The findings of the PRA for Seabrook, in any event, are not substantially different from, or do not justify departing from the "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (NUREG-0654, FEMA-REP-1), as some have suggested. This document, intended as a guide to emergency planning, offers the following guidelines when considering available response times: Time from an 'event' to start of release 1/2 hour to one day; duration of release 1/2 hour to several days; and travel time to a point 5 miles downwind 1/2 hour to two hours. Since Newburyport lies about six miles from Seabrook, we should plan on the basis of 'plume arrival times' as short as one hour, if we are to account for the 'worst case'.

For these short lead time accidents, the Radiological Emergency Response Plan for Newburyport provides the following: (p. 11-F-2) "Sheltering would be recommended in instances where evacuation may be advised but cannot be implemented due to time constraints and/or impediments to highway movement." ("Sheltering") will require the public proceed indoors; close doors, windows and ventilation systems and remain inside until otherwise directed."

I feel strongly that the inadequacy of such a plan speaks for itself. I raised this point in the deliberations of the review committee. When I asked Mr. Neil Boucher, who represented Anna Jaques Hospital, if he felt it was practical to remain cloistered in the cellar of the hospital with all the ventilation turned off for any length of time, he replied that he would have no problem remaining there for "weeks", if necessary! became the chairman of the review committee!

This same Boucher later

So what are we left with?

We are left with a nuclear power plant which many deem

unnecessary, which, by its operation, poses a certain "probability", arguably remote, in light of recent events, of failing in such a

way as to create a regional disaster of proportions hitherto

undreamed of except in nightmares.

It seems to me that even if the "probability" is slight, it must be amplified by the far-reaching, possibly devastating, consequences.

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While some nuclear advocates point out that one is more likely to be struck by lightning than have a serious accident at Seabrook, they fail to see the meaninglessness of such comparisons. They do not consider that while the 'lightning scenario' affects one person, and maybe his family, a nuclear accident could affect many thousands of people, even the yet unborn! It is imperative that in considering those seemingly miniscule numbers, this picture be born in mind, is any such degree frisk justified?

Which brings us back to the question, "Is Seabrook Safe"? In the final analysis, this is a socio-political question, not a scientific one. The scientists cannot translate into numbers such things as the loss of wildlife on Plum Island, or the loss to a parent of a leukemic child. These are questions fairly addressed in the social and political debate, and entirely appropriate to any discussion of whether or not Seabrook Station should be licensed

to operate.

It is the reponsibility of you, our elected delegates and officials to see to it that we, the public, are protected from unnecessary harm or risk. It is our right to be so protected, and your duty to protect and defend that right.

After careful consideration of all the evidence, and a thorough examination of potentially less risk-laden and more publicly acceptable alternatives, it is my belief that the prudent course of action is to deny an operating license to Seabrook Station on the grounds that it poses an unnecessary and unacceptable risk to the public.

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AA

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A notification time of 15 minutes should be added to the clear time estimates for each scenario to determine the total evacuation time. Clear time estimates include mobilization time.

Winter day scenarios represent low population under normal weather conditions.

Summer weekend scenarios represent high population under normal weekend conditions unless noted otherwise.

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