ML20149N058

New England Coalition on Nuclear Pollution Interrogatories & Requests for Production of Documents to State of Nh.* Questions Concern FEMA Supplemental Testimony on Offsite Emergency Planning.W/Svc List.Related Correspondence

ML20149N058
Person / Time
Site:	Seabrook
Issue date:	02/24/1988
From:	Weiss E HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	NEW HAMPSHIRE, STATE OF
References
CON-#188-5693 OL, NUDOCS 8803010072
Download: ML20149N058 (5)

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56 U SEMD CORR,E_S,gg DOCKETED U)NEC February 24, 1988 16 RB 26 P4 06 UNITED STATES NUCLEAR REGULATORY COMMISSION

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. BEFORE THE ATOMIC SAFETY AND LICENSING BOARD BRANCH

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In the Matter of )

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Public Service Company of )

New Hampshire, et al. ) Docket Nos. 50-443 OL ,

) 50-444 OL (Seabrook Station, Units 1 & 2) ) OFFSITE EMERGENCY, '

) PLANNING

)

NECNP INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STATE OF NEW HAMPSHIRE Pursuant to 10 CFR S S 2.740b and 2.741, and Order of the Licensing Board, NECNP propounds the following interrogatories 1

and requests for production of documents to the State of New l Hampshire. They should be answered under oath by the individ-uai(s) providing the response.

The fc2 lowing questions relate to "No, Hampshire Response to l FEMA Supplemental Testimony," Enclosure 1 to the February 11, l 1988 letter f rom Richard H. Strom2 to Henry G. 'Yickers.

1. Identify as specifically as possible the "limited range of conditions" as to which sheltering of the beach population "is not without benefits." (Enclosure 1, p.1) .

2. The following statement appears on page 2 of Enclosure 1:

Third, the state feels that if a release of radiation warranted movement of the public, they are much more likely to be af forded meaningf ul dose reductions by moving out of the EPZ than by moving to a shelter within the EP2.

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i Please provide any documents the state has which evaluate, 1

assess or discuss in any way the dose reductions to the beach population f rom evacuation as compared to sheltering in any acci-dent scenario.

3. The following sentence appears on page 3 of enclosure 1 (emphasis added);

Such considerations dissuade the state from considering -

the movement of large numbers of people to public shelters as a primary protective action for beach transients given that evacuation is seen as providing dose savings in nearly all accident scenarios.

Please identify those accident scenarios for which evacua-tion does not provide dose savings.

4. On page 4 of Enclosure 1, the state quotes from the RAC review of NHRERP Rev. 2, as follows:

According to the State response and the plan revisions, the use of public shelters is not proposed during a Seabrook Station emergency. The only exception is the possible use of public buildings for shelters for transients without transportation.

Does the quoted material accurately describe the current version of the NHRERP? Are there any circumstances where the state might order sheltering of the general beach population beyond transients without transportation? If so, describe those circumstances as specifically as possible.

5. The following statement appears on page 4 of Enclosure 1:

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.

i

l Identify the "other nuclear power plant sites" referred to in that statement. ,

6. The following statement appears on page 5 of Enclosure 1:

...the protective action of sheltering may be preferable to evacuation in only a very limited number of accident scenarios.

Identify with specificity the accident scenarios for which sheltering of the general beach population (beyond those without transportation) is preferable to evacuation and provide all docu-ments, assessments, evaluations or other data which support the State's conclusion that sheltering is preferable to evacuation for these scenarios.

7. The following statement appears on page 7 of Enclosure 1 referring to the Stone and Webster shelter study:

It identified a large number of shelters that may serve as a pool f rom which shelter choices will be made. Based upon its review of the (Stone and Webster) Shelter Study , the State is confident that unforeseen demand for shelter can be, met provided that the limits of usefulness inherent in any shelter (e.g., sheltering factors, weatherization, capacity, etc. ) are considered in the decision-making process.

, a. Has the state identified specific shelters that would be used if the decision is made to shelter the beach population? If so, identify.

b. What is the sheltering factor, weatherization and capac- )

1 ity of each auch shelter?

c. Describe specifically how the state will "consider in the decision-making process" the "limits of usef ulness" inherent in shelteting? l 1

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d. Identify what section(s) of the NHRERP, attachments or worksheets will be used by the decision-maker in considering whether to order the general beach population (beyond transients without transportation) to shelter.

8. Does the NHRERP include an EBS message directing the general beach population (beyond transients without transporta-tion) to shelter? If not, does the state intend to amend the plan to include such a message?

By:

1 1 Ellyn R. heiss HARMON & UEISS 2001 S Street, N.U.

Suite 430 Hashington, D.C. 20009 (202) 328-3500 Counsel for NECNP l

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1 DCL KE ii'.:

SEABROOK SERVICE LIST- OFFSITE LICENSING BOARD Ivan W. Smith, Chairman J.P. Nadeau Edgdghgasp4 06 Office of General Counsel Town of Rye Sherwin E. Turk, Esq. FEhiA U.S. NRC 155 Washington Road OfGee of General Counsel 442 J.W. McCormack Washington, D.C 20555 Rye,NewIlampshire 03870 U.S. NRC Washington, D.C. 20555 (1

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Dr. Jerry Harbou,r Richard E. Sullivan, Mayor Office of General Counsel Cityllall Mr. Angie Machiros, Sandra Gawtis U.S. NRC Newburyport,MA 01950 Chairman RFD 1 Box 1154 Washington, D.C 20555 .

Town of Newbury East Kensington, Nil 03827 Alfred V. Sargent, Chairman Town llall,25 Iligh Road Gustaw Linenberger Board of Selectmen Newbury,MA 01951 Charles P. Graham, Esq.

Office of General Counsel Town of Salisbury, MA 01950 McKay, Murphy and Graham U.S. NRC 11. Joseph Flynn, Esq. 100 Main Street Washington, D.C 20555 Senator Gordon J. Ilumphrey Ofuce of General Counsel Amesbury, MA 01913 U.S. Senate FEMA -

Atomic Safety and Licensing Washington,D.C 20510 500 C Street S.W.

Board Panel (Attn. Tom Burack) War.hington, D.C 20472 U.S. NRC Washington, D.C 20555 Selectmen of Northampton George Dana Bisbee, Esq.

Northampton, New flamp. Geoffrey M. Iluntington, Esq.

Atomic Safety and Licensing shire 03826 Office of the Attorney General Appeal Board Panel State llouse Annex U.S. N RC Senator Gordon J. Ilumphrey Concord, Nil 03301 Washington, D.C 20555 1 Eagle Square, Sie 507 Concord, Nil 03301 Allen Lampert Docketing and Service Civil Defense Director U.S. NRC Michael Santosuosso, Town of Brentowood Washington, D.C 20555 Chairman Exeter, Nil 03833 Board of Selectmen Mrs. Anne E. Goodman Jewell Street, RFD # 2 Richard A. Ilampe, Esc,.

Board of Selectmen South flampton, Nil 03842 Ilampe and McNicholas 1315 New Market Road 35 Pleasant Street Durham, Nil 03S42 Judith 11. Mirner, Esq. Concord. Nil 03301 Silverglate, Gertner, et al.

William S. Lerd, Selectman 88 Broad Street Gary W. Ilolmes, Esq.

Town Hall- Friend Street Boston,MA 02110 llotmes & Ellis Amesbury,MA 01913 47 Winnacunnent Road Rep. Roberta C Pevear llampton, Nil 03842 Jane Doughty Drinkwater Road SAPL llampton, Falls, Nil 03844 William Atmstrong 5 Market Street Civil Defense Director Portsmouth, Nil 03801 Phillip Ahrens, Esq. 10 Front Street Assistant Attorney General Exeter, Nil 03833 Caro 1 S. Sneider, Esquire State flouse, Station # 6 Assistant Attorney General Augusta,ME N333 CaMn A.Canney 1 Ashburton Place,19th Floor City Manager Boston, MA 02108 Thomas G. Dignan, Esq. City IIall R.K. Gad II, Esq. 126 Daniel Street Stanley W. Knowles Ropes & Gray Portsmouth, Nil 03801 Board of Selectmen 225 Franklin Street P.O. Box 710 Boston,MA 02110 M atthew T. Brock. Esq.

North flampton, Nil 03826 Shaines & McEachern Robert A. Backus, Esq. P.O. Box 360 Backus, Meyer & Solomon Maplewood Ave.

111 Lowell Street Portsmouth, Nil 03801 l Manchester, Nil 03105

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