ML20150A875

Rebuttal Testimony of Doctors G Thompson,Rl Goble & J Beyea on Behalf of Atty General for Commonwealth of Ma on Sheltering Contentions.* Certificate of Svc Encl

ML20150A875
Person / Time
Site:	Seabrook
Issue date:	06/30/1988
From:	Beyea J, Goble R, Thompson G MASSACHUSETTS, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
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'

gh gpgR$MDW DCLKE;Er uwc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.'88 JLL 1 Before Administrative Judgeh0Cbfh;fr/((k[./

Ivan W. Smith, Chairperson BRAgy Gustave A.

Linenberger, Jr.

Dr. Jerry Harbour 1

)

i In the Matter of

)

)

Docket Nos.

PUBLIC SERVICE COMPANY OF NEW

)

50-443-444-OL

)

(Off-site EP)

HAMPSHIRE, ET AL.

)

June 30, 1988 (Seabrook Station, Units 1 and 2)

)

)

_)

REBUTTAL TESTIMONY OF DR. GORDON THOMPSON, DR. ROBERT L. GOBLE, AND DR. JAN BEYEA ON BEHALF OF THE ATTORNEY GENERAL FOR THE CQMMONWEALTH OF MASSACHUSETTS ON SHELTERING CONT I.

IDENTIFICATION OF WITNESSES i

i Q.

Please state your names, positions, and business i

addresses.

{

A.

(Thompson)

My name is Dr. Gordon Thompson.

I am Executive Director of the Institute for Resource and Securit y

i Studies in Cambridge, Massachusetts.

A.

(Goble)

My name is Dr. Robert Goble.

I am a j

Research Associate Professor at Clark University in Worce t s er, Massachusetts.

A.

(Beyea)

My name is Dr. Jan Beyea.

I am the Senior Energy Scientist for the National Audubon Society in New Yo k r

City.

69 Rod \\

5Y

$Ptipse

r

.b.

s Q.

Briefly summarize your experience and professional qualifications.

(Thompson)

I received a Ph.D in applied mathematics from Oxford University in 1973.

Since then I have worked as a consulting scientist on-a variety of energy, environment, and international security issues.

My experience has included technical analysis and presentation of expert testimony on issues related to the safety of nuclear power facilities.

In 1977, I presented testimony before the Windscale Public Inquiry in Britain, addressing safety aspects of nuclear fuel reprocessing.

During 1978 and 1979, I participated in an internaticaal scientific review of the proposed Gorleben nuclear fuel center in West Germany, a review sponsored by the government of Lower Saxony.

1 Between 1982 and 1984, I coordinated an investigation of safety issues relevant to the proposed nuclear. plant at Sizewell, England.

This plant will have many similarities to the Seabrook plant.

The investigation was sponsored by a group of local governments in Britain, under the aegis of the Town and Country Planning Association.

This investigation formed the basis for testimony before the Sizewell Public Inquiry by myself and two other witnesses.

From 1980 to 1985, first as a staff scientist and later as a consultant, I was associated with the Union of Concerned Scientists (UCS), at their head office in Cambridge, MA.

On behalf of UCS, I presented testimony in 1983 before a licensing board of the US Nuclear Regulatory Commission (NRC), concerning

-2

I.

4 the merits of a system of filtered venting at the Indian point nuclear plants.

Also, I undertook an extensive review of NRC research on the reactor accident "source term" issue, and was co-author of a major report published by UCS on this subject in 1986.

Currently, I am one of the principal investigators for an emergency planning study based at Clark University, Worcester, MA.

The object of the study is to develop a model emergency plan for the Three Mile Island nuclear plant.

Within this effort, my primary responsibilities are to address the characteristics of severe reactor accidents.

My other research interests include:

the efficient use-of energy; the supply of energy from renewable sources; radioactive waste management; the restraint of nuclear weapons proliferation; and nuclear arms control.

I have written and made public presentations in each of these areas.

At present, I am Executive Director of the Institute for Resource and Security Studies, Cambridge, MA.

This organization is devoted to research and public education on the efficient use of natural resources, protection of the environment, and the furtherance of international peace and security.

A detailed resume is included in the attachments to this testimony.

A.

(Goble)

I received a ph.D. in physics from the University of Wisconsin in 1967, specializing in high energy 1

elementary particle physics.

Since then I have held combined 1 )

4.

research and teaching posts at Yale University, the University-

'l of Minnesota, the University of Utah, Montana State University, and Clark University.

My present. position at Clark is Research Associate Professor of Physics where I am a member'of the l

-l program on Environment, Technology, and Society, and part of the Hazards Assessment Group of the Center'for Technology,'

Environment, and Development (CENTED).

I have taught a wide range of physics courses at both the j

undergraduate and graduate level and a number of courses dealing with the relationship between technologies and society.

My current research interests are:

(1) emergency planning for a

nuclear reactor accidents (I am one of the. principal i

researchers in a two year Clark project to write an emergency tesponse plan for the TMI nuclear reactor); (2) risk assessment

]

1 (I am conducting research on risks from radon exposures in 1

indoor air, and am working with other CENTED group members on reviewing risk assessments for a potential radioactive waste I

repository in Nevada); (3) air pollution dispersal (I am continuing work on both short and long range pollutant dispersal, including applications to the acid rain problem, as well as the transport of radionuclides from nuclear accidents).

A complete resume is included in the attachments to this testimony.

(Beyea)

I received my doctorate in nuclear physics from Columbia University in 1968.

Since then I have served as an Assistant Professor of physics at Holy Cross College in Worcester, MA; as a member for four years of the research staff

-4

of the Center for Energy and Environmental Studies at! Princeton University; and, as of May 1980, as the Senior. Energy Scientist for the National Audubon Society.

While at Princeton University, I worked with Dr. Frank von Hippel to prepare a critical quantitative. analysis of attempts

~

to model reactor accident sequences.

The lessons learned from this general study of nuclear accidents'and the computer codes written to model radioactivity releases I then applied to specific problems at the request of governmental and non-governmental bodies around the world.

I have written major reports on the safety of specific nuclear facilities for the President's Council on Environmental Quality (TMI reactor), for the New York State Attorney General's Office (Indian Point),

for the Swedish Energy Commission (Barsebeck reactor), and the state of Lower Saxony (Gorleben Waste Disposal Site).

I have also examined safety aspects of specific sites for the California Energy and Resources Commission, the Massachusetts Attorney General's Office and the New York City Council.

Also while at Princeton, I wrote a computer program, useful for reactor emergency planning, for the New Jersey Department of Environmental Protection.

After joining the National Audubon Society, I continued to work as an independent consultant on nuclear safety issues.

I participated in a study, directed by the Union of Concerned i

Scientists (UCS) at the request of the Governor of Pennsylvania, concerning.ne proposed venting of krypton gas at Three Mile Island.

The UCS study, for which I made the j

t radiation dose calculations, was the major reason the Governor gave for approving the venting.

I participated in the international exercise on. consequence modeling (Benchmark Study) coordinated by the Organization for Economic Cooperation & Development (0.E.C.D.).

Scientists and engineers from fourteen countries around the world used their own auence models to calculate radiation doses following hypothetical "benchmark" releases.

Other participants from the

~

United States included groups from Sandia Laboratories, Lawrence Livermore Laboratory, Batelle Pacific-Northwest, and Pickard, Lowe and Garrick, Inc.

I also served as a consultant-from the environmental community to the N.R.C.

in connection with their development of "Safety Goals for Nuclear Power i

Plants."

At the request of the Three Mile Island Public Health Fund, I supervised a major review of radiation doses from the Three Mile Island accident.

This report, "A Review of Dose i

Assessments at Three Mile Island and Recommendations for Future Research," was released in August of 1984.

Subsequently, I 1

organized a workshop on TMI Dosimetry, the proceedings of which were published in early 1986.

In 1986, I developed new dose models for the Epidemiology Department of Columbia University.

These models.are being used to assess whether or not the TMI accident is correlated with excess health effects in the local population.

The new computer models account for complex terrain, as well as time varying meteorology (including changes in wind direction).

4 In addition to reports written about specific nuclear facilities, an article of mine on resolving conflict at'the Indian point reactor site, an article on emergency planning for reactor accidents, and a joint paper with Frank von Hippel of princeton University on failure modes of reactor containment systems have appeared in The__ Bulletin _g_f the Atomic Scientists.

I have also prepared risk studies covering sulfur emissions from coal-burning energy facilities, and I have managed a project that analyzed the side effects of renswable energy sources.

1 I regularly testify before congressional committees on j

energy issues and have served on several advisory boards set up by the Congressional Office of Technology Assessment.

I currently participate in a number of ongoing efforts aimed at promoting dialogue between environmental organizations and industry.

A complete resume is included in the attachments to this testimony.

II.

OVERVIEW OF TESTIMONY Q.

To what testimony does your rebuttal testimony refer?

i A.

(All) Our testimony addresses the "Amended Testimony'of William R. Cumming and Joseph H.

Keller on Behalf of the Federal Emergency Management Agency on Sheltering / Beach i

population Issues" ("FEMA Testimony"), dated June 10, 1988.

Specifically, our testimony addresses the conclusion of that 7-

]

.4 testimony that, "if the dose reduction strategy is sheltering first-followed by an e,acuation after plume passage, the total dose reduction would not be as great as that for the immediate evacuation strategy."

FEMA Testimony at p.

9.

As FEMA's technical witness, Joseph Keller, testified on cross-examination, FEMA's conclusion, that evacuation would in almost all cases be the preferred dose reduction strategy for h

the beach population, is premised on a generic analysis (including a generic dose consequence analysis) that did not take into a-',,it

.iy factors or problems of emergency planning specific to _he Seabrook site.

Egg Tr. at 14192-14193; 14230; 14273; 14250.

Our testimony demonstrates that this generic analysis is not applicable to the Seabrook site.

In addition, our testimony addresses certain matters raised in cross-examination of the Applicants' panel No. 6 on Sheltering.

Specifically, our testimony rebuts that panel's conclusion, as developed on cross-examination, that immediate evacuation would always be the preferred dose reduction strategy in the event of a. severe accident.

Egg, 222.,

Tr. at 10556; 10426; 10428; 10591-10592.

Our testimony also addresses the appropriateness of that panel's use, as developed on cross-examination, of a "maximum dose reduction" standard, and the panel's reliance on precautionary measures, i.e. early beach closing, as providing sufficient time to protect the summer beach population.

Q.

please summarize your testimony. :

O A.

(All)

Our testimony addresses'the relative effectiveness of a range of emergency response strategies for protection of the beach population near the Seabrook-plant.

These strategies. encompass a spectrum of potential actions in-regard to sheltering and evacuation.

The relative effectiveness of the strategies is assessed for a range of potential reactor accident conditions.

Through this testimony, we demonstrate three major deficiencies of the NHRERP.

First, the NHRERP will not be significantly more effective than strategies involving unplanned emergency response.

Second, New Hampshire does not have an adequate basis for rejecting sheltering as a planned emergency response measure for the general beach population, especially in severe accident situations.

Third, the NHRERP will be significantly less effective than generic emergency responses to nuclear plant accidents.

As a result of these.

deficiencies, the NHRERP cannot be said to provide adequate protection to the beach population.

Q.

Doec your testimony cover the same ground as the rejected April 25, 1988 Commonwealth of Massachusetts Testimony of Sholly, Beyea, and Thompson?

A.

(All)

No.

Our present testimony does not contain estimates of radiation doses and does not assume any particular j

accident scenario.

Instead, the testimony addresses the relative effectiveness of emergency response strategies across a range of potential accident conditions.

The same issue has been addressed in the June 10, 1988 FEMA Testimony of Keller and Cumming, although in that case without supporting analysis.

-9

III.

ANALYTIC APPROACH 0

please explain your analytic approach.

A.

(All)

We follow in the footsteps of the authors of=

NUREG-0396, which provides the planning basis for current 1

emergency planning.

Appendix I'of NUREG-0396, which provides the rationale for that planning basis, includes a discussion of the emergency planning implications of the Reactor Safety Study I

(WASH-1400).

Within that discussion, the results of technical l

analyses are presented, partly without attribution and partly j

with attribution to the report NUREG/CR-ll31.1 Where attribution to NUREG/CR-ll31 is made, the analytic results drawn from that document pertain in part to the relative effectiveness of various emergency response strategies.

1 NUREG/CR-1131 itself contains a more elaborate treatment of the relative effectiveness issue.

Our approach is similar in principle to that of NUREG/CR-ll31, except that we do not present estimates of actual radiation doses or the number of people suffering adverse health effects.

Thus, our analysis is strictly confined to the issue of relative effectiveness.

In addition, some details of our analytic approach differ from those of NUREG/CR-ll31, as explained later in this testimony.

Q.

What are the major elements of your analysis?

1/

Reference (6) in Appendix I of NUREG-0396 is currently available as:

D.C. Aldrich et al., EXami DA_tl_QA__QL._01f S i10 A nd L71oaiq31_Epergency Protective Measu res for Nuclear Reactor Accidents Involvina Core Melt, NUREG/CR-1131, October 1979. [

a

I A.

(All)

First, we identify a set of emergency response strategies which collectively represent the spectrum of sheltering and evacuation actions potentially available to the beach population.

Second, we select parameters which represent the potential application of these strategies.

T.trd, we select, following NUREG/CR-1131, a set of parameter combinations to represent _the spectrum of potential accidents at the Seabrook plant.

Fourth, we estimate, in part using the MACCS computer program, the relative effectiveness of each emergency response strategy.

IV.

EMERGENCY RESPONSE STRATEGIES i

Q.

please outline the set of emergency response strategies which you have identified.

A.

(All)

We have identified four evacuation strategies and four sheltering strategies.

Collectively,'these represent the spectrum of sheltering and evacuation actions which might in principle be available to protect the general beach' population.

Of the four evacuation strategies, the first (El) represents evacuation performed without beaefit of prior planning.

The second (E2) corresponds to the evacuation currently envisioned in the NHRERp.

The third (E3) respresents evacuation conducted with a rapidity typical of that anticipated at a generic plant site.

Tne fourth (E4) represents evacuation situations in which plume arrival overlaps evacuation but there is no entrapment of the 4

population.

These strategies are hereafter referred to as "unplanned evacuation," "NHRERP evacuation," "generic evacuation" and "generic evacuation with difficulties",

respectively.

The NHRERP contemplates the possibility of sheltering the general beach population in certain limited, unspecified circumstances.

(Enq Applicants' Direct Testimony No.-6 (Sheltering), dated April 15, 1988, at p. 19.)

However, the NHRERP contains no plans for implementing that strategy.

(Eng aenerally, Comm. of Mass. Testimony of Goble, Renn, Eckert and Evdokimoff,~ dated April 25, 1988; Egg alsn, Tr. at 10180, 10182, 10153, 10165, 10578).

Thus, our first sheltering strategy (S1) represents sheltering carried out without benefit of prior planning; we hereafter refer to this as "ad hoc shelter."

Our second sheltering strategy (S2) represents a-type of sheltering which might be contemplated if the NHRERP were modified to provide for implementing this kind of response.

Since much of the currently available shelter space is in wood-frame buildings without basements, we hereafter refer to this strategy as "shelter equivalent to wood frame buildings without basements."

It is important to remember the~

many of the buildings in the beach area are so insubstantial that they do not meet the specifications we have assumed for this strategy.

Our third and fourth sheltering strategies may be considered the "generic" sheltering strategies.

The third strategy (S3) represents the degree of sheltering which is achievable in the basements of typical houses in the Northeast region.

12 -

--,..,.-.y

Hereafter, we refer to this as our "shelter equivalent to wood frame buildings with basements" strategy.

Our fourth strategy (S4) represents a better quality of shelter, achievable in medium-sized office or~ industrial buildings of masonry construction.

This strategy is hereafter referred to as the

+

"good shelter" case.

Q.

Are all these options available to the beach population?

A.

(All)

Clearly, the El and E2 strategies are readily available.

Also, existing structures would allow the S1 and S2 strategies to be available to part of the general beach population, although execution of the S2 strategy would require considerably more planning than is currently evidenced in the i

l 11HRERP, Rev.

2.

The remaining strategies would only be available if additional I:eparations were made.

Preparation for implementing strategies equivalent to E3 and E4 would involve measures which increase the mobility of the beach population.

Increased mobility could be achieved through measures such as the building of new roads, or by limiting the number of people who are permitted to visit the beaches.

It is not our purpose here to propose or to assess the merits of any particular measure for achieving faster evacuation but simply to compare the relative effectiveness of various potential strategies.

t The S3 and S4 strategies could be made available by the construction of special-purpose shelters or the improvement of existing structures.

Alternatively, access to the beach could

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a be limited so that the beach.~ population'never-exceeded the capacity of existing shelter space in'the relevant category.

Q.

Why did you include in your analysis protective strategies not readily available to the beach population?

A.

We included these strategies in response to FEMA's analysis of the adequacy of the NHRERP's provisions for_.the-beach population.

FEMA's conclusion that the NHRERP's provisions for the beach population are "adequate in concept" (FEMA Testimony at p. 8).-is based on a generic assessment of' the relative dose savings to be achieved from evacuation and sheltering in the event of a serious accident, and not on any site-specific analysis of the situation at the Seabrook~

site.A#

One of the purposes of our testimony is to demonstrate that this generic analysis is not applicable to the Seabrook site.

By introducing the E3 and E4 cases, we are able to show how generic evacuations differ from evacuations.at the Seabrook site.

The E4 case, although it accounts for difficulties which might be experienced during evacuation, i

nevertheless represents a faster rate of evacuation than is envisioned for the Seabrook beach population.

Similarly, the S3 strategy represents sheltering of a typr which could readily be achieved at a "generic" site in this i

Northeast region where, according to 1970 U.S. census data, 87%

2/

Tr. at 14192-14193; 14230; 14233; 14250.

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of the year-round housing units have basements.1' By contrast, the S1 and S2 strategies, which employ shelters of a type currently available in the New Hampshire beach area near Seabrook, provide the sheltered population even less shielding from radiation than Aldrica et al. have assumed ~would be provided to populations at other nuc1!ar power plant sites even if no protective actions were recommended. A' Q.

Please' describe how you'have selected parameters to describe the four evacuation strategies.

A.

(All)

The most important parameter here is the evacuation time.

For the E2 case, we use times estimated by Dr. Thomas Adler, using methods described'by him in separate t

testimony in this case.

(Sea Testimony of Adler, dated April 25, 1988)

Adler's calculations indicate that 4000 to 5000 vehicles will leave the beach area in an initial relatively rapid movement, before traffic jams become established.

We assume that half of these vehicles belong to residents, while the remaining half belong to members of the besch population.

3/

D. C. A ld r ich at al., P_ublic F ro t ec_ tion S t r a t egigs for Entential Nuclea r Reactor Accidents :

Shelterino Concepts with E&is11Du Public and Private St ructures, Sandia National Laboratory, SAND 77-1725, February 1978 (hereinaftet "Aldrich et al., SAND 77-1725").

4/

D.C.

Aldrich et al., SAND 77-1725 at 14.

-The characterization of an "unplanned evacuation" (strategy _

El) is necessarily speculative.

Two considerations are noteworthy for the case of Seabrook.

The first concerns-the efficiency of notification.

Because the evacuation network in the beach areas freezes into traffic' jams very quickly (see Adler Testimony), delays in notifying even a substantial.

portion of the beach population will have negligible effect on-the evacuation times.

The second consideration is planning for enhancing traffic flow.

Here the major proposal in the NHRERP is a capacity-enhancing traffic control point (TCp) at the junction of I-95 and Route 51.

(Adler, April 25 Testimony).

We have based our estimated times on two runs by Adler (April 25 Testimony] using the Applicants' "updated beach popu'lation figures"; one run with staffinc for the TCP; the other without.

We assume the same increases in times will hold for our assumed populations.

The E3 case represents evacuation with a rapidity typical of a generic nuclear plant site.

As indicated above, such a site would have a very small population within 2-3 miles.

Thus, the evacuation time will reflect only the time required to notify people, and the time required for vehicles to leave the affected area.

In some instances, evacuation times will be prolonged by factors such as a high population density.

Our E4 case represents evacuation where such factors are operative -- hence our use of the designation "generic evacuation with difficulties."

In selecting an evacuation time for strategy 16 -

0

1

-1 E4, we were guided by evacuation time estimates made for some nuclear plant sites with a high density surrounding

(

population.

We employed, in part, a recent survey by Dr. Michael Black of esacuation time estimates for fourteen densely populated sites.

This survey indicates that the population within 2 miles could be completely evacuated out to ten miles, under adverse conditions, in times ranging from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

For nine of the sites, it is estimated that this population could be evacuated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.E' Of these fourteen sites, the San Onofre site provides a pertinent comparison with Seabrook, in that people frequent the beach near the San Onofre plant on summer weekends.

Evacuation time estimates by Wilbur Smith and Associates indicate that the summer weekend population within 2 miles of San Onofre can be completely evacuated in 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />, while the population within 5 miles can be completely evacuated in 3.50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />, assuming a balanced North-South routing of evacuees.N#

Presumably it would take less time for an evacuation just to three miles.

An important point to note about our E4 case is that it reflects an overlap of evacuation with plume passage, but 1/

Michael Black, ComDatino Emeroency Re.saquig Po tentiill_. a_t Sgahrook With That of other US Nuclear Plant Sites, April 12, 1988.

6./

Wilbur Smith and Associates, Analysis of Time Requited.to Eyanuate Tran1 Lent and Permanent Pooulation From Various Areas j

Wi thin._thE_P_lume Exposu re Pa t hway Emeroency Plannino Zone:

San Onofre Nuclear Generatino Station, November 1985..

l without entrapment of the evacuating population.

Such a situation could easily arise at a typical site where factors hindering evacuation are operative.

We have chosen evacuation times which illustrate the resulting effects.

Q.

What are the conventions associated with your selection of evacuation times?

A.

(All)- First, we selected evacuation times both for the 50th percentile and for the 90th percentile members of the beach population.

In this instance, the 50th percentile member is that person who, when successfully evacuated, has been preceded by 50 percent of the initial beach population.

Likewise, the 90th percentile member is that person who, when successfully evacuated, has been preceded by 90-percent of the initial beach population.

Second, we have defined "successful evacuation" as departure from the beach area or, more precisely, as moving beyond a 3-mile radius from the Seabrook plant.

We chose a 3-mile radius because for most accident sequences that encompasses the area wherein people are at greatest risk of 4

receiving doses that could result in early fatalities and severe health effects.

(Sag, e.c.,

NUREG-1210, Vol.

4, at pp.

12-14, 28, 41).

In fact, the generic protective action strategy that is advocated in NUREG-1210 (within 3 miles of the 9

plant:

early evacuation; beyond 3 miles:

sheltering and i

selective expeditious evacuation after monitoring to locate hotspots) is based on their conclusion that "even for the worst possible accident, virtually all early fatalities can be

prevented if the art.

.ar the plant (2-to 3 miles) is "1#

evacuated before-or shortly after a release Third, our selected evacuation times begin at the time when plant conditions yield a signal that a release is imminent.

This point precedes the commencement of the release by a time intervsl hereafter designated as the "warning time."

With this convention, the term "evacuation time" actually covers a number-of sequential actions.

It includes sequential time intervals during which utility officials notify state authorities, those authorities make the decision to evacuate, notification of the i

beach population occurs, and that population moves to its vehicles.

Throughout this testimony, for both evacuation and sheltering cases, a composite notification time of 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> is assumed.

That is, the sequence of emergency response actions taken by a member of the public is assumed to begin at a point 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the release is known to be imminent.

Q.

What evacuation times do you use?

A.

(All)

For the E2 ("NHRERP evacuation") case, we use evacuation times of 4.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> and 7.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for the 50th percentile and 90th percentile population members, l

j l

respectively.

In the El ("unplanned evacuation") case, we use evacuation times of 4.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> and 8.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for these two population members.

For the E3 ("generic evacuation") case we use evacuation times of 0.9 and 1.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, while for the E4 1/

NUREG-1210, Vol.

4, at 41 l

("generic evacuation with difficulties") case, we use evacuation times of 1.5 and 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, based on an assumed clearance time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after notification.

Q.

What assumptions do you make about radiation exposure during evacuation?

A.

(All)

We assume that people are located inside cars with the windows open.

(We assume windows are open because on a hot summer beach day it is highly unlikely that people could stay in their cars for any reasonable length of time with the windows closed and the use of air-conditioning systems under the evacuation conditions expected in the Seabrook beach area may cause cars to overheat.)

A shielding factor of 1.0 is assumed for exposure to the radioactive cloud and 0.7 is assumed for exposure to contaminated ground.

In addition, we

\\

account for deposition of radioactivity on the outer and inner l

surfaces of each car and on the people inside each car.

This is done by increasing the effective shielding factor for exposure to contaminated ground from 0.7 to 1.0.

Appendix A pcovides a technical justification for these factors.

Q.

please describe how you have selected parameters to describe the four sheltering strategies.

i A.

(All)

For our illustrative analysis, four parameters are important:

the time it takes people to get into shelters; the quality of the shelter; the time during which sheltering occurs; and the time required for successful subsequent evacuation.

As our testimony evaluating the NHRERp's provisions for sheltering indicates, without any plans in place for implementing a shelter strategy in the beach area the task of getting people into shelter could be a considerable problem at the Seabrook site.E' Thus, our S1 ("ad hoc shelter") case assumes that people are still in the open, seeking shelter, at times when the radioactive plume may have arrived.

In our remaining three sheltering cases, it is assumed that the relevant population is sheltered prior to plume arrival.

It will be noted that careful planning would be necessary to achieve that result, and we do not imply that such planning would be successful.

4 Earlier in this testimony we have outlined the types of shelter which would characterize each sheltering strategy.

Our 1

choice of specific parameters to describe those shelter types is described later.

For all four sheltering cases, we assume that a portion of the population who are instructed to shelter will-instead choose to evacuate.

These evacuees, who do not shelter, are assumed to account for 50 percent of the resident and employee population within the EpZ, together with 25 percent of the l

beach population.

We further assume that people who do shelter will be instructed to leave shelter only after the roads have 1

cleared of the initial evacuees.

Based on Adler's testimony, i

B/

See Testimony of Goble, Renn, Eckert and Evdokimoff, dated April 25, 1988.

J i

a we assume that the roads will-be cleared of the initial evacuees within 3.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />.

Allowing 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for this information to be communicated to the sheltering population, this means that everyone in shelter (from the remaining resident population in the beach area and the remaining beach population) is assumed to leave shelter at a point 4.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> after a release is known to be imminent.

We assume that post-sheltering evacuation will be qualitatively similar to a direct evacuation, except that the evacuating population will be smaller (since an initial group is assumed to evacuate instead of seeking shelter).

In selecting post-sheltering evacuation times, we employ Adler's calculations, adjusted for the smaller population.

This 1

approach ignores any special behavioral effects which might arise as populations evacuate areas known to be contaminated.

In introducing the S3 and S4 strategies, we pointed out that sheltering of this quality might be obtainable at Seabrock if access to the beach were limited so that the beach population never exceeded the capacity of existing space in the l

relevant category.

If such an approach were taken, the post-sheltering evacuation times would be smaller than assumed here.

This point could be pursued through further analysis if appropriate.

Q.

What conventions do you employ in describing the sheltering strategies?

A.

(All)

As with the evacuation strategies, we selected sheltering and evacuation times for the 50th percentile and _____

-- A

90th percentile members of the-initial beach population, as previously defined.

Here also, "successful evacuation" is defined as moving beyond a 3-mile radius from-the Seabrook plant.

As mentioned above, our sheltering cases assume that 25 percent of the beach population will evacuate immediately, without seeking shelter.

In some instances, people in this group will accrue greater radiation ~ doses than-many in the sheltering population.

The capturing of this effect would require a more elaborate analysis than we have conducted so far, and would involve ranking the beach population by dose rather than by precedence in achieving successful evacuation.

We do not expect that such an analysis would lead to change in our overall conclusions.

As for evacuation, the time at which sheltering sequences commence is defined here as the point when plant conditions signal that a release is imminent, a point which precedes commencement of the release by a time interval known as "warning time."

However, unlike evacuation strategies, sheltering strategies involve three phases:

the time interval i

during which shelter is sought; the sheltering interval; and the subsequent evacuation interval.

Q.

What time intervals did you select?

A.

(All).

As mentioned earlier, we assumed that, in the S2, S3 and S4 cases, people reach shelter before the plume arrives.

In these cases,.the pre-sheltering interval is thus effectively zero.

For the S1 case, we assume that the 50th percentile person will enter shelters after 1.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, while the 90th percentile person enters shelter after 3.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

These times are derived by adding a 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> notification interval to time estimates made by Ortwin Renn in testimony before this Board.E' I

As mentioned above, for each sheltering strategy we assume that people begin post-sheltering evacuation at a point 4.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> after a release is known to be imminent.

For the S2, S3, and S4 cases, we select post-sheltering evacuation times of 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 5.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for the 50th percentile and 90th percentile person, respectively.

In the S1 case, we are interested in the

_averaae post-sheltering evacuation time, which we assume to be 3.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

The 50th percentile and 90th percentile persons are distinguished under the S1 strategy by the difference in their pre-sheltering intervals.

Q.

What shielding factors did you select to represent shelter quality?

A.

(All)

For sheltering in the S1 and S2 cases, we were guided by the NHRERP, whose decision criteria for sheltering assume a shielding factor of 0.9 for cloud shielding, and 2 air changes per hour.

For a structure of this kind, an appropriate l

shielding factor for radionuclides deposited on the ground is 2/

See Testimony of Goble, Renn, Eckert and Evdokimoff, dated April 25, 1988.

At page 78, a median estimate of 2.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is shown for the pre-shelter interval for the 90th percentile person.

Under cross-examination on May 9, 1988 (see Transcript, page 11108), Renn estimated the pre-shelter interval for the 50th percentile person at 55-60 minutes.

We assume an interval of 0.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> for this person.

- 24

0.5.10/

In the S1 case, it is also necessary to account for deposition of radioactive material on people who are exposed to the plume prior to entering shelter.

We account for this by increasing the ground shielding factor in proportion to the fraction of the duration of plume passage during which the person is exposed prior to sheltering, up to a maximum ground shielding factor of 0.8.

Appendix A provides supporting information.

As mentioned above, the S3 strategy is equivalent to l

i sheltering in the basements of typical New England houses.

For.

I l

this type of shelter, cloud and ground shielding factors of 0.5 and 0.08, respectively, are appropriate.11' We assume 1 air change per hour, j

The S4 strategy is equivalent to sheltering in a medium-sized office or industrial building.

Here, cloud and i

ground shielding factors of 0.2 and 0.02, respectively, are i

typical.1A#

We assume 0.5 air changes per hour.

l Q.

What assumptions do you make about radiation exposure prior to sheltering and during post-shelter evacuation?

LQ/

Aldrich et al., SAND 77-1725, Tables 1 and 2.

We use values from the upper end of the range reported in Table 2.

11/

Aldrich at al, SAND 77-175, Tables 1 and 2.

12/

Aldrich Et 11, SAND 77-175, Tables 1 and 2. - _ - - - - _ _ _ _ _ _ - _ - _ _ _ _ - _ _ _

A.

(All)

The S1 case is the only one.in which pre-sheltering radiation exposure must be considered.. Here, we assume a cloud shielding factor of 1.0 and a ground shielding factor of 1.0.

The latter factor reflects the deposition of I

radioactivity on exposed people.

For post-sheltering evacuation under case S1, we also assume a cloud shielding factor of 1.0, but assume a variable ground shielding factor.

To account for deposition both on cars and on people, we assume that the ground shielding factor ranges from 0.9 to 1. 2, in proportion to the traction of the duration of plume passage during which the person is exposed prior to sheltering.

For post-sheltering evacuation in the S2, S3 and S4 cases, we assume a shielding factor of*1.0 for exposure to the radioactive cloud.

However, we employ an effective shielding factor for exposure to contaminated ground of 0.9, instead of the factor of 1.0 used in the direct evacuation case.

The difference is based on our expectation that less radioactivity will be deposited on the skin.

Appendix A provides a justification for this assumption.

Q.

please summarize the parameters selected for each strategy.

A.

(All)

Table 1 shows the exposure times selected for each strategy, while Table 2 shows the shielding factors.

Together with the statements made immediately above about the rates of air change in various shelters, these two tables completely characterize the six emergency response strategies. - - __________ __

i

V.

POTENTIAL REACTOR ACCIDENTS Q.

How did you select parameters to represent a range of accident conditions?

A.

(All)

In the spirit of NUREG/CR-ll31, we selected the parameters-estimated in WASH-1400 for the accident release categories PWR 1 through PWR 9.

These release categories ercompass the spectrum of potential accidents.

WASH-1400, Appendix VI, Table VI 2-1 (Attachment 2 to-this-testimony}

provides a complete characterization of these release categories, including their estimated probabilities of occurrence.

We actually go beyond NUREG/CR-ll31, in that the more limited set of release categories PWR1 through PWR5 was used in NUREG/CR-ll31 as a basis for comparative analysis of the effectiveness of emergency response strategies.

Through its reference to that analysis, and through presentation of results from related analyses, NUREG-0396 clearly regards these five release categories as playing an important role in defining the emergency planning basis.

However, our points are made even more forcefully by considering the entire spectrum of potential accidents.

Q.

Do you endorse the WASH-1400 estimates of the probability and other characteristics of severe core damage accidents?

i A.

(All)

Not necessarily.

Our purpose here is to create nn analogte to the analytic procedure which underlies 4

t

' 1 A

NUREG/CR-ll31 and, through its reference to that document, NUREG-0396.

Q.

Please explain the relationship between accident release characteristics and the effectiveness of precautionary _

emergency responses.

A.

(All)

The "warning time", as defined above, provides a time interval during which emergency responses can be i

initiated.

If the warning time is long enough, it may be possible to evacuate people before they are exposed to the radioactive plume, with_an obvious public health advantage.'

The State of New Hampshire apparently believes that warning times at Seabrook will be long enough to allow such successful precautionary evacuation.

In the State's Letter of I

i "ebruary 11, 1988 to FEMA, it is stated (at p.4) that "the addition of these precautionary measures alleviates most concerns about sheltering the beach population."

Q.

Has New Hampshire demonstrated any basis for this assumption?

A.

(All)

No.

In order to demonstrate such a basis, New Hampshire or the applicants would need to address the potential characteristics of accidents specific to the Seabrook plant.

There is no testimony on that subject before this Board.

Q.

How have you handled the issue of warning time?

4 A.

(All)

Following the planning basis in NUREG-0396, we have analyzed the relative effectiveness of emergency response

.I strategies across the range of release categories PWR1 through PWR9.

The warning times for these release categories are provided by WASH-1400.

(See Attachment 2).

(

- 28 l

VI.

ES.TIMATIN1_THE RELATIVE EFFECTIVENESS OF-THE EMERGENCY RE.SpONSE STRATEGIES Q.

Please outline the analytic procedure you employ to assess the relative effectiveness of emergency response strategies.

A.

(All)

We use three measures of relative effectiveness.

First, we use the total exposure of a relevant.

individual over the time interval until successful evacuation is completed, relative to the exposure of the 50th percentile individual in the "unplanned evacuation" (S1) case.

Here, "exposure" is physically equivalent to the collective dose to the red bone marrow of the exposed population, which is in turn similar to the collective whole body dose.

Second, we use the probability of an individual suffering early death, again relative to the 50th percentile individual in the "unplanned evacuation" (SI) case.

Finally, we use the probability of an individual suffering prodromal vomiting, relative to the same 50th percentile individual.

A single measure of effectiveness such as "dose savings" (see Applicants Testimony p.

4) is not adequate to characterize emergency preparedness.

That is because the goals of emergency planning inc3ude the avoidance of early death and injuries (see NUREG-0654, p.

6) as well as dose reduction, and those early health effects have thresholds.

A protective response strategy that is primarily directed toward reducing the aggregate dose to a large population (such as the ordering of a prompt evacuation over a large region) might be quite ineffective at preventing injuries and deaths to a population close to i

1 e

I the plant.

We, therefore, consider dose reduction, reduction in the number of deaths, and reduction in one representative early injury to be three independent measures for judging the effectiveness of a response.

For each of the release categories PWR 1 through PWR 9, we estimate the radiation exposure and the probabilities of early health effects for each emergency. response strategy, both for the 50th percentile and 90th percentile individuals.

We use-the MACCS computer code for this purpose, assuming a wind-speed of 12 miles per hour (20 km/hr) and Class C (moderately unstable) stability.

These meteorological conditions are intended as representative fair weather conditions.

They are not favorable conditions for emergency response, nor are they "worst case" conditions.

These results are combined over the release categories PWR 1 through PWR 9 by weighted averaging, where the weights correspond to the probabilities of occurrence of each release category, as estimated in WASH-1400.

In this respect, we employ a more sophisticated procedure than NUREG/CR-1131, which merely combines the release categories into one composite category.

Q.

How do you analyze the relationship between air change in buildings and inhalation exposure?

A.

(Goble)

We have assumed continuous exchange of indoor air with air outside and have compared the average concentration indoors with the concentration outdoors assuming the outdoor concentration is constant for the duration of the l

release (as specified for-each accident category in WASH-1400, Table VI 2-1).

The indoor average is calculated only for the reriod of plume passage except that, in_ agreement with the NHRERp, we use the 1-hour average for releases of less than an hour duration.

We do not assume that the building provides any filtering.

The values we have used for'various durations of release and air exchange rates are shown in Table 3.

Q.

please summarize your results.

A.

(All)

Tables 4 through 6 and Figures 1 through 3 summarize the results of our assessment.

Our interpretation of the summarized results depends on two sets of observations:

one is the relative raagnitude of the entries in the tables; the second is the sensitivity of these entr'ies to particular assumptions in the modeling.

The magnitudes in the tables and figures show:

1) The "NHRERp evacuation" (E2) case is only marginally more effective than is the "unplanned evacuation" (El) case according to all three measures of effectiveness; 2) The "generic evacuation" (E3) and the S3 and S4 sheltering cases are substantially more effective than either the El or the E2 cases.

Thus, protective responses which are available at most nuclear power plant sites provide significant reduction in exposure to radiation and in early deaths and injuries as compared with emergency responses envisioned for Seabrook; 3) The E4 and S2 (shelter equivalent to wood frame buildings without basements) cases appear to have j

some potential effectiveness, with E4 appearing generally i

better according to these measures; 4) The "ad hoc shelter" (SI) case is not an effective response.

. i

.-,-e

,-,m,

The quoted results are potentially sensitive to a wide range of uncertainties in the modeling, including details of accident characteristic and meteorological conditions.

Of most interest in interpreting the results are the effects of possible variation in warning times and duration of release.

The results for ths El and E2 cases are quite insensitive to-moderate changes in warning time and duration of release.

The three sheltering cases, S2, S3 and S4 are insensitive to warning time, until it becomes short enough that a significant fraction of the population remains outdoors at the time of plume arrival.

The effectiveness of sheltering, especially poor sheltering, decreases moderately with increased duration of release, because large inhalation exposures may be anticipated.

The E4 case is most sensitive to changes in warning times and duration of release (since it represents an evacuation which overlaps with plume passage, but does not have a trapped population).

Increases in warning time and release duration provide substantial increases in effectiveness, a decrease in warning time reduces the effectiveness.

To conclude:

the results of our analysis show with reasonable robustness that:

1) As a response to the spectrum of potential accidents, including those used in the NRC planning basis, the NHRERp appears to be only marginally more effective in reducing exposures and early health effects for the transient beach population than an unplanned evacuation.

The situation would be characterized by "entrapment" of the population, exposing them potentially to the major portion-of the release uhile they are immobile and without shelter; 2) The,

m,,

relative effectiveness of the NHRERP is much poorer for the spectrum of accidents than the effectiveness expected for emergency response at most nuclear power plant sites where sheltering and more rapid evacuation are provided;

3) Our analysis is not adequate to quantify the benefits of a sheltering strategy as S2, nor do we address its feasibility, i

The analysis does indicate that there are potential benefits to be derived from such'a planned sheltering response, but th'at-no such benefit would be derived from an ad han sheltering response.

In view of the ineffectiveness'of the proposed plan and the absence of a detailed analysis of the feasibility of a sheltering strategy based on existing or improved buildings, i

j New Hampshire has no basis for rejecting sheltering.as a l

planned emergency response.

, 3

~.

4 APPENDIX A SHIELDING FACTORS DURING EVACUATION BY AUTOMOBILE:

TECHNICAL DISCUSSION i

-Due to the relatively lightweight structure in the upper part of an automobile, and the presence of windows, the shielding factor for exposure of a vehicle occupant to a radioactive cloud is effectively 1.0.

That is, a person inside an automobile gains no protection against cloudshine.

For exposure to contaminated ground, neglecting deposition of radioactivity on the automobile or on the exposed person, the shielding factor for a vehicle occupant can be calculated to have a range of 0.53-0.78.

This rance represents an updating of the 0.4-0.7 shielding factor range used in the Reactor Safety Study (WASH-1400).

Cars are lighter today (and will be more so in the future) compared to the 1975 vehicles analyzed in the Reactor Safety Study.

Assuming that vehicles involved in an evacuation will be 30% lighter than 1975 vehicles,1# the appropriate shielding factor range turns 1/

Due especially to the decrease in the amount of steel used in U.S.-built cars, the material weight of U.S. cars dropped 15% between 1975 and 1981 and was projected to drop another 15%

by 1985.

(Table 4.3, p.

122, Transportation Energy Data Book, edition 6, G. Kulp, M.C. Holcomb, ORNL-5883 (special), Noyes Data Corporation.)

4 out to be 0.53-0.78.2 Now, the relative contributions of doses from deposited material, accounting for deposition on the ground, on or in the automobile, or on people, can be obtained as follows:

Dose per unit time (Relative to dose from a flat, contaminated plane):1#

A) to person standing on contaminated beach, parking lot, road, ete:

1.0 x Sg A/

B)

Dose inside car from contaminated ground:

1.0 x Sc kl 2/

Shieldfng varies exponentially with mass per unit area.

Thus ( 9) / = 0.53; (.7) 7 = 0.78-3/

In the absence of detailed calculations, we assume that absorption effects in air can be handled by neglecting all absorption at distances less than 100 meters and by treating absorption beyond 100 meters as total.

Thus, we replace the exact problem of a contaminated plane of infinite extent by a finite circular surface of radius 100 meters.

Since the integral over the disk turns out to be logarithmic with radial distance, the total dose is insensitive to the cutoff distance chosen.

These calculations are conservative since they ignore ground scattering effects which increase relative doses from deposition close to the receptor.

Deposition is assumed to proceed unifor!aly on any external surface regardless of the surface's orientation.

Thus, a square centimeter of ground is assumed to receive the same contamination as a square centimeter of skin.

4/

Shielding factor, Sg = 0.47-0.85.

Egg WASH-1400, Appendix VI.

5/

Shielding factor, Sc = 0.53-0.78.

Egg WASH-1400, Appendix VI.

9 C)

Dose inside car from radioactivity deposited on outside of vehicle:

.22 x Sc f/

D)

Dose inside car. from radioactivity deposited on inside of vehicle with open windows:

.04

.2 2/

E)

Dose from skin contaminated while outside vehicles:

.35 H/

6/

Based on numerical integration over an idealized automobile, deposition is assumed to take place on the underside of the vehicle as well as on the top surface'.

2/

This case would occur: (1) if windows had been left open, or (2) if evacuees reached their vehicles and opened windows before plume _ passage were complete.

The low number corresponds to low wind speeds; the high number corresponds to high wind speeds.

H/

An estimate of the relative contribution of skin contamination to the total dosa can be obtained by replacing the complex shape of the human body with a set of bounding.

geometric surfaces:

1) sphere:

the dose rate at the center of a sphere contaminated with N curies of radioactivity per square centimeter is 43% of the dose rate 1 meter above a circle of 100 meter radius that has also been contaminated with N curies per unit area.

Although a cylindrical model would be more accurate, the results will not differ by a large amount, as shown below.

2) right circular cylinder:

numerical integration in the case of a cylinder with radius 1/10th of the length indicates that the sverage centerline dose is approximately 17% greater than the sphere center dose discus ad previously.

For a cylinder with radius 1/5th of the length, the average centerline dose is slightly less than the sphere case.

The results of these rough calculations suggest that direct contamination of people must make a significant contribution to the total dose.

We take the numerical relationship to be 35%,

that is, the skin contribution is assumed to be 35% of the dose from contaminated ground.

F)

Dose from skin contaminated while insidt vehicles with open windows.

.17 2/

For our illustrative analysis, we assume that the basic shielding factor without deposition on the car or on people --

that is, the factor Sc -- is 0.7.

During direct evacuation, we assume that car windows will be open during passage of the radioactive plume.

Thus, people inside cars will be exposed to dose elements B, C and D from the above list.

This yields an effective ground shielding factor in the range 0.89-1.05.

In addition, people will be exposed to doses from radioactive material deposited on their skin or clothes -- that is, to dose elements E or F from the above list.

Considering all these dose contributions, we assume an overall effective ground shielding factor of 1.0 for the direct evacuation case.

For post-sheltering evacuation, it is likely that many cars will have been left with their windows closed, and will not have been internally contaminated during plume passage.

In addition, people will have been protected from deposition of radioactive material on their bodies, to an extent dependent on the rate of shelter.

However, people will be at risk of.being contaminated after leaving shelter, through brushing against 2/

We take this dose to be half of the value for a person standing in the open, assuming that half of a person's surface area is pressed against a seat and, therefore, not subject to deposition..

..~.. ~.. -

t contaminated; buildings'.or vehicles or from passage through.

clouds of resuspen'ded material'.

We account for all these-considerations by assuming an overall effective ground shielding. factor'of-0.9 for the post-shelter-evacuation case.

1 1 'j

1 TABLE 1 POTENTIAL EXPOSURE TIMES FOR EACH STRATEGY TIME IN THE-OPEN BEFORE TIME IN TIME ON SHELTERING SHELTER THE ROAD STRATEGY (hours)

_( hou r s )

(hours)

(A) Evacuation Strategies El. Unplanned Evacuation 0,

0 0,

0 4.75, 8.0 E2. NHRERP Evacuation 0,

0 0,

0 4.25, 7.0 E3. Generic Evacuation 0,

0 0,

0 0.9 1.4 E4. Generic Evacuation with Difficulties 0,

0 0,

0 1.5 2.5 (B) Sheltering Strategies S1. Ad Hoc Shelter 1.4, 3.1 2.95, 1.55 3.0 3.0 S2. Shelter Equivalent to Wood Frame 0,

0 4.25, 4.25-2.5 5.0 Buildings Without Basements S3. Shelter Equivalent 0,

0 4.25, 4.25 2.5 5.0 to Wood Frame Buildings With Basements S4. Good Shelter 0,. 0 4.25, 4.25 2.5 5.0 LLQ1EB:

1.

The entries x, y indicate times for the 50th percentile and 90th percentile population members, respectively.

2.

Sequences of protective action begin when plant conditions signal that a release is imminent.

The three time periods shown across each row are consecutive.

3.

"Time on the road" terminates when people move beyond a 3-mile radius from the Seabrook plant.

TABLE 2 SUIELQlts'G _E6 CIQ8S _EQB_EG CU_SIBOIEGY CLOUD SHIELDING GROUND SHIELDING SIBOIEGY E6CIDB FACTOR BEFORE IN IN BEFORE IN IN (A> Eseacuation_Stratesies SUELIE8 SUELIE8 CG8 SUELIE8 SUELIE8 COB E1. Ur 'lanned NA NA 1.0 NA NA 1.0 Evacuation E2. NHRERP NA NA 1.0 NA TJA 1.0 Evacuation E3. Generic NA NA 1.0 NA NA 1.0 Evacuatson E4. Generic NA NA 1.0 NA NA 1.0 Evacuation with Dafficulties (8) Shelterins_Straicair.a 2

2 S1. Ad Hoc Shelter 1.0 0.9 1.0 1.0 0.5 to 0.0 0.9 to 1.2 S2. Shelter Equiv.

NA 0.9 1.0 NA 0.5 0.9 to Wood Frame Building Without Basements S3. Shelter Equiv. to NA 0.5 1.0 NA O.08 0.9 Wood Frame Buildings With Basements S4. Good Shelter NA 0.2 1.0 NA 0.02' O.9 NQIES 1.

"NA" means "Not Applicable".

2.

Across this range, the factor is proportiona.' to the fraction of the duration of plume passage during which the person is exposed prior to sheltering.

TABLE 13 FRACTION OF' EXTERNAL INHALATION EXPOSURE THAT WOULD' OCCUR' INDOORS Number Of Air Chances'Per Hour.

Duration'of Release' 2

1

.5

.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

.5

.35

.22 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

.65

.45

.29 3.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />

.85

.65

.45 4.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />

.9

.75

.55 d

TABLE 4 BELATIVE EXPOSURE FOR EACH STRATF2X 50th PERCENTILE 90th PERCENTILE STRATEGY-PERSON PERSON (A)

Evacuation Stratecies El.

Unplanned Evacuation 1.0

'1.24 E2, NHRERP Evacuation 0.95 1.16 E3.

Generic Evacuation 0

0.33 E4.

Generic Evacuation 0.46 0.70 With Difficulties (B) Sheltering Strategies Sl.

Ad Hoc Shelter 0.97 1.43 S2.

Shelter Equivalent to 0.71

~0.88 Wood Frame Buildings Without Basements S3.

Shelter Equivalent to 0.49 0.66 Wood Frame Buildings With Basements S4.

Good Shelter 0.38 0.55 liqTES:

1.

The entry for the 50th percentile person for the "Unplanned Evacuation" strategy is arbitrarily set at unity.

2.

Here, "exposure" is physically equivalent to red marrow dose.

)

v

l I

Relative Effectiveness of Response in Reducing Expected Doses 2-N 8

2 E Dose 90*

J

,B O

l

.g

)

0-E1 E2 E3 E4 S1 S2 S3 S4 STRATEGY (See text for description)

FIGURE 1

TABLE 5 RELATIVE PROBABILITY OF' EARLY DEATH FOR'EACH STRATEGY 50th PERCENTILE

.90th PERCENTILE

-STRATEGX PERSON PERSON (A) Evacuation'Stratecies El. Unplanned Evacuation 1.0.

-6.55 E2. NHRERP P.vacuation 0.84 3.45 E3. Generic Evacuation 0

0.0005 E4. Generic Evacuation 0.004-0.27 With Difficulties (B) Shelterina Stratesigs Sl. Ad Hoc Shelter 1.26 47.1 S2. Shelter Equivalent to 0.09 1.76 Wood Frame Buildings Without Basements S3. Shelter Equivalent to 0

0.042 Wood Frame Buildings i

With Basements l

S4. Good Shelter 0

0.013 ILQIE:

The entry for the 50th percentile person for the "Unplanned Evacuation" strategy is arbitrarily set at unity.

Relative Effectiveness of Response A

in Reducing Early Deaths 47 10 -

8-6-

c.

E 50 %ile

,y j E 90 %ile o

~

2-n' 0

\\

E1 E2 E3 E4 S1 S2 S3 S4 STRATEGY (See text for description)

FIGURE 2

9 s.

TABLE 6 RELATIVE PROBABILITY.0F PRODROMAL VOMITING FOR EACH' STRATEGY 50th PERCENTILE 90th PERCENTILE STRATEGY PERSON PERSON (A) Evacuation Stratecies El. Unplanned. Evacuation 1.0

.2.08 E2. NHRERP Evacuation.

0.80 1.92 E3. Generic Evacuation 0

0.016 E4. Generic"Evacuation 0.056 0.24 With Difficulties (B) Shelterina Strateaies S1.,Ad Hoc Shelter 1.52 2.32 S2. Shelter Equivalent to 0.81 1.73 Wood Frame Buildings Without Basements S3. Shelter Equivalent.to 0.24 0.88 Wood Frame Buildings With Basements S4. Good Shelter 0.12 0.63 HQIE:

The entry for the 50th percentile person for the "Unplanned Evacuation" strateg** is arbitrarily set at unity.

1

i 4

Relative Effectiveness of Responee In Reducing Prodromal Vomiting l

3-l 2-e O

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before Administrative Judges:

Ivan W.

Smith, Chairperson Gustave A.

Linenberger, Jr.

Dr. Jerry Harbour

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In the Matter of

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Docket Nos.

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50-443-444-OL PUBLIC SERVICE COMPANY OF NEW

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(Off-site EP)

HAMPSHIRE, ET AL.

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June 30, 1988 (Seabrook Station, Units 1 and 2)

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ATTACHMENTS TO REBUTTAL TESTIMONY OF.DR. GORDON THOMPSON, DR. ROBERT L. GOBLE, AND DR. JAN BEYEA ON BEHALF OF THE ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS ON SHELTERING CONTENTIONS Carol Sneider Assistant Attorney General Nuclear Safety Unit Department of the Attorney General Commonwealth of Massachusetts One Ashburton Place Boston, MA 02108-1698 (617) 727-220G L

. t ATTACHMENTS.

Professional Qualifications'_of Dr. Gordon Thompson Professional' Qualifications of Dr. Robert.L. Goble Professional Qdalifications of Dr. Jan Beyea

-Attachment 2 WASH-1400, Appendix VI, Table VI 2-1 F

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ATTACHMENT 1

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PROFESSIONAL QUAIIFICATIONS OF DR. GORDON Ts:0MPSON t

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I Resume for Gordon Thompson

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January 1987 Professional Exoertise Consulting scientist on energy, environment, and international securi Education

• PhD in Applied Mathematics,0xford University,1973.

• BE in Mechanical Engineering, University of New South Wales, Sydn Australia,1967.

• BS in Mathematics and Physics, University of New South Wales,1966.

Current Accofntments

• Executive Director, Institute for Resource & Security Studies ( IRSS )

Cambridge, MA.

• Coordinator, Proliferation Reform Project ( an IRSS project ).

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• Treasurer, Center for Atomic Radiation Studies, Acton, MA.

• Member, Board of Directors, Political Ecology Research Group Oxford UK

• Member, Advisory Board, Gruppe Okologle, Hannover, FRG.

Consultina Excertence ( selected )

• Natural Resources Defense Council, Washington, DC, 1986-1987 : prepa of testimony on hazards of the Savannah River Plant.

• l.akes Environmental Association, Bridgton, ME,1986 : analysis of federal regulations for disposal of radioactive waste.

• Greenpeace, Hamburg, FRG,1986 : participation in an internationa the hazards of nuclear power plants.

• Three Mlle island Public Hesith Fund, Philadelphia, PA,1983-present studies related to the Three Mlle island nuclear plant.

• Attorney General, Commonwealth of Massachusetts, Boston, MA,1984-present : analyses of the safety of the Seabrook nuclear plant.

• Union of Concerned Scientists, Cambridge, MA, 1980-1985 : studies on energy demand and supply, nuclear arms control, and the safety of nuclear installations.

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• Conservation Law Foundation of New England, Boston, MA,1985 :

preparation of testimony on cogeneration potential at the Maine facillttes of Great Northern Paper Company.

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• Town & Country Planning Association, London, UK, 1982-1984 : coordination and conduct of a study on safety and radioactive waste implications of th'e proposed Sizewell nuclear plant.

• US Environmental Protection Agency, Washington, DC, 1980-1981 assessment of the cleanup of Three fille Island Unit 2 nuclear plan't.

• Center for Energy & Environmental Studies, Princeton University, Princeton, RJ,1979-1980 : studies on the potentials of various renewable energy sources.

• Government of Lower Saxony, Hannover, FRG, 1978-1979 : coordination and i

conduct of studies on safety aspects of the proposed Gorleben nuclear fuel center.

Other Excertence ( selected )

• Co-leadership ( with Paul Walker ) of a study group on nuclear weapons proliferation, Inst tute of Politics, Harvard University,1981.

• Foundation ( with others ) of an ecological political movement in 0xford, UK, which contested the 1979 Parliamentary election.

• Conduct of cross-examination and presentation of evidence, on behalf of the 4

Political Ecology Research Group, at the 1977 Public inquiry into proposed expansion of the reprocessing plant at Windscale, UK

• Conduct of research on plasma theory ( while a PhD candidate ), as an associate staf f member, Culham Laboratory, UK Atomic Energy Authority, 1969-1973.

• Service as a design engineer on coal plants, New South Wales Electricity Commission, Sydney, Australia,1968.

Publications ( selected )

• The Nuclear Freeze Revisited ( written with Andrew Haines ), November 1986, Nuclear Freeze and Arms Control Research Project, Bristol, UK

• Nuclear-WeaDon-Free Zones A Survey of Treatles and Procosals ( edited with David Pitt ), Croom Helm Ltd, Beckenham, UK, fortncoming.

• International Nuclear Reactor Ha7ard Study ( written with fif teen other authors ), September 1986, Greenpeace, Hamburg, FRG ( 2 volumes ).

• "What happened at Reactor Four" ( the Chernobyl reactor accident ), Bulletin of the Atomic Scientists. August / September 1986, pp 26-31.

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l PROFESSIONAL QUALIFICATIONS OF DR. ROBERT L.

GOBLE i

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4 May 1988 ROBERT L. GOBLE Center for Technology, 137 Gardner Road Environment, and Development Brookline,MA 02146 and Department of Physics 617-566-4574 Clark University Worcester, MA 01610 617-793-7683 Present Position Research Associate Professor of Environment, Technology, and Society, and Adjunct Associate Professor of Physics, Clark University.

Education B.A. (Honors), Physics, Swarthmore College, June 1962 Ph.D., Physics, University of Wisconsin, January 1%7 Previous Employment 1984 - 85 Princeton University, Cer,ter for Energy and Environmental Studies and j

Department of Philosophy: Hewlett Fellow 1

1976 -

Clark University, Physics Department and Program on Science, Technology, and Society: Visiting Assistant Professor, Research Associate Professor (on leave 1984-85) 1974 -76 Montana State University, Physics Department: Assistant Professor, Adjunct Assistant Professor 1972 - 74 University of Utah, Physics Department: Research Associate /

Associate Instuctor 1969 - 72 University of Minnesota, Physics Depanment: Research Associate 1966 - 69 Yale University, Physics Department: Research Staff Instructor 1962 -66 University of Wisconsin, Physics Department: NSF Cooperative Fellow, Research Assistant Current Research Air Quality / Acid Deposition:

Assessments and Reviews Tracer and Transport Studies local Air Quality Risk Assessment / Hazard Mangement:

Comparing Hazards and Hazard Assessment Methodologies Ethical Issues in Hazard Management Planning Issues for Waste Disposal Radon Exposure and Health Effects Emergency Planning for Nuclear Power Plants

Recent Research Activities 1983 -

Emergency Planning for Nuclear Power Plants (Consultant to New Hampshire Attomey General's office, Three hiile Island Public Health Fund, hiassachusetts Attomey General's Office, Ontario Nuclear Safety Review Board) Reviews, Testimony, Consequence Analysis. hf ajor Planning Project at Thfl.

1985 -

Risk Assessment and Socio Economic Impacts in Radioactive Waste Management (Consultant to State of hiississippi, Citizens Against Nuclear Trash, and State of Nevada /hiountain West Inc.) Several reports, testimony.

1977 -

Ethical Issues in Hazard Management (supported by NSF-EVIST, Hewlett Foundation, Principal Investigator and Co-Principal Investigator). Book in progress; articles on radioactive waste, occupational and environmental hazards comparison, susceptible workers.

1983 - 86 Acid Deposition Assessment,(Consultant, U.S. EPA). Co-author, Acid Deposition and its Effects: Critical Assessment Document,1985. Section Author,1985 Assessment section on Sulfur Mass Balance.

1982 - 83 Implementation of the Occepational12ad Standard. Supported by OTA; (Principal Investigator, four researchers). Report published as attachment to OTA Report: Preventing illness and iniurv in the Workolace.

1977 - 82 Nuclear Power Plant Performance,(supported in part by DOE, Principal Investigator, three researchers). Articles relating nuclear power plant performance to general plant characteristics.

I 1976 -83 Demonstration of a Grid-Connected Cogeneration System at Clark University; technical advisor and coordinator for Clark University. The program resulted in the construction of a $2.5 million National Demonstration Power Plant, based on a gas fired 1.8 MW diesel engine with heat recovery fmm the exhaust and Jacket. He plant began operation in Summer 1982; it supplies appmximately half Clark's thermal energy needs and enough excess electricity so that half the output will be sold to the utility.

Teaching and Student Research Supervision Dissertation Advisor for M. Yersel, May 1984 Ph.D.

Atmospheric Turbulence and Diffusion in an Urban Environment.

Student Research Pmjects:

Supervision of more than 20 graduate and undergraduate students in energy, air pollution, and physics: High Energy Cosmic Ray Showers; Clark Energy Use Profiles and Models; Environmental Tradeoffs in Cogeneration; Cogeneration Road Map for Colleges and Universities; Measurements of Worcester Weather; Pollutant Dispersal in Urban Areas; Effects of Buildings on Pollutant Dispersal; Cogeneration System Monitoring; Radon in Indoor Air; Radon - Induced Health Effects; AIDS and Health Care Programs in Zaire; 2

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1 Environment, Technology, and Society:

Introductory Case Studies on Population and Food; Special Topics in Altemative Energy:

Cogeneration; Altemative Energy Systems Laboratory, Graduate Core Course: Limits of the Eanh, Science Writing Seminar.

Physics for Non-Science Student:

Einstein's Ideas; Cultural Astronomy; College Physics; Particle Physics (an honors course with laboratory); Urban hieteorology Undergraduate Physics:

Electricity and hfagnetism; Classical Physics Graduate Physics:

Quantum hiechanics; Advanced Quantum hfechanics; hiathematical hfethods l

Professional Societies American Association for the Advancement of Science American Physical Society: Forum on Science and Society; Division of Particles and Fields Sigma Xi l

Society for Risk Analysis Air Pollution Control Association Service 1976 - 83 City of Worcester Energy Task Force 1977 -

Clark Science. Technology, and Society, Program Committee 1978 - 80 Altemate, Clark Graduate Board 1978 -

Clark Energy Task Force 1981 - 84 Faculty Lounge Committee (installation and operation of new faculty dining room) 1983 -

CENTED Steering Committee Recent Individual Awards and Honors National Science Foundation / National Endowment for the Humanities:

Individual Incentive Award (Jan.1984-Jan.1986)

Princeton University: Hewlett Fellow (Sept.1984-June 1985)

American Association for the Advacement of Science: Summer Fellowship in Environmental Science (Summer 1982)

Other Activities Consulting Agreements:

1986 - 88 hfassachusetts Attomey General's Office, Sheltering in the Emergency Plans for the Seabrook Nuclear Reactor.

3

1986 - 87 Rhode Island Dept. of Environmental Management. Risk Assessment hiethods for Toxic Substances in Seafood.

1986 - 88 State of Nevada / Mountain West Inc., Risk Analysis for Radioactive Waste Disposal.

1986 Citizens Against Nuclear Trash - Socio Economic Impacts of Radioactive Waste Disposal.

1985 Mississippi Health and Safety Office - Radioactive Waste Risk Analysis.

1983 New Hampshire Attorney General - Nuclear Emergency Planning.

1982 - 86 U.S. EPA: Acid Deposition Assessment.

1986 Lecturer, Harvard School of Public Health, Short Course on Risk Assessment and Occupational Health.

1981 Lecturer, Depanment of Engineering and Applied Science, University of Wisconsin-Extcasion Program on Industrial Facility Cogeneration.

GRANTS AND AWARDS University Grants Demonstration of a Grid Connected Integrated Community Energy System DATE TITLE AMOUNT 1982 - 84 Mass Electric Company / Colt Industries /

20,000 Mass Electric Construction. Grants i

for Cogeneration Monitoring 1981 - 83 Mass Energy Office / DOE-Energy Conser-104,000 vation Measures in Schools and Hospitals, 2 matching grants for cogeneration heat recovery equipment co-authored with J.

Collins and B. Kimball)

1. DE-FG41-81R 113973

1. DE FG4182R 143391 13,750 1980 - 82 HUD: Loan for Plant Construction 1,200,000 (co-authored with J. Collins, B. Kimball) 1980 82 DOE Phase III: Constuction: grid connec-330,000 tion and constuction management costs (co-authored with J. Collins) 4

1977 - 78 DOE Phase II: Detailed Feasibility and 206,000 Preliminary Design (co authored with C. Hohenemser 1977 DOE Phase I: Preliminary Feasibility 149,000 Study (co-authored with C. Hohenemser)

Other Grants and Grant Support Received DATE TITLE AMOUNT 1987 88 Or.tario Nuclear Safety Review Board - Modelling 12,160 Consequences of Reactor Accidents (Principal Investigator) 1987 88 Rhode Island / EPA "Risk Assessment Methodology 10,000 for Contaminated Seafood (Co-Principal Investigator with H. Brown) 1984 86 NSF/NEH -Interdisciplinary Incentive AwrJ 45,800 Ethical Issues in Hazard Management (Princi-palInvestigator Individual Award) 1983 - 85 NSF - Sensitive Workers, Ethical Issues and 170,500 Differential Sensitivity to Workplace Hazard (Co-Principal Investigator with R. Kasperson)

1. RII 8217297 1983 - 84 Clark Univers'ty - Elemental Analysis of Par-1,500 ticulates (Jointly with C. Hohenemser-Faculty Development Award) 1982 - 83 OTA - Implementation of Occupational Lead 29,000 Standard (Principal Investigator) Cortract

1. 233 7040.0 1982 DOE - Nuclear Power Plant Peribrmance 9,000 (Principal Investigator) Purchase Order

1. DE-AP0182 El19625 1982 AAA S - Summer Fellowship in Environmental 6,800 Sciences (for work on Acid Rain in EPA's Office of Strategy Assessment and Long Range Planning) 5

0 1980 - 82 NSF - Labor / Laity: Comparison of Worker 240,000

& Public Protection from Technological Hazards (Co-Principal Investiator with R. Kasperson)

1. OSS 79-24516 1979 80 Association of Physical Plant Administration -

4,000 Preparation of a Cogeneration Reference hianual for Colleges and Universities (Principal Investigator) 1979 Argonne Laboratories - Testing Computer 5,240 Models for Cogeneration System Design (Principal Investigator)

Univ. #98456-01 1977 - 80 NSF-Equity Issues in Radioactive Waste 190,000 Management #oss 7716564 (Co-principal Investigator with Roger Kasperson)

PUBLICATIONS Articles (Energy / Hazards / Air Quality) 1988 "The Social Amplification of Risk: A Conceptual Framework" (with R.E. Kasperson, O.

Renn, P. Slovic, H.S. Brown, J.E. Emel, J.X. Kasperson, and S. Ratick) Risk Analysis (to be published).

"Methodology for Assessing Hazards of Contaminants in Seafood"(with H.S. Brown, and L.

Teitelbaum) Reculatory Toxicoloey and Pharmacoloev. 8:76 - 101 (1988).

1986 "Turbulence Parameters in an Urban Environment" (with M. Yersel), Boundary Laver Meteoroloev. V. 37, #3 p.271 (1986).

"Methods for Analyzing and Comparing Technological Hazards: Definitions and Factor Structures" (with C, Hohenemser, J. Kasperson, R. Kasperson, R. Kates, P. Collins, P. Slovic, B. Fischoff, S. Lichtenstein and T. Layman.) In Risk Evaluations and Management, V. Covello, J. Menkes and Y. Mumpower, eds. Plenum Press, New York,1986.

1985 l

"Protecting Workers, Protecting Publics: "Ihe Ethics of Differential Protection" (with P.

j Derr, R. Kasperson, R. Kates)in V.T. Covello (ed.) Risk Analysis in the Private Sector, 1

Plenum Press, New York,1985.

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1983 "Time Scales in the Radioactive Waste Problem" Eaulty Issues in Radioactive Waste Management. R. Kasperson, Ed. Oelgeschlager Gunn, Hain, Cambridge 1983, Chapter 6, p.

139-174.

"Short Distance Diffusion in an Urban Atmosphere" (with M. Yersel, J. Morrill),

Atmosoheric Environment, V.17, No. 2,275 (1983).

"Responding to the Double Standard of Worker /Public Protection (with P. Derr, R.

Kasperson, R. Kates), Environment V. 25, No. 6,6 (1983).

1982 "Airbome Lead: A Clear-cut Case of Differential Protection," (with D.Hattis and N.

Ashford), Environment V. 24, No.1,14 (1982).

"Technological Risk Perception and Nuclear Power Costs: The Quantification of Uncertainty" (with D. Shakow) Technological Forecasting and Social Change, V 21, No. 3, 185 (1982).

1981 "Worker /Public Protection: The Double Standard" (with P. Derr, R. Kasperson, R. Kates),

Environment, V. 23, No. 7,6 (1981).

1979 "Nuclear Power Plant Performance: An Update," (with C. Hohenemser) Environment V. 21, No. 8,32 (1979).

1978 "Power Plant Performance" (with C. Hohenemser), Environment V. 20, No.3,25, (1978).

Technical Monographs 1988 Potential Retrieval of Radioactive Waste at Prooosed Yucca Mountain Recository: A Review of Risk Issues (with D. Golding, R. Kasperson)(1988) 17 p.

Postclosure Risk at the Procosed Yucca Mountain Reoository: A Review of Methodological and Technical Issues (with J. Emel, R.E. Kasperson, and O. Renn) (1987) 53 p.

7

6 1987 hiethodolocv for Assessing Hazards of Contaminants in Seafood,(with H. Brown, and L.

Teitelbaum), for the Naragansett Bay Project, U.S. EPA and Rhode Island Department of Environmental hianagement,47 p.

Preclosure Risks at the Prooosed Yucca Mountain Reoositorv. (with R.E.Kasperson, J. Emel, J.X. Kasperson, and O. Renn), (1987) 40 p.

Nuclear Waste System Risks at the Prooosed Yucca Mountain Renositaly,(with J. Emel, J.X.

Kasperson, R.E. Kasperson, and O. Renn), (1987) 116 p.

1986 Evaluation of the Radtran III Afodel: Usefulness and Practicability. (with O.Renn), CENTED, Clark University.

Site-Characterization Risks at the Yucca Niountain Site: A Preliminary Review. (with J.

Emel, R. Kasperson, O. Renn), CENTED, Clark University.

The croposed Sebaco Lake nuclear waste reoository area: A preliminary assessment of selected risk and social impact considerations. (with J. Emel, J. Kasperson, and R.

Kasperson.) Worcester, h1A: Hazard Assessment Group, CENTED, Clark University.

1985 Risk Issues Associated with a Salt-dome Recository at Richton. Mississippi. (with H. Brown, J. Emel, J. Kasperson, and R. Kasperson.) New York: SocialImpact Assessment Network.

1983 Methods for Analyzine and Comparine Technological Hazards: Definitions and Factor Structures,(with C. Hohenemser, J. Kasperson, R. Kasperson, R. Kates, P. Collins, A.

Goldman, P. Slovic, B. Fischoff, S. Lichtenstein, and M. Layman), CENTED Research Report

1. 3, October 1983.

1982 Atmoscheric Processes Affectine Acid Decosition: Assessine the Assessments and Suegestions for Further Pescarch, AAAS, Fall 1982.

1980 Cogeneration: A Campus Ootion,(with W. Goble) Association of Physical Plant Administrators, Washington,1980).

8

1978 Statistical Analysis of Nuclear and Coa! Power Plant Performance. (with C. Hohenemser)

Scientists Institute for Public information, New York,1978.

Governraent Papt.rs 1985 Imolementation of the Occupational Lead Standard,(with D. Hattis, M. Ballew, D. 7hurston),

CENTED Working Paper HAG /WP 83-1, October 1983: in Preventine illness and Injury in the Wortolace. Vol. 2, NTIS. Office of Techno'ogy Assessment, Washington, Spring,1985.

The Acid Dcoosition Phenomenon and Its Effects Critical Assessment Document Co-authors D. Bennett, R. Linthurst) U.S. EPA, EPA /60018-851001, August 1985.

1977-78 "Grid Connected Integrated Community Energy System, Clark University":

Phase I, Preliminary Feasibility Study, v.1: Executive Summary, DOE Report #C00-4211-1/1 (NTIS,1977) v.2: Final Report, DOE Report #C00-4211 1/2 (NTIS,1977).

Phase II, Detailed Feasibility and Prelin'inary Design Preliminary Report, DOE Report #C00-4211-2 (N'rIS,1978).

v.1: Final Report, DOE Report #C00-4211-3/1 (NTIS,1978).

v.2: Appendices, DOE Report #C00-42113/2 (NTIS,1978).

(These reports were produced by the Clark Demonstration Team and consultants. I wrote the main text and edited each volume.)

Conference Proceedings (Energy, Hazart, Air Quality),

1987 Estimatica of Economic Consequences of a Severe Accident at the Pickering Nuclear Pcwer Station, (with S. lonergan, C. Corcoraton). Brief Presented to Ontario Nuclear S afety Review Board, September 24 26,1967.

Radioactive Wastes and the Social Amplification of Risk, (with R.E. Kasperson, J. Emel, C.

Hohenemser, J.X. Kasperson, and O. Renn). In R.G. Post (ed.) Waste Management '87.

Tucson, AZ: Arizona Board of Regents (1987).

9

Can Risk Assessment be Transplanted to Dewloping Cout.tnee (with H. Brown) Invited paper f ar the Fourth Talleries Seminar on Intemational Development Entitled "hf anaging Envircumental Risk in the Economic Development of Newly Industrializing Countries" May 12 14,19P7, Tufts University Tallories European Center, F ance.

"Potential use of210Pb as a Biological Marker of Exyisure to Radon, "First Intemational Symposium on Environmental Health," Pittsburgh, PA, June 198',.

1985 "The Variation in Worker Response to Occupational Hazards" in Symposium on hianaging High Risk Workers, Society for Risk Analysis, October 1985.

1984 "Acid Rain." Invited talk presented at American Institute of Hydrology Conference, Future Issues in Hydrology, May 31,1984.

1983 "Short Range Dispersion from a Point Source in an Urban Area,"(with M. Yersel),

Proceedings cf the 6th Symposium on Turbulence and Diffusion American Meteorological Society, Boston (1983).

1981 "A Participatory Agmach to Undergraduate Energy Education: the Case of Clark Universiy(with D. Ducsik) Proceedings of the Intemational Conference on Energy Education, Providence, Rhode Island,1981.

"Clark University's Grid-Connected Cogeneration Plant,"(with J. Rodousakis, J. Cook),

District Heating, V. 67, No.1,4 (1981).

1979 "A Micrometeorological Study in the Worcester Area" (with A. Molod, M. Yersel),

Proceedings of the Conference on the Meteorology of Northem New England and the Maritime Provinces, Gorham, ME (1979).

1978 "Grid Connected Cogeneration at Clark University: The Effect of Terms of Utility Interconnection: (with S.E. Nydick), Proceedings of the Intemational Conference on Energy Use Management, Tucson (1978).

1977 10

"Energy Profiles at Clark University: Implications for Cogeneration" (with R. Collins, A.

Gottlieb), Proceedings fo the First National Conference on Technology for Energy Conservation, Washington, D.C. (1977).

Testimony 1988 Nuclear Regulatory Commission. Before the Atomic Safety Licensing Board: Sheltering in the New Hampshire Radialogical Emergency Response Plans for the Seabrook Reactor-Concord, N.H. hiay 1988.

1986 Before Department of Energy, Office of Civilian Radioactive Wastes hianagement: Social and Economic Consequences of a Proposed Sebago Lake Repository - Naples, hiaine. April 1986.

Articles (Particle Physics) 1975 0

"Determination of the A++

A hiass Difference (with J.S. Ball), Phys. Rev. D 11,1971 (1975).

1973 "Two Pion Intermediate States in Decay KS - 2y." Phys. Rev. D 4,931 (1973).

O 1972 "Soft Pion Production in Electron Positron Collisions" (with J.L. Rosner), Phys. Rev. D 5 2345 (1972),

1971 "Current AlgeM and Analyticity: Bootstrapping the p and a with the Pion Decay Constant Setting the '... ' (with (L.S. Brown), Phys. Rev. D 4 723 (1971).

I1

s 1968 "Pion Pion Scattering, Current Algebra, Unitarity, and the Width of the Rho Meson"(with L.S. Brown), Phys. Rev. Lett. 20 346 (1968).

"Soft Photons and the Classical Limit" (with L.S. Brown), Phys. Rev. 173,1505 (1 % 8).

1965 "Cross Section for the Production of a Possible Bound Cascade Nucleon System" (with M.E.

Ebel) Phys. Rev. B 140 1675 (1965).

Conference Proceedings (Particle Physics) 1988 "Pion Pair Produc. ion by Two Photons at Low Energy," Proceedings from the VIII International Workshop on Photon Photon Collisions (Israel,1988).

1973 "Pion Form Factor and Inelastic n - n Scattering," Proceedings of the International Conference on n - n Scattering (Tallahassee,1973).

12

t e

PROFESSIONAL QUALIFICATIONS OF DR. JAN BEYEA

e Resume for Jan Beyea July 1986 EDUCATICN:

Ph.D., Colubia University, 1968 (Physics).

B A., Anherat College,1962.

EPPIOtMDC HISICRY:

~

1980 to date, Senior Staff Scientist and, as of 1985, Director of the Environmental Policy Analysis Department, National Audubon Society, 950 S ird Avenue, NY, NY 10022.

1976 to 1980, Research Staff, Center for Energy and Environmental Studies Princeton University.

1970 to 1976, Assistant Professor of Physics, Holy Cross College.

1968 to 1970, Research Associate, Colurrbia University Physics Depart 1 rent.

CCNSULTING WCRK:

Consultant on iclear energy to the office of Technology Assessrrent, the New Jersey Depa:i ~1t of Environmental Protection; the Offices of the Attorney General in New Yoa State and the Cereonwealth of Massadusetts; the State of lower Saxony in West Germany; the Swedish Energy comission; the Wree Mile Island Public Health Fund; and various citisens' groups in the United States.

PUBLICATICNS CCNCERNING DlEICY CCNSEPVATICN, DiEE*/ PCLICY, AND DiEPGY Articles:

"Oil and Gas Resources on Federal Lands: Wilderness and Wildlife Pefuges," Stege and Be9ea, Annual Review of Enercy (to be published, Octeter 1986).

[An earlier version appeared as National Auduben Society Report, EPAD No. 28, June 1985.]

I "U.S. Applipce Efficiency Standards," Pollin and Beyea, Enerey Policy, 13, p. 425 (1985).

"Computer Modeling for Energy Policy Analysis," Medsker, Peyea, and Lycns, Proceedings of the 15th Annual Modeline and Sirrulatien Conference, Pittsburgh, PA, 15, part 3, p. 1111 (1984).

"Centainment of a Reactor Meltdevn," (with Frank von HiFFel), sulletin of the Atcaic Scientists, 38,, p. 52 (August /Septefrber 1982).

"Second Doughts (about Nuclear Safety)," in Nuclear Pcwer:

Beth Sides, W. W. Ncrton and Co. (New York, 1982).

"Indoor Air Pollution," Bull. At. Scientists, J7, p. 63 (Teb.1981) 7

-2 frticles (Con't)

"Drergency Planning for Reactor Accidents," Bulletin of the Atomic Scientists, 36,, p. 40 (Decerber 1980).

(An earlier version of the article appeared in German as Chapter 3 in Im Ernstfall hilflos?, E. R. Roch, Fritz Vahrenholt, editors, Keipenheuer & Witsch, Cologne,1980.)

"Dispute at Indian Point," Bull. At. Scientists, 3!,, p. 63, (May 1980).

"f.,ocating and Eliminating cbscure but Major Energy Losses in Residential Housing," Hartje, Dutt, and Beyea, ASHRAE Transactions, 85,, Part II (1979).

(Winner of A9CPAE outstanding paper award.)

"Attic Heat Ioss and Conservation Policy," Dutt, Beyea, and Sinden.

Technology and Society Division Paper 78-TS-5, Houston, Texas,1978.

A9'E "Critical Significance of Attics and Basements in the Energy Balance of Twin Pivers Townhouses," Beyea et al., Energy and Buildings, Vol. I (1977),

Page 261.

Also Chapter 3 of Saving Energy in the Home, Ballinger,1978.

"The Twc-Resistance Podel for Attic Heat Flow: Irplications for Con-servation Policy," Woteki, Dutt, Beyea, Energy-We Intl. Journal, Published Debates:

3, 657(1978)

Proceedings of the Workshop on tree Mile Island Desinetry, %ree File Island Purlic Health Fund,1622 Locust Street, Phila., Pa., Dec.1985 "Land Use Issues and the Media," Ctr. for Cerrnunication, NYC, Oct.1904.

Nuclear Peactors:

Academy Forum of the National Acacery of Sciences, Wash., D.

Line, P.B.S. Television.%e Crisis of Nuclear Energy, Subject No. 367 on William Transcript printed by Southern Education Ccemuni-cations Assoc., 928 Woodrow Street, P. O. Box 5966, Colurbia, s.C.,1979.

Remrts:

[See also, Intro. to Special Issue on Legal Issues Aris.*ng Energy Plan 1984, Colunbia Journal of Envirenmental Law, IJ1,, p.251, (1986)]

A Review of Dose Assesswents at %ree_ Mile Island and Peccmnendat Future Research, Report to the tree Mile Island Public Eealth Fund, August 1984.

[See also, "Author Challenges Review," Health Physics Newsletter, March,198 5, and "TMI-Six Years Later," Nuclear Medicir.e,16, p.1345 (1985). ]

6,

. Reports (Con't)

"Irplications for Mortality of Weakening the Clean Air Act," (with G.

Steve Jordan), National Audubon Society, EPAD Report No.18, May 1982.

"Scme Len9-Term Consequences of Hypothetical Major Peleases of Radioactivity to the Atomosphere frorn Wree Mile Island," Report to the President's Council on Environmental cuality, Decer:cer 1980.

"Decontaminaticri of Krypton 05 from 3ree Mile Island Nuclear Plant,"

(with Kendall, et al.), Report of the Union cf Concerned Scientists to the Governor of Pennsylvania, May 15, 1980.

"Some Contnents on Consequences of Hypothetical Reactor Accidents at the Philippines Nuclear Power Plant" (with Gordon Wompson), National Audubcn Society, EPAD Report No. 3, April 1980.

"Nuclear Reactor Accidents: The Value of Improved Containment," (With Frank von Hippel), Center for Energy and Environmental Studies Report PU/ CEES 94, Princeton University, January 1980.

"The Effects of Releases to the Atmosphere of Radioactivity frem Hyrcthetical Large Scale Accidents at the Proposed Gorleben Waste Treatment

)

Facility," report to the Government of Icwer Saxony, Federal Republic of Germany, as part of the "Gorleben International Review," February 1979.

"Reactor Safety Research at the Large Consequence End of the Risk i

Spectrum," presented to the Experts' Meeting on Reactor Safety Research in the Federal Republic of Germany, Bonn, Septenber 1,1978.

A Study of STe of the Consequences of Hypothetical Peactor Accidents at Barseback, repcrt to the Swedish Energy Com., Stockhc12, CS I 1978:5, 1978.

Testimony.

"Respenses to the Chernobyl Accident," before the Senate comittee on Energy and Natural Resources, U. S. Senate, June 19, 1986.

"Dealing with Uncertainties in Projections of Electricity Consumption,"

befcre the Co m. on Energy and Natural Rescurces, U. S. Senate, July 25, 1985.

"Scre Consequences of Catastrephic Accidents at Indian Point and Their Implications for Emergency Planning," testimony and cross-examination before the Nuclear Regulatory Comission's Atoric Safety and Licensing Board, on behalf of the New York State Attorney General and others, July 1982.

N

. Testirtony (Con't)

"In the Matter of Application of Orange and Rockland Counties, Inc. for conversian to Coal of Ievett Units 4 and 5," testiscay and cross-examination on the health irrpacts of eliminating scruthers as a requirernent for conversion to coal Department of Environmental Resources, State of N.Y., Nov. 5, 1981.

"Future Prospects for Corrmercial Nuclear Power in the United States,"

before the Subecernittee on oversight and Investigations, Connittee on Interior and Insular Affairs, U. S. House of Representatives, October 23, 1981.

"Ccmrents on Energy Forecasting," material submitted for the record at Hearings before the Subcomittee on Investigations and Oversights of the House Comittee on Science and Technology; Cemrittee Print No.14, June 1-2,1981.

"Stockpiling of Potassiur Icdide for the General Public as a Condition fcr Restart of TV.I Unit No.1," testimony and cross-examination before the Atomic Safety and Licensing Board on behalf of the Anti-Nuclear Group Representing York, April 1981.

"Advice and Recamendations Concerning Qian9es in Reactor Design and Safety Analysis which should be Required in Light of the Accident at Wree Mile Island," statement to the Nuclear Regulatory Comission concerning the propcsed ruleraking hearing on degraded cores, Decerrber 29, 1980.

"Alternatives to the Indian Point Nuclear Peactors," statenent before the Envirennental Protecticn Comittee cf the New Ycrk City Council, Jecember 14, 1979.

Also before the Comittee, "We Impact on New York City cf Peactor Accidents at Indian Point, June 11, 1979. Also "Consequences of a Catastrophic Reactor Accident," statenent to the New York City Board of Health, August 12,1976 (with Frank von Hippel).

"Erergency Planning for a Catastrophic Reactor Accident," testirm.,

Pesponse and Evacuation Plans Hearings, Novenber 4,19 "Ccments on the Proposed FIC Trade Pegulation Rule en Labeling and Advertising of termal Insulation," Beyea and Dutt, before the pit,1978.

"Consequences of Catastrcphic Accidents at Jartsport," testierony before the N.Y. State Peard cn Electric Generation Siting and the Envirenrent in the Patter of Long Island Lighting Co. (Jarresport Nuclear Pcwer Station), Pay 1977.

the Sundesert Nuclear Installation," testirony before the Ca Resources and Develeprent Comission, Decereber 3,1976

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CALCULATION OF REACTOR

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Table 2. SulalARY OF ELEASE CATECORIES REPRESErlTir4C IIYPOTilETICAL ACCIDENTS m

T4 M(

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N'IIQQ Time of Duration Manning Time Elevation Release of Release for Evacuation of Release Enertyy Release Release Probability _ )

(br)

(br)

(br)

(meters)

(100 Btu /hr)

Category (reac tor-y r PWR 1 9 x 10 2.5 0.5 1.0 25 20 and-520(*)

~ (* }

~ I' PWR 2 3 x 10 2.5 0.5 1.0 0

170

-6 PWR 3 4 x 10 5.0 1.5 2.0 0

6

-7 PWR 4 5 x 10 2.0 3.0 2.0 0

1 PWR S 7 x 10~

2.0 4.0 1.0 0

0.3 PWR 6 6 x 10~

12.0 10.0 1.0 0

N/A PWR 7 4 x 10~

10.0 10.0 1.0 0

N/A

}

PWR 8 4 x 10~

0.5 0.5 II/A O

N/A PWR 9 4 x 10 '

O.5 0.5 ri/A 0

N/A

~

(a) Accident sequences within PVR 1 category have two distinct energy releases that affect consequences. PWR'1 category is subdivided 1:sto PWR lA with a probability of 4 x 10 7 per reactor year and 20 x 10 Btu /hr and 6

PWR IB with a probability of 5 x 10-7 per reactor-year and '>20 x 106 Btu-hr.

(b) Not applicable.

(c) A 10 meter elevation is used in place of zero representing the mid-point of a potential containment break.

Any impact on the results would be slight and conservative.

1 e

TABLE 2.

(cont.) StJMMARY OF REI. EASE CATECORIES REPRESENTING liYPOTilETICAI ACCIDENTS *

( @

TixJw

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=f W M H - 1 4 c e.

t Release Category Frac, tion _of Core Inventory Released Xe-Kr I

Cs-Ri>

Te-Sb Ba-Sr Ru La PWR 1 0.9 0.7 0.4 0.4 0.05 0.4 3x 10-PWR 2 0.9 0.7 0.5 0.3 0.06 0.02 4 x 10-PWR 3 0.8 0.2 0.2 0.3 0.02 0.03 3 x 10-PWR 4 0.6 0.09 0.04 0.01 5 x 10-3 x 10-4 x 10-

-3

-4 PWR S 0.3 0.03 9x 10-5x 10-1 x 10 6 x 10 7 x 10-PWR 6 0.3 8 x 10-8x 10

1 x 10-9 x 10-7 x 10 1 x 10

-5

-5

-S

-5

-6

-6 PWR 7 6 x 10-2 x 10 1x lo-2 x 10 1 x 10 1 x 10 2 x 10-7 PWR 8 2 x 10-1 x 10 5 x 10

1 x 10-1 x 10-0 0

-II PWR 9 3 x 10-1 x 10-6 x 10-1 x 10-1 x 10 O

O-(d) Background on the isotope groups and release mechat.tsms is presented in the Reactor Safety Study Appendix V11.

(c) Organic iodine is combined with elemental fodlaes in the consequence calculations. Any error is neglible since its release fraction is relatively small for all large release categories.

(f)

Includes Ru, Rh,fio, Tc.

(g)

Includes Y, La, Zr, Nh, Ce, Pr, Nd, Np, Pu, Am, Cm.

• The release categories and prohnhility information were derived from Reference 4 and based upon an analysis of the design of the Surry Noc1 car Power Plant.

?

i

b THE COMMONWEALTH OF MASSACHUSETTS 9

DEPARTMENT OF THE ATTORNEY GENERAL JOHN W. McCORMACK STATE OFFICE BUILDING

@jk'l'f y

ONE ASHBURTON PLACE, BOSTON 02106-1698

/

fj UNITED STATES OF AMERICA Yn A o" NUCLEAR REGULATORY COMMISSION

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DoCKETInc a -

.4 SERV!Cr BliA NCII 7

Eter-r;:C D

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IQT D In the Matter of

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PUBLIC SERVICE COMPANY OF

)

Docket No.(s)

NEW HAMPSHIRE, ET AL.

)

50-443/444-OL

}

(Seabrook Station, Units 1 and 2)

)

)

)

CERTIFICATE OF SERVICE I,

Carol S.

Sneider, hereby certify that on July 7, 1988, I made service of the following: (1) REBUTTAL TESTIMONY OF EP.. GORDON THOMPSON, DR. ROBERT L. GOBLE, AND DR. JAN BEYEA ON BEHALF OF THE ATTORt1EY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS ON SHELTERING CONTENTIONS (with tables); and (2) ATTACHMENTS TO REBUTTAL TESTIMONY OF DR. GORDON THOMPSON, DR. ROBERT L.

GOBLE, AND DR. JAN BEYEA ON BEHALF OF THE ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS ON SHELTERING CONTENTIONS, by mailing copies thereof, postage prepaid, by first class mail or by Federal Express mail as indicated by (*],

to:

• Ivan Sniith, Chairman

• Gustave A.

Linenberger, Jr.

Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S.

Nuclear Regulatory U.S.

Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814

• Dr.

Jerry Harbour

• Sherwin E. Turk, Esq.

Atomic Safety & Licensing Board U.S.

Nuclear Regulatory Commission U.S.

Nuclear Regulatory Office of General Counsel Commission 15th Floor East West Towers Building llS55 Rockville Pike 4350 East West Highway Rockville, MD 20852 Bethesda, MD 20814

s.

.i

• H.

Joseph Flynn, Esq.

Stephen E. Merrill Assistant General Counsel Attorney General Office of General Counsel George Dana Bisbee-Federal Emergency Management Assistant Attorney General Agency Of fice of the Attorriey General 500 C Street, S.W.

25 Capitol Street Washington, DC 20472 Concord,.NH 03301

• Docketing and Service Paul A.

Fritzsche, Esq.

'U.S.

Nuclear Regulatory Office of the Public Advocate Commission State House Station 112 Washington, DC.

20555 Augusta, ME 04333 Roberta C.

Pevear Diana P.

Randall State Representative 70 Collins Street Town of Hampton Falls Seabrook, NH 03874 Drinkwater Road Hampton Falls, NH 03844 Atomic Safety & Licensing Robert A.

Backus, Esq.

Appeal Board Panel Backus, Meyer & Solomon U.S.

Nuclear Regulatory 116 Lowell Street Commission P.O.

Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.S.

Nuclear Regulatory 5 Market Street Commission Portsmouth, NH 03801 Washington, DC 20555 Matthew T.

Brock. Esq.

J.

P.

Nadeau Shaines & McEachern Board of Selectmen 25 Maplewood Avenue 10 Central Road P.O.

Box 360 Rye, NH 03870 Portsmouth, NH 03801 Sandra Gavutis, Chairperson Calvin A. Canney Board of Selectmen City Manager 1

RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E.

Kingston, NH 03827 Portsmouth, NH 03801 Senator Gordon J.

Humphrey Angelo Machiros, Chairman U.S.

Senate Board of Selectmen Washington, DC 20510 25 High Road (Attn: Tom Burack)

Newbury, MA 10950 Senator Gordon J.

Humphrey Edward G. Molin 1 Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton)

Newburyport, MA 01950 j )

1

Donald E.

Chick William Lord Town Manager Board of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street.

Exeter, NH 03833 Amesbury,-MA 01913 Brentwood Board of Selectmen Gary W.

Holmes, Esq.

RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH 03841 Philip Ahrens, Esq.

Ellyn Weiss, Esq.

Assistant Attorney General Harmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W.

State House Station #6 Washington, DC 20009 Augusta, ME 04333

• Thomas G.

Dignan, Esq.

Richard A.

Hampe, Esq.

Ropes & Gray Hampe & McNicholas 225 Franklin Street

-35 Pleasant Street

' Boston, MA 02110 Concord, NH 03301 Beverly Hollingworth Ashod N. Amirian, Esq.

209 Winnacunnet Road 376 Main Street Hampto,n, NH 03842 Haverhill, MA 01830 William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2 10 Front Street South Hampton, NH 03827 Exeter, NH 03833 Robert Carrigg, Chairman Anne E. Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-15 Newmarket Road Atlantic Avenue Durham, NH 03824 North Hampton, NH 03862 A'len Lampert Sheldon J.

Wolfe, Chairperson Civil Defense Director Atomic Safety and Licensing Town of Brentwood Board Panel 20 Franklin Street U.S.

Nuclear Regulatory Exeter, NJ 03833 Commission Washington, DC 20555 Charles P.

Graham, Esq.

Barbara St. Andre, Esq.

McKay, Murphy & Graham Kopelman & Paige, P.C.

Old Post Office Square 77 Franklin Street i

100 Main Street Boston, MA 02110 Amesbury, MA 01913

Judith H. Mizner, Esq.

R.

Scott Hill-Whilton,.-Esq.

Lagoulis, Clark, Hill-Whilton

.Lagoulis, Clark, Hill-Whilton.

& McGuire-

&-McGuire 79 State Street 79 State Street Newburyport, MA 01950 Newburyport, MA 01950 3'-

d

(

)

Carol S.

Sneider Assistant-Attorney General Nuclear Safety Unit Department of the' Attorney General One Ashburton Place Boston, MA 02108-1698 (617) 727-2265 DATED:

July 7, 1988

-4

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