ML20080Q020

Motion for Summary Disposition of Commonwealth of Ma Contentions I,Ii,Iii,Iv a & Iv.G,Seacoast Anti-Pollution League Contention 5 & New England Coalition on Nuclear Pollution Contentions 3,4,5,7,12 & 13

ML20080Q020
Person / Time
Site:	Seabrook
Issue date:	10/07/1983
From:	Shotwell J MASSACHUSETTS, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20080Q025	List: ML20080Q020 ML20080Q032
References
ISSUANCES-OL, NUDOCS 8310120147
Download: ML20080Q020 (46)

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T 8 DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

• 83 00T 11 A10 U2 BEFORE ADMINISTRATIVE JUDGES:

Helen F. Hoyt, Chairman GFFICI DF SEC:ETAin Dr. Emmeth A. Luebke $$f;kErW:cl Dr. Jerry Harbour

)

In the Matter of ) Docket Nos.

) 50-443-OL PUBLIC SERVICE COMPANY OF ) 50-444-OL NEW HMiPSEIRE, et al. )

(Seabrook Station, Units 1 and 2) ) October 7, 1983

)

MOTION OF ATTORNEY GENERAL BELLOTTI FOR

SUMMARY

DISPOSITION ON MASSACHUSETTS CONTENTIONS I. II, III, IV A., and IV. G.,

SAPL CONTENTION 5 and NECNP CONTENTIONS 3, 4, 5, 7, 12, and 13 RELATIVE TO EMERGENCY PLANNING FOR THE STATE OF NEW HAMPSHIRE Pursuant to 10 C.F.R. $2.749, Attorney General Francis X.

Bellotti hereby moves for summary disposition on the following con entions, each of which was either sponsored by the Attorney General or raises the same issue as a contention which he sponsored: Massachusetts Contentions I, II, III, IV A. and IV.

G, SAPL Contention 5, and NECNP Contentions 3, 4, 5, 7, 12 and

13. Each of these contentions challenges the omission from the New Eacpshire Radiological Emergency Response Plan ["RERP"] of one or more items clearly required by the Commission's regulations, which omission is clear on the f ace of the RERP.

8310120147 831007 PDR ADOCK 05000443 O PDR

, s There are, therefore, no material issues of fact remaining for litigation relative to these contentions and the RERP is, as a matter of law, inadequate. See Exhibit A, " Statement of Material Undisputed Facts."

Massachusetts Contention I This contention challenges the failure of the RERP to prcvide the necessary assessment of the State 's emergency response needs and resources and to provide the necessary de=ons: ration that resource requirements have been satisfied in the following areas: emergency transportation; medical treatment for contaminated injured individuals; radiological monitoring and assessment equipment; dosimeters and respiratory equipment for emergency workers; manpower for traf fic manage:ent and access control; manpower for emergency transportation; manpower for security operations; manpower for etergency maintenance of evacuation routes and response to abandoned vehicles and traf fic accidents ; and staf fing of e=ergency response f acilities. As we explained in detail in the bases provided for this contention at the time of its sub:ission (See Exhibit B hereto, incorporated herein by reference, pages 1-6), the Commission's emergency planning re gul ations require that state emergency plans demonstrate that critical ranpower and resource assessment has taken place and

all necessary resources assured. As we further explained in the bases to the contention, the RERP does not satisfy those Cornission regulations because it contains no analysis of the e=ergency response needs of the State, no inventory of its equipment, vehicles, or personnel, or assessment of its capacity to satisfy its resource requirements, either on its own or' through arrangements with other parties. See Exhibi t B, a 3-6. Nor does the RERP contain any letters of agreement or other evidence that potential private or outside sources of necessary equipment, vehicles, and personnel will, in fact, supply them and on a timely basis, as required by 10 C.F.R.

s30.47(b)(3). See Exhibit B, at 6. Thus, there is at present no basis for the requisite assurance that the State will have the necessary manpower and other resources to implement the RERP at the time of an emergency and summary disposition should be granted for Attorney General Eellotti on Massachusetts Contention I.

The following contentions filed by other parties raise the sare challenge to the failure of the RERP to assure adequate resources and should, therefore, be upheld on summary disposition as well: SAPL Contention 5, challenging the plan's failure to demonstrate that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability exists i

to fetermine the doses received by emergency personnel, as re quired by 10 C.F.R. t50.47(b)(ll) and NUREG-0654, Criterion

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~4-K.3; NECNP Contention 3, challenging the plan's failure to identify those areas in which the State requires federal assistance or to make arrangements for obtaining that assistance, as required by 10 C.F.R. $50.47(b)(3) and KU.:.E G-06 54, criterian II.C.l.b.; NECNP Contention 12, contesting the plan's failure to demonstrate that adequate equipment and personnel will be available to assess and monitor actual or potential of f-site consequences of a radiological esercency, as required by 10 C.F.R. $50.47(b)(9); and NECNP Contention 13, regarding the plan's failure to demonstrate that adequate arrangements have been made for medical services for contaninated injured individuals, as required by 10 C.F.R.

$ 50.47 (b) (12) . The bases for each of these contentions is .

ircorporated herein by reference.

Massa chuset ts Contention II As was discussed in the original bases for this contention, see Exhibit B, at 7, the Commission requires that state e=ergency plans establish an " emergency action level scheme" consistent with that established by the facility licensee. The l

( RER: contains no such emergency action levels at this time and, herefcre, fails on its face to comply with this requirement.

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Massachusetts Contention III This contention challenges the failure of the RERP to establish procedures for notification of emergency personnel by the response organizations in the state (III.A) or to demonstrate that provisions exist for prompt communications among principal response organizations to emergency personnel and to the public (III.B.), as required by 10 C.F.R.

{50.47(b)(5) and (6). See Exhibit B, at 8-10, incorporated herein by reference. The plan contains no provision whatsoever for notification of emergency personnel by response crganizations in the state and explicitly states that the required public notification system has not yet been designed, that there is insufti'ient communications ability with ambulances outside the EPZ, and that no center for receipt of communications and dispatch of ambulances has yet been e s tablished . Moreover, the plan acknowledges that most Emergency Broadcast Stations are not operational on a 24-hour basis, but makes no alternative provision for prompt instruction of the public. And the plan contains no plane for notification of local emergency response organizations. In these respects, therefore, the plan is facially deficient and sutmary disposition is in order.

In the bases to Contention III we further challenged the adequacy of the plan's provisions for communication between the licensee and state response organizations. That challenge is one which cannot be resolved by summary disposition, for the p an does contain some provisions for such communication and the Commission's regulations are not specific as to the precise requirements in this regard.

With the sole exception, then, of our challenge to the adequacy of the plan's provisions for communication between the licensee and the State encompassed by Section B of Contention III., we move for summary disposition on Massachusetts Contentions III.A. and B. Since NECNP Contentions 4 and 7 raise the same challenges to the plan's failure to provide for notification of emergency personnel and the public, we move for i st==ary disposition on them as well.

i Massachusetts Contention IV With this contention, Attorney General Bellotti challenges l the failure of the RERP to develop protective actions for i

e=ergency workers and the public. See Exhibit B, pages 10-23, incorporated herein by reference. While subsections C, D and E l

of the contention require interpretation of Commission regulations or simultaneous review of state and local plans and l

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1 I e are net, therefore, proper subjects for summary disposition at this tire,1/ subsections A and G challenge che omission from the RERP of items clearly required by the Comrission's regula ions to be included therein such that summary disposition is appropriate.

Contention IV.A challenges the failure of the RERP to establish evacuation routes, traf fic access and control points, and reception centers, as required by 10 C.F.R. 50.47(b)(10) and NUEEG-0654, Criterion II.J.10. See Exhibit B, at 11-13 and 15 for fuller discussion. Contention IV.G and the bases therefer (See Exhibit B, at 22-23) challenge, inter alia, the plan's failure to include provisions for the storage and distribution of radioprotective drugs to emergency workers and

.: redetermined conditions for their use by emergency workers, as required by 10 C.F.R. 50.47 (b) (11) and NUREG-0654, Criteria II.J.e. and f. These items, clearly required by Commission '

regula tions, are absent from the RERP and, therefore, summary judgmen; should be granted for Massachusetts on its Contention IV.A. and Contention IV.G. to the extent it relates to the absence of provisions for the storage, distribution, and use by energency workers of radioprotective drugs. Summary judgment 1 Subsections B and F were not admitted to the proceeding.

shculd likewise be granted on NECNP Contention 5, which cites the failure of the RERP to establish relocation centers.

Respectfully submitted, FRANCIS X. BELLOTTI ATTORNEY GENERAL '

By: - x,

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J p n Shotwell assistant Attorney General Environmental Protection Division Public Protection Bureau One Ashburton Place Boston, Massa chusetts 02108 (617) 727-2265 S

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EXHIBIT A STATEMENT OF MATERIAL UNDISPUTED FACTS

1. The New Hampshire Radiological Emergency Response Plan

["RERP"3 does not demonstrate that each phincipal response organization in the State has staff to respond and to augment its initial response on a continuous basis, that adequate emergency facilities and equipment to support the emergency response (including radiological monitoring equipment) have been provided, that adequate arrangements have been nade for medical services for contaminated injured individuals, or that arrangements have been made for requesting and effectively using assistance resources.

2. The RERP contains no initiating emergency action level conditions at this time.

3. The State of New Hampshire has not yet established an emergency action level scheme consistent with that established by the Applicants.

4. The RERP does not establish procedures for notification of emergency personnel by state response organizations.

5. The RERP does not establish means to provide early notification of an emergency to the public.

6. There is insufficient communications ability with ambulances outside the Emergency Planning Zone and no center for receipt of communications and dispatch of ambulances has been established.

7. The RERP does not establish means for 24-hour prompt instruction of the public.

E. The RERP does not establish procedures for notification of local emergency response organizations.

9. The RERP does not establish evacuation routes, traffic access or control points, or reception centers.

10. The RERP does not include provisions for the storage of radicprotective drugs or their distribution to emergency workers or predetermined conditions for their use by emergency workers.

. *101GXWXT M*

UNITED STATES OF A!1 ERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Admins trative Judges:

Helen F. Hoyt, Chairperson Emme th A . Luebke Jerry Harbour

)

In the Matter of ) Docke t Nos. 50-443-OL

) . 50-444-OL

)

FU3LIC SERVICE COMPANY OF )

NT4 EAMPSEIRE, e t al. )

(Seabrook S ta tion, Units 1 )

and 2) ) June 23, 1983

)

CONTENTIONS OF ATTORNEY GENERAL FRANCIS X. BELLOTTI RELATIVE TO EMERGENCY PLANNING FOR THE STATE OF NEW EAMPSHIRE CONTENTION I: The New Hampshire Radiological Emergency Eespo..se Plan does not sa tisfy the requirements of 10 C.F.R. 550.47 (b) (1) , (B), (9) or (12) because there has been no assessment of the State's emergency response needs and resources or satisfaction of its resource requirements in th e f:llowing areas: overall emergency transpor ta tion; transportation for special f acilities, schools, and people wi th special needs or without priva te transpor tation; emergency

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redical transportation; medica 1' treatment for contamina ted injured individuals; radiological monitoring and assessment equip =en t; dosimeters and respiratory equipment for emergency workers; and manpower for traffic management and access con tr ol, emergency transportation and security operations, emergency maintenance of evacuation routes and response to abandoned vehicles, traffic accidents, and o ther obs tructions to evacuating traffic flow, and staffing of emergency response f acilities. In the absence of an assessment and satisf action cf the S tate 's requirements in these areas , there can be no

" reasonable assurance that adequate protective measures can and will be taken" to protect persons present in the State of New Ea=pshire in the event of a radiological emergency at Seabrook S t'a tion , as required by 10 C.F.R. 550.4 7 (a ) (1) .

3ASES : .

! The Ocmmission's emergency planning regulations require state emergency response plans to demons trate that critical manpower l

and resource assessment has taken place and all necessary l

l resources assured. Specifically, the regulations require tha t "e ach principal response organization ha [ve) s taf f to responc i

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and :c augment i ts initial response on a continuous basis," 10 C.T.R. 5 50.4 7 (b) (1) , tha t "[aj dequa te emergency f acilities anc l

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equipment to support the emergency response are provideo and ma in tained , " 10 C.F.R. 550.47 (b) (8) , that " [ a] dequa te me thods ,

sys: ems, and equipment for assessing and monitoring actual or pctential offsite consequences of a radiological emergency rendition are in use ," 10 C.F.R. 550.4 7 (b) (9) , and that

"[a]rrangements are made for medical services for contaminated injured individuals," 10 C.F.R. 550.47 (b) (12) . None of these requirements has been satisfied in the draf t New Hampshire plan because there has been no analysis of the emergency response needs of the S tate, no inventory of its equipment and vehicles, 1

and no assessment of available personnel. There is, ther e f or e ,

no basis for assurance that the personnel, equipment, and transportation requirements of the State will be satisfied in an emergency.

Thus, while the draf t plan contains some discussion of the types of emergency equipment and vehicles needed in an ,

emergency and possible sources for them, it contains no assessment of the quantity of any given item of equipment or the numbers of vehicles or personnel needed to suppo: t an j emergency response. Nor does it contain any assessment of the capacity of the State to satisfy those resource requirements, either en its own or through arrangements with other governmental or priva te entities.

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Specifically, there has been no analysis of the State 's l

neafs or capabilities with respect to emergency transpor ta tion l l

for schools and other facilities, persons needing medical l i

assis tance, persons dependent on public transpor tation, and the ncn-E=bulatory population. The plan s ta tes , a t page 1.2-5, th a t "[W] hen buses are not needed to transport school children they say be used for mass tr anspor ta tion . " And yet, there has been no inventory of available bases and there is absolutely no basis for concluding that there will be a sufficient number to acccmmoda te the school children, let alone other persons in need of transportation.

S imilarly, there has been no analysis of the number of persons needed to staff the various emergency facilities and I perform the various emergency functions and no determination I

thar the necessary personnel will be available. This problem ,

is ce= plicated by the plan's provisions for removing local .

emergency workers from the emergency zone if releases of radienuclides other than I-131 are projected to occur in amoun ts tha t recuire protection. See New Hampshire l

I Radiological Emergency Response Plan [" Plan"), at 2.7-3. The plan provides no basis for assurance that there will be

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adequa:e personnel available to replace those local workers ,

! and en a timely basis .

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The draf t plan f or the S ta te of New Hampshire fur ther f ails to assess the hospital and medical services necessary to treat

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centa=inated injured individuals in the event c' an emergency cr to assure that those needs can be met. NUREG-0654, IIMA-EIP-1, Rev.1: " Criteria for Preparation and Evaluation of 7.adioicgical Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," (Nov., 1980), which is incorporated into the Commission's regulations at 10 C.F.R. 5 5 0.4 7 (b) , n.1, pr ovides , in Cri terion II .L.l. , tha t the S ta te nest " arrange for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake , including assurance that persons providing these services are adequately prepared to handle contaminated s

individuals." However, the draf t New Hampshire plan contains no letters of agreement with any medical f acilities or other evidence that the hospitals named in the . plan, at page 2.8-9,

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l have the capacity to handle contaminated individuals and to i

evaluate radiation exposure and uptake or tha t they have agreed i

o provide those services. Moreover, the plan contains no assessment of the numbers of persons who may require such services or assurance that those-numbers can be accomodated by these hospitals.

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The plan does grossly missta te the number of hospitals whien are identified therein, see 51an.at pages 2.5-8 -

2.5-9, I '

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6-and characterizes .two ' hospitals' l'ocated within the EFZ 'as two cf the three primary hospitals to be used in an emergen~cy. See

~ ?lz n , at' 2 4 5 -3. Particularly in light of these errors, ther e is need der 'a . thorough assessment of the extent of services which ray be Jneeded in an emergency and the capacity of the S ta te to . satisfy those needs.

Finally,, the. draf t plan contains no letters of.. agreement,

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as required by NUREG-0654, I tem II . C . 4 , er o ther evidence tha t the potential cutside sources cf necessary equipment, vehicles and persennel centioned in the plan will, in fact, supply them in an amergency. Thus, there is no assurance that necessary rescurces will be available in any of the categories of a

response activities which we have discussed if, those of the S ta te itself ar e inadequate.

CONTCION II: The New Hampshire Radiological Emergency .

F.esponse Flan does no t satisfy the requirements of 10 C.F.R. 5 5 3.4 7 (b) (4 ) because there is no emergency action level scheme dor. an energency a t the Seabrook S ta tion. In the absence of an adecuate emergency action level scheme there can be no

' reasonable assurance tha t adequate protective measures can and kill be taken" to protect persons present in the S tate of New Earpshire in the event of a radiological emergency at the 5eatrcck S ta tic n , as required by 10 C.F.R. 550.47 (a) (1) .

_7 3 ASIS:

The Commission's regulations, a t 10 C . F. R. S 50. 4 7 (b) (4 ) ,

require tha t there be in place a " standard emergency classification and action level scheme, the bases of which incicde facility sys tem and effluen t parame ters. " The criteria of NCEIG-0654 clarify tha t each s tate and local governmen tal body within the plume exposure pa thway IPZ "shall es tablisn an ere:gency classification and emergency action level scheme censistent with tha t es tablished by the f acility licensee. "

NCEIG-0654, suora, III.D.3. In this case, there is no l

energency action level scheme in place for Seabrook Station, either in the Applicants ' Radiological Emergency Plan or in the fr af e New Earpshire plan.- -

The New Hampshire plan coes use the term " emergency action levels" improperly in describing the four standard classes of e ergencies. See , e.c., Plan , a t 1.4 -1.

However, it is clear frca the absence of any material in Appendix A, en ti tled

" nitiating Emergency Action Level Conditions," tha t the S ta te recognizes the omission from this draf t of the facility system and effluent parameters which will trigger each emergency riassification. Withou t such specific parame ters, mu tually

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agreef upon by utility, s ta te , and local officials , there can

e ne assurance that emergencies will be properly classified Inf in a timely fashion so as to permit effective response.

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CONTENCION III:

The New Hampshire Radiological Emergency Response Plan does not satisfy the requirements of 10 C.F.R. 55 0.4 7 (b) (5) and (6) because procedures have not been established for notification of emergency personnel by the response organizations in the s tate and there is no demonstration that provisions exist for pronpt communications among principal response organizations, to emergency personnel, or to the public. Until these requirements have been satisfied there is no " reasonable assurance that adequate protective measures can and will be taken" to protect those present in the State of New Hampshire in :he event of a r adiological emergency at the Seabrook S tation, as required by 10 C.F.R. S50.47 (a) (1) .

EASIS:

Part 2 of the draf t New Hampshire emergency plan relating l to emergency no tifica tion and communica tions does no t es tablish pr ocedures for notification of emergency personnel by state l response organizations, as required by 10 C.F.R. 550.47 (b) (5) and NUREC-0 654, Cri teria II.E. 2, and II.F.1.e, and, ther e f or e ,

provides no demons tration that such notification could be e f f ec ted pr omptly, as requir ed by 10 C.F.R. 5 50.47 (b) (6 ) . As regards Civil Defense personnel, the plan simply contains a i

J conclusionary s tatement that "[a] t the ALERT level, NHCDA will

=cbili:e all of its staff." See Plan, at 2.1.4. And as regards all other emergency personnel, the plan simply provides th a t NECDA will notify the o ther response organirations. See Plan, at 2.1.5. The plan makes no provision whatsoever for "no:ification of emergency personnel by all [ response]

crganiza tions," as required by 10 C.F.R. S50.47 (b) (5) .

The draf t planning document before the Board further fails to demons tra te , as required by 10 C.F.R. 550.4 7 (b) (5 ) and NCRIC--0 6 5 4 , Criterion II .E.6 and App. 3, that the means have been established to provide' early notification and clear ins truction to the public in New Hampshire. In fact, the plan clearly demonstrates that no such means have yet been developed, for it specifically states (a t page 2.1-9 ) tha t the 1.udible Alert System for the Seabrook area is still being designed. And the plan acknowledges that most Emergency l Broadcas t System Stations are not operational on a 24-hour basis but makes no alternative provision for rapid instruction Of the public. See Plan, a t 2.1-11.

The draf t New Hampshire plan further f ails to demons trate th a: p cvisions exist f or prompt communication between the licensee and state response organizations, as required by 10 C.F.R. 5 50.4 7 (b) (6) . Under the draft plan, the licensee need

..c : notify the Sta te Police until fif teen minutes af ter an l l

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_10 emergency classification and there then has to be no tification of the DPE and verification by it before the other response organi:a tions will be contacted. Moreover, the NHCDA will no tify all other state response organizations sequentially.

See Plan, at 2.1 2.1-6.b/ And there are no definite plans for s tate notification of local emergency response Organizations. See Plan, at 1,2 1.2-6. These procedures fo not ensure prompt notification of anyone. The draf t plan further specifically acknowledges that there is insufficient cecrumications ability with ambulances outside the EPZ and that no center for receipt of communications and dispatch of ambulances has yet been established. See Plan, a t 2 . 2 14 .

CCNTENTION IV:

The New Hampshire Radiological Emergency Response Plan does not satisfy the requirements of 10 C.F.R. 55 0.47 (b) (10 ) and (11) because protective actions for emergency workers and the

! public have not been sufficiently developed. The protective Option of evacuation has not been sufficiently developed in th a: nc evacuation rou tes, traffic access or control points, or reception centers have been es tablished and the evacuation time 1/ Cnder the current plan it is only af ter NECCA notifies all 5ther emergency response organizations th a t it will activa te the siren alert sys tem f or the public. See Plan, at 1.3-5.

The delegation of all these responsibilities to NECLA unnecessarily delays public notification.

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_11 I es timates contained in the plan. are inaccurate and f ail to pr ovide informa tion needed by protective action decisien-makers. Furthermore, no plans have been made for evacuation of special institutions (including schools) or people with special needs or dependent on public transportation c .- for decontamination o'f all persons and vehicles exposed to radiation. The protective option of sheltering has not been sudficiently developed because no plans have been made for sheltering the summer beach population or those seasonal residents where homes provide inadequate shielding from radionuclides. The plan further provides insufficient basis f er protective action decision-making, and lacks adequate  ;

provisions for controlling the radiological exposure of emergency response personnel. Given these deficiencies in the plan, there is no " reasonable assurance that adequate l

protective measures can and will be taken" to protect tho se present in the State of New Hampshire in the event of a radiolcgical emergency at the Seabrook S ta tion, as required by

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10 C.F.R. 55 0.4 7 (a) (1) .

SA5IS:

The Commission's regulations require, a t 10 C . F . R .

5 5 3.4 7 (b) (10 ) , tha t "[a] range of protective actions [be]

l devel: ped for the plume exposure pathway IPZ for emergency wc kers and the public . " The criteria of NURIG-0654, at I

f II. .lC anf 12, incorporated into the Commission's regulations a

at 10 C.F.R. 5 50.4 7 (b) , n.1, clarify that this recuirement is

.o me: unless a state emergency plan includes the following items:

13. a. Maps showing evacuation routes, evacuation areas, preselected radiological sampling and monitoring points, relocation centers in host areas, and shelter areas. . .

d. Means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement;

e. Provisions for the use of radioprotective drugs, particularly for emergency workers and ins ti tu tionalired persons. . . , including quantities, s torage, and means of dis tribution; .

h. Reloca tion center s . . . ;

i. Con trol of access to evacua ted areas. . . ;

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1. Time es timates for evacuation of various sectors and dis tances based on a dynamic analysis (time -

motion s tudy under various conditions) for the plume exposure pathway emergency planning

ene . . .;

The bases for the choice of recommended

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protective actions from the plume exposure pathway during emergency conditions. This shall include expected local protection afforded in residential units or other shelter for direct and inhalation exposure.

LLsEG-0654, supra , Cri teria II .J.10 and 12.

None of these requirements is satisfied in the draf t New Hampshire plan. While the plan contains a map indicating th e 3:1.cipal roadways which will be utilized in an evacuation, see Plan, at 2.6-10, it does not contain an evacuation routing scheme. There is no evidence in the plan tha t there has been any consideration of the most efficient routing for various segnents of the population within the EP". And there has clearly been no assignment of routes. Particularly in view of the NEC S taff's de termination tha t the Applican ts ' evacua tion time es tima tes , incorporated into the New Hampshire plan, are "ep inistic" and based on assumptions as to preferred evacuation routing, see NUREG/CR-2903, "An Independent As sessment of Evacuation Time Es timates f or a Peak Popula tion Scenario in the Emergency Planning Zone of the Seabrook Nuclear

! P:ver S ta tion , " (October, 1982), at iv., 1, 20, definitive t

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evacuation routing is essential. In the absence of either fesigmated routing which conforms to that assuned by the Applicants in their evacuation time study or a new time study based cn cther designated routes, decision-makers will be using inaccurate time estimates in deciding whether an evacuation can he sumeessfully implemented.

The NP.C Staff has fur ther de termined tha t the Applicants '

evacuation time estimates, now incorporated into the New Ea=; shire plan, are lower than those prepared by an NRC contractor largely due to differences in the estimated effectiveness of traffic controls and that the Applicants '

estimates will be useful to protective action decision-makers enly if the emergency plans reflect the traf fic management assemptions developed by the Applicants. See Affidavit of John

?. . Sears attached to "NRC Staff Response to Applicants ' Sev en th

Contentien NE-21) and Twen ty-Firs t (Contentions NECNP III.12 and ICI.13) Motions for Summary Disposition," filed June 6, 1953, Pars. 11, 12. And ye t there are no traf fic managemen t plans in the New Hampshire submittal. As an NRC Staff member has a rtes ted, th e r ef or e , ther e is at present no basis for use cf the evacuation time es tima tes se t for th in the draf t New Ea:pshire plan a t the time of an emergency and protective a::icn f ecision-makers will be without information critical te

ne chcice be: ween evacuation and sheltering. And, as the f

Staff 's own expert has fur ther indicated, the time needed to complete an evacuation will be considerably greater than if effective traffic controls were in place. There is, ther e f or e ,

an unnecessary risk of radiological exposure to the evacuating population.

The draf t New Hamp. hire plan further f ails to develop the protective option of evacuation in that no traffic access points or reception centers have been es tablished. See Plan, at 2.6-13, 2.6-28. And the plan inappropriately provides that reception centers will not be activated until a General Emergency is declared, see Plan, at 1.3-5, providing no basis for confidence tha t the centers will be prepared to receive evacuees shortly thereaf ter.

We have already noted certain respects in which the evacuation time estimates contained in the New Hampshire plan are inaccurate and fail to provide emergency response officials i

wich critical information. Those estimates are further deficient in that they fail to do the following:

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l. Account for the time recuired for protective action decision-making , notifica tion of off-site agencies and the public, preparation and mobiliration,

! and confirmation of evacuation; l

2. Account f or simultaneous evacuation of the peak summer population on the beach areas lying frc= NE to l

SSE of the site, or even for simultaneous evacuation of Eampton Beach and either of Seabrook Beach or Salisbury State Beach.

3. Provide an estimate for evacuation of the entire plume exposure pathway EPZ, as recuired by NUREG-0654, App. 4, a t 4 -4.

4. Employ a reasonable estimate of the number of automobiles being evacuated;

5. Account for evacuation of schools, hospitals and o ther institutions located within the EPZ; j 6. Account f or the public transpor tation-dependent popula tion ;

7. Include major employers in the estimates of summer l

transient automobile demand; l

l l

l E. Account for voluntary evacuation beyond the EPZ;

9. Account properly for population growth over the .

life of the plant; l

10. Account properly for the effect on evacuation times of adverse wea ther conditions; 1

11. Account f or o ther than home-based evacuation tra f fic;

12. Account for any of the f ollowing possibilities:

a. vehicles breaking down or running our of fuel; l

l

b. traf fic acciden ts;

c. abandoned vehicles;

d. disregard of traffic control devices; and

e. evacuees using inbound traffic lanes for l

outbound travel.

The potential protective action of evacuation is also insufficiently developed in the draf t plan before the Board in that no plans have been set forth therein f or evacuation of special facilities, including schools, or for persons dependent en public transportation or with special needs. The plan si= ply contains conclusionary statements to the effect tha t

ansportation for those without cars will be provided by local emergency planners, that municipalities will have provisions f er evacuating the handicapped and others with special needs, hat school children will be bused directly to reception centers, and that "the State is prepared to provide emergency transportation to those communities tha t reques t it." See Plan, at 2.6-9. The plan contains no arrangements for carrying out any of :hese ma tters, no assessment of necessary resources, and no letters of agreement or other evidence tha t the necessary vehicles and personnel will be available. Fu r thermor e , th e plan contains no procedures for accommodating parental pick-up

f children at schools prior to evacua tion, clearly centemplating instead that all parents will agree to evacuate v - - - - - - -n -,- -, -e,,, -------.-w,,--rem ,e-,,,-,,-,,,,--n. -- - ,-, -,--

independently of their children, a factual premise which finds no support in the plan and which defies credulity.

Finally, as regards evacuation, the draf t plan is inadequace in that it allows evacuees exposed to radiation to evacuate directly to the homes of family members or friends without radiological monitoring or decontamination. It is only if exposures are estimated to have reached certain levels that all evacuees will be monitored. See Plan, at 2.7-9. Until those levels are reached, persons who do not evacuate to reception centers, and their families and friends, will centinue to be exposed to radiation. Once the specified levels are reached, evacuees will be directed to access control points, where vehicles will be'~ screened for possible decen tamina tio n. Since this ' deviation from traf fic routing and screening process may have a significant effect on evacuation

, times, the time es timates to be used by officials in ,

i l

l determining that an evacuation should be ordered must account for this contingency.

The protective option of sheltering has also been insufficiently developed in the draf t New Hampshire plan. The plan centains no provisions for sheltering of the summer beach pcpulation within the EPZ. While sugges ting that tr ansien ts ay "if possible" be asked to " seek directions to a nearby public building from local emergency werkers," see Plan, at 2.5-5, the plan makes no provisions for informing transients of I - _ _ _ _ - _ _ _

the need to seek directions or 'for assuring tha t emergency werkers will be present to give directions. And, more impo r tan tly, the State has conducted no analysis of available public sheltering or its capacity to accommodate the beach pcpulation. There is, therefore, insufficient basis for (and has not been) any development of sheltering as a potential protective action for the beach population.

The same is true for the summer resident population within th e I? Z . While acknowledging that "[t]he dose reducticn from which an individual benefits by sheltering is a function of how well the structure is sealed. . ." and the weight and layers of building naterial providing protection, the S ta te has no t analyred the amount of protection which can be afforded by the uninsulated, wood-frame summer homes in the Seabrook area.

There is, therefore, no basis for determining whe ther in-place sheltering of the summer resident population is a. viable option.

[

l The critical need for development of the protective action i

of sheltering in the vicinity of this site was confirmed by the Federal Emerge'ncy Management Agency in its report, FEMA-RIP-3, "Eynamic Evacua tion Analyses : Exposure Pa thway Emergency Planning Zones of Twelve Nuclear Power Stations," February, 1951. That report states, at page 7, tha t:

. . .if there is an accident with a relatively f as t release, the guidance suggests that the time from the initiatin's event through travel time to the 10-mile IP2 boundary may be as short as two hours. . . . Wi thin this two-hour time frame , [the Seabrook EPZ) can only be partially evacua ted. For an accident under these conditions, sheltering could be a viable protective ac tio n.

Although needed, then, in the event of a fast-developing accident, the protective action of sheltering is not yet a viable option for the transient and seasonal resident population in the Seabrook vicinity. This leaves a substantial percentage of the population supposedly being served by the New Hampshire plan completely devoid of protection in the event of a f as t-developing accident. /2' c

In addition to f ailing to develop the protective actions of evacuation and sheltering, the draf t New Hampshire plan fails to provide sufficient information to guide protective action choices. Thus, the plan indicates that

• predetermined dose 2/ According to the Applicants, there is an estimated summer Feak population of 84,366 within a five-mile radius of the s i te . See FSAR, App. C , Table 4.4. And the Licensing Appeal Board has determined that the beach area located just over 3

1-1/2 miles from the Seabrook Station is the nearest population center to the site , since it will "at times be the mos t densely pcpulated area in the s ta te . " See Public Service Company cf New Ea=pshire, ALA3-422, 6 NRC 3 3, at 51 (1977). The Board f urther s ta ted tha t "there is no doubt that, at peak periods ... in excess of 25,000 people will be found in that fensely populated area." Ibid.

reduction factors associated with small structures will be used in choosing between evacuation and sheltering. See Plan, at 2.6-4E - 52. And ye t, as we have noted, there are no plans to provide any shelter for the large transient beach population.

Th e assump tion th a t the entire target population will be sheltered in small s tructures is, ~therefore, inappropriate in the event of an accident during summer months. The plan provides no alternative basis for protective action decision-making during the summer. Nor is there any basis for application of the dose reduction f actor applicable to small, c year-round s uctures in connection with the seasonal 1

l residential population. The plan contains no evidence that the f actor being used is appropriate for that population and no l

alternative basis for protectiva action decision-making with respect to tha t popula tion. And there is insufficient basis for protective action decision-making throughout the year because no radiological monitoring locations have been s elec ted . See Plan, a t 2. 5 -15 .

The plan also f ails to provide any inf ormation or gu_ dance for emergency response officials as to the hazards of ordering evacuation in vehicles with closed windows and ventilation systems on a hot summer day. The plan indicates that any ordered eracuation will proceed under such instructions, see Plan, at 2.5-5, but fails to analyze the obvious po ten tial

effects on human health and orderly evacuation flow if those i instructions are carried out in intense heat or to provide guidance for consideration of those effects in assessing the merits of evacuation.

As we have no ted,10 C.F.R. 550.4 7 (b) (ll) and NUREG-0654, Criteria II.J.10.e and f. , fur ther require that means be established for controlling radiological exposures to emergency workers and, specifically, that s ta te plans include provisions for the use of radioprotective drugs by emergency workers and institutionalized persons, including provisions for the storage and distribution of such drugs. The draf t planning document before the Board provides that radioprotective drugs will not be s tored in the state, but will be obtained from the l neighboring states or from the federal government if the need arises, see Plan, a t 1.3-10, hopefully "early enough to allow sufficient time for [ the drugs] to be effectively used." See Plan, a t 2.7-3, 2.7-8. In the absence of plans for s tockpiling the drug in the Seabrook vicinity or specific plans for and assurance of rapid supply of the drugs by other state or

, federal officials, the drugs will not necessarily be on hand in 1

time for use by emergency workers. The current plan, th e r e f o r e , does not satisfy the Commission's requirements.

l The draft plan f urther f ails to neer the crirerion set i

fer h at N U ?.Z G - 0 6 5 4 , II.K.3.a., for ther e is no provision for

T "24-hour-per-day capability to . determine .the doses received by emergency workers...". As was discussed previously, there has been no assessment of the numbers of personnel who will be involved in emergency response activities. There can, therefore, be no assurance that a sufficient number of dosimeters is available. The same is true of respiratory devices. And the plan again inappropriately assumes a slow-developing accident when it provides for storage of the respitatory equipment at the S ta te IFO, rather than the local EOC's. See Plan, a t 2. 7-1.

CCNTENTION V: The FSAR, ER-OL, SIR, FIS , and New Hampshire Radiological Emergency Response Plan contain insufficient data as to the effectiveness of the protective actions of evacuation

and sheltering in mitigating adverse consecuences to human health (early fatalities, early injuries, delayed f atalities, delayed injuries, and' genetic and developmental defects) in the event of an accident at Seabrook Station recuiring off-site protective action.- Those filings contain no calculations as to the mean numbers of these specified health effects associated with PWR-1 to PWR-9 accidental releases or SST 1, SST 2, or SST 3 accidents at the Seabrook S tation. In the absence of such calculations, based en realistic evacuation time estimates and shielding f acters , reflecting the peak transient population

wi thin the IPZ , and accounting _ f or population growth over the lifetime of the plan t, there is no basis for assessing the effectiveness of evacuation or sheltering in minimizing radiological exposures. There is, therefore, no basis at this time for de termining tha t " adequate protective measures can and will be taken" to protect those present in New Hampshire at the time of an accident, as required by 10 C.F.R. 550.47 (a) (1) , or that the planned protective actions are " adequate" and " capable of being implemented," as required by 10 C.F.R. 550.47 (a) (2) .

BASIS:

The draft New Hampshire Radiological Imergency Response Plan s tates , a t page 2. 6-6, tha t the two protective actions which may be ordered in the event of a serious accident at the Seabrook Station are sheltering and evacuation. The plan defines "pr otec tive ac tions ," at page 1.7-5, as " emergency measures to be taken by the public to mitigate the consequences of an accident by minimi:ing the radiological exposures that would likely occur if such actions were not undertaken."

However, neither the draf t emergency plan nor the Applicants '

and NRC Staff's filings in this proceeding provide any basis f or concluding that evacuation or sheltering will, in fact, minimize radiological exposures to persons present in the State of New Eampshire in the event cf a severe accident at rhe Seabrook Starion, particularly in the summer months.

F l

1 1;one of the documents on file in this proceeding contain calculations as to the mean numbers of early fatalities, early injuries, latent cancer fatalities, and other adverse health efdects associated with the PWR-1 to pWR-9 accidental releases described in the Reactor Safety Study (WASE-1400) or with the Co= ission's "r ebaselined" SST 1, SST 2, and SST 3 accident scenarios (NUREG-0715). In the absence of such calculations, based en realistic evacuation time estimates and shielding f actors , there is no measure of the effectiveness of evacuation er sheltering as protective actions fo.- this site and no basis for the premise underlying the draf t plan that those actions can mini = ire radiological exposures to those present in the state at the time of such an accident. These calculations mus t be performed for a peak transient population scenario to ac= cunt for the tremendous seasonal population within the immediate vicinity of the site. See discussion, supra, at page l

20, and cust assume no sheltering for the beach population i

since there are at present no plans to shelter those persons.

And calculations must be performed so as to reflect expec ted

.erranent and transient population growth in the area over the expected life of the plant if there is to be any assurance th a t evacuation and sheltering will constitute viable protective actiens throughout the plant's term of operation.

i i

l l

o -

It has long been recognized that the beaches in the vicinity of the Seabrook site present unusual evacuation Oc ns train ts . From the beginning of the Seabrook cons truction permit proceedings, the NRC Staff has maintained that it has the authority to require a demons tration of the feasibility of evacuating persons beyond the Seabrook LPZ because of the proximity of the Station to coastal beaches, the inadequacy of sheltering f acilties along the coast, ar.5 the limited road ne twcrks serving the beaches. See Public Service Comoany of New Ean= shire, ALAB-390, 5 NRC 733, at 735-36 (1977). This position has been supported by the Advisory Committee on Reactor Safeguards. See Letter from the Chairman of the ACRS to the Chairman of the AEC reviewing Seabrook application (December 10, 1974) [ relevant language quoted at 5 NRC 751) .

While grossly inadequate for all the reasons discussed above, a: pages 13 - 17, the Applican ts ' own evacuation time es timates, now incorporated into the New Hampshire plan, also leave substantial doubt as to the feasibility of evacuation as a protective option for the area surrounding this site during the summer mon ths. Applicants es tima te tha t, on a summer weekend, it will take 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 20 minutes to evacuate a l

15 0-degr ee sector to the nor th of the plant having only a

v -m_le radius. See Applicants' Emergency Plan, Appendix C.,

Table 4. That sec:c: includes only one beach area, Hampton 1

1 I

Beach, and accounts for only 5,247 of the 9,177 estimated vehicles associated with that beach population. Id., Table 2.

The Applicants provide a similar estimate -- 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 30 minutes -- for evacuation of the ten-mile 90-degree nor theas t sector containinc. 3am.= ton Beach. _I d_. , Table 4.

Even without accounting for such f actors as simultaneous evacuation of more than one beach, notification / preparation time, and population growth, the n , the Applicants ' es tima tes exceed the time period during which early fatalities and injuries will result from exposure to radionuclides in the event of an "a tmospheric" Class 9 accident, according to NUREG-0396. See NURIG-0396, EPA 520/1-78-016: " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans In Support of Light Water Nuclear Power Plants" (December, 1978), Figures I - 17 and I - 18.

That document reveals that, assuming a uniform population density of 100 persons per scuare mile and evacuation speed of 10 m.p.h. , an evacuation time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> will result in approximately three deaths and twelve early injuries in the 0-5

' mile range of the plant and approximately five early in]uries in the 5-10 mile range. If evacuation time reaches five hours (with, for example, the addition of no tifica tion time) , the

res:1:s are approximately six deaths and twenty-eight early injuries in the 0-10 mile range.1/ Of course, NUREG-0396 nakes no attempt to estimate the long-term genetic or other health effects associated with such evacuation times.

Thus, even if evacuation can be accomplished within the tires currently estimated by the Applicants, there will be a significant number of early injuries and deaths in the event of an at=cspheric Class 9 accident at Seabrook. And, given the f eficiencies in the Applicants ' current evacuation time es tima te s , it is clear that actual evacuation times will be nuch lenger. It is important to note in this regard that the evacuation time estimates provided by the licensee in its PSAR are significantly higher than its current es timates, even though the earlier estimates relate to 22.5 degree sectors

a:her than 90 degree or 180 degree sectors) and cover only a five-=ile radius. See Seabrook PSAR, Amendment 23, July, 1974, i

l at 513 S13-16.4/ In its PSAR, the licensee estimates

{

l 3/ As we have noted, the population density in the beach area Esar the Seabrook site is much greater than the 100 persons per square mile assumed in NUREG-0396. As the Licensing Appeal 3 card has noted, "there is no doubt that, at peak periods . . .

I in excess of 25,000 people will be found in ( tha t) densely popula ted area. " Public Service Company of New Eameshire, ALA3-422, 6 NRC 33, at 51 (1977). Thus, all of tne nealth and fa ality figures contained in NURIG-0396 are understated so f ar as the Seabrook site is concerned.

i/ The earlier figures do purport to include notification time ,

i

. . tha t it will take eight hours f, rom the occurrence of the accident to clear three of the six beach sectors to the five-mile radius and tLat the other three sectors will require five and one-half to six hours. See Seabrook PSAR, at S13-16.

A FEMA study estimates that a minimum of six hours and 10 minutes will be needed to evacuate the en tire EPZ on a summer Sunday, even if notification is completed within 15 minutes.

See FEMA-REP-3: "The Dynamic Evacuation Analyses: Independent Assessment of Evacuation Times from the Plume Exposure Pathway Emergency Planning Zones of Twelve Nuclear Power Stations" (February, 1981), a t 46. That study further concludes that The behavior of drivers who are caught in congestion within direct sight of the Seabrook Station can only be guessed at this time. Any breakdown in orderly evacc~ation traffic flow will result in evacuation times greater than the ones .

estimated above. Total dvacuation times could 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 for an evacuation in which tr af fic control is generally ineffective.

Ibid. FEMA es tima te s', then, are also considerably higher than the Applican ts ' curren t estimates. The early deaths and injuries i

resulting from a severe accident would, of course, be significantly higher than the figures recited above if the longer times estimated by FEMA or by the Applicants in the 1974 amendment to their PSAR are actually required for evacuation.

O e Accident consequence data for the Seabrook site prepared by the NRC and released to the public by the Subcommittee on Oversight and Investigations of the Committee on Interior and Insular Affairs of the United States Congress, a copy of which is a ttached hereto as Exhibit A, appears to confirm that the health effects which will result from a severe accident at Seabrook are much greater than those set forth in NUREG-0396. Tha t da ta indicates that an "SSTI" release from Seabrook Station may result in 7,000 early fatalities, 27,000 early injuries, and 6,000 cancer de a th s . Whether those greater figures are a result of higher assumed evacuation times or, indeed, whe ther the calculations even assume evacuation or other protective action cannot be known in the absence of discovery.

As regards sheltering, the New Hampshire plan acknowledges that sheltering in the year-round homes in the Seabrook vicinity can provide protection for only two hours. See Plan, a t 2. 6-7.

And, as we have discussed, the protection afforded by the summer homes in the area is even less and there are at present no provisions whatsoever for sheltering the summer beach population.

Thus, while the filings in this proceeding provide no evidence of the extent to which evacuation or sheltering can minimize the adverse health consequences to those present in New Eampshire a t the time f a serious accident, they do contain ample evidence that neither evacuation nor sheltering can eliminate sucn adverse

31_

he alth effects. And both the documents filed with the Board and other caterials sugges t that a very significant number of f atalities and injuries may result from a severe accident, particularly one which occurs on a summer weekend, even given curren: plans for evacuation and sheltering. There must,

herefore, be a study of the consequences for human health of a severe accident at this site reflecting peak summer population es timates and realistic assumptions as to evacuation times and available sheltering. In the absence of such data, there is no evicence of the level of protection which can be afforded by ef f-site protective action in the vicinity of this site anc, th u s ,

no basis for the requisite de termination tha t the level of protection which can be provided is " adequate."

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CERTIFICATE OF SERVICE I, Jc Ann Shotwell, Esquire, counsel for Massachusetts Attorney General Francis X. Bellotti, hereby certify that on April 12, 1983, I made ser.-ice of the within Contentions, by mailing copies thereof, postage prepaid, to:

Eelen Hoyt, Chairperson

• Rep. Beverly Hollingworth A:cmic Safety and Licensing Coastal Chamber of Commerce Ecard Pane' 209 Winnacunne Road C.E. Nuclear Regulatory Commission Hampton, NE 03842 Washing:cn, DC 20555 Er. :-meth A. Luebke* William S. Jordan, III, Esquire A:ctic Safety and Licensing Diane Curran Board Panel Harmon & Weiss U.S. Nurlear Regulatory Commission 1725 I Street, N.W.

W:shing:en, DC 20555 Suite 506 Washington, DC 20006 Dr. Jerry Earbour* Edward L. Cross, Jr., Esquire Atcmic Safety and Licensing Assistant Attorney General Ecard Panel Dana Bisbee, Esquire U.S. Nuclear Regulatory Commission Assistant Attorney General

• 4ashington, DC 20555 Office of the Attorney General 208 State House Annex Concord, NE 03301 A:cmic Safety and Licensing Appeal Roy P. Lessy, Jr., Esquire

• Ecard Panel David A. Repka, Esquire

• U.S. Nuclear Regulatory Commission Robert G. Perlis, Esquire

• Wcshington, D C 20555 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 A:cmic 5adety and Licensing Robert A. Backus, Esquire l

Board Panel 116 Lowell Street

! U.S. Nurlear Regulatory Commission P.O. Box 516

Washing en, DC 20555 Manchester, NE 03105 1

Prilip Ahrens, Esquire Dr. Mauray Tye Assistan: A :crney General Sun Valley Association i Cepar:ren; of the Attorney 209 Summer Street General Haverhill, MA 01530

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avid R. Lewis

• Thomas G. Dignan, Jr., Esquire **

A::nic Safety and Licensing Robert K. Gad, III, Esquire **

Ecard Panel Ropes & Gray U.S. Su lear Regulatory Commission- 225 Franklin Street E=. E/W-439 Boston, MA 02110 Washing:cn, DC 20555 Mr . Jc hn E . Tanzer Ms. Olive L. Tash resignated Representative of Designated Representative of the Town of Hampton the Town of Erentwood 5 Merningside Drive R.F.D. 1, Dalton Road Ec p cn, SE 03842 Brentwood, NE 03833 Roberta C. Pevear -

Edward F. Meany resignated Representative of Designated Representative of the Town of Eampton Falls the Town of Rye Erinkwater Road 155 Washington Road.

Earp:en Falls, , NE 03844 Rye, NE 03870 Mrs. S andra Gavutis Calvin A. Canney Lesigna:ed Representative of City Manager the T:vn of Kensington City Hall RFD 1 126 Daniel Street Ins: F.ings:cn, NE 03827 Portsmouth, NE 03801 Patrick J. McKeon '

Jane Doughty Sele:tmen's Office Field Director 10 Central Road Seacoast Anti-Pollution League P.ye, N3 03870 5 Market Street Portsmouth, NE 03801 Richard I. Sullivan, Mayor Docketing and Service Section Town Hall Office of the Secretary Newb:rypert, MA 01950 U.S. Nuclear Regulatory Commissi'on

• Washington, DC 20555 Erian P. Cassidy Representative Nicholas J. Costel Regi:nal Counsel 1st Essex District '

FEMA Region 1 Whitehall Road J:hn W. McCormack Post Office Amesbury, MA 01913

& Cen:: house Bost:n, MA 02109

.AL . Angie Machiros, Chairman Diana P. Randall Newbury 5:ard of Selectmen 70 Collins Screet I:vn Of Ne-bury, MA 01950 Seabrook, NE 03874

• Sy Ixgr ess Mail

Sy Eand Lelivery

I oo=s Fn: rick C. McKacn Anne Vorgo, Chairperson Chairman cf Selectmen, Rye, Board of Selectmen New Ea:pshire Town Hall 10 Central Rcad _. South Hampton, NE 03842

?.ys, SE 03570 Ocnald E. Chick Maynard B. Pearson Tcwn Manager Board of Selectmen Town Of Exeter 40 Monroe Street 10 Tron: Stree: Amesbury, MA 01913 Now Earpshire 03E23 Solsc: en Of Scrth Eampton Mr. Daniel Girard Town of Scrth Ea:pton . Civil Defense Director Now Eanpsnire 03562 25 Washington Street Salisbury, MA 01930 Sonator Gorden J. Humphrey Senator Gordon J. Humphrey 1 Pillsbury Street U.S. Senate concord, NE 03302 Washington, D.C. 20510 (A::n: Eerb Scynton) (Attn: Tom Burack)

Signed under the pains and penalties of perjury, this 23rd day June, 1983.

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Jo Ann Shotwell l

Assistant Attorney General l Environmental Protection Divisi Public Protection Bureau Onc Ashburton Place Boston, MA 02108