ML20212K370

Atty General Jm Shannon Offsite Emergency Planning Interrogatories & Request for Production of Documents to Applicants (Set 1).* Interrogatories Should Be Answered by 870319.Certificate of Svc Encl.Related Correspondence

ML20212K370
Person / Time
Site:	Seabrook
Issue date:	03/05/1987
From:	Bronstein D MASSACHUSETTS, COMMONWEALTH OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20212K324	List: ML20212K320 ML20212K348 ML20212K370
References
OL, NUDOCS 8703090289
Download: ML20212K370 (45)

Text

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8 ELATED CORRESM,6 00CKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION q ng g p3:32 Before Administrative Judges:

Helen F. Hoyt, Chairperson Gustave A. Linenberger, Jr. 4FFICE OF SECgdAHYStCMETING &

Jerry Harbour 3 RANCH

)

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 5, 1987

)

6 ATTORNEY GENERAL JAMES M. SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST'FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANTS (SET NO. 1)

Pursuant to 10 C.F.R. S2.740 and 2.740b, Attorney General James M. Shannon hereby propounds the following interrogatories to the Applicants. These interrogatories are to be answered in writing on or before March 19, 1987 and under oath by an employee, representative, or agent with personal knowledge of the facts or information requested in each interrogatory.

Definitions As used in these interrogatories, the following terms have the following meanings:

1. " Litigate" with regard to a topic or contention means to' offer direct testimony relating to, to cross-examine on, to 8703090289 870305 gDR ADOCK 05000443 PDR ,

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offer proposed findings or rulings regarding, or to urge the

. denial (or allowance subject'to conditions) of the pending application on the basis of the topic or contention.

2. " Contention to be litigated by the Attorney General"

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means those contentions admitted in this proceeding by the Order of the Licensing Board, dated February 18, 1987 and specified in " Attorney General James M. Shannon's Notice of Intention To Participate On Newly Admitted Contentions," dated March 2, 1987. Specifically, those contentions are ToH Revised Contention III; ToH. Revised Contention VI; ToH Revised Contention VIII; NECNP Contention RERP-8; SAPL Revised Contention 31; Reasserted SAPL Contention 8; SAPL Contention 8a; Reasserted SAPL. Contention 16; SAPL Contention 33; and SAPL Contention 34.

3. " Document" means.any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive-and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

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4. " Identify" with respect to any document means to state the following respecting the document:'

its title, its date, the author of the document, the person to whom the document was sent, all persons who received or reviewed the document, the substance _and nature of the document, and the present custodian of the document and of any and all copies of the document.

5. " Identify" with respect to any action or conduct means to state the following regarding any such action or conduct:

the person or persons proposing and taking such action; the date.such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or 4

proposed effect of such action; any document recording or documenting such action.

6. " Describe" with respect to any action or matter means to state the following regarding such action or matter: the substance or nature of such action or matter; the persons participating in or having knowledge of such action or matter; the current and past business positions and addresses of such persons; the existence and location of any and-all documents relating to such action or matter.

7. " Identify" with respect to an expert witness means to state:

(a) The name, mailing address, age and present professional or employment affiliation of the person; (b) The profession or occupation and field of claimed expertise of the. person;

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-(c) The hist'ory of formal education or training of the person, including, but not limited to, (i) the name and address of each school where the person received special education or training, (ii) the date those schools were attended, and (iii) a description of each degree earned, including the date and granting institution; (d) The history of specialized training in the area of claimed expertise, including, but not limited to, (i) the type of training received, (ii) the name and address of the institution providing this training, and (iii) the dates of such training; (e) A list of publications of any kind by the person in the area of claimed expertise, including, but not limited to, (i) the title and subject matter, (ii) the name and address of the puolisher, and (iii) the date of publication; (f) A list of any and all licenses in the area of claimed expertise, including, but not limited to, (i) the designation of the authority by which the license was issued, (ii) the date(s) of the licensing, (iii) the requirements for obtaining each license, and (iv) the manner by which these requirements were met; (g) The amount of time the person has worked in the field of claimed expertise, stating periods where work was other than on a full-time basis; (h) The name and address of every person, or every corporation or other institution, that has employed the person within the last ten years of employment:

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i' (i) All periods of claimed self-employment, including a-description of all duties and responsibilities thereof; (j) All previous experience in the field of claimed expertise which involved problems, analyses or studies similar to those concerning which the person is expected to testify in this proceeding; (k) All other litigation in which the person has been consulted, specifying those matters in which the person has testified, including the name of the case or matter and~the court or other forum in which testimony was given; and (1) Any other experience in the field of claimed expertise.

8. " Identify" with respect to a non-expert witness means to state:

(a) The name, mailing address, age and present professional or employment affiliation of the witness; (b) The profession or occupation of the witness; (c) The name of the supervisor and department of the witness; (d) The current employment or professional relationship, if any, between the witness and you; (e) The past employment or professional relationship between the witness and you, including the dates of that relationship; and (f) All litigation in which the person has testified on any matter in which you have had an interest, including the

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name of the case or matter.and the court or other forum in

-which testimony was given.

Wherever appearing in these interrogatories, the masculine form is defined to include the feminine and/or the neuter and the singular form is defined to include the plural wherever necessary to apply the context to any factual situation that may exist or to render the interrogatory more inclusive in scope.

Notice Regarding Supplementation Your attention is called to the provisions of 10 C.F.R.

S 2.740(e) regarding your obligation to supplement interrogatories and requests for the production of documents.

Request for the Production of Documents

. Pursuant to 10 C.F.R. S 2.741, you are hereby requested to produce, for inspection and copying, each document identified in response to these interrogatories and each document required to be identified in response to these interrogatories, at the offices of Attorney General James M. Shannon, Room 1902, one Ashburton Place, Boston, MA 02108 on March 19, 1987 at 10:00 o' clock a.m. Each document produced in response to this request should be labeled to indicate the interrogatory or interrogatories in response to which it is produced.

11 INTERROGATORIES

1. LDescribe in detail your position with respect to each contention to be litigated by the Attcrney General and each' subpart of each such contention. , Describe.in ' detail the reasons for your position.-

2. Identify and produce all documents on which you have relied,-do rely, or will rely to support your position on each of these contentions. Identify the information in each document on which you have relied, do rely, or will rely and

' the specific subpart of each contention which that information Concerns.

3. State whether you have relied, do rely, or will rely on any study, calculation, or analysis to support your position on each of these' contentions. If so, please:

a. Describe the nature of the study, calculation or analysis and identify any documents that discuss or describe the study, calculation or analysis;

b. Identify the persons who performed the study, calculation or analysis;

c. State when and where the study, calculation or analysis.

was performed;

.d. Describe in detail the information or data that was studied, calculated or analyzed;

e. Describe the results of the study, calculation or analysis;

f. Explain how such study, calculation, or analysis provides support for your position on each of these contentions.

4. Do you intend to offer the testimony of any expert witness with respect to any contention to be litigated by the

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LAttorneynGeneral?~ If so, please:.

1a.,l Identify each1 expert wit' ness'who.you inten'd to present with. respect to each.subp. art'of each such contention; i-

'b.. State'the substance of-thEJfacts to which each expert-  !

witness is expected.to. testify;-

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c. State the substancelof the opinion or. opinions to which each'~ expert witness is expected to testify;

d. Provide a-summary of the grounds for-each' opinion.to which each. expert-witness is expected.to testify;;

e. . State whether the_ facts _and opinions listed in response to the foregoing are contained in any document; ,

f '. State whether.the opinion of any expert witness.is

. ' based in whole-or in part on any scientific rule or principle, and, if so, set forth such rule or principle;;

l g. State whether the opinion of any expert witness .s i based in whole or in part on any code or regulation, governmental or otherwise, and, if so, identify;each 1 -such code or regulation.and the specific section or

[ portion thereof relied upon; and ,

h. State whether the opinion of any expert witness is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.

Do you intend to offer the testimony-of any non-expert-2

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witness with respect to any contention to be. litigated by the Attorney General? 'If so, please:

a. Identify each non-expert witness who you intend to present with respect to each subpart of each such

, contention;

b. State the substance of-the facts to which each non-expert witness is expected to testify; and

c. . State whether the facts listed in response to the foregoing are contained in any document, and produce the same, e-e.

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6. Identify and produce all documents in'which'you or any agent on your behalf have assessed the adequacy of state and local emergency plans with respect to any contention to be litigated by the Attorney General. Include in your response any documents concerning steps which have been taken or will be taken by the State of New Hampshire or the Applicants to address. inadequacies in any past or current local plans.

7. Are peak summer day evacuation time estimates for the populations within two miles, five miles and ten miles of the Seabrook plant' longer than the average two-mile, five-mile, and ten-mile EPZ evacuation time estimates for nuclear power plants in this country?

8. Please provide the names of all nuclear power plants that have longer evacuation time estimates for populations located within two miles, five miles and ten miles of those plants than does the Seabrook reactor. Include those respective time estimates for each plant.

.9. Is population density greater for the areas within two miles, five miles, and ten miles of the Seabrook plant than the average population densities for areas within two miles, five miles and ten miles of all other nuclear reactors in this country?

10. Please provide the names of all nuclear power plants in this country that have nigher population densities in the areas within two miles, five miles and ten miles of the plants than does the Seabrook reactor.

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11. : Is there a larger summer transient population within twomileE,five'milesortenmilesoftheSeabrookplantthan-

-there is within two miles, five miles, or-ten miles of all

12. please' identify all nuclear power plants in.this country tha't have a larger summer transient population than does~the Seabrook plant for the areas. located within two miles, five miles, or ten miles of the plant, and for-each of those reactors indicate what provisions, if any, have been made to shelter-the transient' population; where such population is situated with respect to that reactor; the average dose re' duction factor of shelters used for that population; evacuation time estimates for that population if it were to be evacuated; the location with respect to the transient population of any sheltering they will be expected to use;

, whether that population is predominantly a beach population; whether sufficient sheltering capacity exists to shelter the entire transient population; and if sufficient capacity does not exist to. enable the sheltering of-the entire population, state-for what percentage of the population sufficient sheltering capacity exists.

13. . Will emergency planning for the area within ten miles i

of the Seabrook plant effectuate less " dose reduction" than the average dose reduction for all other nuclear plants in this country, assuming comparable radiological releases in the event of an accident?

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14. Compare the average dose reduction expected to be effectuated for the summer transient beach population within ten miles of the Seabrook plant to the average dose reduction expected to be effectuated, for persons within ten miles of all other reactors in this country, assuming comparable radiological releases in the event of an accident.

15. Please. provide the basis for your response to interrogatories 13-14 and any documents relevant to your responses.

16. Do homes within the Seabrook ten-mile EPZ have on the average a lower dose reduction factor than do homes around all other nuclear reactors in this country.

17. Compare the average dose reduction factor of homes within the Seabrook ten-mile EPZ beach area to average dose reduction factors of homes around other reactors.

18. Please provide the basis for your responses to interrogatories 16-17 and any documents relevant to your response.

19. Describe in detail your relationship with KLD Associates and Edward B. Lieberman since January 1, 1985, i detailing the amounts, if any, you have paid to KLD Associates,

,. to Mr. Lieberman, and others, to conduct the evacuation time study contained in Volume 6 of the New Hampshire Radiological Emergency Response Plan (NHRERP) Revision 2. Produce all contracts and other documents which describe the relationship.

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20. Did you pay KLD associates, or~ Edward Lieberman, or any employee of KLD Associates any money after January 1, 1985, for any reason other than as payment for conducting the ETE study? If so, detail the amounts, to whom, and the reasons for these payments. Identify and produce all documents, including contracts, which relate to these payments.

21. State whether any employee or agent of yours communicated orally during the period from January 1, 1985, through September 1, 1986, with Edward B. Lieberman or any other officer, agent, employee or person acting or parporting to act on behalf of KLD Associates.

22. If you answer the previous interrogatory affirmatively, as to each communication:

a. state whether made in person or by telephone;

b. state the date and place;

c. state the content of the communication as disclosed in any corporate or internal record;

d. identify each person who participated in the communication or who had knowledge thereof;

e. identify and produce each document referring or relating to the subject matter of subparagraph (c) hereof.

23. Identify and produce each document passing between any employee or agent of yours and Edward B. Lieberman or any other officer, agent, employee or other person acting or purporting to act on behalf of KLD Associates during the period from January 1, 1985, to September 1, 1986, referring or relating in I

any way to' terms and conditions _of payment to Mr. Lieberman;or KLD Associates foriconducting an ETE study; instructions,

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guidance, criticisms, or suggestions to Mr. Lieberman or KLD

' Associates in conducting.an'ETE' study orfin drafting 7 Volume 6 ,

of the NHRERP-Revision 2;-data supplied to Mr. Lieberman or KLD.

Associates having anything to do with the ETE study; or inquiries or reports from Mr. Lieberman or.KLD Associates regarding any aspect of the ETE study.

24. Identify and produce each-document,'.not identified in response.to prior interrogatories, that evaluates or discusses the adequacy, reliability, or the sensitivity of KLD's ETE study or any aspect or subpart of this study.

2 5. . Do you support the KLD finding that, at mid-day;with good weather on a. summer weekend in 1987 when the beach area population is at its-highest expected levels, and assuming that the evacuation of the. beaches begins 20 minutes before a general order to evacuate the entire EPZ is given, the entire

~ population within the entire EPZ can in fact be evacuated within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 15 minutes after the general order to evacuate is given? If you do support this finding, state.all .

reasons why you believe this finding is accurate, identifying all'exper'ts, other persons, and documents upon which you rely.

If you do not agree with or support this KLD finding, state how long you contend such an evacuation would take, and identify ,

all experts, other persons, and documents upon which you rely.  ;

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26. How-long would an estimated evacuation time for the entire EPZ, in the manner assumed in the previous interrogatory, have to be before you would agree that adequate protective measures cannot be taken to protect the public health and safety? State your reasons in detail for this answer, and_ identify all experts, other persons, studies and documents upon which you rely.

27. Do you contend that the NHRERP- Revision 2, as drafted and dated August 1986, without further revision, meets-the standard contained in 10 C.F.R. SSO.47(a) that emergency' plans be adequate for the NRC to find "that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency"?

a. If your answer is "no", state what revisions in the plan are necessary to meet this standard and whether these revisions have been made.

b. State what responses you (i) have taken, and (ii) intend to take, prior to the off-site EP hearings to respond to the inadequacies identified in the FEMA /RAC Review of Revision 2 of the NHRERP.

28. Assuming an accident when beaches are at or near capacity and assuming implementation of Revision 2 of NHRERP, do you contend that KLD's ETE study demonstrates that evacuation times are short enough to prevent all fatalities among members of the beach population under all accident sequences? If not, state how many early fatalities would occur, and specify under which accident sequences these fatalities would occur.

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-, s 12 9 . Do you contend that the number of early fatalit;ies j

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likely_to be caused by a serious radiological emergency at the ~

Seabrook plant is not a relevant factor in determining whether iD there is-" reasonable assurance that adequate protective measures,can and will be taken-in'the event of a radiological

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emergency"?. Explain your answer. l If there is a limit to the number of likely early fatalities beyond which you would' agree that an. evacuation plan does not offer such " reasonable assurance," state that limit.

30. On what basis does KLD estimate (Vol. 6,;p. 2-27)~ or assume (Vol. 6. p. 10-3) that there will be 3000 vehiclee traveling through the EPZ when an Alert is anncun'ed? c Identify all experts, other. persons, and documents including aerial photos, upon which KLD relied in making this estimate o'r assumption.

31. In computing ETE's was the IDYNEV Systera programmed to assume that there were 3000 vehicles traveling through the EPZ at the time of an Alert? If so, describe in detail the i  ;

distribution of these vehicles inside the EPZ which the model was programmed to assume. -

32. Identify the aerial films mentioned on p.'1:0-16 of Volume 6-of NHRERP-Revision 2 by stating when they were taken, by whom, and who has this film. Produce this film.

33. Do you contend that the estimates of vehic}e demand

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displayed in Figures 2-4, 2-5, and 2-8 of Vo'lume 6 of Revision 2 of NHRERP, based on numbers estimated for the NRC by M.

Kaltman in 1981, are reliable?

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,y ** a. IEyouanswerintheaffirmative,stateyourreasons

, and identify any expert's, other persons, studies, or

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ofber; documents upon wnich your reasons are based.

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U b.' ;idsstify any.otherfenperts,. persons, studies, or other documents which contain information about vehicle demandiwhich differs.in any way from that contained in

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Figures 2-4, 2-5, and 3-8 of Volume 6 of NHRERP.

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,3k' ;7.Identi.fy'and produce all documents which indicate or

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x a projeut the population of the following groups inside the EPZ:

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'C, '(a) in~ the~, period 1985-86, Ab) in the t summer of 1987, (c) in s

the next five (5) years, or (d)' aver C,he expected operating life of the Seabrook plantf [

1. Permanent resi-Sqnt population

2. Employee population-

, s '. 3. Seasonal population 4'.7 Transient tourist population

5. Peakbeachgoingpopdlation

6. Trknsit dependent pollution p

'" 35. Identify and p':odrce any documents which calculate or

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p projecc when, as a result af pcpuln' cion growth, the ETE's 5 contained'i.n(Vo?ume6ofNH23RPmaybecomeunreliable.

36. For dach New Hampshire town which is not participating in evacuation planning, (1) state the name, city or town of a residence, name of employer, job title or position, and location et' usual work site for each ,t raf fic guide, bus driver, or other emergency worker the Stata of New Hampshire intends to mobilize to perform an emergency respanse function; (2) describe for each such person which traffic control post or F

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.other function,.each.said person has been assigned; and (3) list r.

e jtqp; 3I' 'for such person how:long it is estimated it'will take to travel E " ht to the assigned duty-post: (a) from said person's home and (b) from said person's usual work site.

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/ 37. LIn calculating that an Immediate General Emergency

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_oul w extend phejETE's by 20-30 minutes (see p. 10-16 of -

O' volbme6), how soon after the evacuation order is given did KLD .

assume that all: traffic management and control. measures would be in effect.- State you'r basis for this answer and. identify any documents and experts upon which you rely for yot.r answer.

38.- What is the basis for the assumption, noted on p. 10-3 of Volume 6 of NHRERP, that 25 percent of the population within

.the EPZ,'but outside the region ordered to evacuate, will j spontaneously evac,uate, contrary to instructions? Identify any

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' i' surveys, studies-or. experts upon which you rely in making this

-assumpt,i)on.

? 9 4 In calculating ETE's with the "25 percent" assumption  !

.noted above in Interrogatory 25, was it assumed that those who y would spontaneously evacuate would be randomly distributed m" - 'I through'out that portion of the EPZ not ordered to evacuate? If r +

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not, what distribution was assumed? In either event, state the

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basis for this assumption and identify any surveys, studies, -

'ib and experts upon which you rely for this assumption.

< 40. Have any studies or surveys been conducted since the nuclear reactor accident'at Chernobyl to see what effect this <

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Leventihas had on KLD's125% spontaneous evacuation assumption?

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_Iffso, identify any such studies o'r surveys.

41. LDidlthe-KLD' study contained in1 Volume.6 of Revision 2.

C .of-the NHRERP~-assume or take into account in any' manner that

-some portion of the population ~beyond the EPZ would also ispontaneously~ evacuate, taking up some roadway capacity beyond the EPZ and thereby impeding' evacuation progress out of_the EPZ? If so, describe how-this was'taken~into account.

Identify any studies or surveys, conducted both.before andi

- after Volume 6 was' published, which you have gathered on this topic..

42. In Volume 6~of the NHRERP-Revision 2, Appendices F and G areL not entirely legible. Produce a legible copy of each.

43. Describe.in detail the methodology for the telephone survey described in Appendices F and G-of. Volume 6 of Revision s

2 of NHRERP, including, inter alia s who conducted it, what the

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' instructions were to each telephone survey researcher, what was the. sample strategy used to select the numbers called, how many l- calls were made altogether to produce the 1300 responses included-in the tabulation (App. F), the schedule of actual phone calls attempted and phone calls completed by time of day and day of week, what methods were applied to ensure against

.having a non-response bias in the survey, and what validity and reliability tests were applied to assess the representativeness 4;c of the responses obtained. Also identify who has the actual i.

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.7 survey 1 data sheets. . 2 Produce all written descriptions ofLthe survey, the survey methodology, all' drafts'of-the survey instruments,. instructions given to.the; survey researchers,' all.

computerireadable data sheets produced by them, all. computer-print-outs,:all. documents. assessing, reviewing, validSting, or

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critiqueing the.results,-and:all. correspondence-regarding this

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telephone survey,. identifying each-correspondent. -

-44. :Have:you, KLD, or-anyone else conducted-any other

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telephone or in-person survey research or' poll.to assess, or re-assess,. trip generation-time or'any other aspect of the expected evacuation behavior of persons residing within the Seabrook EPZ? If so, please identify and produce all documentation relating to such surveys.

45. In conducting the ETE study,.did KLD assume that all community workers would return home in their normal time frames? State the basis for yourLanswer and identify any studies, experts, and other information upon which you rely for ,

your answer.

46. Do you agree that Basis 8 to SAPL's Revised Contention No. 31 contains an accurate statement of the number of traffic guides needed in New Hampshire for Traffic Control Posts and Access Control P? If not, state what you contend the accurate 4

numbers are, and identify the source or sources of your information.

47. List the names and home adiresses, employment I -

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' addresses, and. traffic control assignments of each of the New .

1 Hampshireftraffic control personnel.

1 4 8. - Identify and.producefcopies of all.the-instructional a

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' sheets, manuals, aor guides which have been: given to _these 'New Hampshire traffic ~ control' personnel.

149.- Does Revision 2 of the NHRERP reflect the specific

' assignment ofLthe: tow truck's recommended in Table 12-1 of Volume 6 of Revision 2 of the NHRERP?. If your answer is yes, state where-and how'these: ass'ignments are reflected, andLlist the name, home and business address, and specific location assignedifor.each tow truck driver.

50.- Have any surveys or other studies been conducted to assess the impact-of role conflict on those traffic control personnel,. bus and tow truck drivers, law enforcement'and other emergency' workers who have families residing within the EPZ?

.If so, identify and-produce said studies.

'51. Have any studies or surveys been conducted to assess any aspect ofEthe likely evacuation behavior of the beach-going L or other transient population inside'the EPZ? If so, identify and produce-said study.

L .52.. At page 11-18 of Volume 6 of Revision 2 of the NHRERP I

Hit is noted that a " telephone survey" of organizations which own.and operate buses was undertaken to obtain estimates of mobilization time.

f a. Produce a copy of the survey methodology and the

! survey instrument or form; L

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Jb. . 'If3none exist,[ describe'the methodology in detail,.

j specifying1the_ questions asked;-

c. Describelwhen'this. survey: occurred and_.who' conducted

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'd.- -Produce the survey ~ data collection: sheets. identifying; for'each the name and: address-of the company called;

e. Iflno survey data sheets exist, list'each. bus company'

, 1 called,1who was spoken.to, the questions' asked'and the.

responses.given;

_f. Describe.how, if-at all, the results of this telephone

- survey.were checked for reliability; L.

. g.- -Identify"and describe any follow-up studies that have been-or will be-done to re-assess or refine the

.,' Lestimates of bus mobilization time utilized'in Volume -

'6 of the NHRERP-Revision 2.

53. . Produce copies of all instructions and instructional.

Lmaterials which:will-be or have been provided to bus drivers (a) prior to.an accident'and'(b) at staging areas upon their arrival during an evacuation..

54. JWhat is the number of transit dependent persont in the EPZ which you contend should be utilized in calcula'.ing ETE's and the need for transit assistance vehicles. Describe in detail.(a) the.metholodogy'used to calculate this number, (b)

all-assumptions made in conducting this calculation and the

. reasons, documentation, studies, and experts supporting these f

. assumptions. Produce all documents and studies which you have

' relied on or have reviewed in calculating the number of transit h

dependent persons. ,

55. Produce each of the records, studies, photos, slides, reports, and other documents referenced in Appendix E of L Volume 6 of the NHRERP-Revision 2.

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56. Produce.all correspondence and documents passing between you and FEMA since your receipt of the FEMA /RAC Review-of'Seabrook Station Evacuation Time Estimates and Traffic Management Plan Update-contained in the State of New Hampshire-Radiological Emergency Response Plan (Rev. 2-8/86).

57. List and describe each and every change that you have made to Volume 6 of the NHRERP-Revision 2 since it was published.

58. List and' describe each and every step you or KLD have taken to address the issues ' raised in the FEMA /RAC Review of Volume 6 to the NHRERP-Revision 2.

59. Produce all-documents relating to the survey of all residents of New Hampshire conducted in June 1986 by the New Hampshire Civil Defense Agency and referenced on page 11-9 of

-Volume 6 of the NHRERP-Revision 2. This production should include the survey instrument, methodology, sample strategy, measures of its validity and reliability, data collection sheets, computer print-outs, and tabulations of results.

60. Produce the transcript of the audio cassettes made by KLD personnel as they drove the entire highway system within l

the EPZ and portions beyond, as referenced on p. 1-10 of Volume 6 of the NHRERP-Revision 2.

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61. Produce all additional information and studies which update or refine the highway characteristics documented in the l field survey described in the previous interrogatory.

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62. Please provide any other documents, including aerial photos, you~or KLD have reviewed regarding the size of the beach-population which were not listed in Appendix E of Volume 6 of.the NHRERP-Revision 2.

63. Do you admit that the NHRERP contains no contingencies which~ permit the redirection of evacuating vehicles'in response-to a change in plume direction? If your answer is negative, explain ~in-detail what these contingencies are and how they would be implemented. Identify any person, expert, and document upon which you rely for your answer.

64. Describe in detail what traffic guides have been instructed to do:

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a. when evacuating drivers seek to go in a direction described on the intersection sketches as " movement discouraged";

b. When evacuating drivers stop, thereby blocking a line of vehicles, to speak to the traffic guide for any reason (complain, ask directions, seek assistance, etc.);

c. when evacuating drivers stop to obey traffic lights and stop, signs;

d. when evacuating drivers seek to disobey traffic lights and stop signs;

e. When an accident or a breakdown occurs which blocks or impedes traffic through an intersection.

65. Will traffic control guides be stopping drivers to question and direct them to appropriate evacuation routes and host communities?

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66. Identify and produce-each and every document, including correspondence, which pertains, directly or-indirectly, to any contention to be litigated by the Attorney Genral and was exchanged between you and FEMA since your receipt offthe FEMA /RAC' Review of the NHRERP-Revision 2.

67.- Describe each change which has been or will be made to the NHRERP-Revision-2 since it was published and which pertains, directly or indirectly, to any contention to be litigated by the Attorney General. If said changes are noted in any documents, produce said documents.

68. Produce computer-readable listings of all input files and data necessary to reproduce: (a) the IDYNEV runs documented in Volume 6 of the NHRERP-Revision 2; and (b) any subsequent runs, conducted in response to the FEMA /RAC review of Revision 2 or for any other reason, relating to refining,

-correcting, supplementing, updating, testing, or revising the evacuation time estimates contained in Volume 6 of the NHRERP-Revision 2. Indicate whether the computer readable listings produced in response to (a) are identical to the data files currently stored at FEMA in Washington, D.C.

69. Produce paper copies of the IDYNEV outputs produced in the runs specified in the previous interrogatory.

70. Produce all empirical data, studies, or surveys used to support the snow clearance time estimates shown on page 4-20 of Volume 6 of the NHRERP-Revision 2. Indicate what personnel, by name, address, and employment position, will be used for

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. snow clearance and if NHRERP-Revision 2 depende upon the same personnel taa perform other emergency response tasks.

71. Describe in detail the telephone inquiries of hotel / motel managers referenced on page.6-1 of Volume 6 of the NHRERP-Revision 2, and produce copies of all related~ documents, including'those which contain the dates-calls were made, text of the questions asked, the tabulated responses, and the list of the hotels / motels called. If no documentation exists, state who was called, when calls were made, what questions were asked, and what response each call produced.

72. In computing evacuation time estimates, what, if any, data was included in the computation regarding estimates of the time required .to set out cones, signs, and barricades?

Indicate by name, address and employment position, the personnel designated to set out such cones, signs and barricades.

73. List the anticipated storage locations for cones, signs, and barricades.

74. Is it your position that sheltering will never be relied upon as a protective action for the summer transient beach population located within ten miles of the Seabrook L plant, or for any portion of that population?

75. If sheltering is to be relied upon as a protective response option only for a portion of the summer beach population, please identify that portion of the population, and the basis for any determination that sheltering should be a

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response option for that portion and not the remaining portion-of the. transient summer beach population.

76. Please provide any documents you have reviewed thatL are relevant to the conclusion (s), set forth in response to--

interrogatory 74-that sheltering will or will not ever be relied upon as a protective response for the transient summer beach population.

77. Please identify all documents you intend to rely upon to support your position that sheltering will or will not be used as a protective response for the transient summer beach population.

78. Unless your answer to interrogatory 74 is an unqualified yes, describe when and under what circumstances, including types of accident sequences and meteorological conditions, you anticipate that sheltering will be relied upon as a protective action for the summer transient beach population.

79. Please provide any plans you have relative to sheltering the transient suncer beach population, and indicate if, how, and when you intend to amend or add to those plans in any way.

80. If no plans for sheltering the transient summer beach population currently exist, please indicate if, when and how you intend to develop any plans for sheltering the transient summer beach population located within ten miles of the Seabrook plant.

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81. 'IfLthe transient summer beach population, or any portion-thereof, is instructed to shelter, how, by whom and on what basis will that decision to shelter the beach population be made? Please provide any documents on which you intend to rely in making that decision.

82. If the transient summer beach population, or any portion thereof, is instructed to evacuate,.how, by whom and on what basis will that decision to evacuate the beach population be made? Please provide any documents on which you intend.to rely in making that decision.

83. Please describe your methods for estimating radiation releases.

84. Please describe, and provide all documents pertaining to, all meteorological models to be used for projecting doses off-site.

.85. Please describe any provisions in the plans, or means available, to monitor during an emergency the public's compliance with the State's protective action instructions, including whether there is a capability and an intent to monitor during the course of an emergency in which the public is instructed to shelter the numbers of persons evacuating from the area.

86. Is it your position that sheltering should never be relied upon as a protective response action for the transient

! summer beach population located within ten miles of the j Seabrook plant, or for any portion of that population?

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87. Unless your answer tol interrogatory 86-is an zunqualified.yes,. describe under what. circumstances, and for

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L.what portion ofLthe population, sheltering should be used:as a ,

protective response.for the transient-summer beach population.

J 88. Please provide the basis for your' determination that Lsheltering should or should not ever be used:as a protective response option for all, or'any portion'of, the t'ransient summer beach population.

4 89. Please provide any documents you have reviewed that arefin any way relevant to the conclusion (s) set fort'h in

, response to interrogatory 86. ,

90.- Please identify all documents-you intend to1 rely upon f to support your position that sheltering should or should not ever be used as'a protective response option for each portion of the transient summer. beach population located within ten

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miles of the Seabrook plant.

91.- Is it your position that sheltering of the transient summer beach population is feasible at all beach areas located within ten-miles of the plant?

92. Please identify those beach areas within ten miles of the Seabrook plant for which sheltering of the transient

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population would not be a feasible response.

93. Please provide the basis for your determination that sheltering of the transient beach population , or a particular

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portion thereof, is or is not feasible.

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'9 4 . Please 4 provide any documents you have. reviewed-that'

are'in any.way relevant'to the conclusion (s) set forth in response

to interrogatory 90.

95. PleaseDidentify all' documents you intend to rely upon-tojsupport your_. position that sheltering of the_ transient-

summeribeach. population, or any portion-thereof, located within ten ~ miles-of the Seabrook plant is or is-not feasible.

- 96. .Is it your position that adequate physical facilities exist in all beach areas located within Seabrook's ten-mile EPZ to shelter the entire peak transient summer beach population?

97. Please provide the basis for your response to interrogatory 95 that adequate physical facilities do-or do not exist.

98. Please provide any documents you have reviewed that are in any way relevant to the conclusion (s) set forth in response to interrogatory 95.

99. Please identify all documents you intend to rely upon to support your position that adequate physical facilities do or do not exist to shelter the entire peak transient summer

j. beach population.

i 100. Please identify all facilities that could be used to l

shelter the transient summer beach population and provide the 3- dose reduction factor for each, identifying for each the basis l for your determination of the dose reduction factor and

i. providing all computations, materials, photographs, notes and i

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r. 5 other. materials relied upon or reviewed in determining the dose reduction-factor of each building or facility.

101. Is it your position that sheltering of the transient summer beach population located within ten miles of the Seabrook plant could never be an adequate protective response action for.that population,.or for any portion of that population, under any plausible accident scenario?

102. Please provide the basis for your response to interrogatory 101, and unless your answer to that interrogatory is an unqualified yes, state under what circumstances, including accident sequences and meteorological conditions, sheltering could provide an adequate protective response for the transient summer beach population, or any portion thereof, located within. ten miles of the Seabrook plant.

103. please provide any documents you have reviewed that are in any way relevant to the conclusions set forth in response to interrogaties 101 and 102, 104. Please identify all documents you intend to rely upon to support your position that sheltering of the transient summer beach population could or could not ever be an adequate protective response option for that population.

105. Is it your position with regard to the transient summer beach population, or for any portion of that population, that the protective response of sheltering could never achieve the same level of dose reduction as the protective response of evacuation?

106. Please provide the basis for your response to interrogatory 105.

107. Please provide any documents you have reviewed that are relevant to the conclusion (s)' set forth in response to interrogatory 105.

108. Please identify all documents you intend to rely upon to support your position set forth in response to interrogatory 105.

109. .Is it your position that with respect to the transient summer beach population the protective response of evacuation will in all cases provide an adequate level of protection?

110. Is it your position that for the transient summer beach population the protective response of evacuation will in all cases be an adequate protective measure?

111. please define your use of the terms " adequate" and

" adequate level of protection" with respect to your response to interrogatory 109 and define your use of the term " adequate protective measure" with respect to your response to interrogatory 1107 112. please provide the bases for your responses to interrogatories 109 and 110, including all documents you rely upon in support of those responses.

112a. If your answer to either interrogatory 109 or 110 is anything but an unqualified yes, please identify and describe

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i-those situations for which the protective response of evacuation will'not be " adequate" or achieve an'" adequate level of protection" and the manner.in which the response will not be adequate?

113. If.your answers to interrogatories 109.and 110 are anything but an unqualified yes, please describe what, if any, other or additional actions will be taken to protect the population in those situations where the protective response of evacuation is not deemed by you to be an adequate protective measure or expected to achieve an adequate level of protection?

114. Is it your position that with respect to the off-site population no early fatalities, defined herein as death ~from

. radiation exposure within thirty to sixty days, could result from an accident at Seabrook, and, if not, how many early fatalities might result in your view of a worst-case scenario?

115. please define " worst-case scenario" as used by you to respond to interrogatory 114.

116. please provide all data, charts, and statistics you have indicating types of accident sequences and scenarios (under varying meteorological conditions) that might result in fatalities to the off-site population within ten miles of the Seabrook plant, and the numbers of such possible fatalities.

117. please provide all documents you have reviewed indicating what effect, if any, the protective responses of sheltering and evacuation will have on the numbers of

3 fatalities or incidents of serious radiation illness that might I result from the accident sequences and scenarios identified in

. response to interrogatory 116.

118.- Please describe separately for the general population )

within ten miles of the Seabrook plant, for the permanent population within five miles of the' plant, for the permanent.

population within two miles of the plant, and for the transient summer beach population within ten, five, and two miles of the plant, under what-circumstances, and for what types of accident sequences and scenarios, and meteorological conditions, the protective response of sheltering will be prescribed.

119. please describe when, including under what types of accident sequences and scenarios and meteorological conditions, the protective response of sheltering would, if used instead of just evacuation for the transient summer beach population, result in lower radiation exposure to that population.

120. In determining whether to shelter or immediately evacuate persons in the beach area, including the permanent population and overnight visitors, what considerations, if any, will be given to meteorological conditions along the shore?

121. Please describe and identify what equipment or other means you have for plume tracking and for monitoring weather and wind conditions throughout the EPZ and specifically along the shore.

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s 122. If the protective-response of sheltering is ever to be used-for any portion of-the. transient summer beach ^

population, please describe, and provide any materials not included in the NHRERp relevant'to, how that population will be instructed to take shelter, the precise wording of'any instructions, and how, by whom, and where they will be directed to go?

123. If the protective response of sheltering were to be employed for the transient summer beach population, please provide any data you have, or otherwise your opinion, on how rapidly such sheltering could be effectuated?

124. In situations where the general population is directed to take shelter, precisely what instructions will be given to the, transient summer beach population, assuming the beaches have not already been closed?

125. In situations where the transient beach population, but not the general population, is directed to evacuate, precisely what instructions, if any, will be given to permanent residents and overnight visitors in the beach areas?

126. Is it your opinion i at the New Hampshire Radiological Emergency Response plan [NHRERp] provides in any manner for the possibility of an accident resulting in a large-scale early (within several hours) release of radiation?

If so, please identify those sections and pages of the plan which do so provide.

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127. In the event of an accident at the Seabrook plant

.that does-result in a large-scale early release of radiation on a peak summer weekend day, what protective response ~ actions will the following populations be instructed to take: (a)'the transient summer beach population;.(b) the non-transient beach population, including overnight visitors; and (c) the general population.

128. In'the event of an anticipated small-scale short release of radiation on a peak summer weekend day, what respective protective response actions will the tansient summer beach population, non-transient beach population and the general population be instructed to take assuming for each of these populations that the release will occur: (a) within thirty minutes of notification of off-site authorities; (b) within one hour; and (c) within two hours of notification of off-site authorities.

129. Is it your position that the transient beach population can in all cases be evacuated in time to avoid any radiation exposure to that population?

130. Please provide the basis for your response to interrogatory 129 and any documents relied upon to support that response.

131. Is it your position that the transient beach population can in all cases be evacuated in time to avoid the incurrence of radiation exposures in excess of 200 rem by the entire evacuating population?

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132. Please provide the basis for your response to

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interrogatory 131 and all documents you rely on to support that response.

133. Is it your position that in the event of a

- large-scale early release of radiation that for the transient summer beach population the protective response of evacuation

' will b'e an adequate protective response action?.

13 4 '. - Please provide the basis for your response to; interrogatory 133 and all documents you rely on to support that response.

135. In the event the transient summer beach population, or any portion therof,-is instructed to shelter, please

' describe:- (a) what provisions or plans, if any, have been made to evacuate such persons from those shelters, including the timing of such evacutions, and if the evacuation is to be staggered, how such persons will be instructed when to leave the shelters; (b) how the transient population will get to cars after sheltering,-or specifically what other transportation might be provided to evacuate this population and from where that transportation will be obtained; (c) any provisions for washing off or otherwise decontaminating the transient population and their cars; and (d) any special provisions or plans not already specified herein that take into account the possibility that the population could upon exit from the shelters be exposed to radiation, from ground deposition or an overhead plume, after exit from the shelters.

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136. Please identify and provide copies of all photographs, including-aerial-photographs, of the beach area within ten miles of the Seabrook plant that are in your possession or' that have been provided by you to, or used by, or

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.are in the possession of any entity, agency, person, firm, or business,' including KLD Associates, that has at any time been retained, contracted with, or paid for by you to perform any-activity relative to emergency planning.

137. Please identify, by indicating on maps or otherwise, each and every possible parking space in the beach area within ten miles of the Seabrook plant that KLD Associates identified or counted in determining the peak numbers of vehicles, or other figures relevant to the number of persons, in the EPZ beach areas.

138. Please identify and provide copies of all surveys performed by you or relied upon by you to identify, or calculate, or that is in any way relevant to a determination of, any population figure provided in the NHRERP, including Volume 6.

139. With respect to any surveys identified in interrogatory 138 please provide: all data generated by such surveys; all drafts of such surveys, including drafts of all proposed questions whether used or not used; and any notes, documents, data, memoranda, or correspondence that are in any way relevant to such surveys; and please identify: all

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methodologies employed; assumptions used; all persons or

. entities involved in performing or devising such surveys; and the names, addresses and phone numbers of all persons surveyed.

140. Please provide all documents, notos, calculations or other material that have been used by you in determining, or that are in any way relevant to, any of the population figures provided in the NHRERP, including population figures for the summer beach area population, and identify for each such e document provided the population figure to which it relates and the manner in which it relates to that population figure.

141. Please identify and provide all documents, notes, calculations, methodology, or other material used, looked at, or listened to by KLD Associates in determining any population figure or other population-related statistic, such as numbers

.of automobiles or buses, indicated in Volume 6 of the NHRERP, and identify for each document so provided the figure or statistic to which it relates and the manner in which it relates to that statistic.

142. Please produce all records of the on-site interviews with emergency planning personnel noted on page 1-2 of Volume 6 of the NHRERP-Revision 2 and state whether these are the same on-site interviews described on page 1-11 of this volume. If

' not, please produce records for these interviews as well.

143. Please produce the demographic data obtained from the State Planning Office noted on page 1-2 of Volume 6 of the NHRERP-Revision 2.

3 144. Please produce the survey instruments, methodology, data collected, and all documentation pertaining to the field surveys at the beach areas described in the last paragraph of page 1-10 of Volume 6 of NHRERP-Revision 2.

145. In the last full paragraph at the bottom of page 1-11 of Volume 6, it is noted that "(d]emographic data was obtained from several sources." Please list these sources and produce the date obtained from each.

146. On Exhibit 2-1 on page 2-5 of Volume 6 of the NHRERP-Revision 2, where did tne numbers 0.87, 0.98, 0.86, 0.78 come from and identify the assumptions, experts, studies, or other sources upon which they are based.

147. To clarify the " Note" to Table 2-1 on page 2-9 of Volume 6, state whether the state data used was for the two years 1980 and 1985 or the six years 1980 through 1985.

148. Explain why, as stated on page 2-24 of Volume 6, "it is not reasonable to assume that all lots servicing retail establishments are filled to capacity on a day when the weather attracts people to the beach area." Identify any data, assumptions, experts, or other sources on which you rely.

149. Assuming that Seabrook Unit 1 is licensed and becomes operational: (a) how many employees will work there and (b) how many tourists, including school children, are expected to visit the plant on an average weekday during the school year?

I, 150. In the " Note" at the bottom of pages 4-9 of Volume 6, describe what is meant by the term " normalized" and explain how the " don't know" responses were distributed?.

151. Please produce all the source materials relied upon to produce Tables 5-1 and 5-2 of Volume 6 and describe the methodology employed and all assumptions used for projecting 1986 employment data in Table 5-1.

152. Describe the basis for making the three assumptions about weekend employment made on the bottom half of page 5-6 of Volume 6.

JAMES M. SHANNON ATTORNEY GENERAL

('a.u A b !) u ,t* 3 Donald S. Bronstein Carol S. Sneider Assistant Attorneys General Environmental Protection Division One Ashburton Place, Rm. 1902 Boston, Massachusetts 02108 617-727-2265 Date: March 5, 1987

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DOCKETED UNITED STATES OF AMERICA UWE NUCLEAR REGULATORY COMMISSION 17 M@t -6 P3 d3

) E Of SEut.TARY In the Matter of ' g ETg }E8vlCf; PUBLIC SERVICE COMPANY OF NEW ) Docket No.(s) 50-443/444-OL' HAMPSHIRE, ET AL. )

(Seabrook Station, Units 1 and 2) )

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)

CERTIFICATE OF SERVICE I, Donald S. Bronstein, hereby certify that on March 5, 1987 I made service of the within documents, 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

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• 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 Funator Gordon J. Humphrey Mr. Angelo Machiros, Chairman U.S. Senate Board of Selectmen Wasnington, 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 Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amesbury, MA 01913

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~Brentwood Board,of Selectmen Gary W.-Holmes, Esq.

RFD Dalton Road. Holmes & Ellis Brentwood,.NE 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. <

Rampe & McNicholas y Ropes & Gray' 35 Pleasant Street '

225 Franklin Street Concord,, NH 03301 Boston, MA 02110 ^

Beverly Hollingworth

• Edward A. Thomas U . . ,

209 Winnacunnet Road Federal Emergency., Management Hampton, NH 03842 Agency 442 J.W. McCormack (POCU)

Boston, MA 02109 William Armstrong Michsel Santosuosso, dhairman 3 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 Darham, 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 Commisnion '

Exeter, NH 03833 Washington, DC 20555 Dr. Emmeth A. Luebke, Jr. Charles P. Graham, Esc.

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 Bothesda, MD 20814 Bethesda, MD 20814 1

Judith H. Mizner, Esq.

Silvergate, Gertner, Baker, Fine, Good & Mizner 88 Broad Street Boston, MA 02110 r

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~ Rep.EEdwar'd J. Markey, Chairman

.U.8. Hous( of' Representatives 3'abcommisc*e on Energy Conservicion and Power ,

Room H2-316 House Office Building '

Annex No. 2-Washington,.DC 20515 Attn: Lindt Correia s '

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- Donald S. Bronstein.

l$' ' Assistant Attorney General

,', Environmental Protection Division

. Dated: March 5, 1987 H -

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