ML20207S631
| ML20207S631 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/18/1987 |
| From: | Sneider C MASSACHUSETTS, COMMONWEALTH OF |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| CON-#187-2827 OL, NUDOCS 8703200113 | |
| Download: ML20207S631 (40) | |
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00CHETED USHRC UNITED STATES OF AMERICA .-
17 MM 19 P2:46 NUCLEAR REGULATORY COMMISSION Before Administrative Judges: F Helen F. Hoyt, Chairperson [0CQT lb
BRANCH Gustave A. Linenberger, Jr.
Jerry Harbour
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF NEW ) Docket Nos.
HAMPSHIRE, ET AL. ) 50-443/444-OL (Seabrook Station, Units 1 and 2) ) (Off-Site EP)
) March 18, 1987
)
ATTORNEY GENERAL JAMES M. SHANNON'S SUPPLEMENTAL RESPONSE TO APPLICANTS' OFF-SITE INTERROGATORIES (SET NO. 1) DATED APRIL 28, 1986 Pursuant to 10 C.F.R. S2.740(e), Attorney General James M. Shannon hereby files a supplemental response to Applicants' Interrogatories (Set No. 1) dated April 28, 1986.
Specifically, with respect to the Applicants' " General Interrogatories" and interrogatory groups VI, XV, and XXXIX, the responses provided below supplement the prior responses made to these interrogatories in Attorney General Francis X. Bellotti's Response to Applicants' Interrogatories
.and Request for Production of Documents, filed July 3, 1986.
l In addition, supplemental responses are provided below to l
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I B703200113 870318 l PDR ADOCK 05000443 i G PDR $D3
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interrogatory groups IV, V, and XXXVII because Attorney General James M. Shannon has only recently, on March 2, 1987, given his notice of his intention to litigate these contentions (as revised).
Answer.t to Interrogatories IV, V, and XXXVII IV-1. Yes, as revised.
IV-2. Yes. The Massachusetts Attorney General believes that the State of New Hampshire will not make arrangements to obtain sufficient vehicles to evacuate schools, other special facilities, non-auto owning residents and all other transit dependent persons in Hampton, including those at the beaches, because (a) insufficient bus and driver pairs are available within a reasonable distance from Hampton, (b) the State has undercounted this population, and (c) the Massachusetts Attorney General agrees with the reasons given in the bases
! submitted by Hampton with this contention, as revised.
IV-3. No.
l IV-4. No.
l IV-5. The Massachusetts Attorney General agrees with Comment 17 on p. 4 of the RAC Review of the Seabrook Station Evacuation l
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Time Estimates and Traffic Management Plan Update. It is not reasonable to assume that "not even a fraction" of the thousands of transients and summer employees will need transit assistance from the EPZ in the event of an evacuation.
IV-6. The Massachusetts Attorney General does not know whether any two-way roads will be converted to one way traffic flow during an emergency.
IV-7. The Massachusetts Attorney General does contend that, given the plans to install cones and traffic barricades at most key intersections in the EPZ, there would be at least a substantial delay in the arrival of many evacuation vehicles.
The further each vehicle must travel, the longer the delay is likely to be . However, if these roads were all operated during an emergency in the " normal manner," i.e., without any cones or barricades, chaos would result and most out-of-town emergency vehicles would not reach Hampton.
IV-8. The Massachusetts Attorney General does not know.
IV-9. The Massachusetts Attorney General has no knowledge of the basis of the population estimates in Mr. French's affidavit.
9 IV-10. The Massachusetts Attorney General does not know.
IV-ll. The Massachusetts Attorney General has not decided whether to offer the testimony of any expert witness with respect to this contention and will supplement this answer, if necessary, pursuant to 10 C.F.R. S 2.740(e).
V-1. Yes, as revised.
V-2. No. The Massachusetts Attorney General.has no information or knowledge to support the assertions by Mr. French in his affidavit. The Massachusetts Attorney General is not aware of any studies, surveys, or analyses to provide a foundation for Mr. French's estimates.
V-3. The Massachusetts Attorney General does-not know.
V-4. The Massachusetts Attorney General does not know.
V-5. The Massachusetts Attorney General is currently reviewing all studies which led to estimates of people population in Hampton, including the beaches. At this time, however, the Massachusetts Attorney General has not determined whether these studies are inaccurate or accurate.
V-6. The Massachusetts Attorney General has no such data.
V-7. The Massachusetts Attorney General does not know.
V-8. The Massachusetts Attorney General does not know.
V-9. The Massachusetts Attorney General does not know.
V-10. The Massachusetts Attorney General does not know.
V-ll. The Massachusetts Attorney General does not know.
V-12. The Massachusetts Attorney General does not know.
V-13. The Massachusetts Attorney General does not know.
V-14. The Massachusetts Attorney General does not know.
V-15. The Massachusetts Attorney General does not know.
V-16. The Massachusetts Attorney General does not know.
V-17. The Town of Hampton is refusing to participate in evacuation and preparation for an emergency at the Seabrook i
nuclear plant.
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s V-18. See NHRERP Vols. 18 and 18A. See, in particular Vol. 18, p. II-28, 28a, 30, 31.
V-19. They may have been dropped off at the beach that day, or days or weeks earlier, and have no vehicle available to leave the beach area. They also may have pedalled a bike or walked to the beach from some distance away.
V-20. The Massachusetts Attorney General does not know. At this time the Massachusetts Attorney General is still in the process of identifying the data or studies in contending that accidents, breakdowns, driver disobedience, panic and gas shortages will occur to the extent that an orderly evacuation cannot be implemented.
V-21. The Massachusetts Attorney General does not know.
V-22. The Massachusetts Attorney General has insufficient information to answer this interrogatory.
V-23. The Massachusetts Attorney General does not know.
V-24. The Town of Hampton is refusing to participate in evacuation planning and preparation for an emergency at the Seabrook nuclear plant.
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V-25. The Massachusetts Attorney General has not decided whether to offer the testimony of any expert witness with respect to this contention and will supplement this answer promptly, if necessary, pursuant to 10 C.F.R. S 2.740(e).
XXXVII-1. Yes.
XXXVII-2. The Massachusetts Attorney General does not have sufficient information to answer this interrogatory at this time.
XXXVII-3. See response to interrogatory XXXVII-2.
XXXVII-4. See response to interrogatory XXXVII-2.
XXXVII-5. See response to interrogatory XXXVII-2.
XXXVII-6. Sec response to interrogatory XXXVII-2.
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XXXVII-7. See response to interrogatory XXXVII-2.
XXXVII-8. See response to interrogatory XXXVII-2.
XXXVII-9. See response to interrogatory XXXVII-2.
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g XXXVII-10. See response to interrogatory XXXVII-2.
XXXVII-11. See response to interrogatory XXXVII-2.
XXXVII-12. The Massachusetts Attorney General is currently reviewing whether the State has adequate manpower to perform a broad range of emergency functions under various serious accident sequences. At this point the Massachusetts Attorney General contends that there is inadequate manpower assigned to drive transport vehicles and tow trucks. The basis for this assertion is that the NHRERP-Rev. 2 seriously undercounts the number of persons needing transit assistance, especially among those persons on the beaches, and the number of breakdowns and accidents which will occur that would impede traffic flow.
XXXVII-13. The Massachusetts Attorney General has not decided whether to offer the testimony of any expert witness with respect to this contention and will supplement this answer, if necessary, pursuant to 10 C.F.R. S 2.740(e).
Supplemental Response to Interrogatories VI, XV and XXXIX In addition to the expert witnesses previously identified by the Massachusetts Attorney General in his response dated July 3, 1986, the Attorney General intends to offer the testimony of Dr. Robert Goble, Center for Technology,
D Environment and Development, Clark University, Worcester, Massachusetts, on: Hampton Contention 8; SAPL Contention 16 and NECNP Contention 8. A resume of Dr. Goble is attached hereto. Dr. Goble's testimony will be introduced with respect to the need for and adequacy or inadequacy of any plans for sheltering the summer beach population near Seabrook.
Dr. Goble is still in the process of preparing his testimony and the facts and final opinions which will form the substance of his testimony have not yet been determined. The Attorney General will provide a supplement to this response at such time as the substance of those facts and opinions is determined.
The Attorney General expects Dr. Jan Beyea, previously identified in our response of July 3, 1986, to testify as to the inadequacy of evacuation alone as a protective response action for the summer beach population. Dr. Beyea will base his testimony primarily on his analysis of the dose consequences to the summer beach population of four categories of accident releases, under varying meteorological conditions, assuming, as the NHRERP provides, that the population is
- instructed to evacuate without sheltering. Dr. Beyea's l
analysis will be based on essentially the same considerations (analyzing " skin deposition dose," " car deposition dose" and considering the same Pasquill stability classes, wind speeds, dose scaling factors etc.) as set forth at pp. 3-12 e
(" Exhibit A") of the basis t'o the contention previously filed in this proceeding by the Massachusetts Attorney General on February 21, 1986 and September 9, 1983 [ attached hereto]. The four categories of accident releases on which Dr. Beyea is expected to testify with respect to the adequacy of the evacuation response are:
Category 1: Early containment failure with core oxidation. This category is respresented by an "Sl" steam-explosion release defined in the Seabrook Probabilistic Safety Assessment (PSA).
Also included in this category is a high-pressure melt ejection sequence.
Category 2: A rapid containment bypass release, as represented by an "S6V-total" sequence defined by analysts at Brookhaven National Laboratory (as part of their review for the NRC of the Seabrook PSA). In this release category, a direct pathway to.the atmosphere is opened as a result of containment bypass and the bulk of the escaping radioactivity leaves the reactor within a one-hour period. Included in this i
category are thermally induced steam generator
! tube failures and interfacing systems accidents.
Category 3: An overpressurization ("PWR2")
release as defined in the NRC's Reactor Safety Study (Wash-1400).
Category 4: A slow containment bypass release, as defined in the Seabrook PSA, in which radioactivity escapes in puffs of varying duration.
The basic modelling to be employed by Dr. Beyea in
(
analyzing the dose consequences to the beach population has l
i been previously utilized by him as follows:
(a) Jan Beyea, Program BADAC-1, "Short-Term Doses Following a Hypothetical Core Meltdown (with Breach of Containment)" (1978), prepared for the New Jersey Department of Environmental Protection.
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(b) Jan Beyea and Frank von Hippel, "Some Long-Term Consequences of Hypothetical Major Releases of Radioactivity to the Atmosphere from Three Mile Island," report to the President's Council on Environmental Quality, Center for Environmental Studies, Princeton University, (1979), Appendix E.
(c) Jan Beyea, "A Study of the Consequences of Hypothetical Reactor Accidents at Barseback," (Stockholm: Swedish Energy Commission, 1978) (See appendices for a detailed discussion of the basic dose calculations used in these programs).
(d) Brian Palenik and Jan Beyea, "Some Consequences of Catastrophic Accidents at Indian Point and Their Implications for Emergency Planning," direct testimony on behalf of New York State Attorney General, Union of Concerned Scientists (UCS), New York Public Interest Research Group (NYPIRG), New York City Audubon Society, before NRC Atomic Safety and Licensing Board, July, 1982.
The basic modelling is similar to the approach taken by radiological protection agencies around the world, including the NRC, and the only novel aspects of the calculations involve the following:
- 1) Radiation shielding: Radiation shielding factors for cars used in the 1975 Reactor Safety Study have been updated to account for changes in car construction that have been made to improve fuel economy in the intervening years.
! 2) . Accounting for dispersion over water. Certain beach sites, e.g., Seabrook beach, have water between them and the reactor. Adjustments have been made for decreased j dispersion using standard methodology.
- 3) Radioactivity deposited on vehicle surfaces.
- 4) Radioactivity deposited on the skin and clothing of l beach-goers.
l
! The testimony of Dr. Gordon Thompson, previously
- identified, may also be offered with respect to the types of l
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a b
accident sequences considered by Dr. Beyea in his testimony.
Attorney General Shannon will further supplement this response in accordance with section 2.740(e) when the facts and opinions to which Dr. Beyea will testify are determined, and when decisions are made as to whether supporting testimony from any additional experts, such as Dr. Thompson, will be relied upon.
Respectfully submitted, JAMES M. SHANNON Attorney General By: b-Carol S. Sneider Donald S. Bronstein Assistant Attorneys General Environmental Protection Division Department of the Attorney General One Ashburton Place, Room 1902 Boston, MA 02108 (617) 727-2265 Dated: March 18, 1987 i
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July, 1986 ROBERT L. GOBLE Center for Technology, 137 Gardner Road Environment, and Development Brookline, MA 02146 and Department of Physics Clark University 617-566-4574 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 1967 Previous Emplovmant 1984-85 Princeton University, Center for Energy and Environmental Studies and Department of Philosophy: Hewlett Fellow 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 Department: Research Associate 1966-69 Yale University, Physics Department: Research Staff, Instructor 1962-66 University of Wisconsin, Physics Department: NSF Coopera-tive Fellow, Research Assistant Current Rasaarch Air Quality / Acid Deposition: Assessments and Reviews Tracer and Transport Studies Local Air Quality Risk Assessment / Hazard Mangement: Comparing Hazards and Hazard Assmessment Methodologies Ethical Issues in Hazard Management Planning Issues for Waste Disposal Radon Exposure and Health Effects Emergency Planning for Nuclear Power Plants
a
. Bag;aDi Ranmarch Activities 1983 - Emergency Planning for Nuclear Power Plants (Consultant to New Hampshire Attorney General's office, Three Mile Island Public Health Fund) Reviews, Planning Project is Pending.
1985 - Risk Assessment and Socio Economic Impacts in Radioactive Waste Management (Consultant to State of Mississippi, Citizens Against Nuclear Trash, and State of Nevada / Mountain West Inc.) Two 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 Occupational Lead Standard.
(Supported by OTA; Principal Investigator, four research-ers.) Report published as attachment to OTA Report:
Ereventino Illness and Infurv in j;ha 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.
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 from the exhaust and jacket. The plant began opration in Summer 1982; it supplies approximately half Clark's thermal energy needs and enough excess elec-l tricity so that half the output will be sold to the utility.
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, Tawhina And Student Bazaanr.h haarvision Dissertation Advisor for M. Yersel, May 1984 Ph.D.
Atmospheric Turbulence and Diffusion in an Urban Environment, Student Research Projects:
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; Cogen-eration Road Map for Colleges and Universities; Measurements of Worcester Weather; Pollutant Dispersal in Urban Areas; Effects of Buildings on Pollutant Dispersal; Cogeneration System Monitoring Environment, Technology, and Society:
Introductory Case Studies on Population and Food; Special Topics in Alter-native Energy: Cogeneration; Alternative Energy Systems Laboratory Physics for Non-Science Student:
Einstein's Ideas; Cultural Astronomy; College Physics; Particle Physics (an honors cou.se with laboratory); Urban Meteorology Undergraduate Physics:
Electricity and Magnetism; Classical Physics Graduate Physics:
Quantum Mechanics; Advanced Quantum Mechanics; Mathematical Methods Professional Sactaties American Association for the Advancement of Science American Physical Society: Forum on Science and Society; Division of Particles and Fields Sigma Xi Society for Risk Analysis Service 1976- City of Worcester Energy Task Force 1977- Clark Science, Technology, and Society, Program Committee 1978-80 Alternate, Clark Graduate Board 1978- Clark Energy Task Force 1981- Faculty Lounge Committee (installation and operation of new faculty dining room) j 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 198S)
American Association for the Advacement of Science: Summer Fellowship in Environmental Science (Summer 1982)
e Qthat Activittas Consulting Agreements:
1986 Rhode Island Dept. of Environmental Management. Risk Assessment Methods for Toxic Substances in Seafood.
1986 State of Nevada / Mountain West Inc., Risk Analysis for Radioactive Waste Disposal.
1986 - Citizens Against Nuclear Trash - Socio Economic Impacts of Radioactive Waste Disposal.
198S - Mississippi Health and Safety Office -- Radioactive Waste Risk Analysis.
1983 - New Hampshire Attorney General - Nuclear Emergency Planning.
October 1982-present. U.S. EPA: Acid Deposition Assessment.
1986 - Lecturer, Harvard School of Public Health, Short Course on Risk Assessment and Occupational Health.
1981 - Lecturer, Department of Engineering and Applied Science, University of Wisconsin--Extension Program on Industrial Facility Cogeneration.
e
. GRANTS NO AWARDS DAIE IIILE AMatmT university Grants Demonstration of a Grid-Connected Integrated Community Energy System 1982-84 Mass Electric Company / Colt Industries / 20,000 Mass Electric Construction. Grants 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) "
- DE-FG41-81R 113973
- DE-FG41-82R 143391 13,750 1980-82 HUD: Loan for Plant Construction 1,200,000 (co-authored with J. Collins, B. Kimball) 1980-82 DOE Phaso III: Constuction: grid connec- 330,000 tion and constuction management costs (co-authored with J. Collins) 1977-78 DOE Phase II: Detailed Feasibility and 206,000 Preliminary Design (co-authored with C. Hohenemser 1977 DOE Phase I: Preliminary Feasibility Study (co-authored with C. Hohenemser). $ 149,000 Other Grants And Grant hanort Raceived DAIE TITLE AMXMT 1984-86 NSF/NEH-Interdisciplinary Incentive Award 45,800 Ethical Issues in Hazard Management (Princi-pal Investigator- Individual Award) 1983-85 NSF-Sensitive Workers, Ethical Issues and 170,500 Differential Sensitivity to Workplace Hazard (Co-Principal Investigator with R. Kasperson) #RII 8217297 1983-84 Clark University-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) Contract
- 233-7040.0
_ _ __ J
. 1982 DOE-Nuclear Power Plant Performance 9,000 (Principal Investigator) Purchase Order
- DE-AP01-82 E119625 1982 AAAS-Summer Fellowship in Environmental 5,800 Sciences (for work on Acid Rain in EPA's Office of Strategy Assessment and Long Range Planning).
1980-82 NSF-Labor Latty-Comparison of Worker $ 240,000
& Public Protection from Technological Hazards (Co-Principal Investiator with R. Kasperson). #0SS 79-24516 1979-80 Association of Physical Plant Ad 4,000 ministration, Preparation of a Cogeneration Reference Manual 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 foss 77-16564 (Co-principal Investigator with Roger Kasperson).
1
, Publications ARTICLES (Energy / Hazards / Air Quality) 19Bfi
" Turbulence Parameters in an Urban Environment" (with M. Yersel) To be published in Boundary Layer Meteorology.
" 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 Hisk Evaluations And Management, V. Covello, J. Menkes and Y. Mumpower, eds. Plenum Press, New York, 1986.
1985
" Protecting Workers, Protecting Publics: The Ethics of Differential Protection" (with P. Derr, R. Kasperson, R. Kates) in V.T. Covello (ed.) Risk Analysis fn thg Private Sector, Plenum Press, New York, 1985.
1981
" Time Scales in the Radioactive Waste Problem" Eouitv Issues ja Radioactive Waste Managamant, 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), A+mnscheric 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
" Airborne 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 Quantifi-cation 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) 1922 "N.uclear Power Plant Performance: An Update," (with C. Hohenemser)
Environment V. 21, No. 8, 32 (1979)
_ m, , - . . . - - - . - . - . . - - . m.,.- -- . - . -
a-
. 191a
" Power Plant Performance" (with C. Hohenemser), Environment V. 20, No.3, 25, (1976).
TECMICAL MONOGRAPHS 1986 Ihn proposed Sebago LAkg nuclear waste repositoi y Arna: A oreliminary assessment af selected r.isk And social imoact considerations, (with J. Emel, J. Kasperson, and R. Kasperson. )
Worcester, MA: Hazard Assessment Group, CENTED, Clark University.
1981 Hisk issues associated with A salt-dQma repositorv At Richton, Mississioni, (with H. Brown, J. Emel, J. Kasperson, and R.
Kasperson.) New York: Social Impact Assessment Network.
1981 Methods 12E Analyzing And Comoaring Technological Hazards: Defini-tions 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 #3, October 1983.
1982 Atmosnheric Processes Affecting Acid Deoo*ition: Assessing .thg Assessments And Suggestions fat Further Research, AAAS, Fall 1982.
19aQ Cogeneration: A Camnus option, (with W. Goble) Association of Physical Plant Administrators, Washington, 1980).
1916 Statistical Analysis nf Nuclear And Caitl Power Plant Performance, (with C. Hohenemser) Scientists Institute for Public Information, New York, 1978.
4 1 *
. GDVERMENT REPORTS M
Tmnlementation ni thg Decunational LRad Standard, (with D. Hattis, M.
Ballew, D. Thurston), CENTED Working Paper HAG /WP 83-1, October 1983; in Preventing Illness and Iniury In thg Workolace, Vol. 2, NTIS.
Office of Technology Assessment, Washington, Spring, 1985.
Iha Acid Denosition Phenomenon and lig Effects: Critical Assessment Document Co-authors D. Bennett, R. Linthurst) U.S. EPA, EPA /60018-851001, August 1985.
1922-la
" 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 Preliminary Design Preliminary Report, DOE Report #C00-4211-2 (NTIS, 1978).
v.1: Final Report, DOE Report #C00-4211-3/1 (NTIS, 1978).
v.2: Appendices, DOE Report #C00-4211-3/2 (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, Hazards, Air Quality).
N "The Variation in Worker Response to Occupational Hazards" in Symposium on Managing High Risk Workers, Society for Risk Analysis, October 1985.
19ai
" Acid Rain." Invited talk presented at American Institute of Hydrology Conference, Future Issues in Hydrology, May 31, 1984.
M "Short Range Dispersion from a Point Source in an Urban Area," (with M. Yersel), Proceedings nf ihn dih symoostum nn Turbulence and Diffusion American Meteorological Society, Boston (1983)
M "A Participatory Approach to Undergraduate Energy Education: the Case of Clark Universty" (with D. Ducsik) Proceedings sd[1he International conference nn 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)
_-_ ____U
n a
. 1 91.2 .
"A Micrometeorological Study in the Worcester Area" (with A. Molod, Mi Yersel), Pro. eedings Af. m Conference na h Meteorolony pf;RQI thern Hex England Aad 1.hg Maritime Provinces, Gorhart, ME (1979).
12IA _
l'
" Grid-Connected Cogeneration at Clark Univursity: The Effect of Terms of Utility Interconnection: (with S.E. Hydick), Proceedings af.f.h2 s ,
International conference na Enerov JLei2 Manacerrant, Tucson (1978). ,
" Energy Profiles at Clark University: Implications for Coggn;iration" (with R. Collins, A. Gottlieb), Proceedings J.n f.he Drst H,*112nal Conference na Technology fan Energy Conservation, Washingtoil, D.C.-
(1977).
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. t ARTICLES ' Particle Physics) i f
i 1915
" Determination of the a -A Mass Difference (with J.S. Ball),
Phys. Rev. D 11, 1971 (1975).
J 1921 Y 8
, ."Two Pion In',ermediate States in Decay K - 2 Y ," Phys. Rev. D 1,
..931 (1973).
\
s 1922
" Soft, Pion Production in Electron-Positron Collisions" (with J.L.
Romesr), Phys. Rev. D E 2345 (1972).
r
" Current Algebra and Analyticity: Bootstrapping the p and owith the Pion Decay Constant Setting the Scale" (with (L.S. Brown), Phys. Rev.
( D1 723 (1971).
q, , , M s
I'i
" Pion-Pio.1 Scattering, Current Algebra, Unitarity, and the Width of iF' the Rho Meson" (with L.S. Brown), Phys. Rev. Lett. 2Q 346 (1%8).
t t "So't Photons and the Classical Limit" (with L.S. Brown), Phys. Rev.
123, 1505 (1 % 8).
7 y ,. ,
l' " Cross Section for the Production of a Possible Bound Cascade-Nucleon
( System" (with M.E. Ebel) Phys. Rev. B liq 1675 (1965).
p
( l' ,
COWERENCE ruuut.101EGS (Particle Physics) kq ' " Pion Form Facter and Inelastic m- w Scattering," Proceedings of the Internationa? Conference on w - WScattering (Tallahassee,1973).
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- l. '
t s
I i
t Dept #1:VITAERG
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e, f.,
r
- 6 EXHIBIT "A" (
l,9 -.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING SOARD i
Before Administrative Judges: _
Helen F. Hoyt, Chairperson Emmeth A. Luebke Jerry Harbour t
f f )
In the Matter of ) Docket Nos. 50-443-OL {
r ) 50-444-OL PUBLIC' SERVICE COMPANY OF )
_ ',NEW HAMPSHIRE, et al.
)
i (Seab rook iSt'at ion, Units 1 )
and 2) ) September 9, 1983
)
CONTENTION OF ATTORNEY GENERAL FRANCIS X.13ELLOTTI RELATIVE TO EMERGENCY PLANNING FOR THE NEW HAMPSHIRE BEACH COMMUNITIES On August 23, 1983, the Board ordered that contentions relating to off-site emergency planning for any or all of the fifteen New Hampshire communities for which draft emergency plans were recently submitted1! be filed on or before this date. In accordance with that order, Attorney General Bellotti
' hereby submits a single contention which relates to off-site O
1/ The fifteen communities are Hampton, Newton, Rye, Stratham, Exeter, New Castle, North Hampton, Stabrook, Brentwood,
'Kensington, Newfields, Portsmouth, South Hampton, East Kingston, and Kingston.
e 6
l emergency action in the coastal beach areas of Seabrook,
( Hampton, North Hampton, and Rye which are frequented by Massachusetts citizens.
CONTENTION:
The draft radiological emergency response plans for the Towns of Seabrook, Hampton, North Hampton, and Rye do not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at the Seabrook Station, as required by 10 C.F.R. 550.47(a)(1),
because in the event of a severe accident on a summer weekend some or all of the beach area transient populations within those communities cannot under many plausible meteorological conditions be protected by means of evacuation even from early death and because there are not adequate plans or provisions for sheltering the beach area transients within those communities.
BASES:
The draft emergency response plans for the Towns of Seabrook, Hampton, North Hampton, and Rye all rely on evacuation and sheltering as the two options for protecting persons present in those communities at the time of a radiological emergency at Seabrook Station which results in a radiological release to areas within those communities. See, e.g., Seabrook Plan, at II-I6 - II-I8; Rye Plan, at II-I6 -
II-I8; North Hampton Plan, at II-I7 - II-20; and Hampton Plan,
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at II-I7 - II-20.
However, a preliminary site-specific accident consequence analysis performed for the Massachusetts Attorney General has revealed that, given the unusual circumstances associated with dense beach populations, evacuation cannot protect the transient beach area populations in the vicinity of the Seabrook site from early death in the event of a PWR 2 release as defined in the NRC's Reactor Safety Study (WASH-1400) on a summer weekend.
A Seabrook-specific accident consequence analysis is being performed for the Department of the Attorney General by Dr. Jan Beyea, a nuclear physicist with extensive experience in accident consequence modelling and analysis. (A copy of Dr.
Beyea's resume is attached hereto as Exhibit A and incorporated herein by reference.) Dr. Beyea has advised the Department that there are unique considerations involved in the modelling and analysis of accident consequences for a site such as Seabrook having a large summer beach area population which have never before been taken into account in generic or site-specific consequence studies. In addition to the obvious effects on accident consequences of the increased population and evacuation times associated with summer beach areas and the absence of shielding normally provided by buildings, there are increased consequences due to material deposited directly on the skin and hair of beachgoers and on vehicles in the plume.
The former factor has received no consideration in accident
consequence analyses in the past and the latter has received inadequate consideration.
In the work which Dr. Beyea and his assistant Brian Palenik, a graduate student at the Massachusetts Institute of Technology, have performed for this Department to date they have investigated the conditions under which the nearest beach population to this site, at about two miles, might be exposed to doses at a threshold level for early death (200 rem) in the event of a PWR 2 release as defined in the Reactor Safety Study (WASH-1400). Estimates of the time within which that population would receive a 200 rem dose have been calculated for various weather stability classes and wind speeds using two sets of assumptions. The first set assumes that all persons are inside automobiles when the release occurs and receive only a fraction of the doses they would receive if they were in the open, exposed directly to a plane of contaminated ground.
These results have been calculated using the assumptions which have heretofore been considered standard in accident consequence calculations. The second set of results goes beyond the standard assumptions, to account specifically for 1
the Seabrook beach situation. Those results assume that some of the population will not have reached their vehicles before plume passage such that there will be a " skin deposition dose" and a " car deposition dose." For each of the two sets of results calculations have been performed separately for high
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and low energy release rates. This division was necessary given the large uncertainty in the height to which the radioactive plume will rise, a factor which is affected by energy release rates and which is an important determinant of the doses to a nearby population.
Tabl$s 1 and 2, which follow hereafter, contain the results of Dr. Beyea's modelling and analysis as described above. The entries in the last column of each table result from a ,
comparison between the time required to reach a 200 rem dose and current estimates of the time required to evacuate the population within two miles on a summer weekend. See Table 3.
The data set forth in these tables reveal that the summer weekend beach population within two miles of the Seabrook site cannot be protected from early death by means of evacuation under many weather conditions.
It should be noted that neither precipitation nor slow wind speeds have been considered in the analyses set forth in Tables 1 and 2. Both such conditions are more severe than those represented in the tables. The frequencies of the Pasquill l
stability classes reflected in Tables 1 and 2 as reported in the Applicants' ER-OL are given in Table 4. The frequencies of the A, B, and C stability classes increase during the summer l months, with C the most frequent of the three. D and E are the l
dominant stability classes. The results discussed herein are a.
not, therefore, based on infrequently occurring or worst-case weather conditions.
O TABLE 1 PROTECTION OF CLOSEST BEACH POPULATIONa)
FROM EARLY DEATH ON A SUMMER WEEKEND DAY HIGH ENERGY RELEASE RATE DI Dose Stability C) Wind Speed Scaling d) Time to Reach Protection *I Class- (m/,sec) Factor 200 rem of Population A 2 .53 .78 14.5-20.9 Yes A
2 1.0-1.3 9.0-11.5 Yes A 4 .53 .78 > 24 Yes 4 1.0-1.3 19.2-25.0 Yes A
2 .53 .78 4.6-6.4 No B
2 1.0-1.3 3.2-3.8 No B
B 4 .53 .78 12.2-17.8 Yes 4 1.0-1.3 7.6-9.6 Yes B
.53 .78 2.6-3.4 No C 2 1.0-1.3 1. 9- 2. 2 No C 2 4 .53 .78 8-11.5 Yes C
1.0-1.3 5.1-6.4 No C 4
.53 .78 > 24 Yes D 2 Yes D 2 1.0-1.3 )24
.53 .78 6.5-9.2 Yes D 4 4.2-5.3 No D 4 1.0-1.3 a) The population two miles from tne plant. 6 b) Assumes an energy release cate of 176 x 10 Stu/ hour.
c) Pasquill stability class.
d) The dose scaling factor range of .53 .78 assumes an individual is in a car within ene plume. The dose scaling factor range of 1.0-1.3 assumes an individual is in a car within the plume, with a dose component froa radioactive material deposited on the car and directly on the individual e) Protection of the population from a 200 rem dose or higher. This If the assumes an evacuation time of about five and a half hours.
evacuation time is longer, the population is not necessarily protected.
7-TABLE 2 PROTECTION OF CLOSEST BEACH POPULATION"I PROM EARLY DEATH ON A SUMMER WEEKEND DAY LOW ENERGY RELEASE RATE DI Dose Stability c) Wind Speed Scaling d) Time to Reach Protection *)
Class (m/sec) Factor 200 rem of Population-A 2 .53 .78 13.8-19.9 Yes A 2 1.0-1.3 8.6-10.9 Yes A 4 .53 .78 )24 Yes A 4 1.0-1.3 18.4-23.7 Yes B 2 .53 .78 3.7-4.9 No B 2 1.0-1.3 2.5-3.0 No B 4 .53 .78 9.9-14.2 Yes B 4 1.0-1.3 6.2-7.8 Yes C 2 .53 .78 l1 No C 2 1.0-1.3 (1 No C 4 .53 .78 1.7-2.2 No C 4 1.0-1.3 1.3-1.5 No D 2 .53 .78 (l No D 2 1.0-1.3 (l No D 4 .53 .78 (l No D 4 1.0-1.3 (l No a) The population two miles from the plant. 6 b) Assumes an energy release rate of 20 x 10 stu/hcur, or an equivalently low plume for reasons unrelated to the energy release rate.
c) Pasquill stability class.
d) The dose scaling factog range of .53 .78 assumes an individual is in a car within the plume. The dose scaling factor range of 1.0-1.3 assumes an individual is in a car within the plume, with a dose component from radioactive material deposited on the car and directly on the individual.
e) Protection of the population from a 200 rem dose or higher. This assumes an evacuation time of about five and a half hours. If the evacuation time is longer, the population is not necessarily protected.
O m r
TABLE 3 SEABROOK EVACUATION CLEAR TIME ESTIMATES a)
SUMMER WEEKEND / FAIR WEATHER SCENARIO Radius Degrees HMMb ) VorheesC) Maguired) NRCO) 0-2 360* 4:50 5:10 5:40 ---
0-3 180* E 5:20 --- --- ---
0-5 360' 5:50 5:10-5:40 --- ---
0-10 360* 6:05 5:10-6:10 5:50 11:25 a) Time (hours: minutes) for the population to clear the indicated area after notification.
b) Preliminary Evacuation Clear Time Estimates for Areas Near Seabrook Station, HMM Document No. C-80-024A, HMM Associates, Inc., May 20, 1980.
c) Final Report, Estimate of Evacuation Times, Alan M. Vorhees & Associates, July 1980.
d) Emergency Planning Zone Evacuation Clear Time Estimates, C.E. Maguire, Inc., February 1983.
e) An Independent Assessment of Evacuation Time Estimates for a Peak Population Scenario in the Emergency Planning Zone of the Seabrook Nuclear Power Station, M.P. Mueller, et al., Pacific Northwest Laboratory NUREG/CR-2903, PNL-4290.
e
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o TABLE 4 FREQUENCY OF PASQUILL STABILITY CLASSES AT SEABROOK a)
(Values in % of Time)
Month A 3 C D E F G Apr 1979 1.27 2.11 3.80 49.65 29.10 7.88 5.91
!!ay 1.20 2.86 4.82 52.86 26.51 5.27 6.48 June 2.92 6.69 12.26 39.83 25.49 6.13 6.69 July 4.90 6.94 11.56 29.12 28.84 12.65 5.10 Aug 2.91 4.71 ~ 9.97 43.07 26.59 7.34 5.:40 Sep 1.25 7.64 11.81 30.69 27.36 10.83 10.42 Oct 0.81 2.96 5.79 39.30 34.05 10.09 7.00 Nov 0.00 0.56 4.76 43.92 34.83 9.37 6.57 Dec 0.00 0.41 2.70 47.03 41.35 5.81 2.70 Jan 1980 0.13 1.88 6.59 51.88 30.38 5.78 3.36 Feo 0.44 2.03 5.37 50.36 34.69 5.66 1.45 Mar 10.68 1.64 5.34 43.15 24.66 6.03 8.49 Yearly 2.22 3.37 7.08 43.31 30.38 7.76 5.37 a) Period of Record: April 1979 - March 1980. Stability class calculated using 43'-209' delta temperature. Source: SB 152, ER-OLS, Table 2.3-24. ,
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The size of the beach area population around Seabrook is uncertain. One estimate of this population for 1980 has been made by Public Service Company of New Hampshire and is found in Table 5. Although its accuracy is uncertain, this estimate does indicate that a substantial number of people are located within two mil'es of the plant. The number of persons that would be located within a plume obviously varies with wind direction, but it also varies with stability class and distance from the plant. At two miles the plume could be viewed as being between a 29' wedge (A stability class) and a 13' wedge (D stability class)3! compared to the 22.5 8 population wedges in the table.
In addition to investigating the conditions under which the beach population within two miles of the Seabrook site might be exposed to early death doses, Dr. Beyea and Mr. Palenik have commenced work designed to determine the radius within which early deaths might result in the vicinity of this site assuming an accidental release on a summer weekend. Dr. Beyea has found early death radii ranging from <2 to 4.3 miles assuming a PWR 2 release as defined in the Reactor Safety Study (WASH-1400), C stability class weather conditions, an evacuation time of 5-1/2 hours, and the two sets of dose scaling factors discussed previously. For weather conditions with overcast skies (D 2/ Wedges are assumed to have plume widths equal to three times the horizontal dispersion coefficient.
S s s ,
TABLE 5 1980 BSACE AREA TRANSIENT POPULATION ESTIMATE a) BY SECTOR DI Ring dadii (miles) NE ENE E ESE SE SSE 0-1 0 0 0 0 0 0 1-2 464 14,647 12,780 5,842 129~ 23 2-3 1,104 8,882 0 0 3,905 654 3-4 8,710 608 0 0 0 6,198 4-5 4,344 0 0 0 0 8,880 5-10 5,660 0 0 0 0 16,597 Source: Public Service of New Hampshire, Seabrook Station - Units 1 & 2, Environmental Report, Operating License Stage, Figure 2.1-19.
a) Estimate of peak transient population found by multiplying the capacity of beach area parking lots (less leased space) by 3.2 persons per vehicle, and contributions from off-street parking users, seasonal residents, and overnight visitors.
b) Each direction in the table is the centerline of a 22.5 degree wedge.
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stability class), or longer evacuation times,2# the early death radii will be larger. And the tims before doses reach 200 rem, assuming.a PWR 2 release on a summer weekend evening and a low energy release rate such as that assumed in the draft Seabrook Probabilistic Risk Assessment, is less than four hours out to 6-7 miles from the site. Thus, the beach area population within 6-7 miles exposed to the plume would not be protected from early death even if there were a 20-30 percent reduction in evacuation times from daytime to evening. It should be noted in this connection that at least the Hampton Beach area has a very substantial nighttime population.
Thus, primary accident consequence data developed for this Department reveal that evacuation cannot under a number of plausible weather conditions protect the summer weekend beach area populations in the vicinity of this site from even early death. The results described herein do not account for the less severe consequences of radiation illness and delayed fatalities due to latent cancers. Despite the severe limitations on the utility of evacuation as a protective option for the transient beach population, however, there are currently no provisions for sheltering that population within the EPZ. Neither the New Hampshire Radiological Emergency J/ The Applicants have now provided a 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 5 minutes estimate for summer weekend simultaneous beach evacuation within ten miles of the site. See Applicants' Direct Testimony
.No. 1, filed July I5, 1983, at 19-20.
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Response Plan nor the local community plans contain any analysis of available public sheltering, or its capacity to accommodate the beach populations or to provide shielding from radionuclides, or any plans for effecting such sheltering. In short, there is at present no basis for (and has not been) any development of sheltering as a potential protective action for the beach population.
Respectfully submitted, FRANCIS X. BELLOTTI ATTORNEY GENERAL N
By:
JO
) SHOTWELL --
As ant Attorney General En onmental Protection Division One Ashburton Place Boston, MA 02108 (617) 727-2265
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4 UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC 17 WR 19 P2:46
)
In the Matter of ) 0FFICE OF SECHGiF.
) 00CKETI% A SE AvfCf.
PUBLIC SERVICE COMPANY OF NEW ) Docket No.(s) 50-Fif/#44-OL HAMPSHIRE, ET AL. )
(Seabrook Station, Units 1 and 2) )
)
)
CERTIFICATE OF SERVICE I, Carol S. Sneider, hereby certify that on March 18, 1987 I made service of the within document, by mailing copies thereof, postage prepaid, by first class mail, or as indicated by an asterisk, by Federal Express mail, to:
- Helen F. Hoyt, Chairperson *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 Third Floor Mailroom Third Floor Mailroom Bethesda, MD 20814 Bethesda, MD 20814
- Dr. Jerry Harbour *Sherwin E. Turk, Esq.
Atomic Safety & Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission East West Towers Building Tenth Floor 4350 East West Highway 7735 Old Georgetown Road Third Floor Mailroom Bethesda, MD 20814 Bethesda, MD 20814
- 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 Office of the Attorney General 500 C Street, S.W. 25 Capitol Street Washington, DC 20472 Concord, NH 03301
9 4
- 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 Ms. 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 Paul McEachern, Esq. J. P. Nadeau Matthew T. Brock, Esq. Board of Selectmen Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P.O. Box 360 Portsmouth, NH 03801 Ms. Sandra Gavutis, Chairperson Mr. Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E. Kingston, NH 03827 Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. 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 Mr. Peter J. Matthews 1 Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Donald E. Chick Mr. William Lord Town Manager Board of Selectmen i Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amesbury, MA 01913
p.
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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. Diane Curran, 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.
R.K. Gad III, Esq. Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth
- Edward A. Thomas 209 Winnacunnet Road Federal Emergency Management Hampton, NH 03842 Agency 442 J.W. McCormack (POCH)
Boston, MA 02109 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 Mrs. 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 Allen Lampert Sheldon J. Wolfe, Chairperson Civil Defense Director Atomic Safety and Licensing Town of Brentwood Board Panel 20 Franklin Street U.S. Nuclear Regulatory Commission Exeter, NH 03833 Washington, DC 20555 Dr. Emmeth A. Luebke, Jr. Charles P. Graham, Esq.
Atomic Safety & Licensing Board McKay, Murphy & Graham U.S. Nuclear Regulatory Old Post Office Square Commission 100 Main Street East West Towers Building Amesbury, MA 01913 4350 East West Highway Third Floor Mailroom Third Floor Mailroom Bethesda, MD 20814 Bethesda, MD 20814 Judith H. Mizner, Esq.
Silvergate, Gertner, Baker, Fine, Good & Mizner 88 Broad Street Boston, MA 02110 i
V Rep._ Edward J. Markey,_ Chairman U.S. House of Representatives Subcommittee on Energy Conservation and Power Room H2-316 House Office Building Annex No. 2 Washington, DC 20515 Attn: Linda Correia L ik)
Carol S. Sneider
-Assistant Attorney General Environmental Protection: Division Dated: March 18, 1987
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