ML20148L937

Applicants Response to Atty General Jm Shannon Offsite Emergency Planning Interrogatories & Request for Production of Documents to Applicants (Set 3).* Certificate of Svc Encl.Related Correspondence

ML20148L937
Person / Time
Site:	Seabrook
Issue date:	03/28/1988
From:	Lewald G, George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
References
CON-#288-5982 OL, NUDOCS 8804050045
Download: ML20148L937 (31)

Text

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4 7-EtN.t0_CORRESPONDENC3 00CKETED USHFC March 28, 1988 26 KM 31 P4:21 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-Och7fd[$$J/'

BRANCH before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues l

)

)

APPLICANTS' RESPONSE TO ATTORNEY GENERAL JAMES M. SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANTS (SET NO. 3)

INTERROGATORY NO. 1 Ouestion:

Identify all documents on which you will rely to support your position on the sheltering contentions, and produce all such documents not previously produced. Identify the information in each document on which you will rely and the specific subpart of each contention which that information concerns.

Resconse:

As of this time, Applicants may rely upon some or all of l the following and reserve the right to rely on additional l

documents as the need arises.

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1. NHRERP, Volume 4, Appendix F and Volume 4A, Appendix U, Protective Action Decision Criteria. Protective Action Decision Making for Seasonal Beach Populations, Protective Action Recommendation Worksheet, e.nd Attachment C. As to all sheltering contentions and subparts thereof.

2. NHRERP, Volume 1, Section 2.6.7, Figure 2.6-7, Decision Criteria for Selecting Between Evacuation and Sheltering Recommendations for the Governor. Description in Section 2.6.7 Criteria for Sheltering Protective Actions for Direct Exposure Within the Plume Exposure EPZ (p. 2.6-24). As to all sheltering contentions and subparts thereof.

3. Protective Action Evaluation, Part 1, The Effectiveness of Sheltering as a Protective Action Against Nuclear Accidents Involving Gaseous Releases, EPA-520/1-78-001A, April, 1978. Shelter structure model and fallout gamma source attenuation. As to all sheltering contentions and subparts thereof.

4. Protective Action Evaluation, Part II, Evacuation and Sheltering as Protective Actions Against Nuclear Accidents Involving Gaseous Releases, EPA 520/1-78-001B, Revised 8/78. As to all sheltering contentions and subparts thereof.

5. NUREG-0654, FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and

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Preparedness in Support of Nuclear Power Plants, Evaluation Criteria J and Appendix 1, Emergency Action Level Guidelines for Nuclear Power Plants. As to all sheltering contentions and subparts thereof.

6. Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-520/1-75-001, Revised June, 1980. As to all sheltering contentions and subparts thereof.

7. NHRERP, Volume 1, Section 2.6.5, Protective Actions for Direct Exposure Within the Plume Exposure EPZ. As to all sheltering contentions and subparts thereof.

8. A Study to Identify Potential Shelters in the Beach

. Areas Near Seabrook Station, Stone & Webster Engineering Corporation, August 1987. As to all sheltering contentions and subparts thereof.

9. NHRERP, Volume 6, Seabrook Station Evacuation Time Study. Evacuation Time Estimates for the general population. As to all contentions and subparts thereof.

10. Federal Emergency Management Agency, Radiation Safety in Shelters, CPG 2-6.4, September 23, 1983. (Estimate shelter capacity by dividing total available space by 10, p. 4-9.) As to all contentions and subparts thereof.

11. Aldrich, et al., Public Protection Strategies in the Event of a Nuclear Reactor Accident: Multicompartment

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Ventilation Model for Shelters, SAND 77-1555. As to all contentions and subparts thereof.

12. Aldrich, 31 al., Public Protection Strategies for Potential Nuclear Reactor Accidents: Sheltering Concepts with Existing Public and Private Structures, SAND-77-1725. As to all contentions and subparts thereof.

13. Structure Shielding from Cloud and Fallout Gamma Ray Sources for Assessing the Consequences of Reactor Accidents, EG&G, Inc., Las Vegas, Nevada, EGG-1183-1670 (1975). As to all contentions and subparts thereof.

14. NFPA 101, Code for Safety to Life from Fire in Buildings and Structures (Life Safety code) 1985 Edition. As to all contentions and subparts thereof.

15. American Society of Heating, Refrigeration Engineers Standard (ASHRAD) 062-1981. As to all contentions and subparts thereof.

16. State of New Hampshire response to FEMA Supplemental l Testimony dated February 11, 1988, Enclosure 1 and Attachments 1 and 2. As to all contentions and subparts

! thereof.

17. Applicants' Direct Testimony No. 7, with attachments.

18. Applicants' Direct Testimony No. 6, with attachments.

l 19. Applicants' Supplemental Analysis of the Stone & Webster Shelter Study transmitted by letter from Terry L.

Harpster to Richard H. Strome dated February 11, 1988.

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20. Testimony of Dr. Joan Hock, Joseph H. Keller and William R. Cumming on behalf of the Federal Emergency Management Agency on sheltering / beach population issues, dated March 14, 1988.

INTERROGATORY NO. 2 Ouestion:

State whether you have relied, do rely, or will rely on any study, calculation, or analysis to support your position on the sheltering contentions. If so, to the extent you have not already done so, please:

a. Describe the nature of the study, calculation or analysis and identify any documents that discuss or describe the study, calculation or analysis;

b. Identify the persons who performed the study, calculation or analysis;

c. State when and where the study, calculation or analysis was performed;

d. Describe in detail the information or data that was studied, calculated or analyzed;

e. Describe the results of the study, calculation er analysis;

f. Explain how such study, calculation, or analysis provides support for your position on each of these contentions.

Response

As of this time, Applicants may rely upon some or all of the i following and reserve the right to rely on additional documents as the need arises.

a. 1. A Study to Identify Potential Shelters in the Beach Areas Near Seabrook Station, Stone & Webster l

Engineering Corporation, August 1987 as described

r in Applicants' Direct Testimony No. 6 dated January 6, 1988.

2. A visual inspection of 78 of 205 potential public shelters in Hampton Beach as described in Applicants' Direct Testimony No. 6 dated January 6, 1988.

3. Structure Shielding from Cloud and Fallout Gamma Sources for Assessing the Consequences of Reactor Accidents, EG&G, Inc., Las Vegas, Nevada, EGG-1183-1670 (1975) as described in Applicants' Direct Testimony No. 6 dated January 6, 1988.

4. Protective Action Evaluation, Part 1, The Effectiveness of Sheltering as a Protective Action Against Nuclear Accidents Involving Gaseous Releases, EPA-520/1-78-001A, April 1978, Table 2 which supports an assumption of an air exchange rate of 2 changes per hour as the maximum air exchange for a structure without ventilation, weatherstripping or storm sashes.

b. 1. Donald W. Bell, Senior Nuclear Technology Engineer, Stone & Webster Engineering Corporation.

2. NHY contractor personnel under the direction of Anthony M. Callendrello, Manager, Emergency Planning, New Hampshire Yankee.

3. Z.G. Burson and A.E. Profio, EG&G, Las Vegas.

4. George H. Anno and Michael A. Dore, U.S.

Environmental Protection Agency.

c. 1. August, 1987 ht Town Offices of Towns of Hampton and Seabrook.

2. June, 1987 at Hampton Beach.

3. March, 1975; location unknown.

4. April, 1978; location unknown.

d. 1. The information and data studied is described in detail in Applicants' Direct Testimony No. 6 dated January 6, 1988.

2. The information and data studied is described in detail in Applicants' Direct Testimony No. 6 dated January 6, 1988.

3. Radiation sheltering provided by transportation vehicles and structures typical of rabe"9 people live and work were estimated for -

a tnd fallout gamma ray sources resulting from a hypothetical reactor accident.

4. The general characteristics of small and large categories of shelter structures available to the public were studied. The basis shelter model I

characteristics considered were gamma ray attenuation, source geometry, gaseous fission-

! product ingress, and air change rate.

e. 1. The results are described in Applicants' Direct Testimony No. 6.

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2. The results are described in Applicants' Direct Testimony No. 6.

3. Wood frame structures without basements were assigned a dose reduction factor of 0.9.

4. Rooms or buildings with windows or exterior doors on three sides that have no weatherstripping or storm sashes were assigned infiltration estimates of 2 air changes per hour,

f. The results of each of the studies described supports the position that shelter as a protective measure for the beach population is not precluded.

INTERROGATORY NO. 3 Ouestion:

Do you intend to offer the testimony of any expert witness with respect to sheltering contentions? If so, please:

a. Identify each expert witness who you intend to present with respect to each subpart of each such contention;

b. State the substance of the facts to which each expert witness is expected to testify;

c. State the substance of the opinion or opinions to which each expert witness is expected to testify;

d. Provide a summary of the grounds for each opinion to which each expert witness is expected to testify; I e. State whether the facts and opinions listed in response to the foregoing are contained in any document;

f. State whether the opinion of any expert witness is based in whole or in part on any scientific rule or 1

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I principle, and, if so, set forth such rule or l principle;

g. State whether the opinion of any expert witness is based in whole or in part on any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon; and

h. State whether the opinion of any expert witness is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.

Response

As of this time, subject to possible later revision, Applicants would offer the testimony and the basis for it of the panel of expert witnesses identified in Applicants' Direct Testimony No. 6 as is presented in that document, along with an exhibit, attachments and the qualification of the witnesses, all of which has been served on the Board and parties.

INTERROGATORY NO. 4 Question:

Do you intend to offer the testimony of any non-expert witness with respect to the sheltering contentions to be litigated by the Attorney General? If so, please:

. a. Identify each non-expert witness who you intend to

! present with respect to each subpart of each such i contention;

b. State the substance of the facts to which each non-

expert witness is expected to testify; and i

l c. State whether the facts listed in response to the foregoing are contained in any document, and l produce the same.

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Response

Applicants object to the interrr.gatory as stated as inquiring into the work product and legal theory of counsel and further object on graut.ds that there is no provision in ths Rules of Practice for requiring the listing of "fact" witnesses.

INTERROGATORY NO. 5 Ouestion:

Identify, as defined in Paragraph 4, all experts and other persons you have retained to prepare testimony on the sheltering contentions and all experts and other persons with whom you have consulted in preparation of any testimony on the sheltering contentions, whether or not you have decided to introduce such testimony, and for each such person, please:

a. Identify the contention or subpart of the contention on which he was consulted, or on which he has or is preparing testimony;

b. State the substance of the facts to which each expert may testify;

c. State the substance of the opinicn or opinions to which each expert may testify;

d. Provide a summary of the grounds for each opinion to which each expert may testify;

e. State whether the facts and opinions listed in response to the foregoing are contained in any document; j

f. State whether the opinion of any expert is based in I whole or in part on any scientific rule or i principle, and, if so, set forth such rule or principle;

g. State whether the opinion of any expert is based in l whole or in part on any code or regulation, l

governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon; and i

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h. State whether the opinion of any expert is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.

Response

Applicants object to the interrogatory as stated for the reason that Mass. AG seeks trial preparation materials of the Applicants' counsel without a showing of exceptional circumstances and a substantial need of the materials, and that he is unable without undue hardship to obtain a substantial equivalent.

INTERROGATORY NO. 6 Ouestion:

In accordance with 10 C.F.R. 5 2.740(e), please supplement your answers with respect to sheltering contentions to Massachusetts Attorney General's Interrogatories and Requests for Production of Documents, filed March 5, 1987 and May 19, 1987.

Response

1. Supplement to Applicants' response to Mass. Attorney General Supplemental Interrogatory 45 to the Applicants:

The sheltering capacity for the population, including transients, in each New Hampshire beach are in the i

Seabrook Station plume exposure EPZ (with shelters

! having a minimal cloud shielding factor at least as effective as that assumed in the NHRERp) is provided in "A Study to Identify Potential Shelter in Beach Areas i Near Seabrook Station" performed for New Hampshire Yankee by Stone & Webster Engineering Corporation in l

August 1987. This study has been served on the parties in this proceeding.

2. Supplement to Applicants' supplemental response to Mass.

Attorney General's Interrogatory 91 to the Applicants:

Yes. This response is based on adequacy of shelter facilities per NHRERP Volume 1, Section 2.6.5 and the availability of sufficient facilities as documented in the Stone & Webster Engineering Corporation Study of August 1987, entitled "A Study to Identify Potential Shelters in the Beach Areas Near Seabrook Station."

3. Supplement to Applicants' supplemental response to Mass.

Attorney General's Interrogatory 98 to the Applicants:

NHRERP Volumes and the Stone & Webster Engineering Corp.

! study of August 1987 have been served on the parties.

Study worksheets and notes used to compile this study j have been placed in the Seabrook Station discovery room and have been made available for inspection.

4. Supplement to Applicants' supplemental response to Mass.

Attorney General's Interrogatory No. 119 to the l

Applicants: Circumstances which include the range of conditions explained on pages 5 and 6 of Enclosure 1 of the State's response to FEMA Supplemental Testimony would be applicable.

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l INTERROGATORY NO. 7 Ouestion:

State how and in what manner, if any, your current position with respect to sheltering the summer beach population differs from the position articulated in Applicants' prefiled Direct Testimony No. 6 on Sheltering, dated September 10, 1987, and provide, for each specific change in position, the basis for that change, including all supporting documentation.

Resconse:

Applicants' current position and the prefiled Direct Testimony No. 6 dated September 10, 1987, do not materially differ. There have been minor changes in the prefiled testimony and attachments as described in the errata sheets served on the parties.

INTERROGATORY NO. 8 Ouestion:

On p. 3 at 1 2, of the "New Hampshire Response to FEMA Supplemental Testimony" ["NH Response") it is stated with respect to the State's position on sheltering, "This position does not preclude the State from considering and selecting sheltering as a protective action for the beach population." Please identify and describe:

a. under what conditions the State would consider and might select sheltering as a protectiva action for the beach population;

b. the means by which the beach population will be instructed to shelter, including any emergency

, messages;

c. how the buildings which will shelter the beach l population will be identified;

! d. the specific buildings which will be relied upon to shelter the beach population; l

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e. the personnel who may be employed to assist the beach population in seeking shelter, including the numbers of such personnel who may be available and a description of any training such personnel will receive pertinent to that task; and

f. any agreements, understandings, or other communications with the owners of buildings that may be used as public shelters relating to the owners' consent to use their buildings as public shelters in the event of an accident at Seabrook Station.

ResDonse:

The Applicants' defer to the State's response to this interrogatory.

INTERROGATORY NO. 9 Ouestion:

On page 22 of Applicants' Direct Testimony No. 6 (Sheltering), dated September 10, 1987, it is stated with respect to the beach population, that:

Sheltering for example may ba the appropriate protective action for a puff release -- a gaseous or gaseous and particulate release -- of less than two hours duration. (Manual of Protective Action

Guides, U.S. EPA, p. 129.)

Do you still contend that sheltering of the beach i population may be the appropriate protective act1on for a puff release of less than two hours duration?

l ResDonse:

7 Yes.

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INTERROGATORY NO. 10 Question: ,

Do you anticipate that there might be circumstances in which transients with access to transportation would be instructed to shelter?

B.esconse:

Yes.

INTERROGATORY No. 11 Question:

Please define the term "transient beach population" as used in the NH Response, stating whether the term applies only to day-trippers to the beach area or whether it also includes overnight visitors staying in motels, hotels or rental cottages.

Resconse:

The Applicants' defer to the State's response to this interrogatory.

INTERROGATORY NO. 12 Ouestion:

On page 4 of the NH Response it is stated, "The addition of these precautionary measures alleviates most concerns about sheltering the beach population." What State concerns does it not alleviate?

Resconse:

The Applicants defer to the State's response to this interrogatory.

INTERROGATORY NO. 13 Ouestion:

On page 4 of the NH Response it is stated, "These precautionary actions and the State emphasis on getting the population out early are consistent with actions planned at other nuclear power plant sites with transient populations."

a. What are the "other nuclear power plant sites" referred to in the above sentence?

b. What is the size of the transient populations at these other sites?

c. What the evacuation time estimates for the transient populations at these other nuclear power plant sites?

d. What is the proximity of the transient populations at these other sites to the nuclear power plant?

e. Is any sheltering available for the transient populations at these other sites, and, if so, what the Dose Reduction Factors (DRF) of these shelters?

Ps.gponse:

The "other plants" referred to are:

a) Surry Power Station - Virginia Zion - Illinois Brunswick - South Carolina Indian Point - New York Millstone - Connecticut Perry - Ohio Davis Besse - Ohio San Onofre - California Palisades - Michigan D.C. Cook - Michigan St. Lucie - Florida Pilgrim - Massachusetts b) Surry - 42,000 Zion - 50,000 Brunswick - 7,000-8,000 Indian Point - not available Millotone - 81,000 Perry - 30,000 Davis Besse - 29,105 San Onofre - 6,000-8,000

Palisades - 19,000 D.C. Cook - not available St. Lucie - 21,099 Pilgrim - 21,000 c) Information on ETE's for transients was not obtained.

d) Surry 10 miles Zion 5 miles Brunswick 7 miles Indian Point - not available Millstone - 4.5 miles Perry - 10 miles Davis Besse 8 miles San Onofre 7 miles Palisades - adjacent to plant site D.C. Cook - 5 miles St. Lucie 10 miles Pilgrim 9 miles e) Surry - yes, shelter available Zion - no Brunswick - no Indian Point - no Millstone - yes Perry - no Davis Besse - no San Onofre - no Palisades - no D.C. Cook - no St. Lucie - no Pilgrim - yes Shelter Dose reduction factors were not available.

INTERROGATORY NO. 14 Ouestion:

On p. 7 of the NH Response, it is stated: "It [the Shelter Study) identified a large number of shelters that may serve as a pool from which public shelter choices will be made." Please answer:

a. How and when will such choices be made?

b. On what criteria will the choices be based?

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Resoonse:

Applicants defer to State's response to this interrogatory.

INTERROGATORY NO. 15 Ouestion:

Provide copies of all draft or proposed amendments to the NHRERP concerning protective actions for the beach population that the State is presently considering and for each proposed amendment:

a. state whether the State has any present intention to adopt such amendment;

b. describe the steps that must be taken before such amendment is adopted;

c. provide the anticipated date by which such amendment will be adopted;

d. state whether there are any considerations against adopting such amendment, and the basis of such considerations; and

e. provide any proposed changes to the draft amendment.

Besconse:

Applicants defer to State's response to this interrogatory.

INTERROGATORY NO. 16 Ouestion:

Does the term "beach population" as used in the NH Response include permanent residents of the Seabrook and Hampton beach area?

Resoonse:

Applicants defer to State's response to this interrogatory.

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INTERROGATORY NO. 17 Ouestion:

Do you foresee any situation in which the transient beach population would be instructed to evacuate and the residents of the Seabrook and Hampton beach area instructed to shelter?

Response

No.

INTERROGATORY NO. 18 Ouestion:

On page 29 of Applicants' Direct Testimony No. 6 it states:

The result of the residential survey showed that 34 percent of 3,036 residences in Hampton beach and 51 percent of 758 residences in Seabrook Beach provide basement and masonry sheltering capability. The remaining percentage of residences provide sheltering characteristics at least as effective as that assumed by the NHRERP. The field survey revealed very few wood-frame residences that would not meet these sheltering characteristics.

Please produce such survey, and all documentation, notes, calculations and memoranda pertinent thereto, and for each residence surveyed:

a. provide the address of the residence;

b. indicate the type of residence, e.g., whether it '.s an apartment, house, condominium, etc.

c. indicate whether the residence has a basement or masonry sheltering capability;

d. indicate whether the residence does or does not "provide sheltering characteristics at least as effective as that assumed by the NHRERP "

Resconse;

a. Specific street addresses were obtained for condominiums. Other residences were tallied by street, or groups of streets, therefore, specific individual residence addresses were not obtained. (See Attachment 1)

b. The structures were broken down into only two categories, condominiums or residential structures.

This breakdown is provided in Attachment 1.

c. See Attachment 1.

d. The residential survey (Attachment 1) did not have as an objective locating residences that would not meet the minimum sheltering characteristics assumed by the NHRERP. However, that survey and a subsequent external visual survey of residences did not identify any residences that did not meet the criteria in Reference 11, response to Mass AG Interrogatory No. 1.

INTERROGATORY NO. 19 Question:

On what basis do you contend that the sirens in the l beach area, when used in the voice mode to instruct the beach population, can be intelligibly heard and understood by all persons in the beach area? Please provide copies of any and all documentation, calculations and analyses including any acoustical tests, that form, or are in any way relevant to, the basis for your response, whether or not it supports your response.

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Response

The Applicants do not contend what the question suggests.

Means for notifying the public at the beach are described in the NHRERP, Rev. 2, Volume 1, page 2.1-14.

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. l As to Answers:

&CD j George S. Thomas ,

Vice President, Nuclear Production New Hampshire Yankee Division of Public Service Company of New Hampshire March 25, 1988 State of New Hampshire Rockingham County, ss.

Then appeared before me the above subscribed George S.

Thomas and made oath that he is the Vice President, Nuclear Production of New Hampshire Yankee Division, authorized to execute the foregoing responses to interrogatories on behalf of the Applicants' that he made inquiry and believes that the foregoing answers accurately set forth information as is available to the Applicants.

Before me, kb Nou%.{

My CommissiG Expires Mard 6,1990 As to objections:

/ M;}4 aMd2 Thomas G. Dignan, Jr.

George H. Lewald Kathryn A. Selleck Deborah S. Steenland Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for Acolicants

Page 1 of 6 ATTACHMENT 1 HAMPTON No. of Residential Structures With Masonry and/or Basement Street (s) Yes No Epping 5 20 River Avenue 7 13 Boston 10 17 Concord 7 21 Dover 8 33 Ocean Boulevard (east side) 29 36 Atlantic Avenue 9 8 Bradford Avenue 2 12 Haverhill Avenue 1 4 Sunsurf Avenue 2 6 Great Boar's Head Avenue 3 7 Boar's Head Terrace 9 21 Dumas Avenue 16 12 Cliff Avenue 10 12 Ancient Highway 14 13 Shaw 2 1 Toppan 1 5 James 3 7 Beach Plum Way 8 11 Oceanr 3oulavard (west side) 49 58 King's Highway (east side) 7 34 King's Highway (west side) 7 48 1-19 Streets 27 42 Roads west off King's Highway 13 77 Huckleberry Lane 25 11 Bayberry / Linden / Juniper 13 2 Robin Lane 5 6 Brian Road 0 9 Roads off Brian 5 26 i North Shore Road (to Quinlan) 20 33 I Cusack Avenue 1 0

! Seaview Avenue 7 22 l Cliff Road / Willow Lane 1 6 l Mill Pond Lane / Fox / Glen 9 32 l

Birch 43 12 Acorn Road 4 51 Smith Avenue 0 2 High Street (to Birch) 21 10 Winnacunnet Road 21 31 l

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Page 2 of 6 HAMPTON (continued)

No. of Residential Structures With

• 'sonry and/or Basement Street (sl Yes No Donair/ Shirley Terrace 9 18 Acadia Avenue / Hemlock 8 10 Walnut / Sapphire 15 20 Emerald + 4 off roads 13 18 Tnorwald/ Viking 11 22 Island Path / Garland /Battcock/ Jones 6 91 Brown + off rcyls 22 69 Ashworth Avenue (wcrt side) 4 3 Hobson Avenue 4 22 Manchester 0 19 Keefe 1 7 Mooring 0 26 Auburn + Ext. 0 32 Perkins 1 24

.7ohnson 3 17 Riverview 0 31 Bragg 1 16 Tuttle 0 18 Fellows / Harris 6 30 Dow/Whitten 4 9 Dustin/ Harbor 0 11 Bailey 5 4 Ocean boulevard (south-west side) 5 5 Ashworth Avenue (east side) 8 21 A-Q 42 153 Nudd 1 61 Highland 7 50

, Kentville Terrace . 0 35 l Rosa Avenue 2 13 Church / Charles 8 30 i Williams /Lyons/ Francis 5 10 l McKay/ Cutter 10 20 Ocean Park / Fuller Acres 7 19 l Tilton 0 5 l

l i TOTALS 632* 1710 l 632 have basements.

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l HAMPTON CONDOS No. of Residential Structures With Masonry and/or Basement Man / Lot Name/ Address Yes No 265/17 Atlantic Shores 10 0 421 Ocean Boulevard 151/9 Bailey 0 30 933 Ocean Boulevard 210/25 Blue Spruce 0 16 66 King's Highwal 265/2 Coast View 12 0 425 Ocean Boulevard 235/24 Coastal Scene 15 0 591 Ocean Boulevard 295/15 Daniel'c Landing 20 0 20 Harris Avenue 134/83 Harbor Point 0 30 975 Ocean Boulevard 235/12 Holiday Shores 0 23 615 Ocean Boulevard 255/7 Island View 17 0 541 Ocean Boulevard 183/51 King's Highway 0 6 120 King's Highway 167/6,7,8 Meadow Pond Estates 6 0 475-481 King's Highway 210/15 North Beach 32 0 68 King's Highway 168/2 Ocean Crest 36 0 190 King's Highway 245/10 Ocean Meadows 20 0 561 Ocean Boulevard 265/9 Ocean Spray 22 0 407 Ocean Boulevard 133/68 Ocean Willows 0 32 23 Cusack Road 152/13 Plaice Cove 30 0 971 Ocean Boulevard 266/52 Rocky Bend 0 18 504 Ocean Boulevard 245/3 Royale Sand Beach Club 27 0 579-581 Ocean Boulevard 151/4 St. Magnus 0 26 943-951 Ocean Boulevard

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HAMPTON CONDOS (continued)

No. of Residential Structures With Masonry and/or Basement Mao / Lot Name/ Address Yes No __

235/11 Sar.dpiper Bay 0 16 571 Winnacunnet Road 265/63 Sea Castle 6 0 20 Fuller Acres 151/5 Seaborne 20 0 939 Ocean Boulevard 266/1 Seabreeze 0 36 461-3 Ocean Boulevard 265/8 Seven Gables 27 0 405 Ocean Boulevard 266/8 Surfside Thirty 30 0 493 Ocean Boulevard 2G6/28 Top of the Surf 15 0 445 Ocean Boulevard 222/7 Twin Oak 0 18 470 Winnacunnet Road 296/13 U.S. Hampton Beach 21 0 19 Atlantic Avenue 235/10 Village by the Sea 12 0 2 King's Highway 223/75 Waterglade Villas 0 16 30 King's Highway 183/12-13 146-8 King's Highway 0 4 146-8 King's Highway 222/78-81 476-482 Condos 8 0 476-482 Winnacunnet 235/13 611 Ocean Boulevard 9 0 611 Ocean Boulevard 134/51 989 Ocean Townhouses 0 28 989 Ocean Boulevard 1

TOTAL 395 299 395

+112 694 condo units

Page 5 of 6 HAMPTON

SUMMARY

With Masonry and/or Basement Structure:

3esidential Structures 632 Condo Units 221 TOTAL 1,027 Without Masonry or Basement:

Residential Structures 1,710 Condo Units 299 TOTAL 2,009 1,027 2.009

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OVERALL TOTAL 3,036 100%xh'hff=34%

Page 6 of 6 SEABROOK No. of Residential Structures With Masonry and/or Basement Street (s) Yes No Atlantic Avenue (south), State Line 29 22 Street, Amesbury, Newbury, Groveland Route 1A (east side) 18 21 Route 1A (west side) including a 10-unit 18 3 brick condo Thorton 23 6 Ocean Drive (east side) 20 15 Ocean Drive (west side) 22 7 Portsmouth (east side) 25 24 Portsmouth (west side) 8 10 Campton 6 0 Plymouth 12 8 Woodstock 13 21 Ashland 12 20 Bristol 7 22 Tilton 12 22 Franklin 11 17 Concord 10 16 Pembrooke 11 14 Suncock 6 8 Hooksett 7 5 Manchester 12 10 Atlantic Avenue (east side) 30 10 Atlantic Avenue (west side) 16 10 Lawrence 4 1 Wethuen 3 3 Andover 3 2 Dracut 3 2 Lowell 4 2 Chelmsford 7 3 Tyngsboro 4 4 Nashua 10 5 Hudson 7 8 l River 11 34 Cross Beach Road 0 18 Route 286 1 0 TOTAL 385 373 385 (Yes) + 373 (No) = 758 Overall Total 100% x = 51% Having Masonry and/or Basement Structure 354 of these have basements

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a 00CKETE0 USNRC t

CERTIFICATE OF SERVICE I, Kathryn A. Selleck, one of the attorneys fgFyp ; iRialAFY Applicantsherein,herebycertifythatonMarch28,vg99'j{gjuWKL '

made service.of the within document by depositing copies thereof with Federal Express, prepaid,.for delivery to (or, where indicated, by depositing in the United States mail,

. first class postage paid, addressed to):.

Administrative Judge Ivan W. Smith ' Robert Carrigg, Chairman Chairman, Atomic Safety and Board of Selectmen Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Judge Gustave A. Linenberger Diane Curran, Esquire Atomic Safety and Licensing Andrea C. Ferster, Esquire Board Panel Harmon & Weiss U.S. Nuclear Regulatory Suite 430 '

Commission 2001 S Street, N.W.

East West Towers Building Washington, DC 20009

4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill t Atomic Safety and Licensing Attorney General  ;

Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General ,

East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire _'

Atomic Safety and Licensing Office of General Counsel l'

Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building One White Flint North, 15th Fl. ,

i 4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852 .

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• Atomic Safety and Licensing Robert A. Backus, Esquire ,

Appeal Board Panel 116 Lowell Street l

U.S. Nuclear Regulatory P. O. Box 516 l Commission Manchester, NH 03105 Washington, DC 20555 i

t Philip Ahrens, Esquire Mr. J. P. Nadeau As71stant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney 25 Maplewood Avenue General P.O. Box 360 One Ashburton Place, 19th Flr.

Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

• Senator Gordon J. Humphrey Mr. Angie Machiros U.S. Senate Chairman of the Board of Washington, DC 20510 Selectn.en (Attn: Tom Burack) Town of Newbury Newbury, MA 01950

• Senator Gordon J. Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas l

47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 l

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, Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region I Silverglate, Gertner, Baker, 442 John W. McCormack Post F 'e, Good & Mizner Office and Court House 88 Broad Street Post Office Square Boston, MA 02110 Boston, MA 02109 Charles P. Graham, Esquire McKay, Murphy and Graham 100 Main Street Amesbury, MA 01913 A l KathvYn A. Selleck

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