ML20207C595

Intervenor Exhibit I-State-37,consisting of Draft Outline of Rebuttal Testimony Re Beach Shelter Issue

ML20207C595
Person / Time
Site:	Seabrook
Issue date:	05/26/1988
From:	Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Harbour J, Linenburger G, Smith I Atomic Safety and Licensing Board Panel
References
OL-I-STATE-037, OL-I-STATE-37, NUDOCS 8808090298
Download: ML20207C595 (4)

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• 8 JUL 19 P6 :04 October 5,1987 grn o. : . rjj rf.i. v DDCKE IN 4 '9'MI.

BRANCH Ivan Smith, Esq. , Chairman Gustave A. Linenberger. Jr.

Administrative Judge Administrative Judge l Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regu!atory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 in the Matter of l PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ET AL.

(Seabrook Station, Units 1 and 2) l Docket Nos. 50-443,30-444 Off-Site Emergency Planninq l l

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Dear Administrative Judges:

In a f: ling dated September 4, 1987, the NRC Staff advised the Board '

and parties that it may wish to submit rebuttal testimony with respect to the beach shelter issue, in accordance with the Licensing Board's "Memor.andum and O rc'e r (Clarifying Presentation of Rebuttal Testimony)", dated September 9, 1987, the Staff hereby submits a draft outline of the areas it may wish to address in its rebuttal testimony, in the event the Staff determines following cross-examination that such rebuttal testimony is appropriate.

Sincerely, h 0 Sherwin E. Turk

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Counsel for NRC Staff cc: Service List D 8808090298 880526 V DR ADOCK 050 j 43

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Proposed Rebuttal Testimony of NRC Staff C Concernint NHRERP Protective Actions For

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     ' '                          Seabrook Area Seasonal Beach Populations

1.

Introduction:

The Function and Objecti'.es of Emergency Planning. A. The Coal of Emergency P'anning Is To Mitigate the Radiological Impacts of An Accident if A Release of Radiation Should Occur. l B. The Overall Objective of Emergency Planning is To Provide Dose Savings (and in Some Cases , immediate Life Saving) for A Spectrum of Accidents That Could Produce Doses in Excess of the Protective Action Guides. C. The Planning Basis Regtfires Applicants and Covernmental Organizations to Demonstrate A Capability for Prompt Notification of the Public.

b. Planning is Not Pequired for Any Particular Acddent, Nor is Planning Recuired to Assure the Avoidance of Any Particular Dose Or to Demonstrate That Any or All of the EPZ Can Be Evacuated Within Any Particular Time Frame.

E. The Provision of 10 C.F.R. 9 50.47(b)(10) That There Be "A p Range of Protective Actions" Does Not Require That There Be A d Range of Protective Act!ons For All Accidents at All Times and at All Locations W! thin the EPZ. fl. The Provisions Contained in NHRERP Revision 2 for Protection of Seabrook Area Seasonal Beach Populations Comply With the Guidance Contained in N U R EG-0654, Except to the Extent that Deficiencies Otherwise Exist in the NHRERP. A. The NHRERP Provides A Range of Protective Actions for Beach Areas During Most of the ' rear. B. During the Beach Season, the NHRERP Providu; for Early Consideration, At the "Alert" Level, As to Whether to Restrict Public Access to the Beaches or Close the Beaches and Commence Early Evacuation of Beach Areas Before a General Evacuation Would Commence. C. The Beach Areas Are Equipped With Sirens Capable of Providing Both Tone Alerts and Public Address (Voice) Messages, in Order to Afford Seasont.1 Beach Populations With Prompt Notification and instructions to Follow in An Emergency. O

D. The NHRERP Provides for Traffic Control and Other Emergency bm) Response Personnel to Assist the Public in Evacuating Beach Areas. E. Evacuation is the Prefer ed Protective Response for Seabrook Area Seasonal Beach Populations. F. Ihe Absence of Sheltering As An Alternative Protective Response for Seabrook Seasonal Beach Populations Does Not Contr.avane NRC Area Regi ,laIIons and Guidance, and is Consistent With the Level of Planning in Place at Other Nuclear

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t Plant Sites. Ill. Concusion: The NHRERP Provides Dose Sav!ngs for A Spectrum of Accidents That Could Produce Doses in Excess of the PAGs. Consistent With 10 C.F.R. 9 50.47(a), the NHRERP Provides Reasonable Assurance That Adequate Protective Measures Can and Will, Be Taken, With Respect tra Seabrook Area Seasonal Beach Populations, in the Event of A Radiological Emergency. 2 O l l

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