ML20151B349

Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning

ML20151B349
Person / Time
Site:	Seabrook
Issue date:	03/03/1987
From:	Coffey P AFFILIATION NOT ASSIGNED
To:	NRC
References
FRN-52FR6980, RULE-PR-50 52FR6980-00177, 52FR6980-177, NUDOCS 8807200331
Download: ML20151B349 (2)

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Nuclear Regulatory Commissioq; Jr . .

1717 H Street, N.W. [f'gTp '

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Washington, D.C. 20555

Dear Sirs:

This letter is to register my firm opposition to the proposed rule changes which would either-limit tha role of individual states to review and/or approve the evacuation plans for any nuclear power plant or that would reduce the size of the present ten mile evacuation zone.

My opposition is based on the facts that the present road network in'and around the Seabrook, N.R. power plant is presently unable to handle the routine summer. traffic that is experienced almost daily. Evacuation planning for this area actually-routes traffic toward the nuclear power plant in order

'to access state and interstate evacuation routes. peripheral roads are narrow two lane roadways unsuitable for handling present peak traffic loads, let alone an evacuation.

In addition, local police, fire and ambulance services are small in nature and without sufficient manpower ot vehicles to effectively route an evacuation or to evacuate those without transportation. Response of stata police, mutual ald-units and civil defense units in sufficient numbers to be of direct assistance would take heurs.

We New Eng?.anders look forward to our cooling offshore scabreezes each suramer and dread our -inf amous nor' easters each f all and winter. Reduction of

-the ten mile ev- ua'. ion zone. ignores the local weather patterns which would direct any radiactive release inland during our frequent east to west coastal breezes.

Evan a gentle breeze of ten miles per hour would mean that TOTAL evacuation of.the present ten mile zone would need to occur within'60 minutes, in order to avoid contact with any contaminants. This is predicated on immediate detection of every leak, immediate activation of the evacuation alarms ~and immediate evacuation by the populace. Any delay at any step would reduce the 60 minute ' safe' evacuation time.

A reduced evacuation zone or even an offshore storm would endanger the safety of the citizens around seabrook and turn the evacuation planning into an exercise of the absurd.

The combination of a poor road network, local weather and geographical conditions, the influx of a large summer population, limited local resources to deal with an emergency situation and a woeful lack of emergency preparedness beyond the planning stage makes the situation surrounding Seabrook ripe for our nations first nuclear catastrophe.

0 l0 l 8807200331 070303 PDR PR 50 S2FR6980 PDR

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Js 1 I invite you and the members of the U.R.C. and staff t'o drive along Route 1 or lA on a summer weekend in the vicinity of seabrook. Massachusetts officials have researched the possibility of evacuating the communities within the ten mile zone and found it to be unrealistic. Response of sufficient personnel and vehicles to route fleeing traffic, evacuate those without transportation, remove the-patients in nursing homes and hospitals and the elderly in housing developments would take several hours to initiate, let alone begin the actual evacuation.

The mistaken idea that officials at Seabrook could develop a plan that would even remotely deal with reality, let alone be the basis for a working evacuation would turn over responsibility for the protection of the citizens of Massachusetts to the very people who have already demonstrated their inability to comply.with existing safety regulations. The readily apparent ,

conflict of interest here should alarm you and your staff and encourage a rethinking of the role of the N.R.C. and its responsibility for the safety of nuclear power plants.

No plan wi21 work or even begin te 'e a basis for an exercise unless:

a, the plan is published an/. distributed in full to all state and local agencies involved in carrying out the plan. A series of tabletop exercises must follow to iron out the problems encountered until the most likely scenarios have all been practiced.

b, the plan .ust then be distributed taa the chief of ficers, managers, directors and supervisors in each agency and practiced within each agency until its role and responsibilities are clearly understood,

c. tha plan must then be distributed to every member of every agency involved so that they undserstand what is expected of them, who is available to assist and where the necessary equipnent will oe before they are needed.

! Experiences gained by the fire and emergency medical services organizations in this country ahow that pre-planning and practice are vital to I

the successful management of large scale incidents. Mere planning is NOT i suf ficient to assure the safety of the public.

l l No federal Or private agency or company can crew up workable plans for any l local mass casuOlty, disaster or evacuation situation. Only local and state officials have enough information to decide what can and cannot be done.

l l Massachusetts officials have determined that evacuation is not feasible and to consider reducing the evacuation zone to make it feasible is tantamount to criminal negligence in light of what happened at Chernobyl.

I urge you to leave the present rules intact and to consider strengthening the role of 6.he state goverments in assuring the safety of their citizens.

Yours Truly, h (j, ..

paul H. Coffey, cc: President Ronald Reagan Senator Edward Kennedy Senator John Kerry Governor Michael Dukakis

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