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Category:INTERVENTION PETITIONS
MONTHYEARML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20237C6981998-08-18018 August 1998 Sapl/Necnp Reply to Naesco Response to Proposed Contentions.* Board Should Admit Sapl/Necnp Contentions 1-4 & North Atlantic Energy Svcs Corp Arguments to Contrary. W/Certificate of Svc ML20237C6791998-08-18018 August 1998 Sapl/New England Coalition on Nuclear Pollution Reply to Staff Answer to Contentions.* Petitioners Believe Board Can & Should Give Cases Consideration W/O Filing of Addl,But Not Substantively Different Contention.W/Certificate of Svc ML20237A0501998-08-10010 August 1998 North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied ML20236X9281998-08-10010 August 1998 NRC Staff Answer to Contentions.* for Reasons Stated,All of Contentions Proposed Should Be Rejected & Proceeding Should Be Terminated.W/Certificate of Svc ML20066H2581991-02-14014 February 1991 Response of Ma Atty General & Necnp to ASLB Order of 910124.* Intervenors Believe ASLB Should Reopen Record, Permit Discovery & Hold Hearing on Beach Sheltering Issues. W/Certificate of Svc ML19332D7241989-11-21021 November 1989 Intervenors Motion for Clarification Or,In Alternative,For Reconsideration.* Clarification or Reconsideration of Scheduling Requirements Set by Commission 891121 Order Requested.Certificate of Svc Encl ML19332D5191989-11-15015 November 1989 Applicant Answer to Intervenors Motion to Admit late-filed Contention & Reopen Record Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Sys Network & Wcgy.* Motion Should Be Denied Since Results Unlikely to Change ML19325E0171989-10-20020 October 1989 Applicant Answer to Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Motion to Assert Addl Bases for Original Onsite Exercise Contention JI-Onsite Ex-1 Should Be Denied.W/Certificate of Svc ML19325E0011989-10-20020 October 1989 Applicant Response to Intervenors Motion to Amend Intervenors Motions of 890929 & 1013 to Admit Contentions on 890927 Onsite Emergency Plan Exercise.* Issue Re Admittance Committed to Board Discretion.Certificate of Svc Encl ML20248J3511989-10-13013 October 1989 Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Advises That Applicant Contentions Filed on 890929 to Admit Addl Bases Re Scope of Onsite Exercsise Should Be Admitted.W/Certificate of Svc ML20248J0601989-09-28028 September 1989 Intervenors Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Requests Hearing & to Engage in Discovery for Hearing on Contention.Supporting Documentation & Certificate of Svc Encl ML20247Q6761989-09-22022 September 1989 Intervenors Second Informational Suppl to Low Power Contentions Filed on 890721 & 0828.* Incorporates Encl Plant Startup Test Procedure 1-ST-22,Rev 2 Into Low Power Testing Contentions.W/Supporting Info & Certificate of Svc ML20246N1001989-09-0101 September 1989 Intervenors Reply to Responses of Applicant & Staff Re Intervenors Motion to Admit Contention,Or,In Alternative,To Reopen Record & Request for Hearing.* Contention Raises New Issues & Should Be Admitted.W/Certificate of Svc ML20247E0321989-07-21021 July 1989 Intervenors Motion to Admit Contention,Or in Alternative,To Reopen Record & Request for Hearing.* Requests Contentions Re Deficiencies in Training,Mgt Control,Supervision, Communication & Procedure Compliance Be Admitted ML20246P2041989-07-0505 July 1989 Joint Intervenor (Ji) Contentions on Spmc & June 1988 Graded Exercise.* ML20248F4691989-04-0303 April 1989 Seacoast Anti-Pollution League (Sapl) Trial Brief on Contention Ji 56 & Sapl Contentions EX-2,4,6,7,8,12,13 & 14.* Svc List Encl ML20206M9761988-11-23023 November 1988 NRC Staff Response to 881114 Board Order Requesting Comments on Significance of ALAB-903 for Seabrook Proposed General Exercise Contentions.* Contentions & Bases Should Be Denied. Certificate of Svc Encl ML20206M9431988-11-22022 November 1988 New England Coalition on Nuclear Pollution Comments on Significance of ALAB-903 to Seabrook Offsite Exercise Contentions.* Svc List Encl ML20206M9031988-11-22022 November 1988 Seacoast Anti-Pollution League Comments on Significance of ALAB-903 to Exercise Contentions.* Svc List Encl ML20205R7201988-11-0202 November 1988 Town of Hampton Contention on Applicant Plan to Fund Decommissioning Costs of Seabrook Station.* Supporting Documentation & Certificate of Svc Encl ML20205R5661988-11-0202 November 1988 Seacoast Anti-Pollution League Contentions on Applicant Plan in Response to NRC Order CLI-88-07.* Supporting Documentation Encl ML20205R5441988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Financial Qualifications to Operate Seabrook Nuclear Power Station.* Supporting Documentation & Certificate of Svc Encl ML20205R4971988-11-0202 November 1988 New England Coalition on Nuclear Pollution Contentions on Applicant Decommissioning Plan,Motion for Stay of Low Power Operation & Motion to Reopen Record.* Supporting Info & Svc List Encl ML20205R4821988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Decommissioning Plan for Seabrook Nuclear Power Station.* ML20205E0011988-10-24024 October 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to Commonwealth of Ma Atty General Exercise Contentions.* Certificate of Svc Encl ML20205E0271988-10-21021 October 1988 New England Coalition on Nuclear Pollution (Necnp) & Town of Hampton (Toh) Reply to Applicant & NRC Staff Responses to Contentions Toh/Necnp EX-2 & Toh/Necnp EX-3.* Svc List Encl ML20205D8051988-10-21021 October 1988 Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl ML20206C1951988-10-18018 October 1988 Seacoast Anti-Pollution League (Sapl) Reply to Applicant & Staff Responses to Sapl Contentions on June 1988 Graded Exercise.* Svc List Encl ML20204G9731988-10-13013 October 1988 NRC Staff Response to Intervenors Contentions on Graded Exercise.* Proposed General Exercise Contentions Should Be Admitted for Litigation & Proferred Contentions Should Be Denied Admission.Certificate of Svc Encl ML20154S4571988-09-28028 September 1988 Applicant Response to Intervenor Contentions on June 1988 Seabrook Exercise.* Intervenor Contentions Should Be Disposed Of.Certificate of Svc Encl ML20154P3461988-09-21021 September 1988 New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl ML20154K8741988-09-21021 September 1988 Commonwealth of Ma Atty General Exercise Contentions Submitted in Response to June 1988 Plant Initial full- Participation Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154K9331988-09-21021 September 1988 Town of Hampton & New England Coalition on Nuclear Pollution Emergency Planning Contentions on 880628-29 Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154N9061988-09-20020 September 1988 Seacoast Anti-Pollution League Contentions on Graded Exercise.* Svc List Encl ML20154D7431988-09-12012 September 1988 New England Coalition on Nuclear Pollution Petition for Review of ALAB-899.* Petition Should Be Granted on Basis That Integrity of RCS Significantly Paramount to Safe Operation of Plant.W/Certificate of Svc ML20151A6461988-07-0707 July 1988 NRC Staff Response to Town of Salisbury Amended Contentions Re Applicant Plan for Commonwealth of Ma Communities.* Applicant Untimely Amends to Contentions Should Be Rejected. Certificate of Svc Encl ML20151A6301988-07-0606 July 1988 NRC Staff Response to City of Haverhill Detailed Contentions.* City of Haverhill late-filed Contentions Should Be Rejected.Certificate of Svc Encl ML20196G7031988-06-27027 June 1988 Applicant Response to City of Haverhill Detailed Contentions.* Contentions Should Be Rejected & City Should Be Denied Admission as Party,Per 10CFR2.714.Supporting Documentation & Certificate of Svc Encl ML20196A3761988-06-22022 June 1988 New England Coalition on Nuclear Pollution (Necnp) Reply to Applicant & NRC Staff Response to Necnp Contentions on Spmc.* Certificate of Svc Encl ML20196A3991988-06-22022 June 1988 Reply of Massachussetts Atty General to Responses of NRC Staff and Applicant to Contentions 7 Through 83 Filed by Massachussetts Atty General.* Certificate of Svc Encl ML20196A5261988-06-22022 June 1988 Town of Amesbury Reply to NRC Staff & Applicant Responses to Town of Amesbury Contentions on Seabrook Plan for Massachussetts Communities.* Certificate of Svc Encl ML20196A8701988-06-20020 June 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to First Six Contentions Filed by Commonwealth of Ma Atty General.* ML20151N6271988-06-17017 June 1988 Town of Salisbury Reply to Applicant Response to Intervenor Contentions on Seabrook Plan for State of Ma Communities ML20151A8361988-06-17017 June 1988 Reply of Town of West Newbury to Responses of Applicant & NRC Staff to Intervenors Contentions Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl ML20151N6461988-06-17017 June 1988 Town of Salisbury Amended Contentions Re Applicant Plan for State of Ma Communities.Certificate of Svc Encl 1999-07-20
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20237C6981998-08-18018 August 1998 Sapl/Necnp Reply to Naesco Response to Proposed Contentions.* Board Should Admit Sapl/Necnp Contentions 1-4 & North Atlantic Energy Svcs Corp Arguments to Contrary. W/Certificate of Svc ML20237C6791998-08-18018 August 1998 Sapl/New England Coalition on Nuclear Pollution Reply to Staff Answer to Contentions.* Petitioners Believe Board Can & Should Give Cases Consideration W/O Filing of Addl,But Not Substantively Different Contention.W/Certificate of Svc ML20237A0501998-08-10010 August 1998 North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied ML20236X9281998-08-10010 August 1998 NRC Staff Answer to Contentions.* for Reasons Stated,All of Contentions Proposed Should Be Rejected & Proceeding Should Be Terminated.W/Certificate of Svc ML20066H2581991-02-14014 February 1991 Response of Ma Atty General & Necnp to ASLB Order of 910124.* Intervenors Believe ASLB Should Reopen Record, Permit Discovery & Hold Hearing on Beach Sheltering Issues. W/Certificate of Svc ML19332D7241989-11-21021 November 1989 Intervenors Motion for Clarification Or,In Alternative,For Reconsideration.* Clarification or Reconsideration of Scheduling Requirements Set by Commission 891121 Order Requested.Certificate of Svc Encl ML19332D5191989-11-15015 November 1989 Applicant Answer to Intervenors Motion to Admit late-filed Contention & Reopen Record Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Sys Network & Wcgy.* Motion Should Be Denied Since Results Unlikely to Change ML19325E0171989-10-20020 October 1989 Applicant Answer to Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Motion to Assert Addl Bases for Original Onsite Exercise Contention JI-Onsite Ex-1 Should Be Denied.W/Certificate of Svc ML19325E0011989-10-20020 October 1989 Applicant Response to Intervenors Motion to Amend Intervenors Motions of 890929 & 1013 to Admit Contentions on 890927 Onsite Emergency Plan Exercise.* Issue Re Admittance Committed to Board Discretion.Certificate of Svc Encl ML20248J3511989-10-13013 October 1989 Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Advises That Applicant Contentions Filed on 890929 to Admit Addl Bases Re Scope of Onsite Exercsise Should Be Admitted.W/Certificate of Svc ML20248J0601989-09-28028 September 1989 Intervenors Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Requests Hearing & to Engage in Discovery for Hearing on Contention.Supporting Documentation & Certificate of Svc Encl ML20247Q6761989-09-22022 September 1989 Intervenors Second Informational Suppl to Low Power Contentions Filed on 890721 & 0828.* Incorporates Encl Plant Startup Test Procedure 1-ST-22,Rev 2 Into Low Power Testing Contentions.W/Supporting Info & Certificate of Svc ML20246N1001989-09-0101 September 1989 Intervenors Reply to Responses of Applicant & Staff Re Intervenors Motion to Admit Contention,Or,In Alternative,To Reopen Record & Request for Hearing.* Contention Raises New Issues & Should Be Admitted.W/Certificate of Svc ML20247E0321989-07-21021 July 1989 Intervenors Motion to Admit Contention,Or in Alternative,To Reopen Record & Request for Hearing.* Requests Contentions Re Deficiencies in Training,Mgt Control,Supervision, Communication & Procedure Compliance Be Admitted ML20246P2041989-07-0505 July 1989 Joint Intervenor (Ji) Contentions on Spmc & June 1988 Graded Exercise.* ML20248F4691989-04-0303 April 1989 Seacoast Anti-Pollution League (Sapl) Trial Brief on Contention Ji 56 & Sapl Contentions EX-2,4,6,7,8,12,13 & 14.* Svc List Encl ML20206M9761988-11-23023 November 1988 NRC Staff Response to 881114 Board Order Requesting Comments on Significance of ALAB-903 for Seabrook Proposed General Exercise Contentions.* Contentions & Bases Should Be Denied. Certificate of Svc Encl ML20206M9431988-11-22022 November 1988 New England Coalition on Nuclear Pollution Comments on Significance of ALAB-903 to Seabrook Offsite Exercise Contentions.* Svc List Encl ML20206M9031988-11-22022 November 1988 Seacoast Anti-Pollution League Comments on Significance of ALAB-903 to Exercise Contentions.* Svc List Encl ML20205R7201988-11-0202 November 1988 Town of Hampton Contention on Applicant Plan to Fund Decommissioning Costs of Seabrook Station.* Supporting Documentation & Certificate of Svc Encl ML20205R5661988-11-0202 November 1988 Seacoast Anti-Pollution League Contentions on Applicant Plan in Response to NRC Order CLI-88-07.* Supporting Documentation Encl ML20205R5441988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Financial Qualifications to Operate Seabrook Nuclear Power Station.* Supporting Documentation & Certificate of Svc Encl ML20205R4971988-11-0202 November 1988 New England Coalition on Nuclear Pollution Contentions on Applicant Decommissioning Plan,Motion for Stay of Low Power Operation & Motion to Reopen Record.* Supporting Info & Svc List Encl ML20205R4821988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Decommissioning Plan for Seabrook Nuclear Power Station.* ML20205E0011988-10-24024 October 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to Commonwealth of Ma Atty General Exercise Contentions.* Certificate of Svc Encl ML20205E0271988-10-21021 October 1988 New England Coalition on Nuclear Pollution (Necnp) & Town of Hampton (Toh) Reply to Applicant & NRC Staff Responses to Contentions Toh/Necnp EX-2 & Toh/Necnp EX-3.* Svc List Encl ML20205D8051988-10-21021 October 1988 Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl ML20206C1951988-10-18018 October 1988 Seacoast Anti-Pollution League (Sapl) Reply to Applicant & Staff Responses to Sapl Contentions on June 1988 Graded Exercise.* Svc List Encl ML20204G9731988-10-13013 October 1988 NRC Staff Response to Intervenors Contentions on Graded Exercise.* Proposed General Exercise Contentions Should Be Admitted for Litigation & Proferred Contentions Should Be Denied Admission.Certificate of Svc Encl ML20154S4571988-09-28028 September 1988 Applicant Response to Intervenor Contentions on June 1988 Seabrook Exercise.* Intervenor Contentions Should Be Disposed Of.Certificate of Svc Encl ML20154P3461988-09-21021 September 1988 New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl ML20154K8741988-09-21021 September 1988 Commonwealth of Ma Atty General Exercise Contentions Submitted in Response to June 1988 Plant Initial full- Participation Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154K9331988-09-21021 September 1988 Town of Hampton & New England Coalition on Nuclear Pollution Emergency Planning Contentions on 880628-29 Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154N9061988-09-20020 September 1988 Seacoast Anti-Pollution League Contentions on Graded Exercise.* Svc List Encl ML20154D7431988-09-12012 September 1988 New England Coalition on Nuclear Pollution Petition for Review of ALAB-899.* Petition Should Be Granted on Basis That Integrity of RCS Significantly Paramount to Safe Operation of Plant.W/Certificate of Svc ML20151A6461988-07-0707 July 1988 NRC Staff Response to Town of Salisbury Amended Contentions Re Applicant Plan for Commonwealth of Ma Communities.* Applicant Untimely Amends to Contentions Should Be Rejected. Certificate of Svc Encl ML20151A6301988-07-0606 July 1988 NRC Staff Response to City of Haverhill Detailed Contentions.* City of Haverhill late-filed Contentions Should Be Rejected.Certificate of Svc Encl ML20196G7031988-06-27027 June 1988 Applicant Response to City of Haverhill Detailed Contentions.* Contentions Should Be Rejected & City Should Be Denied Admission as Party,Per 10CFR2.714.Supporting Documentation & Certificate of Svc Encl ML20196A3761988-06-22022 June 1988 New England Coalition on Nuclear Pollution (Necnp) Reply to Applicant & NRC Staff Response to Necnp Contentions on Spmc.* Certificate of Svc Encl ML20196A3991988-06-22022 June 1988 Reply of Massachussetts Atty General to Responses of NRC Staff and Applicant to Contentions 7 Through 83 Filed by Massachussetts Atty General.* Certificate of Svc Encl ML20196A5261988-06-22022 June 1988 Town of Amesbury Reply to NRC Staff & Applicant Responses to Town of Amesbury Contentions on Seabrook Plan for Massachussetts Communities.* Certificate of Svc Encl ML20196A8701988-06-20020 June 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to First Six Contentions Filed by Commonwealth of Ma Atty General.* ML20151N6271988-06-17017 June 1988 Town of Salisbury Reply to Applicant Response to Intervenor Contentions on Seabrook Plan for State of Ma Communities ML20151A8361988-06-17017 June 1988 Reply of Town of West Newbury to Responses of Applicant & NRC Staff to Intervenors Contentions Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl ML20151N6461988-06-17017 June 1988 Town of Salisbury Amended Contentions Re Applicant Plan for State of Ma Communities.Certificate of Svc Encl 1999-07-20
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] |
Text
1 o
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L, ,,
DOCKETED usuc UNITED STATES OF AMERICA
.h p 16 /di:53 NUCLEARREGULATORYCOMMISSIOf[CE[Tnqs 0~ SECREru ,
- ,_ ,g
- ATOMIC' SAFETY AND LICENSING BOARD Before Administrative Judges:
Helen F. Hoyt, Chairperson Emmeth A. Luebke Jerry Harbour
)
In the Matter of ) Dockst Nos. 50-443-OL
) 50-444-OL PUBLIC SERVICE COMPANY OF )
et al. )
NEW HAMPSHIR3, (Seabrook Stati E,Tnits 1 )
and 2) ) September 9, 1983
)
CONTENTION OF ATTORNEY GENERAL
, FRANCIS X. BELLOTTI RELATIVE TO EMERGENCY l PLANNING FOR THE NEW HAMPSHIRE BEACH COMMUNITIES l
l . On August 23, 1983, the' Board ordered that contentions relating to off-site emergency planning for any or all of the l fif teen New Eanpshire communities for which draf t emergency plans were recently submitted 1! be filed on or before this date. In accordance with that order, Attorney General Bellotti hereby submits a single contention which relates to off-site i 1/ Obe fifteen communities are Hampton, Newton, Rye, Stratham, l Exeter, New Castle, North Hampton, Seabrook, Brentwood,
! -Kensington, Newfields, Portsmouth, South Hampton, East Kingston, and Kingston.
8309190357 830909 PDR ADOCK 05000443 j O PM
emergency action in the coastal beach areas of Seabrook,
'Sampton, North Hampton, and Rye which are frequented by Massachusetts citizens.
CONTENTION:
The-draft radiological emergency response plans for the Towns of Seabrook, Hampton, North Ha:npton, and Rye do not provide reasonable assurance that adequate protective' measures can and will be taken in the event of a radiological emergency at the Seabrook Station, as required by 10 C.F.R. 550.47(a)(1),
because in the event of a severe' acc: dant on a summer weekend some or all of the beach area transient populations within those communities cannot under many p~.ausible meteorological conditions be protected by means of evacuation even from early death and because there are not adequate plans or provisions for sheltering the beach area transients within those
. communities.
BASES:
The draft emergency response plans for the Towns of Seabrook, Hampton, North Haupton, and Rye all rely on evacuation and sheltering as the two options for protecting persons present in those communities at the time of a radiological emergency at Seabrook Station which results in a radiological release to areas within those communities. See, e.c., Seabrook Plan, at II II-18; Rye Plan, at II II-18; North Hampton Plan, at II II-20; and Hampton Plan,
at II II-20. However, a preliminary site-specific
-accident. consequence ,
analysis performed for the Massachusetts Attorney General has revealed that, given the unus'ual J .:
/ circ'umstances associated with dense beach populations,
.svac'hation cannot protect the transient beach area populations inthevicinity.oftheSeabrooksitefromearlhdeathinthe event of a PWR 2 release as defined in the NRC's Reactor Safety Stucy (WASH-1400) on a summer weekend.
A Seabrook-specific accident consequence analysis is being performed for the Department of the Attorney General by Dr. Jan Beyea, a nuclear physicist with extensive experience in accident consequence modelling and analysis. (A copy of Dr.
. Beyea's resume is attached hereto as Exhibit A and incorporated herein by reference.) Dr. Beyea has advised the Department that there are unique considerations involved in the modelling
~
j-1 'and analysis of accident consequences for a site such as 4 Seabrook having a large summer beach area population which have r
[
never before been taken into account in generic or site-specific. consequence studies., In addition to the obvious
. effects on accident consequences of the increased population and evacuation times associated with summer beach areas and the absence of shielding normally provided by buildings, there are increased consequences due to material deposited directly on the skin and hair of beachgoers and on vehicles in the plume.
The former factor has received no consideration in accident l
consequence analyses in the_past and the latter has received inadequate consideration. -
In the work which Dr. Beyea and his assistant' Brian palenik, a graduate student at the Massachusetts Institute of Terinology, have performed for this Department to date they have investigated the conditions under which the nearest beach population to this site, at about two miles, might be exposed to doses at a threshold level for early death (200 rem) in the event of a PWR 2 release as defined in the Reactor Safety Study
(~n'ASE-1400 ) . Estimates of the time within which that population would receive a 200 rem dose have been calculated for various veather stability classes and wind speeds using two sets of assunptions. The first set assumes that all persons are inside automobiles when the release occurs and receive only a fraction of the doses they would receive if they were in the open, exposed directly to a plane of contaminated ground.
9
. These results have-been calculated using the assumptions which have beretofore been considered standard in accident consequence calculations. The second set of results goes beyond the standard assumptions, to account specifically for the Seabrook beach situation. Those results assume that some of the population will not have reached their vehicles before pinse passage such that there will be a " skin deposition dose"
- and a " car deposition dose." For each of the two sets of results calculations have been performed separately for high
-3_
and lov energy release rates. This division was necessary l l
given the large encertainty in the height to which the radicartive plume will rise, a factor which is affected by i emergy release rates and which is an important determinant of the doses to a nearby population.
Celes I and 2, which follow hereafter, contain the results of Dr. Beyea's modelling and analysis as described above. The entries it the last column of each table result from a com.sarison between the time required to reach a 200 rem dose and current estinates of the time required to evacuate the pop:1ation within two miles on a summer weekend. See Table 3.
The data set forth in these tables reveal that the summer wester.d beach population within two miles of the Seabrook site cannot be protected from early death by means of evacuation ander nacy weather conditions.
I: sbo:ld be noted that neither precipitation nor slow wind
~. g speeds have been considered in the analyses set forth in Tables i
1 a:d 2. 3 ort such conditions are more severe than those ,
represented it the tables. The frequencies of the Pasquill statility classes reflected in Tables 1 and 2 as reported in
- be~ Applicants' ER-OL are given in Table 4. The frequencies of Ibe A, 3, and C stability classes increase during the summer Ic :ts, vi:h C the rost frequent of the three. D and E are the im-" nan: stability classes. The results discussed herein are
-:::. :terefore, based on infrequently occurring or worst-case vea:ter conditions.
~
TABLE 1 FROTECTION OF CLOSEST BEACH POPULATIONa)
FROM EARLY DEATH ON A SUMMER WEEKEND DAY EIGH ENERGY RELEASE RATED)
Dose Stability:) Wind Speed Scalingd) Time to Reach Protection *I Class (z/sec) Factor 200 rem of Population?
A 2 .53 .78 14.5-20.9 Yes A 2 1.0-1.3 9.0-11.5 Yes A 4 .53 .78 > 24 Yes A 4 1.0-1.3 19.2-25.0 Yes E 2 .53 .78 4.6-6.'4 No E 2 1.0-1.3 3.2-3.8 No
~E 4 .53 .78 12.2-17.8 Yes 9
E. 4 1.0-1.3 7.6-9.6 Yes C 2 .53 .78 2.6-3.4 No C 2 1.0-1.3 1.9-2.2 No C 4 .53 .78 8-11.5 Yes C- 4 1.0-1.3 5.1-6.4 No ,
D 2 .53 .78 )> 24 Yes C I 1.0-1.3 )* 24 Yes L 4 .53 .78 6.5-9.2 Yes E 4 1.0-1.3 4.2-5.3 No
- c. ::s po;; a:io two miles from the plant.
- J.ss'er.er an ens gy release rate of 176 x 106 Btu / hour.
-c; Fasq ill stability class.
'd : 7:e dose scaling f ae:o: range of .53 .78 assumes an individual is in a car v4-~-'- --* pS-* "he dose scaling factor range of 1.0-1.3 assumes ar. : d vidral is in a car within the plume, with a dose component from rad: a tive raterial deposited on the car and directly on the individual, o,. F:::*ctit: cf ::e popciation from a 200 rem dose or higher. This ass;m== =- traccatic: time of about five and a half hours. If the e v a:_ ati:: zire is 1:nger, the population is not necessarily protected.
a TABLE 2 PEOTECTION OF CLOSEST BEACH POPULATIONa)
FEOM EARLY DEATH ON A SUMMER WEEKEND DAY LOW ENERGY RELEASE RATEb)
Dose StabilityC) Wind Speed Scalingd) Time to Reach Protection
- Class (m/sec) Factor 200 rem of-Population?
A 2 .53 .78 13.8-19.9 Yes A 2 1.0-1.3 8.6-10.9 Yes A 4 .53 .78 )>24 Yes A 4 1.0-1.3 18.4-23.7 Yes E 2 .53 .78 3.7-4.9 No E 2 1.0-1.3 2.5-3.0 No E 4 .53 .78 9.9-14.2 Yes E 4 1.0-1.3 6.2-7.8 Yes C 2 .53 .78 4,1 No C 2 1.0-1.3 <[1 No C 4 .53 .78 l 1.7-2.2 No C 4 1.0-1.3 1.3-1.5 No ,
D 2 .53 .78 <[ 1 No D 2 1.0-1.3 (, 1 No D 4 .53 .78 <[1 No 0 4 1.0-1.3 <C 1 No
- a. Tr.e p gulatio two tiles from the plant.
- Ass';2er an energy release rate of 20 x 106 Btu / hour, or an equivalently Icw pitme for reasons unrelated to the energy release rate.
- P asquill stability class.
d, :e d:ss scaling factor range of .53 .78 assumes an individual is in a d- '
--c piers. The dose scaling factor range of 1.0-1.3 assumes car vi-an ind vidual is in a car within the plume, with a dose component from radicarnive-ta:erial deposited on the car and directly on the individual.
- o. 7:::+::100 cf :ts population from a 200 rem dose or higher. This a s z;m e an evac;a:icn time of about five and a half hours. If the eta: ation tire is longer, the population is not necessarily protected.
l i
2ABLE 3 SEABROOK EVACUATION CLEAR TIME ESTIMATESa)
SUMMER WEEKEND / FAIR WEATHER SCENARIO Radies Degrees HMMb) Vorhees c) Maguire 0I NRC*
0-2 360* 4:50 5:10 5:40 ---
0-3 180' E 5:20 --- --- ---
0-5 360' 5:50 5:10-5:40 --- ---
0-10 360* 6:05 -5:10-6:10 5:50 11:25 c, Tims (tours: minutes) for the population to clear the indicated area after notification.
b; Pre'isinary Evacuation Clear Time Estimates for Areas Near Seabrook Starion, EMM Document No. C-80-024A, HMM Associates, Inc., May 20, 1980.
c1 Final ?.eport, Estimate of Evacuation Times, Alan M. Vorhees & Associates, July 1980.
d) Etergsccy Planning Zone Evacuation Clear Time Estimates, C.E. Maguire, I r. c . , Feburary 1983.,
- 0) Ar. :ndependent Assessment of Evacuation Time Estimatos for a Peak Pop:lation Scenario in the Emergency Planning Zone of the Seabrook
!iaclear Power Station,.M.P. Mueller, et al., Pacific Northwest Laboratory
!;CRIG/CR-2903, PNL-4290.
e
TABLE 4 FREQ7ESCY OF PASQUILL STABILITY CLASSES AT SEABROOKa)
(values in % of Time)
Month A B C D, E_ F G, Apr 1979 1.27 2.11 3.80 49.65 29.40 7.88 5.91 May 1.23 2.86 4.82 52.86 26.51 5.27 6.48 Jun 2.92 6.69 12.26 39.83 25.49 6.13 6.69 Jul 4.93 6.94 11.56 29.12 28.84 12.65 5.99 Aug 2.91 4.71 9.97 43.07 26.59 7.34 5.40
-s ,
Sep 1.25 7.64 11.81 30.69 27.36 10.83 10.42 Oct 3. 8- - 2.96 5.79 39.30 34.05 10.09 7.00 Nov 0.0L O.56 4.76 43.92 34.83 9.37 6.57 Dac 3.00 0.41 2.70 47.03 41.35 5.81 2.70 Jan 1950 3.13 1.88 6.59 51.88 30.38 5.78 3.36 Feb 3.44 1.03 5.37 50.36 34.69 5.66 1.45 Mar 13. 6 E 1.64 5.34 43.15 24.66 6.03 8.49
. Yearly 1.21 1.37 7.08 43.31 30.38 7.76 5.87 c; Ps:iod cf Record: April 1979 - March 1980. Stability class calculated ts ng -43 '-209 ' delta temperature. Source:' SB 1&2, ER-OLS, Table 2.3-24.
4
_ .- - . ~ . . y,
-w-- re,<w- -
, ~ ,-
The size of the beach area population around Seabrook is tacertain. One estimate of this population for 1980 has been sade by Public Service Company of New Ziampshire and is found in Table 5. Although its accuracy is uncertain, this estimate
.does indicate that a substantial number of people are located withir. two miles of the plant. The number of persons that wocid be located within a plume obviously varies with wind direction, but it also varies with stability class and distance f:cm the plant. At two miles the plume could be viewed as beine between a 29' wedge (A stability class) and a 13* wedge (D stability class)2/ compared to the 22.5 population wedges in the table.
In addition to investigating the conditions under which the beacc population within two miles of the Seabrook site might be exposed to early death doses, Dr. Beyea and Mr. Palenik have co=menced work designed to determine the radius within which early deaths might result in the vicinity of this site assuming ac accidental release on a summer weekend. Dr. Beyea has found .
early death radii ranging from <2 to 4.3 miles assuming a PWR 2 release as defined in the Reactor Safety Study (WASH-1400), C stability class weather conditions, an evacuation time of 5-1/2 hours, and the two sets of dose scaling factors discussed pr evi ously. For. weather conditions with overcast skies (D 2/ 'Redges are assumed to have plume widths equal to three tires the horirontal dispersion coefficient.
TABLE 5 19E0 EEACE AEEA TRANSIENT POPULATION ESTINATEa) BY SECTORD)
El:g- Iadii (niles; NI ENE E ESE SE SSE 0-1 D 0 0 0 0 0 1-2 464 '
14,647 12,780 5,842 129 23 2-2 1,;04 8,882 0 0 3,905 654 3-4 E,719 608 0 0 0 6,198 4-5 4,244 0 0 0 0 8,880 5 -1~ 5,E60 0 0 0 0 16,597 Source: Fublic Service of New Hampshire, Seabrook Station - Units 1 & 2, Environnectal Eeport, Operating License Stage, Figure 2.1-19.
c Estimate of peak transient population found by multiplying the capacit'y of ~:eacs area parking lots (less leased space) by 3.2 persons per vehicle, and contributions f rom of f-street parking users, seasonal res; den:s, End overnight visitors, b; Eac: direction in the table is the centerline of a 22.5 degree wedge.
l l
. , , . . - , - . - , , - - - ..-n.. - --
r
.- stability class), or longer evacuation times,3/ the early death :adii will be larger. And the time before doses reach 20C Cen, assuming a PWR 2 release on a summer weekend evening and a ~ow energy release rate such as that assumed in the draft Seabro:k Probabilistic Risk Assessment, is less than four hours cat to 6-7 =iles f rom the site. Thus, the beach area pop:lation within 6-7 miles exposed to the plume would not be prc:ected from early death even if there were a 20-30 percent red:ction in evacuation times from daytime to evening. It she:ld be noted in this connection that at least the Hampton Beach area has a very substantial nighttime population.
Ch's, a prinary accident consequence data developed for this Depir:nect reveal that evacuation cannot under a number of pla:sible weather conditions protect the summer weekend beach area peptlations in the vicinity of this site from even early death . The results described herein do not account for the less severe consequences of radiation illness and delayed fattlities due to latent cancers. Despite the severe .
IL=itations oc the utility of evacuation as a protective option fer the transient beach population, however, there are
~
l Oc::e=tly no provisions for sheltering that populatien within
-c ro t . Neither the New Hampshire Radiological Emergency 3/ =e Applicants have now provided a 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 5 minutes is::: ate fcr s -rer weekend simultaneous beach evacuation v'- '- en ciles of the site. See Applicants' Direct Testimony 5:. .. filed Caly 15, 1983, at 19-20.
I t
F.esponse Plan nor the local community plans contain any analysis of available public sheltering, or its capacity to secommodate the beach populations or to provide shielding from radionuclides, or any plans for effecting such sheltering. In shcrt, there is at present no basis for (and has not been) any deve_optent of sheltering as a potential protective action for the 'each c population.
Respectfully subatted, FRANCIS X. BELLOTTI ATTORNEY GENERAL By: A s "
sh JO ARN SHOTWELL Assistant Attorney General Environmental Protection Division One Ashburton Place Boston, MA 02108 (617) 727-2265 i
L
r "
" EXHIBIT A"-
. E**M 3h /
Fr..D., Columbia University,1968 (fluclear Physics)
E. A_ , Acherst College,1962 Er?'.CwE;C .-!ISTORY:
1 5E,0 te' date, Senior Energy Scientist, :tational Audubon Society, '
950 Third Avenue, New York, llew York 10022.
.97E to 1980, Research Staff, Center for Energy and Environmental Studies, Prir.ceton University.
5 0 I: 2976, Assistar.t Professor of Physics, Holy Cross College.
..:H to ;970, :.esearcn Associate, Columoia University Fnysics Department.
. . . .: _ . . . .e cs . r. ..
- . al:an: cn nuclear energy to tne Office of Tecnnology Assessment, the New
. sese. +:arrent cf Envircnmental PrctEction the ' Offices of the Attorney General in
. ::r. 5 tate and the Ccronweal th. of :4assachusetts; the state of lower Saxony in
.ss: Ee mar.y; :.a Swedish Energy Commissior; and various citizens' groups in the
.' ' e: E .ates.
- E_- : :CG IC CEE*;I:45 EifERGY CONSERVATION IND ENERGY POLICY:
C:r .er.:s er Energy Forecasting," r.aterial submitted fer the record at
- e ' ea-ings ~ sft-re tne Sunconr.ittee on Investigations and Oversights of the
- -i: se en Science ar.d Tecnnology, U. 5. Ecuse of Representatives; Committee -
I'i- t. 7:.:.e 1, 2, 1951 / !!c. 14 /.
T-e kcson Energy P'an Technical Re;: ort," Peterson, Beyea, Paulson and
.: e". :iaticr.ai kddon Ecciety, Acril 1981.
[
L:cating and Eii=trI4 ting Obscure but Major Energy Lesses .in Residential 4:.si ;." Earrje, N:t and Beyea, ASHRAE Transactions , 85, Fart II (1979).
E'.~er .f. ASH:.AE c::tstanding paper award. )
ric Eeat 1. css and Conservation Policy," Dutt, Seyea, Sinden. ASME Te:-- .:r._y and ic:iety Division paper 78-TS-5, Houston. Te>.as,1978.
'C~=ments or. :he proposed FTC trade regulation rule on labeling and adver-
's' : of the:- al insulation," Jan Beyea and Gautam Dutt, testimony before the
- e:s-si Trade Co"T-ission, January 1978.
6 ^ ~.-frical Sf grificance of ' Attics and Baserents in the Energy Balance of
- i- :#ters Ted. arses." Seyea, Dutt, Weteki, Enercy e d Buildings,-Voluw .I
- :i;e ?f'.. T.s: C*.arter 3 of Saving Ener y n :ne Home, Ballinger, 1975.
! e ':: :ss' star.:e **:cei for Attic Hea- Flew: Italications for Conservation
- ^ :; . E::ed , '.. .:, Eeyea , Enerev--tne !nternational Journal , 3, 657 (1976).
E.er;y-C:.se-va:'cr i- an Old 3-Story Apartment Cc' plex." Beyea, Farrje, e . E.e ;:. .se Macareeert, Fa::clare and Snitn, Pergamen 1977, Volu"'e I,
- s. .=. . . . .
.:a: 5.- F:'-: -e:r-i des Usine H re A?;liances," Jan Sefea, Rober: Weathervax,
-E t ; . s e 'ea .a re :. r :::lare a anc Srith, Pergamen 1978, Volume 111/!'.',
.:,..,.r...-
. 1 - P8.~o's*,1CM10NS CONCERNING. ENERGY R15KS:
f: Articles: , _ . . ,
.~- - "Contairraent of a Reactor Meltdown,"lwith Frank von Hipp'el),
~
Eulletin of the Atomic Scientists , 38., 8Page 52, December 1982.
r . .-
- . "Second Thoughts'.(about Nuclear Safety)," in Nuclear Power: Both Sides, W. W. Norton and Co. (New York,1982). -
~
"Incoor Air Pollution," Commentary in the Builerin of the Atomic Scientists, E, Face 53, February 1981.
"Erergency Planning for Reacter Acticents," E.lietin of tne Atomic i:ie tists, 36, Page 40, December 1980. ( An earlier version cf tnis article
-a:: care: in E an. as Chapter 3 in im Ernstfall hGfics?, E. R. Koch, Fritz
' ahrtr.hcit, editors, Kiepenheuer & W1 scn, Coicene,1980.)
" Dispute at Indian Point," Bulletin of the A:cric Scier.tists, 3, Page 63, F.ay 1980. .
F.t'ished Debates:-
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!.ine , .5.5.5. Televi sion. Transcript printed by 50.;thern Educational Communications Association, S28 Woodrow Street, P. O. Box 5956, Cciu bia, Scuth Carolina,1979.
- 'uclear Reactors
- How Safe Are They?, panei discussion sponsored by 'the
- . A:Ede:rf foru: of The National Academy of Sciences, 2101 Constitution Avenue,
. . L'as' n ington, D. T 20418, May 5, .1980.
Re:cr s: . . .
"I::plications for.: Mortality of Weakening the Clean Air Act," (with
- . - G. Steve Jordan), National Audubon Society, Environmental Policy Analysis '
. Depar: ment Report No.18, May 1982.
i
- "Some Long-Term Corisecuences of Hypothetical Fajor Releases of Radioactivity I
- the A::nosphere from Three Mile Island," Report to the President's Council on
~
.' Enyjronmental Quality, . December 1980.
" Decontamination of Krypton 85 from Three Mile Jsland Nuclear Plant," (with
. rer.dall, et.al.), Report of the Union of Concerned Scientists to the Severne cf Pennsylvania, May 15, 1980.
'Some Cor:9ents on. Consequences of Wypothetical Reacter A: idents at
- e ';nfli:;;ines !;uclear Power Plant" (with Gercen c :sen) . ::ational Aucucen Socie-E t re:mer. .al Policy Analysis Department Report :::. -
~
- iutiear Reactor Accidents: The Value of Improved Containment," (wi-h Frank ve : ?.ippel), Center for Energy and Environmental Studies Report PU/ CEES 94,
- ri-:e r. University, January 1980.
"The Effects of Releases to the Atocsphere of Racioactivity from Fyp thetical
.arce-Scale Accidents at the Proposed Gorleoen as:e Treatment Facility.' report 4
tc .ne 2 Govern ~ent of lower Saxony, Federal Republic cf Germany, as par. cf the
'Gorleben International Review," February 1979 e a-- = n- W
_s.
.=.-
?c -s (Cast'd_):..
~e Safet;y Research at the Large Consequence End of the Risk Spectrum,"
. .. preserad to the Experts' Heeting on Reactor Safe.ty' Research in tha Federal
. ;E;Pdifc of Germany, Bonn, September I,1978.
A Stx*v of h of the Consecuences of Hycothetical Reactor Accidents at Ea-s= 7-. reper; to the Swedish Energy Co=nssion Stocknolm, DS 1 1978:5,
-arr.aa-y 1978. . __ _
h ^.: n ....
'E: E !.: .se aen:es cf Catastrc: hic l t:idents at :ndian Point anc ineir
- . P:. arises fer E=ergency Planning," testimony anc cross-examination before the I.:Cler- Feg la = y Ca=nissicn's Atomic Safety and Licensing Board, en behalf of
.e .a.: hart 5:a e AIwrrey General anc ::ners, July 1982.
"'Ir. :he Parter cf A plication of C-angt and Rockiand Counties, Inc. for br-wsi:r. : Cosi of Lcvett Units 4 ar.d 5, testi..onj and cress-examination on
.e 'aml:1 icac s of eliminatinc scrunners as a recuirerent for conversion to
=50: :e ar : e.-t :f Environmental Resources 5:ste ci :;ew York, ricvember 5,1981.
- m. :- ec s for C==,erciai ;ucle ar Dower ir. The United States," before l's I__~. _ .-:-_es c= Eversight and Inves ti ga .i ors , Cc"-i ttee on Interior and
- E:ia - E .'hs, U 5. r ieuse of Representatives , Oc:cter 23. 1981.
5 . k::ilf:g crf Potassie= 1odice for tne General Fut.1ic as a Condition for.
b c :" 7EI 1::it2:3. 1," testimony and cross-exacination before the Atomic' 5Ef H7 Erd Utensi=g Board on behalf of the Anti-!;uclear Group Representing isrt,. April 3961. ._
. dice at:d Rh.wncations Concerning Chances in Reactor Design and Safety 4.a sis P..i= 5:s:Af l .e_Recui red ir. Li;'.: r of the Acci ent at inree M.ile Island,"
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snes.ent = cae R.sclear Regulatory Cor-ission concerning the proposed rulemaking
.ca:iss c: degrzsed cores, December 29, 1980.
"~~i
.- ernztives is the Indian Point !!uclear Reactors," Statement before the l En-i ... - =. cal :7..ec-ic Co.....ittee of the i;ew York Ci ty Ccuncil , December 14, 1979.
l Es= :.efc s ~_M Littee, "The I= pact on f;ew Ycrk City of Reactor Accidents at bdNan Pcisst," 2:ne 11,1979 Also " Consequences of a Catastrophic Reactor A:=i/=~ ." w t to the Hew York City Board of Health, August 12, 1976 (with F7-* ves: feippe1).
Ew-: . lan. int for a Catastrophic Reacter accicent," Testimony before l re Calif. ~ia Emery.y Resources and Development Coeission, Emergency Response a: E =-*=ri:n : ans F. earings, Nove ber 4, 1975, Page 171 5 c -'s- Effe::s Of a:as trcphic accicer.:s en Ec ..u :ities Sur-cu-c'ng tne l 1 :sse- .se:iear Installation," testiecr.y be fore :ne Califernia Energy Resources 2_: ".s reir:mme=t er-issier., December 3,1976.
.-' meeter.:ss :f Catas trechic Accicents at James: r . " Testimeey re'_ -e:a se.c : - < State Ecard on Electric Genera: ice Sit ng and the Enn onment i i- -14 Ma ter cf I.c .9 Island Lighting Comsany (Jawsocr- !4uclear Power I .Iri:r_ Lv.i s : an: 2),P.a.. 1977.
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- r'mts on WASH 1400 " Statement to the Subcommittee on Eneroy and the w Oversloht Hearinos on Reactor-Safety.' June 11, 1976, Serial No. 94-61,
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d 00LKE1ED USNE CERTIFICATE OF SERVICE
'83 97 16 21:53 I, Jo Ann Shotwell, Esquire, counsel for Massachusetts Attorney l General Francis X. Bellotti, hereby certify th4tagnose ember 9, 1983, I ;
rade service of the Motion of Attorney GeneralInfl SEF dE'-
Reconsideration of Board Ruling Re Examination of P q' ration Time, Ection of Attorney General Francis X. Bellotti For Clarification of Board order Dated August 30, 1983 and Contention of Attorney General Francis X.
Bellotti Relative to Emergency Planning For New Hampshire Beach Cc:2a-izies by nailing copies thereof, postage prepaid, to the parties camed below:
Eelen Hoyt, Chairperson
- Rep. Beverly Hollingworth Atatic Safety and Licensing Coastal. Chamber of Commerce 3 card Panel 209 Winnacunnet Road C.5. Fuclear Regulatory Commission Hampton,'NH 03842 Washington, DC 20555 Cr. Immeth A. Luebke* William S. Jordan, III, Esquire At:mic Safety and Licensing Diane Curran Board Panel Harmon & Weiss C.S. Euclear Regulatory Commission 1725 I Street, N.W.
Washington, DC 20555 Suite 506 Washington, DC 20006 D r. Jerry Earbour* Edward L.- Cross, Jr., Esquire Atcmic Safety and Licensing Assistant Attorney General Soard Panel Dana Bisbee, Csquire
,U.S. Naclear Regulatory Commission Assistant Attorney General Washington, DC 20555 Office of the Attorney General 208 State House Annex .
Concord, NH 03301 Atomic Safety and Licensing Appeal Roy P. Lessy, Jr., Esquire
- Eoard Panel David A. Repka, Esquire
- U.S. Naclear Regulatory Commission Robert G. Perlis, Esquire
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a Atonic Safety and Licensing Robert A. Backus, Esquire Board Panel
- 116 Lowell Street C.S. Euclear Regulatory Commission P.O. Box 516 Washirston, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Dr. Mauray Tye Assistant Attorney General Sun Valley Association Department of the Attorney 209 Summer Street General Haverhill, MA 01830 Augusta, ME 04333 a7id R. Lewis
- Thomas G. Dignan, Jr., Esquire **
Atomic Safety and Licensing Robert K. Gad, III, Esquire **
Soard Panel Ropes & Gray C .3. Suclear Regulatory Commission 225 Franklin Street E=. 3/W-439 Boston, MA 02110
~4ashirgron, DC 20555 Er. Jchn B. Tanzer Ms. Olive L. Tash Eesigrated Representative of Designated Representative of the Town of Hampton the Town of Brentwood 5 Morningside Drive R.F.D. 1, Dalton Road Earp:cn, NE 03042 Brentwood, NH 03833 Roberta C. Pevear Edward F. Meany Designated Representative of Designated Representative of the Town of Hampton Falls the Town of Rye Drinkwater Road 155 Washington Road Earpten Falls, NH 03844 Rye, NH 03870 W-= cacdra Gavutis Calvin A. Canney Designated Representative of City Manager rhe Town of Kensington City Hall Er3 'l 126 Daniel Street l East Eings ton , NH 03827 Portsmouth, NH 03801 ,
i ratrick J. McKeon Jane Doughty Selectmen's Of fice Field Director I
10 Central Road Seacoast Anti-Pollution League
! Rye, N3 03870 5 Market Street Portsmouth, NH 03801 Richard I. Sullivan, Mayor Docketing and Service Section l
Town Hall Office of the Secretary Newbc ryport , KA 01950 U.S. Nuclear Regulatory Commission Washington, DC 20555
- 3y Hand Delivery on 9/12/83 1
i r
e Brian P. Cassidy Representative Nicholas J. Costel l Regional Counsel 1st Essex District l FEMA Region 1 Whitehall Road John W. McCormack Post Office Amesbury, MA 01913
& Courthouse Boston, MA. 02109 Mr. Angie Machiros, Chairman Diana P. Randall Newbury Board of Selectmen 70 Collins Street Town of Newbury, MA 01950 Seabrook, NH 03874 Patrick J. McKeon Anne Verge, Chairperson Chairman of Selectmen, Rye, Board of Selectmen New Hampshire Town Hall 10 Central Road South Hampton, NH 03842 Rye, NH 03870 Donald E. Chick Maynard B. Pearson Town Manager Board of Selectmen Town of Exeter 40 Monroe Street 10 Front Street Amesbury, MA 01913 New Hampshire 03833 Selectmen of North Hampton Mr. Daniel Girard Town of North Hampton Civil Defense Director New Hampshire 03862 25 Washington Street Salisbury, MA 01930 Senator Gordon J. Humphrey Senator Gordon J. Humphrey 1 Pillsbury Street U.S. Senate Concord, NE 03302 Washington, D.C. 20510 (Attn: Berb Boynton) (Attn: Tom Burack)
Signed under the pains and penalties of perjury, this 9th day of September, 1983.
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A/ Ann Shotwell Wssistant Attorney General Environmental Protection Divisior Public Protection Bureau One Ashburton Place Boston, MA 02108 1
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