ML20081A413

Answers to 831005 Interrogatories & Requests for Documents on Emergency Planning.Certificate of Svc Encl

ML20081A413
Person / Time
Site:	Seabrook
Issue date:	10/24/1983
From:	Dignan R, Dignan T, Gad R, Johnson W PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	SEACOAST ANTI-POLLUTION LEAGUE
Shared Package
ML20081A403	List: ML20081A400 ML20081A413 ML20081A423 ML20081A438
References
ISSUANCES-OL, NUDOCS 8310260261
Download: ML20081A413 (11)

Text

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Filed: Octobsr 24, 1983 DOCKETED 6 USNRC 13 BH 25 P2:22 UNITED STATES OF AMERICA - , ,

0FF'CE OF SEl_ut .

NUCLEAR REGULATORY COMMISSION NC!!

before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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PUBLIC SERVICE COMPANY OF NEW ) Docket Nos. 50-443 OL HAMPSHIRE, et al. ) 50-444 OL

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(Seabrook Station, Units 1 & 2) )

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APPLICANTS' ANSWERS TO " SEACOAST ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE APPLICANT ON EMERGENCY PLANNING FOR THE STATE OF NEW HAMPSHIRE" Pursuant to 10 CFR S 2.740b, the Applicants hereby respond to the " Seacoast Anti-Pollution League's Interrogatories and Requests for Documents to the Applicant on Emergency Planning for the State of New Hampshire,"

served on them by mail on October 5, 1983.

i 8310260261 831024 PDR ADOCK 05000443 Q PDR

o SPECIFIC INTERROGATORIES Interrogatory No. 1 Question:

In the opinion of the Applicants, does New Hampshire law provide clear authority for the Governor to order a protective response, including evacuation, in the event of a radiological emergency? If the answer is in the affirmative, state with particularity the legal analysis upon which that conclusion is based, including the steps and thought processes utilized in arriving at that conclusion.

Provide all applicable references to existing statutory and case law, and cite any and all documents or other informational sources relied upon in your response.

Objection:

The question is objected to as being purely a question of law and a request for legal research to be done for SAPL at Applicants' expense. SAPL has its own counsel which it can ask to provide it a legal analysis of the question asked.

Interrogatory No. 2 Question:

In the opinion of the Applicant, does the NHRERP provide for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability to determine doses received by emergency personnel? Does, in the opinion of the Applicant, the NHRERP comply with 10 C.F.R. $50.47(b)(11)?

Does, in the opinion of the Applicant, the NHRERP comply with the criteria under NUREG-0654 K.3.? If the responses to any and/or all of the above are in the affirmative, state in minute detail the facts upon which your conclusions are based, including detailed citations to all documents and/or other informational sources upon which you rely for your answer. If any of the answers are in the affirmative, cite the provisions, including page numbers, within the NHRERP '

which provide for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability to determine doses received by emergency personnel, including citations to provisions in the NHRERP, including pages, which provide for the equipment necessary to provide that capability with i

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respect to all emergency personnel within the 10 and 50 mile EPZ's, respectively, and provide in detail the basis upon which you conclude that such equipment will be sufficient to meet the criteria of NUREG-0654K.3. If, any or all of the responses to interrogatories 1 or 2 are in the negative, similarly provide in detail the basis for that response, including detailed citations to any or all supporting documents or other informational sources relied upon in support of the answer.

Answer:

The answer to all three questions is "Yes." The New Hampshire RERP provides for tracking of doses received by emergency personnel throughout the course of an accident response. Section 2.7.2 Dosimetry in the RERP describes the steps to be taken to record emergency worker exposures. The EOCs and the IFO wouild be manned continuously during an emergency condition thereby allowing for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> monitoring of exposures. Section 2.7.4 of the RERP describes the means for monitoring radiation exposures of emergency workers during accident response activities. The guidelines, consistent with EPA Protective Action Guides for limiting emergency worker's exposures are presented on Table 2.6-1 of the RERP. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> capability to determine doses would be provided by staff at the local EOCs who would keep the Department of Public Health personnel at the IFO informed of the exposure history of emergency workers. The log sheet shown in Figure 2.7-1 would be used to record the appropriate data. The local EOCs and IFO would be staffed continuously during emergency operations. Three dosimeters

will be distributed to each emergency worker. These include a high range and low range self-reading dosimeter.

Emergency workers will be instructed to read their dosimeters at specified intervals and report exposures to the EOC or IFO as appropriate, when specific dose levels have been reached. Section 2.7.4 of the New Hampshire RERP provides additional details. Monitoring equipment and dosimeters which will be provided in each EOC are listed on Table 2.7-1 of the RERP.

Interrogatory No. 3 Question:

In the opinion of the Applicant, does the NHRERP adequately provide for the radiological decontamination of emergency personnel wounds, supplies, instruments and equipment, including showing that there exists a means for waste disposal? If the answer is in the affirmative, state in detail the factual basis upon which the response rests, including detailed citations to supporting documents and/or informational sources relied upon for the response.

Answer:

Yes. Section 2.7.5 and Appendix H of the Department of l

Public-Health Procedures (which are attached to the New Hampshire RERP as Appendix B) discuss the subject of l

decontamination. With regard to decontamination of persons l

with wounds, Appendix H states that such persons should be referred to medical facilities for specialized treatment.

No discussion is presented in the New Hampshire RERP for decontamination of supplies, instruments and equipment.

Section 2.7.5 concludes with a statement that procedures for

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waste disposal have been adopted by DPH and are on file in DPH offices. Applicant has not reviewed these procedures.

Interrogatory No. 4 Question:

If (sic) the Applicant aware of any' provision in the NHRERP for any decontamination centers adequately staffed and equipped to perform the numbers of decontaminations that would be required of emergency personnel and supplies, instruments and equipment? If so, cite with particularity the provisions and page numbers in the NHRERP which make the above provision.

Objection:

The NHRERP is a document. The document speaks for itself. Without waiving the foregoing we suggest that Appendix H and Section 2.7.5 appear to discuss the subject referenced.

Interrogatory No. 5 Question:

Does the NHRERP, in the opinion of the Applicant make any analysis or reference to hospital treatment facilities and emergency workers which would provide decontamination of emergency personnel wounds?

l Answer:

Yes.

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Interrogatory No. 6 Question:

Does, in the opinion of the Applicant, the NHRERP provide sufficient means for waste disposal of low-level radioactive waste resulting from decontamination of emergency personnel wounds, supplies, instruments and equipment? If the answer is in the affirmative, state with particularity the provisions in the plan that provide for such disposal, as well as citations to page numbers. Also state with particularity the individuals responsible for such waste disposal, their authority to engage in low-level radioactive waste disposal, and their professional qualifications to engage in that activity. Also state with particularity the cites identified for location of low-level radioactive waste resulting from such decontamination referred to above, whether those sites be temporary or

! permanent.

l Answer:

l See response to question 3.

l l Interrogatory No. 7 Question:

i l Does, in the opinion of the Applicant, the NHRERP comply with the requirements of 10 C.F.R. 650.47(b)(10) and NUREG-l 0654 J.11.7 If the answer is in the affirmative, cite the l

provisions in the NHRERP which support your response, including page numbers. In particular, state where the plans provide for (a) maps for recording survey and l

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monitoring data, key land use data, dairies, food processing plants, water sheds, water supply intake and treatment plants, and reservoirs, (b) identification of procedures for detecting contamination, for estimating the dose consequences of uncontrolled ingestion, and for imposing protection procedures such as impoundment, decontamination, processing, decay, product diversion, and preservation, (c) criteria for deciding whether dairy animals should be put on stored feed, and (d) the protective measures to be used for the ingestion pathway, including the methods for protecting the public from consumption of contaminated food stuffs.

If, in the event the Applicant is unable to cite provisions in the NHRERP which provide for the above mandated criteria, state with particularity why the Applicant concludes that the NHRERP is nevertheless adequate to protect the public.from contamination through the ingestion exposure pathway notwithstanding its inability to meet the applicable criteria under NUREG-0654 J.ll. If in the event the Applicant is of the opinion that the NHRERP is inadequate in this regard, state with particularity how and when these criteria will be met, and identify the specific resources available within the State of New Hampshire to implement those criteria.

Answer:

Yes. Sections 2.6.4-2.6.8. The maps are not required to be in the plan by NUREG-0654. Objection is made to supplying further detail as the document speaks for itself.

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Signatures As to Answers:

I, Wendell P. Johnson, being.first duly sworn, do depose and say that the foregoing answers are true, expect insofar as they are based on information that is available to the Applicants but not within my personal knowledge, as to which I, based on such information, believe them to be true.

EsI b Vendelf P. Jo ison nLu

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Sworn to before me this day of October, 1983:

llC u_ m&

lNotaryPublic 6 My Commission expires: g/.D c/J' [

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.As to Objections: -

A s der Thomas G. Dignan, Jr.

R. K. Gad III Ropes & Gray 225 Franklin Street l Boston, Massachusetts 02110 Telephone: 423-6100 I

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CERTIFICATE OF SERVICE I, Thomas G. Dignan, one of the attorneys for the Applicants herein, hereby certify that on October 24, 1983, I made service of the within Applicants' Answers to Seacoast Anti-Pollution League's Interrogatories and Requests for Documents to the Applicant on Emergency Planning for the State of New Hampshire 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 Harmon & 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 Regalatory Director Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 Atomic Safety and Licensing Robert A. Backus, Esquire j Appeal Board Panel 116 Lowell Street

! U.S. Nuclear Regulatory P.O. Box 516 Commission Manchester, NH 03105 Washington, DC 20555 l

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Philip Ahrens, Esquire Anne Verge, Chairperson Assistant Attorney General Board of Selectmen Department of the Attorney Town Hall General South Hampton, NH Augusta, ME 04333 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 Charles Cross, Esquire Ms. Olive L. Tash Shaines, Madrigan & McEachern Designated Representative of 25 Maplewood Avenue the Town of Brentwood P. O. Box 366 R.F.D. 1, Dalton Road Portsmouth, NH 03842 Brentwood, NH 03833 Ms. Roberta C. Pevear 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

. IUN) 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 Town Manager's Office Town Manager Town Hall Town of Exeter Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833

Brian P. Cassidy, Esquire Brentwood Board of Selectmen Regional Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833

Agency - Region I 442 POCH Boston, MA 02109

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'M/PF Thomas G'.~ pitfhan, Jr.

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