ML20069G496

Affidavit of SS Fan.Until NRC Properly Considers Class 9 Accidents & Identifies Addl Features or Other Actions Which Would Prevent or Mitigate Consequences of Serious Accidents, NRC Will Not Comply W/Nrc 800613 Policy Statement

ML20069G496
Person / Time
Site:	Seabrook
Issue date:	03/23/1983
From:	Fan S NEW HAMPSHIRE, STATE OF
To:
Shared Package
ML20069G449	List: ML20069G445 ML20069G450 ML20069G465 ML20069G478 ML20069G492 ML20069G496 ML20069G500 ML20069G502
References
NUDOCS 8303250168
Download: ML20069G496 (2)

Text

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

4

~

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS'SION

~ 9../, ;e d3 Before the ATOMIC SAFETY AND LICENSING BOARD f

i

! )

In the matter of: ) '

4

)

PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE) Docket Nos.: 50-443 ET AL. ) and I ) 50-444 (Seabrook Station, Units 1 and 2) )

. ) March 23, 1983 Affidavit of Stephen S. T. Fan I'

I, Stephen S. T. Fan, being duly sworn, state as follows:

i

.! 1. I am currently Professor of Chemical Engineering and Chairman of the Department of Chemical Engineering at the University of Neu Hampshire, and consultant to the New l, Hampshire Office of the Attorney General. My professional

, qualifications are outlined M. my curriculum vitae attached l as Attachment A to New Hampshire's January 12, 1983

j. Response to Applicant's Interrogatories.

2. In light of the uncertainty bounds on the quantitative assessment of environmental and health impact ranging from a factor of 10 to 100 and given the potential consequences ,

of a Class 9 accident, possible measures to interdict the transport of radioactive contaminants through air or liquid pathways should be studied now, and not after an accident occurs.

4

3. Until the Staff has properly considered this issue and

. identified " additional features or other actions uhich A

E i

i I

0303250168 pDR ADOCK 05000 830323

o

3 4

would prevent or mitigate" the consequences of a serious accident, it will not have fully complied with the 2..

June 13, 1980 NRC Policy Statement, 45 Fed. Reg. at 40103.

4 qd- - G(

IL ll.

l.

([littit -

Dr. Stephen S. T. Fan Chairman and Professor College of Engineering and Physical Sciences Department of Chemical Engineering

Kingsbury Hall ,

University of New Hampshire Durham, New Hampshire 03824 THE STATE OF NEW HAMPSHIRE STRAFFORD, SS.

Personally appeared this 23rd day of March, 1983, Dr. Stephen S.T. Fan, before me, the undersigned officer, an'd made oath that the foregoing statements are true to the best of his knowledge and belief.

. - 3 Y)- s, i ,Y // .s ?

i TE5kV L AUSSELL !Jotar/ Public Notary;Public/Jeseire ot the-Peace IAy Commicsi:9 Encircs April 22,1936 7 e

i j .

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