ML20247B657
| ML20247B657 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/06/1989 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20247B564 | List: |
| References | |
| OL, NUDOCS 8909130098 | |
| Download: ML20247B657 (36) | |
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'89' SEP 11 All 32 September 6, 1989 UNITEDSTATESNUChkkRfREGULATORYCOMMISSION
-ADVISORY COMMITTEE ONFREACTOR. SAFEGUARDS
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In the Matter of
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Docket No. 50-443 PUBLIC SERVICE COMPANY
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(Emergency Planning oOF NEW HAMPSHIRE, et al.
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Issues)
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(Seabrook Station, Unit 1
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COMMENTS OF THE SEACOAST ANTI-POLLUTION LEAGUE FURNISHED TO THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS REGARDING THE MEETING OF THE SEABROOK SUBCOMMITTEE AUGUST 17, 1989 INTRODUCTION The Seacoast Anti-Pollution League stands appalled by the outright misrepresentations of fact provided by a representative of the Seabrook utilities, (See pages 8-9, infra) and even more appalled, indeed outraged, by the misrepresentations and half truths made by the NRC Staff as reflected in the record of August 17, 1989. (See pages 2-3, infra).
The Seacoast Anti-Pollution League will now attempt to set the record straight, so that the Committee will clearly realize that the emergency planning problem at Seabrook is not a trivial issue-and that the'NRC Staff, in particular, has been disingenuous in the extreme in its presentation to the Committee.
SAPL believes that the NRC Staff deserves the strongest possible censure from the ACRS for its role in this blatantly misleading presentation.
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t THE HISTORY OF THE EMERGENCY PLANNING PROBLEM AT SEABROOK Contrary to the representations of NRC Staff counsel Edward Reis at pages 21 and 22 of the transcript, suggesting that generally the Seabrook site is no more difficult than other sites, i.e.,
there are no "significant weak links in the Seabrook emergency plan," the fact is that the Seabrook site has long been recognized by all, including the ACRS itself, to be a problem.
On December 10, 1974, the ACRS issued its report on the proposed construction of Seabrook Station, Units 1 and 2, to former chairman Dixie Lee Ray of the Atomic Energy Commission.
In that report, the Committee noted as follows:
The Seabrook Station, Units 1 and 2 will be the first commercial nuclear power plant in the State of New Hampshire.
For this reason, the Committee recommends that the Applicant and Regulatory Staff give particular attention to assuring proper coordination with appropriate state and regional agencies in the development of effective emergency plans for this facility.
Because of the proximity of the Seabrook Station to the beaches on the coast and because of the nature of the road network serving the beaches, the Applicant has given early attention to the problems of evacuation.
The Committee believes, however, that further attention needs to be given to evacuation of residents and transients in the vicinity even though they may be outside the LPZ.
(The ACRS Report is attached hereto as Appendix A.)1 1/ Despite the ACRS' 1974 concern, the NRC continued to adhere to the official position that no consideration of evacuation needed to be provided to persons outside the LPZ for any nuclear power plant through the construction permit licensing process at the NRC.
In ALAB-390, 5 NRC, 733 the NRC Appeals Board officially ruled that no consideration had to be given to people outside the LPZ at Seabrook, notwithstanding that immediately outside the LPZ boundary, 1 1/4 miles from the reactor, there existed the barrier beaches, with the highest population concentrations in the state of New Hampshire on peak summer weekends. 1 l
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1 The failure to mention _this report is merely one of the serious emissions in the chronology.of the handling of the emergency planning ',,roblem at Seabrook re.flected in the transcript of the subcommittee's August 17 hearing.
Indeed, the chronology of emergency planning at Seabrook, as provided by New Hampshire Yankee's' George Gram, pages 58 through
-60 of the transcript, is replete with significant, and we believe intentional, omissions.
There'is no mention of the fact that, in 1979, as a result of the accident at Three Mile Island, SAPL attempted to have the NRC issue a show cause order pursuant to 10 CRF S 2.206, on the ground Lthat the emergency planning [roblems at Seabrook were so intractable'that they should be addressed immediately, perhaps through design changes, and not await the operating license Ltage.
The NRC declined to do so.
In 1982, the Court of Appeals for the District of Columbia, in upholding the denial of the 10 CFR S2.206 petition brought by SAPL, stated the obvious:
We are.not unsympathetic with SAPL's position in this case.
SAPL has presented evidence regarding the unique features of the Seabrook area and the current state of emergency preparedness in the area that would seem to warrant the Commission's most careful examination in evaluating the adequacy of the final Seabrook EPZ emergency plans.
SAPL v. NRC, 690 F.2d 1025 at 1033 (D.C. Cir. 1982). j
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Indeed, in dissenting from the Commission's three to two decision not to review Harold Denton's decision not to undertake a S2.206 proceeding, former Commissioners Gilinsky and Bradford said:
Seabrook poses difficult, and pet..eps unique, emergency planning problems.
In light of the time and cost likely to be involved in improving Seabrook's emergency preparedness, we should begin to seek solutio::s now, not some years from now, when the plant is almost ready to operate.
Moreover, at that time it will be much more difficult for the 11RC to require remedial measures which could delay plant operation.
Among the options which we should now be considering are:
improving parking at the beach so as to permit rapid evacuation, adding improved access roads to the beaches, and constructing additional access roads to Interstate-95.
It should be understood that if emergency preparedness is not improved sufficiently by measures such as these, Seabrook's operation may be contingent on restricted use of the beaches.
The Federal Emergency Management Agency (FEMA) as far back as 1981 had described Seabrook as "a special case" due to the extent of public concern over the site problems.
According to FEMA, l
Evacuation time by sectors within the EPZ and under the 15-minute alerting and notification for Summer Sunday ranges from 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 10 minutes to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 10 itinutes depending on the combination of sectors.
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Tt The basic conclusions are:
The. evacuation time for the Summer Sunday case is determined almost totally'by the F
rate at which the beaches can be evacuated.
Speeding up_the alerting and notification process simply accelerates the rate at which motorists enter the existing traffic congestion, that ranges up to'a maximum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 15 minutes.
Figure III-20 shows the long cues-(backups) along the' beaches.
The behavior of drivers who are caught'in congestion within~ direct sight of the Seabrook Station can be only be guessed at this time.
Any breakdown in orderly evacuation traffic flow will result in evacuation times greater than the ones estimated'above.
Total evacuation times could range from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> 30 minutes to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> 40 minutes for an evacuation in which traffic control is generally.
ineffective.
FEMA-Rep.-3, February 1981, Mass. AG Exh. 48, p. 46.
In ALAB-422 the NRC's Appeal Board acknowledged, in describing the issue of the proper application of the Commission's siting criteria, that "no one disputes that this area [seabrook beach area] will be at times the most densely populated area in the State."
6 NRC 33 at 51 (1977)
Even the Licensing Board below acknowledged the uniqueness of the Seabrook site.
In examining the evidence and proposed findings presented by the Massachusetts Attorney General, the Board agrees that there are certain factors specific to the Seabrook EPZ that should be considered regarding protection of the summer beach population.
The Federal Emergency Management Agency has stated with respect to its consideration of this issue that:
[F] actors unique at least-in magnitude to Seabrook.
. concerning protection of.the-Seabrook beach population are the size of the transient
(" day-tripper")-
beach population; size of the beach population; number of unwinterized housing / commercial buildings;-
volume of corridor type road traffic; complexity of road network; number of local governments involved in the emergency planning process; and large geographic size of the EPZ.1 (PID 8.47, p. 201)
Thus, long before this proceeding, all concerned, including the Court of Appeals, members of the Commission, the Appeal Board, and FEMA, and the ACRS were well aware that Seabrook, due to'its location next to heavily utilized beaches, and in light of the limited road network, would pose an. enormous obstacle to a finding that an " adequate" level of safety could be achieved through emergency. planning.
Before the Court in SAPL v. NRC, supra, the' NRC solemnly promised that if an " adequate" level of safety could not reasonably be assured through emergency' planning, no operating license would be issued.
CDi. at 1030)
None of this is mentioned in the New Hampshire Yankee or Staff presentation to you, and all of this gives the lie to NRC Staff counsel Reis" misrepresentation that "the Staff does not feel that this plant is much different than any other plants [ sic]
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either in times or difficulties of evacuation."
(Id. 22.)
sh final point needs to be made about the Staff's outrageous performance before the ACRS subcommittee.
Not only is the Staff absolutely wrong in suggesting there is nothing "particularly _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - -
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l difficult" about the Seabrook site, the Staff is legally wrong in suggesting that this determination can be made by reference to any other site.
The Commission, in adopting its rule change on utility emergency planning, on November 3, 1987, 52 Fed. Reg.
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42078, specifically said that no emergency plan was to be judged by comparing it with other emergency plans, whether at other sites, or by comparing a utility plan to a governmental plan.
There are other omissions from the chronology offered to the Subcommittee, as follcws:
1.
At page 57, New Hampshire Yankee's Gram mentions that New Hampshire submitted its first version of its emergency plan in December of 1985.
Mr. Gram fails to mention that the exercise of that plan, held in February, 1986, resulted in a finding of a record high number of deficiencies, 55.
2.
There is no mention of the appeals in the Partial Initial Decision, and the numerous issues raised on those appeals.
3.
There is no mention of the fact that the NRC Staff is now supporting a "best efforts" approach to emergency planning, and is refusing to consider requiring the licensee to take steps such as those recommended by Commissioners Bradford and Gilinskey to reduce the extraordinarily long evacuation times, found by the Licensing Board to be as long as 8 1/2 hours.
All told, the Committee s!ould view the statements made by New Hampshire Yankee and the NRC Staff are statements made by i
parties that have a distinct advocacy interest in this proceeding. ___
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'The Staff has not even the illusion of impartiality in-this l
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THE SEABROOK SITE The worst of the deceptions and misrepresentations offered to the Subcommittee on August 17 relate to the Seabrook site itself.
Contrary to the NRC Staff's statements,.on pages 22 and 23, the ASLB, itself said that the site was " unique at least in magnitude" as to certain factors, including size of the beach population, and number of underwinterized housing / commercial buildings; volume or type of road traffic; complexity of road networks; number of local governments involved in emergency planning process; and large geographic size of the EPZ.
(PID
.54.47, Slip Opinion, p. 201)
The road and traffic factors will be demonstrated by the SAPL I
video tape on September 8.
However,.at Tr. p. 36, occurs the single most outrageous misrepresentation made to the Committee on August 17.
At that time, New Hampshire Yankee Vice President of Nuclear Operations, Mr. Ted Feigenbaum, was. presenting a slide and describing the road network in the vicinity of the plant.
He stated:
The major transportation routes that run through the EPZ are Interstate 95 which is an eight lane super highway in the vicinity of the plant.
Route 495 is another interstate which runs east-west; I-95, of course, runs north-south; and 495 is a six lane interstate.
q Then we have major state roads, Route 1, and Route 51-101 which run east-west.
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Mr. Carroll: 'What; kind of roads are they?
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Mr. Feigenbaum:
They.are state roads.
Mr. Carroll:
Lanes?
Mr. Feigenbaum:
Well, Route l'is in many sections a three lane highway around'the EPZ and Route 51-101 is a two lane highway.
In the maior portion of the EPZ it does expand out to four lanes further on out, Route 101-51.
-(Emphasis added.)
The emphasized statement is false.
Route 101-51 is at no point in the EPZ a four lane hichway.
This is something that Mr.
Feigenbaum must know, since Route 51, which becomes Route 101, is indeed the major route between the Seabrook plant and the offices of Mr. Feigenbaum's corporate employer, Public Service Company of New Hampshire, in Manchester.2 The character of Route 51 will be evident in the video tape.
It-starts, as the major west bound escape route from the beach area, as.a very narrow one lane road, known as Church Street.
As will be shown on the video tape, it is obvious that this point, where traffic is supposed to turn from the beach highway, Route 1A, that many vehicles have run into the buildings that stund on the sides of this choke point.
Route 51 then generally parallels the Seabrook plant, and provides full views of the plant for several miles for the 2/.The Committee should be aware that Mr. Feigenbaum recently replaced Mr. George Thomas as Vice President of Nuclear Operations.
Mr. Thomas was asked to leave his position as a result of his being accused of being less than candid in his statements to the NRC after the Tune 22 low power test incident.
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.e evacuating beachgoers.
Only 16 miles from the plant, well beyond the EPZ, does this route become a four lane highway.
Route 95, which Mr. Feigenbaum describes as a "eight lane super highway" (Tr.-36) does cross the EPZ north-south, as he relates,.but Mr..Feigenbaum carefully did not mention the fact, as demonstrated in the SAPL video tape, that even this eight lane j
super highway backs up with traffic in a stop and go condition on summer weekends.
The Committee will see vehicles attempting to l
1 drive on the breakdown lanes, indeed on the shoulder, as the traffic stops as it approaches the barricade-type toll house further north.
ACCIDENT PROBABILITY It is distressing to SAPL that when Mr. Bender of the Committee, at Tr. 18, asked the NRC Staff's project manager:
Dr. Kerr:
Mr. Nerses, what is the likelihood that one will have to use the emergency plan in a serious accident.
Mr. Nerses answered as follows:
"Could I defer that to the Utility?"
One would think that the Agency charged with regulating the utility would have had an immediate answer to the chairman's j
question, and not defer to the supposedly regulated entity.
Moreover, it is surprising that the NRC Staff did not promptly offer the'only possibly correct answer to this question, i
l which is that the accident probability, for purposes of assessing the adequacy of the emergency plan, is one.
That is, in judging L j
the adequacy of an emergency plan, one is to assume that an accident, within the planning spectrum that resulted in NUREG-0654, which planning spectrum includes fast breaking accidents with large airborne releases, will indeed occur.
NRC Staff knows that this is law, and conceded as much in testimony before the ASLB.
Finally, although reluctantly, NRC Staff did acknowledge this basic truth at the Tr. at page 20.
In late 1986, the Seabrook utilities, having apparently decided that adequate emergency planning would be too difficult to achieve for the 10-mile zone, without the participation of the Commonwealth of Massachusetts, petitioned for a rule waiver in order to be able to shrink the Seabrook emergency planning zone from 10 miles to one mile.
The ASLB, in April, 1987, rejected the proposal to shrink the emergency planning zone to one mile, noting 1
that the case for treating Seabrook differently from other nuclear plants had not been sufficiently established on technical grounds.
Accordingly, it is absolutely clear that the law of this case is that Seabrook has to meet the same emergency planning standard as any other nuclear plant, and that includes the assumption that a serious accident, including a fast breaking accident, will indeed occur, and could occur with the barrier beaches at or near capacity. -
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1r THE WEAK LINK SEABROOK EMERGENCY RESPONSE ' PLANNING New Hampshire Yankee's Mr. Feigenbaum-told the Subcommittee I
-on. August 17 that: "there are no weak links 'at Seabrock in terms -
- of the emergency' response' plans." (Tr. 43)
Although Mr..Feigenbaum is an employee-of the proposed-l..
licensee here,-this is nonetheless an amazing statement, given the-n
.' difficulties of the Seabrook site, and in light of some of the L
findings in the Partial Initial Decision.
The weak links at Seabrook include.the following:
1.
The fact. that' of 74 traffic control posts intended to be manned in the New Hampshire Emergency Plan, including both access cont'rol points, and traffic control points, only 13 state policemen can' be assured to be on station two hours' after notification.
Only six' state police are guaranteed for manning the TCP's within one hour.- In other words, it would certainly be proper to characterize the. inability to manage the' traffic control L[
posts only to this limited extent as a " weak link."
(PID 9.71-73, Slip Opinion, pages 260-261) 2.-
The fact that there is no sheltering plan for the many 1
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thousands of beachgoers who may be trapped on the barrier beaches, although the New Hampshire Emergency Response Plan does call for sheltering as the protective response of choice in certain circumstances, including the circumstance when sheltering would l
provide the greatest dose reductions.
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The fact that staffing for the decontamination and reception centers is marginal at best, as the Licensin5 Board found.
The Licensing Board noted as follows:
"Notwithstanding Colburn's [New Hampshire Emergency Services Coordinator from the Department of Public Bealth Services] Confidence that sufficient numbers of DHHS workers would be available to respond to an emergency at Seabrook, the Board believes that SAPL's concerns regarding the availability of DHHS volunteers have merit.
The Board finds that further effort should be made by the state officials to develop a list of workers who, in fact, may reliably be called upon to staff the reception centers regardless of the time of day.
The Board also notes that the FEMA witnesses indicated that call list rosters for local personnel should be made available.
(PID, 5.82, Slip Opinion, p. 108) 4.
The fact that all 13 school teachers who testified before the Licensing Board stated flatly, although reluctantly, that they would not perform the task required of them under the Plan, remaining at school with the school children and then accompanying on evacuation buses, but would first seek to assure the safety of their own families.
5.
The fact that there was no showing that hundreds of school bus drivers needed to drive evacuation buses would be available.
The Applicants, having attempted to show that sufficient members of the local Teamsters Union would be available, and having f ailed in that regard, have now resorted to reliance upon the National Guard, with no showing that the National Guard has the capability to perform this task in a timely manner. l
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The fact that evacuees from Hampton Beach could take as long as six hours to get no further'.; rom the plant than where they started, namely, from the Hampton beach State parking lot to the water tower at Hampton Beach,-at which point they would still be in sight of the-reactor,' the very source of the risk-they fleeing.
L (See attached excerpts from the Tranceript of December 1, 1987) 7.-
The fact that the so-called reception centers were established only to monitor and, if necessary, decontaminate, only about 20 percent of the EPZ population, despite expert testimony that suggested a " vast majority" of evacuees should be provided with this service.
EVACUATION TIME ESTIMATES AND SHELTERING Although New Hampshire Yankee dwells at-length on its chain of command, the emergency classification system, and its hard work with local and state governmental officials, it is less than candid in discussing the critical issue of the actual effectiveness of the plan, as measured by the two major protective actions available, evacuation and sheltering.
At page 155, for example, New Hampshire Yankee's Callendrello stated that the EPZ-wide evacuation time estimate, for a peak summer weekend, was seven hours and five minutes.
However, the Atomic Safety and Licensing Board found the EPZ-wide evacuation to take seven and one-half to eight and one-half hours, a figure that SAPL (and the Massachusetts Attorney General) believe to be a serious underestimate. -
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..x At 19.123,; Slip Opinion, p. 282, the Board found the ETE on a peaktsummer beach day to be eight and one-half hours "and-the reasonably expected ~ peak occupancy would correspond to an ETE of 7:32."-
- No explanation 1 tor the failure of.the Staff of the Applicant--
to' bring this to the attention of the Subcommittee : appears in the transcript.
With regard to sheltering, the discussion on the part of the Staff and the Applicant fails to mention the fact that the dose reduction factors available in the beach housing stock is so low as to be essentially meaningless,'about1.9.
Nonetheless, in the face of these extraordinarily long ETE's, for a beach population of many thousands,: within two miles of and frequently -in sight of the' reactor, and no effective sheltering, the Staff offers no
-conclusion.except that there are "no weak links" in the New Hampshire Emergency Plan.
This is an unconscionable dereliction
-of duty in the part of an agency charged with protecting the public health and. safety.
It signifies that the Staff, notwithstanding the NRC's finding that adequate emergency plans are " essential" to safety, iactually. treats the emergency planning requirement as less than a serious-licensing issue.
EIsb The Subcommittee was presented with a statement by FEMA's Richard Donovan, assigned in 1988 to oversee the FEMA review of the Seabrook Emergency Plan.
It was also told, at Tr. p. 106, i
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that the adequacy of the protection of the beach population was
" supported by the NRC who in their June, 1987 review of the New Hampshire Emergency Plans for the beach population provided the following assessment to the FEMA Regional Assistance Committee, and that's quote:
"New Hampshire provisions for these individuals near the Seabrook site appear to be well advanced in comparison with those at other applicable sites."
It is ironic indeed that New Hampshire Yankee's Callendrello would mention the NRC's favorable report of June 1987, because it was in that very month that FEMA, through its prior official in charge of Seabrook emergency planning, found the New Hampshire plans fundamentally inadequate, because of the problem of the beach population.
There is attached hereto a page of FEMA's Pre-filed Testimony in this matter, submitted in September, 1987, and which concludes as follows:
"Therefore, using the standard guidalice for the initiation and duration of radiological releases, and the current New Hampshire RERP including ETE, it appears that thousands of people could be unable to leave during an accident at Seabrook involving a major releaser of radioactivity without adequate shelter for as much as the entire duration of that release.
Therefore, until these issues are resolved even if the other inadequacies and deficiencies cited in the RAC reviews of the New Hampshire 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 Power Plant are adequate to meet our regulatory standard that such plans ' adequately protect the public health and safety by providing reasonable assurar.ce that appropriate protective measures i
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can b'e taken off-site in the event of a radiological emergency.'"
The Committee should be aware that although FEMA's position on this matter has changed, the facts that support the original FEMA position have never changed, as admitted by FEMA's own counsel.
("In fact, there has not been any new technical information which has caused us to re-examine our earlier position."
(Transcript of ASLB Hearing, Statement of FEMA counsel Joseph Flynn, Tr. 8540-41)).
In fact,.the FEMA about face in this matter came about not as
- a. result of any technical information or new facts that indicated that the New Hampshire Emergency Plan'had magically achieved
" adequacy," but rather came about as a result of a. concerted effort on the part of NRC Staff and the Ipplicants to undercut the prior FEMA position, including a statement made by Executive Director of Operations, Victor Stello, disguised as pretending to be concerned about FEMA's interpretation of NRC's regulations that if-the FEMA position did not change, there would be " total war" between the agencies. (Tr. 13027)
Within a week after Mr. Stello made this statement to FEMA's top official dealing with radiological emergency planning, Grant Peterson, FEMA had initiated a change of position on this matter, culminating in its June 1988 testimony finding that the New Hampshire Emergency Plan was now adequate, merely because it complied with the checklist requirements of NUREG-0654, also found ___________-_ _ _ _ _____ - _ -
in FEMA's regulations at 44 CFR 350.5(a), notwithstanding the even longer ETE's found by the Licensing Board, and the lack of a sheltering plan.
CONCLUSION SAPL since 1979 has been attempting to get the NRC to responsibly address the serious emergency planning problems at Seabrook.
Every time the issue has been presented, the NRC has avoided it, promising to deal with the issue forthrightly and fearlessly at a later time.
That later time is now here, and the NRC Staff is not dealing with the issue forthrightly and fearlessly, but rather is desperately attempting to trivialize the issue, and pretend that the fact of the difficulties at Seabrook will disappear.
It is time for the ACRS to remind the NRC Staff of its primary duty to protect the public health and safety, to realistically look at the f act of thousanc >, of unprotected beachgoers in the Seabrook EPZ during the summar months, and to call for meaningful ameliative measures, such as those suggested by Commissioners Gilinskey and Bradford back in 1981.
l The Committee should strongly recommend that no operating j
license be issued for Seabrook until such measures as improving parking lot exits, additional evacuation-only ramps to the interstates, or additional access roads have been provided.
Anything else would be a serious dereliction of duty, and a condonation of the substantial elimination on the requirement of j
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" adequate" emergency-planning in order to license Seabrook for ful power' operation.
Respectfully submitted, Seacoast Anti-Pollution League By its Attorneys, BACKUS, MEYE4t & SOLOMON
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By:
/W Rober't A. Backus, Esquire 116 Lowell Street P.O. Box 516 Manchester, NH 03105 (603) 668-7272 DATED:
September.6, 1989 I hereby certify that a copy of the within comments has been.
'telefaxed' ? Raymond Fraley, Executive Director of.the' Advisory Committee,n Reactor. Safeguards, copies of the within. comments will be served in hand at the ACRS meeting on September 8, 1989 to the parties attending the meeting, and copies have been forwarded by first-class mail, postage prepaid to the parties on'the attached service list-indicated by an asterisk.
-,$Wf,4*
~
Robert A.'Ba'ckus, Esquire I p
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APPENDIX A
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( 'hf ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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E UNITED STATES ATOMIC ENERGY COMMISSION a
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December 10. 1974 1:
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vg Honorable Dixy Lee Ray a
/A es Chairman th ?D' U. S. Atomic Energy Comission
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Washington. D. C. 20545 W
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Subject:
REPORT ON SEABROOK STATION, UNITS 1 and 2
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Dear Dr. Ray:
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.At its 176th Meeting, December 5-7, 1974, the Advisory Comittee on 1 3; Reactor Safeguards reviewed the application of the Public Service j?.
Company of New Hampshire, et al, for permits to construct Seabrook q@I :@y Station, Units 1 and 2.
This project had been considered previously
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during a Subcommittee meeting in Hampton, New Hampshire, on August' 21-22,
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1974, subsequent to a tour of the site by members of the Committee gj. Y; on August 21, 1974; at the 173rd Meeting of the Committee, September 5-7, g $p 1974; during a Subcommittee meeting in Washington, D. C., October 9, 1974; et the Special Meeting of the Comittee, October 31-November 2,1974; g IF M.. -Y and during a Subcommittee meeting, December 4,1974 During its review, I.O the Comittee had' the benefit of discussions with the' AEC Regulatory Staf f
[7 lY and representatives and consultants of the applicant, the Westinghouse c
Electric Corporation, and United Engineers and Constre: tors, Inc. The f( [g Comittee also had the benefit of the documents listet below and of 3ll
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comments and presentations from members of the public.
- s: W The site for the station is a 750-acre tract, located near the town of n
y,
- g. 3 Seabrook, New Hampshire. The site is approximately 12 miles south-southwest of Portsmouth, New Hampshire and 40 miles north-northeast of g
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Boston, Massachusetts. Portsmouth is the nearest population center with
$_ TE 1970 population of about 26,000. Due to the beach areas of Seabrook and 1
Hartpton, New Hampshire, there is a large sumertime increase in population
%y within a few miles of the site.
E f:s-T.
W The Seabrook Station vill utilize two, four-loop pressurized water reactor Zi nuclear steam supply systems each having a power level of 3411 IN(t) and a lE E design similar te that of the Catawba Nucicar Station units previously
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reviewed by the Committee and reported upon in its letter of November 13, W. 1,.
1973..' a v Ogg. c %4, Q.'i. EI' g' 'K' l fi ~.5 te- ? 1509 $.. ; e
L Honorable Dixy 1,ee Ray December 10, 1974 l i The Regulatory Staf f has determined that the ECCS performance j evaluation for the Seabrook Station units meets the Interim Acceptance j ~ Criteria of June 1971. In addition, the applicant's ECCS performance J evaluation, using an approved Westinghouse model, to show compliance with the Final Acceptance Criteria of 10 CFR 50.46 must be reviewed (' and approved by the Regulatory Staff. - r The Committee recommended in its report of September 10, 1973, on acceptance criteria for ECCS, that significantly improved ECCS [) capability should be provided for reactors filing for construction permits after January 7, 1972. The Seabrook Station units are in y{ this category. These units v111 use 17x17 fuel asse'iolies similar to those to be used in Catawba Units 1 and 2. Although calculated peak + + h clad temperatures in the unlikely event of a LOCA are less for 17x17 assemblies than for a 15x15 array, the Committee believes that the g applicant should continue studies responsive to the Committee's September 10, 1973 report. If studies establish that significant q' further ECCS improvements een be achieved, consideration should be given to incorporating them into this plant. g Although many details of the proposed 17x17 fuel design are avai.lable, rLmple+e analyses of the performance of this fuel arrangement are not t yet available from the applicant, and the AEC Regulatory Staff has not completed its review. The Committee will review and address questions relating to the proposed 17x17 fuel design within the next f ew months in connectie. with operating license applications for other naclear units employing similar fuel. The applicant proposes a horizontal ground acceleration of 0.25g on bedrock at founda'. ion as a seismic design basis for safr. shutdown. Extensive censidr. ration by the ACRS and its consultants of the site, of the foundation structure, and of the relationship of the site to the tectonic prcvince in which it is located has led the Committee to conclude that the proposed acceleration 'is' acceptable for this site. Field and laboratory investigations by the applicant indicate that there are no known geologic features in the vicinity of the site that are likely to localize seismicity. Nevertheless, the Committee believes that all site excavations should be carefu?.ly mapped and any unusual features reviewed by geology and seismology experts of the applicant and the Regulatory Staff prior to being covered over or severely weathered. l l 1510 o
') $h 4 u g. s . 'J y w'T i h ;9 g (:. Honorable Dixy Lee Ray ~3-De c ert.b e r 10, 1974 n M M'D One aspect of the engineered safety features in this plant which 7;f. I-warrants further examination is tha necessity of a cooling system 6 @Z for the charcoal adsorption beds in case of a major accidental release of airborne radioactive material within containment or the ]f; 3, fuel storage building. To assist in resolving this issue, the {y Committee recommends that a parametric study be conducted to i ti p define an upper limit of the source term, to estimate quantita-y Q tively the resulting radionuclides loading on the beds, and to a _1 calculate the subsequent temperature increase as a function of [ IE.' time within adsorption beds of various configurations. If the heat i l y l nM i s nne ton broe, much mtepa as inc.reased air flow through the d@ beds, cooling of the gas prior to entry into the beJ, and rearrange-W: 7. ment of the charcoal configuration within the beds may be adequate, j h The Comittee wishes to be kept informed. d t. p w The Seabrook Station Units 1 and 2 will be the first co:rnercial nuclear power plant in the State of New Hampshire. For this reason, K the Committee recommends that the applicant and Regulatory Staff ? W: give particular attention to assuring proper coordination with q ,j T appropriate state and regional agencies in the development of 3 T effective emergency plans for this facility. Because of the a f; proximity of the Seabrook Station to the beaches on the coast e M i
- ' u' because of the nature of the road network serving the beaches, the T]l 8-applicant has given early attention to the problems of evacuation.
f '4 g The Con:nittee believes, however, that further etttention needs to / ~j . [i~ be given to evacuation of residents and transients in the vicinity j, g: even though they may be outside the LPZ, U 2, g Several unresolved issues, such as appropriate capacity of the j' A containment ventilation system and the containment enclosure transient v. ! Y pressure analysis following a postulated pipe break outside of 1 'l containment, should be resolved in a manner satisfactory to the .] ] Regulatory Staff. y. T i Generic problems relating to large water reactors have been identified 3 E by the Regulatory Staff and the ACRS and discussed in the Committee's y report dated February 13, 1974. These problems should be dealt with -3 y appropriately by the Regulatory Staff and the applicant. s t E' a l 3 - 3 ~:
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.-_---__g, p.s - k y?' / U p.. l.. Honorable Dixy Lee. Ray December. 10, 1974- .The Advisory Committee on Reactor Safeguards. believes thatLthe items mentioned above can.be resolved during construction and' that, if due consideration is given to the foregoing, the Seabrook Station Unit's 1 and 2:can be' constructed with reasonable ~ assurance that--it can be operated without undue risk to the health ~ and safety of the public. Additional recaska 'uy Dr. D. Okrent ar6 attachtd. Sincerely yours, / W. R. Stratton Chairman References attached h 1512
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j 4 i 9 4 h. !r Fi Honorable Dixy Lee Ray December 10, 1974 Additional cotments by D. Okrent 0: 4 7 The Seabrook Station site is near what is generally recognized as the [, Cape Ann-to-Ottawa Trend. Mechanisms for earthquake generation in fj the New England area are not vell understood, and expert opinion p differs concerning the potential for and probability of relatively ( 3 large earthquakes at or near the site. I,d. _I .{5 The Regulatory Staff have ultimately based their judgment as to an acceptable safe shutdown earthquake on the application of 10 CFR e [ ' [] Part 100, Appendix A, rather than a probabilistic estimate of p earthquake size versus recurrsnee interval. It is of interest to 'gl note that Appendix A provides ocly general guidance; furthermore, it specifically refers to the possible choice of a safe shutdown 2 earthquake larger than that found in the historical record for a j u tectonic structure or province. d During the ACRS review the Regulatory Staff did state that the s seismicity of the tectonic region applicable to the Seabrook site could be interpreted to be about an order of magnitude larger than ,j other tectonic provinces having a similar maximum historical seismic event. Furthermore, a member of the Regulatory Staff stated that j i his estimate of the probability per year of occurrence of an earth- } quake of intensity MM VIII at the Seabrook site is about 10~4, and j~ the Staff did not rule out the possibility of a larger earthquake j occurring within the region under consideration. They stated that conservatism in analysis, stress limits, and other factors decrease f' _ _ and piping by a few orders of magnitude and hence, the overall the overall probability of failure of seismic Class 1 structures a(r probability of a seismically induced accident exceeding 10 CFR j Part 100 would be acceptably low. However, earthquakes are almost i unique in their ability to fail each and every structure, systen, = component, or instrument important or vital to,s,afety, and, in my j opinion, the Staff evaluation of additional margin available from stress limits, methods of analysis, etc., did not consider all such 1-systems, e.g., D.C. power or emergency A.C. power. 1 j It is clear that the capability of a reactor to achievt safe shutdown, i assuming its SSE occurs, cannot be fully demonstrated by test. Those limited, detailed independent audits of seismic design of actual i plants that have been published indicate that some inadequacies in design and construction exist. Equally or more important, it appears to be unlikely that the plant could survive safely, with a I' high degree of assurance, a larger earthquake having one or two 1 orders of magnitude lower probability than the proposed SSE. I 1513
t hii -;>: p L Honorable Dixy. Lee Ray December 10, 1974-1 - Additional comments b= D. Okrent (continued)' i Given'this background, and recognizing the substantial surrounding j1 year-round. population density and. the very high nearby population i' during the' summer months at Seak-nok, I am lef t uneasy and believe it would.be. prudent to augment tne~ proposed SSE acceleration of. p 0.25g.- y p I also wish to reiterate my conclusion previously_ stated in con ' nection with the-review of Grand Gulf Units 1 and 2, namely that i. .it veu d be pru ent te provide ec== =dditienal =:rgin in the l d seismic design bases for most future nuclear plants sited east of the Rockies. e 8 6 1 l 1 1514 ) ( j
}- e: i: M 'i Honorable Dixy Lee Ray December 10, 1974 e
References:
'5 1. Public Service Company of New Hampshire Application for a ] f-Construction Permit for the Seabrook Station with Preliminary 7,'. Safety Analysis Report (PSAR), Volumes 1 through 7. 2. Amendments 1-13, 15-19, and 21-26 to the.PSAR.
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Directorate of Licensing's Safety Evaluation of the Seabrook Station, Units 1 and 2, dated August 14, 1974; Supplement 1, dated August 20, 1974; and. Supplement 2, dated October 8, 1974. 4. Directorate of Licensing's Summaries of Outstanding Safety-Related issues for the Seabrook Station, Units 1 and 2, dated 2 August 16, 1974; October 9, 1974; and October 31, 1974, L-respectively. -x) 5. Public Service Company of New Hampshire letters: b a. October 23, 1973, concerning transient beach population. i ^! b. Decesber 21, 1973, concerning waste processing system. (_" c. December 26, 1973, concerning geology-tegional fault y; investigations. j a-d. October 1,1974, concerning anticipated transients without f[. scram and reactor protection system. 4j-6. New England Coalition on Nuclear Pollution letters: ?[ a. August 15, 1974, concerning seismic issues and population ^ t; jyj density and evacuation. av b. October 25, 1974, concerning site characteristics, geology 1[ and seismology. f c. December 2, 1974, concerning seismology, c.jj! d. December 5, 1974, concerning seismology. 7 7. Elizabeth H. Meinhold letters:
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August 13, 1974, concerning seismology, geology, and 3 y C #. evacuation. i ;] b. Undated (received October 3,1974) concerning safe shutdown '7 earthquake design value. c. October 21, 1974, concerning earthquake intensities. fi ll = s ' u. I j h 9 kU $ hf ~ B,d is. CW -l. Wh..*. I ' P' 1515 j V;, L 7 G.: fu-___
APPENDIX B 6E UNITED STATES NUCLEAR REGULATURY COMMISSION 1 ATOMIC SAFETY AND LICENSING BOARD 2 Sec50T?. .l ,s ) 4 In the Matter of ) Docket Nos. ) 50-443-OL 5 PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, et al., ) 50-444-OL ) OFF-SITE EMERGENCY 6 (SEABROOK STATION, UNITS 1 AND 2) ) PLANNING 7 8 EVIDENTIARY HEARING 9 i S
- Monday, Decetaber 1, 1987 10 a
i Hall of Representatives 11 New Harapshire Statehouse Concord, NH 12 13 The above-ent it led raat t er carne on for hearing, 14 pursuant to notice, at 9:15 a.ra. 15 I BEFORE: JUDGE IVAN W. SMITH, CHOIRMAN Atoraic Safety and Licensing Board 16 U. S. Nuclear Regulatory Coraraission 17 Washington, D. C. 20555 ~~ JUDGE JERRY HARBOUR, MEMBER 18 Atoraic Safety and Licensing ' Board 19 U. S. Nuclear Regulatory Coraraission Washington, D. C. 20555 .\\ 20 JUDGE GUSTAVE A. LINENBERGER, J R., MEMBER ) Atoraic Safety and Licensing Board 21 U. S. Nuclear Regulatory Coraraission 22 Washington, D. C. 20555 23 24 25 Heritage Reporting Corporation (202) 628-4888 n
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sp/ *go j@ PANEL NO. 7 - CROSS 671 L _0 nearing and again today, you talked about the saturated 3 condition of the roadways being the critical factor. Do I g understand your testimony correctly that on the beaches, and focusing particularly on Seabrook and Hatapton Beaches, so li ra i of those long as the roadways -- the taeans of egress out 5 6 beaches are saturated, that the trip generation times are 7 actually irrelevant? i 8 A (Lieberman) They are irrelevant so long as they 9 don' t extend beyond the evacuation tiraes associated with the 10 saturated traffic movement. In other words, if it takes six 11 hours, to cite a figure, to evacuate say Harapton Beach, so long 12 as a trip Deneration tirne does not approach that figure, 13 anything less than that would have no effect on evacuation 14 t irae. 15 O Is that your figure, six hours? 16 A (Li ebertaan) No, I just picked it out. It's not far 17 f rora the t ruth, but I used a round nuraber. 18 Q I was going to suggest that it was five and a half 19 hours; that that was say recollect ion of your test iraony. 20 A (Liebertaan) Yes, that's right. I used that as an 21 e x arapl e. 22 O Okay, but I' ra not asking you to accept say est iinat e. i 23 I' ra asking you what your est itaate is. 24 A (L i e berinan) Five and a half hours ray recollect ion 25' says is about right. We also looked into the study conducted Heritage Reportind Corporation (202) 628 4888 3
t F s .,n 1 PANEL NO. 7 - CROSS 6725' 1 by HMM wherein they took,ATR counts throughout the surnrner, and ; i-2 corapared the nuraber' of vehicles which exited the beach areas 3 over' a si x-hour per'iod under norraal tiraec when you have 4 substantial inflowing volutae and found that it was comparable S to the nuraber of vehicles that would exit over that period of tL t irae during evacuat ion. 7 So effectively what I'ra.saying is the available data 8 derdonstrates that the existing highway systera can in fact 9 service the ' nuraber of ent iraated cars on the beach at a peak l 10-point within the t ira e fearne ect iraated by the I-DYNEV model. l 7 11 (Continued on next page.) 12 13 14 -i 15 16 17 18 1 19 20 ^ 21 22 23 I i. 24 i 25 l i Heritage Reporting Corporation i (202) 628-4888 c. b W.
y PANEL NO. 7 - CROSS sq[ 1 Q So.the number is five and a half hours i n -- J'.$a ...s t s' 3 A (L i ebertaan) To ray recollect ion, that sounds right. d, 3 Q And that assuroes a vehicle populat ion -- I think that the nuraber was about 26,000? 5 A ( L i ebertaan) Well, the five and a half hour figure, 6 and it raay be higher with the now Avis figures, raay be closer 7 to six hours. 8 We use the projected. figure chown on Page 28 of the 9 direct testiroony of 29,300 roughly. 10 Q Okay, so the five and a half hour figure, which you 11 have just given us, relates to a vehicle population of 29,3007 ( 12 A (L i e bertaa n) No. 13 Let rae call your attention to Page 10-11, which is 14 Table 10-9, shows the ent iraat ed t irae to evacuate the beach 15 areas, and it shows five hours and 40 rainutes f o r-Harapt on. And 16 that is baced on our previous 'ect irante, of vehicles at the 17 beach, which in turn, relied upon our projection of reasonable 18 upperbound, or peak populat ion on the beach, baced on the 19 August lith, 1985 filrau. 20 We have since updated that i n forraat i on, using the 21 Avis photos. We now have a higher count of vehicles on Harapton 22 Beach, and I ara sure that translates into a longer tirae to 23 evacuate the beach area. 24 I f yot.t give sae a few rai nu t.es, I can look that up if 25 you like. But I would say that is probably in the neighborhood J t Heritage Reporting Corporation (202) 628-4888 I A t s ( h I l mm- _
u. M ,f PANEL NO. 7 - CROSS 6715 f (. ;. ~ s 1 of six or over six hours, at this point. , /,' i Q No, it is not necessary for say purposes that you give 2 rae an exact nusaber. .It is enough that you would agree the raor'e 4 vehicles there are, beyond the nuraber you assurned, the l orig e r-5 the evacuation tirae. 6 A (Liebertaan) The taore vehicles ther'e are on Harapton 7 Beach, yes. 8 Q Now, I want to clarify what, where the vehicles ar'e, 9 at the end of that period of tirae. 10 In your' dir'ect t est i raony, in the previous-weeks of 11 the hearing, you talked about the tirae it takes for' the i 12 vehicles to get off the beach and you identify being off the 13 beach, with being, as I reraeraber' it, at the point where the 14 raarshes start. i 15 Have I ruraetabered your' tcctiraony corr'ectly? 16 A-(L i ebertaan) That is close enough. 17 Q Okay, you are looking at the phot ogr'aph behind you, 18 and I was going to suggest exactly that. In the upper 19 right-hand corner of the photo on the right, let's use the i 20 water tower as a point of referen'ce. 21 Do you see that? 22 A (Lieberraan) Yes. 23 Q A r.d is that the point that you were referring to, 24 when you talked about being off the beach? 25 0' was it that U-shaped intersection, a little bit to [ Heritage Reporting Corpora. ion (202) 628-4888 3 [ s. i E 1 i 1 Y .4 I 1
( PANEL NO. 7 - CROSS ypp f.% )i i the want? r 2 A (Lieberraan) Well, to be precise, what we do as we 3 g at h e r-data on a link and we ask, when does that link etapty P 1 4 out? A rid I would say the water tower is pr'obably a good l l 6 l aridntar k for' the: point where, which we used as a t'eference to 7 gather these figur'es. 8 Q So the five and a half hour figur'e refers to the 9 point i n t irac, when all of the vehicles on Harapton Beach have 10 passed the water tower? 11 A ( L i e berraa n) That is r'ight. 12 It includen the assurapt ion that every vehicle that i 13 actually there, i s, in fact, used to evacuate. 14 O And let rae go back, for' a raornent, to one of ray 15 earlier questions. 16 We wur'e talkirig about the t'elat iorishi p bet ween t r'i p 17 generat ion t irae and evacuat ion t irae, under sat ur'ated 18 cor d i t i or.c. 19 1 used sorae cordplicated str uct ur es in ray sent ences, 20 a rid I wanted to raake it s i tap l e r', so that it is easier to 21 u rid e rc t ar.d it when we go throutjh the record later. 22 What you are saying, as I understand it, is if it 23 takes five and a half hours to get off the beach, then it 24 doesn' t rauch raa t t er', wh et h e r-it takes people 10 rainutes or 25 three hour's to get irito their cars. Heritage Reporting Corporation (202) 628-4888
~1 ~r-r APPDJDIX C I; i. (24ITED STATES T AMERICA '.y NUCLEAR RKULA20Rf COMMISSICN ?), BEFORE ' DIE AIOMIC SAFETI AND_LICD1 SING BOARD 1 ) )- In the Matter of ) ) Ebeket No. 50-443-OL Public Service Co. of New Hat.pshire, 50-444-OL ) et al. ) Offsite Dnergency (Seabrook Station, Units 1 & 2) ) Planning Issues ) FDR PRE-FILED TESTDCTI The Federal Emergency Management Agency (FEMA) hereby serves on the parties to this proceeding its prefiled testirony on contentions on the FD% notes, for the New Hanpshire Radiological Emergency Response Plan. record, that its review of issues addressed thereiri is ongoing. 4 -q/r.,..x.'. Q. e: 4 t e. H. Joseph Flynn Assistant' General Counsel Federal Emergency Management Agency l Washington, D.C. Septerter 11, 1987 i
C i l 39. i / 2C? CCCirC:: 2_'S-S (Cont. ) (1) The primary cuidance dorument used by FEMA and the PAC in reviewing off-s ice emergency plans is SUREG-0654, FEM REP-1, Tev.1, a doct. ment jointly developed by FEM and the NRC. ' hat guidance l document indicates on p.13 that "(t)he range of times between j the onset of accident conditions and the start of a major release is of the order of one-half hour to several hours". This statement j is further clarified on p.17, Table 2 to indicate that (a) the { major portion of a release may occur in a time period ranging from as little as one-half hour to one day after the release begins and (b) that the travel time of the release to exposure j point can range fram one-half hour to two hours at five miles, and one hour to four hours at ten miles. l On peak str:mer days there are thousands of beachgoers in the (2) Seabrook EP2 in areas beginning approximately 1.7 miles frem ne current New Hampshire plans contemplate evacuating the plant. the many thousands of beachgoers who have access to no adequate shelter as a protective action in the event of an accident at Seabrook. l We understand that the plans contain no consideration of sheltering ay trippers" because on su::mer days when there are a large t gh number of these people, it is not conible to find reasonably accessible shelter for them. Dere are an additional number of persons who would be in or have access only to shelter in unwinter-ized cettres and tx*al - _ The protection afforded by shelterinc 'in these structures will definitelv be less than that ~ afforded by a normal wood frame house. [ The Evacuation Time Estimate for the Seabrook EP2 subnitted by the (3) State of New Hampshire indicates at pp.10-1 et.sec. that in goed weather when the beaches are at 60 to 100 percent of capacity it will take three and one-half hours to clear the beaches, and a total of fran four hours and fif ty minutes to five hours and fifty minutes to evacuate all the population on the besches from In sone situations such as sudden bad weather following the EP2. a peak str:mer day, the total evacuation time for portions of the EPZ range up to seven hours and fifty minutes. Therefore, using the standard guidance for t'he initiation and duration of radiological releases, and the current New Hampshire RERP including ETE, it appears that thousands of people could be unable to leave during an accident at Seabrook involving a major release of radioactivity _without' _ adequate shelter for as much as the entire duration of that release. Thererore, until these issues are resolved even if all the other inadequacies and deficiencies cited in the RAC Peviews of the New Hampshire Plans, and the Peview of the Exercise of these plane were to be corrected, FEMA would not be able to conclude that the New Hampshire State and local clans to protect the public in the event of an accident at the Seabrook L;1 ear Fewer Plant are adequate to meet our regulatory 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)). d .y
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l V iv & W, Scith,-!Chr.irman' Suzinnt Broiseth IThonos Dignen. Esquira ( l Atomic;Sdisty cnd-Board of Salectm:n . Ropes!& Gray. ,'Lic1nsing Board Town Hall' -One International Place % US(NRC., One Drinkwater Road Boston, MA. 02110-2624
- k. N W.:shington, DC 20555 Hampton Falls, NH 03844-0;;;
Kennsth A..McCollom f Docketing & Service Sec. g Jane, Doughty LAtomic Safety and . Office of.the Secretary -SAPL tLicensing' Board US NRC 5 Market Street
- US NRC-Washington, DC 20555' Portsmouth, NH 03801.
.W3chington,.DC 20555 ) Geoffrey Huntington, Esquire .. Office of Selectmen Richard F. Cole g'AttorneyGeneral'sOffice Town of Hampton Falls Atomic' Safety and Licensing 1Hrmpton Falls, NH 03844 Board-State House Annex US.NRC Concord, NH 03301 Washington, DC.20555 oM12hodN.Amirian,' Esquire f Joseph Flynn, Asst. Gen. Cnsl. g Sandra Gavutis -l 145' South Main Street Federal Emergency Town of Kensington P.O.-Box 38 Management Agency Box 1154 -Bradford, MA 01835~ 500 C Street SW East Kensington, NH 03827 Washington, DC 20555- ~[JohnTraficonte,, Esquire . g Sherwin E. Turk,' Esquire
- Charles P. Graham, Esquire A2sistant Attorney General
. Office of Exec. Legal Dr. Murphy & Graham Ont Ashburton-Place US NRC
- 33. Low Street 19th Floor Washington, DC. 20555 Newburyport, MA 03950
-Boston, MA 02108 / R., Scott HillrWhilton, Esq. Judith H. Mizner, Esquire p William S. Lord 79 State Street 79 State Street Office of Selectmen Nawburyport, MA- 01950 Newburyport, MA 01950 Town Hall Friend Street Amesbury, MA 01913 ..[DisneCurran, Esquire Paul McEachern, Esquire gSenatorGordonJ.Humphrey H1rmon, Curran & Tousley Shaines & McEachern US Senate 20001 S Street NW 25 Maplewood Avenue Washington, DC 20510 Suite 430 P.O. Box 360 Attn: Gordon Mcdonald f Washington, DC 20009 Portsmouth, NH 03801 I af
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