ML20023D826

Objection to Applicant twenty-first Motion for Summary Disposition of Contentions III.2 & III.13.Affidavit of Ja Macdonald Insufficient as Matter of Law to Support Grant of Summary Disposition.Statement of Matl Facts Encl

ML20023D826
Person / Time
Site:	Seabrook
Issue date:	06/01/1983
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20023D825	List: ML20023D824 ML20023D826 ML20023D827
References
ISSUANCES-OL, NUDOCS 8306030359
Download: ML20023D826 (2)

Text

MIS)~T/

r /

N UNITED STATES OF AMERICA / Ib '

NUCLEAR REGULATORY COMMISSIO'N , %2' BEFORE THE  !-j "Uyq [

ATOMIC SAFETY AND LICENSING ~ BOARD

• 7 <.s

-4

'j( '

,, da

'/:y% /o

) s. NU In the Matter of ) ,

Pr x\)

) Docket Nos.ld50 443 OL .

PUBLIC SERVICE COMPANY OF ) 50-444 OL NEW HAMPSHIRE, et al. ) June 1, 1983

)

SEABROOK STATION, UNITS 1 and 2 )

)

NECNP'S OBJECTION TO THE APPLICANTS' TWENTY-FIRST MOTION FOR

SUMMARY

DISPOSITION (CONTENTIONS NECNP III . 2 and III.13)

Pursuant to 10 C.F.R. 52.749, NECNP hereby objects, for the reasons outlined in the Affidavit of Philip B. Herr on NECNP Contentions III.12 and .13 being filed herewith, to the Applicants' Twenty-First Motion for Summary Disposition. NECNP further endorses and joins in the arguments set forth by SAPL i in its objection to this same motion to the effect that the Affidavit of James A. MacDonald submitted in support thereof is insufficient as a matter of law to support a grant of summary l disposition.

Respectfully submitted, J n '

s Diane Curran Harmon & Weiss 1725 I. Street, N.W.

Suite 506 Washington, D.C. 20006 8306530359 830601

, PDR ADOCK 05000443 C- PDR

STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS DISPUTE

1. While the time estimates made by the Applicants and contained in the FSAR have been subjected to a validation study, that study does not in fact validate the assumptions, methodology, or results of the Applicants' work.

2. The methodology employed by the Applicants in their

" Preliminary Evacuation Clear Time Estimates for Areas Near I

Seabrook Station" contained in the FSAR is not consistent with that set out in NUREG/CR-2504.

l

3. Past experience and common knowledge can, and in this case

, do, reveal errors in the assumptions, methodology, and l results of computer models for simulating evacuations.

4. The Applicants' " Preliminary Evacuation Clear Time Estimates for Areas Near Seabrook Station" contained in the FSAR are unrealistically low and derived from faulty methodology, and that study fails to provide emergency planners with much information which they will need to respond to emergency conditions at the Seabrook Station.

I

_ _ , _ _ _ _ _ __ ,. _. _ - _ _ _ _ . , _ _ _ _ _ . . _ _ _ , , . . . . _ _ _ _ _ _ , - _ .