ML20215M019

From kanterella
Jump to navigation Jump to search
Applicant Supplemental Responses to Intervenor Interrogatories.* State of Nh Radiological Emergency Response Plan & Chapter 15 of FSAR Basis of Applicant Response to Interrogatory 131.W/Certificate of Svc
ML20215M019
Person / Time
Site: Seabrook  
Issue date: 05/07/1987
From: George Thomas
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
MASSACHUSETTS, COMMONWEALTH OF
References
CON-#287-3403 OL, NUDOCS 8705130061
Download: ML20215M019 (6)


Text

.

- 3fbb i

DOCKETED USNFC Dated:

May 7,

1986

'87 MY 11 PS :15 UNITED STATES OF. AMERICA 0FFICE r ?E Tes y NUCLEAR REGULATORY COMMISSION 00CKEimG".9 v:!1 BRAID:

before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of

)

)

PUBLIC SERVICE. COMPANY OF

)

Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.

)

50-444-OL

)

Off-site Emergency (Seabrook Station, Units 1 and.

)

Planning Issues

)

)

APPLICANTS' SUPPLEMENTAL RESPONSES TO INTERVENOR INTERROGATORIES MASSACHUSETTS ATTORNEY GENERAL INTERROGATORIES INTERROGATORY NO. 28 (giving effect to the Licensing Board's Memorandum and Order, April 7, 1987 at p.

6) i l'

Q:

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 l

that evacuation times are short enough to prevent all fatalities among members of the beach population under all accident sequences?

R:

The ETE is a decision tool to be used in determining the most effective public protective mee.sure and as such I

does not consider doses to the public.

8705130061 870507 PDR ADOCK 05000443 G

PDR

)

m 9

s.

~

INTERROGATORY NO. 116 Q:

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.

R:

Applicants have ru) data, charts or statistics-for-the category suggested in Interrogatory No. 116.

Data, charts and statistics which Applicants have relating to accident sequences and scenarios (under-' varying.

meteorological conditions) were developed.in connection with Applicants' application for an operating license.

These materials are presented in Chapter 15 of the i

. Applicants' Final Safety Analysis Report which has been served on the parties.-

INTERROGATORY NO. 117-Q: -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 fatalities or incidents of serious radiation illness l-that might result from the accident sequences and scenarios identified in response to interrogatory 116.

R:

See answer to Interrogatory 116.

INTERROGATORY NO. 131 Q:

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 that entire population?

'R:

Applicants have no "in all cases" studies on.which to base positions.

Applicants are of the position that transient beach population can be evacuated so as to avoid radiation exposures in excess of 200 rem in any transient beachers for any design bases accident or other accident that has been analyzed in their application for an operating license and reported on in Chapter 15 of Applicants' Final Safety Analysis Report.

INTERROGATORY NO. 132 Q:

Please provide the basis for your response to interrogatory 131 and all documents you rely on to support that response. - -., - - -, -. - - - - - -.. _ -..

4 R: The basis of Applicants' response to Interrogatory 131 is NHRERP and Chapter 15 of Applicants' FSAR X

/

Geor'ge S.' Thomas Vice President, Nuclear Production New Hampshire Yankee Division of Public Service Company of New Hampshire May 7, 1987 State of Maryland Montgomery County Then appeared before me and the above subscribed George S. Thomas and made oath that he is the Vice President, Nuclear Production of New Hampshire Yankee Division, authorized to execute the foregoing supplemental responses to interrogatories on behalf of the Applicants, that he made inquiry and believes that the foregoing answers accurately set forth such information as is available to the Applicants.

.A, Sefore me, i

f\\

D

55. A U'({ ; e I. I..!!. i r, _

%/

( A IU C1/J i. f.6 /d.'-. / G ! L~ 1. L!/C.9

/ q h/. 3 /, / '/ '?."

7 l

My Commission Expires:

00LKETEF r

UMIRC CERTIFICATE OF SERVICE-I, Kathryn A. Selleck, one of the attorneys foh7 ygY 11 PS:16 t

Applicants herein, hereby certify that on May 7, 1987, I made; service of the.within document by depositing dropiesie..a

.r thereof'with Federal Express, prepaid, for deliverj00t!6Tf

!. Wit f.

whereindicated,by.depositingintheUnitedStatesmai[g,}-

l, first classLpostage paid, addressed'to):

Administrative Judge Helen Hoyt, Robert Carrigg, Chairman-Chairperson, Atomic Safety and Board of Selectmen Licensing Board Panel Town. Office U.S. Nuclear Regulatory.

Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway l

Bethesda, MD -20814 Judge Gustave A.

Linenberger-Diane Curran, Esquire Atomic Safety and Licensing Andrea C.

Ferster, Esquire

-Board' Panel Harmon & Weiss U.S. Nuclear Regulatory Suite 430 Commission ~

2001 S Street, N.W.

East West Towers Building Washington, DC 20009 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney. General Board Panel.

George Dana Bisbee U.S. Nuclear Regulatory-Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814

  • Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814
  • Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel 116 Lowell Street U.S. Nuclear Regulatory P.O.

Box 516 Commission Manchester, NH 03105 Washington, DC 20555 s

A Philip Ahrens, Esquire Mr.

J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S.

Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

  • Senator Gordon J. Humphrey Mr. Angie Machiros U.S.

Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn:

Tom Burack)

Town of Newbury Newbury, MA 01950

  • Senator Gordon J. Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn:

Herb Boynton)

Newburyport, MA 01950 Mr. Thomas F.

Powers, III Mr. William S.

Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.

Washington, DC 20472 Gary W.

Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 _

4 n

Mr. Ed Thomas Judith H. Mizner, Esquire

-FEMA, Region I Silverglate, Gertner,. Baker, 442 John W. McCormack Post Fine, Good & Mizner Office and Court House 88 Broad Street Post Office Square

-Boston, MA 02110 Boston, MA 02109 Charles P. Graham, Esquire McKay, Murphy and Graham 100 Main Street Amesbury, MA 01913 Kaitth2/yn A. Selleck

(*=0rdinary U.S. First Class Mail.)

0 l

4 f

I,

i

-.. _..