ML20077P361
| ML20077P361 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/09/1983 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8309130349 | |
| Download: ML20077P361 (13) | |
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FILED:
September 9,
18&;%ETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY CONNISSION T3 MP 12 A11:27 BEFORE THE ATOMIC FAFETY AND LICENSING BOARD OFFICE cp 3gggg7,;.
OCCMEIyG A SEng,;
in the matter of:
OR4!CH PUBLIC SERVICE OOMPANY OF Docket Nos.
50-443 OL NEW HAMPSH IRE, et al 50-444 OL (Seabrook Station, Units 1 and 2)
SEAOOAST ANTI-POLLUTION LEAGUE'S SUPPLEMENTAL PETITION FOR LEAVE TO INTERVENE Pursuant to 10 C.F.R. 02.714(b), the Seacoast Anti-Pollution League (SAPL) submits the following contentions for litigation in this proceeding.
The contentions are based on the submitted Radiological Emergency Response Plans for the Towns of Seabrook, Newfields, Portsmouth, Kingston,
- Hampton, South Hampton, North
- Hampton, Newcastle,
- Newton, Exeter, Brentwood,
- Rye, Stratham, Kensington, and East Kingston, New Hampshire.
It i s SAPL's posi t ion that the submitted plans fail to meet the standards set forth in 10 C.F.R. 650,.47.
In many instances, SAPL has relied on the standards and regulatory criteria of NUREG-0654 Rev. I which provide a' benchmark against which the Board may judge compliance with the regulations.,
This is.an appropriate function of NUREG-0654 Rev. 1 given its speci fic citation in the Commission's regulations, and the def erence it has been afforded by this and other boards as well as the Appeals Board for this case.
See 10 C.F.R. 450.47 (b), and in the Matter of Sou thern ' Cali fornia -Edi son Company, et al (San Onofre Nuclear Generating Station, Units 2 & 3), 15 N.R.C.
1163, May 14, 1982, as O$00f3 PDR 50
s.
well as the recent decision In the Mat ter of Public Service Company of New Hampshire, et al. (Seabrook Station Units 1 & 2), ALAB-737, Slip Op.-August 26, 1983.
The following contentions apply to all fif teen of the submi tted plans except where noted (hereinafter referred to as "The Plans").
SAPL LP-1.
The plans contain no specific information concerning the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone.
Therefore, the plans do not meet the requirements of 10 C.F.R. 650.47
( a)(1), 6 50. 4 7 (b) ( 6 ) and NUREG-0654, E. 6.
( All ref erences to NUREG-0654 hereafter refer to that document published-in November, 1980 by the U.S.
N.R.C.
as NUREG-0654, FEMA-REP-1, Rev. 1.)
Basis:
The regulations state that provisions must exist for prompt communications from principal response organizations to emergency personnel and the public.
This requirements is clarified by NUREG-
- 0654, E.6, which specifically requires that local emergency plans include information as to the time required for notifying and providing prompt, instructions to the public.
A clear indication of the level of information necessary to satisfy this requirement is set forth in Appendix 3 of that document.
The submitted plans do not contain information concerning time requirements.
There are references to public' notification (stated generally at page 11-2), stating that: j
m' 4
The Public. Alerting System (consisting of sirens, tone-act ivated radios, and mobile public add,ress units) will be used to initiate "Public Notification".
This level of information contained in the plans is inadequate
-with respect to the standards referred to above.
inclusion of this information and its assessment are of crucial importance in determining the adequacy of the plans.
The time required to notify the public in the event of an evacuation will have a tremendous impact upon the abilities of emergency response personnel to evacuate the public in a timely and safe manner.
The Applicant has, to date, avoided the issue of time t'eku i r emen t s involved with public notification both in its FSAR emergency response. plan, and in these hearings generally.
In addition, the recent decision of the Atomic Safety and Licensing Appeals Board supports SAPL's position that careful scru tiny of noti fication times is an important component of overall evacuat ion t ime estimates. See ALAB-737, Memorandum and Order issued August 26, 1983, at page 11.
Consequently, it is appropriate for the Applicant to fully comply with the applicable regulatory.
standards.
SAPL LP-2 The plans f ail to specify the personnel responsible for notif ying the public through the use of mobile public address units.
Basis:
Since many persons may not have access to radio or television due to their location in recreation areas or due to power outages, instructions must be given through local PA units or other means.
T_his' requires time and personnel.
If the plans contemplate the use i
' a
of. police, fire, or other emergency personnel for this function, they must'spe,cifically so state, since engagement and notification will preclude' performance of other pressing duties such as traffic control, medical response, communications coordination, monitoring
-radiation, or any number of other duties assigned by the plans.
SAPL LP-3 The plans do not provide-for adequate, off-site radiological monitoring capability as required by 10 C.F.R. 650.47(b)(9) and NUREG-0654, H.7.
Specifically, the independent monitoring cross-referenced to the Department of Public Health Services in the state plan cannot be implemented as stated in the -plans.
Basis:
The plans. s tate taa t local of ficials have no responsibility for accident assessment.
That responsibility lies with the Department of Public Health Services in Concord.
As stated in the. state plan, three 2-person monitoring teams would be sent via civil aviation to Pease Air Force Base f rom Concord.
Those teams would_ proceed to the EPZ.
How those teams would be transported against the evacuation flow is unclear, and no specific monitor'ing locations have been designated in any of the plans.
Further, no let ter or other specifics of any agreement between DPHS and the U.S. Air Force has been detailed in any of the plans.
The lack of specificity regarding accident assessme'nt in general and radioactive monitoring in particular is contrary to the regulatory
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requirements.
SAPL LP-4
. t 2
4 The plans are insuf ficient to provide reasonable assurance that adequate. protective measures can and will be taken in the event of a radiological emergency as required by 10 C.F.R. 650.47(a)(1) in that the plans are. incomplete.-
Specifically, the plans make no provisions for an evacuation of persor.s institutionally confined.
B_a s i s :
Virtually all of the plans disregard the evacuation of persons whose mobili ty may be impaired to inst i tut ional or other confinement.
Identif.ication of the means for protecting such individuals is required by 10 C.F.R. 650.47(a)(1) as set f o r t h i n NUREG-0 6 54 J.10.d.
The drafters of the plans include references to special facilities' emergency response plans in.their tables of contents.
Those plans are not complete. Withou t the special f acili ties' plans, the documents fall to meet the appropriate regulatory critiria.
.SAPL LP-5
.The plans are insuf ficient to provide reason'able assurance that adequate protective measures can and will be taken in the' event of a radiological emergency as required by 10.C.F.R.
950.47(a)(1) in that.the pla'ns-are incomplete.
Specifically, with.the exception of the-Greenland, N,ew Hampshire plan, the plans do.not include maps showing evacuation
- routes, evacuation
- areas, or preselected radiological sampling and monitoring points.-
Basis:
LTh'e requirements for detailing town specific evacuation routes, host-reception centers, and preselected radiological sampling and monitoring points are clearly set forth in NUREG-0654 J.10.a.
The
plans submitted do not inc'lude maps detailing these areas and are therefore not in compliance with the regulations.
SAPL LP-6 The plans fall to comply with the requirments of 10 C. F.R.
650.47(b)(10), and (b)(12), as well as NUREG-0654 J.12 as they include no description of the means of registering and monitoring evacuees at relocation centers.
Specifically, the *,lans should include a description of the equipment and personnel required to monitor the radioactive contamination levels of evacuees as they arrive at the centers.
Basis:
Without the means to determine which evacuees have received radioactive contamination, it would be impossible to determine which evacuees require transportation to medical facilities for decontaminatlon.
The regulations clearly I,rovide that ar rangmen t:i mus t be made for medical services for contaminated individuals. NUREG-0654 s ta t es specifically that:
Each organization shall describe the means for registering and monitoring of evacuees at relocat ion centers and hos t areas. The personnel and eg'uipment available should be capable of monitoring within about a 12-hour period all residents and transients in the plume exposure EPZ arriving at relocation centers.
(NUREG-0654, J.12.)
Without a demons tration of this capability, it would be entirely possibl'e for numerous persons to remain at the shelters for extended periods of time without the s1ightes!
- dea of how much radiation they had received, and its potential effect on their health.
This requirement relates directly to the capability of reception center l
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personnel to respond to the medical needs of contaminated individuals.
The plans contain no information on this point.
Given that this Board has exp'ressed its willingness to construe the regulations in light of NUREG-0654 absent any showing to the contrary, it is approprlate that the Applleants comply with J.10 in all fif teen plans.
S AP L LP - 7 The plans are insuf ficient to provide reasonable assurance that adequate protective measures can and will be taken in the event of e radiological emergency as required by 10 C.F.R. 650.47(a)(1) in that no relocation centers have been identified.
This is contrary to NUREG-0654 J.h which requires identification of relocation centers in host areas which are at least five miles and preferably ten miles beyond the boundaries of the plume exposure EPZ.
(Note:
This Contention applies to all towns with the spectfic exemption of Greenland.)
Basis:
The establishment of relocation centers to receive large numbers of evacuees is fundamental to the successful evacuation of the EPZ.
The plans must include not only identification of the centers, but also a descriptlon of their capabilities for feeding and safely sheltering evacuees.
Although the local Red Cross chapters are designated to provide food and shelter, the plans include no letters of agreement to that effect.
Such let ters are specifically required under NUREG-0654 A.3 as the Red Cross is clearly a support organization having an emergency response role.
To the extent that these plans continue to lack
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appropriate identification of relocation
- centers, they remain incomplete and cannot meet the appropriate standards.
SAPL LP-8 The plans fall to meet the requirements of 10 C.F.R. 6 50.47(b)(11) and NUREG-0654 K. S.b. because there has been no showing that the means for radiological decontamination of emergency personnel, wounds, supplies, instruments, and equipment have been established.
Further, there has been no showing that a means for waste disposal exists.
Basis:
The decontamination facilities for emergency personnel described in the plans are inadequate for their intended purpose.
Either they are not specified at all, or local fire stations are not equipped with decontamination showers.
Provisions for safe internment of contaminated equipment and instruments are non-existent.
The sole reference in this regard is to the person
. responsible for the internment.
In Seabrook and other towns, for example, impoundment of contaminated equipment is the responsibili ty of the road agent.
That person's expertise in the area of low level radioactive waste storage is non-existent.
SAPL LP-9 The hospitals responsible for treating ill or injured persons suspected or known to be contaminated are not suf ficiently equipped or staf fed to handle the numbers of persons that would require such at tention in a serious radiological emergency. Further, no provisions are made for the transport of radiological accident victims to the.
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designated hospi tals. _ Thi s violates 10 C.F.R. 650.47(b)(11), (b)(12) and NUREG-0654 L.1 and L. 4.
Basis:
The regulations mandate arrangements for treatment of contaminated, injured individuals.
NUREG-0654 L.1 states that:
Each. organization shall arrange for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake, i ncluding assurance that persons providing these services are adequately prepared to handle contaminated individuals.
(Emphasis added.
NUREG-0654 L.4.
also provides that:
Each organization shall arrange for transporting victims of radiological accidents to medical support facilities.
The plans submitted do not provide the assurance that contaminated,' injured persons will receive adequate treatment.
For example, B.r igham & Women 's Hospi t al in Bos ton, Massachuset t s has_ a. total emergency room capaci ty of only twenty (20) persons. M can only-handle four (4) trauma patients at one time.
- Available
.s taf f _ t rained in the management of,lonizing radiation injury and decontamination procedures numbers four.(4) doctors, f our (4) nurses, and ten (10) oth,ers.
It boasts one decontamination shower.
Other hospitals have lesser capabilitles.
Of the medical facilities which have yet to respond to a SAPL survey, Brigham &
Women's Hospital tops the list in terms of capacity and qualified personnel.
The _ extremely limited capacity of hospitals to cope with contaminated, injured persons is significant due to the potential for large numbers -of people requiring precisely that type of
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it is entirely reasonable to expect that thousands of persons may require immediate treatment.
Then th'ere is the question of transportation.
What vehicles will be used to transport contaminated, injured victims to hospitals?
Who will provide quallfled medical personnel to staf f those vehicles?
What impact will impeded traffic flows due to evacuation have on medical transportation?
These questions are either ignored or insufficiently addressed in the plans.
SAFL LP-10 The plans are inadquately drafted in that they do not include a cross-reference to NUREG-0654.
This is in' violation of 10 C.F.R. 650.47(a)(1), 50.47(b)(1) et seg as interpreted in NUREG-0654 P.8.
Basis:
The drafters of the plans have failed to provide the necessary cross-referencing to the NUREG-0654 criteria as required by that document.
This has made it difficult and time consuming for all Intervenors to analyze the plans in light of appropriate criteria.
Despite a listing of the cross-references in the-plans' tables of contents, no cross-referencing has been included.
It is in the best interes'ts of all. parties to this proceeding that the referencing be provided immediately.
SAPL LP-11 The plans are insuf ficient to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
Specifically, the plans neither discuss
-nor analyze an account for behavioral variations among members of
~
the public in the event of a radiclogical emergency. Such behavioral -.
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1 variat ions would include evacuee disregard of evacuat ion ins truct ions resulting from panic.
Basis:
implicit in all of the plans submitted is the assumption that the - public will respond rationally and obediently to emergency notification. This assumption is f alse and disregards the potential for panic and its impact upon an orderly evacuation.
In sworn testimony presented on behalf of Suffolk County, New York, Susan Saeger t, Prof essor at the Center for iluman Environments, City University of New York, concludes that:
Existing psychological research suggests that a number of psychological factors may interfere with successful management of a radiological emergency.
Various studies report a
large discrepancy between lay opinion concerning the danger of nuclear power and expert opinion. The public tends to see the occurrence of a
radiological emergency that kills large numbers of people as relatively likely.
This fear is likely to influence response to an emergency in the direction of leading to either defensive avoidance of information and emergency preparedness or in the direction of a tendency to overreact.
Both responses could occur simultaneously.
This state of affairs is made more difficult to remedy by a history of expert underestimation of the dangers related to nuclear energy and by the technical compicxity and expert disagreement about probabilities and dangers.
The danger of nuclear power presents problems of risk evaluation to both the public and the experts because of its complexity and the uncertain state of scientific knowledge.
The problem of traffic congestion further complicates an evacuation.
The experience of traffic congestion will add to the likelihood that people will not be able to effectively comprehend the relative advantages and disadvantages of various courses of action, it increases the likelihood of frustration and irrational
- behavior, including possible aggressive behavior.
a-Similar conclusions have also been reached in detailed studies of Long Island, New York residents living in proximity to the Shoreham Nuc lear' Power f aci li ty.
A repor t prepared by James 11. Johnson, Jr.,
Ph.D., Department of Geography, University of Cali fornia, and Donald J.
- Zeigler, Ph.D.,
Department of Geography and Political Science, Old Dominion Universi ty, Nor folk, Vi rginia, f or Suf folk County, New York, also concludes that nuclear accidents are likely to give rise I
to higher levels of extreme behavior than has been reported in studies of non-radiological emergencies.
In general, the Ziegler and Johnson study concludes that people tend to ignore of ficial instructions and
" spontaneously evacuate" in the event of a radiological emergency.
The research of Professors Saegert, Ziegler and Johnson into 1
the area of psychological issues related to radiological emergency planning raises serious questions about the desirability of any plan that fails to even discuss and account for behavioral variation.
This is particularly true with regard to Seabrook and its proximity to extremely high population densities.
Of additional importance in this proceeding is the nature of the beaches as recreational areas.
Families of ten spli t up to pursue separate interests, agreeing to rendezvous later.
In the event of a sudden public notification of a radiological emergency, it is entirely reasonable that parents would not depart the area without first gathering their families together.
The confusion and panic resulting f rom such a situation would be catastrophic to the ef forts of police and other emergency personnel to initiate and maintain an orderly evacuation. -
Also, resident children attend schools throughout the area, of ten with relocation centers dif ferent f rom those assigned to their parents.
Co'nfusion and' panic could foreseeably result from this
-situation as well.
Parents would be reasonably expected to attempt to pick up their children from school, or to return to the EPZ from their assigned relocation centers when their children do not show up. All reasonably foreseeable scenarios of this type would seriously 1
disrupt the evacuation process.
Du'e to the extent of the available literature on the subject to psychological issues and radiological emergency planning, it is crucial that the plans address the issues of behavioral response directly.
Failure to do so is to ignore what lay persons and psychological experts agree is a reasonably foreseeable result of emergency not i f i cat ion: panic and i ts negat ive impacts on protective response.
SAPL LP-12 The plans are insuf ficient to provide reasonable assurance that adequate protective measures can and.will be taken in the event of-a radiologica'l emergency.
Specifically, the plans neither discuss nor account for. behavioral variations among designated emergency personnel that would impair or extinguish their abili ty to carry out assigned dutles.
Basis:
There is no reason to arsume, as the plans implicitly do, that emergency personnel would disregard considerations of their own personal safety and the-safety of their families in 'a ra'diological emergency.-
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An extensive study of emergency personnel responses to an accident-at Shoreham in New York raises serious questions about the reliability of such personnel in a nuclear emergency.
That study, conducted by Social Data Analysts, Inc.,
for Suffolk County, New York, examined the response potential for such key emergency personnel as school bus drivers and firemen.
The study concludes that a radiological emergency wou ld create serious role conflicts among emergency personnel, and large numbers of individuals would see first
.to the safety and relocation of their families before responding to official duty.
There is no evidence to support an assumption that emergency personnel in New Hampshire would react dif ferent ly, or that the role conflicts stemming from an accident would be limited to school bus drivers and firemen.
Therefore, the failure of the plans to investigate and discuss response factors among emergency personnel is a serious flaw that must be addressed to meet the standard of 10 C.F.R. 650.47(a)(1).
SAPL LP-13 The plans are inadequate because there are insufficient personnel available in the fire and police departments within the EPZ to fulfill designated obligations at the local level.
Basis:
An example is the Town of Hampton.
In his recent comments submitted to the NRC concerning the adequacy of the Town of Hampton RERP, Mr. John Tanzer, Civil Def ense Director for the Town of Hampton, states that.
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The requirement to control.an evacuation of up to 100,000 people is awesome.
Even that of eva.cua t ing t he " beach" i s con f ound ing.
Without rep, eating previous paragraphs, it is apparent that the Hampton Police Force is f ar outweighed by the magni tude of the problem.
The same holds for Public Works, and the Fire Department must hold in place for its primary mission.
There are easily ten times more duties for these personnel described in the plan than there are personnel to do them.
As Civil Def ense Director for the Town of Hampton, Mr. Tanzer's comments should be considered carefully by this Board.
His observat'lons are based on fi rs t-hand knowledge of the Seacoas t area, the size of the crowds that may need to be evacuated, and the specific response capabilities of Hampton emergency response personnel.
Consequently, his comments establish a solid basis upon which to submit this contention.
SAPL LP-14 The plans submitted are inadequate because they purport to provide for a feasible protective response, including evacuation, absent a declaration of assumptions.
Basis:
P.lanning for any type of emergency by definition requires the l
making of assumptions to anticipate the emergency itself.
Such assumptions'should be explicit, not implicit, both the public and cmergency response personnel must have a reasonable framework of l
assumpt ions upon which to opera te. The plans are loaded wi th implici t
- assumpt ions ( i. e., tha t there will be minimal panic interfering with cn orderly evacuation), but devoid of explicit assumptions which may be subject to criticism by local of ficials and planners who live in 1
the EPZ and have a first-hand, realistic view of their capabili ties.
. 1
Explicit, stated assumptions lay bare the fundamental precepts upon which the plans are based.
This is essential if the plans are to receive a meaningful and realistic evaluation by all parties concerned, particularly the general public.
SAPL LP-15 Procedures to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ. required by 10 C.F.R. ~)S0.47(b)(5) are inadequate in that the plans do not provide for bilingusi messages for the large numbers of French-speaking individuals who are often in the area in large numbers.
Basis:
Local experience in the Seacoast area, pa r t i cu lar ly in the summer months, indicates serious language barrier problems with French-Canadian visitors.
These people are known to visit the EPZ area in large numbers and would be unable to respond to any emergency notifications provided in English.
At a minimum, all relevant communications and informational material presented to the public must be in both English and French.
l Emergency response personnel who may have to deal with non-English i
speaking people must be' fluent in French and all such personnel must be trained in handling the behav,ioral dif ficulties that may arise as
.a result of the language barrier.
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l SAPL LP-16 l
The plans 'do not contain adequate guidelines for the choice of
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information on which the choice of protective protective actions or actions could be based in the event of an emergency.
Basis:
I l
None of the plans contains any information concerning the effectiveness of various protective actions in potential accident situations. 'In particular, none provides any basis for judging the effectiveness of sheltering as a protective action.
There is no information concerning the ability of the various types of structures to. provide shelter against radiation exposure, the conditions under which some structures would be acceptable and others would not, or the conditions under which sheltering must be abandoned in favor of evacuat' ion.
There is also no assessment of the ability to shelter those without easy' access to any form of shelter, particularly the transient and recreation areas and on the beaches.
LBecause of the plan's failure in this regard, they do not meet the requisite standards of 10'C.F.R.
650.47(a)(1), as interpreted in NUREG-0654'J., et seq.
SAPL LP-17 The plans are inadequate because they do not contain maps of evacuation routes, predictions of the time required for evacuation, or the impact of inclement weather during evacuation procedures, and
'the need for alternative routes.
(This contention does not apply to the Greenland RERP.)
Basis:
The basis for the contention is the underlying regulatory requirement, the provisions of NUREG-0654, par t icularly II.J-10, and the: absence f rom the local plans of the information described in the contention.
SAPL LP-18 m
The local plans do not adequately provide for requesting and effectively using assistance resources, including private resources as well as the resources of other governmental entities.
This is in violation of 10 C.F.R. 650.47(b)(3).
In particular, the plans do not set forth requisite letters of agreement detailing how assistance resources will be provided as required under NUREG-0654 A.3.
Basis:
Although the plans provide that the towns may seek outside assistance for various
- purposes, including transportation and material deficiencies, there has been no assessment of the scope and extent of aid that may be needed, nor are there any explicit written agreements to confirm the arrangement and the availability of resources. Although the towns will rely upon the New Hampshire Civil Defense Agency to fulfill many of these needs, there are no specific agreements to that effect, and there has been no delineation of how the agency will fulfill this role.
- Further, NUREG-0654 explicitly, requires written agreements referring to the emergency measures to be provided and the mutually acceptable erit,erla for their implementation as well as the arrangements for exchange of i n,f o r m a t i o n.
To date, none of these l
letter agreements are in place with respect to any of the personnel or equipment support mechanisms established under the local plans.
SAPL LP-19 The plans are inadequate because they f all to address the impacts of egress route flooding upon an orderly evacuation.
The plans cannot reasonably assure that adequate measures can and will be taken l
m in the event of a radiological emergency wi thou t addressing the flooding issue.
Basis:
Route 286 and Route 1A 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, as they were during severe winter storms during the winter of 1978-79.
SAPL LP-20 Th'e plans fall to assure that adequate measures can and will be taken to protect the health and safety of the public in the event of a radiological emergency.
Specifically, they fail to address the impact of limited gasoline supplies within the EPZ upon an orderly evacuation.
Basis:
The plans do not account for a limited gasoline supply available to the general public should-a full evacuation be ordered.
Such supplies are limited, and it is reasonably foreseeable that numerous vehicles would stall out due to lack of fuel while sitting in an evacuation traffic jam.
The potential for this happening to large numbers of automobiles along egress routes has not been addressed in the plans.
Consequently, local of ficials have no way of knowing the extent to which stalled vehicles may impede evacuation progress ar.d precisely how many tow trucks might be needed in order to maintain the flow of outgoing evacuation traf fic. This is par t icularly crucial In areas such as Hampton Beach, where t iny bottlenecks such as where Route 51 meets Ocean Boulevard can be ent irely choked of f wi th the stalling and abandonment of only one or two cars. i
m.
SAPL LP-21 The loca.1 plans are inadequate to protect the health and saf ety of ' the publi'c because they make no provision for radiological emergency notification of response personnel in advance of news releases to the public.
This allows for no lead time allowing emergency response personnel to initiate designated procedures, and will result in non-dedicated telephone lines to county dispatchers, fire, and police departments being tied up with public inquiries concerning the incident.
Basis:
A simultaneous notification of emergency' response personnel and the general public would seriously impair response capabilities.
Throughout the local plans, primary communications links depend upon non-dedicated telephone lines.
Those lines would become instantly jammed and unusable due to public inquiry, and the local plans do not provide for sufficient backup communications to fill the gap.
Consequently, local emergency response personnel would have their efforts seriously hampered if not neutralized by.the breakdown in
[
l communications, particularly with state officials.
SAP L LP-2 2 The local RERP's fail to make an adequate showing that 24-hour per day capabilities exist to determine the doses received by emergency personnel and hence fail to comply with 10 C.F.R. 650.47 (b)(11) and NUREG-0654 K 3.
There has been no discussion of what equipment will be provided at the reception centers for Division of Welf are and Red Cross workers monitoring evacuees.
Exposures of the numbers.of emergency workers that will need to be in the proximity l
l,
e of contaminated evacuees cannot be handled by the small amount of equipment des:cribed in the local plans.
The local road agents and water-department employees responsible for clearing the roadways, the State. Police and all others involved in the EPZ will require dosimeters.
There are too few dosimeters, and of those there are, too,f ew have the capacity to measure exposures beyond the 20 Range.
DPil. staff will be overburdened with other responsbilities such as analysis of environmental media, es t in.at ion o f the to tal populat ion dose and locating and tracking the plume.
There has been no showing that DPH has adequate staff to monitor and evaluate worker exposure records, too.
S AP L ' LP-2 3 The plans are inadequate to protect the health and safety of the public because they fall to assess the time it will take to evacuate permanent-residents and transient populations from the respect ive localit ies wi thin the EPZ. An analysis of these evacuation times is crucial if local officials and emergency personnel are to plan adequately for an ef fective evacuat ion should one be necessary.
i Basis:
The basis for this contention lies in the fact that local emergency planners must know the duration of their expected duties in the event of an evacuation.
State and federal planners should know how long the particular towns will take to evacuate in order r
to effectively focus equipment and pdrsonnel-resources in a
radiological emergency.
Some areas within the EPZ may take much longer to evacuate than others, to the extent that federal,, state i - - _..
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and local.of ficials are aware of the dif ferences in local evacuation times, and wiIl be able to plan accordingly.
Respectfully submitted, Seacoast Anti-Pollution League By its attorneys, t-BACKUS, SilEA & MEYER f
s B[
(#4 C Ba'cliu's 116 Lowell St.,
Box 516 Manchester, N.H.
03105 Tel:
(603) 668-7272 September 9, 1983 4
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CERTIFICATE OF SERVICE Brian Cassidy Helen Hoyt, Chm.
Thomas G. Dignan, Esq.
Fed. Fmerg. Mgmt. Agcy.
Admin. Judge Ropes and Gray
. Region I Atomic Safety & Lic.
225 Franklin Street J.W.LbConnack POCH Board - U.S. NRC Boston, MA 02110 Doston, MA 02109 Washington, DC 20555 Sen. Gordon Htanphrey hf3in J
E*
d Attn: Tom Burack
- "#I Atomic Saf ty &Lic.
n t
DC 20510 Wa ngton 20555 Sen, Gordon Hunphrey Roy P. Lessy, Jr., Esq.
Robert L. Chiesa, Esq.
Office of Executive 95 Market Street Pi is U.
hC Concord, NH 03301 Washington, DC 20555 Phillip.Ahrens, Esq.
Jane Doughty Asst. Atty. General Field Director
-Town Manager's Office State House, Station #6 SAPL Town Hall - Friend St.
Augusta, ME 04333 5 Market Street Amesbury, MA- 01913 Portsmouth, NH 03801 Donald E. Chick Anne Verge, 02airperson Dana Bisbee
'Ibwn Manager Board of Selectmen Attorney General's Office S
eo wH h re ee 0 33 S. Hampton, NH 03842
.Dr. Emmeth A.
Luebke David R. Lewis Office of Selectmen
'Ibwn Of North Hampton Admin. Judge Atomic Safety & Lic. Brd.
North Hampton, NH 03862 Atomic Safety & Lic.
U.S. NRC - Rm. E/W-439 Board - U.S. NRC Washington, DC 20555 Washington, DC 20555 Anne Verge, Chm.
Jo Ann Shotwell, Asst. AG Calvin A. Canney, Board of Selectmen One Ashburton Place, 19th City Mgr.-City Hall Town Hall Floor 126 Daniel Street South Hampton, NH -03842 Boston, MA 02108 Portsmouth, NH 03801
' John B. 'Ihnzer William S. Jordan, II, Esq.
Mr. Angie Machiros, Chnnn.
-Town of Hampton Ellyn R. Weiss, Esq.
Board of Selectmen 5 Morningside Drive 1725 I Street, N.W.
'Ibwn of Newbury Hanpton, NH 03842 Suite 506 Newbury, MA 09150 Washington, DC 20006 Edward Meany Dr. Muray'fye, President Sandra Gauvutis Town of Rye Sun Valley Assoc.
Town of Kinsington 155 Washington Road 280 Haverhill Street RFD 1
' Rye, NH 03870 Lawrence, MA 01840 East Kensington, NH 03827
' Alfred Sargent, Chm.
Brentwood Board of Selectmen Richard E. Sullivan, Mayor City Hall Board of Selectmen RFD Dalton Road Town of Salisbury,MA 01950 Newburyport, MA 01950 Bn h i 03833