ML20205P711

Motion for Summary Disposition (Tok 4).* Motion Based on Listed Reasons & Ja Macdonald Affidavit.Statement of Matl Facts Not in Dispute Encl

ML20205P711
Person / Time
Site:	Seabrook
Issue date:	03/25/1987
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
Shared Package
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References
OL, NUDOCS 8704030350
Download: ML20205P711 (5)

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Dated: March 25, 1987 UNITED STATES OF: AMERICA NUCLEAR REGULATORY: COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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

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

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MOTION FOR

SUMMARY

DISPOSITION (TOK 4)

Now come the Applicants pursuant to 10 CFR 2.749 and on the basis of the facts sets forth in the " Affidavit of James A. MacDonald (TOK 4)" (MacDonald Affidavit) and for the reasons set forth below move the Board to enter an order granting summary disposition in favor of the Applicants with respect to Town of Kensington (TOK) Contention No. 4.

REASONS FOR GRANTING THE MOTION TOK Contention 4 reads as follows:

"The NHRERP, Revision 2 for "TOK" does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook Station, as required by 10 CFR 50.47(a)(1), because the 0 h43 PDR

1-Kensington Elementary School provides inadequate-radiological protection" This contention has.previously been limited."to a demonstration that the Kensington Elementary School has.DRF' of .9 and how that determination was made by the State of NH." ASLB Mem. & Ord. Nov. 4, 1986 at p. 34. A study'has.

now been done which demonstrates that the DRF for the Kensington Elementary School is better than 9; it is about

.8. MacDonald Aff., passim.

Moreover, what is important is that, in arriving at a protective response recommendation, the decision-makers be aware of the availability of shelters and that-this be factored into the process along with the prognosis for the accident, time constraints and other existing conditions.

Since protective active recommendations are based upon the dose projection for the entire population, evaluation of protection provided by the Kensington Elementary School would neither make it more suitable for sheltering nor affect the choice of the sheltering option. An individualized evaluation of the protection afforded by the Kensington Elementary School, which the town seeks would have no impact on the plan's decision making process.-

Notwithstanding the above, Applicants have evaluated the shielding factor of the Kensington Elementary School in order to close the issue once and for all. MacDonald Aff.

It shows that the shielding factor is better than that v , .

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I assumed for the General' Population dose in the Protective Action Recommendation Worksheet. \ 5 g

By their attorneys, M

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' ThN Digpifff, Jr.

R. K. Gad IIT \

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Kathryn A. Selleck \

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Ropes & Gray

' ' 225 Franklin Street Boston,GfA 02110 t 5' 8 5 (617) 423-6100 \

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4 STATEMENT OF MATERIAL' FACTS /

NOT IN DISPUTE

1. An evaluation was conducted of the Kensington '

1 Elementary School based upon visual inspection and actual. l measurements of the outside of ' the building -in order. to

' approximate its DRE.

2. The methodology of:the report, " Structure Shielding from. Cloud'and Fallout of Gamma Ray Sources for Assessing the Consequences of Reactor Accidents," December'1975, was used to determine'the dose reduction' factor.for the.

Kensington Elementary School.

3. Based on a calculation, included as Attachment 1, i) the report concluded that the overall dose reduction factor is approximately 0.8.

4. If the projected evacuation dose to the general population does not exceed the Protective Action Guidelines, 5 (PAG's) ,then the question of adequacy of a shelter is a moot point since'any shelter at all would only further reduce the projected dose.

5. If the projected evacuation dose to the general population exceeds the PAG's as' implied in the-report entitled, " Structure Shielding From Cloud and Fallout Gamma

, Ray Sources For Assessing the Consequences of Reactor l

Accidents", December 1975, then essentially any indoor  !

., locatikn, even a wood frame house with no basement, provides

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at least a 10% reduction for a cloud source or a DRF of 0.9 (see. table 10 of the referenced document).

6. As demonstrated in the affidavit of James A.

MacDonald, the Kensington Elementary School is reasonably expected to provide at least'this level, if not an even larger dose reduction. A decision to recommend shelter-in-place, therefore, under this scenario would not be invalidated by the physical details of the school.

7. Instructions are provided to school officials via the Emergency Broadcast System, Public Information Materiala' and in Appendix F of each town's RERP to close all windows and doors, and turn off all ventilation systems using outside air to maximize the dose reduction potential of a shelter.

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