ML20204B549
| ML20204B549 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/18/1987 |
| From: | Chan E NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | HAMPTON, NH |
| Shared Package | |
| ML20204B512 | List: |
| References | |
| OL, NUDOCS 8703250091 | |
| Download: ML20204B549 (16) | |
Text
F REl.ATED C08RESPONpM c
March 18, gTED o
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 23 @ 3 2 DEFORE THE ATOMIC SAFETY AND LICENSING BOARD crrrct: or J.
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In the Matter of
)
)
Docket Nos. 50-443 OL PUBLIC SEhVICE COMPANY OF
)
50-444 OL NEW HAMPS!!!RE, et al.
)
Off-site Emergency Planning
)
(Seahrook Station, Units 1 and 2
)
NRC STAFF'S RESPONSE TO TOWN OF HAMPTON FIRST SET OF INTERROOATORIES AND REQUEST FOR T!!E PRODUCTION OF DOCUMENTS TO THE NRC ON TIIE liEW HAMPSil!RE RADIOLOGICAL 1:MERGENCY RESPONSE PLANS (AS CORRECTED)
The NFC Staff (" Staff") hereby submits its responses to " Town of Hampton First Set of Interrogatories and Requests for the Production of Documents to the Nuclear Regulatory Commission on the New Hampshire Radiological Emergency
Response
Plans,"
filed March 5, 1987 and corrected March 9,1987 Interrogatories addressed to the Staff are governed by the i
need-based discovery provisions of 10 C.F.R.
I 2.720(h)(2)(ii) requiring a formal finding of necessity by the presiding officer II 1
1 1/
10 C.F.R. I 2.720(h)(2)(ii) provides in relevant part:
[A] party may file with the presiding officer written interrogatories to be answered by NRC personnel with knowledge of the facts designated by the Executive Director for Operations.
Upon a finding by the presiding officer that answers to the interrogatories are (FOOTNOTE CONTINUED ON NEXT PAGE) l 0703250091 870318 PDR ADOCK 03000443 o
[
rather than the general discovery provisions of 10 C.F.R. I 2.740. Since most Staff documents related to licensing actions are publicly available under Commission regulations, there is little need for formal discovery against the Staff.
See Pennsylvania Power and Light Company (Susquehanna Steam Electric Station, Units 1 and 2), ALAB-613,12 NRC 317, 323 (1980) (discovery against Staff on "different footing" than discovery against other parties; Staff documents publicly available pursuant to 10 C.F.R.
I 2.790).
Except as specifically objected to herein, the Staff in this case voluntarily responds to the propounded interrogatories, notwithstanding Town of !!ampton's failure to seek a required finding by the presiding officer that the answers to the interrogatories are "necessary to a proper decision" and "are not reasonably obtainable from any other source."
In so doing, the Staff reserves its rights to require full compliance with the Commission's regulations in future discover *.
INTERROGATORY 1 With respect to each contention and subpart thereof admitted by the Licensing Board's order of February 8,1987, please provide the following information:
[a). What is the NRC's position with respect to each contention and its subparts? Describe in detail the reasons for your position.
(FOOTNOTE CONTINUED FROM PREVIOUS PAGE) necessary to a
proper decision in the proceeding and that answers to the interroga-tories are not reasonably obtainable from any other
- source, the presiding officer may require that the staff answer the interrogatories.
[b]. Identify and provide access to all documents on which you rely during this proceeding to support your position on each of these conten-tions.
This includes all documents used in answers to these interroga-tories, summary disposition, motions, testimony and cross-examination of witnesses during hearings.
[c]. Identify all persons you tray call as witnesses on each of these contentions during these proceedings; describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.
[d]. Identify all persons on whose factual knowledge, opinions, or technical expertise you rely for your position on each contention and subpart thereof.
RESPONSE
a.
To date, the Staff has not developed any positions with respect to the merits of the admitted contentions or their subparts. The admitted contentions relate to offsite emergency planning and preparedness matters which, under a Memorandum of Understanding between the Nuclear Regulatory Commission and the Federal Emergency Management Agency (FEMA), are within the scope of FEMA's review.
However, the Staff intends to retain a consultant to review and respond to the admitted contentions concerning evacuation time estimates ("ETE").
The Staff does not possess any information, nor has the Staff developed a position, concerning the adequacy of the New !!ampshire Radiological Emergency Response Plan within the scope of the admitted contentions, which is different from the position and/or the information in FEMA's possession, b.
See Response to Interrogatory 1(a), above, c.
The Staff identiftes Dr. Thomas Urbanik, !!, as a person whom it intends to call as a witness concerning the admitted ETE contentions, or upon whose testimony it might rely in this proceeding.
A copy of
I-Dr. Urbanik's Curriculum Vitae is attached to this response.
Since the Staff has not developed any pocitions, with respect to the admitted contention, the Staff is not in a position to describe the contents of Dr. Urbanik's testimony nor identify or describe any documents upon which he may rely for his testimony.
J d
d.
See Response to Interrogatory 1(c), above.
INTERROGATORY 2
/
Please identify and [ provide access to all documents net ' identified in response to interrogatory (1)(b) that. evaluate or discuss tho adequacy of emergency planning and preparedness,with respect to any.of the issues admitted for litigation by the Licensing Board's order of February 18, 1987.
~
~
~
OBJECTION The Staff objects -to this interrogatory on the grounds that the requested information is reasonably obtainable from other sources, i.e.,
the Applicants, FEMA, or the State of New Hampshire.
See 10 C.F.R.
I 2.720(h)(2)(ii). 2/
2/
Insofar as the Staff objects to the instant interrogatories, the Staff
~
hereby requests that the Licensing Board issue a protective order pursuant to 10 C.F.R. 5 2.740(c) precluding further discovery with respect to these matters.
~.
/
.s
RESPONSE
The Staff is not in possession of documents concerning the adequacy of the New Hampshire Radiological Emergency Response Plan, within the scope of the admitted contentions, apart from those' documents which are in FEMA's possession.
Respectfully submitted, Elaine I. Chan Counsel for NRC Staff Dated at Dethesda, Maryland this 18th day of March,1987 i
I'
_..~__
t' CURRICULUM VITAE URBANIK I-I, Thomas P.E., ~ Ph.D.
UFFICE PHONE:
.409/845-1535 5
HOME ADDdESS: 12 Post Oak Bend Rd.
HOME PHONE:
409/690-6795 College Station Texas 77840 Birthdate: February 15, 1946 Citizenship:
U.S.
S.S. No.:
079-36-0185 Marital Status: Married, 2 Sons PRUFESSIUNAL INTERESTS: Traffic Engineering Transportation Planning Evacuation Planning Highway Design / Safety Public Transportation EDUCATION:
Ph.D., Civil Engineering, Texas A&M University, 1982 M.S., Transportation Engineering, Purdue University,- 1971 B.S., Civil Engineering, Syracuse University, 1969 B.S., Forest Engineering, New York State College of Environmental Science and Forestry, 1968 PROFESSIUNAL LICENSES:
Registered Professional Engineer, Michigan No. 22008 Registered Professional Engineer, Texas No. 42384 EXPERIENCE:
1982-1986 Lecturer Depar.tment of Civil Engineering Civil Systems Group Texas A&M University College Station, Texas 77843-3136 undergraduate instruction in transportation engineering and planning, traffic engineering, and highway design.
Program Manager Transport Uperations Texas Transportation Institute Texas A&M University College Station. Texas 77843-3135 Duties and responsibilities are to provide specific direction to program in its conduct of transportation research projects for fed-eral, state, and local transportation agencies.
L
h-5 The range of transportation projects include: traffic engineering.
transportation planning, highway safety, public transportation, and
. transportation systems management.
Management responsibilities are to identify and pursue research
~
opportunities,.. locate and recommend staff, monitor research activities to meet budget and project objectives, develop overall program funding, provide an annual staff review (15 personnel),
4 supervise preparation of proposals, develop writing and communica
~
tion skills of the program staff, review and allocate work, coor-dinate equipment and staffing needs, recommend and approve perti-nent expenditures for annual budget of. approximately $600,000.
1976-1982 Assistant Research Engineer Conducted research, prepared proposals, and provided project super-vision on research activities.
Responsible for final report preparation and presentation.
Research areas included traffic engineering, transportation planning, public transportation and evaluation planning.
1972-1976 Traffic Engineer City of Ann Arbor Department of Streets, Traffic and Parking Ann Arbor, Michigan Responsible to Director of Streets, Traffic and Parking, Ann Arbor, Michigan.
Responsible supervisory and professional traffic engi-neering work in directing the traffic engineering function of the department.
Work involved responsibility for the application of professional engineering skill and knowledge to difficult traffic engineering problems in traffic regulation and control, street use, street lighting, geometrics, parking, school safety, curb cuts, and related traffic engineering activities.
Was directly responsible for the supervision of the traffic signal and traffic sign mainte-nance personnel.
1971-1972 Transportation Planning Engineer City of Ann Arbor Traffic Engineering and Transportation Department Ann Arbor, Michigan Responsible to Director of Traffic Engineering and Transportation, Ann Arbor, Michigan.
Reviewed transportation aspects of all plans
{
for development in the city.
Staff member to the Ann Arbor Trans.
portation Authority responsible for budget and union negotiations.
Staff Coordinator for the planning, design, implementation, and op-eration of the Dial-A-Ride demand-responsive demonstration project.
1970-1971 9
Research Assistant Joint Highway Research Project '
Purdue University West Lafayette, Indiana Conducted research concerning high-way related grade crossings.
Designed attitudinal questionnaire concerning public transportation for a home interview survey in Lafayette, Indiana.
Also analyzed survey results for inclusion in a report on public transportation in Lafayette, Indiana SOC'IETY MEMBERSHIP:
Transportation Research Board Institute of Transportation Engineers American Society of Civil Engineers American Society for Engineering Education HONUR SOCIETIES Chi Epsilon CURRENT COMMITTEE MEMBERSHIP Chairman, Institute of Traffic Engineers, Texas Section, Committee on Continuing Education Member. Transportation Research Board, Committee on Intercity Bus Transportation PUBLIC SERVICE Member, We11 born Community Center, Board of Directors CONTINUING EDUCATION / PROFESSIONAL DEVELOPMENT Association of 011 Pipelines, Educators Tour, July 1984 The University of Michigan, Bureau of Industrial Relations, Graduate School of Business Administration, Principles of Effective Supervisory Management U.S. Department of Transportation Federal Highway Administration, Digit-al Computer-Urban Traffic Control / Bus Priority System (UTCS/ BPS)
Course.
f, Michipr. Department of Civil Service, Principles of Public Sector Labor Relations.
CURRENT RESEARCH
" Cost-Effectiveness Analysis for Ranking New Interchant.es and Highway Rail road Grade Separations", Texas State Department of Highways and Public Transportation
" Automated Transit Ridership Data Collection", Texas State Department of -
Highways and Public Transportation.
" Computerized Dispatch Aids for Small Public Transportation Providers",
Texas State Department of Highways and Public Transportation.
" Safety and Operational Evaluation of Snoulders on Urban Freeways,"
Texas State Department of Highways and Public Transportation.
" Traffic Engineering / Transportation Planning Relative to Evacuation-Time Estimates", Battelle Pacific Northwest Laboratories.
" Evaluation of Transportation Analysis Techniques Used for Estimating Evacuation Timer at Nuclear Power Plant Sites", Battelle Pacific Northwest Laboratories.
PUBLICATIONS AND PAPERS Traffic Engineering Understanaing Forced Flow, ITE Journal, Institute of Transportation Engineers, Washington, D.C., October 1986.
Safety and Operational Evaluation of Shoulders on Urban Freeways, With Carlos R. Bonilla, Texas State Department of Highways and Pu bl ic Transportation, Research Report Number 395-1, Austin, Texas, August 1986.
The Effectiveness of Using Freeway Shoulders for Traffic, With Wes Lum, District 6-District 7 Joint Annual Meeting, Institute of Transportation Engineers, Vancouver, B.C., Canada, July 1986.
Effects of Shoulder Reductions on Highway Safety, With Wes Lum, American Society of Civil Engineers, Specialty Conference on Effectiveness of Highway Safety Improvements, Nashville, Tennessee, March 1986.
Speed / Volume Relationships on Texas Highways, State Department of Highways and Public Transportation, Research Report 327-2F, Austin, Texas, Octnber 1983.
Priority Treatment of Buses at Traffic Signals, Transportation Engineering, November 1977.
Priority Treatment of High-Occupancy Vehicles on Arterial Streets.
State Department of Highways and Public Transportation, Report 205-5, 1977.
Evaluation of Altern4tive Concepts for Priority Use of Urban Freeways in Texas. State Department of Highways and Public Transportation, Report 205-1, 1977.
Driver Information Systems for Highway-Railway Grade Crossings, with K.W. Heathington, Highway Research Record Number 414, 1972.
Evacuation Planning Transportation Analysis for Evacuation:
S ta te-o f-the-Art, ITE Journal, Institute of Transportation Engineers, Washington, D.C., March 1986.
An fndependent Assessment of Evacuation Times For a Peak Population Scenario in the Emergency Planning Zone of the Seabrook Nuclear Power Station, with others, U.S. Nuclear Regulatory Commission, NUREG/CR-2903, 1982.
CLEAR (Calculates Logical Evacuation And Response), A Generic Transpor tation Network Model for the Calculation of Evacuation Times Esti-mates, with others, U.S. Nuclear Regulatory Commis-sion, NUREG/CR-2504 October 1981.
Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones, with others, U.S. Nuclear Regulatory Commission NUREG/CR-1745, 1980.
Analysis of Evaucation Times Around 52 Nuclear Power Plant Sites, with others, U.S.
Nuclear Regulatory Commission, NUREG/CR-1856 Volume 1, 1980.
Texas Hurricane Evacuation Study, The Coastal and Marine Council,1978.
Public Transportation Analysis of Rural Public Transportation in Texas, with others State Department of Highways and Public Transportation, Technical Report 1069-1F, August 1982.
Intercity Bus Riders in Texas, Transportation Research Record 887, 1982.
The Intercity Bus Industry in the U.S. and Texas, with others, State Department of Highways and Public Transportation. Technical Report 0965-1 F, 1981.
Bryan-College Station Energy Contingency Study, Metropolitan Planning Organization of Bryan-College Station,1980.
Bryan-College Station Transit Improvement Plan, with others, Metro-politan Planning Organization, 1979.
Ann Arbor Dial-A-Ride Project Final Report, Ann Arbor Transportation Authority, 1973.
Ann Arbor Dial-A-Ride Operations, Highway Research Board Special Report 136, 1973.
The Greater Lafayette Area Bus Transit Study, with others, Joint Highway Research Project, Purdue University,1971.
Elderly and Handir.apped Transportation Guidelines for Evaluation of Human Services Transportation Programs, with others, State Department of Highways and Public Transportation, Report 1065-2F, 1981.
Evaluation of Selected Human Services Transportation Providers, with Diane Bullard. State Department of Highways and Public Transportation, 1980.
Cost-Effectiveness of Accessible Fixed-Route Buses in Texas, with Jose Soegard, Technical Report 1061-1F,1979.
r UNITED STATES NUCLEAR REGULATORY OF AMERICA DEFORE TIIE COMMISSION ATOMIC SAFETY In the Matter AND LICENSING BOARD of NE II E
gp3fy gECOAIPANY OF (Seabrook Station Docket Nos. 50-443 og
,U t
I and 2 anning I. Donald J. AFFIDAVI'r nF DONALD
- Perrotti, J. PERROTTI cmployed as Emergency P being duly sworn Branch, Division reparedness Specialist, hereby state that I am of Emergency Preparedne
, Emergency Preparedness in the Office of ss C:mmission.
Inspection and Engineering Respons and A statement of my Enforcement, e,
Nuclear The information cnd 2, contained in the "NRreflected in the Sta Regulatory s is attached.
S;t of Interrogatories C Staff's Response to Tresponses to interro es I ths Nuclear Regulato and Requests for the Pr d of Hampton First own Emergency Response Plry Commission uction o
of Documents to correct to the best of my kan (As Corrected)" atta ho adiological c
nowledge, information and b lied hereto, is true and e ef.
m2 thf318th day of Afar h9ubscribed and sworn to b
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s efore rrot c, 1987
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DONALD J. PERROTTI OFFICE OF INSPECTION AND ENFORCEMENT STATEMENT OF PROFESSIONAL QUALIFICATIONS I ~ am _ employed as an Emergency Preparedness Specialist in the Emergency Preparedness Branch, Division of Emergency Preparedness and Engineering Response, Office of Inspection and Enforcement, U.S.
Nuclear Regulatory Commission.
I have responsibility. for the review and evaluation of radiological emergency plans submitted by reactor applicants and licensecs to assure that proposed plans meet the regulatory requirements and guidance of the Commission.
I also function as a Team Leader and Team Member on Emergency Preparedness Appraisal Teams engaged in the onsite inspection of the implementation phase of licensee emergency programs.
I observe nuclear power plant emergency drills and exercises involving State and local government response agencies and participate in interagency critiques.
I served as the staff's expert witness for onsite emergency planning during the evidentiary hearings for the Waterford 3 and Perry 1 operating licenses and for'the Clinch River Breeder Reactor construction permit.
From December 1976 to October 1980 I was employed at the NRC's Region II Office of Inspection and Enforcement in Atlanta, Georgia.
I was the lead inspector for Region II emergency planning inspections at nuclear power reactors and fuel facilities.
My responsibilities included planning, conducting and documenting inspections of licensees' emergency plans and procedures, emergency facilities and equipment, emergrucy training, tests and drills, and coordination with offsite support agencies.
From April 1977 to August 1978, I assisted my immediate supervisor who served as Chairman of the Federal Regional Advisory Committee (RAC) in the review of State Radiological Emergency Plans.
During October 1978 I assisted in the review and approval of emergency plans for two nuclear i
fuel facilitics.
During the period of March - August,1979, I participated in the Commission's coverage of environmental monitoring programs at Three Mile Island, where I served as Emergency Monitoring Team Leader:
i '
in that capacity, I was responsible for coordination with State and Federal 4
agencies engaged in measurement and evaluation of environmental radioactivity levels in the vicinity of the TMI nuclear plant.
From 1973 to 1976, I was employed at Florida Power and Light Company's Turkey Point Nuclear Power
- Plant, as Health Physics instructor.
My duties included radiation safety training of plant personnel (general employees and technicians), special project reports such as providing background material for management comment on proposed changes to the ' Code of Federal Regulations, and maintaining radiation exposure records for plant personnel.
From 1953 to 1973, I served in the United States Army.
As a member of the U.S. Army Engineer Reactors Group during the period 1961 1973, I performed a variety of jobs with varying degrees of i
responsibility as rank and experience were gained.
Among my more responsible Jobs were shift health physics technician at the PM-3A Naval i
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nuclear power plant in McPardo, Antarctia (1965-1966), Senior Health Physics / Process Chemistry instructor at Ft. Delvoir, Virginia (1966-1972),
and Project Officer for the SM-1 Army nuclear power plant (1972-1973).
I received an Associate of Arts Degree from the New York State Regents, Albany, NY, in 1973.
In addition. I attended Army service schools including Special Nuclear Weapons Disposal and the 52-week Nuclear Power Plant Operators course.
I have completed the following U.S. Public Health Service courses:
Basic Radiological Health Radionuclide Analysis by Camma Spectroscopy Environmental Radiation Surveillance Analysis of Radionuclides in Water Occupational Radiation Protection Chemical Analysis for Water Quality Statistical Methods Quality Control in the Laboratory Operational Aspects of Radiation Surveillance Reactor Hazards Evaluation 4
2
~
the '" Radiological Emergency Response Operations" course
. /;.
Test Site, the " Planning for Nuclear Emergencies" course
. O:;S
' University,
and the
" Advanced Management Radiation W, -l
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eourse at the University of New Mexico School of Medicine.
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Md, ave successfully completed the NRC's Pressurized Water Reactor
.ogy Boiling Water Reactor Technology Probsbility Risk Assessment r,3, V fJ Fundamentals, PRA Derspective for Emer
$cy',t.
onse and PRA for Inspection Application courses.gency Planning and p'< q),$
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I am and have been a member of the fiealth Physics Society since 1974.
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DONALD J. PERROTTI OFFICE OF INSPECTION AND ENFORCEMENT STATEMENT OF PROFESSIONAL QUALIFICATIONS o
I am employed as an Emergency Preparednesa Specialist in the
- V,,
' Emergency Preparedness Branch, Division of Emergency Preparedness and Engineering Hesponse, Office of Inspection and Enforcement, U.S.
Nuclear Regulatory Commission.
I have responsibility for the review and evaluation of radiological emergency plans submitted by reactor applicants and licensecs to assure that proposed plana meet the regulatory requirements and guidance of the Commission.
I also function as a Team Leader and Team Member on Emergency Preparedness Appraisal Teams engaged in the onsite inspection of the implementation phase of licensee emergency programs.
I observe nuclear power plant emergency drills and exercises involving State and local government response agencies and participate in. interagency critiques.
I served as the staffs expert witness for onsite emergency planning during the evidentiary hearings for the Waterford 3 and Perry 1 operating licenses and for the Clinch River Breeder Reactor construction permit.
From _ December 1976 to October 1980 I was employed at the NRC's Region II Office of Inspection and Enforcement in Atlanta, Georgia.
I was the lead inspector for Region II emergency planning inspections at nuclear power reactors and fuel facilities.
My responsibilities included planning, conducting and documenting inspections of licensees' emergency plans and procedures, emergency -facilities and equipment, emergency training, tests and drills, and coordination with offsite support agencies.'
From April 1977 to August 1978 I assisted my immediate supervisor who served as Chairman of the Federal Regional Advisory Committee (RAC) in the review of State Radiological Emergency Plans.
During October 1978 I assisted in. the ' review and approval of emergency plans for two nuclear fuel facilitics.
During the period of March '- August,1979, I participated in the Commission's coverage of environmental monitoring programs at Three Mile Island, where I served as Emergency Monitoring Team Leader; in that capacity, I was responsible for coordination with State and Federal agencies engaged in measurement and evaluation of environmental radioactivity levels in the vicinity of the TMI nuclear plant.
From 1973 to 1976, I was employed at Florida Power and I,ight Company's Turkey Point Nuclear Power
- Plant, as Health Physics instructor.
My duties included radiation safety training of plant personnel (general employees and technicians), special project reports such as providing background material for management comment on proposed changes to the Code of Federal Regulations, and maintaining radiation exposure records for plant personnel.
L From 1953 to 1973, I served in the United States Army.
As a member of the U.S.
Army Engineer Reactors Group during the period 1961 1973, I performed a variety of jobs with varying degrees of responsibility as rank and experience were gained.
Among my more responsible Jobs were shift health physics technician at the PM-3A Naval s d
o 3 o-nuclear power plant in McMurdo, Antarctia (1965-1966), Senior Health Physics /Prccess Chemistry instructor at Ft. Delvoir, Virginia (1966-1972),
and Project Officer for the SM-1 Army nuclear power plant (1972-1973).
I received an Associate of Arts Degree from the New York State Regents, Albany, NY, in 1973.
In addition, I attended Army service schools including Special Nuclear Weapons Disposal and the 52-week Nuclear Power Plant Operators coursc.
I have completed the following U.S. Public Health Service courses:
Basic Radiological Health Radionuclide Analysis by Gamma Spectroscopy Environmental Radiation Surveillance Analysis of Radionuclides in Water Occupaticnal Radiation Protection Chemical Analysis for Water Quality Statistical Methods Quality Control in the Laboratory Operational Aspects of Radiation Surveillance Reactor Hazards Evaluation I attended the " Radiological Emergency Response Operations" course at the Nevada Test Site, the " Planning for Nuclear Emergencies" course at Harvard University, and the
" Advanced Management Radiation Accidents" course at the University of New Mexico School of Medicine.
I have successfully completed the NRC's Pressurized Water Reactor Technology Bolling Water Reactor. Technology Probsbility Risk Assessment (PRA) Fundamentals, PRA Derspective for Emergency Planning and Response and PRA for Inspection Application courses.
I am and have been a member of the Ifealth Physics Society since 1974.
00LKETED r
USNHC UNITED STATES OF AMERICA NUCLEAR REOULATORY COMMISSION
's7 tuR 23 P3 32 FFI F CF SEL6t IWt DEFORE Tile ATOR'ir SAFETY AND LICENSING B imG & 3ERVICI.
BRANCH In the Matter of
)
)
Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
)
50-444 OL NEW HAMPSHIRE, g al.
)
Off-site Emergency Planning
)
i (Seabrook Station, Units 1 and 2
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S RESPONSE TO TOWN OF HAMPTON FIRST SET OF INTERROOATORIES AND REOUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS (AS CORRECTED)" and "NRC STAFF'S RESPONSE TO NECNP'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF AND T!!E EXECUTIVE DIRECTOR OF OPERATIONS ON REVISION 2 TO THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY
RESPONSE
PLAN" in the above-captioned proceeding have been served on the following by deposit in the United States mail, nrat class, or (*) through by deposit in the Nuclear Regulatory Commission's internal mail system, or (**) overnight delivery this 16th day of March,1987:
Helen Hoyt, Esq., Chairman
- Gustave A. Linenberger, Jr.*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Doard U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour
- Ms. Carol Sneider, Esq.**
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Ofnce of the Attorney General l
U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor i
Washington, DC 20555 Boston, MA 02108 Deverly Hollingworth Richard A. Hampe, Esq.
209 Winnacunnet Road New Hampshire Civil Defense Agency Hampton, NH 03842 107 Pleasant Street Concord, NH 03301 Sandra Gavutis, Chairman Calvin A. Canney, City Manager i
Board of Selectmen City Hall l
RFD 1 Box 1164 126 Daniel Street Kensington, NH 03027 Portsmouth, NH 03801 i
l l
I
j
.g.
Stephen E. Merrill Paul McEachern, Esq.
Attorney General Matthew T. Brock, Esq.**
- George Dana Bisbee Shatnes & McEachern Assistant Attorney General 25 Maplewood Avenue Office of the Attorney General P.O. Box 360 25 Capitol Street Portsmouth, NH 03801 Concord, NH 03301 Roberta C. Pevear Angie Machiros, Chairman State Representative Board of Selectmen Town of Hampton Falls 25 High Road Drinkwater Road Newbury, MA 09150 Hampton Falls, NH 03844 Allen Lampert Mr. Robert J. Harrison Civil Defense Director President and Chief Executive Officer Town of Brentwood Public Service Co. of New Hampshire 20 FrankHn Street P.O. Box 330 Exeter, NH 03833 Manchester, NH 03105 Charles P. Graham, Esq.
Robert A. Backus, Esq.**
McKay, Murphy and Graham Backus, Meyer 6 Solomon 100 Main Street 116 Lowell Street Amesbury, MA 01913 Manchester, NH 03106 Diane Curran, Esq.**
Philip Ahren. Esq.
Harmon & Weiss Assistant Attorney General 2001 S Street, NW Office of the Attorney General Suite 430 State House Station #6 Washington, DC 20009 Augusta, ME 04333 Edward A. Thomas Thomas G. Dignan Jr., Esq.**
Federal Emergency Management Agency Ropes & Gray 442 J.W. McCormack (POCP) 225 Franklin Street Boston, MA 02109 Boston, MA 02110 H.J. Flynn, Esq.
William Armstrong Assistant General Counsel Civil Defense Director Federal Emergency Management Agency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Pancl*
Doard*
U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Jane Doughty Docketing and Service Section*
Seacoast Anti-Pollution League Offico of the Secretary 5 Market Street U.S.
Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, DC 20555
o
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Maynard L. Young, Chairman William 8. Lord Board of Selectmen Board of Selectmen 10 Central Road Town Hall - Friend Street South ifampton, NH 03287 Amesbury, MA 01913 Michael Santoaucaso, Chairman Peter J. Matthews, Mayor
~
Board of Selectmon City Hall South Hampton, NH 03287 Newburyport, MN 09150 Mr. Robert Carrigg, Chairman Judith H. Misner, Esq.
Board of Selectmen Silverglate, Gertner, Baker Town Office Fine and Good Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Boston, MA 02110 R. K. Gad III, Esq.
Mrs.
Anne E.
- Goodman, Chairman Ropes A Gray Board of Selectmen 225 Franklin Street 13-15 Newmarket Road Boston, MN 02110 Durham, Nil 03824 Gary W. Holmes, Esq.
Honorable Gordon J. Humphrey Holnies & Ellia United States Senate 47 Winnacunnet Road 531 Hart Senate Office Building Hampton, NH 03842 Washington, DC 20510
& : as Elaine I. Chan Counsel for NRC Staff