ML20206M326
| ML20206M326 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/15/1987 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20206M223 | List: |
| References | |
| OL, NUDOCS 8704200086 | |
| Download: ML20206M326 (4) | |
Text
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Dated:
April 15,1987 G
00pyg UNITED STATES OF AMERICA NUCLEAR REGULATOP?? COMMISSION jg ge16 N156.
before the FFig,[ANCdj,h NI.
ATOMIC SAFETY AND LICENSING BOARD BR In-the Matter of
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Docket No. 50-4)3-OL PUBLIC SERVICE COMPANY OF
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NEW HAMPSHIRE, et al
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Off-Site Emergency
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Planning Issues (Seabrook Station, Unit 1)
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SEACOAST ANTI-POLLUTON LEAGUES' RESPONSE TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITON OF SAPL CONTENTION NO. 34 Pursuant to 10 CFR S2.749, and on the basis of the Affidavit of Albert E. Luloff and for the reasons set forth below, SAPL hereby moves the Board to enter an order denying summary disposition of SAPL Contention No. 34.
REASONS FOR DENYING APPLICANTS ' MOTIQH SAPL Contention No. 34 reads:
The New Hampshire State and local plans do not meet the requirement that there be maps showing the population distribution around the f acility as required at NUREG-0654 'J.10.b. and Appendix 4.
Therefore, there is no reasonable assurance that adequate 8704200086 870415 PDR ADOCK 05000443 G
_2 protective measures can and will be taken pursuant to 10 CFR 5 50. 47 (a) (1) and 5 50.47 (b) (10).
Though there was one typographical error in numbers stated in SAPL's Contention No. 34, the other numbers cited were correct statements of total of numbers provided in Table 1 of the local plans.
Totals were off by 3,000 in some instances due to a mistake appearing in the plans for the summer midweek population for-the Town of Hampton. (See # 8 of Applicants '" Statement of Material Facts Not in Dispute" for an acknowledgement of this error).
The Affidavit of Albert E. Luloff states that very little or no confidence should be placed in the accuracy of figures in the NHRERP for (1) projections of population growth rates for towns in the EPZ, (2) the size of the special needs and other transit dependent groups and (3) the size of the peak transient population
( Af fidavit at 2).
The NHRERP reliance on figures drawn from local town offices and from a model developed by the Office of State Planning of New Hampshire does not provide an independent measure of validity (Affidavit at 4).
Experiential evidence and ancillary evidence support SAPL's claim that the area along the coast can be expected to have grown f aster than the county wide average (Affidavit at 6).
. GENUINE ISSUES OF MATERIAL FACT IN DISPUTE (SAPL CONTENTION NO. 34) 1.
SAPL's statements of population figures derived from Table 1 of the local RERP 's were not " false" as stated by the Applicants except for the number for summer population of 142,529.
This was a typographical error and should have been 142,569.
SAPL's number of 142,929 for total peak summer midweek population was correctly derived from Table 1.
The disagreement with Applicants arises because of a mistake in the plans themselves for the summer midweek population for the Town of Hampton which was 3,000 more than it should have been. (See Applicants' acknowledge-ment of this error at #8 in their " Statement of Material Facts Not in Dispute.")
2.
The peak summer midweek population for the EPZ derived 0
from Table 1, when corrected for the error in the plans described at #1 above, becomes_226,726, not 225,726 as the Applicants assert.
3.
The peak summer weekend population as derived from Table 1 is, as stated in SAPL's Contention 231,292, not 228,292 as the Applicants assert.
4.
Little confidence should be placed in the accuracy of i
figures in the NHRERP for (1) projections of population growth rates for towns in the EPZ, (2) the size of the special needs and other transit dependent groups and (3) the size of the peak transient population.
5.
An independent measure of validity is not provided by the NHRERP reliance on figures drawn from local town offices and
. from a model developed by the Office of State Planning of New Hampshire.
6.
Experiential and ancillary evidence support the claim that the area along the coast has grown f aster than the county wide average.
Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE by its Attorney Dated: April 15,1987
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' Robert n. Backus 116 Lowell Street Manchester, NH 03105 603-668-7272
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I hereby certify that a copy of the within Seacoast Anti-Pollution Leagues' Response to Applicants' Motion for Summary Disposition of SAPL Contention No. 34 has been sent this date, first class, postage prepaid, to those listed on the attached service list and has been federal expressed to those indicated by an asterisk.
-?$9.hkf$5$Aer Robert A. Backus
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