ML20024C247
| ML20024C247 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/05/1983 |
| From: | Dignan T, Gad R, Gad R PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8307120444 | |
| Download: ML20024C247 (6) | |
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UNITED STATES OF AMERICA
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ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY OF NEW
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Docket Nos. 50-443 HAMPSHIRE, et al.
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50-444
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(Seabrook Station, Units 1 & 2)
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APPLICANTS' RESPONSE TO SAPL CONTENTIONS ON NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN Contention No. 1 SAPL Proposed Contention No. 1 is:
"The New Hampshire Radiological Emergency Response Plan (NHRERP), 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. 50.47(a)(1), in that the plan is incomplete."
The proposed contention as worded is simply too broad and too open-ended.
The Applicants would have no objection to individual contentions phrased in the language of the e307I20444 830705 DR ADOCK 05000 4 D503
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-various particulars set out in the accompanying statement of basis in the SAPL filing.
Contention No. 2 SAPL Proposed Contention No. 2 is:
" Contrary to the requirement of NUREG-0654 l
II A 2.b, New Hampshire law does not provide clear authority for the governor to order a protective response, to include evacuation."
NUREG-0654 5 II.A.2.b. requires that the plan " describe the legal basis for" the authority granted various persons.
It-does not require what the SAPL contention says it does.
Contention No. 3 No objection.
Contention No. 4 SAPL Proposed Contention No. 4 is:
"The evacuation estimate set forth in Table-2.6-7 is unreliable and underestimated."
Table 2.6-7 is entitled "Seabrook Station Evacuation i
Clear Time Estimates by Analysis Sectors" and is taken from the Seabrook Station Emergency Plan.
Those estimates have been partially disposed of by summary disposition, and
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remaining issues will be litigated in Phase 1 of the hearings.
There is nothing to be relitigated in Phase 2.
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Contention Nos. 5-6 No objection is made to Nos. 5 and 6 as framed.
Contention No. 7 SAPL Proposed Contention No. 7 is:
"The periodic exercises of emergency response capabilities as described in the NHRERP do not satisfy the requirements of 10 C.F.R. 50.47(b)(14.) or NUREG-0654 N lb."
This. contention is not litigable in an operating license proceeding.
10 C.F.R. 5 50.47(a)(2).
Contention No. 8 No objection Contention No. 9 SAPL Proposed-Contention No. 9 is:
"The NHRERP fails to comply with the requirements of 10'C.F.R. 50.47(b)(10) and NUREG-0654 J 12 as it has made no showing that the means for registering and monitoring of evacuees at relocation centers in host areas exist'or that personnel and equipment are available to provide the capability of monitoring all EPZ residents and transients within a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period."
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The regulations cited contain no requirements such as SAPL describes.
No objection would be made to a reframing of a series of contentions from the " basis" statement where specific defects are alleged.
,tfully su
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Thomas G.
D/gnan,.Jr.
R. K. Gad III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 e
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CERTIFICATE OF SERVICE I,
R. K.
Gad III, one of the attorneys for the Applicants herein, hereby certify that on July 5, 1983, I made service of the within Applicants' Response to SAPL Contentions on New Hampshire Radiological Emergency Response Plan by mailing copies thereof, postage prepaid, to:
Helen Hoyt, Chairperson Diana P.
Randall Atomic Safety and Licensing 70 Collins Street Board Panel Seabrook, NH 03874 U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Emmeth A.
Luebke William S.
Jordan, III, Esquire Atomic Safety and Licensing Harr^n & Weiss Board Panel 1725 I Street, N.W.
U '. S. Nuclear Regulatory Suite 506' Commission Washington, DC 20006 Washington, DC 20555 Dr. Jerry Harbour G. Dana Bisbee, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Office of the Attorney General U.S.
Nuclear Regulatory 208 State House Annex Commission Concord, NH 03301 Washington, DC 20555 Atomic Safety and Licensing Roy P.
- Lessy, Jr.,
Esquire Board Panel Office of the Executive Legal U.S.
Nuclear Regulatory Director -
Commission U.S.
Nuclear Regulatory Washington, DC 20555 Commission
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Washington, DC 20555 Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel 116 Lowell Street U.S.
Nuclear Regulatory P.O.
Box 516 Commission Manchester, NH 03105 Washington, DC 20555 Philip Ahrens, Esquire Anne Verge, Chairperson l
Assistant Attorney General Board of Selectmen Department of the Attorney Town Hall General South Hampton, NH Augusta, ME 04333 A
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David R.
Lewis, Esquire Jo Ann Shotwell, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Department of the Attorney General Commission One-Ashburton Place, 19th Floor Rm. E/W-439 Boston, MA 02108 Washington, DC 20555 Mr. John B. Tanzer Ms. Olive L. Tash Designated Representative of Designated Representative of the Town of Hampton the Town of Brentwood 5 Morningside Drive R.F.D.
1, Dalton Road Hampton, NH 03842 Brentwood, NH 03833 Ms. Roberta C.
Fevear Mr. Patrick J. McKeon Designated Representative of Selectmen's Office the Town of Hampton Falls 10 Central Road Drinkwater Road Rye, NH 03870 Hampton Falls, NH 03844 Mrs. Sandra Gavutis Mr. Calvin A. Canney Designated Representative'of City Manager the Town of Kensington City Hall RFD 1 126 Daniel Street
-East Kingston, NH 03827 Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. Angie Machiros U.S.
Senate Chairman of the Washington, D.C.
20510 Board of Selectmen (Attn:
Tom Burack)
Town of Newbury Newbury, MA 01950 Senator Gordon J. Humphrey Mr. Richard E.
Sullivan 1 Pillsbury Street Mayor Concord, NH 03301 City Hall (Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Donald E.
Chick Mr. Maynard B.
Pearson Town Manager 40 Monrce Street Town of Exeter Amesbury, MA 01913 10 Front Street Exeter, NH 03833
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