ML20028E332
| ML20028E332 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/17/1983 |
| From: | Bisbee G, Fan S, Tupper E NEW HAMPSHIRE, STATE OF, NEW HAMPSHIRE, UNIV. OF, DURHAM, NH |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8301210231 | |
| Download: ML20028E332 (30) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CCCX.ETE9 ye :a-Before the ATOMIC SAFETY AND LICENSING BOXB) JAN 20 A10:29 FF .E li .L As *
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In the matter of: )
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PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE) Docket Nos.: 50-443 ET AL. ) and
) 50-444
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(Seabrook Station, Units 1 and 2) )
) January 17, 1983 THE STATE OF NEW HAMPSHIRE'S RESPONSE TO THE NRC STAFF'S INTERROGATORIES AND REQUESTS FOR THE PRODUCTION OF DOCUMENTS FILED NOVEMBER 10, 1982 I. INTERROGATORY l N.H. Contention 9 0.I(l) At present, New Hampshire relies on the following persons to substantiate its contentions: Dr. Stephen S.T. Fan, Mr. William Dotchin, Dr. Filson Glanz, and Dr. William Mosberg. New Hampshire may'well rely on additional persons and ,,
will provida the names of additional persons in the future.
0.I(2) Please find attached the curriculum vitae of the above perso.is as,At.tachments A, B, C and D, respectively.
0.I(3) New Hampshire has'not yet determined which witnesses it will call with respect to this contention.
8301210231 830117 g DR ADOCK 05000443 PDR _
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Q.I(4) See answer to Q.I(3).
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0.I(5) New Hampshire has not yet finalized the bases and -
documents upon which it will rely with regard to this contention. However, at this time we can provide a partial list which is set forth below:
NUREG-0737 Sections II.B.2, II.B.3, II.F.1, III.D.l.1, III.D.3.3, III.D.3.4, NUREG-0800 GDC-63 GDC-64 Regulatory Guide 1.97 FSAR Ch. 6.4, 7, 9.4, 11, 12, 15 All documents produced by the Applicant in response to the State's Interrogatories on Contention NH-9, W.W. Weaver, Aging Techniques and Qualified Life for Safety System Components, Nuclear Safety, Vol. 21,
- p. 51, January 1980, Report of the President's Commission on the Accident at Three Mile Island.
Q.I(6) New Hampshire has not yet finalized the materials which it will use to support this contention or refer to during examination of witnesses. However, we have set forth a partial list at this time (see answer to Interrogatory Q.I(5)). In the event that a document is listed which is not available to NRC, we will make such document available.
N.H. Contention 10 0.I.(1), Q.I(2), O.I(3), and 0.I(4): See the answers to Interrogatory Q.I.1-3 in Contention NH-9 for each.
Q.I(5) New Hampshire has not yet finalized the bases and documents upon which it will rely with regard to this
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contention. However, at this time we can provide a partial list which is set forth below:
GDC 13, 19, 20, 21, 22 NUREG-0700 NUREG-0737, I.C.1, I.D.1, I.D.2, II.B.1, II.D.3, II.F.1, II.F.2, and Supplement 1 NUREG-08 01 NUREG-069 6 Regulatory Guide 1.97 Technical Note: The Control Room Design Review, E.W. Hagen (Ed.), Nuclear Safety, 23 (291-299),
1982 Documents produced by the Applicant in response to the New Hampshire's interrogatories on Contention NH-10.
Survey of Control Room Design Practices with Respect to Human Factors Engineering, J.L.
Seminara, S.W. Parsons, Nuclear Safety, 21 (603-617), 1980 Human Factors Engineering Enhancement of Nuclear Power Plant Control Rooms, J.L. Seminara, R.W. Pack, S. Seidenstein, S.K. Eckert, Nuclear Safety, 21 (351-363), 1980 Human Factors Engineering in the U.S. Nuclear Arena, E.W. Hagen, G.T. Mays, Nuclear Safety, 22 (337-346), 1981 Some Possible Ways to Improve Nuclear Pouer Plant Instrumentation, Y.Y. Hsu, A.L.M. Hon., Nuclear
Safety, 22 (728-737), 1981 Establishing Priorities in Control Room Design Review, E.L. Zebroski, M.E. Maddox, P.E. Dietz, Nuclear Engineering International, July 1982, pp.30-34 Q.I(6) New Hampshire has not yet finalized the materials which it will use to support this contention or refer to during examination of witnesses. However, the documents set forth in L m
the answer to Q.I.5 are a part of what will be used. (See
,, answer to Q.I(5). .
N.H. Contention 13 Q.I(l), O.I(2), O.I(3), and 0.I(4): See the answers to Interrogatories Q.I.1-3 on Contention NH-9 for each.
Q.I(5) New Hampshire has not yet finalized the basis and references upon which it will rely with regard to this contention. However, we have set forth below a partial list at this time. In the event that a document is listed which is not available to NRC, we will make such document available.
FSAR, Chapter 13 and Emergency Plan NUREG-0737 2/12/82 letter DeVincentis to Miraglia regarding compliance with NUREG-0737 NUREG-0654 10/1/81 letter Miraglia to Tallman degarding deficiency in compliance with NUREG-0737, Item I.C.l.
10 C.F.R. Part 50 0.I(6) New Hampshire has not yet finalized the materials which it will use to support this contention or refer to during examination of witnesses. However, the documents set forth in the answer to 0.I.5 are a part of what will be used.
N.H. Contention 20 0.I(l) In addition to the persons named in the answers to Interrogatory Q.I.1 on Contention NH-9, New Hampshire relies at the present time on the following persons: Mr. Michael Nawoj and Mr. Norman H6bbs. -
Q.I(2) Please find attached the resumes of the two above-named persons as Attachments E and F, respectively.
Q.I(3) New Hampshire has not yet determined which witnesses it will call with respect to this contention.
Q.I(4) See answer to 0.I.(3) above.
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I 0.I(5) New Hampshire has not yet finalized the bases and documents upon which it will rely with regard to this contention. However, at this time we can provide a partial -
list which is set forth below. ,
NUREG-0737 NUREG - 0654 j l Emergency Plan -
FSAR, Chapter 13 O.I(6) New Hampshire has not yet finalized the materials which it will use to support this contention or refer to during
- examination of witnesses. However, the list set forth in the answer to 0.I(5) above is a partial list of materials New Hampshire may use. In the event that a document is listed which is not available to NRC Staff, we will make such document available.
N.H. Contention 21 0.I(l), 0.I(2), 0.I(3), and 0.I.(4): See answers to Interrogatories 0.I.1-3 on Contention NH-20 for each.
0.I.(5) New Hampshire has not yet finalized the bases and documents upon which it will rely with regard to this contention. However, at this time we can provide a partial list which is set forth below. ,
l FSAR, Chapter 13 c
Emergency Plan I 10 C.F.R. Part 50 i
NUREG-0654 '!
NUREG-0737 0.I.(6) New Hampshire has not yet finalized the materials I which it will use to support this contention or refer to during l examination of witnesses. However, we have set forth in Interrogatory 0.I.(5), a partial list. In the event that a j document is listed which is not available to NRC, we will make such document available.
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I II. SPECIFIC INTERROGATORIES
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N.H. Contention 9 .
Q.9(a):
(1) New Hampshire has not yet finalized its position with regard to Contention 9 and, therefore, we can provide only a partial answer at this time.
This is based in large part on the fact that although Public Service Company has indicated that it will comply with Sections II.B.2, II.B.3, II.F.1, III.D.1, III.D.3.3, and III.D.3.4, the Applicant has not completed its submission to the Staff on most of these items. Further, as indicated by the Staff in its answers to New Hampshire's Interr,gatories,. complete information regarding the radiation monitoring system has not been provided by the Applicant. Because of the incompleteness of information supplied by the Applicant, it has not demonstrated that NUREG-0737 and GDC 64 has been or will be complied with.
(2) With regard to GDC 64, see (1) abovb. With regard to GDC 63, we have not yet completed our review of the system's ability to detect conditions that may result in loss of residual heat removal capability. As soon as this review is completed, this answer will be supplemented.
(3) Our reasons for asserting non-compliance are stated in (1) and (2) above.
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(4) Because of the incompleteness of information, we f cannot state the means by which deficiencies can be cured.
0.9(b) New Hampshire has not yet finalized its position
( ':ith regard to the adequacy of monitoring capacity and the location and number of monitoring sites because of the lack of complete information from the Applicant.
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0.9(c) No.
l 0.9(d) Again, because of the lack of complete l
information provided to date, we cannot provide an answer to l
the Interrogatory.
Q.9(e) No.
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- i N.H. Contention 10
'~ I 0.10(a) A detailed Control Room Design Review or .
Preliminary Control Room Design Assessment is required under NUREG-0737, I.D.1 and Supplement thereto. Equally important to ,
this review requirement is the requirement under 1.D.2 that I safety parameters be displayed as a system. Evaluation of control room design problems since the accident at Three Mile Island has indicated that improvement of Control Room Design i and procedures is essential to safe operation of a nuclear power facility. It is noted that review of emergency procedures is required by NUREG-0737, I.C.l.
The focus of New Hampshire's contention is to assure that an assessment of the Control Room Design and emergency procedures is performed and results in appropriate modifications. The Applicant's answers to Interrogatories NH-10.13 and NH-10.14 reflect that such a review or assessment has not been performed and that human factors and task analyses have not been performed. Similarly, the Applicant has not developed a proposal for SPDS.
The State of New Hampshire has not performed a technical assessment of the Applicant's compliance with General Design -
Criteria 19, 20, 21, and 22 and at this time, we do not intend to offer direct testimony on these specific issues. However, the absence of the review and assessment process required by NUREG-0737 indicates that compliance with the General Design Criteria has not been demonstrated. Since we have not had an opportunity to review the DCRDR or preliminary assessment, as neither are yet available, we cannot be more specific on areas 1 in which the Applicant has failed to improve Control Roon Design and procedures as required by NUREG-0700 and 0737.
New Hampshire bases its position that a detailed Control l Room Design review is required on the following regulatory l requirements and documents. These documents, in general, i indicate the importance of timely review and upgrading of Control Room Design and procedures. Because the Applicant has not completed its Control Room Design Review, this is a partial
list which may be supplemented.
GDC 13, 19, 20, 21, 22 NUREG-0700 I
l NUREG-0737, I.C.1, I.D.1, I.D.2, II.B.1, II.D.3, II.F.1, II.F.2, and supplement 1 i
NURCG-0801 i
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Regulatory Guide 1.97 , j Documents produced by the Applicant in response to New Hampshire's Interrogatories on Contention NH-10.
Technical Note: The Control Room Design Review, E.W. Hagen (Ed.), Nuclear Safety, 23 (291-299), 1982 Survey of Control Room Design Practices with Respect to Human Factors Engineering, J.L. Seminara, S.W. Parsons, Nuclear Safety, 21 (603-617), 1980 Human Factors Engineering Enhancement of Nuclear Power Plant Control Rooms, J.L. Seminara, R.W. Pack, S. Seidenstein, S.K. Eckerte Nuclear Safety, 21 (351-363), 1980 Human Factors Engineering in the U.S. Nuclear Arena, E.W. Hagen, G.T. Mays, Nuclear Safety, 22 (337-346.),
1981 Some Possible Ways to Improve Nuclear Powet Plant Instrumentation, Y.Y. Hsu, A.L.M. Hon.,' Nut ear Safety, 22 (728-737), 1981 Establishing Priorities in Control Room Design Review, E.L. Zebroski, M.E. Maddox, P.E. Dietz, Nuclear Engineering International, July 1982, pp.?U-34 0 10(b) (1) As indicated above, the Applicant has not yet completed and New Hampshire has not reviewed the program plan proposed for compliance with the provisions of NUREG-0737(1)(D)(1) and (1)(D)(2). Similarly, with regard to l
(II)(B)(1), (II)(D)(3), (II)(F)(1), and (II)(F)(2), New l
Hampshire asserts that the Applicant has not provided sufficient information to determine whether it will comply with i these requirements. At the present time, we are not in the
! position to suggest how the short-comings can be corrected.
(See answer to 0.10(a).),
0.10(c) Because we have not had access to any documents related to the detailed control room design review which is I
apparently 50% completed, we cannot determine whether such review is adequate or not.
Q.10(d) New Hampshire has not yet completed its review of the human factors analysis proposed by the Applicant.
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0.10(e) The reference on page 27 in the Contentions to
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Reg. Guide 1.47 was a typographical error. It should have read i
' Reg. Guide 1.97." .
O.10(f) See answer to Q.10(e).
Q.10(g) We do not yet have sufficient detailed information with regard to the equipment located outside the control room as required by General Design Criteria 19 to answer the Interrogatory. When ue obtain such information, we wi'll answer the Interrogatory.
N.H. Contention 13 0 13(a) The Emergency Plan does not demonstrate how the listed personnel will be trained to:
(a) recognize emergency conditions; (b) classify observed emergency conditions in accordance with the emergency classification system;
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(c) notify off-site officials of emergencies; (d) recommend protective actions to off-site authorities; (e) direct station staff to take appropriate protective actions, and (f) control or mitigate accidents in which the core is severely damaged. .
Furthermore, the Emergency Plan fails to provide for adequate evaluation of the training program, particularly by neither specifying the scope and frequency of any audits, nor designating who will conduct such audits.
Q. 13(b) As to all of the listed positions, New Hampshire has asserted its concern that operations personnel have the necessary experience and training to properly respond to accidents by (1) controlling or mitigating the accident and (2) implementing adequate emergency response measures. The basis for these concerns are NUREG-0737, Items I.C.1 and II.B.4, and the response requirements of 10 C.F.R. Part 50 and NUREG-0654. Further detail concerning the necessary experience and the training program for the listed interrogatories of
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4 personnel must be provided. In addition, it may be necessary to expand the scope of the training programs to provide more thorough training in the areas of accident mitigation and .
emergency response.
Q. 13(c) Yes. New Hampshire contends that Section 13.2 of the Emergency Plan does not detail the scope of technical training as it pertains to the mitigation of accidents and how the methods by which the effectiveness of this training will be evaluated.
Q. 13(d) New Hampshire contends that the Applicant has not demonstrated in Chapter 13 of the FSAR and the Emergency Plan, that its operations personnel will have the necessary experience and training to respond properly to accidents in which the core is severely damaged. New Hampshire has, at this time, no other reason to believe that the Applicant will be unable to conduct proper training.
N.H. Contention 20 0.20(a) and 0 20(b) New Hampshire contends in its Contention 20 that the Applicant has not adequately -
l demonstrated its ability to assess and classify ah accident at Seabrook Station and te notify its personnel, local and state governments, and the public in the event of an accident. Those sections of the Emergency Plan which are deficient in this regard are outlined below. Please note, however, that New Hampshire has not finalized its position on this contention.
New Hampshire is aware of its duty to supplement its answers to these interrogatories where appropriate under 10 C.F.R.
S 2.740(e).
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New Hampshire contends that the following sections of the Applicant's Emergency Plan are inadequate as they concern on-site emergency planning.
Emergency Plan S5 The Applicant has not submitted Emergency Action Levels, and has not discussed-them with State and local l Therefore, New Hampshire asserts i governmental authorities.
that the Emergency Plan does not comply with 10 C.F.R. S50.47(b)(4)), and 10 C.F.R. Part 50, Appendix E, SIV,B, and NUREG-0654, Item II(D).
Emergency Plan S6 and 97 The Emergency Plan does not assure that adequate emergency facilities and equipment are provided and
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maintained, in that the location of the various emergency
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response centers has not yet been selected, or if selected, may not be appropriate. For example, as the Applicant -
indicates in its January 5, 1983 response to New Hampshire ;
Ir.terrogatory 20.14, the location of the EOF is still under rrriew. Also, New Hampshire believes the Media Center's ,
proposed location in seabrook may be too close to the plant. !
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In addition, there is insufficient assurance that the !
facilities will be properly equipped with communications equipment, and will be capable of coordinating with State emergency response personnel. New Hampshire is particularly concerned that.the commercial telephone lines for use between the Technical Support Center (TSC) and the Emergency Operations Facility (EOF), the TSC and the Incident Field Office (IFO), and each of these facilities and the Emergency Operations Center (EOC) in Concord are inadequate. The Applicant has, then, not demonstrated compliance with 10 C.F.R. 550.47(b)(8); 10 C.F.R. Part 50, Appendix E, SIV, E; and NUREG-0654, Item II, F.
Emergency Plan 59 The Emergency Plan does not assure that those personnel responsible for classifying an accident and notifying State officials should a classifiable event occur at Seabrook Station, will be adequately experienced or j trained for this responsibility. Thus, the Emergency Plan does not demonstrate compliance with 10 C.F.R. 550.47(b)(5 and 15); 10 C.F.R. Part 50, Appendix E, SIV, D; NUREG-0654,
' Item II, O. (See also New Hampshire's answer relative to 55 of the Emergency Plan in this Interrogatory, and its answer to NRC Staff Interrogatories relative to Contention NH-13.) -
Emergency Plan S10.2 The Emergency Plan does not demonstrate that persons responsible for recommending protective actions to off-site authorities have the proper training and experience for l this responsibility. For exa.mple, this section does not l provide sufficient information on the training staff and
- program, evaluation of the training program, and the maintenance of emergency preparedness. Therefore, New Hampshire maintains that the Emergency Plan is not in compliance with 10 C.F.R. S50.47(b)(5 and 15); 10 C.F.R. Part 50, Appendix E, SIV, D.
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6 Emergency Plan Sll
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The public notification (warning) system for the .
Seabrook site has not yet been developed. (See p.11-1 cf the Emergency Plan.) Also, since the Emergency Plan does not indicate that a brochure, or other means of public information, has been developed, there is no assurance that the public will know how to respond to an emergency warning. The Emergency Plan, furthermore, does not adequately detail how the public is to be informed during an accident, or how the various emergency centers, including the Media Center, will coordinate public information functions. The Emergency Plan, therefore, is not in compliance with 10 C.F.R. Part 50, Appendix E, SIV, D, 1; and 10 C.F.R. S50.47(b)(5, 7). (See also New Hampshire's answers above regarding SS 6 and 7 of the Emergency Plan.)
Emergency Plan S12 This section of the Emergency Plan does not demonstrate that communications, medical, radiological monitoring, and health physics drills will be implemented adequately. For instance, the medical drill i,s to be conducted annually uith one simulated, contaminated person. New Hampshire asserts that this is insufficient to evaluate medical personnel and facilities. Also, the content and frequency of " scenarios," as described in 12-3 l of the Emergency Plan, is insufficient. New Hampshire contends then, that the Emergency Plan is not in compliance with 10 C.F.R. S50.47(bs(15); 10 C.F.R. Part 50, Appendix j
E, SIV, D; NUREG-0654 Item II, O.
New Hampshire has identified the above areas of concern as ones that should be improved; it has not yet developed its own position on how these improvements should be accomplished. However, it is clear from the above answers that the following steps must be taken to correct some of the deficiencies noted by the State of New Hampshire: ,
- a. submission by the Applicant of emergency action levels, after they have been discussed with and agreed upon by State and local governmental authorities;
- b. a final decision made on the location of the EOF, and consideration of changing the location of the Media Center; i
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- c. improvement of the communication systems between various emergency response centers to
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insure proper communication and coordination with .
State emergency response personnel;
- d. further detail provided on the necessary experience and training for those personnel responsible for classifying an accident and notifying State officials, and for recommending protective actions to off-site authorities;
- e. an adequate public notification system must be developed. Also, the means by which the public will be educated about the warning system and what it represents, and informed during an accident must also be demonstrated in the Emergency Plan; and
- f. an increase of the frequency of various emergency planning drills and the objectives of the drills expanded.
Q.20(c) The Applicant has not submitted Emergency Action Levels (EALs) identifying parameter values and equipment status for each emergency class. Whether the EALs when submitted are adequate and how any deficiencies could be corrected cannot be
- answered until they are submitted by the Applicant.
Q.20(d) The regulatory basis for the subject assertion is 10 C.F.R. S50.47(b), 10 C.F.R. Part 50, Appendix E, SIV, B, NUREG-0654, Item II, D (2), and NUREG-0737, Item I.C.l. Where the Applicant must analyze the postulated accidents in the FSAR, it is logical that they should be included in the initiating conditions of the emergency classification and action scheme.
Q.20(e) The reference to " environmental" plan should read
" emergency" plan. This being the case, 10 C.F.R. S50.47(b)(4),
10 C.F.R. Part 50, Appendix E, SIV, B, and NUREG-0654, Item II, D, form the basis of the subject statement.
0 20(f) Sections 3.2, 8.2, and 9.2 of the Emergency Plan state only that the Unit Shift Supervisor has the responsibility to recognize emergency conditions and notify the Shift Superintendent, and that the Shift Superintendent is responsible for classifying the observed conditions, and notifying the appropriate authorities. The responsibilities of the Unit Shift Supervisor and Shift Superintendent thus described are ambiguous in that they do not clarify how and in what time frame the Unit Shift Supervisor and Shift
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Superintendent are to carry out these responsibilities,
-- contrary to the requirements of 10 C.F.R. 550.47(b)(2) and -
NUREG-0654, Item II, B. This deficiency may be corrected by a more detailed unambiguous description of the responsibilities of the Unit Shift Supervisor and the Shift Superintendent.
0.20(g) New Hampshire will not pursue that aspect of Contention NH-20 which asserts that the Emergency Plan does not provide for adequate, continued staffing.
0.20(h) As stated previously, the Applicant has not yet submitted complete Emergency Action Levels. Also, the Emergency Plan does not demonstrate that plant personnel can properly and promptly notify off-site officials of the Applicant's protective action recommendations, as stated in New Hampshire's answer to Q.20(a)(b) above. Until more information
! is available, New Hampshire will not be in a position to describe how any' deficiencies can be corrected.
0.20(i)and(j) Section 3.2, and sections 8.2 and 9.2, of j the Emergency Plan do not assure that the Shift Superintendent will receive notification of an event and initiate emergency action properly and promptly. The procedures for emergency assessment and notification outlined in the Emergency Plan are not detailed enough to provide a sufficient basis on which a finding can be made that adequate notice will be provided by the Applicant to State and local response organizations, as required by 10 C.F.R. S50.47(b)(5). The special difficulties presented by the Seabrook site vis-a'-vis emergency response make immediate emergency assessment and notification to State officials imperative. Further detail on the Applicant's notification capabilities must be provided.
0.20(k) New Hampshire has not yet finalized its position i
on how the Applicant can comply with the the 10'C.F.R.
l 550.47(b)(10) protective action recommendation requirements.
However, New Hampshire contends at this time, as stated above in answers to Q.20(a and b), that the Emergency Plan should provide in greater detail the training and experience required i for those personnel responsible for notifying State officials and the guidelines to be followed,in making their recommendations.
Q.20(1) The Em'ergency Plan is in' complete in that it does not adequately describe the information which will be contained in the Emergency Plan brochure. Further, the Emergency Plan does not provide any means by which the effectiveness of the Applicant's public information program can be evaluated. At this time New Hampshire maintains that the means by which the public is to be informed about emergency preparedness and how
. these methods are to be evaluated must be set forth in greater detail.
0.20(m) New Hampshire has not finalized its position on how the media are to be adequately acquainted with emergency plans and procedures, in accordance with 10 C.F.R. 550.47(b)(7).
N.H. Contention 21
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The following response to the Staff's Interrogatories on N.H. Contention 21 is limited to concerns regarding on-site protective measures, in conformance with the Board's September 13, 1982, Memorandum and Order, at page 32. To the extent that the Staff's Interrogatories raise broad issues involving on-site and off-site protective actions, Neu Hampshire will respond only as to on-site issues, reserving the right to raise off-site protective action questions at the appropriate time.
_.21(a)
Q and (b) New Hampshire contends that the sections of the Emergency Plan listed below are inadequate, for the reasons stated. .
Emergency Plan S9 See New Hampshire's answers to the staff's Q.20(a) and (b), relative to Sections 5 and 9 of the Emergency Plan.
Emergency Plan S10 Subsection 10.3 of the Emergency Plan is inadequate in that it does not set forth in any detail how plant personnel will be protected from exposure to radiation.
Also, subsection 10.4 of the Emergency Plan provides no detail on how contaminated injured personnel will receive proper medical treatment. (See also the Applicant's answer to Interrogatory NH-21.2.)
New Hampshire has identified the above areas of concern as ones that should be improved; it has not yet finalized its own position on how these improvements should be accomplished. However, it is clear that until the Emergency Plan adequately demonstrates that arrangements have been made for the transportation and treatment of contaminated individuals, and that those responsible for these duties are capable of properly carrying them out, the Applicant will not be in compliance with 10 C.F.R.
S50.47(b)(12) and 10 C.F.R. Part 50, Appendix E, SIV, and NUREG-0654, Item II, L. ,
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Q.21(c) and (d)
- - As stated in the previous answer, the Emergency Plan contains insufficient reference to and assurance of the manner in which contaminated injured personnel will receive proper medical services. New Hampshire's concern focuses on the adequacy of the arrangements which have been made for transportation of victims of radiological accidents and the ability of the medical treatment facilities to properly handle contaminated individuals. New Hampshire contends that the Emergency Plan must demonstrate more completely that the necessary transportation and medical services can and will be provided.
Q.21(e) Yes. See answers to 0 21(a) (b), and (c).
Q.21(f) See answers to 0.20(a), (b) and (k) as to the bases on which protective action recommendations should be made. With regard to how on-site protective actions will be
! implemented, see relevant answers to the Staff's j
interrogatories on Contentions NH-13, NH-20, and NH-21.
Q.21(g) Yes, but for purposes of on-site protective actions, only to the extent that emergency workers may include on-site personnel. -
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Dr. Stepien S.T.~ Fan Chairman and Professor College of Engineering and Physical Sciences Department of Chemical Engineering Kingsbury Hall University of New Hampshire Durham, New Hampshire 03824 l
TTuww Mk E. Tupper RiWder
. Assistant Attorney General l
Office of the Attorney General l
Environmental Protection Division
! Georde<tapa Bisbee
l Attorney Office of the Attorney General Environmental Protection Division State House Annex Concord, New Hampshire 03301 cel. 603/271-3678
THE STATE OF 11EU HAMPSHIRE STRAFFORD, SS.
Personally appeared this /7 day of January, 1983, Dr. Stephen S.T. Fan, before me, the undersigned officer, and made oath that the foregoing statements are true to the best of his knowledge and belief.
01 d . &
tiotary Public/ Justice of 'the Peace CAROL FRENCH, Note.ry Public My Commission Expires June 6,19B4 THE STATE OF NEW HAMPSHIRE MERRIMACK, SS.
Personally appeared this day of January, 1983, E. Tupper Kinder, before me, the undersigned officer, and made oath that the foregoing statements are true to the best of his knowledge and belief.
/
M Comm ss on Exp e A 1 2,1966 I M _ / Justice Notary P Ic of the Peace THE STATE OF NEU HAMPSHIRE MERRIMACK, SS.
Personally appeared this day of January, 1983, George Dana Bisbee, before me, the undersigned officer, and made oath that the foregoing statements are true to the best of his knowledge and belief.
- M TERRY L. AUSSELL, intary Psblic [
fay Commission Exprcs April 22, 1956 Notary bliC/ Justice of the Peace
CERTIFICATE OF SERVICE
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I, E. Tupper Kinder, Esquire, hereby certify that a copy of ,
the foregoing State of New Hampshire's Response to the NRC Staff's Interrogatories and Requests for the Production of Documents Filed November 10, 1982 have been mailed this 17th day of January, 1983, by first class mail, postage prepaid, to:
Helen F. Hoyt, Chm. Dr. Emmeth A. Luebke Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. NRC U.S. NRC Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry Harbor Jo Ann Shotwell, Asst. AG Administrative Judge Office of the Attorney General Atomic Safety and Licensing One Ashburton Place, 19th Floor Board Panel Boston, MA 02108 U.S. NRC Washington, D.C. 20555 Mrs. Beverly Hollingsworth 822 Lafayette Road Roy P. Lessy, Jr., Esquire P.O. Box 596 Robert Perliss, Esquire Hampton, New Hampshire
~
03842 Office of Executive Legal Dir.
U.S. NRC William S. Jordan, II, Esquire Washington, D.C. 20555 Ellyn R. Weiss, Esquire Harmon and Weiss Robert A. Lackuc. Esquire 1725 I Street, N.W.
116 Lowell Street Suite 506 P.O. Box 516 Washington, D.C. 20006 Manchester, N.H. 03105 Edward J. McDermott, Esquire Phillip Ahrens, Esquire Sande,rs and McDermott Assistant Attorney General 408 Lafayette. Road State House, Station 96 Hampton, N.H. 03842 Augusta, Maine 04333 Atomic Safety and Licensing Robert K. Gad, Esquire Board Panel Thomas G. Dignan, Jr., Esquire U.S. NRC Ropes and Gray Washington, D.C. 20555 225 Franklin Street Boston, Massachusetts 02110 David R. Lewis, Esquire
( Atomic Safety'and Licensing i
Board I U. S . NRC - Room E/W - 4 3 9 Washington, D.C. 20555 0 Tw W E. Tupper IMnder i
Dated: January 17, 1983 i
ATTACmiENT A STEPHEN S. T. FAN Department of Chemical Engineering University of New Hampshire .
Durham, New Hampshire (603) 862-3654 Date of Birth: January 2,1934 Education: ,
Stanford'Universit'y, B.S., Chemical Engineering 1957 Stanford University, Ph.D., Chemical Engineering, 1962 Academic Experience:
1962-1967 Assistant Professor, Department of Chemical Engineering University of New Hampshire 1967-1971 Associate Professor, Department of Chemical Engineering University of New Hampshire ,
1971-1976 Associate Professor and Chairman, Department of Chemical Engineering, University of New Hampshire 1976-present Professor and Chairman, Department of Chemical Engineering University of New Hampshire Industrial Experience:
Summer 1957 Research Engineer, Wolff Process Co. , Huntington Park, California Summer 1963 Research Engineer, Gulf Oil Co., Pittsburg, Pennsylvania Summer 1964 Expert, U.S. Army Cold Regio 6s Research. Laboratory, Hanover, New Hampshire Courses Taucht:
Applied mathematics, thermodynamics, kinetics, transport phenomena, nuclear engineering, energy and pollution g Research Interests:
Waste heat utilization, heat and mass transfer, multicompnent diffusion Publications:
- 1. Regan, T. and Fan, S.S.T., " Waste Heat Utilization from Electric Power Generation", presented at the 5th National Conference on Energy and Environment, Cincinnati, Nov. 1977.
- 2. S.P. Ho, Fan, S.S.T., "Effect of Clothing on the Temperature Distribu-tion of Human Thermal System," Computers in Biology and Medicine, Dec. 1975.
^ _. _ _ _ _ _
FAN (Continued) l l
- 3. Foss, S.D. and Fan, S.S.T., " Approximate Solution to the Freezing of I the Ice-Uater System with a Constant Heat Flux in the Water Phase," )
Water Resources Research, 10_, 511-513, 1974.
._ 4. Fan, S.S.T. and Slater, S.M., "The Classification of Refineries and .
Steady ~ Stat'e Operations, Chapter III," in The Impacts of an Oil Refinery Located in Southeastern New Hampshire: A Preliminary Study. University of New Hampshire, 1974.
- 5. Foss, S.D. and Fan, S.S.T., " Approximate Solution to the Freezing of the Ice-Water System," Water Resources Research, 3_, 1083-1086, 1972.
.6. Fan, S.S.T. and Dillman, W., " Measurement of Multicomponent Gaseous Diffusion Coefficients with Chemically Reac, ting Systems," presented at the 21st Canadian Chemical Engineering Conference, Montreal, Canada Oct. 1971.
- 7. Fan, S.S.T. and Yen, Yin-Chao, "Nonsteady Compressible Flow Through Anisotropic Perous Media with Particular Reference to Snow," Water Resources Research, 4, 597-606, 1968.
- 8. Fan, S.S.T. and Yen, Y.C., " Pressure Wave Propagation in Porous Media with Non-Uniform Permeability," Research Report, '210, CRREL, U.S.
Army, 1966.
- 9. Fan, S.S.T. , Rosza, R.B. , and Mason, D.M. , " Heat Transfer in Reacting Systems: Effect of Chemical Kinetics on the Thermal Conductivity of Gases," Chem. Eng. Sci., 18, 737-752, 1963.
- 10. Fan, S.S.T. and Mason, D.M. , " Effects of Chemical Reaction on Gas Properties and Lewis Number," ARS Journal, 3_2,2 899-906, 1962.
- 11. Fan, S.S.T. and Mason, D.M., " Properties of the System N 0 :2N0 2N0 + 0 ," J. Chem. Eng. Data, 7_, 182-186, 1962. 24 2 2
- 12. Fan, S.S.T. and Mason, D.M.,. "Effect of Chemical Dissociation on Gas Properties," Preprint A, Presented at the Fifty-Fourth Annual Meeting of American Institute of Chemical Engineers, New York, N.Y., December, 1961.
Professional Affiliations:
American Institute of Chemical Engineers American Association of. University Pr,ofessors Tau Beta Pi Sigma Xi .
Consulting:
Environmental Protection Division, Office of N.H. Attorney General.
U.S. Army Cold Regions Research Lab, Hanover, N.H.
Private Firms.
FAN (Continu d)
M.S. Theses Supervised:
Kaseri Dandh -
Studies on Effective Thermal Conductivity in
',, Packed Bed - June, 1965.
Stephen Foss -
Heat Transfer in a Heterogeneous Catalytically Reacting System - June, 1965.
Eino Lilback -
Adsorption Isotherms for Freon 11 on Activated Carbon Silica Gel, and Mixed Adsorbents -
June, 1966.
Raul Acosta -
Unsteady Heat Conduction.in Chemically Reacting Systems with Local. Equilibrium - June, 1967.
George T. S. Chen -
Heat Conduction in Chemically Reacting Systems with Catalytic Surfaces - June, 1967 Warren Dillman -
The Measurements of Effective Multicomponent Diffusion Coefficients with Chemically Reacting
- / stems - June,1967.
Yue-Kwang Yang -
Heat Transfer in Chemica'ly l Reacting Flow Systems with Local Chemical Equilibrium: Film Model and the Relating Numerical Methods - June,1968.
Shi-Ping Ho- -
Mathematical Modelling for'the Human Thermal Regulation System - September, 1971.
Mohan Rao -
Adsorption Isotherms for Freon 21 on Activated Carbon, Silica Gel, and Mixed Absorbents -
June, 1971.
William Fifty -
A Mathematical Model for the Steady State Thermo-regulation of the Human Leg - June,1973.
Mahendra Shah -
Utilization of' Waste Heat From Power Generation, August, 1973.
Thomas Regan -
Utilization of Waste Heat from Nuclear Power Plants, 1976.
Shashi Lalvani -
Transport of Water Through Artificial Membranes -
August, 1979.
Ph.D. Thesis Supervised:
Stephen D. Foss, An Approximate Solution to the Moving Boundary Problem j Associated with the Freezing and Melting of Lake Ice,1974.
l i
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RESUME ,
ATTACHMENT B L. William Dotchin 306 Upper Sixth Street Dover, New Hampshire 03820 '
Telephone: (503) 742-7524 home ,
(603) 862-2790 office EDUCATION Graduate Education University of New Hampshire Durham, New Hampshire Master of Science degree in Physics was awarded in June,1965.
Recipient of Teaching Assistantship in 1962 and Research 1962 Assistantship 1963 through 1965. Thesis emphasis was on to measurements of lifetimes of atomic states using the Beam-1965 foil method. Results of this work were included in the initial proposal to NASA in 1964 for funding of the atomic and molecular beam research on the University of New Hampshire Physics Department accelerator.
Undergraduate Education Bates College Lewiston, Maine 1958 Awarded Bachelor of Science degree in Physics and Mathematics, to June, 1962. Laboratory assistant junior and senior years.
1962 Member of science honor society. Thesis emphasis on transistor circuit design.
PROFESSIONAL EXPERIENCE Hired as Director of the University Instrumentation Centor in October, 1978, a 70%-time appointment, and as Coordinator of 1978 Research Safety, a 30%-time appointment. The responsibilities as Director of the University Instrumentation Center include Present teaching a senior / graduate student course in Experimental Physics.
1973 Hired as Radiation Safety Officer at the University of New to Hampshire in July, 1973. Responsibilities include teaching a l 1978 senior / graduate student course in Experimental Physics.
1965 Hired as Research Physicist at the University of New Hampshire to in February,1965, to continue the atomic and molecular beam 1973 research begun as a. graduate student. Also hired by Physics Department as part-time instructor and placed in charge of l Department accelerator installation.
l PROFESSIONAL l SOCIETIES New Hampshire Safety Council New England Chapter of the Health Physics Society University Laboratory Managers Association l
l l
l DOTCHIN (Continued)
~;
2 COMMUNITY ACTIVITIES Member of the St. Thomas Episcopal Church vestry for the past eight years. Currently Treasurer of the church.
PERSONAL BACKGROUND Born in August, 1940, in Hartford, Connecticut. Raised in West Hartford and Wethersfield, Connecticut. Attended Wethersfield Junior and Senior High Schools. Married with two children, aged five and seven. Hobbies include: flying and gardening.
REFERENCES References available on request.
e e
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^
ATTACHMENT C Filson H. Glanz Associate Professor Electrical Engineering Department
-- A. EDUCATION , '
B.S. Math Stanford University 1956 M.S. Engineering Mechanics Stanford University 1957 Extension Course in Space Technology Digital Computers UCLA 1957-1959 Ph.D. Electrical Engineering Stanford University 1965 BB&N Underwater Acoustics - one day a month for 9 months .
1965-1966 IEEE Short Course on Digital Signal Processing B. EXPERIENCE University of New Hampshire Associate Professor 1972-present University of New Hampshire Assistant Professor 1965-1972 Stanford Electronics Laboratory Research Assistant 1963-1965 EDAL Project-Sea Lab Summer 1966 Meteor Trails December 1966 Stanford Research Institute Research Assistant 1962-1963 Lockheed Aircraft Corporation Bio Behavioral Group :
Palo Alto, California Programmer Summer 1961 Librascope, Incorporated, Analysis of land Glendale, California navigation system 1957-1960 Douglas Aircraft, El Segundo, California Math Analysis -
1955-1956 C. PROFESSIONAL HONOR SOCIETIES AND HONORS
- 1. Sigma Xi
- 2. IEEE (2 prof. groups)
- 3. Recipient of one of two UNH Alumni Distinguished Teaching Awards, May 1980 D. TEACHING RESPONSIBILITIES - Various undergraduate & graduate courses including Digital Signal Processing, Communication Systems and Digital Systems.
E. RESEARCH ACTIVITIES - in Digital Signal Processing, Meteor Trails Radar, Ecological Modelling.
F. PAPERS AND REPORTS (Partial List)
"An Azimuth Measuring System for a Meteor Trails Radar", IEEE Transactions on Geoscience Electronics, Vol. GE-9, No.1, Jan.1971, p. 56-62.
"Models for Human Operators Based.on Non-uniformly Sampled Systems",14th Annual Manual Control Conference, May 1970 Dayton, Ohio, with George D. Kontopidis and David E. Limbert.
"Models of Man-Machine Tasks Based on Non-uniformly Sampled Systems", 2nd Inter-national Conference on Information Sciences and Systems, July 1979, Patras, Greece with G.D. Kontopidis and David E. Limbert.
"A Study on Non-unifonnly Sampled Systems", International Conference on Cybernetics and Society, October 1979, Denver, Colorado, with G.D. Kontopidis and David E. Limbert.
" Computer Controlled Systems Using Multiplexed I/0", giver it the Spring Conference on Industrial, Control and Instrumentation Applications o, ini and Microcomputers, March 1980 with G.D. Kontopidis and D.E. Limbert.
i
ATTACHMENT D e
William Mosberg Associate Professor
. - Mechanical Engineering Department University of New Hampshire -
Durham, NH 03824 EDUCATION B.S. Columbia University 1956 M.S. Yale University 1960 EXPERIENCE Acad emic : .
1981 - Pres 4nt Associate Prof essor, Mechanical Engineering Department University of New Hampshire Associate Professor 6 Chairman, Mechanical Engineering l972 - 1981 Department, University of New Hampshire 1965 - 1972 Associate Professor Mechanical Engineering, University of New Hampshire 1963 - 1965 Faculty Fellow (N.S.F.) Columbia University.
1958 - 1963 Assistant Professor of Mechanical Engineering, University of New Hampshire 1956 - 1958 Teaching Assistant, Yale University INDUSTRIAL AND MILITARY Cities Service Research 6 D,velopment e Laboratory, Granberry, New Jersey,
- Engineer, Summer 1965.
Griest Manufacturing Company, New Haven, Connecticut,. Engineer, Summer,1957.
Bechtel Company, New York City, Designer, Summer, 1955.
M.W. Kellogg Company, New York City, Piping Designer 6 Engineer, 1948-1954.
Roy M. Henwood Assoc., New York City, Oil Storage Plant Designer, 1946.
U.S. Army, 1942-1946 M.E. Student A.S.T.P. at M.I.T., 1942-1943; Completed Geodetic Computing Course - 1944; Math Instructor 657 Topographic Battalion - 1944 The Lummus Company, New York City, Draftsman, 1941-1942.
l O
William Mosberg - Resura ,
Page 2 Recent Consulting Activities:
- - Howell Laboratories, Inc., Bridgton, Maine
~
Kalwall Corporation, Manchester, New Hampshire Sylvania Corporation, Exeter, New Hampshire COURSES TAUGHT Macro Thermodynamics (graduate and undergraduate)
Microscopic Thermodynamics Fluid Dynamics
- Analytical Fluid Dynamics Gas Dynamics Heat Transfer Continuum Mechanics Theoretical Hydrodynamics Engineering Mechanics Graphics and 'escriptive Geometry C0hMITTEES Chairman of Faculty and Faculty Caucus, 1973-1974 University Senator most years 19S8-1974 -
Blue and White Concerts Committee Allied Arts Committee Faculty Welfare Committee Chairman Allied Arts Committee Council on Educational Innovation M.E. Thermal Science Committee Secretary, Ph.D. Transport Phenomena Committee SOCIETY MEMBERSHIP l
AAUP - University of New Hampshire Chapter President, 1967-1968.
ASEE NYSPE F
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1 l
gf W P ATTACHMENT E MICHAEL M. NAWOJ RFD # 1 Normand Road Goffstown, New Hampshire 03045 Home Telephone 603-497-3249 Buisness Telephone 603-271-2231
SUMMARY
OF QUALIFICATIONS: ,
Nearly fifteen years of progressive emergency managment and technical experience at state and local levels of government.
Extensive project development, implementation and management experience of state and local emergency managment systems for radiological and other technical hazards. Experienced in the formulation of emergency response operations procedures, and rescource management systems. Also experienced in the management of Radiation Safety / Health ~ Physics, and radiological monitoring programs.
PROFESSIONAL AFFILIATIONS:
State of New Hampshire Civil Defense Agency Town of Goffstown New Hampshire Civil Defense Director Town of Goffstown New Hampshire Police Department United States Army
- ~
SPECIFIC EXPERIENCE:
As the state Radiological Emergency Response Planning coordinator is responsible for the development and coordination of the Radiological Emergency Response Planning Project for the~ State of .New Hampshire.
This includes coordination of radiological emergency response preparedi. ass activities for two nuclear power plant sites, Vermont Yankee, and Seabrook, as well as two Department of Defense / Department of Energy facilities, Pease Air Force Base, and the Portsmouth Naval Ship Yard. Designed and implemented the current program for the development of the State and local a radiological emergency response plans for these sites. Responsible
- for supervising the activities of agency staff and consultant
! personnel in the preperation implamentation and maintainence of state and local plans.
Developed the Radiological Defense Officer Program for the State.
Supervise the Radiological Systems Maintenance Program as well as the Radiation Safety and Training program.
b
MICHAEL M. NAWOJ (continued)
Served as a member of the Governors Hazardous Materials Advisory
.. Board.
Was Director of Civil Defense for the Town of Goffstown, New Hampshire, with responsibilities for the development and coordination of the towns Comprehensive Emergency Managment plan for all town agencies.
~ PROFESSIONAL ASSOCIATIONS:
Member Health Physics Society Radiological Defense Officer Radiological Defense Officer Instructor Trainer Member Hazardous Materials Managers Training Coulee University of .
New Hampshire Durham, New Hampshire Guest Lecturer Franklin Pierce Law School Concord, New Hampshire Guest Lecturer St Anselms College School of Nursing Manchester, New Hampshire s EDUCATION:
St. Anselms College, BA Biology .
University of Lowell, Graduate work Radiological Health '
Numerous Federal Emergency Management Agency Nuclear Regulatory Comission, Department of Defense, and Department of Energy Training Programs New Hampshire State Police Academy SECURITY CLERANCE:
SECRET (2)
ATTACHMENT F 1
NORMAN A. HOBBS, JR 6 1/2 Holmes Street
.. Nashua, New Hampshire 03060 ,
Home Telephone: 603/883-2008 Office Telephone: 603/271-2231
SUMMARY
OF QUALIFICATIONS Fifteen years of communications and communications management experience in the private sector as well as in state government and the military.
Extensive project management experience in the planning, design and implementation of complex, multi-user, and multi-channel communications and information systems. Experienced in providing technical assistance to units of state and local governments. Also experienced in microwave system planning and design. Experienced in data telecommunications information entry and retrieval for state and federal law enforcement agencies.
PROFESSIONAL AFFILIATIONS
- New Hampshire State Civil Defense Agency New Hampshire State Police U.S. Armed Forces
-U.S. Naval Reserve
-U.S. Army Reserve
-N.H. National Guard SPECIFIC PROJECT EXPERIENCE With New Hampshire Civil Defense Agency, engaged in communications system requirements analysis, design and implementation. Microwave system design, implementation and management in support of a statewide emergency network was a recent project involvment. Responsible for all facets of ,,
emergency planning for the Vernon Vermont Nuclear Power Plant. Managed New Hampshire's Emergency Response Planning to involve all appropriate state government agencies. Developed a management program in support of nuclear plants. Provided consultive assistance to state and local governments in the analysis and design of emergency communications systems. Specified and purchased communications and computer hardware for the agency. Had direct control of the New Hampshire National Warning System (NAWAS) and various Federal communications networks.
Acted as staff technical advisor to the Director on matters of telecommunications and equipment / hardware purchases as well as funding and budgetary matters.
- r. r
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a NORMAN A HOBBS, JR (continued)
(2)
While with New Hampshire State Police, managed the states participation in a national telecommunications law enforcement informational exchange network, (NCIC). Trained local and state users, and provided technical assistance to members of the law enforcement community. Served as instructor at the Police Academy on matters of . communications and computer usage. Operated various data entry / retrieval equipment as well as varied two-way radio and teletype equipment.'
PROFESSIONAL ASSOCIATIONS Past President N.H. Police Dispatchers Association Past Member N.H. Police Association Past member of the instructional team, University of New Hampshire Hazardous Materials >
CETA Program Past Member of the Executive Board of the State Employees Association Nominated to be member Federal Communications Commission Public Safety Services Subcommittee.
Member Concord Police Department Oral Board Communications Selection Committee Member Hazardous Waste Council, University of New Hampshire Member New Hampshire State Library Microwave Committee EDUCATION Manchester Technical College, Courses in Electronics U.S. Army Communications School, Fort Belvoir, VA U.S. Army Engineer School l Training Programs NRC/FEFR Technical Operations Course
- FEMA /00E Radilogical Emergency Response Organization l Decision Making Course l Analytical Reports Course Office Information Management Course, SECURITY CLEARANCE Top Secret LENGTH OF EXPERIENCE 15 years l
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