ML20247L761
| ML20247L761 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/15/1989 |
| From: | Traficonte J MASSACHUSETTS, COMMONWEALTH OF |
| To: | |
| References | |
| CON-#389-9184 OL, NUDOCS 8909250057 | |
| Download: ML20247L761 (39) | |
Text
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s, 1:D(KETED UNITED STATES OF AMERICA NUCLEAR REGULATORY. COMMISSION ATOMIC SAFETY.AND LICENSING 7' 7AL BOARD Before Administrative Juuges:
QFil rn G. Paul Bollwerk, Chairman Alan S Rosenthal Howard A.
Wilber
)
In the Matter of
)
Docket Nos. 50-443-OL
)
50-444-OL PUBLIC SERVICE COMPANY
)
OF NEW HAMPSilIRE, EI AL.
)
)
-'Nobrook Station, Units 1 and 2)
')
September 15, 1989
)
COMMENTS OF MASSACHUSETTS ATTORNEY GENERAL ON APPLICANTS' RESPONSE TO-APPEAL BOARD ORDER OF AUGUST 30, 1989 The Massachusetts Attorney General (" Mass AG") submits these comments in~ response to the Applicants' September 7, 1989 Response (" Response") to this Board's August 30 Order concerning the evacuee load calculations at the four New Hampshire reception centers.
These comments are organized around four interconnected, although separable, issues:
1.
If an emergency plan geographically divides an evacuating population into four unequal parts and assigns each
~~
~
part to a different reception center, does increasing the staffing at the cente.] to which the smaller portions of the evacuating population are assigned so that those centers could 1
l handle the same number of evacuees as are sent to the busiest i
center actually increase overall the percentaae af the evacuatina oooulation that could be monitored oursuant in that 213.D7 3
8909250057 890915
{0 PDR ADOCK 05000443 PDR-g
.e - -
2.
What are the formulae and the set of calculations necessary to arrive at the peak population ("Pp") totals for each New Hampshire EPZ community assigned to each of the four host communities as set forth on page 3 of the Response?
What inputs were used in these calculations?
Why does the peak population for Hampton (assigned to the Dover center) which is stated as 22,647 include over 8,000 transients who are actually located on the northern portion of Hampton Beach, particularly when the Response at 3 identifies Hampton Beach as a separate pP entry (total PP - 23,609) and assigns its transient population to a different reception center, i.e.,
Manchester?
In light of the fact that the pre-emergency information calendar and the pre-scripted EBS messages in the NHRERP both identify Manchester as the reception center for Hampton Beach y_isitors, how reasonable is it for purposes of calculating evacuee load capacity to assign over 8,000 persons who would be Hampton Beach visitor's to the Dover reception center?
What is the impact on the purported " conservatism" of the NHRERP reception center staffing when these 8,000 persons from Hampton Beach are allocated (as they should have been) to the Hampton Bea,ch PP (23,609) set forth under the Manchester center on page 3 of the Response?
3.
How reasonable is it in December, 1988 (or for that l
matter in September, 1989) to calculate the actual percentage 1
of the total evacuating population which can be monitored by using peak population numbers which are themselves based on resident population figures projected for 1986 from early 1985 town clerk estimates as to each town's permanent population?
I - - _-_.
6-(App. Exh.L5, Volume.6 at 2-3 and Table 2-1.at 2-9)
How reasonable is this when the record contains an expert's uncontradicted permanent resident population forecasts for each New Hampshire EPZ community for 19887 4.
How reasonable is it to calculate the actual percentageLof'the total evacuating population which can be monitored when the total evacuating population figure is based on" peak' population numbers which are themselves based on Applicants' 29,293 total EPZ beach vehicle estimate which the Licensing Board rejected in a different portion of its. opinion?
What is the impact on the purported " conservatism" of NHRERP reception center planning, when the peak beach vehicle estimates as found by the Board and the corresponding peak beach population estimates are used to calculate the peak populations for each EPZ community as set forth at page 3 of the Response?
1#
Issue-1:
The Applicants and the Licensing Board reasoned that the fact that the largest number of evacuees expected at any one center was used as a planning basis for all centers supports the inference that the " planning basis works out,to be about 25% of all evacuees."
This reasoning is deeply flawed:
l
~
a)
The traffic management plan and the Applicants' ETE 1
study (Applicants' Exhibit 5, Volume 6) are based on a set of evacuation routes or paths for the evacuating population.
The 1/
The Board's statement in 15.9 conerning an actual planning basis of 25% is taken verbatim from Applicants' March 1, 1988 Proposed Findings at 15.1.19 at 66-67... - _ - _ _
a4
- ~
allocation of evacuating populations to four different centers
. reflects the different evacuating paths for different portions of population depending on their point-of origin.
(Attached as
' Exhibit 1, hereto, is a shaded (originally colored) portion of.
the Public Information Calendar which visually demonstrates l
this point.)
Thus, the fact that the Rochester teception center to which is assigned the evacuating population of Portsmouth is actually capable of handling 9,667 evacuees (the largest number expected.at any one center, Response at 2) really only means i-that the Applicants have the capacity tu monitor 30% of the peak population qf Portsmouth (9,667 31,906).
Aggregating, 1.
L as Applicants have done (Response at 10), this higher than 20%
capacity with a center (e.g., Manchester) which can handle only 20% of the population of the geographic areas assigned to it to arrive at an " average" total percentage does nni reflect a l
larger overall 25*5 planning basis at ell.
The " average" is a statistical truth but a real-world falsehood.
It would be reasonable only if either:
- 1) excess populations over 20%
l arriving at Manchester (the highest load center) were sent to the Rochester center, or 2) excess staff and resources at Rochester were sent to Manchester if needed there.
The NHRERP i
contemplates neither course of action.
The simple fact is that of the peak population which is assigned to Manchester, the Applicants' own numbers suggest that staff and resources exist to monitor only 20.5% within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
(As explained below, this percentage is calculated by Applicants using incorrect data and is much lower than 20.5%.) l-
l
~
the' aggregation'of.the four b)
- More fundamentally,
- centers separate capacities (Manchester =.20.5% (9,667
- 47,147);. Dover = 21.6% (9,667
'44,552); Salem = 31.5% (9,667
~
30,674)' and Rocliester = 30.2% (9,667 3
31,906)) to arrive at the 25% capacity (Response at 10) ignores the obvious fact L
that the~EPZ population's need for monitoring will not be evenly distributed across the EPZ.
Obviously, the' populations L
closer to the. reactor.who take longest to evacuate will disproportionately receive dose as compared to a population near'the EPZ boundary.
(The technical support for this statement is, in part, the basis of ALAB-905's determination that FEMA had an succort for its 20% EPZ-wide planning basis.)
.Thus, the population of Portsmouth is unlikely to need a per capita monitoring capacity equivalent to that needed by the close-in beach populations of Hampton and Hampton Beach.
- Thus, not only does the capacity to monitor 30% of the population of Portsmouth at the Rochester center not help the evacuating populations arriving at Dover or Manchester, but the extra capacity at Rochester is being placed at the location where it is least likely to be needed by any portion of the EPZ population.2 Issue 2:
Turning to page 3 of the Response we find peak
~
population ("Pp") estimates for each EPZ community.
Applicants on pages 6-8 provide an incomplete account of the derivation of 2/
The " extra" capacity at Rochester may still be needed, however.
The Mass AG does not believe that 30% of any portion of the EPZ population is a sufficient planning basis in light of the overall Seabrook EPZ-wide summer ETEs.
The point here is that it is clearly irrational to add extra capacity (from 20% to 30%) at precisely those centers which are comparatively less likely to need that capacity. _ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _
~ these estimates..In fact, the PP estimates for all New Hampshire EPZ towns are substantially vehicle-based and can be reproduced.using evacuating traffic demand data in theLrecord.
The PP' formula for each town is as follows:
PP = (permanent residents' vehicles)A x (2.6) + (beach and non-beach transients
- vehicles)A# x (2.4) +-(non-EPZ resident employees' vehicles) x (1.16).
To illustrate this formula, we take two examples:
the first a "non-beach" town '
E and the second a town which has a beach area.
Applicants assert that Kensington has 1,564 persons who should be counted Eus part of the summer weekend peak evacuating population (Response atn3).
Although Applicants cite " Table 1" for this information, it also can be calculated in accordance with the above formula using the traffic demand data in Appl. Exh.
5,
' Volume 6, Appendix M, Traffic Demand for Scenarios 1 and 2 (summer weekend), M-1 through M-5, 1/
" Permanent vehicles" are vehicles owned by permanent residents.
In communities which border the seacoast (" beach towns"), the residents live in both non-beach areas and in beach areas.
When they are present in beach areas, they must be subtracted from the aerial-photo-based beach vehicle counts to arrive at an accurate transient beach vehicle count.
A/ ' Transient vehicles exist in beach and non-beach areas of the New Hampshire EPZ.
Beach transient vehicles are the only new input from the July, 1987 data the Applicants used in calculating the PPs set forth on page 3 of the Response.
I 5/
There are 17 municipalities in the NH EPZ.
The Response at 3 lists "Hampton Beach" as if it is a municipality.
All of Hampton Beach lies within the municipality of Hampton.
l Further, Hampton Beach North and Hampton Beach South (Egg App.
I Dir. No.
7, ff. 5622 at 38) are both part of Hampton and are l
areas geographically distinct from North Hampton and the beach area of North Hampton. _ _ _ _ - _ _ _ _ _ _ _ _ _ -.
v PP = (533)E# x (2.6) + (74)1/ x (2.4) + (0) x (1.16)
=
1,386 +'178 + 0 1,564 persons.
To calculate PP for a beach community is somewhat more complicated but follows the same formula.
Appli; ants assert that North Hampton has 5,526 persons who should be counted as part~of the evacuating population (Response at 3).
The i
calculation is as follows:
(593)E' x (2.4) + (407) x (1,399)E x (2.6) +
PP =
L (1.16) - 3,637 + 1,423 + 472 - 5,532 persons.
l f/
The " permanent residents' vehicles" input is derived from the Kensington portion of Appendix M, page M-3 to Volume 6 of the NHRERP (Applicants' Exhibit 5).
Attached as Exhibit 2 i
hereto are pages M-1 through M-5.
It appears that 533 l
permanent' vehicles were estimated for Kensington based on 1985 l
town clerk data projected to 1986.
Volume 6 at 2-3 and Table j
i 2-1 at 2-9.
These 533 vehicles are positioned at two different
" origin centroids" (Nos. 2026 and 2027) which are placed.on the link node diagram at the geographically appropriate place, l
i.e.,
within the boundaries of the municipality of Kensington.
I l
(The link node diagram is in Volume 6 at 1-13 and the only i
relevant marks are the red origin centroids.
These origin centroids reappear and are identified for each municipality on l
pages M-1 through M-5 attached hereto.)
1, The transient vehicle count for Kensington does not include any beach transients.
Thus, the total transient vehicles on l
M-3 (Exhibit 2), 74, is used.
Similarly, M-3 identifies no non-EPZ-resident employee vehicles.
H/
Again, M-3 sets forth the origin centroids for North Hampton and indicates that 1,399 vehicles belong to the permanent resident population.
Similarly, M-3 sets forth the non-EPZ-resident employee vehicle count used.
2/
This car count number reflects the Applicants' new beach vehicle counts derived from the July, 1987 Avis Airmap aerial photos.
To' understand it one must first take the beach vehicle count for North Hampton set forth at App. Dir. No.
7, ff 5622 l
at 38.
This number is 308.
Next, one identifies and locates i
the origin centroids in North Hampton (as set forth on M-3) on the link node diagram (Volume 6 at 1-13) to determine which centroid (s) are beach area origin centroids.
For North Hampton j
there is only one origin centroid in the beach area, No. 2109.
l Next one subtracts from the beach vehicles counted by aerial -
1 Now that the formula and the source of the inputs for calculating PP for each New Hampshire town as set forth on page 3 of the Response is clear, we turn to the PP for Hampton Beach (23,609) which population is assigned to Manchester and the PP for Hampton (22,647) which is assigned (at least on page 3 of the Response) to Dover.
The Applicants' Hampton Beach calculation is as follows:
l (0)12#
(9,675)11' x (2.4) +
(230)1E x (2.6) +
x PP =
1A' (1.16) = 598 + 23,220 + 0 = 23,818 The Hampton calculation is as follows:
2/ (Cont.) photo the number of " permanent" vehicles in that same beach area to avoid double counting these vehicles.
M-3 indicates that centroid 2109 contains 140 permanent vehicles.
Thus, 308 - 140 = 168.
To this number is then-added the remaining non-beach transient vehicles for North Hampton as set forth on M-3.
This number is 425.
(The beach transient vehicle total for North Hampton - 180 transient vehicles at centroid 2109 - is subtracted from the transient vehicle total - 605 -
425.)
Thus, 425 + 168 = 593.
1D/
There are four origin centroids for the Hampton Beach area.
These are 2105, 2106, 2107, and 2108.
See M-3 and link node diagram.
Three of these centroids contain the vehicular beach population above a geographic landmark called " Great Boars Head" (2106, 2107, and 2108) and one contains the beach vehicular population below Great Boars Head (2105).
The Hampton Beach areas above and below Great Boars Head are also called Hampton Beach North and Hampton Beach South by the Applicants.
App.
Dir. No.
7, ff. Tr. 5622 at 38.
The Aeolicants are counting
~
only Hamoton Beach South in their PP for Hamoton Beach as it acoears on oa'ae 3 of the Response.
The centroid for this beach area (2105) identifies 230 permanent vehicles in the beach area, so that number is used here.
11/
The Avis Airmap count for Hampton Beach South is 9,905.
App. Dir. No.
7, ff. Tr. 5622 at 38.
Subtracting the 230 permanent vehicles to avoid double counting results in 9,675.
12/
M-3 indicates that no employee vehicles are identified at l
the Hampton Beach South centroid.
13/
The Mass AG cannot explain the disparity between 23,818 and the 23,609 figure on page 3 of the Response. l
\\
l
(3,864)1E x (2.4) +
(4,860)1A
.x (2.6) +
PP -
12#
(706)15# x (1.16) = 12,636 + 9,274 + 819 - 22,729 From these calculations we can determine that'the Hampton PP on page 3 of the Response (22,647) actually contains over 1E/
8,000 beach transients who are located on northern Hampton Beach but not counted in the Hampton Beach total of 23,609.
14/
The " permanent" vehicles for Hampton as set forth on M-3 minus the 230 at centroid 2105 counted in the pp for Hampton Beach.
5,090 - 230 - 4,860.
15/
This transient vehicle count has two parts:
one non-beach and one beach.
For the non-beach transients, one simply adds together the " transient" vehicles for each non-beach centroid for Hampton identified on M-2 and M-3.
(One excludes centroids 2105, 2106, 2107, and 2108).
This total is 978 vehicles.
To this number is added the Avis Airmap beach vehicle count for Hampton Beach North (3,352 vehicles, App. Dir. No.
7, ff. Tr.
5622 at 38) minus the permanent vehicles in the same beach area (centroids 2106, 2107, 2108 = total of 466).
3,352 - 466 -
2,886.
2,886 + 978 = 3,864 beach and non-beach transient vehicles for Hampton and the north beach area of Hampton.
15/
M-3 indicates that there are 706 non-EPZ-resident employee vehicles for Hampton and that none are in beach centroids.
12/
The Mass AG cannot explain the disparity between 22,729 and the 22,647 figure on page 3 of the Response.
Although the determination that origin centroid 2107 is a beach area centroid may be incorrect (Eng link node diagram, Vol. 6 at 1-13) the relatively small permanent and transient vehicular numbers involved for that centroid do not explain the disparity and otherwise do not affect the general accuracy of this Mass AG reconstruction of the Applicants' PP calculations for Hampton and Hampton Beach.
1H/
The total for the population of that part of the Hampton Beach area counted by the Applicants as part of the Hampton PP is calculated as follows:
+ (beach " permanent" (beach " transient" vehicles)(2.4) vehicles)(2.6)
=x From the numbers set forth above, it is clear that:
(2,886)(2.4) + (466)(2.6)
=x 6,926 + 1,212 - 8,138 persons in northern beach areas of Hampton Beach counted as part of Hampton and nat Hampton Beach on page 3 of the Response. L_________-______-____.
1E#
Obviously, if these 8,138. persons are added to the Hampton Beach: total.of 23,609_and are allocated to the Manchester reception center, the existing present capacity of that center
~
L (9,667).will no' longer represent.20.5% of.the evacuating population directed to that center.
Instead, the planning basis would actually be 17.4% for the very center'likely to receive the highest percentage of total evacuees for monitoring because of the proximity of Hampton and Hampton Beach to the reactor.
In fact, it is clear that all of the Hampton Beach
. transients ara directed in accordance with the;NHRERP to the Manchester center.
First, attached as Exhibit 3 is a copy of page.4 of the Public Information Calendar (Applicants' Exhibit
- 5) which indicates that " visitors to Hampton Beach go-to the Manchester reception center."
Much more significantly, the EBS messages contained in Volume 4 to the NHRERP (Applicants' Exhibit 5) make clear that the State of New Hampshire is planning on sending all of the Hampton Beach transients to.
Manchester and not a substantial portion to Dover as Applicants indicate on page 3 of the Response.
Appendix G to Volume 4 of the NHRERP contains a set of prescripted EBS messages.
Message F s.tates:
11/
The above calculations make clear that no double counting is involved.
The Avis Airmap numbers are broken out for Hampton Beach north and south and the issue here is allocation I
and not double counting.
App. Dir. No.
7, ff. Tr. 5622 at 38.
Moreover, Volume 6 itself proposed the division of the Hampton Beach population and its allocation to two different reception centers.
Cf Vol.
6, App. K, ERPA A evacuation route map with ERPA D evacuation route map.
As discussed below, the State of New Hampshire apparently did not adopt this recommendation choosing instead to send.all Hampton Beach transients to the Manchester center. _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
T.i
[.
L Persons working or visiting beach areas-in the towns of Hampton and Seabrook from North Shore Road and Ocean Boulevard.12 the North.
are advised to evacuate the area. -For persons from these areas who require assistance.
. Reception Facilities have been opened in the City of Manchester.
Appendix G to Volume 4 of Applicants' Exhibit 5 at G G-31 (emphasis supplied).1E North Shore Road is'at or-near the northern boundaryfof Hampton and is to the north of those portions of Hampton' Beach identified by the Applicants as Hampton Beach North-in the Avis Airmap counts (App. Dir. No.
7, ff. Tr. 5622 at 38)'and allocated to the Dover center as part of the undisclosed total PP for Hampton on page 3 of the Response.
Thus, the critical allocation of evacuating beach population which undergirds the assertions in both the Response and the PID concerning the planning basis for the NHRERP (such basis " works out to be about 25*5") finds no reflection in the NHRERP's protective action machinery itself.
Far from having staffed all four centers with staff sufficient to handle the largest 1Q/
The message quoted above is dated 8/86.
Attached as Exhibit 4 hereto is the most recent updated version of that same Message F. dated 2/88.
The Mass AG is uncertain whether Exhibit 4 hereto is or is not part of the NHRERP record.
In I
any event, at G-28 of the 2/88 version of this message it states:
~
All persons working in or -isiting beaches and parks in Seabrook and Hampton are advised to evacuate those areas immediately.
for Hampton Beach area visitors, the reception center is in Manchester.
In both the 1986 and 1988 versions of this and other relevant messages, Dover is not identified as the reception center for any portion of the Hampton Beach visitor / transient population.
(1986: 'G-31 Appendix G to Vol. 4 of App. Exh. 5; 1988: G-29 in Exhibit 4 hereto).
Egg also App. Exh.
5, Vol. 33 (Dover Host j
Plan) at I-1 not identifying Dover as a reception center for i
any portion of Hampton Beach and App. Exh.
5, Vol. 36
)
(Manchester Host Plan) at I-1 identifying Manchester as the l
reception center for "Hampton Beach."
l j i
4
.t U
' number ofLevacuees at any one center, the Applicants underestimated the number of' evacuees assigned by the NHRERP to the largest center by 17.2% (8,138 47,147 - 17.2%)'.
As a consequence they,.in fact, do not have sufficient capacity to monitor.even.20% of those populations instructed'to go to the j
a l Manchester-reception area.
Egg SAPL's March 21, 1989 Brief on l
n.
7.
Appeal of the PID on the NHRERP at 44 Issue-3.
In light of the inputs to the PP calculations in the Response-as set forth above, it should also be obvious that l
a' portion of the total' peak populations represents an estimate of the permanent resident population.
If this Board is l
l interested in establishing the actual percentage of the total l
evacuating population which can be monitored in light of the existing reception center staffing and resources, 1988 permanent resident estimates and not 1986 estimates should be (and should have beer.) used.
These appear uncontradicted in the record in Supp. Direct Test. of Luloff, ff. Tr. 8211 at 5-6.
The totals reflect a 4.3% increase over the estimates made in Volume 6 and incorporated into the PPs set forth on page 3 of the Response.
Issue 4.
Finally, we turn to that portion of the PPs on
]
page 3 of the Response which represents and reflects a hotly disputed issue in the NHRERP proceeding:
the beach vehicle and person populations.
As is now clear, the PPs on page 3 for the five beach " towns" (actually four towns -- Seabrook, Hampton, North Hampton, and Rye -- and an Applicant-created entity "Hampton Beach") have as a major input in their calculation a beach vehicle estimate and a beach person population estimate - - _ _ --
based'on the person per vehicle factor ("PPV").
SAPL raised
.directly to the Licensing board in its' Proposed Findings at 15.1.6 the obvious relevance of the total beach population.
(presented in the ETE portion of the case).for any determination whether the'20% planning basis for reception centers had been met.
.(SegLalso SAPL's March 21, 1989 Brief on Appeal to this-Board at'44 n. 7.).The Licensing Board noted this precise
. issue at 15.61, 28 NRC 667, 712:
SAPL' asserts that Applicants failed to properly determine the number of expected evacuee arrivals even
.nsino the 291 plannina basis.
SAPL argues that Applicants' vehicle counts based on the July 18 photographs were too low and should be increased by 52*5 (High at al. Dir., ff. Tr. 6849 at 5).
(emphasis supplied)
The Board Dever addressed this araument at all in the context of.the challenge to the adequacy of the monitoring capacity.A1 Instead, the Board stated at 15.69:
SAPL's arguments regarding the determination of the peak population and vehicle counts will be addressed in connection with NHRERP Revision 2 evacuation time estimates.
Sag S9, infra, ldm at 715.
Yet, when we turn to S9 of the PID (particularly 119.89-9.129; id at 795-803) we find that the Board reiected the verv beach vehicle totals reflected in the EEE Egt forth an pace 1
~
of the Resoonse.
The total beach vehicle count whose components were used as inputs to the PPs on page 3 of the Response was ll/
In fact, during the hearing on the adequacy of the utility plan for the Massachusetts portion of the EPZ, the Board ruled it had nat made a finding about the appropriate beach vehicle and person totals to be used in assessing the 20*5 capacity issue.
SPMC transcript at 24422-23, 24426. -_
> a
(
29,293.
App..Dir. No.
7, ff. Tr. 5622 at 38.
This figure was-expressly rejected by the Board.
9.120.
Id at 801.
Moreover, the Board found:
In total, the Interveners' view is that, on busy days, the peak vehicle count may be approximately 36,000.
We find thatEby either estimation,from the July 18, 1987 observations or by considering expectable maximum occupancy of parking areas that'35,000 to 36,000 be reasonably postulated as the " peak of vehicles may /
the peaks."42 Id. 'Although the Board made a series of findingsA3# as to total beach vehicle population, none of the approved figures was the 29,293 that undergirds the PPs for the five beach towns on page 3 of the Response.
Even more puzzling, if not bizarre, is the Board's (and the Applicants') treatment of the person per vehicle (PPV) factor.
As discussed in the Response at 7 and above in detail, three different PPVs were used in calculating the PP for each town.
12/
The Mass AG has indicated in its March 24, 1989 Brief to this Board at 9-10, nn. 10, 11, and 12 that the population in the beach areas is within a range.
For purposes of the planning basis for monitoring capacity, the high end of that range should be adopted because some percentage (in the NHRERP 20%) is multiplied times it thereby reducing the actual number of evacuees actually planned for.
22/
The Board found:
- 1) 35,000 to 36,000 vehicles, as noted, is 'the " peak of the peaks" (19.121 (801)); 2) 39,000 vehicles
~
is the " reasonable estimate of the beach area capacity" (19.119 (801)); 3) 32,800 vehicles "were likely present in beach areas on July 18, 1987" (49.120 (801)); and 4) 31,000 vehicles is an
" appropriate number for reasonably expectable peak occupancy" (19.122 (802))..
In this blizzard of contradictory findings, the Licensing Board could not see its way clear to make any L
findings at all on:
a) a reasonable estimate of the beach person population for purposes of determining whether E
monitoring capacity equalled 20% of the EPZ population even though SAPL presented this issue directly to the Board; and b)
]
the proper person per vehicle factor to be used to generate a beach person population from a beach vehicle finding.
This latter point is discussed in more detail infra. _ - _ - - _ - _ _ _ _ - _
s-u y
From the' calculations set forth above it is obvious that the o
i.e., the PP is calculated ba' sed on' PPs are vehicle-derived, Lthe number of potential evacuating vehicles originating in a particular' town.
Notwithstanding'that this means that the
~ Applicants know how many vehicles should actually arrive at a reception center,2A when it came time to calculate the staffing and resources needed for the vehi~cular monitoring that the NHRERP calls for,-the Applicants applied a PPV in reverse (i.e., divided evacuees by a PPV) La derive a vehicle count' f.Inm the vehicle-derived oopulation estimate.2E#
PID at 15.22 (704).
Although the Board stated in its discussion of the monitoring capacity that it would discuss the 2.6 PPV in
~
"more detail" in its discussion of ETEs (15.72 (716)) there is not a word in S9'of the PID about the correct PPV for
-calculating total beach (or non-beach) population.
As indicated in the Mass AG's March 24, 1989 Brief on Appeal of the PID at 9 n.
11, the Mass AG put in evidence that the 23/. The calcu)= tion would simply be 20% x the sum of all vehicles assigned to each EPZ town as described in detail above.
15/
To grasp how absurd this is, take the example of Hampton Beach on page 3 of the Response.
We know from the calculations
~
set'forth above that'the PP of 23,609 persons is derived from 9,675 beach transient vehicles plus 230 beach permanent vehicles.
Thus, for purposes of estimating the vehicular load at a host community represented by this population the number should be at least 9-,905 x 20% = 1,981 vehicles.
Instead, a PPV of 2.6 is used and it is divided into 20% of the person popu'lation.
Thus, 23,609 x 20% 1 2.6 = 1,816 vehicles.
- Thus, this reverse PPV calculation unddrcounted 165 cars from Hampton Beach or 9% of the number actually counted.
Looked at in a more sinister light:
the Applicants use a low beach PPV (2.4) to arrive at a lower person population total for person staffing and then, even though they have the vehicular count in hand, they use a higher PPV in reverse to move from the person population to a lower beach vehicular count for purposes of vehicular staffing. - - - _ - _ - _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _
4:
correct PPV for the beach areas is-2.85 and not 2.4.
.The Board appears to have made no finding at all in this regard.AE#
Let us examine the impact of these two inputs on the PP for Hampton BeachLand its impact in turn on the actual evacuee monitoring. load capacity represented by' existing planning at Manchester.
First, we shift to Manchester as discussed above, the-8,138 persons on the northern portion of Hampton Beach assigned by the Applicants to Dover on page 3 of the Response.
Thus, the total number of beach vehicles on Hampton Beach that supports the PPs in the Response is 13,257.
(App. Dir. No. 7, ff. Tr. 5622 at 38.)
This number reflects a total beach vehicle count of 29,293.
If we choose as a peak vehicle count 39,000 vehicles which the Board found as a " reasonable estimate of the beach area capacity" (19.119 (810)), we will have increased beach' vehicle totals by 9,707 vehicles.
This number represents an increase of 33% over the 29,293 figure that lies behind the PPs on page 3 of the Response.
(39,000 - 29,293 - 9,707.
25/
Arguably, the Board again made contradictory findings:
first, by finding that there existed a 20% monitoring capacity the Board implicitly approved the PPVs that were embedded in the PPs.
Thus, the Board approved 2.4 as the PPV for the beach transient vehicle count.
Second, however, the Board found'2.6
~
app'ropriate as the PPV to divide into the estimated monitoring loads to obtain the vehicular load estimates.
During the hearing on the adequacy of the utility's plan for Massachusetts, the Board ruled that the issue of the appropriate PPV(s) to be used to calculate total population for the purpose of determining whether 20% of the population could be monitored in about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> was LEE iudicata:
the Board ruled that 2.4'was the number it had found based on yet another portion of it's PID - 18.43 (761).
SPMC transcript at 27804-805.
Egg also SPMC Tr. 27811.
However, as noted above, the Board never addressed the total beach population challenge which SAPL presented in its Proposed Findings on the adequacy of the NHRERP monitoring capacity.
l _
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l' 9,707 29,293 =-33%.)
Thus,-this input change (which.is.
perfectly reasonable in light of1the lower-Board's' finding that 39,000.is capacity) will increase.the Hampton Beach person estimate in turn by 33%.11#
E Hampton Beach -'-23,609 (page 3 of Response)
+
8,138 (reallocated Dover ~ population'see discussion,above)
L 31,747 x 33% - 10,477 persons Adding these additional 10,477 persons to the' total for the-Manchester center results in the following:
Manchester - 23,538 (non-Hampton Beach towns, page 3) 23,609 (Hampton Beach, page 3) 8,138 (see discussion above)
'10,477 (33% increase in Hampton Beach population due only to vehicle counts) 65,762 If the total evacuating population assigned to Manchester is 65,762 then the present. staffing capability (9,667, page 2 of thel Response) represents only 14.6% of that population (9,667 65,762)
Next, let us add the impact of an upward shift in the ppV for,the beach population originating from Hampton Beach.
Using s
only 2.6 we find as follows:
11/
Obviously, this analysis assumes an evenly distributed and proportional increase in each town's beach vehicle population as the vehicle total is increased from 29,293 to.39,000.
- Also, the analysis assumes that an increase in beach vehicle counts should result in a direct and equal increase in beach population counts.
This assumption ignores the impact on person population when different ppVs are used for different kinds of vehicles. - - _ _ _ _ - - _ _ -. _ -
' w i
HamptoniBeach
.13,257 vehicles'(App. Dir. No. 7,Jff. Tr'.
5622.at 38)
J 13,257 x 33%~= 4,375 vehicles'(increase'due.
3 to larger.
capacity figure) 13,257 l
+' 4.375 17,632 vehicles x 2.6 PPV =~45,843 persons Adding this-new PP for Hampton Beach.(which reflects:
- 1) the beach populations the' Applicants assigned to Dover; 2)
~
an increase of 33%'over the beach vehicle totals'used'in the PP.
' set'forth in the' Response; und 3) the same'PPV.(2.6) the Applicants'and the Board used to calculate vehicular load) to
.the totals for Manchester results in:
Mancheuter = 23,538 (non-Hampton Beach towns, page 3)
+ 45,843 (new PP as described above for Hampton Beach) 69,381 = total evacuating population If the total evacuating population assigned to Manchester is 69,381 then the present staffing capability (9,667, page 2 of the Response) represents only 13.9% of that population.
(9,667 1 69,381).
1 1
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)
CONCLUSION Present monitoring capacity'in the NHRERP not only does not
" work []out to 25% of all evacuees" but-for'the critical.
- close-in beach populations there is not even the capacity-to monitor 20% of the evacuating population.
Respectfully submitted, COMMONWEALTH OF MASSACHUSETTS JAMES M.
SHANNON ATTORNEY GENERAL L A, s-4.9.
1-
. (M5hn Traficonte-
/
Chief, Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 (617) 727-2200 DATED:
September 15, 1989 9 _ - _ _ _ _ - _ - _ _ _
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Traffic Demand for Scenarios 1, 2
(
Total-Generated Tries Communitv-Centroid Permanent Transient E=clovees Total
- Amesbury, 2068-264
- 424, 0
2069 681~
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0 2077 748 0
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.2079 1,000 0
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2082 100 944 0
2104-7 372 0
2200 0
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2083 432 0
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0 2087 319 249 0
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2089 988 48 0
1 2090 1,034 0
0 2091 739 129 0
2102 520 0
0 2114 253 245 0
2202 0
0 483
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0 483
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1 Salisbury 2092 332 0
0 2093 81 3,519 0
2094 192 3,792 0
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. Traffic Demand for Scenarios 1, '2.(cont. )
' Total Generated Tries Community Centroid-Permanent Transient Emelovees Total Salisbury.
2095
-192 288 0
(conc.)
2096 844
'O O
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2098 776 96 0
2209 0
0 503 2210 0
0 503 2,587 7,837
.1,006 11,430 W.,Newbury
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2100-446 46 0
2101 413 0
0 2205 0
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0 2002 162-0 0
2119.
112 0
0' 784 0
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44 88 0.
2005 112 2
2 485 123 0
608 Exeter 2006 338 114 0
2007 404 0
0 2008 404 0
0 2009 582 114 0
2010 696 0
0 2011 532 64 0
2012 396 0
0 2013 352 44 0
2014 240 0
0 2032 573 0
0 2223 0
0 337 2224 0
0 337 4,517 336 674 5,527 Greenland 2015 220 52 0
2016 292 0
0 2017 344 0
0 2227 0
,_0 29 856 52 79 987 Hampton 2056 520 0
0 2057 291 229 0
2058 643 65 0
2059 924 0
0 M-2 i
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l Traffic Demand for-Scenarios 1, 2 (cont.)
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'2095 192 288 0
(conc.)
2096 844-0-
0 2097 170
-142 0
2098 776 96 0
2209 0
0 503 2210 0
0 503 2,587 7,837 1,006 11,433 W.
Newbury
~2099 409-134 0
2100 446 46 0
2101 413'
'O O
s 2205 0
J lg 1,268 180 348 1,796-Brentwood' 2001 460 0
0 2002~
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0 2119 151 0
0 784
~ 0 0
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Kingston 2003 120 0
0 2004 44 88 0
2005 111 35 0
485' 123 0
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.Exeter 2006 338 114 0
2007 404 0
0 2008 404 0
0 2009 582 114 0
2010 696 0
0 2011 532 64 0
2012 396 0
0 2013 352 44 0
2014 240 0
0 2032 573 0
0 2223 0
0 337 2224 0
0 337 4,517 336 674 5,527 Greenland 2015 220 52 0
2016 292 0
0 2017 344 0
0 2227 0
_Q 21 856 52 79 987 Hampton 2056 520 0
0 2057 291 229 0
2058 643 65 0
2059 924 0
0 M-2
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Traffic.0emand for Scenaries 1, 2 (cont.).
Total' Generated'Tries Communitv Centroid'
.Fermanent-Transient Irelevees Total Hampton 2060 812 72 0-
'(conc. )
2061 204 364-0 2062 465 155 0
2105-23C.
6,070 0
2106 115 1,313
.O.
2107 115 173 0
~2108 236 882 0
2113 399 29 0
2117 136 64 0
2219 0
0 353 2220 0
0 353'-
5,090 9,416 706 15,212 Hampton Falis 2116 567 194 0
2218.
0 0
11 567 194 95
'856 Kensington 2026
.327 41 0
2027 106 H
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533 74.
0 607 Kingsten 2023 476 0
0 2024 476 0
0
'2025 528 0
0-2030 476 0
0 2215 0
0 107 1,956 0
107 2,063
'New Castle 2019' 239 53 0
292 Newfields 2018 334 26 0
2226 0
J 194 334 26 184 544 Newton 2028 720 12 0
2029 720 R
0 1,440 24 0
'1,464 No. Hampton' 2050 115 13 0
2051 275 149 0
2052 319 105 0
2053 228 0
0 2054 82 158 0
2055 240 0
0 2109 140
-180 0
2221 0
0 407 1,399 605 407 2,411 M-3
5 l
Traffic Demand for Scenarios 2, 2 (cont.)
Total Generated Tries corr. unity Centroid Peranent Transient Erelevees Total Portsmouth 2038 480 0
0 2039 480 0
0 2040 448 100 0
2041 480 0
0 2042 1,144 100 0
2043 1,444 100 0
2044 672 100 0
2045 1,004 100 0
2046 904 100 0
2047 1,816 100 0
2048 383 100 0
2049 412 100 0
2103 672 100 0
2228 0
0 754 2229 0
0 754 2230 0
0 754 10,339 1,000 2,262 13,6D1 Rye 2033 273 0
0 2034 244 0
0 2035 248 0
0 2036 240 8
0 2037 224 0
0 2110 244 80 0
2111 244 1,195 0
2112 244 580 0
2232 0
0 91 1,961 1,863 96 3,920 Seabrook 2063 512 2,128 0
2064 779 20 0
2065 274 606 0
2066 800 0
0 2067 773 0
0 2115 0
1,500 0
2211 0
0 271 2212 0
0 542 2214 0
0 271 3,138 4,254 1,084 8,476 So. Hampton 2031 269 214 0
2213 0
0 140 269 214 140 623
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Total Generated Tries Cc-. unity Centreid Femanent Transient - Irelevees Tota.'
Stratha 2020 385 67 0
2021 452 0
0 2022 488 0
0 2222
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Attachmen: 2 Page 1E.cf 37 MESSAGE F -- GENERAL EMERGENCY (EVACUATION & SHELTERING)
(RELEASE OF RADIOACTIVE MATERIAL)
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e w w w a w e u w w w a w w w a w w w a w w a w w w w w w w w w a *w w w w a w A GENERAL EMERGENCY was declared at (time) t: day at Seabrock i
Station. A GENERAL EMERGENCY means :na: events are in pr:gress that c:uld I
result in scme significant release of racicactive materials with releases ex:ected to go beycnd levels set by the United States Environmental Protec:ica Agency cutside tne Seabrock Statien site bcuncary.
A release cf racicactive material into the air cc urred 2:
(time).
Certain acticns for the prote::ica of the ;ublic are being rec:mcended by tne i
Govern:r of New Hampshire, New Hampshire Emergency Management and pt:lic heal:n cfficials. State anc local Emergency 0;erations Centers are func:icning and l
State and local emergency werkers are ready t: take any necessary actions.
(Seascnal only, May 15 to Se:tember IS)
All cersons working in or visitin; beaches and carks in Sentrock and Hamoten are acvisec to evacuate tnose areas 1rmecla:ely.
If you are at ceacnes or car <s in Sea:roce anc Ham:::n. cc: cc nct nave your cwn transcortarlon. you wil! :e safer 1f you wa1: insice for a cus.
Go to cne of :ne follcwing cullcings:
Wait for a message over this station ann:Uncing what time emergency buses will te travelln; alon; main r:acs in Sea:r:ce anc Hamot:n.
ine cuses will taxe ycu to a rece :1:n center cuts 1ce tne evacua:ec area.
Recection centers will cro-vice nelo an: temocrary snelter.
For Sea: rock Seacn area visitors tne rece: tion center is at Salem Mign Scacol on Geremen:y Dr1ve in Salem: fr Hamot:n Seacn area vis1::rs. tne rece::1cn center 1s at Mancnester Memorial Hign Scnoc) en Scu:n 3:rter Street in Mancnester.
The United States Coast Guard has been requested to prohibit beating in the ccean waters within five miles of Seabr:ck Station. All offshore beaters near the plant are advised to relocate or c:ck ia waters farther than five miles fr:m the plant until further notice.
l 1
Vol. 4 G-2E Rev. 2 2/EE
1 l
L p
Page 13 of 37 i
Immediate evacuaticn is rec:m?. ended for pecple in the t:wns of (circle t:wns af fected and dele:e others) c
.,ev'
[5eabrock, Ham:::n Fal1s, Hamptan] ',2.s, 2'
,..g (and) n c
[Kensington, South Ham:t:n, North Ham:::n],Fc?s (anc)
-[BrentwCCd, East Kingsten, Exeter, Kingst:n, Newfields, Newt:n, Stra: nam, Greenlanc, New Castle, Portsm u:5, Rye]
j i
For Seabr:ck, the Rece:tien Center is at Salem High School on Gerementy Drive in l
Salem.
For Hamat:n Falls anc year-rcund residents of Hamaton, the Rece::icn Center is at Dover dign 5checi en Durham R:ad in 0 ver.
For Kensington, the Rece: tion Canter is a: Meccrial High Scheci en Scuth Porter S:ree: in Mancnester. Scuth Hamet:n's Re:e: tion Center is Salem Hich Sch:01; Nerch Hamet:n's Receptica Center 15 OcVer High Sch 01.
For Fcrtsmouth, the Reception Center is at Spaulding High Scheci en Wakefield Stree: in Rocnester. For Kingst:n and Newt:n, the Reception Center is Salem High School; for 3rentweed, Eas: Kincst:n, Exeter, Newfields and Stra: nam, the Rece::icn Center 15 Manenester Memorial nign Scaccl; for Greenlanc, New Castle and Rye, the Receptien Center is Dover High Schccl.
NOTE:
THE FOLLOWING IS TO BE READ CNLY IF ADVISED SY DPHS THAT THIS INCIDENT MAY CR WILL PRODUCE A CONTAMINATING ACCIDENT:
"There is a goed possibility for this emergency to pr: duce a c:ntaminating accident.
It is str:ngly rec:mmended tnat as a precaution, persens leaving the t:wns told to evacuate go to their designated reception centers for moni to ring. "
Services effered at the Rece::icn Centers and rec: mended for all evacuees incluce: m:nitoring f:r c:ntamination; dec:ntamination if necessary; inf:r-matien and message centers; and referral to mass care centers.
All schecls within the t:wns directed to eva:uate are being evacuated to the designated Receptien Centers f:r tne t:wn in which they are located.
Parents sh:uld not drive to schc01 to meet their children since schecis are new being evacuated and children are being taken safely by bus directly to their Receptica Centers.
Vci. a G-29 Rev. 2 2/SS
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t' If ycu have been advised to evacuate but do not have ycur cwn trans:cr:ation anc cannet get a ride fr:m a neigh:cr er scmeone else, buses will travel along main emergency r:utes to pick you up and take you to a Rece;;ica Centar.
Wait ind:crs for an announcement stating wnat time buses will begin traveling these emergency routes in your t:wn.
1 If ycu have a bedridden, handica;;ed or other persen in your hcme who needs s;ecial evacuaticn help and who has not made previcus arrangements with 1ccal Emergency Management officials, please call ycur local Emer;ency Operations Canter.
If there is no answer at your local Emergency Cceratiens Center, call the New Hampshire Office of Emergency Management at 433-1419.
If ycu have alreacy registered, there is no need t: call new; help will socn te en its way.
All persons in the area to be evacuated are urged to be goed neighbors and help cne another by sharing rides and helping others with pr:blens.
If you knew of any neignbors or c:-wcrkers with language or hearing pr::lems, please check en them to be sure they have been infermed of the emergency and understand what they suculd do.
Befcre ycu leave your hcme er workplace, make sure you have put cut all fires and closed fireplace dam:ers.
L ck all decrs when you leave. Take blankets an:
pillcws with you for ycur cwn use and any medicines which you regularly take.
Pack ence;h clothing fcr several cays.
If ycu are at work Outside tne evac-uaticn area, but live inside it, you may return hcme to ac::mplish tnese cncres anc collect family mem:ers or necessary belongings.
Pecple in the t:wns of (circle t:wns affected anc delete others)
[Seabr:ck, Ham t:n Falls, Hampt:n]
r i
(and)
[Kensingt:n, South Hampt:n, North Hampt:n]
j (and)
[Srentweed, East Kingst:n, Exeter, Kingston, i
i Newfields, Newt:n, Stratham, Greenland, New Castle, Portsacuth, Rye]
l will be safer if they SHELTER IN PLACE immediately. This means t: remain j
)
ind:crs.
To get the greatest benefit fr:m protection pr viced b"y sheltering, ycu shculd take the follcwing actions:
l I.
Shelter indecrs.
2.
Make sure all windcws and d:crs are closed tightly.
3.
If ycu are in ycur car, cicse all wind:ws and vents while ycu travel to your destination.
a.
Turn off all fans, heating er air c:nditiening sys: Ems if they bring in cutside air.
Vcl. 4 G-30 Rev. 2 2/SB i
p e
l,7. ? ",,ah Page 15 of 37 N' '
G'
,p.
5.
Take a radio with you and move to the - room with fewest windows and
{
doors.
1 6.
Keep all members of your household indoors and stay tuned to your local Emergency Broadcast System radfo station.
7.
Remain indoors until told by local or state officials that it is safe to go outside, or until further protective actions are recommended.
l Scnocls, hospitals and other institu f ons' in the towns advised to shelter are l
taking similar sheltering actions. Public officials have instructions for pro-tecting the children or other persons in their care until sheltering is no longer necessary.
Parents and relatives are advised not to call the schools or other institution. nor to drive to :ne schools to attempt to pick up their ch!!dren.
Community safety will be better protected if the schocis are per-mitted to conduct their sheltering plans over the next several hours.
Please do not use the phone except in case of personal emergency.
If you are at home, look up your emergency information brochure, which includes evacuation routes, bus routes and sheltering tips.
Emergency. information brochures also have been delivered to hotels, motels, businesses. and beach and park facilities.
Check the local telephone book for additional information.
This information could be useful in understanding future messages.
Once again:
Seabrook Station has declared a GENERAT., EMERGENCY.
l This message will be repeated every fif teen minutes or until new information is ava!!able. Keep tuned to this sta: ion for the latest official information.
If you are in northeastern Massachusetts, you should tune to a local radio sta-tion in Massachusetts for news about your town.
Actions recommended in this message are intended only for persons in ec=munities within ten miles of Seabrook Station.
2 Vol. 4 G-31 Rev 2 2/88
's
- 3.. [
'89 SEP 18 P4 :14 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION gg 00Crd ' h ; i u!
1 ATOMIC SAFETY AND LICENSING APPEAL BOARD FP AN-Before Administrative Judges:
G. Paul Bollwerk, Chairman Alan S. Rosenthal Howard A. Wilber
)
In the Matter of
)
Docket Nos. 50-443-OL
)
50-444-OL PUBLIC SERVICE COMPANY
)
OF NEW HAMPSHIRE, ET AL.
)
)
(Seabrook Station, Units 1 and 2)
)
September 15, 1989
)
CERTIFICATE OF SERVICE I, John Traficonte, hereby certify that on September 15, 1989, I made service of COMMENTS OF THE MASSACHUSETTS ATTORNEY GENERAL ON APPLICANTS' RESPONSE TO APPEAL BOARD ORDER OF AUGUST 30, 1989 by Federal Express as indicated by (*) and by first class mail to:
Ivan W.
Smith, Chairman Kenneth A. McCollom Atomic Safety & Licensing Board 1107 W.
Knapp St.
~
U.S.
Nuclear Regulatory Commission Stillwater, OK 74075 East West Towers Building 4350 East West Highway
-Bethesda, MD~ 20814 Dr. Richard F.
Cole Robert R. Pierce, Esq.
Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East West Towers Building East West Towers Building 4350 East West Hignway 4350 East West Highway i
Bethesda, MD 20814 Bethesda, MD 20814 l
l L__
Y l
- Docketing and Service
- Thomas G.
Dignan, Jr.
f U.S. Nuclear Regulatory Commission Ropes & Gray Washington, DC 20555 One International Place j
Boston, MA 02110 1
- Sherwin E.
Turk, Esq.
Richard Donovan U.S.
Nuclear Regulatory Commission FEMA Region 10 Office of the General Counsel 130 228th Street, S.W.
11555 Rockville Pike, 15th Floor Federal Regional Center Rockville, MD 20852 Bothell, WA 98021-9796 H.
Joseph Flynn, Esq.
- Atomic Safety & Licensing Assistant General Counsel Appeal Board Office of General Counsel U.S.
Nuclear Regulatory Commission Federal Emergency Management Washington, DC 20555 Agency 500 C Street, S.W.
Washington, DC 20472 Robert A. Backus, Esq.
Atomic Safety & Licensing Board Backus, Meyer & Solomon U.S.
Nuclear Regulatory Commission 116 Lowell Streut Washington, DC 20555 P.O. Box 516 Manchester, NH 03106 Jane Dougnty Dianne Curran, Esq.
Seacoast Anti-Pollution League Harmon, Curran & Towsley Five Market Street Suite 430 Portsmouth, NH 03801 2001 S Street, N.W.
Washington, DC 20008 Barbara St. Andre, Esq.
Judith Mizner, Esq.
Kopelman & Paige, P.C.
79 State Street 77 Franklin Street Second Floor Boston, MA 02110 Newburyport, MA 01950 Charles P.
Graham, Esq.
R.
Scott Hill-Whilton, Esq.
Murphy & Graham Lagoulis, Hill-Whilton & Rotondi 33 Low Street 79 State Street Newburyport, MA 01950 Newburyport, MA 01950 Ashod N. Amirlan, Esq.
Senator Gordon J.
Humphrey 145 South Main Street U.S.
Senate P.O. Box 38 Washington, DC 20510 Bradford, MA 01835 (Attn:
Tom Burack)
Senator Gordon J. Humphrey John P.
Arnold, Attorney General One Eagle Square, Suite 507 Office of the Attorney General Concord, NH 03301 25 Capitol Street (Attn:
Herb Boynton)
Concord, NH 03301 Pn1111p Ahrens, Esq.
William S.
Lord Assistant Attorney General Board of Selectmen Department of the Attorney General Town Hall - Friend Street Augusta, ME 04333 Amesbury, MA 01913
J-V.
Paul McEachern, Esq.
- G.
Paul Bollwerk, Chairman Snaines & McEachern Atomic Safety & Licensing l
25 Maplewood Avenue U.S.
Nuclear Regulatory Conmission l
P.O. Box 360 Commission Portsmouth, NH 03801 Washington, D.C.
10555
- Howard A. Wilber
- Alan S.
Rosenthal Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Appeal Board l
U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
10555 Washington, D.C.
10555 l
[
Respectfully submitted, 1
JAMES M.
SHANNON ATTORNEY GENERAL Oy-
/
!_df IW/c. c&
J, ann Traficonts
,/Cblef, Nuclear Safety Unit
@partment of the Attorney General
,,tne Ashburton Place
~ Boston, MA 02108 (617) 727-2200 Dated:
Sept emoe r 15, 1989
~
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