ML20072H555
| ML20072H555 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/24/1983 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8306290532 | |
| Download: ML20072H555 (5) | |
Text
4
/
3 FILED:
JUNE 24 d g
UNITED STATES OF AMERICA 4
NUCLEAR REGULATORY COMMISSION s
p N// g 7 BEFORE THE ATOMIC SAFETY AND LICENSING BOA G
19 Q f,
in the matter of:
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PUBLIC SERVICE CXM1PANY OF Docket Nos.
NEW HAMPSHIRE, et al 50-(Seabrook Station, Units 1 and 2)
ERRATA TO SAPL CONTENTIONS ON NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN The following pages and/or corrections should be substituted on the filing made by SAPL entitled above:
1.
Pages 1, 3, and 5 attached should replace the preseht pages 1, 3 and 5.
2.
On page 2, line 1 the following:
"(page 2.6 28)" should read
"(page 1.3-10)".
3.
On page 4, Contention 6, line 2 the following: "NUREG-0654 K 56" should read "NUREG-0654 K Sb".
Contention 7, lines 3 and 4 the following:
"NUREG-0654 1 b"
should read "NUREG-0654 N lb".
4.
Page 6, Contention 9, line 6 the following:
"23 hour2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> period" should read "12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period".
5.
Page 7, 1ine 1 "monitring", should read " monitoring".
Respectfully submitted, Seacoas t Ant i-Pollu t ion Leagtte By its attorneys, BACKUS, SilEA & MEYER l
8y:
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.A h532 830%0 3
CK 0500 pp Kobe t L'Backus 116 Lowell St.,
Box 516 g
Manchester, N.H.
03105 Tel:
(603) 668-7272
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FILED:
June UNITED STATES OF AMERICA NUCLEAR REGULATORY CX%1 MISSION h
0UN 2 N yf;'
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
[sar..
/
g In the matter of:
N PUBLIC SERVICE COMPANY OF Docket Nos.
50-443 OL NEW HAMPSHIRE, et al 50-444 OL (Seabrook Station, Units 1 and 2)
SAPL CONTENTIONS ON NEW HAMPSHIRE RADIOIDGICAL EMERGENCY RESPONSE PLAN CONTENTION 1 The New Hampshi re Radiological Emergency Response Plan (NHRERP),
4 is insufficient to provide reasonable assurance that adequate protective measures can and will be taken in the event of a
radiological emergency as required by 10 C.F.R. 650.47(a)(1),
in that the plan is incomplete.
Basis:
The NHRERP is incomplete in that the town EOC's have not been set up, s tate police have not yet received high-band portable radios (see page 2.2-6), the line of succession from the governor has not yet been es tablished (ref erence page 2.2-9), radios for field units, especially DPH field monitoring teams are not yet available (see page 2.2-11), the four-channel emergency medical communication system has not yet been installed (page 2.2-14), a dispatch center for emergency medical mobile units has not been selected (page 2.2-14), reception facilities have not been designated (page 2.6-28),
monitoring locations for the Seabrook Station EPZ have not yet been determined (page 2.5-15), Seabrook Station Decontamination Centers h a.ve
W Independent Assessments of Evacuation Times From the Plume Exposure Pathway Emergency Planning Zones of Twelve Nuclear Power Stations, February 1981, Federal Emergency Management Agency.
CONTENTION 5 The NHRERP fails to make an adequate showing that 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability exists to determine the doses received by emergency personnel and hence falls to comply with 10 C.F.R. 6 50.47 (b) (11) and NUREG-0654 K3.
Basis:
There has been no discussion of what equipment will be provided at the reception centers for Division of Welfare and Red Cross workers monitoring evacuees.
The exposures of the numbers of emergency workers who will need to be in the proximity of contaminated evacuees cannot be handled by the small amount of equipment described in Sec t ion 2. 7. 2 The Division of Public Works and Highways employees responsible for clearing the roadways, the State Police and all others involved in an emergency response in the EPZ will require dosimeters.
There are too few dosimeters, and of those there are, too f ew have the capaci ty to measure exposures beyond the 20R range.
DPH staff will be overburdened with other responsibilities such as i
analysis of environmental media, estimation of the total population dose and locating and t racking the plume.
There has been no showing that DPH has adequate staff to monitor and evaluate worker exposure records, too.
i
E requirement for unannounced exercises. Only under wholly unannounced conditions can the readiness of emergency response organizations be given a true test.
00NTENTION 8 The NHRERP fails to comply with the requirements of 10 C.F.R.
I 50.47 (b) (10) and NUREG-0654 J 11.
The measures for protecting the public f rom contaminat ion through the ingest ion exposure pathway are not adequate.
Basis: Maps for recording survey and monitoring data, key land use data, dairies, food processing plants, water sheds, water supply intake and treatment plants and reservoirs have not yet been prepared (see page 2.4-10).
The NHRERP states that:
"In New Hampshire, contamination of dairy feed is not likely to be a significant problem, since 75-80% of all feed is stored."
No provision for the other 20-25% of feed is made.
No provision is made for the case in which contamination of animal feed occurs before harvest time.
A list of all public water supplies does not appear in the Appendix - as is stated at page 2.6-45.
Lists of commercial agricultural facilities for the Seabrook Station EPZ do not appear in the appendix as claimed at page 2.6-45.
There has been no showing that there are lists with the names and locations of all facilities which process milk and other food or agricultural products f rom the Seabrook Station EPZ as is required by NUREG-0654 J 11.
The Division of Public Health has f ailed to show that it has adequate staf fing to perf orm the monitoring i
i \\
1
CERTIFICATE OF SERVICE a
Helen Hoyt, Chm.
Thomas G. Dignan, Esq.
Admin. Judge Ropes and Gray Atomic Safety & Lic.
225 Franklin Street Board - U.S. NRC Boston, MA 02110 Washington, DC 20555
- er Harbour Sen. Gordon H @ ey Docketing and Service Sec.
n Attn: ' Ibm Burack
- Y Atomic Saf ty &Lic.
DC 20510 hash ngton DC 20555 Sen. Go h W ey Roy P.
Lessy, Jr., Esq.
Robert L. Chiesa, Esq.
Attn Boynton Office of Executive 95 Market Street gal Director Manchester, NH 03101 Concord, NH.03301 Washington, DC 20555 Maynard B. Pearson Phillip Ahrens, Esq.
Asst. Atty. General Jane Doughty Rep. Amesbury, MA Field Director State House, Station #6 40 Monroe St.
SAPL Augusta, ME 04333 Im mbury, MA 01913 5 Market Street Portsmouth, NH 03801 Donald E. Q11ck Anne Verge, Chairperson Town Manager Board of Selectmen Dana Bisbee 10 Front Street Town Hall Attorney General's Office Exnter, NH 03833 So. Hampton, NH 03842 State of New Hampshire Concord, NH 03301 Dr. Emmeth A. Luebke David R. Lewis Office of Selectmen Admin. Judge Atomic Safety & Lic. Brd.
Town of North Hampton
' ' brth Hampton' NH 03862 Atomic Safety & Lic.
U.S. NRC - Rm. E/W-439 Board - U.S. NRC Washington, DC 20555 Washington, DC 20555
. Anne Verge, 01m.
Jo Ann Shotwell, Asst. AG Calvin A. Canney,
' Doard of Selech One Ashburton Place, 19th City Mgr.-City Hall Town Hall Floor 126 Daniel Street i South Hampton, NH 03842 Boston, MA 02108 Portsmouth, NH 03801 l
- John B. 'Ihnzer William S.
Jordan, II, Esq.
Mr. Angie Machiros, Chnun.
Ih n of Hampton Ellyn R. Weiss, Esq.
Board of Selectmen 1
5 Morningside Drive 1725 I Street, N.W.
'Ibun of Newbury Hampton, NH 03842 Suite 506 Newbury, MA 09150 Washington, DC 20006 Edward Meany Dr. Muray-Tye, President Sandra Gauvutis rown of Rye Sun Valley Assoc.
'Ihn of Kinsington i155 W"hington Road 280 Haverhill Street RFD 1 l
Rye, NH 03870 lawrence, MA 01840 East Kensington, NH 03827 1
i
' 11 fred Sargent, Chm.
Ietty Hett, Selectman Richard E. Sullivan, Mayor
' loard of Selectmen Town of Brentwood City Hall
- lbwn of Salisbury,MA 01950 RFD Dalton Road Newburyport, MA 01950 g
Brentwoodo NH 03833 t