ML20245J541
| ML20245J541 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/23/1989 |
| From: | Bloch P, Harbour J, Luebke E Atomic Safety and Licensing Board Panel |
| To: | HAMPTON, NH, MASSACHUSETTS, COMMONWEALTH OF, NRC OFFICE OF THE GENERAL COUNSEL (OGC), PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| CON-#389-8819 88-858-01-OL, 88-858-1-OL, LBP-89-17, OL, OL-1, NUDOCS 8907030084 | |
| Download: ML20245J541 (40) | |
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$ $nYI$LN retene um:
m 17 W JUN 26 P2 :12 UNITED STATES OF AMERICA NUCLEAR REGIUsATORY COMMISSION b
ATOMIC SAFETY D
BOARD Before Administrative Judges:
Peter B.
Bloch, Chair Dr. Emmeth A. Loebke
$ 2 SERVED JUN 271989 Dr. Jerry Harbour Docket 50-443-OL-1R2 In the Matter of 50-444-OL-1R2 PUBLIC SERVICE COMPANY (On-Site Emergency Planning and OF NEW HAMPSHIRE, et al.
Safety Issues -- Notification)
(Seabrook Station, ASLBP No. 88-858-01-OL Units 1 and 2)
June 23, 1989
\\
MEMORANDUM AND ORDER Final Initial Decision This case involves one aspect of the efforts of Public Service Company of New Hampshire, et al. (Applicants) to comply with the emergency planning regulations of the Commission.
The particular aspect with which we are concerned involves the adequacy of Applicants' plans, should an emergency occur, to alert people who are within the portion of the emergency planning zone that is in Massachusetts.
Applicants' plans had been to send electronic signals that would sound sirens that they had permanently mounted on fixed poles.
But then the ground was taken out from under the poles.
Applicants learned that the Town of West 8907030084 8906D3 DR ADOCK 0500 3
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i Newbury, Massachusetts, had directed that'five utility poles
-l on which sirens were mounted should be removed.'
Applicants l
sought to block tha removal through legal action, but the i
courts ruled that the Town was within its rights.2 Subsequently, Applicants abandoned all fixed-position sirens 1
in Massachusetts.3 1
Applicants have now planned a system called. VANS i
(Vehicular Alert Notification System).
VANS would hire 120 i
people to work round-the-clock shifts to assure that there will be those ready to rush out in the event of an emergency driving trucks equipped with a hydraulic telescoping' boom that would arrive at designated destinations,' rapidly raise their sirens to at least 45 feet and sound the alarm.'
The
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commonwealth of Massachusetts has attempted to demonstrate l
l that the Applicants have not carried'their burden of proof i
in showing that people will be adequately protected by this system.
I lALAB-883, 27 NRC 43 (1988) at 47.
2Ibid.
314. at 48.
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'At the same time, emergency messages would be broadcast over the emergency broadcast system (EBS), to which the public will have been referred by various pre-emergency notification devices (calendars, notices, etc.).
See cenerally, App. Exs. 11A & 11B; ADD. Dir. Dost Tr. 75, Attachments A-G.
i m_______________________
4 4
-3 This decision deals with those issues left to be litigated subsequent to our Summary Disposition Decision, LBP 89-09, which narrowed the issues in a manner that we will discuss below.
This is the background of our consideration.
Because all other issues were decided in our Summary Disposition j
i decision,5 our remaining charge is to consider whether the VANS system, as currently designed, complies with emergency planning regulations by not sounding too loud and discomforting a signal and by providing adequately rapid l
notification of people who might be in the emergency j
l planning zone in the event of a rapidly developing accident j
i at Seabrook.
I.
BACKGROUND DETERMINATIONS A.
Contested Issues The specific issues left for determination pursuant to our Summary Disposition decision, LBP-89-09 at 294-295, are:
1.
Whether the olanned siren sound level is too loud?
A.1-1.
Whether sound levels in excess of 123 dBC cause enough discomfort so that the Board should 5Public Service Company of New Hamoshire (Seabrook Station, Units 1 and 2), ' LBP-89-09, 29 NRC 271 (March 3, 1989) (Summary Disposition Decision).
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not approve the use of sirens at a higher level of i
sound?
A.1-2.
If there is some level higher than 123 dBC that the Board should allow, what is that level?
A.1-3.
Whether Applicants' sirens can provide l
adequate covarage if used at sound levels that are not unduly comfortable?
A.1-4.
Whether Applicants' position on the sound level resulting from their sirens is an under-i estimate because of sound reflection from buildings?
)
1 2.
Whether the destination sites for the VANS vehic153 are adeauate?
A.3-1.
Whether the appointed destination locations, including VL-06, VL-07, VL-12, are sufficiently level for the safe deployment of the j
VANS vehicles?
i A.3-2.
Whether or not VANS vehicles may gain l
physical access to VL-03, VL-06, VL-07, and VL-12?
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3.
Whether the sirens will be sounded fast enouch?
A.5-1.
What is the appropriate conservative estimate of the length of time it would take drivers to take the necessary actions before their vehicles leave their stations during conditions likely to prevail at the time of need?
A.5-2.
Given that there is snowfall of 0.5 inches or more during 5.5% of the days of the year, would a conservative estimate of travel times to VANS acoustic locations include the somewhat prolonged travel times anticipated during snow conditions?
If so, what time estimates should be included?
A.5-3.
What is an appropriate conservative estimate of the length of time it would take people
4 I
- I within.five miles of Seabrook to receive the.
informational message to be broadcast over the EBS?'
A.5-4.
What is an appropriate conservative estimate of the total length of time for alerting and informing people within five miles of Seabrook?
Is that estimate within acceptable guidelines?
(If it is longer than 15 minutes, what are the factors we are to consider in deciding whether the time period is adequate?)
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B.
Stipulation i
We note that the issue of adequacy of the destination sites (issues A.3-1 and A.3-2) was resolved, favorably to Applicants, by stipulation of the parties; therefore, this.
j issue was not part of the hearing held on May 2-3, 1989, in j
i Boston, Massachusetts.
I C.
Competence of Witnesses i
We also note that we found all the witnesses of the j
parties competent to testify,' as follows:
APPLICANTS' WITNESSES Edward W. Desmarais of the Independent Review Team for the i
New Hampshire Yankee Division of Public Service Company of New Hampshire David N. Keast, Principal Consultant, Warning System Services Karl D. Krytar, Staff Scientist, Bioengineering Division of i
SRI Inte.~ftional.
4 Edward Lieberman, President, KLD Associates, Inc.
Louis C. Sutherland, Deputy Director and Chief Scientist, Wyle Research Laboratories, Wyle Laboratories i
t
'&tg Qualifications, post Tr. 38; oost Tr. 454, passim; oost Tr. 310, passim.
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I
. INTERVENOR'S WITNESSES Ruth Kanfer, Professor, University of Minnesota Karl S. Pearsons, Senior Consultant, Acentech, Inc.
Charles B. Perrow, Professor, Yale University l
Gregory C. Tocci, President, Cavanaugh Tocci Associates.
NUCLEAR REGULATORY COMMISSION STAFF'S WITNESSES (" STAFF")
Kennath M. Eldred, P.E.,
Principal of Ken Eldred Engineering Falk Kanter, Section Chief, Emergency Preparedness Branch, Division of Radiation Protection and Emergency Planning, Office of Nuclear Reactor Regulation D.
FEMA Approval The Federal Emergency Management Agency has approved the design of VANS.
ADD. Dir. Dost Tr. 75 at 4.
This clothes the design with a rebuttable presumption as to 1
adequacy.
10 CFR S50.47 (a) (2).
However, FEMA did not 1
produce any sponsoring witness in this case.
Tr. 298.
FEMA has not completed its final review.
Tr. 364.
The review that FEMA did complete did not cover any of the factual or legal issues raised in this hearing.
Tr. 365-370.
- Hence, the FEMA presumption has had no effect on our decision.
It has not shifted the burden of proof on litigated issues from Applicants.
(Had we considered the rebuttable presumption to apply, it still would not have affected the outcome; as we have reached our conclusions by a clear preponderance of the evidence and do not consider the evidence ever to have rested in equipoise -- a state from which a presumption might have dislodged it.)
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t I II.
Whether the olanned siren sound level is too loud?
l NUREG-0654, which provides guidance for us in this i
case, states that:
j The maximum sound levels received by any member of the public should be lower than 123 dB, the level which may cause discomfort to individuals.
NUREG-0654, App. 3 at 3-8.
This maximum sound level of 123 dB appears to have been breached because the sirens to be utilized in the VANS j
l system operate at a frequency of 550 Hz and are rated at 134 1
dBC at 100 feet.
App. Ex. 11B at 2-2 -- 2-3.
l However, Applicants have demonstrated that there are 1
only very limited situations in which a bystander will actually hear a sound in excess of the maximum sound level and we are satisfied that NUREG-0654's intention of 7
balancing emergency needs against the discomfort of the IWe are not impressed with Applicants' extensive j
argument that we should interpret the word " discomfort" to mean physical injury.
Although the reference point for setting the discomfort level apparently was derived from j
considering a level of sound that would cause hearing damage 4
through daily exposure over a 10 year period (ERA boo. Dir.
post Tr. 75 at 13), the level was set as one of
" discomfort."
To interpret the language otherwise would be contrary to the clear wording of the NUREG.
Even the testimony of officials involved in drafting the NUREG is inadequate to cause us to vary the meaning of the plain words.
There is no exception in the language for sirens that would be sounded only at rare intervals, rather i
than daily, and it is very difficult to believe that such an exception should be carved in a guidance document addressed to nuclear power plants.
We will not create such an i
exception.
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-8 public has been served.
Hence, we find Applicants in compliance with this guidance,8 which FEMA also interpreted as permitting similar sirens at the Clinton Power Station.'
We are persuaded to adopt the following proposed findings set forth by Applicants:
In order to clarify the difference between the rated sound output of sirens and the sound level to which bystanders might be exposed, one can draw an analogy between the sound emanating from the horn of a siren and the light from a flashlight.
A flashlight produces a focused beam of light.
Some light is shed to the side of this beam but the amount is less than that within the beam.
Similarly, the round from the horn of a siren is focused into a beam and less sound is radiated to the sides of the beam.
App 2_Dir. oost Tr. 75 at 5-6.
Sirens are normally rated in terms of the maximum sound levels observed in the focused beam of sound, at 100 feet from the siren.
Hence, in the case of the VANS siren, it is rated at 134 dBC at 100 feet in the main beam.
However, because the siren is elevated above the ground, the sound level to which bystanders might be exposed is generally j
less than the rated sound output of the siren, just like the light received from a flashlight would be less than in its main beam if the flashlight shined over their heads.
Aco. Dir. oost Tri 75 at 6.
"NUREG-0654 is not a regulation.
It is guidance.
Metropolitan Edison Compary (Three Mile Island Nuclear Station, Unit No. 1), ALAB-698, 16 NRC 1290, 1298-99 (1982).
Guidance may be challenged in a proceeding and need not be applied verbatim.
Vermont Yankee Nuclear Power Corporation (Vermont Yankee Nuclear Power Station), ALAB-17), 7 AEC 174 (1974); Gulf States Utilities Co. (River Bend Station, Units 1 and 2), ALAB-444, 6 NRC 760, 772 (1977).
'Ano. Dir. oost Tr. 75 at 6.
4 9-In this case, the VANS vehicles are designed to raise their sirens to 51 feet, thus creating the auditory analog of displaying a light from the top of a lighthouse.
When the sirens are raised to their full height, there is no problem from the direct sound beam.
The sound beam is aimed parallel to the earth and no member of the public will be subject to a sound pressure level greater than 123 dBC.
App. Dir. nost Tr. 75 at 6-14.
There could be a problem for four seconds concerning maximum sound levels if there is an emergency of such severity that it was decided to begin sounding the siren when it is not fully extended but has been raised to 25 feet above the ground.
Ann. Dir. nost Tr 75 at 15-16; Irt 88.
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Should that occur at a time that an individual were located l.
l 90 feet from the siren and directly in front of it, then there might briefly be an exposure to a sound level of 131 dBC.
However, the boom will continue to be raised so that the sound level will continually diminish as it is sounded.
By the time it reaches 45 feet, the sound exposure will have been reduced to 123 dBC.
ADD. Dir. nost Tr. 75 at 15-16 &
Attach. H.
There also is an issue concerning sound reflection.
Intervenor's witnesses testified that people standing in l
certain positions between the siren and nearby buildings could experience up to 6 dBC additional sound due to
'4 to reflection from the buildings.
Massachusetts Attorney General Dir. Dost Tr. 454 at 10-13.
When this is additional to the 131 dBC which is possible during the four seconds a siren might sound when it is elevated only to a 25 feet height, it is therefore theoretically possible for an individual to receive 137 dBC for four seconds.
Massachusetts Attorney General Dir. nost Tr.
454 at 12.
Once the siren reaches a 51 foot height, then 128 dBC is possible in these locations.
Idz We agree with Applicants and Staff that these temporary (four seconds) and local (reflective) deviations from the l
124 dBC maximum provided in the guidance documents is not significant from a planning standpoint.
The guidance is I
designed to prevent discomfort, not hearing damage.
There i
is no indication that actual damage will occur.
Even as a discomfort standard, the minimum deviations found are acceptable.
The increased volume of 134 dBC rated sirens will be effective throughout the emergency planning zone with only minimum discomfort to a few people.
We note that the guidance we are interpreting would permit more discomfort than Applicants will cause.
For example, the guidance would permit a steady state siren signal of as much as 3 minutes (NUREG-0654) and the Applicants have chosen to rotate their sirens 2.5 times per minute, reducing the sound exposure at any one part of the The regulations also would permit a 1000 Hz signal; arc.
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! i whereas Applicants have chosen a less uncomfortable 550 Hz signal.
Discomfort resulting from sound signals has been studied by examining the extent to which there is a temporary hearing loss two minutes after'the signal was sounded.
This " temporary threshold shift after two minutes" has been called TTS2.
The TTS2 for the maximum signal permitted by the guidance (a 123 dBC sound at 1000 Hz that remains steady and is not rotated for 3 minutes) is 18 dB, i
as compared to the maximum possible signal generated by l
Applicants (131 dBC sound from a 25 foot siren -- not I
l considering building reflection -- at 550 Hz, rotated 2.5 times per minute), which has a TTS2 of 3 or 4 dB.
App.
Dir. oost Tr. 75 at 9-10, 14.
Even with building reflection included, we find that a four-second signal of 137 dBC would have a TTS2 not much over 4 dBC -- well below the TTS2 of 18 dS for the maximum signal permitted by the guidance.
l We therefore conclude that the discomfort generated by Applicants' sirens is acceptable.
The deviation from guidance levels is minimal because of its short duration and because of the limited areas in which building reflection becomes a problem."
Furthermore, the discomfort caused by "We note Mr. Eldred's testimony that it has been customary to apply the 123 dBC level from NUREG-0654 without consideration of building reflection.
Eldred Dir. Tr. 319-21.
1 l i Applicants is less than would be permitted had Applicants a
chosen to generate the most discomforting signal permitted by the guidance, l
We also are pleased to note that Applicants plan am improvement in the VANS system's hydraulics, which should make it unnecessary ever to sound sirens at a height less
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i than the full 51 feet.
ado. Dir. oost Tr. 75 at 19-19A.
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However, we do not rely on that capability in reaching our 1
determination.
l III.
Whether the sirens will be sounded fast enouch?
I Some of the issues relating to speed of dispatch were j
decided in our Summary Disposition Decision, which settled I
the times needed for transmitting the alert signal to drivers, the time it will take to drive from the staging area to the destination area, the setup time and the siren sounding time.
LBP 89-09 at 284-285.
In this portion of our opinion, we will first state the law that is applicable to our determination, then we will review (in the order in which they will occur) each of the stages of the alerting and notification system, concluding with a chart that summarizes the expected total alerting and notification times with respect to each of the sites on 1
which VANS vehicles will be deployed.
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'A.
' Legal Setting We have concluded that the' law requires that Applicants have the canability for their alert and notification of the-
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public to be essentially complete'within'about 15 minutes of a determination that there is a fast-breaking emergency.
That the regulation focuses on gApability means to us.a practical realization that'the=systemLaust,be able to comply
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with the regulations but that no system can' guarantee results_regardless of events and that there could be events-in which the-capability of the system would not be realized.
The use of the words " essentially. complete" and "about" also indicates to us the appropriateness of some flexibility _
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That. flexibility does not,;however,
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permit us to exclude the notification of the public, through an EBS system message, from the elapsed time.
Based on both the. regulations and the guidance,_we interpret the regulation to include both alerting and notification of the public within the "about 15' minutes" time period..
We turn now to the legal materials themselves..
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Appendix E to Part 50, " Emergency Planning and Preparedness for Production and Utilization Facilities" was published for notice and comment and adopted by the Commission.
Administrative Procedure'Act (5 U.S.'C. SS 552, 553, 44 Fed.
Reg. 75,167, 75,171 (1979); 45 Fed. Reg.155,402, 55,408.
Appendix E provides that:
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- 14 The design objective of the prompt public notification system shall be to have the capability to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes.
[ Emphasis added.]
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1d2 at 3-3.
Appendix E then states planning criteria that must be met by an applicant for a license to operate a nuclear power plant.
In addition to these regulations, which have the force of law, this proceeding is affected by a " guidance" document, NUREG-0654, Rev. 1 (1980), which provides further explanation of the planning criteria set forth in 10 C.F.R.,
Appendix E and which was itself subjected to public comment (44 Fed. Reg. 9768, February 13, 1980) but which has a non-binding or suggestive effect."
Relevant parts of NUREG-1 0654 state:
Plannino Standard
[M]eans to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.
141 at 43; see also S 50.47(b)(5).
Evaluation Criteria Each organization shall establish administrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone.
(See Appendix 3.)
It shall be the licensee's
" Regulatory guidance is always subject to attack in licensing proceedings.
Gulf States Utilities Company (River Bend Station, Units 1 and 2), ALAB-444, 6 NRC 760, 772 (1977); see Seabrook, suura, ALAB-875, 26 NRC at 260-61.
. responsibility to demonstrate that such means exist, regardless of who implements this requirement.
Idz at 45.
APPENDIX 3 MEANS FOR PROVIDING PROMPT ALERTING AND NOTIFICATION OF
. THE POPULATION Commercial broadcast messages are the priinary means for advising the general public of the_ conditions of any nuclear accident.
The primary means for alerting the public to an impending notification by public authorities may be any combination of fixed, mobile or electronic tone generators which wi ? convey the alerting signal with sufficient timing and intensity to permit completion of notification by broadcast media in a timely manner.
Idx at 3-2.
. Within the plume exposure EPZ the system shall provide an alerting signal and notification by commercial broadcast (e.g.,
EBS) plus special systems such as NOAA radio.
The minimum acceptable design objectives r
for coverage by the system are:
a)
Capability for providing both an alert signal add an informational or instructional message to the population on an area wide basis throughout the 10 mile EPZ, within 15 minutes.
[ Emphasis added.]
b)
The initial notification system will assure direct coverage of essentially 100% of the population within 5 miles of the site.
c)
Special arrangements will be made to assure 100% coverage within 45 minutes of the population who may not have received the initial notification within the entire plume exposure EPZ.
1 Id2 at 3-3.
We note, as Applicants have argued, that FEMA Guidance I
Memorandum AN-1, FEMA Action to Oualifv Alert and Notification Systems Acainst NUREG-0654/ FEMA-REP-1 and FEMA-l
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REP-10 provides that, "Within 15 or 45 (if applicable) minutes of [the decision to activate.
the system]..
the alert signal must be activated and an instructional message must be on the air."
However, we consider this to L
be improper interpretation of NUREG-0654, which requires that alerting and notification both occur within 15 minutes.
We interpret this to require sequential alerting and notification since people'will not know to receive the EBS notification until after they have heard the siren alerting signal.
Therefore, we reject this guidance.
B.
Alert We concluded in our Summary Disposition decision that-there was no genuine issue of fact concerning Applicants' assertion that it would take 10 seconds from the time the contact person received an initial notification call to the time that each of the VANS operators would have received an alert message.
However, we beclouded that issue by raising the related o'2estion of "How long will it take (to alert VANS drivers] if electronic activation fails and radio or telephone voice contact becomes necessary?"
Id. at 284.
Hence, we consider that the question of additional time for voice contact was left open.
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1 Intervenor claims that it will take one minute to-alert drivers when electronic activation fails and radio or telephone voice contact become necessary.
Zt. 121."12 We have reviewed the cited passage in the transcript and find that there is unopposed testimony, not objected to by Applicants, that establishes that if electronic alerting is entirely unavailable then it would take "on the order of a 1
minute" to alert all the VANS vehicles using voice communication.
There'is no direct evidence on-how much' time it would.take to telephone one or two of the VANS vehicle sites should there be a partial failure in electronic communication.
In our discretion, we find that it.would l
take. somewhat longer than ten seconds to alert all the sites if the electronic system failed at one of the sites.
Therefore, we add ten seconds to the alerting time to compensate for the possibility that one of the sites would require telephonic alerting, bringing. total alerting time to 20 seconds.
(Even were we to rule, based on the burden of proof, that Applicants would take a full one minute to alert a single site telephonically, this additional 50 seconds of alerting time would not change our judgment concerning the outcome.)
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'IMass AG's Proposed Findings and Rulings of Law with
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Respect to Siren Issues,. June 12, 1989, at 20.
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C.
Dispatch In our summary disposition decision we stated that:
We agree with Intervenor that Applicants have misinterpreted the requirements with respect to-dispatch time.
Dispatch time tests included a maximum of 53.35 seconds.
Beard Affidavit, Attach.
B at 1 of 4.
There were seventeen runs with a dispatch time of over 40 seconds.
Id.
We notice that AJA of the runs of over 40 seconds occurred in the first twenty-seven of the fifty runs, indicating a possible bias due to a practice effect.
Hence, we conclude that these trials are consistent with a dispatch time of as great as 53 seconds.
Furthermore, it is not clear whether these tests, where the operators were aware that they would be repeatedly called, are a fair prediction of what would actually happen in an event with no forewarning.
LBP 89-9 at 284.
We note-that there.re reasons to believe that.
Applicants tests were conservative; Applicants cite those reasons to us.
There also are reasons to believe that Applicants' tests lacked sufficient conservatism; Intervenor cites those reasons to us.
This has led us to review each of the reasons advanced, to weigh them, and to reach our own independent conclusion on the appropriate dispatch time to use.
The parameters of Applicants' test of response time were generally conservative.
Test conditions were chosen which would be representative of staging area conditions in general.
Apo. Dir. cost Tr. 75 at 24-25.
Other test conditions, such as requiring the operators to walk -- not run -- to the vehicles after being mobilized, to verbally 1
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.. acknowledge activation rather than take credit for electronic acknowledgment, and to open overhead doors that will be designed for automatic activation, were' designed to assure reasonable bounding time estimates.
Ann. Dir. Dosi Trz 75 at 25.
On the other hand, we'are impressed by Intervenor's expert testimony that the job of VANS driver is:
intrinsically a boring job in which employees will be difficult to motivate and may be expected to exhibit undesirable traits, such as lateness, absenteeism and unexcused absence from duty posts.
Mass AG Dir. Tr. 469-472.
We also agree with the Intervenor that the design of the office environment creates a space to work in that.may add to the boredom.
Trz 106, 112.
We do, however, expect ~that the Applicants' procedures I
will have some effect in reducing the risks related to boredom.
First, the alarms at the duty stations will be-both audible and visual (flashing strobe-type lights).- App.
Dir. oost Tr. 75 at 24.
Also, there will be an effort made 1
to include other tasks in the VANS-drivers' duties. 'See Intervenor's testimony at Trt 520, 523.
More importantly,.
i there will be a rule that VANS operators are not to leave their duty station until relieved and, given all the attention this issue has received, we are confident that the Applicants will develop supervisory procedures that will l
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. assure that this procedure is effective and that non-performers will be either fired or rotated to other jobs."
Aon. Dir. oost Tr. 75 at 20-24; see Trt 523.
We also are impressed by Applicants' plans for "prioritized dispatch."
Under this plan, the first VANS vehicles dispatched will go to the furthest acoustic location.
Each of the staging areas has a minimum of one l
corresponding acoustic location where a VANS vehicle can be completely deployed in an average of 7 minutes or less, which provides a several-minute margin in the event that a
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driver is momentarily off-post at the time of an alert.
1 Aco. Dir. oost Tr. 75 at 23.
(We also note that, whenever l
possible, actions are taken to provide an advance warning to-VANS operators.
Id. at 23-24.)
On balance, we consider 53 seconds -- a time estimate that we derive from Applicants testing program -- to be an appropriate conservative estimate of the time it will take for VANS vehicles to be dispatched.
It is obvious that there could be extreme, unanticipated conditions in which this time could be exceeded.
It is, of course, even "We note Interveners' testimony concerning railroad engineers. Trx 523-525.
However, we have not been informed of the labor and contractual context in which the engineers in the study operated and we are confident that for this newly created position a job can be defined that would permit discipline and firing for absence from the job post.
The only significant responsibility in this job is to be present and alert enough to hear a loud siren, accompanied by strobe lights.
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. possible that one or more drivers would be unavailable because of improper performance of their duty to be alert and on-site.
Although this contingency would be fully avoided if sirens were hung on poles and there was no need to dispatch vehicles, that approach is not available and non-performance is a resulting risk.
Applicants have done their best to mitigate it.
We do not consider that this possibility prevents Applicants from having the required
" capability" to provide an appropriate alerting system.
D.
Route Transit The only question concerning route transit is the extent to which winter snow or ice conditions slow down the VANS vehicles.
In this regard, we accept Applicants' position that there will be a 25 percent reduction in the
{
l speed factor.
Ano. Dir. Dost Tr. 75 at 25-30.
We use as an element of conservatism the large wheels on VANS vehicles, but we do not deduct any time for this feature since a vehicle may always find itself behind an ordinary car with I
1 smaller wheels.
See ADD. Dir. Post Tr. 75 at 25-30.
We do not consider it necessary for Applicants to plan for more extreme weather conditions, such as those existing in Portland, Maine, on 21 days over an eight year period --
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i during which transit times varied from 27 percent to 39 l
percent.
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We will use the 25 percent reduction factor in our i
conclusions.
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E.
Setup'of Sirens
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i In our Summary Disposition Decision, we accepted.
J Applicants' position that once VANS vehicles arrive at their destination sites that.they can set up their sirens within one minute.
LBP-89-9,.29 NRC 271 at 285.
1 F.
Siren Sounding There is no dispute concerning Applicants' assertion 4
that sirens will be sounded for three: minutes.
Id.~at 285.
i G.
Message Capability Based on our reading of'the regulations and guidance, i
as also set forth supra at 16 ff., App 31 cants must have the-
"[c]apability for providing both an alert signal and an informational or instructional message" within 15 minutes.
The fact that the message and siren sounding are simultaneous is not persuasive.
Until a person. hears both
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the siren and the message, the person is not informed of.the appropriate action to take.
We consider that the full 3 l
minute timing for the siren is appropriate for the purpose of assuring that essentially all the people in the five mile zone are alerted.
Logically, there is a distribution of the l.
i
. times at which the people will hear those signals, with some receiving it at the end of the three minute time period.
For conservatism, we consider it appropriate to add the length of time for the EBS message to all the previous times involved, so that those hearing the siren near the end of its sounding will have time to hear the EBS message.
l In this instance, the longest EBS message is two minutes and 38 seconds, as timed by the Board under stipulation by the parties.
Trx 285.
Under the EBS procedure, a tone and initial announcement lasting 55 seconds will begin at the onset of the 3 minute siren period.
Then the 2 minute, 38 second message may be played, for a total of 3 minutes and 3 seconds for the tone, initial 1
announcement and longest EBS message to play sequentially.
After the three minute siren stops sounding, therefore, the longest message may continue for 3 seconds.
For those j
i hearing the siren near the end of the 3 minutes, it will therefore take three minutes and 36 seconds (3 second delay, 55 second tone and initial announcement and 2 minutes, 38 seconds substantive announcement) before they will be fully informed."
"Because of the continuous playing of messages,
{
some people will begin hearing the beginning of a message, while l
others will begin hearing in the middle.
A portion of those l
beginning in the middle may be confused and need a full I
hearing from beginning to end.
However, this will extend the time beyond what we compute only for a portion of those people who wait until the end of the alerting period to begin tuning in their radio.
We do not consider it j
i
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.__-____-_a
- 24 Since these messages appear to be of a reasonable length for the purpose intended, we are not persuaded by Applicants' argument that they cannot control the length of the broadcast message and should not be penalized for that length within their allotted 15 minute time period.
Were the message of unreasonable length, we might consider this issue in another light.
We are adding an additional 12 seconds time because there could be a delay in finding and tuning-in a radio.
We have no direct evidence on how much time to allot; however, we assume that the public has had an opportunity to learn the EBS procedure and that 15 seconds is adequate time to find and tune a radio.
We add only 12 seconds because only those who are actually alerted at the very end of the siren sounding are affected and there is a 3 second delay before necessary to account for this contingency within the requirement that people be alerted and notified.
We note that Staff has cited NUREG-0654, Appendix 3, to state that A prompt notification scheme shall include the capability of local and State agencies to provide information promptly over radio and TV at the time of activation of the alertina sianal.
[ Emphasis added by Staff at Proposed Findings, p. 32.]
This guidance anticipates that there is a single time of activation for all the signals ("the time"), which will not be the case.
We assume the EBS message should begin simultaneously with the activation of the_.first siren --
there being no reason to wait until all sirens are deployed before sounding the first sirens.
However, we do not I
l interpret this " capability" as detracting from the simultaneous requirement of alerting and notifying within 15
{
minutes.
. the alert tone and message will start -- a message which begins with a tone that does not contain essential' information.
We therefore find that it will take 3 minutes and 58 seconds after the end of the sounding of the siren before people may reasonably be expected to hear a recording of the J9ngest pre-recorded EBS message.
H.
Conclusions Concerning Overall Time We have now discussed each of the elements of time, other than the transit times to each of the sites.
Since the transit times for each of the sites were accepted by us in the Summary Disposition decision and are accepted by all the parties, all the elements of time are fixed and all we need do now is add them together.
The following times are the same for all the sites:
TABLE 1 TIME REQUIRED FOR FUNCTIONS AFFECTING ALL SITES Function Time (Minutes: Seconds)
Alert
- 20 Dispatch
- 50 Setup 1:00 Sound Siren 3:00 Tuning and Message 3:58 TOTAL (ALL SITES) 9:08
.l
As a result, the summary of times for each site can now t
be set forth in TABLE 2.
The times in TABLE 2 have been i
computed with a variety of conservative assumptions, l
including an assumption of winter weather that will reduce transit times by 25 percent.
Note that three of the I
locations, shown in bold face type in TABLE 2, have total j
times in excess of 15 minutes.
No location has a time in excess of 20 minutes.
Under all the circumstances of this case, including the fact that concerned political jurisdictions can reduce alerting and notification times by making sites available for sirens permanently mounted on poles, we consider this distribution of alerting times to be permissible.
- Indeed, we appreciate how well Applicants have done in surmounting.
difficult problems in order to design an acceptable second-1 best system."
i Although the matter has not been litigated directly, there is little question that the best alerting system would be to use sirens fixed on poles.
Because that option is not available to Applicants, this proceeding represents their attempt to persuade this Board that they can satisfy the Commission's regulations with a next-best effort.
We note that if the citizens of Massachusetts are seriously concerned about the few extra minutes we are permitting VANS, they can save this time and more by changing local regulations to permit sirens to be mounted on fixed poles.
1 4
, TABLE 2 TIMES FOR EACH SITE.
.-- INCLUDING IN THE TOTAL.9 MINUTES, 8 SECONDS FROM TABLE 1 (Times in: MINUTES: SECONDS)
LOCATION TRANSIT" WINTER TOTAL TRANSIT WINTER
(+ 25%)
(+9:08) 1 8:37 10:46 19:54 2
5:03 6:19 15:27*-
3 6:29 8:06 17:14*-
4 0:00.
0:00 9:08 5
0:00 0:00 9:08 6
3:09 3:56' 13:04*
7 3:42 4:38 13:46 8
7:13 9:01-18:09*'
9 7:17 9:06 18:14*-
10 7:18
'9:08 18:16*
11 7:32 9:25 18:33*
12 8:25 10:31 19:39 13 8:03 10:04
'19:12' 14 0:55 1:09 10:17*
15 3:01 3:46 12:54 16
'11:43 14:39 23:47*
y
- = These locations provide' primary-siren coverage only for populations beyond five miles of;the site.- They are, therefore, not subject to the Appendix 3. requirement that
" essentially 100% of the population" be alerted within'15' minutes.
NOTE: Times of over 15 minutes for areas within 5' miles of the Seabrook Station site are shown in bold face type.
I "Ano. Dir. Dost Tr. 75 at 28.
"We find that in winter months, the population served by this location is reduced enough in density that it would be adequately alerted by a 60 dBC sound level, which is provided by' sirens at acoustic locations VL-02, 04'and 15,-
all of which have shorter predicted winter transit times and' resulting total times.
Id.-at 26-27.
j o
. z__ _ i
1 4
IV.
Statement of Conclusion I
In this decision, we have determined that the VANS system c'oes adequately comply with emergency planning regulations in that the plan for using the sirens does not
)
generate an inordinate volume of sound.
We have also I
determined.that the expected time for alerting and notification -- though three VANS locations somewhat exceed 15 minutes -- is adequate, considering all the circumstances of this case.
I Our answers to each of the questions set for hearing i,
are-1.
Whether the olanned siren sound level is too loud?
l A.1-1.
Whether sound levels in excess of 123 dBC cause enough discomfort so that the Board should not approve the use of sirens at a higher level of sound?
Ansner: Applicants plan to exceed 123 dBC for a very brief time period and to use their sirens in such a way that people standing in the reflective area in front of buildings located within 100 yards i
of the sirens will receive sound levels of up to 6 dBC in excess of 123 dBC.
We find that these violations of the standard set in the guidance, l
which is not binding on us, are minor.
We accept these minor deviations from the standard suggested l
in the guidance.
I A.1-2.
If there is some level higher than 123 dBC that the Board should allow, what is that level?
Answer,: Under the circumstances of this case, I
we have permitted up to 137 dBC for four seconds and, generally, up to 129 dBC, which may occur only
-4 i
. l i
in local areas near buildings, where sound reflection is. expected to occur.
A.1-3.
Whether Applicants' sirens'can provide adequate coverage if used at sound levels that are not unduly comfortable?
l Answer: We have found that Applicants' notification system is adequately comfortable.and, at the proposed sound leve it is conceded to provideadequatecoverage.gs, A.1-4.
Whether Applicants' position on the sound level'resulting from their sirens is an under-estimate because of sound reflection from i
l buildings?
l Answer: We agree with.Intervenor on this point.
Reflection of sound from buildings will cause up to a 6 dBC increase in sound levels.
The evidence suggests that these increased levels will oCCu.
2.
Whether the destination sites for the VANS l
vehicles are adeauate?
A.3-1.
Whether the appointed destination locations, including VL-06, VL-07, VL-12, are sufficiently level for the safe deployment of the VANS vehicles?
Answer: The sites are sufficiently level.
The parties have stipulated to this.
A.3-2.
Whether or not VANS vehicles may gain physical access to VL-03, VL-06, VL-07, and VL-12?
Ansvar:
The VANS vehicles may gain physical access to the listed sites.
The parties have stipulated to this.
1sHad we required a reduction in volume of sound from the sirens, sound coverage would have been reduced to unacceptable levels.
Ann. Dir. oost Tr. 75. at 206-7.
.f'
- 3 0 --
3.
Whether the sirens will be sounded fast enouah?
A.5-1.
What'is the appropriate conservative estimate of the. length of. time it would take drivers,to take.the necessary actions before their vehicles leave their stations during conditions likely~to prevail at the time of need?
Answer: We have decided to use a, conservative
' time-of-dispatch.figura derived from tests conducted by Applicants.
The figure is slower than-
'the one suggested.by Applicants but it does'noto assume ~ unavailability of drivers because of
. motivational concerns.
We are satisfied that'the
-loudness of sirens, the visual l prominence of strobe lights, the,use of regular supervision to' fire non-performing employees, and'a phased system for dispatching drivers, provide adequate combined guarantees.
We do not require Applicants to assure the impossible: that some driver some time may be-delinquent at the time cHE an emergency.
Applicants have promised to do what is practicable,: and we are satisfied that is adequate.
I A.5-2.
Given that there is snowfall of 0.5 inches or more during.5.5%.of'the days of the year, would a conservative estimate of travel times to VANS acoustic locations include the somewhat prolonged travel times anticipated during snow conditions?
If so, what time estimates should be:
included?
{
Answer: We find that it will take 25 percent more time for Applicants to travel to VANS destination locations during winter weather.
A.5-3.
.What is an appropriate conservative estimate of the length of time it would take people within five miles of Seabrook to receive the.
informational. message to be broadcast over the EBS?
-l Answer: Three minutes-and 58' seconds after'the siren ~has stopped sounding.
A.5-4.
What is an appropriate conservative.
estimate,of the total length of time for alerting and informing people within five' miles of Seabrook?
Is that estimate within acceptable guidelines?
(If it is longer than 15 minutes, what are the factors i
l i
1 l
4
.. we are to consider in deciding whether the time period is adequate?)
Answer: The total length of time for alerting and informing people is set forth in TABLE 2, which shows different time values for different VANS locations due to the amount of travel time involved.
Note that the sites marked with asterisks are not required to alert and notify people within 15 minutes because they are not the primary alerting mechanism for any population within five miles of the site.
V.
ORDER For all the foregoing reasons and upon consideration of the entire record in this matter, it is this 23rd day of June, 1989, ORDERED, that:
1.
All genuine issues of fact are hereby resolved in favor of the compliance of Public Service Company of New Hampshire, et al. (Applicants) with the applicable regulations and guidance, as applied by this Board.
2.
VANS (Vehicular Alert and Notification System), which is Applicants' public alert notification system for the Massachusetts portion of the Seabrook Station EPZ, is found to meet the requirements of the Commission's regulations and guidance, as applied by this Board.
3.
There is reasonable assurance that persons located in the Massachusetts portion of the Seabrook EPZ will be notified of a radiological emergency at Seabrook Station within about 15 minutes of the time that cognizant officials of the Commonwealth of Massachusetts decide to make such notification.
4.
This decision disposes of a discrete and major segment of the full power operating license proceeding.
Accordingly, any party may take an appeal from this decision by filing a Notice of Appeal within ten (10) days after service of this decision.
Each appellant must file a brief supporting its position on appeal within thirty (30) days after filing its Notice of Appeal (forty (40) days if the Staff is the appellant).
Within thirty (30) days after the period has expired for the filing and service of the briefs of all appellants (forty (40) days in the case of the Staff), a party who is not an appellant may file a brief in support of or in opposition to the appeal of any other i
i c
J
. party.
A responding party shall file only a single, responsive brief regardless of the number _of appellants' briefs filed.
Egg 10 C.F.R.
S 2.762 (which controls the j
appeal proceeding, regardless of the language of this j
paragraph).
j 1
j FOR THE ATOMIC SAFETY AND LICENSING BOARD M;._ Cl-
-Emmeth A.
Luebke Administrative Judge Y7V
$6rry Hdrbour j
Administrative Judge
- 1/(/.D.
peter'B. Bloch Chair l
Bethesda, Maryland I
e U
-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of I
l PUBLIC SERVICE COMPANY OF NEW l
Docket No. (s) 50-443/444-OL HAMPSHIRE. F.T AL.
I (Seabrook Station. Units 1 and 2) 1 I
I CERTIFICATE OF SERVICE I hereby certify that cooles of the forecoino LB M&O (LBP-89-17) FINAL I D have been served upon the followino persons by U.S. mail, first class, except as otherwise noted and in accordance with the requirements of 10 CFR Sec. 2.712.
Administrative Judae Administrative Judae Alan S. Rosenthal Chairman Thomas S. Moore Atomic Safety and Licensino Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Reculatory Commission U.S. Nuclear Raoulatory Commission Washinoton. DC 20555 Washington. DC 20555 Administrative Judoe Howard A. Wilber Administrative Law Judae Atomic Safety and Licensing Appeal Ivan W. Smith. Chairman Board Atomic Safety and Licensino Board U.S. Nuclear Regulatory Commission U.S. Nuclear Reculatory Commission Washington, DC 20555 Washinoton, DC 20555 Administrative Judae Administrative Judge Richard F. Cols Kenneth A. McCollem Atomic Safety and Licensino Board Atomic Safety and Licensino Board U.S. Nuclear Raoulatory Commission U.S. Nuclear Reculatory Commission Washincton. DC 20555
. Washington, DC 20555 Administrative Judae Robert R. Pierce. Escuire James H. Carpenter-Atomic Safety and Licensino Board Alternate Technical Member U.S. Nuclear Regulatory Commission Atomic Safety and Licensina Board Washington, DC 20555 U.S. Nuclear Reculatory Commission Washington, DC 20555 Edwin J. Reis Esc.
Lisa B. Clark Office of the Seneral Counsel Attorney U.S. Nuclear Regulatory Commission Office of the General Counsel Washinoton, DC 20555 U.S. Nuclear Regulatory Commission I
Washington, DC 20555 l
\\
1 Docket No.(s)G0-443/444-OL LB Mk0 (LBP-89-17) FINAL ! D l
Diane Curran. Eso.
Thomas G. Dianan Jr.. Eso.
l Harmen. Curran k Tousley Ropes & Gray j
2001 S Street.
N.W., Suite 430 One International Place Washincton, DC 20009 Boston MA 02110 1
i Robert A. Backus. Esc.
Paul McEachern. Esc.
Backus. Never & Solomon Shaines & McEachern 116 Lowell Street 25 Maplewood Avenue. P.O. Box 360 Manchester. NH 03106 Portsmouth. NH 03801 l
Sarv W. Holmes. Esc.
Judith H. Mizner Holmes & Ells Silverolate. Gernter. Baker. Fine.
l 47 Winnacunnet Road Good and Mitzner Hampton. NH 03842 98 Broad Street j
Boston. MA 02110 Charles P. Graham. Esq.
Jane Doherty McKay, Murphy and Graham Seacoast Anti-Pollution Leacue 100 Main Street 5 Market Street Amesbury. MA 01913 Portsmouth. NH 03801 Leonard Kopelman Esc.
Ashed N. Amirtan. Esc.
Kopelman and Palos. P.C.
376 Main Street 77 Franklin Street Haverhill. MA 01830 Boston MA 02110 Georce W. Watson Esc.
Edward A. Thomas Federal Emergency Manacement Agency Federal Emergency Manecement Aosncy 500 C Street. S.W.
442 J.W. McCorsack (POCH)
Washinoton, DC 20472 Boston. MA 02109 George D. Bisbee. Esc.
Paul A. Fritzsche. Esc.
Assistant Attorney General Office of the Public Advocate Office of the Attorney General State House Station 112 25 Capitol Street Augusta. ME 04333 Concord. NH 03301
s W
Docket No.(s)30-443/444-OL LB N&O (LBP-89-17) FINAL ! D i
Suzanne Breiseth John Traficente. Esc.
Board of Selectmen Chief. Nuclear Safety Unit Town of Hampton Falls Office of the Attorney General 1
Drinkwater Road One Ashburton Place. 19th Floor Hampton Falls. NH 03944 Boston, MA 02108
.The Honorable I
Peter J. Brann. Esc.
Edward J. Markey. Chairman I
Assistant Attorney General ATTN Linda Correia Office of the Attorney General Subcommittee on Energy Conservation and I
State House Station. #6 Power Augusta. ME 04333 House Committee on Energy and Commerce Washington, DC 20515 J
Richard A. Hampe. Esc.
J. P. Nadeau Hampe & McNicholas Board of Selectmen 35 Pleasant Street 10 Central Street Concord. NH 03301 Rye, NH 03870 i
i Allen Lampert William Armstreno Civil "ifense Director Civil Defense Director
.)
Town of Irentwood Town of Exeter j
20 Franklin Street 10 Front Street Exeter. NH 03033 Exeter, NH 03B33 Sandra Gavutis. Chairman Calvin A. Canney Board of Selectmen City Manager j
RFD #1 Box 1154 City Hall i
Kensington. NH 03927 126 Daniel Street Portsmouth. NH 03801 Anne Goodman. Chairman William S. Lord Board of Selectmen Board of Selectmen 13-15 Newmarket Road Town Hall - Friend Street Durham NH 05024 Asesbury, MA 01913 i
Peter J. Matthews Mayor of Newburyport Michael Santosuosso. Chairman l
City Hall Board of Selectmen
)
Newburyport. MA 01950 South Hampton, NH 03027 i
l Docket No.(s)S0-443/444-OL l
LB M&O (LBP-89-17) FINA'. 1 D j
l l
R. Scott Hill-Whilton.Escuire Stanley W. Knowles. Chairman Laoculis. Hill-Whilton & McGuire Board of Selectmen 79 State Street P.O. Box 710 Newburyport.
MA 01950 North Hampton, NH 03862
)
Norman C. Katner Sandra F. Mitchell Superintendent of Schools Civil Defense Director School Administrative Unit No. 21 Town of Kensinoten I
Alumni Drive-Box 10. RR1 Hampton. NH 03642 East Kinoston, NH 03627 1
John F. Doherty Beverly Hollinowerth 1616 P Street. N.W.
209 Winnacunnet Road I
Washington. DC 20036 Hampton, NH 03842 The Honorable The Honorable Gordon J. Humphrey Nicholas
.Marvoules ATTNr Janet Coit ATTN Michael Greenstein United States Senate 70 Washinoton Street Washinoton. DC 20510 Sales. MA 01970 l
Dated at Rockville. Md. this 26 day of June 1999 Of fthe'5eiheiiry~ofibi'Cc5EIIIion
~
1
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
]
In the Matter of i
1 PUBLIC SERVICE COMPANY OF NEW I
Occket No.(s) 50-443/444-OL-1 HAMPSHIRE. ET AL.
I 4
(Seabrook Station. Units 1 and 2) 1 I
j l
1 i
CERTIFICATE OF SERVICE I
I hereby certify that cooles of the forecoino LB M&O (LBP-09-17) FINAL ID i
have been served uoan the followino persons by U.S. mail first class. except as otherwise noted and in accordance with the requirements of 10 CFR Sec. 2.712.
Administrative Judae Administrative Judae f
Alan S. Rosenthal. Chairman Thomas S. Macre Atomic Safety and Licensino Appeal Atomic Safety and Licensino Appeal i
Board Board 5
U.S. Nuclear Reculatory Commission U.S. Nuclear Raoulatory Commission i
Washincton. DC 20555 Washinoten. DC 20555 i
Administrative Judoe Howard A. Wilber Administrative Judas Atomic Safety and Licensino Acceal Peter B. Bloch. Chairman Board Atomic Safety and Licensino Board U.S. Nuclear Reculatory Commission U.S.-Nuclear Regulatory Commission Washinoton, DC 20555 Washington DC 20555 Administrative Judae Administrative Law Judae Jerry Harbour Ivan W. Smith Atomic Safety and Licensino Board Atomic Safety and Licensino Board U.S. Nuclear Reculatory Commission U.S. Nuclear Reculatory Commission Washinoton DC 20555 Washinoton DC 20555 Administrative Judoe Edwin J. Reis, Esq.
Emmeth A. Luebke Office of the General Counsel 5500 Friendship Boulevard. Apt. 1923N U.S. Nuclear Raoulatory Commission Chevy Chase. MD 20S15 Washington. DC 20555 1
Diane Curran. Esc.
Thomas 8. Dianan. Jr., Esq.
Harmon. Curran & Tousley Rooms & Gray 1
2001 S Street. N.W., Suite 430 One International Place Washington, DC 20009 Boston. MA 02110 l
l 4
e-n' Docket No.(s)D0-443/444-OL-1 LB M&O (LBP-89-17) FINAL 10 Robert A. Backus. Esc.
Paul McEachern. Esc.
Backus. Never & Solomon Shaines & McEachern 116 Lowell Street 25 Maplewood Avenue. P.O. Box 360 Manchester. NH 03106 Portsmouth. NH 03801 Gary W. Holmes. Esc.
Charles P. Graham, Esc.
Holmes & Ells McKay, Murphy and Graham 47 Winnacunnet Road 100 Main Street Hampton. NH 03042 Amesbury. MA 01913 Barton Z. Cowan. Esa.
Jane Douchty Eckert. Seamans. Charin & Mellott Seacoast Anti-Pollution Leacue 600 Grant Street. 42 Floor 5 Market Street Pittsburah. PA 15219 Portsmouth. NH 03801 Georoe W. Watson. Esc.
Edward A. Thomas Federal Emercancy Management Agency Federal Emergency Management Agency 500 C Street. S.W.
442 J.W. McCormack (PDCH) j Washington. DC 20472 Boston. MA 02109 Georos D. Bisbee. Esa.
Paul A. Fritzsche. Esc.
Assistant Attorney General Office of the Pubif-Advocate
{
Office of the Attorney General State House Statie. 112
{
25 Capitol Street Augusta. ME 04333 i
Concord. NH 03301 Suzanne Breiseth John Traficonte. Esa.
Board of Selectmen C5ief. Nuclear Saf ety Unit Town of Hampton Falls Office of the Attorney General Drinkwater Road One Ashburton Place. 19th Floor Hampton Falls. NH 03844 Boston. MA 02108 l
Matthew T. Brock. Esc.
Philip Ahrens. Esc.
i Assistant Attorney General Assistant Attorney General Office of the Attorney General Office of the Attorney Seneral One Ashburton Place. 19th Floor State House Station. #6 Boston. MA 02108 Augusta. ME 04333
e Docket No.(s)50-443/444-OL-1 I
)
i The Honorable Edward J. Markey, Chairman Richard A. Hampe, Esa, i
ATTN: Linda Correia Hampe & McNicholas l
Subcommittee on Eneroy Conservation and 35 Pleasant Street Power Concord. NH 03301 House Committee on Eneroy and Commerce Washinoton, DC 20515 J. P. Nadeau Allen Lampert Board of Selectmen Civil Defense Director 10 Central Street Town of.Brentwood Rye. NH 03870 20 Franklin Street i
Exeter. NH 03833 l
Williar Armstrono Sandra Gavutis. Chairman Civil Def ense Director Board of Selectmen Town of Exeter RFD #1 Box 1154 10 Front Street Kensinoton. NH 03827 Exeter. NH 03833 Calvin A. Canney Anne Goodman. Chairman City Manaaer Board of Selectmen City Hall 13-15 Newmarket Road 126 Daniel Street Durham. NH 03824 Portsmouth. NH 03801 Peter J. Matthews Board of Selectmen Mayor of Newburyport Town Hall - Friend Street City Hall Amesbury, MA 01913 Newburyport. MA 01950 R. Scott Hill-Whilton. Escuire Michael Santosuosso. Chairman Lacoulis. Hill-Whilton & McGuire Board of Selectmen 79 State Street South Hampton NH 03827 Newburyport,, MA 01950 Stanley W. Knowles, Chairman Board of Selectmen Beverly Hollingworth P.O. Box 710 209 Winnacunnet Road North Hasoton, NH 03862 Hampton, NH 03842
6 Docket No.(s)00-443/444-OL-1 LB Mk0 (LBP-89-17)' FINAL ID The Honorable The Honorable Gordon J. Humphrey Nicholas Marvoules ATTN Janet Colt ATTN Michael Greenstein United States Senate 70 Washincton Street Washincton. DC' 20510 Salem, MA 01970 Dated at Rockville. Md. this 27 day of June 1989 Office f the Secretary of the Commission 1
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