ML20070D839

Responses to Interrogatories & Requests for Document Production.Svc List Encl.Related Correspondence

ML20070D839
Person / Time
Site:	Seabrook
Issue date:	12/13/1982
From:	Doughty J SEACOAST ANTI-POLLUTION LEAGUE
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8212160321
Download: ML20070D839 (5)

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RELATED CORBNme UNITED STATES OF AMERICA Nfd'75

NUCLEAR REGULATORY COMMISSION

'82 DEC 15 A11:04 BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD

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In the Matto~r of dSh5 #II pUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL NEW HAMPSHIRE, et al. 50-444 OL (Seabrook Station, Units 1 and 2)

SAPL'S RESPONSES TO NRC STAFF INTERROGATORIES ~AND-REQUESTS FOR DOCUMENT-PRODUCTION TO SEACOAST ANTI-POLLUTION LEAGUE S.3.a. The Staff has asked that SAPL " explain in detail all reasons underlying the statement that the Applicant's analysis of Class 9 accidents, cont.ained..in its environmental report, fails to satisfy the Commission's policy statement of June 13, 1980 at 45 F. R. 4 0101. "

A. First, SAPL believes that its contention relates to the Staff's compliance with requirements of the National Environmental Policy Act, as specified in the Commission's Interim Policy Statement, and not to the Applicant's Environmental Report. However, in regard to the Environmental Report, SAPL believes that the analysis would fail to comply with the Commission's Policy Statement, if the Policy Statement in fact related to the Environmental Report, in the following respects:

1. The Commission's Policy Statement requires that "approximately equal attention shall be given" to the consequences of accidents and to the probability of their occurrence. In addition, the Commission's statement requires that accidenta whose consequences be analyzed shou'ld "not be limited" to those that can reasonably be expected to occur.

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2. Thb Environmental Report does not disclose the full consequences lof a Class 9 accident. Throughout the discussion in Section 7.4, t

" Determination of Release Category Consequences",

the Applicant' discusses the consequences only in combination with the cla'imed low probability of the accident events.

3. The consequences are not presented on a worst case basis, contrary to the Policy Statements requirement that the accident segu'ences "not be" limited to those that can be reasonably expected to; occur. For Example, the Applicant has chosen to use average wind speed, and to use weekday transient population concen-trations.

8212160321 921213 PDR ADOCK 05000443 0 PDR

4. Contrary to the requirements of the Interim Policy Statement, the Environmental Report does not discuss the extent to which events arising from causes external to the plant may be considered possible contributors to the risk.

5. Tie accident consequences are mitigated by the assumption of the " benefits of evacuation", again precluding the disclosure of the full consequences of a worst case accident.

S.3.b. State and explain in detail the steps, if any, that you believe must be taken to correct the deficiencies listed in the answer to question S.3(a).

A. The full and complete disclosure of the consquences of a worst case accident should be provided, and should include infor-mation available from such recent studies as NUREG/CR2239.

S.3.c. Describe in detail the site features, availability of sheltering, and population densities at Seabrook that you believe should affect the analysis of Class 9 accidents, and explain for each identified item how and why it would change the analysis.

A. Site Features - Limited roadway network, choke points on the bridges over the tidal rivers, and the harbor entrance.

Proximity of the reactors to the at-risk population, including the beach population as described in FEMA Rep. 3:

"The behavior of drivers who are caught in congestion within direct sight of the Seabrook Station can only be guessed at this time. Any breakdown in orderly evacuation traffic flow will result in evacuation times greater than the ones estimated above. Total evacuation times could range from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> 30 minutes to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> 40 minutes for an evacuation in which traffic control is generally ineffective." Dynamic Evacuation Analysis:

Independent Assessments of Evacuation Times from the Plume Exposure Pathway Emergency Planning Zones of Twelve Nuclear. Power Stations. February '1981, p. 46 Availability of Sheltering -Resident and beach population out-strip available structures for sheltering. Most structures lack basements. Population Densities - According to the DES, 5-58, the majority of early fatalities would be expected to occur '.'within a 3.2 km. (2-mi.) radius." The population density t

at Seabrook, on a worst case basis, could well be very great l

within the 2 mile radius.

This Intervenor is unable to state, at this point the manner in which each of these factors would change tre aialysis, i except to stn't'e that it would cause the analysis to show more l adverse consequences than presently disclosod,

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S.3.d. Describe the consequences of a Class 9 accident that you feel would require that a license for the facility be denied or that the plant be modified and state and explain the technical or other bases for your belief.

A. Th'e consequences are early' fatalities, latent cancer fatalities,-. radiation illness, genetic damage,. environmental contamination, and land interdection. The basis for this belief is the well-known adverse effect of radiation contamination on human health and the environment.

S.3.e. Describe and explain in detail the conditions that ;'ou feel must be attached to the issuance of an operating license; supply the basis or reasons for imposing such conditions; and describe and explain the plant. modifications, if any, that you believe should

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be undertaken to satisfy these conditions.- ~ ~ - ~ i A. SAPL feels that the operating licens.e should not, be issued so long as a risk of severe accidents exists and the public health and safety cannot be assured through emergency preparedness. See DES 545, last paragraph of Section 5.9.4.4(3). However, should the operating license be issued, it must be recognized, in the words of Commissioner Gilinsky, with whom' Commissioner Bradford agreed, that "Seabrook poses difficult, and perhaps unique, emergency planning problems." Recognition of these problems should require, at a minimum that plant operation not be permitted during the period from Memorial Day to Labor r ay, and at times when travel is restricted due to inclement weather and road conditions.

S.3.f. State the steps that you feel the Applicant must take to satisfy the requirements of 10 C.F.R. Sec. 50.40.

A. See Above.

S.3.g. State and explain the bases for your view that the Wash-1400 methodology for analyzing Class 9 accidents is discredited.

WASH-l'400 has been the subject of numerous criticisms.

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A.

These include not.only the NUREG/CR-0400, but "the risks of nuclear power Reactors: A Review of the NRC Reactor Safety Study" published by the Union of Concerned Scientists, and the comments of Meyer Bender and Jeremiah J. Ray, ACRS members, attached to a letter from ACRS Chairman P. Shawmon to Chairman pallodino dated September 15, 1982.

S.3.h State and Explain the method that you believe should be used in' analyzing Class 9 accidents in lieu of that of WASH-1400.

A. SApL~ believes that in lieu of a technically indefensible probability analysis, the possibility of a Class 9 accident should be acknowledged and assigned a probability of 1.

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c RESPONSE TO INTERROGATORY I - In responding to these issues SAPL intends to rely upon the follosing:

Dr. Richard Kaufman, University oP New Nampphire Dr. Donald Herzberg, Dartmouth-liitchcock Medical Center Dr. Jan Beyea, National Audubon Society _

SAPL does not at this-time have curriculum vitae for the above named individuals, but will forward these as soon as they are obtained. SAPL is unable at this time to identify all the witnesses and docu mnts it will call in support of its contention. It cannot, accordingly, provide summaries of the views, positi.ons, or proposed testimony on this contention.

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w .Yw, a h Jane Dc,ughty , () it)

Field Director -

. . SEACOAST ANTI-POLLUTION LEAGUE i

DATED: /O O ~

State of New Hampshire f C o u n t y o f M B S e 4 -- y J ,,

Personally appeared the above named, Jane ^ Doughty and made oath that the statements subscribed to by,her are true to the best of her knowledge and belief. -

Before me, *

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. Ju(ticF6f JhtFPettis/ Notary Public 1

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'AtomicJSafety'& lac.pp. 225 Franklin Street g DEC 15 Al; a B:ard - U.S. MRC,, -

Boston, MA 02110 Wa hington, DC ?30555 jif. _, .3 sng ,

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,b U DoNeting [nd Service Sec. Ch E ni de Office of the Secretary Atomic Safety &Lic kap.

Board - U.S. NPC- U. S. NRC s Wachington."DC 20555 Washington,' DC 20555 y &

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Roy P.; Lessy, Jr'. p. Esq. -

- R bert L. Chiesa, Esq.

Offico of Executive 95 Market Street, Legal Director U.S.__NRC s Manchestdr. NH 03101 Wa:hington, DC 20555 ' '

Phillip Ahrens, Esq.  ; JanelDoughty - '

Anot. Atty. General Field; Director

• Stato House, Station #6 SAPLi -

Augusta, ME 04333 - i 5 Market Streetc Portsmmith, NH 03801 Wilfred L. Sanders. Esq. I L.

Sanders & McDermotit Tupper Kinder).Esq.

408 Lafayette Road Attorney General's Office .

Hampton, NH' 03842,c State'of New Hampshire Concord, NH 0330l?

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. i Dr. Emmeth A. Luebke David R. Lewis Admin. Judge Atomic Safety & Lic. Brd.

Atomic Salety & Lic. Ap. U. S. NRC - Rm. T/W-439 Board - U.S. NRC ^

Washington, DC g 2 % 55-Washington,,DC 20555 ,

j JoiAnn;3hotwell, Asst. AG .

One AChburton Place, 19th Floor .

Boston, MA i02108' x .

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1 William S. Jordan, I I 4, Esq. .

4 Ellyn R. Weiss, Esq.

1725 I Street, N.W.

Suite 506 Washington.,DC 20006 Edward J. McDermott, Esq. ,

Sanders and McDermott~-

408 Lafayette. Road $

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