ML20028H295
| ML20028H295 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/19/1990 |
| From: | Mcpheters L Federal Emergency Management Agency |
| To: | |
| References | |
| CON-#490-11079 OL, NUDOCS 9011300094 | |
| Download: ML20028H295 (14) | |
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//6)77 November 19, 1990 POLMETED UMC UNITED STATES OF AMERICA T 20 N 00 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-JUDGE IVAN W. SMITH, CHAIFJ%N JUDGE RICHARD F. COLE JUDGE KENNETH A. McCOLLOM
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In the Matter of
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Public Service Co. of New Hampshire,
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Docket No. 50-443-OL et al.
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50-444-OL
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Offsite Emergency (Seabrook Station, Units 1 & 2)
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Planning Issues
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NOTICE OF FILING
-The Federal Emergency Management Agency (FEMA), throagh its undersigned counsel, respectfully submits letters from Grant C. Pete iston, FEMA Associate Director for State and Local Programs and Support, to the Nuclear Regulatory Commission and the State of New Hampshire, notifying each of FEMA's approval of the New Hampshire Radiological Emergency Response Plan in accordance with 44 CFR 350.12 of the FEMA rule.
FEMA additionally submits a copy of the signed original of the certification of the Federal Emergency Management Agency Findings and Determination for the New Hampshire Radiological Emergency Response Plan site. specific to the Seabrook Nuclear Power Station to be forwarded to the Federal Register for publication.
Respectfully submitted, h$ct. Ytt.bd1Y Linda Huber McPheters Federal Emergency Management Agency 500 C Street, S.W.
Room 840 j
Washington, D.C. 20472 (202) 646-3941 I
l 9011300094 901119 PDR ADDCK 05000443
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' November 19, 1990 ULNHC UNITED STATES OF AMERICA
'90 L']V 20 P3 :30 NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.
t JUDGE IVAN W. SMITH, CHAIRMAN JUDGE RICHARD F. COLE JUDGE KENNETH A. McCOLLOM
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In the Matter.of
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Public Service Co. of New Hampshire,
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Docket No. 50-443-OL et al.
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50-444-OL
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Offsite Emergency (Seabrook Station, Units 1 & 2)
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Planning Issues
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L
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CERTIFICATE OF SERVICE I hereby certify that. copies of the foregoing Notice of Filing and accompanying documents have been served upon tha following persons by U.S.
-mail,'first class, on November 1930, 1990.
Administrative Judge.
Administrative Judge G. Paul Bollwerk, III Thomas S. Moore, Chairman Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Bot.rd U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington,' D.C. 20555
' Administrative Judge Administrative Law Judge Howard A. Wilber.
Ivan W. Smith, Chairman-
-Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board
. Board U.S. Nuclear Regulatory Commission
<U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C.-20555
- Administrative Judge Administrative Judge Richard F. Cole Kenneth A. McCollom Att.o.c Safety and Licensing Board Atomic Safety and Licensing Board r..
y U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 L
Robert R. Pierce, Esq.
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Edwin J. Reis, Esq.
Mitzi A. Young, Attorney Office of the General Counsel Office of the General Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Diane Curran, Esq.
Thomas G. Dignan, Jr., Esq.
Harmon, Curran & Tousley Ropes & Gray 2001 S Street, N.W., Suite 430 One International Place Washington, D.C. 20009 Boston, MA 02110 Robert A. Backus, Esq.
Paul McEachern, Esq.
Backus, Meyer & Solomon Shaines & McEachern 116 Lowell Street 25 Maplewood Avenue, P.O. Box 360 Manchester, NH 03106 Portsmouth, NH 03801 Gary W. Holmes, Esq.
Judith A. Mizner Holmes & Ellis Counsel for Newburyport 47 Winnacunnet Road 79 State Street Hampton, NH 03842 Newburyport, MA 01950 Barbara J. Saint Andre, Esq.
Jane Doherty Kopelman and Paige, P.C.
Seacoast Anti-Pollution League 77 Franklin Street 3 Market Street Boston, MA 02110 Portsmouth, NH 03801 Ashod N. Amirlan, Esq.
Jack Dolan 145 South Main St., P.O. Box 38 Federal Dmergency Management Agency Bradford, MA 01830 442 J.W. McCormack (POCH)
Boston, MA 02109 George Dana Bisbee, Esq.
Suzanne Breiseth Assistant Attorney General Board of Selectmen Office of the Attorney General Town of Hampton Falls 25 Capitol Street Drinkwater Road Concord, NH 03301 Hampton Falls, NH 03844 Leslie Greer, Esq.
Assistant Attorney General Office of the Attorney General One Arhburton Place Boston MA 02108-1698 Peter J. Brann Esq.
Richard A. Hampe, Esq.
Assistant Attorney General Hampe & McNicholas Office of the Attorney General 35 Pleasant Stree' State House Station, #6 Concord, NH 03301 Augusta, ME 04333 Certificate of Service, November 19, 1990, p. 2.
L Allen Lampert Willi m Armstrong Civil Defense Director Civil Defense Director Town of Brentwood Town of Exeter 20 Franklin Street 10 Front Street Exeter, NH 03833 Exeter, Nil 03833 Sandra Gavutis, Chairman Calvin A. Canney Board of Selectmen City Manager RFD #1 - Box 1154 City 11all Kensington, NH 03827 126 Daniel Street portsmouth, N11 03801 Anne Goodman, Chairman William S. Lord Board of Selectmen Board of Selectmen 13-15 Newmarket Road Town Hall - Friend Street Durham,'NH 03824 Amesbury, MA 01913 Michael Santosuosso R. Scott flill-Whilton, Esq.
' Board of Selectmen Lagoulis,11111-Whilton & McGuire South }!ampton, Nil 03827 79 State Street Newburyport, MA 01950 Stanley W. Knowles, Chairman Norman C. Katner Board of Selectmen Superintendent of Schools p.0, Box 710 School Administrative Unit No. 21 North }!ampton, NH 03862 Alumni Drive liarpton, Nil 03842
' Sandra F. Mitchell The !!onorable Civil Defense Director Gordon J. Humphrey Town of Kensington ATTN:
Janet Colt Box 10 RR1 United States Senate East Kingston, Nil 03827 Washington, D.C. 20510 4
Mehdm VkPhdu.o LINDA HUBER MCpHETERS Federal Emergency Management Agency 500 C Street, S.W., Room 840 Washington, D.C. 20472 (202) 646-3941 l
1 Dated: November 19, 1990 1.
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l Certificate of Service, November 19, 1990, p. 3.
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Dear Governor Gregg:
I am pleased to advise you that the New Hampshire Radiological Diergency Pesponse Plan site-specific to the Seabrook Nuclear Power Station has been apprtned by the Federal D:ergency Management Agency (FD%) in accordance with 44 CFE 350.12 of the FD% rule. The adoquacy of the public alertirq and notification system has also boen verified by FD% in accordance with the joint Nuclear Regulatory Ccr:nnission (NRC)/FDR criteria contained in NUPE-0654/FD%-REP-1, Pav.1, Apperdix 3, and in the Guide for the Evaluation of Alert ard Notification Systems for Nuclear Ptwer Plants (FD%-
REP-10). The NRC was informed of this verification on September 7,1990.
7his 'is the first approval by FD% of offsite radiological emergency preparedness plans arcurd a nuclear power plant site in New thqrhire.
I know that you will agree that this is an important achievement on the part of your State and the Public Service Ccripany of New Hagshire in their efforts to protect the health ard safety of the public in the New Hagshire portion of the plume ard ingestion pathway emergency plannirg zones of the Seabrook Nuclear Power Station. I have enclosed a copy of our letter to the Nuclear Regulatory Cornission irdicating FD%'s approval of the State plan ard preparedness site-specific to the Seabrook Station.
I wish to octamend you ard all the individuals who participated in this acccruplidiment and to thank you for the excellent cooperation FDR has received.
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t C. Peterson Associate Director State and Local Programs ard Support Enclosure 1
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U.S. Nuclear R4gulatory Cammission Rt; S ?
Washington, DC 20555 IN ::
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Dear Mr. Taylor:
In accordance with the Federal EmcIgen::y Management Aiency (FDG) rule 44 CIR 350, the State of Nea 11arpchire submitttd the Nea llampshire Radiological Emerger y Response Plan for Seabrook Station for radiological energencies sitespecific to the Seabrook Nuclear Pwer Station. The plan was subnitttd to the Regional Dinctor of FDR Region I for FD% revies on December 9, 1985, ard a revision was again submitted on August 30, 1988, with updates ard a reiteration of the Governor's prior formal request for FD%'s review, evaluation ard approval. The Regional Director forwarded his evaluation of the Ne411ampchire State and local plans aryl preparedness to me on Dne m b r 4, 1989, in accordan with section 350.13 of the FD% rule. This evaluation was based on a review of the plan; the joint exercise corducted on June 28-29, 1988, in acx:ordance with section 350.9 of the FD% rule; and, a report of the public meetirg held on July 2,1988, to discuss the site-specific aspects of the State of Maine's plan, the New Harpchire Radiological Emergency Response Plc.., ard the New Hampchire Yankee Seabrook Plan for Massachusetts Ctramunities in accordance with section 350.10 of the FDR rule.
On 7ebruary 9,1990, the Regional Director provided me with an updated interim evaluation and re u.aendations regardirg the status of offsite radiolcgical er:ergency planning ard preparedness for the New Hampshiru portion of the Seabrook c:: urgency plannire zone. This evaluation continued to support Fam's prior firdirg that New Hampshire's radiological emergency respense plan and preparedrv_ss were adequate to protect the health and safety of the public in the Ucw Hampshire portion of the phune ard irgestion pathway emergency plannirg zones of Seabrook by provid!7 masonable assurance that cpprtpriate protective measures can be taken offsite in the event of a radiological emergency ard are capable of being implenented. An updated FD% firdirg was' forwarded to you on February 9,1990; we hava cnclosed a copy for your information.
On September 7, ~690, FDR provided the Nuclear Regulatory Comndssion with a firdirg that the alert and notification system for Seabrook was adequate to promptly alert and notify the public in the event of a radiological emergency at the site. L This finlirg was based on an ergineerirg design review; the abo're-mentioned February 9,1990, interim finding, ard the June 15,1990 incrim firding of adeone.cy for the Seabrcok Plan for 9
lussachusetts canrunitiosi and the results of the May 16, 1990, public For your informtion, we have enclosed a copy of our talophone survey.
September 7,1990, letter confimirg the adequacy of the alert and notification system.
Ibsod on 11URD3-0654/FDM-REP-1, Pov.1, I reiterato my finiirgs ard detemimtion of Febnnry 9,1990, that the State of licw flagchire's Radiolcgical EmcIgoncy Rorponso Plan ard pIrpartdness for the Scabrook lluclear Iber Station are adoquate to protect the health and safety of the public in that there is reasonable as.e that the appropriato protectivo measures can be taken offsite in the lica lla:"pshire portion of the pitmo and ingestion pathway cncrgency planning zones in the avont of a radiolcgical Therefore, I apprtne the 11ew llanchire Iddiological Energency cncIgency.
l-Resporre Plan for Scabrook Station in accordance with 44 CTR 350.12 of the L
112% Iule.
If you have any questions, please contact Craig S. Wirgo, Chief, Techno1cgical llazards Division, at (202) 646-3026.
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Petetron Anscciate Director Stato ard Incal Prtgram.
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1 Federal Emergency Management Agency Washington, D.C. 20472 SEP 7 1990 Mr. James M. Taylor D:ecutive Director for Operations U.S. lAlclear Regulatory Comission Washirgton, D.C.
20555
Dear Mr. Taylor:
We Federal Emergency Management Agency (E%) has completed a review of the prompt alert and notification system for the Seabrook Station located in Seabrtok, New Ikpshire.
'Ihis revica has been completed pursuant to Title selected evaluative criteria ard Apperdix 3 in NUREG-44 CFR, Part 350; 0654/SR-REP-1, Revision 1; celected evaluative criteria in NURD3-0654/FDR-Revision 1,
Supplement 1; and FD%-REP-10, the " Guide for the REP-1, Evaluation of Alert ard Notification.*yste for Nuclear Power Flants."
2e enclosed report
- entitled, "Seabrook Station Site-Specific Offsite Radiological Emergency Prepartdness Alert ard Notification System Quality summarizes the engineering design revies of the Assurance Verification,"
system as described in the April 1988 Ecsign Report P,d the October 1988 and Marrh 1990 Addenda to that report; incorporates the results of the telephone survey of the public conducted follcwing a full r.ctivation of the alert and system on May 16, 1990; and cordirrs the adequacy of the notification applicable evaluative criteria from NUREG-0654/m%-PIP-1, Revision 1; NURD3-0654/mR-PIP-1, Revision 1, Supplement 1; ard FDM-REP-10.
Based on the engineering design review; the firdings of adequacy issued to the-Nuclear Regulatory Ccmission for the Ucw Ha @ ire Radiological Dicrgency Response Plan on February 9, 1990, and the Seabrook Plan for Massachusetts Communities on June 15, 1990; and the results of the May 16, 1990, public telephone survey, FDR has determined that the alert and notification system installed around the Scabrcok Station satisfies the requirements of NUREU-0654/FD%-REP-1, Revision 1; NUPIG-0654/ m %-REP-1, Revision 1, Supplement 1; and FD%-REP-10. _ Scrofore, FDR concludes that the system is adequate to pmptly alert and notify the public in the event of a radiolcgical emergency at the site.
A Title 44 CFR, Part 350, approval of the New Harpshire Radiolcgical Emergency Response Plan will be conpleted Se Honorable Judd Gregg, Governor of New Ha:pshire, ard at a later date.
New Hanpchiro Yankee have toen advised of this apprwal of the Scabrcok Station alert ard notification system.
Notwithstanding this appruval, FDR reccmmends that the State of New its local jurisdictions, and New Harpshire Yankee consider Ha:rpshire, increasing the frequency of the full-cycle tests of the Seabrtok Station,
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FD% believes that additional
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full-cycle tests, at a renthly frequeref, would provide an added dog i
alert ard notification artem.
Ci g ly, Grant C. Fe* m on Associate Director State ard I.ocal ProgIns ard Support Enclosure 4
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______.____.___.__-_._._______________._.--.___~-__-__--__.________.-,_______..____._________._.J
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, Federal Emergency Management Agency I
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i Mr. James M. Taylor i
Executive Director for Operations U.S.- Nuclear Regulatory Commission
' Washington,. D.C.
20555 i
Dear Mr. Taylor:
1 This11s' to transmit the enclosed two reports updating materials included in the Federal Emergency Management Agency's (FEMA) December 1988 consolidated
' finding on the Seabrook Nuclear Power Station. The first report is the February 1990 Review and Evaluation of the State of New Hampshire Radiological Tnis report updates
- Emergency Re',pt.nse Plan (NHRERP) for Seabrook Station.
tne December 1988: Review and Evaluation of tne NHRERP. The second report
.is the January 1990 Report on the Status of Corrective Actions, First
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. Exercise and Orill Cycle,1988 to 1994, of the States -of Maine and New
. Hampshire and New Hampshire ' Yankee's Of fsite Response Organization-for The second report updates and retitles the December
_the Seabrook Station.
.I" 11988 Status of Corrective Actions' for the 1988 FEMA Graded Exercise, h
LThe February 1990 Review and Evaluation of the NHRERP is based on revisions The evaluation
< of tnat plan-recently distributed by the State of New Hampshire, continues to support FEMA's finding that New Hampshire's plans and preparedness
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.New Hampshire portion of the Seabrook Emergency Planning Zone, by providing F-reasonable assurance.that-appropriate protective measures can be taken offsite E
in the event of a-radiological. emergency and are capaole of. being implemented, U
p 646-3692. We
'If you-have any!yuestions,iplease feel fr6 to contact me at F
/wi11 be forwarding additional copies of these reports uncer separate cover.
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Grant C. Peterson-Associate Director r
State and Local Programs and Support Enclosures-As' Stated s
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Federal Emergency Management Agency
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G60rgo W. Watson Acting General Counsel ITai:
Grant C. Pctorcon Acrociate Director A
r Stato and local Programs and Support
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SUIDECT.
- Federal Prgister lioticc Docket !!o. FD%-REP-1-!E-2 Attachcd is a signed origimi of the certification of the Federal L'mcIgency thnagement Agency Firdings ard Detemimtion for the !!cw Hagrhire Radiological I:mergency Eccponco Plan site-specific to the Scabrook liuclear Power Station.
Pleano arrarge for early publication in the Federal Ecgister.
Attachment As Stated a
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2 Billirg Code: 6718-20 FEDERAL D4ERGDiCY MANAGDENT AGDICY DOCKCT 10. :
FD%-REP-1-lel-2 MIE NEW IIAMPSHIRE PADIO103ICAL DERGDiCY RESFQiSE FINI SITE-SPECIFIC IOR 71E SEABROOK 11UCLEAR IWER S'IATION ACTIQi:
CERTIFICATION OF FDR FINDDIGS AND DLTERKDIATIQi In accordance with the Federal Dnergency Management Agency (me) rule 44 CFR 350, the State of lica llampshire formally subnitted the New liampshire Radiological Dnergency Response Plan for Seabrook Station for radiological emergencies site-specific to the Seabtrok Nuclear her Station. The plan was subnitted to the Regional Director of FDR Region I for FD% review on December 9,1985, ard a revision was again submittcd on Atgust 30, 1988, with updates ard a reiteration of the Governor's prior formal request for FD%8s review, evaluation ard approval. The State plan specifies the New flampshiro radiological emergency response in support of offsite plannirg and preparedness for the Seabrook fluclear h er Station. New llampshire is partially within the established plume and irgestion pathway cmezgency plannirg zones of the Seabrook Station.
On December 4,1989, the Rcgioral Director forvarded his evaluation to the Associate Director for State and In:al Programs ard Supporc in accordance with section 350.11 of the FD% Iule. 7he Decenber 4,.1989, evaluation was based on a review of the 11cw 11arpshire plans; an evaluation of the joint exerciso conducted on June 28-29, 1988, in acx:ottlance with section 350.9 of the FD% Iule; ard, a report of the p1blic meeting held on July 2,1988, to discuss the site-specific aspects of the Stetc of New llampchire's Radiolcgical Energency Response Plan, the State et Maino's plan, and Nes llampchire Yankec's ScabIrok Plan for Massachusetts Commtnities in
a acecrdance with soction 350.10 of the FDR rule.
On February 9,1990, the PIgiomi Director provided the Associate Director of State ard local Prtgranc and Support with an updated interim evaluation ard Innwrdations regardirg the status of offsite radiolcgical emergercy plannirq and prepartdness for the New Erfchire portion of the Scabrook emergency plannirg zone. 'Ihis evaluation continued to support FDR's prior firdirq that New ILwpshire's Radiolcgical Energency Responso Plan ard prepartdness were adequate to protect the health and safety of the ptblic in the ! Jew Ikwpchire portion of the plume ard irgestion pathway cnergency plannirq zones of Seabrook by providiry reasomble assurance that appropriate protective measums can be taken offsite in the event of a radiolcgical cmergency ard are capable of beirs inplementcd. An updatcd interim firdirg was transmitted to the Nuclear Regulatory Commission on February 9, 1990.
On September 7,1990, FD% pruvidcd the Nuclear Rcqulatory Commission with a firdirg that the alert ard notification system for Seabtrok was adequate to p.@y alert and notify the public in the event of a radiological emergency at the site. 'Ihis firding was based on an ergineerirg design review; the above-mentioned February 9,1990, interim findirg, and the June 15,1990, interim finding of adequacy for the Scabruok Plan for Wissachusetts Communitics; and the results of the May 16, 1990, public telephono survey.
Based on the abovementioncd evaluations and reconmendations for approval b? the Regional Director and the review by the FD% licadquarters staff, I reiterate my findirgs and determination of February 9,1990, that the New ILupchire Radiolcgical EmcIgency Response Plan and preparcdness for the Seabrook Nuc1 car Power Station are adequate to protect the health ard l
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o safety of the public in the liew liarpchire portion of the plume ard irgestion pathway mergency plannirg zones of Seabrook Station.
The offsite plans ard pre @.ss are awced as adcquate in that they prtnido reasonable assurance that appropriate protective actions can be taken offsite in the event of a radiological energency and are capable of beirq impimentcd. Thcrnfore, I approve the 11cw Ilarpshire Radiological Emergency Response Plan for Scabrook Station in nooordarce with 44 CFR l
350.12 of the FD% Iv3c.
IT!% will continuo to revicu the status of offsite plans ard preparedness associated with the Seabrook th2 clear Iwer Station in accordance with section 350.13 of the FDM rule.
For further details with respect to this action, refer to Doc}mt File FD%-REP-1-lel-2 maintained by the Regional Director, FD% Region I, J.W.
14ccormack Post office and Courthouse, Boston, Passachusetts 02109.
Datcd:
7 For F cral Dr ncy magem.nt Igency 4
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IttcIson Associate Director State and I.ocal Prcgrams ard Support
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of Concern 1,2,3,4,5 and 7 are admitted." Page 31. Nothing in the Order or the Memorandum rewrote the Intervenors' Area of Concern. The place to look, to find ou: what that Area of Concern is,is the Request for Hearing.
Tle Request for Hearing, at page 4, sets forth Area of Concern No.1 as follows:
1.
We are concerned about the potential for an accident such as a fire involving the nuclear materials to be used in the TRUMP S project. Such an accident could release those very toxic materials and cause significant damage to public health and safety and to the environment, and specifically to many members of the petitioning organizations.
That is the concern that was admitted, and that is the concern we are litigating.
Licensee may pretend that Intervenors were concerned only about adequacy of fire procedures, but the Intervenors have a right to speak for themselves, even in NRC proceedings.-
It is true that adequacy of fice procedures is one part of this concern.
Likelihood of a fire is also a part of this concern. Likelihood of a fire was the
_ question of greatest interest to Judges Ylloch and Linenberger in the first telephone conference. Likelihood of a fire has continued to be a subject of major concern throughout these proceedings, continuing through the Licensee's written presentation, and the Order vacating the stay, issued without a hearing and without i
1.
any opportunity to demonstrate inadequacies in Licensee's submittal. Never has
.this concern been limited to adequacy of fire response procedures.
Indeed, if this Concern were so limited, it would be red.indant. Area of Concern No. 4 was:
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4.. We are concerned about the adequacy of emerp:ncy response planning, particularly response to fire and p.ans for medical care of contaminated patients.
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That concern explicitly, specifically brought fire response procedures into the proceeding. Concern No. I was obviously much broader. Licensee's contention now that Concern No. I was limited to fire procedures conflicts not only with the explicit language of the Request for Hearing, but also with Licensee's contention then that this was a " general concern regarding the potential for a fire." Licensee's Response to Request for Hearing, page 16. The ruling now that this Concern was so limited is a travesty.
When the Request for Hearing was filed, no decommissioning plan had been filed. If it had been, its deficiencies might well have been singled out for special mention in the Request. Eventually, it was filed without service on or notice to the Intervenors, in violation of the McGuirc rule. Much later, Intervenors learned of its existence. At that time, Intervenors determined that it was not necessary to add to the excess of paper in this file by amending their Request for Hearing, because an inadequate decommissioning plan obviously increases the risk of an accident such as'a fire, and its inadequacy is therefore encompassed within Area of Concern No.1. One cannot seriously argue that inadequate financial assurance of decommissioning does not increase the risk of fire, not only by adding years to the exposure to risk, but also by adding the element of neglect.
CONCLUSION The motion should be denied, and the Memorandum and Order of November 9 should be amended accordingly.
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.dd sy wis~C. Orseti
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Bruce A. Morrison Green, Hennings & Henry 314 North Broadway, Suite 1830 St. Louis, Missouri 63102 (314) 231 4181 Attorneys for Intervenors 3
CERTIFICATE OF BERVICE True copics of the foregoing woro mailed this I day
[,,g,1990, by first class mail, postage prepaid, tot of m e, The Honorablo Potor B. Bloch Administrativo Law Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 The lionorabic Gustavo A. Linenberger, Jr.
(
Administrativo Law Judge l
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Wachington, DC 20550 Maurice Axelrad, Esq.
Newman & Holtzinger, P.C.
Suite 1000 1015 L Street, N.W.
Washington, DC 20036 Director Research Reactor Facility Research Park Universit Columbia,y of Missouri Missouri 65211 Ms. Betty ll. Wilson Market Square Offico Building P.
O.
Box 977 Columbia, MO 65205 Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attn: Docketing and Service Branch (original plus two copics) office of'the General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety Licensing and Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 (three copies)
Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC / g-m-
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