SERVICE I certify that on October 13, 1983, copies of NECNP CONTENTIONS ON NEW HAMPSHIRE EVACUATION T1AE STUDY were served on the following by first-class mail or as otnerwise indicated:

• Helen Hoyt, Esq., Chairperson Rep. Roberta C. Pevear Atomic Saftey and Licensing Board Drinkwater Rcad Panel Hampton Falls, NH 03844 U.S. Nuclear Regulatory Commission Washington, DC 20555

• Dr. Emmeth A. Luebke Phillip Ahrens, Esq.

Administrative Judge Assistant Attorney General Atomic Saftey and Licensing Board State House, Station #6 U.S. Nuclear Regulatory Commission Augusta, ME 04333 Washington, DC 20555

• Dr. Jerry Harbour Robert A. Backus, Esq.

Administrative Judge 111 Lowell Street Atomic Saftey and Licensing Board Manchester, NH 03105 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Board ** Thomas G. Dignan, Esq.

Panel R. K. Gad, III, Esq.

U.S. Nuclear Regulatory Commission Ropes and Gray Washington, DC 20555 225 Franklin Street Boston, MA 02110 Atomic Safety and Licensing Appeal Dr. Mauray Tye, President Board Panel Sun Valley Asociation U.S. Nuclear Regulatory Commission 209 Summer Street Washington, DC 20555 Haverhill, MA 01830 Docketing and Service *Roy P. Lessy, Jr. Esq.

U.S. Nuclear Regulatory Commission William F. Patterson Washington, DC 20555 Office of the Executive Legal Director Town Manager's Office U.S. Nuclear Regulatory Town Hall - Friend St. Commission Amesbary, MA 01913 Washington, DC 20555 Mr. Angie Machiros Anne Verge, Chair Chairman Board of Selectman Board of Selectmen Town Hall Town of Newbury South Hampton, NH 03842

Jo Ann Shotwell, Esq. George Dana Bisbee, Esq.

Assistant Attorney Ceneral Edward L. Cross, Jr., Esq.

Department of the Attorney Asst. Atty. Generals General State House Annex 1 Ashburton Place, 19th ,?loor Concord, NH 03301 Boston, xA 02108 John B. Tanzer Letty Hett, Selectman Town of Hampton Town of Brentwood 5 Morningside Drive RFD Dalton Road Hampton, NH 03842 Brentwood, NH 03833 Edward F. Meany Sandra Gavutis Town of Rye Town of Kensington 155 Washington Road RFD 1 Rye, NH 03870 East Kensington, NH 03827

• David R. Lewis, Esq. Diana P. Sidebotham Atomic Safety and Licensing Board R.F.D.2 U.S. Nuclear Regulatory Commission Putney, VT 05346 Washington, DC 20555 Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager Newburyport, MA 01950 10 Front Street Exeter, NH. 03833 Alfred V. Sargent, Chairman Brian P. Cassidy, Esq.

Board of Selectmen FEMA Region I Town of Salisbury, MA. 01950 J.W. McCormack Post Office and Courthouse Boston, MA. 02109 Diana P. Randall 70 Collins Street Seabrook, NH. 03874 Senator Gordon J. Humphrey Senator Gordon J. Humphrey U.S. Senate 1 Pillsbury Street Washington, D.C. 20510 Concord, NH 03301 (Attn: Tom Burack) (Attn: Herb Boynton)

Selectmen of Northampton Calvin A. Canney Town of Northampton City Manager New Hampshire 03862 City Hall 126 Daniel Street Portsmouth, NH 03801

'.1, .

Diane Curran

• BY Hand

• • Federal Express

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