ML20009F814

Notice of Issuance of Directors Decision 81-14,denying Seacoast Anti-Pollution League 10CFR2.206 Request to Suspend or Revoke Facility CPs

ML20009F814
Person / Time
Site:	Seabrook
Issue date:	07/15/1981
From:	Harold Denton Office of Nuclear Reactor Regulation
To:
Shared Package
ML20009F812	List: ML20009F811 ML20009F813 ML20009F814
References
DD-81-14, NUDOCS 8108030048
Download: ML20009F814 (2)

Text

{{#Wiki_filter:4 l l '[7590-01] = NUCLEAR REGULATORY COMMISSION [DocketNos. 50-443 & 50-444] l PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ET AL. (Seabrook Station, Units 1 and 2) NOTICE OF ISSUANCE OF DIRECTOR'S DECISION (00-81-14) l On February 11, 1980, the Director of Nuclear Reactor Regulation l denied under 10 CFR 2.206 a petition filed by the Seacoast Anti-Pollution l League (SAPL). See D0-80-6,11 NRC 371 (1980). While the Director's j decision was pending before the Commission for possible review, SAPL filed a letter on June 30, 1980, before the Commission in support of its petition. l Although the Cormiission declined to review the Director's decision, the l Commission referred SAPL's June 30th letter to the Director for considera-tion as a separate petition under 10 CFR 2.206. SAPL's June 30th letter essentially reiterates its earlier request for institution of proceedings to suspend or revoke the permits issued to Public Service Company of New l Hampshire for construction of the Seabrook Station. SAPL's June 30th letter l l raises issues concerning emergency planning and evacuation as the basis of l j its request. Tiie Commonwealth of Massachusetts filed a memorandum in support of SAPL's request on March 13, 1981. Upon consideration of the information provided by SAPL and the l Comunwealth of Massachusetts, I have determined not to institute the l l 8108030048 810715. PDR-ADOCK 05000443l Q PDR t

t requested proceeding. The reasons for this decision are set forth in a " Director's Decision Under 10 CFR 2.206", which is 'available for inspection in the Commission's Public Document Room at 1717 H Street, N. W., Washington, D. C. 20555, and in the local public document room at the Exeter Public Library,- Front Street, Exeter, New Hampshire 03883. A copy of the decision will also be-filed with the Secretary for the Commission's review in accordance with 10 CIR 2.206(c). l Dated at Bethesda, Maryland, this 15 day of July 1981. FOR THE NUCLEAR REGULATORY COMMISSION NA Harold R. Denton, Director ~ Office of Nuclear Reactor Regulation I ~ = s I l l

' NRC FORM 88. (4-79)- ' NRCM 0240 r i i i l -. i t BACKGROUND AND SIGNATURE _ TAB l Use this side of the sheet to precede the background material when assembling correspondence. l (USE REVERSE SIDE FOR SIGNAT!TRE TAB) l i 1 ' I i l i r m.

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TELEPHONE M AN OH EST!*R N EW H AM PSHIRE C3:0 g g 603 668 7272 N June a, A980 John Ahearne, Chairman Victor Gilinsky, Comm. U. S. Nuclear Regulatory Comm. U. S. Nuclear Regulatory Comm. Washington, DC 20555 Washington, DC 20555 Peter A. Bradford, Comm. Richard T. Kennedy, Comm. U. S. Nuclear Regulatory Comm. U. S. Nuclear Regulatory Comm. Washington, DC 20555 Washington, DC 20555 In the Matter of Public Service Company of New Hampshire, et al (Seabrook Station, Units 1 & 2) Dccket Nos: 50-443, 50-444 2

Dear Comissioners Ahearne,

3radford, Gilinsky and Kennedy: I am writing on behalf of the Seacoast Anti-Pollution League, an Intervenor in the Seabrook licensing proceeding before the NRC. As you know, the Seabrook facility is currently under construc. N. tien, although at a reduced schedule due to financial constraints, ~~ at a site just over 1 1/2 miles from Hampton Beach, a population center which the Atomic Safety Licensing Appeal Board stated: 'Will be at times the most densely populsted area in the State." The site area has severe adverse characteristics not only from ~; the point of view of the population density, but also in terms of the road network, with two out of the three roads that provide egress from the beach leading generally westerly from the beach anc toward the reactor site. You now have before you the issue of whether or not to review a decivion made by Mr. Harold Denton,which denied a request made by the Seacoast Anti-pollution League for a Show Cause Order under 10 C.F.R. 52.206. You have now on six' separate occasions e:< tended the time for deciding whether the Commission should take review of this Decision. 10 C.F.R. S2. 206 (c) (1) indicates that a decision on review will normally occur within 20 days. p It is the purpose of this letter to respectfully suggest that the time for Commission action on this matter is overdue. In addition, se respect *ully urge you, in your role as superviso;s of the regula-tory staff, to mandate immediate sta,ff action on the issue raised by the request for a Show Cause Order. That regtie'st was filed, we would add, on May 2, 1979, well over a yle^a'r 'ago. In this regard, we would call to your attention the important =. =! fact that Mr. Denton's decision of February 11, 1980, on the evacuation issue did not actually deny the Show Cause Request, E O N Cit L JR ROBERT A B ACKUS STEPH EN J-S PIELM AN CLtZABETH CAZoEN N

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c which had been sought on the ground that no finding by any _ adjudicatory body within the NRC of the feasibility of evacuation, beyond the 1.25 mile low population zone, had ever been made. Rather, Mr. Denton candidly conceded that a demonstration of evacuability beyond~ the LPZ now would appear to be required. However, he noted that,. by a letter dated December 26, 1979, from Mr. Brian K. Grimes, Director of the Emergency Preparedness Program Office, requests for estimates of evacuation time by construction permittees, such as the Seabrook permittees, was pending. According to Mr. Grimes' letter, the estimates of e.vacuation time after notification were to be provided by March 31, 1980. Mr. Denton therefore concluded, on page 4 of his decision, that the Show Cause request was " premature" until the time estimates were available, for these estimates would in his opinion assist in determining whether the Seabrook facility was a "special instance" which might under the proposed regulation require regulatory action prior to the operating license review. s= The estimates of evacuation time requested in December by

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Mr. Grimes, and to have been furnished by the end.of March, have not, to the knowledge of the Seacoast Anti-Pollution League, been furnished to this date. Indeed, Mr. Grimes, by a letter dated March lith, deferred the deadline for submission of the time estimate due to a claimed need for review by the General Accounting Office. 04r. Grimes states "GAO clearance normally takes about 45 days.") In the meantime, with no response to the important issues raised by the NRC, and with construction continuing, and therefore tending to foreclose options that might be pertinent to a solution, there have been further major developments. First, it has now become known that the NRC's staff considers the Seabrook site to be one of 12 " problem" fixed nuclear sites in the country. A letter form Mr. John W. Macy, Jr., Director of the Federal Emergency Managem.ent Agency to Governor Hugh 'Gallen of i April 22, 1980, lists the Seabrook site, along with Indian Point, Zion, and nine others as one which has "the highest population l density within the 10 mile emergency planning zone or mutually agreed upon by FEMA and NRC." Second, State Civil Defense officials have now publically conceded that.the task of notifying 100% of the population within a five mile area within 15 minutes of notification to State or '9= local officials is impossible. Yet, the 15 minute notification 'EE requirement is ' found in NUREG 0654 " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness Support of Nuclear Power Plants", Appendix 3.

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Third, many local officials have now in sworn statements indicated their belief that evacuation within the time frame indicated in NUREG 0396, Table 2, is impossible. We includy 1 as an attachment hereto affidavits from these individuals. Fourth, the Commission has itself now recognized, in its Interim Policy Statement of June 9th, dealing with the closely related issue of Class 9 accident assessment, that: a "It is also the intent of the Commission that the staff take steps to identify additional cases that might warrant early consideration of either additional features or other which would prevent or mitigate the consequences of serious accidents. Cases for such consideration are those for which a final environmental statement has already been issued at the construction permit stage but for which cne operating license review stage has not yet been reached. In carrying out this directive, the Staff 3 should consider relevant site features, including population density, associated with accident risk in comparision to such l features at presently operating plants. Staff should also j consider the likelihood that substantive changes in plant j _. design features which may compensate further for adverse site features may be more easily incorporated in plants when construction ~ has not progressed very far." In short, the Commission now has a clear duty in this matter, in discharging its duty to protect the public health and safety,4-to immediately review Mr. Denton's decision of February lith, far it is inconsistent with the Commission's publicl y recognized duties to further delay consideration of this issue, or to permit further staff delay. The Commission should immediately require a Show Cause proceeding to be instituted, and should imnediately require staff action to disclose, on the basis of presently available evidence, whether or not evacuation sufficient 4 to protect the public health and safety, and in light of developing regulatory requirements, can be effected. It is undisputed that no finding that the presently required i emergency planning zone for plume exposure, of about ten miles, can be safely and expeditiously evacuated has ever been made. Indeed, as indicated by the enclosed affidavits, present indications are that this is not feasible. In the absence of a finding of i feasibility, construction should not be permitted to continue at the site, for as the Commission's June 9th Interim Policy 1 We also incluk, as illustrative of the problem at the Seabrook site, photo-l graphs of traffic and the beach crowd taken by the Hampton Police Chief, Mr. Ibbert Mark, on Menorial Day Weekend,1979. dE"R:. , m:::5::: 1 I m w

t ~ i i s =. Statement recognizes, this constructiLn is intending to foreclose options that may be important for protecting the public health and safety. Very truly yours, / v Robert A. Backus Attorney for Seacoast Anti-Pollution League RAB/ eld l l l Lss=a. .;;;;n.-- I l l l T:T:... e i -n

-= CERTIFICATE OF SERVICE June 30, 1980 F.: h [.. I, Robert A. Backus, certify that I have mailed, postage 'j prepaid, first class or airmail of the within to: = Ubh Atomic Safety and Licensing .E Alan S. i:osenthal, Chairman Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Appeal Board Commission 3' U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Office of the Attorney General. Dr. John H. Buck 208 State House Annex Atomic Safety and Licensing Concord, New Hampshire 03301 Appeal Board U.S. Nuclear Regulatcry Commission Karin P. Sheldon, Esquire Washington, D.C. 20555 Harmon, Roisman & Weiss Sheldon,6 Suite 50 Michael C. Farrar, Esquire 1725 I Street, N.W. Atomic Safety and Licensins Washington, D.C. 20006 Appeal Beard U.S. Nuc*. ear Regulatory Commission Dr. Ernest o. Salo Washington, D.C. 20555 Professor of Fisheries Research Institute Ivan W. Smith, Esquire College of Fisheries Atomic Safety and Licensing University of Washington .:= Board Panel Seattle, Washington 98195 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Kenneth A. McCc11um 1107 West Knapp Street Joseph F. Tubridy, Esquire Stillwater, Oklahoma 74074 4100 Cathedral Avenue, N.W. Washington, D.C. 20016 Frank Wright, Esq. Dr. Marv.n M. Mann Assistant Attorney General Atomic Safety and Licensing One Ashburton Place Board ?anel Boston,liassachusetts 02108 U.S. Nuclear Regulatory Ccemission Washington, D.C. 20555 Edwin T. Reis, Esquire Chief Hearing Counsel Assistan cv Office of the ExecutiJe Legal /' i Director U.S. Nuclear Regulatory Commission f Washington, D.C. 20555 g es $L e#*

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h i e: l John Ahearne, Chairman U.S. Nuclear Regulatory Commission i Washington, D.C. 20555 s ! Peter A. Bradford, Commissioner g U.S. Nuclear Regulatory Commission = Washington, D.C. 20555 Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard T. Kennedy, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Leonard Bickwit, T. squire Office cf the Ge. oral Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Thomas Eignan, Esq. Ropes & Gray l=_ 225 Franklin Street 27 Boston, Massachusetts 02110 ' Rob 6rt A. Backus 4 =. Z22' =.m. j m + .)

c/ C g. 4.gJe0'IJ y y ep/ :g = w AFFIDAVIT OF DIANA LAMONTAGNE g g a- -= 4 = h5 = My-name is Diana Lamontagne, I reside in Hampton, cad I am 1. = a Selectmen. } In my opinion,no evacuation of Hampton can be affected within 2. should this be necessary because of a nuclear a reasonable time, disaster. such as our police My concerns are that many of the officals, 3. and firemen, who uill have to be in charge of evacuation may them-selves want to leave the area in the event of a nuclear disaster. I am concerned about the children in our schools, about the about the prospect of looting in the event of evacuation, reception our people might have in the destination areas, if 5552 there has been evidence of contamination, and the length of time 1.==. it might be before people could return to their homes. There is no reasonable evacuation plan for the Town of 4. t.nd I personally doubt that it is possible to develop

Hampton, one that will have any reasonable chance of success.

1, --W ' G'L f n._ s 's-a -i. <~ '? 9./ ( Diana Lamontagne DATE:., State of Eew Hampshire County of f Personally appeared the aforementioned Diana Lamontagne and made oath that the above statements subscribed by her are true to the best of her knowledge and belief. Before me, .) ,./.-p.

• Justice of the Peace

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._n... Docu m> 3 [. usmc ,h, JUL 71980 > C4 office of the secrmry 6 h r!nch AFFIDAVIT OF JAY TANZER 3 9 ip N My name is Jay Tanzer, I am the Civil Defense Director 1. I believe the Town sf Hampton is for the Town of Hampton. now approximately 10,000 people. Hampton, however, does include Hamption Beach, one of the most heavily populated places in the State of New Hampshire, and the location of New Hampshire's most popular state park, Hampton Beach State Park. Hampton Beach is within two miles of the Seabrook reactors, 2. and access to the beach, which is a barrier beach is provided One of these roads, Route 286, would by only three roads. not be available for evacuation of Hampton Beach, since it is my understanding the plan would be to close the Hampton ~~# in Seabrook, Harbcr Bridge, so that people south of the bridge, 4 could evacuate souther 1'f. Route 1A, which goes north from Hampton Beach, is a 3. very heavily congested road. The only other road providing access to the Beach is Route 51, also known as the Exeter/Hampton Expressway, which proceeds in a generaly northwesterly direction. It also has a " choke" point which is the bridge over the Tide Mill Creek. The Town of Hampton has at this point no evacuation plans. 4. In my opinion before such a plan can begin to be developed the available Town must have a dedicated radio communications system, In my throughout the day, and also an exaergency warning center. kj3u opinion the people of the Town cannot be protected without these

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/sy y .- k. I believe the total cost of the siren basic requirements. E At the present time we have warning system could be S98,000. I also think we need a so-called " slave" just one miren. radio station as part of. our communications system. There are approximately 57 miles of town roads in the 5. there is a nursing home and there are elderly Town of Hampton, that would need assistance in evacuating. People of this sort would have to be approached by " block wardens". Hampton Beach presents the most difficult 6. In my opinion, I do not problem for evacuation in the Town of Hampton. believe you can evacuate Hampton Beach in a reasonable time =5 without tore roads providing access to t he Beach. I believe that no evacuation plan can be 7. In addition, if you do not have a drill or test of said to be adequate, I do not mean by this that you need to actually that plan. However, I do believe that you have cause people to leave. This also to have your emergency personnel trained and tested. of course will require funding, which (the Town lacks. ? 99 T n er DATE: State of New Hampshire County of Personally appeared before me the aforementioned Jay Tanzer and made oath that the statements subscribed by him are true to the best of his knowledge and belief. ~ 51... Before me, Justice of the Peace

} ,== = AFFIDAVIT OF LESTER BLACKWELL

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1. My name is Lester Blackwell, and I reside at 18 Union Street in Exeter, New Hampshire. I am a retired flight engineer and I expect tio be named Civil Defense Director of the Town of Exeter. 2. My position is an unpaid position and my budget is $1,200, and may be going to $1,800. This is for fixed costs associated with civil defense, such as telephone, maintenance of the generator, and ou'r warning system, consisting of four or five sirens. 3. I do not know, and I do not believe anyone knows, the time required to evacuate the Town of Exeter. My initial impression Nhh:. is that it will take 30 men at $10 an hour to provide necessary traffic control. The total cost cannot be estinated. ~_l 6Y Yb ~ DATE: Lester Blackwell St: ate of New Hampshire County of Perscnally appeared the aforementioned Lester Blackw(~2 ind made oath that the statements subscribed by him are true ti.

;e best of his knowledge and belief.

Before me, .#1 / Nel. jug l h,%.:u.~/w Justice of the Peace . [- ' d g t V 555 // DOC g D " f? USHRC 2 7 90 P ',-4 Ot-Jul smew1 O g,& SdC8 / g % '@4 2

.y // Dockmo unme 9) as JUL 719g3, .s. AFFIDAVIT OF ANDREW CHRISTIE OMee of the % VijE 6 Dochetint & Smice Branch q Lh6-O I4q \\ ' '1. My name is Andrew Christie and I am the Chief of Polic6 in Hampton Falls, New Hampshire and have resided here and served as Police Chief for five years. 2. I believe that to evacuate this town, which is largely rural, would take approximately 10 to 20 people, and, if l everybody had previously been given exact information on what to do and where to go, it would take perhaps 6 to 12 hours. 3. The Hampton Falls police force consists of, in additicn to myself, four special officers, all of whom are out-of-town, and one of whom is a lobster fisherman. I do not know where er3 we would get the manpower necessary te 2pervise an evacuation. i 4. I think the only feasible way to notify people an evacuation would be necessary would be to go frca door-to-door. We do have f one siren, which can be heard for perhaps a quarter-of-a-mile, and would cover 10 or 15 per cent of the families at best, I would estimate. 5. I believe a phamdiet, containing detailed infcrmation on evacuation, should be provided to every household in town. I also believe that we would need additional sirens and communication equipment, which could be very expensive. 6. There are 28 miles of road in this town, with five intersections on Route 88 alone. As a practical matter, I don't believe an evacuation in the event of a major nuclear disaster could ever

Mm be made to work.

, = = - - DATE: <#dA4 8, D' p[cic P A Andrew Christle Scate of New Hampshire

t L. ' =.n. County of i Personally appeared the aforementioned Andrew Christie and made oath that the statements subscribed by him are true to the best of his knowledge and belief. Before me, w.L e 6, o,

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~ AFFIDAVIT OF ROBERT MARK $ was "IC' 3 &38 Doddia8 6 1. My name is Robert Mark / and I ab the Chief of Police y Hampton. 2. I am concerned about my responsibilities as Chief of Police in the event a nuclear evacuation of Hampton was required. 3. I believs the most difficult problem for Hampton would be the evacuation of Hampton Beach, should this become necessary on a day when there is peak usage of the beach. I have photo-graphs taken on May 27, 1979, showing the traffic approaching Hampton Beach at approximately 10 in the morning. These photo-ja. graphs show that the Exeter/Hampton Expressway, the major route to and from the Beach, although it is one lane of traffic in each direction, being used by two solid lines of approaching traffic, stretching as far as the eye can see. The second lane of approaching traffic is using the shoulder, which I understand might have to be reserved for official vehicles and emergency use. 4. I am aware that fire equipment can take from one to two hours to get from Hampton Beach to Route 1 on a peak beach day, although this is only a distance of approximately two miles. It has taken me as much as 1 1/2 hours to go a mere six blocks in the beach area in early July of 1979. I agree with the Affidavit of Mr. Tanzer that it is not possible to evacuate the Beach in a reasonable time without additional roads. %=i%: 'Ei " 3 5. I have 27 full-time of ficers in the police force. The Fira ~ Department has 31 firemen, 8 on duty at a time. a ~~ half

9 i: [ State of New Hampshire County of Rockingham, i:: Personally appeared,before me the aforementioned Robert Marky and mada cath that the statements subscribed by him are - true to the best of his knowledge and belief. Before me, f / N> Just,irce of the Peace 4'&

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_= [ '- ,s y ./, Doeg Q, Usnm f sut 7 tsen y AFFIDAVIT OF SANDRA GAVUTIS Offic, of th 6, Dockting g 7 bh1 6 g 1. My name is Sandra Gavutis and I am a Selectmen in t N m Town of Kensington, New Hampshire, the center of which is approximately 5 or 6 miles from the site of the Seabrook nuclear plant. The population of Kensington is approximately 1,200 people. 2. On March 13, 1980, by voice vote at Town Meeting, the citizens of Kensington voted that evacuation of the Town of Kensington in the event of a nuclear disaster was impractible, and to oppose the use of any Town funds for this purpose. 3. Neither I, or e.o my knowledge, either of the other two $252 Selectmen of the Town of Kensington have ever been contacted 1 by a representative of the "ublic Service Company of New Har.pshire with regard to the evacuation problem in our town. 4. Ou. Civil Defense Director, Andrew J. Mertinooke is a volunteer, and the Town lacks any budget or resources to properly plan for an evacuation. 5. The Town contains three schools, an elemen. sry school, a kindergarten and a nursery school. There are also in Kensington m:ny one car families, where the principal wage earner may be away from home during workin~g hours. 6. The Keasington police force consists of four men, all part-

time, The Chief of Police is a truck driver, who cannot be cound on to be available at all times.

Also, there is no ,.=:=.- gene._1 communications system available in Kensington, only police radios.

h In the event an evacuation was necessary, I believe the ? 7. assuming they could be made available promptly, would

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This would have to go door to doo; to notify inhabitants. be necessary because Kensington is a rural community. For the above reasons, I do not believe that an evacuation 8. of the Town of Kensington is feasible within the time frame d.1 ring which a radioactive plume might cover this Town, which I understand, according to Table II of NUREG-0396, might be on the order of one to four hours. =: =r+ o' f/* ? / I. s, DATE: d'.,/ '2 Sandra Gavutis /' .j o State of New Hampshire County of ,.,. 6,. L.. c : ;, i Personally appeared the aforementioned Sandra Gavutis and made oath that the statements subscribed by her are true to the best of her knowledge and belief. Before me, i.' ' _ $ c,. bi _ l. i Justice of the Paace . i: &=

AFFIDAVIT OF DONALD CHICK hs =: =: I am at the moment My name is Donald Chick and I am the Exeter Town Manager. e. 1. Ik ths /.cting Civ2.1 Defense Director, but hold this position in name only. 's G.'

g To the best of my recollection, I have had not.,contactefrom Public Service

? 2. builder of the Seabrook nuclear power plant, about evacuation planning.

Company, the time frame would be for an evacuation, or the

{ I have had no incication of what + p3rson.tel.or equipment that would be required. been taken by the Selectmen of Exeter with regard :o an evacua-3. !:o action hat I h.ne, however, received an annex prepared by New Hampshire Civil hfense, tior. plan. indica:ing geners.lly the evaucation routes that would be used in this area. 3 dcn't have any idea how lcng an evacuation of Exeter would take, maybe 48 hours 4. I would assume there would be some pan:.c among the population. or mayse a week. the tax payers of Exeter should pay for an evacuation 5. ' also do not believe that egused by the Seobrook nuclear plant. A fund should be established by charges to

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2{.. to cover any evacuation caused by the the users of the electricity from the plant 4 Plani. ef 1 ~ // POCKETED uv3C y ,,/. / / g qqg6Q > .-4 ll ( / .: 1 ~ Donald Chick 01-JUL U Office of the DATE. Dochsting & g 6 8 e s State of New Hampshire Coun,y of Rockingham Persenally appeared the aforementioned Donald Chi.ek and made oath of his knowledge and the statements subscribed by him are true to the best that beli2f. f.N Before me, ? . : w. : '<.. l ~ Notary Public ,,'/ '

ja . c::. G USNN3 a} OI jut 7 $80 > 5"*'t 0 AFFIDAVIT OF WILLIAM W.RSTON om:o' *& led pong 6 8 "-{ Bragch e N 1. My name is William Marston, and I reside in Hampton rmeas, New Hampshire, where I am a member of the Board of Selectmen. I live on Brown Road, and I am a dairy farmer with a herd of appro:<imately 55 dairy cattle. 2. I do not believe that the Town of Hampton Falls is in any way equiped to handle a major disaster at the Seabrook nuclear power plant, which is sited within two miles of the village center. The population of Hampton Falls is around 1,400 to 1,500. There is also a camp ground, many of whose patrons are Canadians, who may not speak English. 3. I have had no contact from Public Service Company zegarding ~"* evacuation planning, and no indict. tion of the time in which an evacuation might have to be accomplished. 4. The Town has no evacuation plan, and has voted, at town Meeting, not to expend public funds for this purpose. 5. In my opinion, the Town of Hampton Falls is ill-equiped to be evacuated in the event of a nuclear disaster, and lacks the resources and personnel to prepare for such an event. ! l j ?l% ~r /7/53/ / -~ DATE: William Marston e J State of New Hampshire County of Personally appeared the aforementioned William Marston and ?E. made oath that the statements subscribed by him are true to the "~ best of his knowledge and belief. Before me, u u m Justiceofthe(Pgce

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[. -o o -e O'NEILL & CACKUS S. ATTO R N EYS AT LAW llE LOWELL STR'. ET-BOX SIG TELEPHON E MANCH ESTER N EW H AM PS HIRE 03105 603 668 7272 January 29, 1981

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g\\. i lyrdL j Mr. Harold i'enton, Di. rector Office of Nuclear Reactor Reculation i Nuclear Regulatory Commission j Washington, DC. 20555 f i l

Dear Mr. Denton:

You presently have under consideration a show cause request under 10 C.F.R. 2.206, on the basis material which I forwarded on behalf of the Seacoast Anti-Pollution League to the Commission in June. I am at this time enclosing for your assistance, video-i tape showing the environs of the Seabrook Nuclear Plant in l the summer of 1980. This videotape was prepared by a member of our organization and has been transcribed onto a tape which I understand is compatible with machines available to i your staff. l I believe this tape will dramatically show the extensive l multiple use of housing at the beach in tha Jummer, and the l traffic congestion that occurs wnen no untoward event is in i progress. In addition, I am enclosing a series of photographs, ~ l ' labeled A through N, taken during the summer of 1980 in the l environs of Hampton Beach. I would offer the following observation on these photographs, referring to them by letter. A is a photo of a parking lot just behind Hampton Beach. It is offered in light of the contention that one car can be assumed to use one residence. B is a photo of traffic entering the beach area. C is a photo of the street immediately behind Ocean Boulevard on Hampton Beach. D is a photo of cars parked behind Seabrook Beach, with the subject nuclear plant in the background. E is a photo of traffic proceeding southerly behind Hampton Beach, toward the Hampton Bridge. F is a black and white photo of traffic proceeding near the police station on Hampton Beach. G is another traffic photo. H the same. LU K E S O' N EP LL J R - ROBERT A BACKUS JoH N P SHEA ELIZAGETH CAZO EN -. D U P f: Il $ A M 6.. M..S 9

p ..-. ~, .2- - 1 I the same. J a photo of traffic on Hampton Beach. K photo showing parking by beach front cottages. L is the same. M is the same. N is the same. I.would appreciate acknowledging receipt of this material. Very truly yours, b Robcrt A. Backus RAB/sid Enc. w.. MW ' e p _.,. - - ,}}