ML20214C950

Suppl to Memorandum on 10CFR2.714(a)(1) & Contentions to Rev 2 to State of Nh Radiological Emergency Response Plan. Intervenor Intends to Introduce Expert Testimony Re Computer Modeling & Traffic Simulation.W/Certificate of Svc

ML20214C950
Person / Time
Site:	Seabrook
Issue date:	11/19/1986
From:	Brock M, Mceachern P HAMPTON, NH, SHAINES & MCEACHERN
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20214C935	List: ML20214C934 ML20214C950
References
OL, NUDOCS 8611210297
Download: ML20214C950 (9)

Text

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I l UNITED STATES OF AMERICA DOLKETED NUCLEAR REGULATORY COMMISSION USHRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'86 NOV 20 All :33 In the matter of

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PUBLIC SERVICE COMPANY OF Docket No. 50-443 OL $7-NEW HAMPSHIRE, et al 50-444 OL I

Seabrook Station, Units 1 and 2 -

TOWN OF HAMPTON SUPPLEMENT TO MEMORANDUM ON 10 CPR I S 2.~114 (a) (1) AND CONTENTIONS'OF THE TOWN OF HAMPTON TO NEW HAMPSHTRE ,

RADIOLOGICAL EMERGENCY RESPONSE PLAN REVISION 2 I. The Town of Hampton hereby supplements its memorandum on 10 CFR S2.714 (a) (1) as follows: ,

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Extent to Which Petitioners Can Contribute to Dev'elopment of a Sound Record The Town of Hampton intends to introduce expert testimony from Robert T. Teischer, Vice President Development, CIM-Telligence, and Thomas J. Adler, President, Resource Systems Group. These individuals have extensive experience in computer modeling and/or traffic simulation, and will be used principally to critique th,o KLD ETE.

Following receipt of discovery, the Town anticipates these individuals may provide further testimony on issues such as the inadequacy of equipment and personnel as provided in the NHRERP, to effectuate an evacuation under the actual and anticipated conditions.

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8611210297 861119 PDR ADOCK 05000443 G PDR SHAINES. M ADRIGAN & McEACHERN PeortssoNAL AssociateN 25 Mart.fWOOD Avthur P O son 360 PonT5MOUTM NH 03ecn

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• l II. The Town of Hampton hereby supplements its Contentions on  !

NHRERP Revision 2, dated October 31, 1986, as follows:1 Revised contention III to Revision 2 (C)7. KLD has failed to provide reasonably adequate information to permit a proper review and critique of its BTE. Upon receipt of discovery, the Town of Hampton anticipates that additional _

unreasonable assumptions, unsupported data, and other flaws and defects in the KLD ETE will become apparent including:

a. KLD apparently fails to account for an increase in ETE due to the time required for traffic'and access control point managers to question each vehicle driver and determine the appropriate evacuation route and host community for that vehicle.

b. KLD apparently adopts the patently false assumption f that a traffic light will remain green 100 percent of the time l

for each line of traffic at an intersection. KLD thereby unrealistically reduces ETE. ,

c. KLD apparently fails to include the " light" traffic on many roads in its simulation model.

d. KLD apparently and unreasonably assumes a substantial amount of passing by evacuating traffic to avoid disabled 1 The Town of Hampton hereby incorporates its previously filed Memorandum on 10 CFR 2.714(a) (1) as justification for this " late filed" supplement.

2 SHAINES M ADRIG AN & McEACHERN PeortssioNAL Assocl* Tion 25 uartrwooo avthur Po som seo Po#T5 MOUTH NM 03801

vehicles. Such passing may be rendered impossible due to vehicle breakdown or disability on many of the narrow EPZ roads,

e. KLD apparently has failed to increase ETE for the reasonably anticipated number of people who would choose not to evacuate promptly, or otherwise comply with the NHRERP.

f. KLD apparently and unreasonably assumes that all accidents will be at low speeds. Since KLD has adopted a speed for incoming emergency buses of:40 to 50 miles per. hour, KLD's low speed accident assumption is unsupportable. KLD apparently wants it both ways, i.e. increased speed of emergency vehicles into the EPZ, without consideration of the increased potential for high speed accidents as a result of the faster moving buses.

g. KLD apparently has failed to conduct adequate .

sensitivity tests on its ETE, including tests to determine the effect on the ETE of major road blockages caused by accident, snow or traffic jam.

h. The adequacy of the simulation model cannot be further critiqued without additional information from KLD.

Revised Contention IV to Revision 2 i

(B) Emergency Exercise, is hereby amended as follows:

The failure of the emergency exercise to include an integrated and coordinated evacuation with Massachusetts EPZ communities necessarily renders that exercice deficient. Absent such a coordinated exercise, no showing can be made that reasonable l

3 SHAINES. M ADRIGAN & McEACHERN - Poortssionat association

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Y protection may actually be available to the EPZ population, including the Town of Hampton, in the event of evacuation.

Dated: November 19, 1986 Respectfully submitted, SHAINES & McEACHERN Attorney r the Town of Hampton By. 6- /

Paul'Mcfacffern By N Matthew T. Brock l

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SH AINES M ADRIGAN & McEACHERN - PoortssoNat association 29 wartfwoOD avf Nut P O BOu MO . PORTSMOUTH NM Ole

I UNITED STATES OF AMERICA  %"' '[r" "

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of gFf 0 jUi", . -

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PUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL NEW HAMPSHIRE, et al. 50-444 OL c (Seabrook Station, Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that copies of TOWN OF HAMPTON RESPONSE TO BOARD ORDER OF NOVEMBER 4, 1986 AND MOTION TO DEFER HEARING SHEDULE AND ALTERNATIVE PROPOSED SCHEDULE and TOWN OF HAMPTON SUPPLEMENT TO MEMORANDUM ON 10 CFR E2.7J 4 (ai fl) AND CONTENTIONS OF THE TOWN OF HAMPTON TO NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN REVISION 2 in the above-captioned proceeding have been served on the following'by deposit in the United States mail, or as otherwise indicated, on this 19th day of November, 1986.

• Helen Hoyt, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission East West Towers Building Fourth Floor 4350 East West Highway Bethesda, MD 20814

• Dr. Jerry Harbour Administrative Judge

• Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Dr. Emmeth A. Luebke Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .

SHAINES. MADRIG AN & McEACHERN - Paortssionat associanon 29 MAPLKWOOO avtNut PO Bon 360 PO77sMOUTM NM 03e05

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• Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mrs. Anne E. Goodman Board of Selectmen 13-15 Newmarket Road Durham, NH 03842 William S. Lord, Selectman Town Hall Friend Street Amesbury, MA 01913 Jane Doughty Seacoast Anti-Pollution League 5 Market Street Portsmouth, NH 03801 Rep. Roberta C. Pevear Drinkwater Road Hampton Falls, NH 03844 Philip Ahrens, Esq.

Assistant Attorney General Office of the Attorney General State House Station 6

• Augusta, ME 04333

• Thomas G. Dignan, Esq.

R.K. Gad II, Esq.

, Ropes & Gray l 225 Franklin Street Boston, MA 02110 2

SH AINES. M ADRIG AN & McEACHERN - PoorgssoNat assoclATON 25 wAPLEWOOO avtNUE PO Bon 360 PORTSMOUTH NH 03808

d Robert A. Backus, Esq.

Backus, Meyer & Solomon 111 Lowell Street Manchester, NH 03105

• Robert G. Perlis, Esq.

Sherwin E. Turk, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission ,

Tenth Floor 7735 Old Georgetown Road Bethesda MD 20814 Mr. Angie Machiros, Chairman Board of Selectmen Newbury, MA 01950

• H. Joseph Flynn, Esq.

Office of General Counsel Federal Emergency Management Agency 500 C " street, S.W.

Washington, D.C. 20472

• George Dana Bisbee, Esq.

Stephen E, Merrill, Esq.

Office of the Attorney General State House Annex Concord, NH 03301 Carol S. Sneider, Esq.

Assistant Attorney General Department of the Attorney General One Ashburton Place 19th Floor -

Boston, MA 02108 Stanley W. Kliowles

• Board of Selectmen P.O. Box 710 North Hampton, NH 03826 J.P. Nadeau, Selectman Town of Rye 155 Washington Road Rye, NH 03870 l 3 l

5H AINES M ADRIG AN & McEACHFRN PRortssoNAL assocs*Tiom 2s paPttwooo avtNut Po nos no - Po#TsucuTM Nu ossoi

r Richard E.'Sullivan, Mayor

' City Hall Newburyport, MA 01950 Alfred V. Sargent, Chairman Board of Selectmen Town of Salisbury, MA 01950 Senator Gordon J. Humphrey U.S. Senate Washington, D.C. 20510 (Attn. Tom Burack)

Michael Santosuosso, Chairman Board of Selectmen Jewell Street RFD 2 South Hampton, NH 03842 Allen Lampert Civil Defense Director Town of Brentwood '

Exeter, NH 03833 Richard A. Hampe, Esq.

Hampe and McNicholas 35 Pleasant Street Concord, NH 03301 Gary W. Holmes, Esq.

• Holmes & Ellis 47 Winnacunnet Road Hampton, NH 03842 William Armstrong Civil Defense Director 10 Front Street '

Exeter, NH 03833 Calvin A. Canney City Manager City Hall 126 Daniel Street Portsmouth, NH 03801 4

SH AINES. M ADRIGAN & McEACHERN ..ortssioNat assooa ch l ,s..,.a......s._,.-o,_

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• Edward A. Thomas Federal Emergency Management Agency 442 J.W. McCormack (POCH)

Boston, MA 02109 Sandra Gavutis Town of Kensington RFD 1, Box 1154 East Kensington, NH 03827 Charles P. Graham, Esq.

McKay, Murphy & Graham 100 Main Street Amesbury, MA 01913 Diane Curran, Esq.

Harmon & Weiss 2001 S Street N.W.

Suite 430 Washington, D.C. 20009-1125 i

Matthew T. Brock

• By Federal Express 5

SH AIN ES M ADRIG AN & Mc E ACHERN - PoortsscNu assoc'* Tion 29 W A.t EWOOD 8vf NUE PO Pos350 POatswouTH Ne* 01801