ML20082P979

Supplementation to Answers to Atty General Bellotti Interrogatories Re Emergency Planning.Certificate of Svc Encl

ML20082P979
Person / Time
Site:	Seabrook
Issue date:	12/05/1983
From:	Gad R, Johnson W PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	MASSACHUSETTS, COMMONWEALTH OF
Shared Package
ML20082P972	List: ML20082P966 ML20082P979
References
ISSUANCES-OL, NUDOCS 8312090263
Download: ML20082P979 (10)

Text

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Filsd: Daccmber 5, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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' SUPPLEMENTATION TO ANSWERS TO INTERROGATORIES Pursuant to their undertaking to do so (see

" Applicants' Answers to ' Attorney General Bellotti's Motion to Compel Answers to " Attorney General Bellotti's Interrogatories and Requests for Documents to Applicants on Emergency Planning for the State of New Hampshire"'" (November 3, 1983)), the Applicants hereby supplement their answers to interrogatories as

, follows:

8312090263 831205 PDR ADOCK 05000443 G PDR

Interrogatory No. 3

a. and b. Emergency transportation needs and resources are identified in Appendix E EPZ Evacuation Time Study, July 1983.,Section VI.D. of that report suggests a method to satisfy the transportation requirements. Applicants understand that arrangements are presently being made to assure the availability of transportation equipment and drivers.

c. The New Hampshire RERP (section 2.8.4) describes the plans for medical treatment for contaminated, injured individuals. Applicants understand that letterc of agreement between the State and the designated hospitals are in preparation.

d.. Section 2.5.3 lists the equipment which will be provided for each monitoring team. This equipment is considered adequate to assess the consequences of an accidental release of radioactivity to the atmosphere.

Applicants are not aware of the current status of the specified equipment (e.g., in hand, on order, etc.) but expect that the State will have the equipment in sufficient time to support the emergency preparedness program for Seabrook Station.

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e. Sections 2.7.2 and 2.7.3 of the New Hampshire RERP discuss the dosimetry and respiratory protection devices which are to be provided. Applicants do not have specific knowledge of the availability of this equipment but expect that it will be available in sufficient time to support the emergency preparedness program for Seabrook Station.

f. Table 17 in Appendix E EPZ Evacuation Time Study identifies a need for 46 people to act as traffic controllers in the New Hampshire portion of the EPZ.

Applicants do not currently have an opinion as to the adequacy of this traffic management scheme, but on the assumption that it is adopted, applicants believe that State and local police and other' supporting agencies can provide 46 traffic controllers.

g. See response to a. and b., above. Applicants understand that the State is acting to formalize agreements to assure the availability of manpower for emergency transportation.

Applicants assume that " security operations" refer to restricting access to emergency facilities. The Emergency Operations Center is the only facility for which the State would provide security. Security of

the Emergency Operations Facility would be maintained L by the facility operators, personnel of the Civil Defense Agency, and if a special problem arose, police assistance would be requested. Applicants do not anticipate any significant security problems.

h. Section 2.6.5 on the New Hampshire RERP discusses evacuation as a possible protective action.

The plan commits the resources of the New Hampshire Department of Public Works and Highways to maintain the availability of the evacuation routes.

i. Table 2.4-4 in the New Hampshire RERP identifies those facilities to which State personnel are assigned. Applicants believe that the State can provide sufficient manpower to staff these facilities as part of the initial response. This capability has been demonstrated by the State at approximately the same scale during two exercises of the Vermont Yankee emergency preparedness program.

The State acknowledges a potential need for support in the event of an extended emergency situation.

Section 1.1.4 identifies three in-place agreements among the six New England states to provide mutual support in the event of emergencies. Section 1.4.5

1 identifies anticipated needs for Federal assistance.

Applicants believe the combination of in-state, New England and Federal resources will enable State emergency facilities to be adequately staffed for an extended period.

Interrogatory No. 8 "I-131 Behavior During the TMI-2 Accident,"

NSAC/30, September 1981, Nuclear Safety Analysis Center, operated by Electric Power Research Institute, 3412 Hillview Avenue, Palo Alto, California 94304.

" Application of Reduced Source Terms in Reactor Accident Analysis," E.A. Warman et al., Stone & Webster Engineering Corporation, Boston, Massachusetts; presented at 1983 Conference of Engineering and Operation Division, Southeastern Electric Exchange, April 14, 1983, New Orleans, Louisiana.

Interrogatory No. 9 Yes. Both Applicants and the State of New Hampshire have adopted the same four tiered emergency classification system as documented in Section 5 of the Seabrook Station Radiological Emergency Plan and Section 1.5 of the New Hampshire RERP.

Both Applicants and the State have adopted the initiating conditions in NUREG 0654 Appendix 1 as a basis for classifying events. Applicants have adopted the Westinghouse Owners Group approach to emergency event classification, which is a further refinement of

-the Appendix 1 examples. This system was reviewed in a meeting with New Hampshire representatives on June 17, I

1983 and these details were subsequently incorporated into Appendix A of the Seabrook Station Radiological Emergency Plan. It is Applicants' belief that the State is in agreement with this scheme.

On the basis of this information Applicants believe that the " emergency action level scheme" of the State of New Hampshire is consistent with that of Applicants.

Both are based on the same emergency classifications and both are based on NUREG 0654 Appendix 1 for example

. Initiating conditions. Therefore, Applicants believe that in the event of a drill or.a real emergency, if Seabrook Station notifies the State of New Hampshire that a particular emergency level exists (e.g., Alert),

the State will accept this and respond in accordance ith the New Hampshire RERP.

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l 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 basa.d 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.

A c.1//. 7 !:1./r L , .

Wendell P. Johnson

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Sworn to before me this day of November, 1983:

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_ 'ary Public QVj Commission Expires:

1. A. CAlLLER, KOTARY PUBUC As to Objections: My Caml5Sl0B tiplRS Apr.13,1987 p ...s Thomas G. Digflan, Jr.

R. K. Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100

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l-CERTIFICATE OF SERVICE 1

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I, R. K. Gad III, one of the attorneys for the l

Applicants herein, hereby certify that on December 5, 1983, I made service of the within " APPLICANTS' SUPPLEMENTATION TO ANSWERS TO INTERROGATORIES" 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, 'O 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 bafety 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 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 Assistant Attorney General Board of Selectman Department of the Attorney Town Hall General South Hampton, NH Augusta, ME 04333 Carole F. Kagan, Esquire Jo Ann Shotwell, Esquire Atomic Safety and Licensing Assittant 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 l

Designated Representative of Selectmen's Office l the Town of Hampton Falls 10 Central Road l Drinkwater Road Rye, NH 03870 l 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

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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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