ML20024E390

Response to Util & NRC Response to Seacoast Anti-Pollution League Contentions on State of Nh Radiological Emergency Response Plan.League Does Not Object to Specifying Incompletion in Plan as Basis for Contention 1

ML20024E390
Person / Time
Site:	Seabrook
Issue date:	08/05/1983
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20024E383	List: ML20024E382 ML20024E385 ML20024E390 ML20024E393 ML20024E396
References
ISSUANCES-OL, NUDOCS 8308100327
Download: ML20024E390 (3)

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e F1 LED: AuggE[ p 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY CXM1 MISSION $5 AljG -8 P4:05 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ctra UF SECI tie 00CKE-TING & SERE In the matter of:

, PUBLIC SERVICE (X)MPANY OF Docket Nos.. 50-443 OL ;g NEW HAMPSHIRE, et al 50-444 OL g 6

(Seabrook Station, Units 1 and 2) S SAPL RESPONSE TO APPLICANT AND STAFF RESPONSE TO SAPL CONTENTIONS ON NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN h NOW COMES the Seacoast Anti-Pollution League, and responds to the ob j ec t ions and comment s to its contentions on the New Hampshire Radiological Emergency Response Plan (NHRERP) as follows:

1. SAPL has no objection to further specifying the incompletion 3 in the NHRERP in the basis for its Contention 1. It does not agree @

that it has an obligation to incorporate the particular incompletions h as part of the Contention, which is, on i ts f ace " reasonably specific" in saying that the plan is incomplete. $

llowever, in order to advise the Board and the parties of the f ur ther incompletions which i t contends renders the plan incomplete, it agrees to strike the last sentence from its statement of basis i

for the Contention, and to substitute the following:

The NHRERP is further incomplete in the following:

a. The evacuation routes have not been designated for persons in the various planning sectors arounds the Seabrook Plant. NUREG-0654 J10a. That is, the plan does not designate persons in which areas are to use the routes .

set out on the map furnished as Figure 2.6-1.

b. There is no indication to show that the response ,

organizations have adequate manpower to meet the staffing -

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requirements for evacuation, as required by 10 C.F.R. 5 50.47(b)(1).

c. There are no appended letters of agreement from any of the response organizations, with the exception of the K1 policy letter from the Public Health Service, and therefore there is no basis for reasonable assurance that any of the response organizations have facilities or resources that can be relied upon in the event of an emergency. NUREG-0654 C 4.

d. The incident field of fice location and layout have not been designated. NHRERP 2.4-15.

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e. No emergency public information has been provided as b requi red by 10 C.F.R. 50.47 (b) 7 and NUREG-0654, G1 and G2.

f. The arrangements for communication services by the Rockingham County Dispatch have not been finalized. NUREG-0654 A (1) (e).

g. No transportation facilities have been designated in NHRERP 1. 3-17, su f f i ci ent to mee t the requ i remen ts of 50. 47 (b) (3) and (8), NUREG-0654 J 10 (d)(g).

2. SAPL stands on Contention 2 in its present form, dealing g Ei with the lack of absence of clear authority for the Governor to .

perform his protective response requirements under state law.

3. As to Contention 3, SAPL notes that the Applicants have not objected to Contention 3, and the Staff has merely noted that it would "not object to an otherwise properly worded contention specifica1ly asserting the NHRERP's failure to define the role of municipal corporations in the plan." In view of these responses, g i

SAPL will stand on this Contention, since this is precisely what SAPL alleged as the basis for this Contention, namely the failure to define the role of the municipal corporations in the radiological a response plan.

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4. As to Contention 4, SAPL stands on this Contention, based y upon its belief that the appropriate time to litigate the reasonableness and accuracy of evacuation time estimates is in the  !

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hearing on the off-site planning issues. SAPL is aware that this .

Boa r d has r u l ed on a Mo t i .;i. to Defer Consideration of Time Estimates by the Massachusetts Attorney General, that the Applicant 's time j i

estimates will be litigated at the upcoming August hearings, but adheres to the position that an overall determination of the time  !

e In which an evacuat ion of the 10 mile EPZ could be carried out depends '

upon the resolution of the issues concerning the adequacy and completeness of state and local emergency plans, and that this issue is therefore properly brought forward for considera tion at that time, j i

i Respectfully submitted, Seacoast Anti-Pollution League By its attorneys, BACKUS, SHEA & MEYER By4 /

K6bfr t A. Backus 116 Lowell St., Box 516 Manchester, N.H. 03105 August 5, 1983 Tel: (603) 668-7272 f

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