ML20235K867
| ML20235K867 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/29/1987 |
| From: | Sneider C NEW HAMPSHIRE, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#487-4527 OL, NUDOCS 8710050259 | |
| Download: ML20235K867 (45) | |
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18CKETEE U5NRC UNITED STATES OF AMERICA hM' g
NUCLEAR REGULATORY COMMISSION 5
NANUI Before Administrative Judges:
Ivan Smith, Chairman Gustave A. Linenberger, Jr.
Dr. Jerry Harbour l
)
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF NEW
)
Docket Nos.
.)
50-443-444-OL (Seabrook Station, Units 1 and 2)
)
(Off-site EP)
)
September 29, 1987
)
MOTION OF ATTORNEY GENERAL JAMES M.
SHANNON, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION
. LEAGUE AND TOWN OF HAMPTON TO POSTPONE HEARING ON SHELTERING CONTENTIONS OR, IN THE ALTERNATIVE, TO STRIKE APPLICANTS' TESTIMONY ON SHELTERING THE BEACH POPULATION Attorney General James M. Shannon and Interveners New England Coalition on Nuclear Pollution [NECNP), Seacoast Anti-Pollution League [SAPL] and Town of Hampton [ToH]
l
[ hereinafter "the interveners"] hereby move the Licensing Board to postpone hearings on all sheltering contentions (Contentions ToH VIII, SAPL-16 and NECNP RERP-8) until such time as interveners have had a sufficient opportunity:
(1) to review the surprise proposed. change to the NHRERP, announced for the first time in the applicants' testimony (No. 6), to utilize sheltering as a protective response option for the summer beach l
A K
N Q
g.
d population; (2) to file new or amended sheltering contentions; and (3) to conduct all appropriate discovery.
Moreover, before the hearings on sheltering contentions begin, FEMA should have an opportunity to review the proposed sheltering amendments, formulate a position as to the adequacy of the new plan and communicate its position to the other parties.1/
In the alternative, the Attorney General and the interveners move to strike all testimony filed by the applicants that references these proposed amendments to the NHRERP concerning sheltering of the summer beach population.
As grounds for this motion the Attorney General and interveners state as follows:
1.
Applicants' testimony on sheltering contentions proposes fundamental, substantive changes to the NHRERP.
Applicants' testimony on sheltering contentions, filed September 14, 1987, proposed for the first time in this proceeding that plans be incorporated into the NHRERP to shelter the large transient summer beach population.
The 1/
To the extent that the Board has already ruled during the j
telephonic pre-trial conference on September 17 that this issue q
will not be decided until motions to strike are filed at the hearing, the Attorney General and interveners respectfully request that the Board reconsider its earlier ruling on this issue in light of the comprehensive nature of the proposed changes to the NHRERP at issue here and the fact that these proposed changes have indeed taken interveners by surprise, as set forth more fully in the body of this motion.
The motion previously filed by the Attorney General and the interveners l
was never intended to address the merits of this issue, but only raised it as one of the bases for requesting a pre-hearing conference.
The Attorney General and interveners fully intended, had their iotion for a pre-hearing been granted, to submit at the time of such hearing a written fully-supported motion on the merits.
1
! I L--__----_-----_--
.c.
NHRERP currently provides that, " sheltering may not be considered a feasible protective action on seacoast beaches during the summer [May 15th-September 15t h ]. "
NHRERP, Rev.
2, Vol.
1, at 2.6-7.
Although applicants have claimed in a self-serving response to discovery that the NHRERP does not
" preclude" sheltering of the beach population, the NHRERP in fact contains ao actual plans to shelter that large transient population.
It provides no decision-making criteria for recommending sheltering of the beach population (see, e.g.,
NHRERP, Vol.
1, Figure 2.6-6, at 2.6-25); no emergency broadcast messages that recommend sheltering of the beach population (see Vol.
4, App. G); and no indication of where in the beach area the many thousands of beachgoers could be expected to shelter.
In sum, as the State of New Hampshire has stated in response to interrogatories, "The RERP provides that the transient population, which includes the transient beach population, should, when sheltering is recommended, leave the EPZ."
The State of New Hampshire's Responses to Attorney General James M.
Shannon's Off-Site EP
)
J Interrogatories and Request for Documents to the State of New Hampshire (Set No. 1), dated March 18, 1987, Response to i
Interrogatory No. 75, at p.
32.
(Copies of the relevant responses are attached.)
Applicants' testimony now proposes to fundamentally amend i
the NHRERP to provide for sheltering the entire beach population of Hampton and Seabrook beaches (there are still no -_
proposed plans for sheltering the transient beach population of Rye and North Hampton).
The specific amendments to the RERP that are expressly proposed in the testimony include the following:
(a) a " clarification" that sheltering of the beach population is not proscribed, Applicants' Direct Testimony No. 6 [ hereinafter " App. Test'y No.
6"), at p.
3; (b) emergency broadcast messages that instruct the beach population to shelter, id. at 23; and (c) pre-recorded beach closing messages to be broadcast over the beach public address system, id.
Further amendments, although not as yet provided, presumably would, at a minimum, include:
decision-making criteria for recommending sheltering to the summer beach population; a list of buildings where the beach population may shelter and a map designating their location; new public information signs (and literature) in the beach areas; and designation of emergency personnel (with training procedures) to assist the beach population to shelter.
In any licensing proceeding, the above changes to a RERP would be deemed significant.
In the instant proceeding, the
]
changes fundamentally affect the most critical issue in the case--the ability to protect the large transient beach population, which makes the beach area, which is only 1.6 miles from the plant, in the words of the Appeal Board "at times the j
l most densely populated area in the State."
Public Service j
i Company of New Hamoshire (Seabrook Station, Units 1 and 2),
j ALAB-422, 6 NRC 33, 51 (1977).Indeed, it is the very lack of a l
4-
sheltering response for the beach population which has led FEMA i
to testify, after several years of in-depth review of this l
issue of protecting the beach population, that:
l even if all the other inadequacies and deficiencies cited in the RAC Reviews of the New Hampshire Plans, and the Review of the Exercise of these plans were to be corrected, FEMA would not be able to conclude that the New Hampshire State and local plans to protect the public in the event of an accident at the Seabrook Nuclear l
Power Plant are adequate to' meet our. regulatory l
standard that such plans ' adequately protect the public health and safety by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiological emergency.' (See 44 CFR 350.5(b)).
FEMA Pre-Filed Testimony, dated September 11, 1987, Exhibit A at p.
39.
2.
Applicants' proposed amendments to the RERP were not previously disclosed to the parties and therefore constitute unfair " surprise."
The first time applicants ever disclosed to the parties that they would amend the NHRERP so as to provide a plan for sheltering the beach population was in their testimony filed on September 14, 1987.
Neither the applicants nor the State of New Hampshire ever previously disclosed these proposed changes despite extensivo interrogatories from the Attorney General and interveners requesting notice of all proposed amendments to the RERP and specifically requesting notice of any amendments that concerned sheltering the transient summer beach population.
- See, e.g.,
Responses of the Applicants and the State of New Hampshire, dated March 18, 1987, to Attorney
o
_ General James M.
Shannon's Off-Site EP Interrogatories (Set No. 1) Nos.
6, 27, 67, 79, and 80; Responses of the Applicants and the State of New Hampshire, dated June 4, 1987, to Attorney General James M.
Shannon's Off-Site EP Interrogatories (Set No.
- 2) No. 23.
Indeed, the State of New Hampshire in its response to the Attorney General's specific request concerning its intention to amend plans to shelter the transient summer beach population stated:
"The state has no intention, at this time, to amend or add to those plans."
State of New Hampshire Response to Attorney General's Interrogatory No. 79, dated March 18, 1987 At no time did the applicants or the State ever provide any supplemental responses to interrogatories that
~
would indicate that the State's March 18 response was no longer accurate.
The applicants' responses to the Attorney General's motions for summary disposition on sheltering contentions did indicate the applicants position that the NHRERP did not totally
" preclude" the option of sheltering the beach population.
The applicants also filed, in response to discovery, a March, 1986, Stone & Webster Engineering Corporation Study that identified potential sheltering space in the beact area.
However, it was clear that no actual " plans" to implement a sheltering response was, or would be, included in the RERP and that if a sheltering response was ever to be implemented for the beach population it would only be done on an ad hoc basis.
- See, e.g.,
Affidavit of 6-1
4 Richard H. Strome (Director of New Hampshire Civil Defense Agency) on Sheltering, dated March 25, 1987, at t 11 ("Although evacuation of the beach areas is the preferred protective action during the limited times when beach areas can be expected to have high seasonal population (and is, in fact, the protective measure for which specific plans have been developed), sheltering is not precluded.") (emphasis added).
In fact, in response to interrogatories specifically requesting the manner in which the beach population might be instructed to chelter, and the precise wording of any such instructions, both the applicants and the State responded by referring only to current sections of the NHRERP that provide no instructions or messages for sheltering the summer beach population.
The applicants expressly noted, "there are no other materials."
See Applicants' and State of New Hampshire's Response, dated March 18, 1987, to Mass Attorney General Interrogatory No. 122 (Set No. 1); see also State of New Hampshire's Response to Interrogatory No. 124 (Set No. 1), specifically noting that "the transient beach population will have been directed to leave the beaches before shelter directives are issued to the general public."
No supplemental responses with respect to instructing the beach population to shelter have ever been provided.
The Attorney General and interveners relied on the applicants and State of New HEmpshire's responses to l
interrogatories, as well as the actual provisions in the NHRERP L
regarding the transient beach population, in preparing their testimony on sheltering contentions.
It would be fundamentally unfair to allow the applicants to make such significant changes to the RERP now, through testimony, when applicants' responses to the numerous interrogatories which preceded the testimony indicated that no such changes would be forthcoming.
Moreover, even with respect to the shelter study previously served on the parties, applicants unfairly surprised the other parties when they served them with a revised shelter study without accompanying explanation less than a week before the testimony was due.
There was certainly no opportunity within this time frame to provide our expert witnesses with a copy of the new study, to provide any sort of in-depth evaluation of the study, or to address the new study in any manner in the testimony that was filed.
Now that the parties have had an opportunity to begin to review that new shelter study, it is clear that it is not a mere " updating" of the study previously disclosed.
The first Stone & Webster study, provided to the parties last May, stated that its identification of buildings suitable for sheltering was based on a review of all potential sheltering space in the beach area.
Now, the amount of available space has been multiplied by nearly a factor of five, because the study's definition of " sheltering space" has been substantially amended, indeed reversed, to include classes of wood framed buildings previously excluded by the applicants as unsuitable.
8-
3.
To force litigation of the sheltering issues at this time without granting the relief souaht by interveners would deny the interveners their due process rights.
Applicants' testimony promises amendments to the RERP that are significant in effect, i.e. a plan to shelter the beach population where previously there was none.
However, the actual proposed amendments are so lacking in substance that they preclude any meaningful litigation at this time.
- See, e.g.,
Cincinnati Gas
& Electric Company (Wm. H.
Zimmer Nuclear Power Station, Unit No. 1), ALAB-727, 17 NRC 760, 772-75 (1983) (Hearings should not be held until "such time as the plans are sufficiently developed to support a conclusion that the state of emergency
' preparedness provide reasonable assurance that adequate protective measures can and will be taken for the
. population in the event of a radiological energency.")
Applicants' testimony regarding a " plan" to shelter the peach population is so skeletal it does not even begin to demonstrate that such a plan could actually be implemented:
there are no agreements with any of the owners of the buildings in which the Applicants propose to shelter the beach population to allow their use as shelters; there are no decision-making criteria for recommending shelter to the beach population that would take into account a number of factors unique to that population; there are no plans for instructing this transient population to leave the shelters, and the manner in which this 1. _ _ _ _ _ _ _ _
e evacuation from the shelters might be accomplished; there are no personnel specifically designated to assist people in locating shelters-(other than a vague reference to " lifeguards, park managers and other available personnel," App. Test'y No. 6 at 19) or training procedures for such personnel; there are no signs indicating to the beach population the location of shelters and what buildings may be used as shelters.
- Instead, the testimony blithely provides that in implementating sheltering of the summer beach population, "New Hampshire decision-makers will rely on the mechanisms now in place, or to be put in place, in the NHRERP for recommending shelter to the public whether on the beach or any place else."
App. Test'y No. 6 at 23 (emphasis added).
This degree of detail is clearly insufficient to allow for any meaningful litigation over the adequacy of these " plans."
The Attorney General and interveners can only speculate as to what the eventual plan for sheltering will be.
If the plan were to be litigated in its present incomplete form, and no further right to litigate was afforded the interveners, the result would be a procedural violation of the Atomic Energy Act, 42 U.S.C.
S 2239, as amended.
Although not all matters need to be resolved before or at the time of hearings on the adequacy of an emergency response plan, "an intervenor must have the opportunity to litigate the substantive question whether there is reasonable assurance that
t e
adequate protective measures can and will be taken".
Southern California Edison Company (San Onofre Nuclear Generating Station), ALAB-717, 17 NRC 346, 380 n.57 (1983) (citations omitted).
The proposed sheltering amendments and supplements to the NHRERP are fundamental and essential components of the plan and as such trigger these statutory hearing rights. Only minor matters such that "on-the-record procedures, including cross-examination, would be unlikely to affect the result,"
id., may be resolved after the hearings have concluded and without the participation of the interveners.
The previous paragraph makes clear that there are certainly more than minor matters left to be filled,into applicants' proposed sheltering
" plan."
Moreover, considering the critical nature of the sheltering issue, from a procedural perspective the changes in the NHRERP proposed now by the applicants are as significant as those made earlier and discussed by the Appeal Board in its ooinion dated liay 1, 1987.
Public Service Co. of New Hampshire (Seabrook Station, Units 1 and 2), ALAB 864, __NRC __ (1987).
The second revision of the NHRERP submitted on September 8, 1986, contained changes to the underlying plan "in such areas as public alerting methods; evacuation and sheltering criteria and procedures; allocation of responsibilities between state and local police authorities; and trar ortation requirements" Id.
at 9, n.21. In light of tnese changes, the appeals panel found _ - _ _ _ _ _ _ _ _ _ _ _ _ _
that the schedule ordered by this licensing board denied the due process rights of the interveners.
Here, significant and parallel changes made by the Applicant should at a procedural minimum trigger the interveners' rights to file contentions and conduct appropriate discovery.
If a compressed discovery and hearing schedule violates due process then certainly a denial of the basic opportunity to investigate and challenge the basis for the applicants' new revisions in the NHRERP or to even be fully informed as to what they are'also violate due process.
In addition, in light of the fundamental nature of these proposed changes to the RERP, and FEMA's current position that the NHRERP is not adequate to protect the summer beach population, before the parties are required to file any testimony on the proposed sheltering amendments, FEMA should be provided an opportunity to review this new plan, to formulate a position on this critical issue and to communicate that position to the parties.
See ALAB-864, supra at 21, t2 requiring modification of hearing schedule to allow the parties 30 days after a full statement of FEMA's position on the contentions become available to the parties for the filing of pre-filed testimony.
See also, Cincinatti Gas & Electric, supra, 17 NRC at 775 (Although hearing need not await final PEMA findings, Board should consider views of FEMA in determining whether plans are sufficiently developed for hearing, that is, whether plans are "sufficiently developed to -- -____-__________--__ _ -
e support a conclusion that the State of emergoney preparedness provides reasonable assurance that adequate protective measures can and will be taken
")
In the instant case, FEMA has yet to find the NHRERP's plans for the summer beach population suffi:lently developed to support a " reasonable assurance finding."
See FEMA testimony, Exhibit A at pp. 38-39.
The applicants' last minute submission of an incomplete " plan" to shelter the beach population, without any prior disclosure of such plan or any submission of the plan to FEMA (not even the earlier shelter study was submitted), must be seen as nothing more than a thinly veiled attempt to circumvent PEMA's finding that these plans are inadequate (and the rebuttable presumption attached thereto) and any further FEMA review.
Due process and NRC regulations require, however, that FEMA be provided an opportunity to review taese plans and to report its position to the parties prior to the submission of any testimony on such plans.
Conclusion The Attorney General and interveners do not make this motion for delay's sake.
At the eleventh hour, the applicants have elected to fundamentally change the plan on which these hearings focus.
Any delay will be due to the applicants' own actions.
The public health and safety questions that are before the Board are simply too important to be litigated by surprise.
It is in the public interest that the issuu of sheltering be fully and fairly presented.
Wherefore, for all of the above reasons, the motion of the Attorney General and interveners should be granted.
Respectfully submitted, James M.
Shannon Attorney General h
By:
Frank W.
Ostrander Carol S.
$neider John Traficonte Allan R.
Fierce Assistant Attorneys General Nuclear Safety Unit Department of the Attorney General Boston, MA 02108-1698 (617) 727-5575 Dated:
September 29, 1937
\\
j i
l STATE OF NEW iiAMPCHIRE'S RECPONSE3 FO MASS AG INTERROGATOR: LEG (CET NO. t)
NOS.
6, D'7, 67, 7C, 79, 00,
.l P P,
1DA AND (GF.T NO, 2) NO., DJ
(
1
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I l
[
/
, c.
)
March 18, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Nuclear Regulatory Commission
)
In the Matter of
)
Docket Nos. 50-443-OL
)
and PUBLIC SERVICE COMPANY OF
)
50-444-OL NEW HAMPSHIRE
)
(Off-Site Emergency (Seabrook Station, Units 1 and 2
)
Planning Issues)
)
THE STATE OF NEW HAMPSHIRE'S RESPONSES TO ATTORNEY GENERAL JAMES M.
SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR DOCUMENTS TO THE STATE OF NEW HAMPSHIRE INTERROGATORIES 1.
Describe in detail your position with respect to each contention to be litigated by the Attorney 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 ycu 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, calculaton, or analysis to support your position on each of these contentions.
If so, please:
Describe the nature of the study, calculaton or analysis a.
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; i
d.
Describe in detail the information or data that was studied, calculated or analyzed; 4
3-5.
Do you intend to offer the testimony of any non-expert witness with respect to any contention to be litigated by the Attorney General?
If so, please:
Identify each non-expert witness who you intend to present a.
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.
Response to Interrogatory Nos. 1-5 See State's response to NECNp's Interrogatories 2-6, filed on this date.
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 Attorhty 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.
Response
The State has commissioned no such document.
See the State's response to the Town of Hampton's Interrogatories 9-10, filed on this date, relative to the RAC reviews.
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?
1 8
Please provide the names of all nuclear power plants that have longer evacuation time estimates for populations located within two f
miles, five miles and ten miles of those plants than does the
]
Seabrook reactor.
Include those respective time estimates for each j
l plant.
J l
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 ren miles of all other nuclear reactors in tnis country?
l u_____________
L 10 -
Resoonse The State of New Hampshire objects to this interrogatory on :ne grounds of relevance, inasmuch as there are no NRC guidelines on acceptable aosolute evacuation times.
Without waiving this ob]ection, the State responds as follows:
The State has not devoted any time or resources to this question, and has, therefore, not developed a position on it.
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. 50.47(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 p1&n 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 tne inadequacies identified in the FEMA /RAC Review of Revision 2 of the NHRERP.
. 11 -
Response
Yes, it is the State's positlan that NHRERP Rev.
2, when implemented, meets the standards for a " reasonable assurance" finding.
The State is in the process of compiling responses to the RAC Review of Rev.
2.
These responses, which will include commitments to continue the implementation of New Hampshire's emergency planning, will probably be assemoled and subiaitted to FEMA in April 1987, 28.
Assuming an accident when beaches are at or near capacity and i
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.
29.
Do you contend that the number of early fatalities likely to be caused by a serious radiological emergency at the Seabrook plant is not a relevant factor in determing whether there is " reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency"?
Explain your answer.
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.
Resoonse to Interrogatory Nos. 28-29 The State of New Hampshire objects to these interrogatories on the grounds of vagueness and overbreadth.
Without waiving this objection, the State responds as follows:
The State of New Hampshire has no data on fatalities that might result among any populations after an accident at Seabrook Station.
The State cannot state wnetner the KLD's ETE study demonstrates, or does not demonstrate, tnat evacuation times are short enough to prevent any fatality ancer any accident sequence.
1
_ c.
Rules of the Road'(RSA 265:9) dictate that the presence-of a traffi'c officer-supercedes fixed traffic signals at'an intersection.
d...See a., b.
and c.,~ supra, e._
Traffic guides have communications equipment, and can call for assistance.
In addition occupants of vehicles behind the'troken-j 1
down vehicle would likely provide assistance in moving broken down vehicles out of the way.
Also, see the State's response to Interrogatory No. 48, supra.
65.
Will traffic control guides be. stopping drivers to question and direct:them to appropriate evacuation routes and host communities?
I
Response
No.
66.
Identify and produce each and every document, including correspondence, which pertains, directly or indirectly, to any contention to be litigated by the Attorney General and was exchanged
-between you and FEMA since your receipt of the FEMA /RAC Review of the NHRERP-Revision 2.
Response
See State's response to Interrogatory No. 56,-supra.
- 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.
Response
See State's response to Interrogatory Mo. 27, supra.
-A
- 1.. 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 plant, or for any portion of enat
.pcpulation?
Response
It is not the position of the State of New Hampshire that a
sheltering will.never be relied upon as a. protective action for the summer transient beach population located within ten miles of the Seabrook' 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 response option for that portion and not the remaining portion of the transient summer beach population.
Response
The RERP provides at Section 2.6.5 (at 2.6-6) that the transient population, which includes the transient beach population, should, when sheltering is recommended, leave the EPZ.
Should a limited number of the transient population not have access to means to
~
evacuate, they may, as stated in Section 2.6.5 (at 2.6-6) be I
requested to take shelter at the locations they are visiting that is 4
to go indoors.
This is consistent with the preferred protective response of l
evacuation for the period between May 15 and September 15 for botn the resident and transient population at Hampton Beach and Seabrook Beach from Ocean Boulevard and Little Boars Head to the north and t-
. Ocean Boulevard and Route 286 to the south, even though tne decision criteria might ~ indicate that sheltering is a sufficient protective-response.(see Appendix F, Vol. 4 and Appendix 0, Vol. 4A, NHRERP).
When no such shelter is available to the transients not able to leave that beach area or any portion of the EPZ when sheltering is recommended the RERP provides for an ad hoc decision to open public facilities for sheltering (see Section 2.6.5 at 2.6-6).
The basis for_the above provisions is not the result of any determination that sheltering should be a response option for part
-but not all of the transient summer beach population.
It is, rather, a response option for those who have no means of leaving the area when-sheltering is recommended and who also have no means of shel,ter.
76.
Please provide any documents you have reviewed that 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.
Response
The State of New Hampshire arrived at the conclusion set forth in response to Interrogatory No. 74 without reviewing any documents and, therefore, has no documents to provide.
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 ceach population.
l~g Response See State's-response to Interrogatory No. 76, supra.
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.
Response
The' circumstances are described in response to. Interrogatory No.
75.
The state cannot speculate as to the " types of accident sequences and meteorological conditions" that could be associated with such circumstances.
79.
Please provide any plans you have relati'e to sheltering the transient summer beach population, and indicate if, how, and when you intend to amend or add to those plans in any way.
Response
See State's response to Interrogatory No. 75, supra.
The state has no intention, at this time, to amend or add to those plans.
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.
Response
See State's response to Interrogatory No. 79, supra.
47 k
4A of the NHRERP.
In addition to data from the applicant's tocaa 1
{
meteorological equipment, supplemental data from tne Concora (11gnt l
Service Station NWS, NOAA, and Pease Air Force base will De avaliac.e for monitoring weather anc winc conditions.
Plume tracking will k
ce conducted by monitoring teams from the Applicant i
ano from UPno.
4 urna a monitoring teams will follow procedures descrioec in Appendix C at i
Volume 4A of the NHRERP.
122.
any portion of the transient summer beach population tor describe, and provide any materials not relevant to, how that includea in tne tvhdERP the precise wording of any instructions, population will be instructea to take they will be directed ano now, oy wnom, ano Nnere to go?
Resppnse Appendix F outlines the strategy to be used to accress tne potential implementation of precautionary actions in tne hampton Beach area.
Volume 1, Section 2.3 outlines the EPI.
Volume a Appendix B contains EBS Messages.
Volume 4 contains Procedures for activating EBS and the Alert Notification System.
123.
the transient summer beach population, please prov
- have, or otherwise your opinion, on now rapioly sucn sneltering coula ou be effectuated?
Resoonse For those transients with access to accommodations at tne oeoc;.,
it is expected that their movement to shelter woulo be no longet tnan that of residents.
48 -
124. In situations where the general population is airectec to ta<e shelter, precisely what instructions will oe given to tne transleht summer beach population, assuming the oeaches nave not alreacy ceen closed?
Resoonse Instructions to tne " transient population" will be no oltferent cet Vol. 2 Appendix e.
than those given to general population.
Note, however, that the transient beach population will nave ceen directed to leave the ceacnes before shelter airectives are isswec cc the general public.
125. In situations where tne transient beach population,, but not ene general population, is directea to evacuate, precisely wnat instructions, if any, will be given to permanent resicents anc overnight visitors in the beach areas?
Response
New Hampshire does not envision a situation where tne transient population would be given instructions which differ from tnose given to the general public.
126. Is it your opinion that the New Hampshire Radiological Emergency Response Plan (NHRERP) provides in any manner for tne possibility of an accident resulting in an large-scale early (sitnin several hours) release of radiation?
If so, please icentify enose sections and pages of tne plan wnich do so provide.
Response
Yes.
Volume 1, page 1:
Purpose.
Volume 1, Section 1.2:
Concept of Operations.
Volume 1, Section 2.1:
Notification Networ< and Procecures.
See NUREG 0o54,Section I(D), pp.
e-7.
. I, Richard H. Strome, being first duly sworn, do depose and say that the foregoing answers are true, except insofar as they are based on information that is available to the State but not within my personal knowledge, as to which I, based on such information, believe i
them to be true.
Q0 L
vwA Ricnard H.
Strome" Director, Civil Defense Agency Sworn to before me this
- 4 day o.f Jiarph
- 1) 87:
l h
Huditi E J.n h My Commission Expires:
,7/2/k/
As to Obiections and Motion for Protective Order:
j
%l l
y Date Georg&' Dana Bisbe#
(
Senior Assistant Attorney General Environmental Protection Bureau office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3 79 3/n n
(-aK.
Date Geoffrey M.
tington
/'
Attorney
/
Environment Protection Bureau Office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3679 1
I
June 4, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Nuclear Regulatory Commission
)
In the Matter of
)
Docket Nos. 50-443-OL
)
and PUBLIC SERVICE COMPANY OF
)
50-444-OL NEW HAMPSHIRE
)
(Off-Site Emergency (Seabrook Station, Units 1 and 2
)
Planning Issues)
_)
THE STATE OF NEW HAMPSHIRE'S RESPONSES TO ATTORNEY GENERAL JAMES M.
SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE STATE OF NEW HAMPSHIRE (SET NO. 2)
ANSWERS TO INTERROGATORIES Interrogatory No. 1 To the extent not previously described in response to the Attorney General's interrogatories, describe in detail your current position with respect to each contention to be litigated by the Attorney General and each subpart of each such contention.
Describe in detail the reasons for your position.
Response
The State of New Hampshire's position on the contentions has not i
changed since it responded to the Massachusetts Attorney General's l
last set of interrogatories.
{
Interrogatory No. 2 Identify and produce all documents not yet producea 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.
Response
All documents identified in these responses are available for inspection at the Civil Defense Agency headquarters in Concord, New l
Hampshire, on reasonable notice, between the hours of 8:30 am, and 4:00 p.m., Monday through Friday.
1
c-e. The State has established no specific criteria for its annual review of the ETE.
It is likely, however, that the State will subjectively consider changes in population or availability of population data, changes in the evacuation roadway network, or changes in emergency response resources when determining whether new analytical work is warranted.
New empiracal data Will likely not be gathered each year.
Interrogatory No. 23 In its Supplemental Answers to SAPL's interrogatories, the State of New Hampshire referred to certain changes in the plans that "will be reflected in the next revision of the NHRERF".
a.
When will this "next revision" of the RERP be filed?
b.
Please produce the most up-to-date draft of this "next revision" of the NHRERP.
For each contention to be litigated by the Attorney c.
i General, list all changes to the offsite evacuation plans i
that will be reflected in the next revision of the RERP and address an element of the plans alleged in that contention to be inadequate or deficient.
d.
State whether you will voluntarily answer interrogatories from the interveners regarding any changes or adcitions to NHRERP-REv. 2 contained in the next revision, whenever it is filed.
Response to a-d Updating of the NHRERP is a continuous process.
Members of the State and local emergency response organizations may suggest revisions to the NHRERP at any time.
Likewise the State may entertain proposals for plan revisions from other knowledgeable and interested parties including affected nuclear power plant operators and their consultants.
The process for proposing, reviewing and adopting revisions to the NHRERP is described in the procedure entitled Instructions to Person Proposing Revisions to the New Hampshire Radiological Emergency Response Plan.
This procedure augments the general guidance on plan revision described in the NHRERP, Vol.
1, Section 3.3.3.
A copy of these Instructions is available for inspection at the Civil Defense Agency offices in Concord, New Hampshire.
To date only a few proposed changes to Rev. 2 have been submitted to or considered by NHCDA for review and approval.
No changes have been finalized.
It is not now known when the next publication of a NHRERP revision will occur.
The State objects to the request to produce draft versions of tne NHRERP on the grounds that such documents are privileged, deliberative process material.
In re Franklin National Bank Securities Litigation, 478 F.
Supp. 577 (S.D.N.Y.
1977).
SIGNATURE I, Richard H. Strome the foregoing answers, being first duly sworn, do depose and say that are true, except insofar as they are based on information that personal knowledge, as to which I,is available to the State but not within my them to be true, based on'such information, believe e
( Wh
~
Richard H.
Strome Director, Civil Defense Agency
\\
Sworn to before me this l
4th day of p ne, 19(7:
f
$dswihne l
Notary 3 Public 1.(. My C'bmmission Expires: [-/ [ /9 f*
o, e
e, As to Objections and Motion for Protectioi Order:
e c
duS, lO W
George Daha Bisbee Senior Assistr.nt Attorney General f
Environmental Protection Bureau office of the Attorney General 25 Capitol Street concord, NH 03301-6397
]
Telephone (603) 271-3679 a
k i
i 1
1
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- - ~ - --
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g p,
m. ' 1m o, s gj y. e, m, u
i) NO,. a
March 18. 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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
)
(Seabrook Station. Units 1 and L)
)
Offsite Emergency Planning
)
Issues
)
APPLICANTS' RESPONSE TO INTERROGATORIES RE:
hMRERP REV. 2
]
PROPOUNDED TO THEM BY OTHER PARTIES I
- l i
I L/099LK.I
________-_____-_---____A
~
~~
MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 6.
Identify and produce all documents in which you or any agent on your behalf have assessed the adequacy of state and local emergency plhns 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 cr the Applicants to address inadequacies in any past or currect local plans.
RESPONSE
The documents which assess the adequacy of state and local energency plans are as follows:
FEMA technical review of New Hampshire's draft State and local a.
planning for Seabrook, dated June 27, 1985.
b.
FEMA /RAC review of the December, 1985 submission of the New Hampsnire State Plans, dated April 30, 1986.
Draf t RAC review of February 1986 submissions by New Hampshire, dated c.
April 30. 1986.
d.
FEMA /RAC review of the New Hampshire submissions of February. 1986 and draft FEMA /RAC review of the New Hampshire submission of April 16, 1986, dated June 2. 1986.
PEMA/RAC comments on the NKRERT changes submitted to FEMA on April 30.
e.
1986 (transmitted to NHCDA under copy of the August 8, 1986 letter from Edward Thomas to Richard Strose).
f.
FEMA /RAC review of Revision 2 of the NKRERP of August 1986 dated December 1986.
g.
Final Report. Independent Review of the Seabrook Station Emergency Preparedness Program, prepared for New Hampshire Yankee 01 vision by the Independent Review Team, dated October 1965.
h.
IRT Report 8030 transmitted vis IRT-86-024 dated 2/13/86 subject:
Offsite Emergency Plans.
Applicants incorporate by reference their response to Interrogatory 2.
L/065LS.6
NASS ATTORNgY GENERAL APPLICANTS' INTERROGATORIES (continued) 27.
Do you contend that the NHRERP-Revision 2, as draf ted and dated August 1986, without further revision. seets the standard contained in 10 C.F.R $
50.47(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"?
If your answer is "no," state what revisions in the plan are a.
necessary to meet this standard and whether these revisions have been made.
b.
State what responses you (1) have taken, and (11) 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.
RESPONS8
- Yes, s.
Not Applicable b.
Proposed corrective actions intended to be undertaken in response to PEMA/RAC consents on NKRERP, Revision 2, are described in Draft State Response to the Review of the State of New Hampshire Radiological Emergency Response Plan for Seabrook (Rev. 2. 8/88).
L/065LS.27
NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 67.
Describa 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.
RESPONSE
No changes to the NHRERP Revision 2 have been made. See response to Interrogatory 827 for proposed corrective actions.
t I
l J
I L/065LS.67
l
?
MASS ATTORNEY GFXERAL APPLICANTS' INTERROGATORIES (continued) 79.
Please provide any plans you have relative to sheltering the transient suaner beach population, and indicate if, how, and when you intend to amend or add to those plans in any way.
RESPoll8E The NHRERP Volumes 1, 16 and 18 provide for the continuus of protective responses that would be laplemented to protect the health and safety of the public, including seasonal beach populations, in the event of a radiological emergency.
The plans in NMRERP Volumes 1. 16 and 18 will be updated periodically as described in NKRERP Volume 1. Section 3.3.
L/06SLS.79
NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 80.
If no plans for sheltering the transient suaner 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.
RESPONSE
Not Applicable. See response to #79.
t L/065LS,B0
NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 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 an'/ saterials not included in the NHRERP that are relevant to, how that popula-tion will be instructed to take shelter, the precise woruing of any instruc-tions, and how and by whom they will be directed specifically where to go for shelter?
t RESPONSS NHRERP, Volume 1. Section 2.3: Volume 2. Appendix L: and Volume 4. Appendlx j
G describe how the population will be instructed, the pre-drafted wording of instructions, and by whom instructions will be provided.
There are no other materials.
k I
i J
l L/065LS.122
._______-______________-__s
l l
4 I
As to Answers:
J v
%d George 3. Thomas Vice President, Nuclear Production 1
New Hampshire Yankee Division of l
Public Seratice Company of New Hampshire I
March 18, 1987 1
State cf Nek Hampshire Rockinghard County, so.
/
i Then appeared before me the above subscribed George S. Thomas and made oath that he fr the Vice President, Nuclear Proditction of New Hampshire Yankee Divistor.; nuthorized to execute' thw foregoing responses to interrogatories on bahalf of the Applicants that he stMe inquiry and believes that the foregoing arawe'es accar.ately met forth such informat. ion as is available to the Applicash.
/
Before ad. T
.,c, p
s j
- 3 00'tJ J 7 -~~ C ' H:'.ta. Ptn:
t/y C:c...ac.. ;.
<a...u O :.e.ct 20, int My Conseission Expires As to C.bjecticas:
Thomas G. Dignaa. Jr.
R. K. Gad III J
Kcthryn A. Selleck Ropes & Gray 20.3 Franklin Street Boston. Massachusetts 02110 (617) 423-6100 Counsel for ADDlicants L/099LK.2 S
k F
7..
A f V
a l'
Dated:
June 4, 1987 I
l l
UNITED STATES OF AMERICA i
1 NUCLEAR REGULATORY COMMISSION l
before the ATOMIC SAFETY AND LICENSING BOARD l
~
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
)
50-444-CL
)
Off-site Emergency (Seabrook Station, Units 1 and 2) )
Planning Issues
)
)
APPLICANTS' RESPONSE TO INTERROGATORIES RE:
NHRERP REV. 2 PROPOUNDED TO THEM BY OTHER PARTIES (SET 2)
l' NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS
\\
23.
In its Supplemental Answers to SAPL's interrogatories. the State of
{
New Hampshire referred to certain changgs in the plans that "will be reflected
}
i in the next revision of the NHRERP."
a.
When will this "next revision" of the RERP be filed?
b.
Please produce the most up-to-date draft of this "next revision"
{
of the NHRERP.
c.
For each contention to be litigated by the Attorney General, list all changes to the offsite evacuation plans that will be reflected in the next revision of the RERP and address an element of the plans alleged in that contention to be inadequate or deficient, d.
State whether you will voluntarily answer interrogatories from the interveners regarding any changes or additions to NHRERP-Rev. 2 **
contained in the next revision, whenever it is filed.
RESPONSE
a.
There is no current plan to file the "next revision."
b.
See subpart (a),
c.
See subpart (a),
d.
See objection to Mass AG Supplemental Interrogatory #15 and subpart (a).
L/253CC.23
As to Answers:
i d' V George 5. Thomas l_
Vice President, Nuclear Production New Hampshire Yankee Division of Public Servico Company of New Hampshi.
June 4, 1987 State of New Hampshire Rockingham County, ss.
Then appeared before me 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 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 avrilable to the Applicants.
Before me, UMW W
My CommWsion ' Expires h
madf,h[,; j 'w"'y eubge j
As to objectionst 3IM Thomhs G.
Dignan, Jr.
George H. Lewald Kathryn A.
Selleck Deborah S.
Steenland Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 Counsel for Applicants
i ghC UNITED STAT 3S OF AMERICA NUCLEAR REGULATORY COMMISSION
'E7 97 30 P3 :20
)
In the Matter of
}
p g gg y 3 g,,g.; p 4dh[
PUBLIC SERVICE COMPANY OF NEW
)
Docket No.(s) 50-4 HAMPSHIRE, ET AL.
)
(Seabrook Station, Units I and 2)
)
)
)
CERTIFICATE OF SERVICE I,
Frank W. Ostrander, hereby certify that on September 29, 1987, I made service of the within Motion of Attorney General James M.
Shannon, New England Coalition on Nuclear Pollution, Seacoast Anti-Pollution League and Town of Hampton to Postpone Hearing on Sheltering Contentions, or, in the Alternative, to strike Applicants' restimony on Sheltering the Beach Population, by depositing in the U.S.
mail, first class postage paid, addressed to, or as indicated
(*],
by mailing copies thereof with Federal Express, prepaid, for delivery to (or where indicated
(**],
by hand delivery to):
- Ivan Smith, Chairman
- Castave A.
Linenberger, Jr.
Atomic Safety & Licensing Board Atomic Safety i 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 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 dest Towers Building Tenth Floor 4350 East West Highway 7735 Old Georgetown Road Bethesda, MD 20814 Bethesda, MD 20814 I
- 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.d.
25 Capitol Street Washington, DC 20472 Concord, NH 03301
j'\\
- 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 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 Sandra Gavutis, Chairperson 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 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 Peter J. Matthews 1 Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton)
Newburyport, MA 01950 Donald E. Chick William Lord Town Manager P.oard of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amesbury, MA 01913 l
l l \\
Brentwood Board of Selectmen Gary W.
Holmes, Esq.
RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH 03841 l
Philip Ahrens, Esq.
Diane Curran, Esq.
I Assistant Attorney General Harmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W.
State House Station #6 Washington, DC 200A9 Augusta, ME 04333 l
- 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 02210 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 kobert Carrigg, Chairman Anne E. Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-15 Newmarket Poad 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 Exeter, NJ 03833 Commission Washington, DC 20555 Dr. Emmeth A. Luebke 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
)
Bethesda, MD 20814 Judith H.
Mizner, Esq.
j Silvergate, Gertner, Baker, J
Fine, Good & Mizner 88 Broad Street Boston, MA 02110 - - - _ - _ _ - - - - -. - - - - - - - _ - - - -. - - - -. -
--)
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 Frank W.
Ostrander' Assistant Attorney General Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 (617) 727-5575 Dated:
September 29, 1987 1
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