ML20148K335

State of Nh Responses to Atty General Jm Shannon Offsite Emergency Plan Interrogatories & Request for Production of Documents (Set 3).* Certificate of Svc Encl.Related Correspondence

ML20148K335
Person / Time
Site:	Seabrook
Issue date:	03/24/1988
From:	Strome R NEW HAMPSHIRE, STATE OF
To:	MASSACHUSETTS, COMMONWEALTH OF
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ML20148K313	List: ML20148K308 ML20148K335
References
OL, NUDOCS 8803310081
Download: ML20148K335 (22)

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UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION DOCKETED USNRC.

Before the Nuclear Regulatory Commission 16 My? 29 A9:38

) OCXih.c.f$3fy-In the Matter of ) Docket Nos. 50-44 3-OLastwey

) and PUBLIC SERVICE COMPANY OF ) 50-444-OL NEN HAMPSHIRE ) (Off-Site Emergency (Seabrook Station, Units 1 and 2 ) Planning Issues)

) March 24, 1988 ,

THE STATE OF NEW HAMPSHIRE'S RESPONSES TO ATTORNEY GENERAL JAMES M. SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS (SET NO. 3)

1. Identify all documents on which you will rely to support your position on the sheltering contentions, and produce all such  ;

documents not previously produced. Identify the information in each document on which you will rely and the specific subpart of each .

contention which that information concerns.

2. State whether you have relied, do rely, or will rely on any study, calculation, or analysis to support your position on the sheltering contentions. If so, to the extent you have not already done so, please:

a. Describe the nature of the study, calculation or analysis and identify any documents that discuss or describe the study, calculation or analysis; t

b. Identify the persons who performed the study, calculation of analysis;

c. State when and where the study, calculation or analysis was performed; r

d. Describe in detail the information or data that was studied, calculated or analyzed;

e. Describe the results of the study, calculation or analysis;

f. Explain how such study, calculation, or analysis provides I support for your position on each of these contentions. "

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Response to Interrogatories Nos. 1 and 2 The State relies on no documents other than NHRERP Volumes 1, 4, and 6 to support its position with respect to the sheltering contentions which are the subject of the current ASLB proceedings.

Further, the State's positions on sheltering as a protective action, and on the sheltering contentions, were devloped without use of any study, calculation, or analysis other than those NRC technical studies, and EPA and FEMA guidance which are generally available.

The Shelter Study completed for the Applicants by Stone and Webster Engineering Corporation, and furnished to the State, has been submitted by New Hampshire to FEMA for technical review and guidance. While the State has reviewed the study, it has neither adopted it nor incorporated its findings into the NHRERP. For further information, see page 7 through the second paragraph of page 8 of the enclosure to the letter from Richard H. Strome, Director, New Hampshire Office of Emergency Management, to Henry G. 'Jickers, Regional Administrator, Federal Energency Management Agency, dated February 11, 1988 ("NH Response").

3. Do you intend to offer the testimony of any expert witness with respect to sheltering contentions? If so, please:

a. Identify each expert witness who you intend to present with respect to each subpart of each such contention;

b. State the substance oi the facts to which each expert witness is expected to testify;

c. State the substance of the opinion or opinions to which each expert witness is expected to testify;

d. Provide a summary of the grounds for each opinion to which each_ expert witness is expected to testify;

e. State whether the facts and opinions listed in response to the foregoing are contained in any document;

f. State whether the opinion of any expert witness is based in whole or in part on any scientific rule or principle, and, if so, set forth such rule or principle;

g. State whether the opinion of any expert witenss is based in whole or in part on any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon; and

h. State whether the opinion of any expert witness is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.

4. Do you intend to offer the testimony of any non-expert witness with respect to the sheltering contentions to be litigated by the Attorney General? If so, please:

a. Identify each non-expert witness who you intend to present with respect to each subpart of each such contention;

b. State the substance of the facts to which each non-expert witness is expected to testify; and

c. State whether the facts listed in response to the foregoing are contained in any document, and produce the same.

5. Identify, as defined in Paragraph 4, all experts and other persons you have retained to prepare testimony on the sheltering contentions and all experts and other persons with whom you have consulted in preparation of any testimony on the sheltering contentions, whether or not you have decided to introduce such testimony, and for each such per: Sn, please:

a. Identify the contention or subpart of the contention on which he was consulted, or on which he has or is preparing testinony;

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b. State the substance of the facts to which each expert may testify;

c. State the substance of the opinion or opinions to which each expert may testify;

d. Provide a summary of the grounds for each opinion to which each expert may testify;

e. State whether the facts and opinions listed in response to the foregoing are contained in any document;

f. State whether the opinion of any expert is based in whole or in part on any scientific rule or principle, and, if so, set forth rules such or principle;

g. State whether the opinion of any expert witness is based in whole or in part on any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon; and

h. State whether the opinion of any expert witness is based 'r whole or in part upon any scientific or engineering book ot other publication, and, if so, identify the book or publication.

Resoonse to Interrocatories Mos. 3-5 The State does not ' ntend to sponsor testimony on the sheltering contentions. State personnel, however, are expected to testify on any panel sponsored by the Applicants on this subject. These individuals, who are listed below, if asked to participate on the Applicants' panel, would testify on those portions of the NHRERP relative to sheltering, on amplifications thereof offered in the NH Response, and on portions of any prefiled testimony prepared by the l Applicants on the subject.

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The State personnel expected to testify on a witness panel of the Applicants are at follows:

Richard H. Strome, Director, New Hampshire Office of Emergency Management William T. Wallace, MD MPH, Director, Division of Public Health Services, Department of Health and Human Services John D. Bonds, Assistant Director / Planning, Division of Public

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Health Services, Department of Health and Human Ser' vices

6. In accordance with 10 C.F.R. S2.740(e), please supplement your answers with respect to sheltering contentions to Massachusetts Attorney General's Interrogatories and Requests for Production of Documents, filed March 5, 1987 and May 19, 1987.

Response to Interrogatorv No. 6 The State's responses to interrogatories submitted on March 5, 1987 and May 19, 1987 by the Massachusetts Attorney General need no further supplementation beyond those modifications included in the NH Response and in testimony of state employees testifying on panels offered by the Applicant.

7. State how and in what manner, if any, your current position with respect to sheltering the summer beach population differs from the position articulated in Applicants' prefiled Direct Testimony No.

6 on Sheltering, dated September 10, 1987, and provide, for each specific change, including all supporting documentation.

Response to Interrogatory No. 7 The State's "current position with respect to sheltering the summer beach population" is articulated in the NH Response and the NHRERP, which are dccuments that speak for themselves. In the main, however, the NH Response is a clarification and elaboration of the State's position on possible sheltering of the beach population.

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8. On p. 3, at 12, of the "New Hampshire Response to FEMA Supplemental Testimony" ("NH Response"] it is stated with respect to the State's position on sheltering, "This position does not preclude the State from considering and selecting sheltering as a protective action for the beach population." Pl?ase identify and describe:

a. Under what conditions the State would consider and might select sheltering as a protective action for the beach population;

b. The means by which tha beach population will be instructed to shelter, including any emergency messages;

c. How the buildings which will shelter the beach population will be identified;

d. The specific buildings which will be relied upon to shelter the beach population;

e. The personnel who may be employed to assist the beach population in seeking shelter, including the numbers of such personnel who may be available and a description of any training such personnel will receive pertinent to that task; and

f. Any agreenents, understandings, or other communications with the owners of buildings that may be used as public shelters relating to the owners' consent to use their buildings as public shelters in the event of an accident at Seabrook Station.

Response to Interrogatory No. 8

a. The State described the conditions for which it would consider and might select shelter for the beach population in the NH desponse beginning at page 5, third paragraph and continuing through page 6.

b. With regard to any recommendation to the beach population to seek shelter, Attachment 3 to the Applicants' Prefiled Testinony No. 6 consisted of sample nessages. The State continues to review these messages and has not decided their final form. With regard to a reconmendation that transportation-dependent transients seek shelter, the NH j Response states, at page 8, as follows:

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We propose to amend the plan to identify potential shelter locations for the transient population without transportation. The appropriate EBS message will be modified to provide for instructions to persons on the beach who have no means of transportation to go to public shelters to await assistance in the event evacuation of the beach is reconnended,

c. Potential shelters for transportation-dependent transients have not been selected, as noted in the NH Response at page 8 (see the above quote). Further, there has been no consideration of what buildings would be suitable as shelter for the beach population. Therefore, the State cannot, at present, indicate low such buildings will be identified.

d. See the response to e, above, e-f. The State has not considered the emergency personnel requirements associated with sheltering the beach population, and, because it has not identified any buildings and has not determined the e:: tent to which agreenents, understandings, or communications are needed or required, no such documents are available.

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9. On page 22 of Applicants' Direct Testinony No. 6 (Sheltering), dated September 10, 1987, it is stated with respect to the beach population, that:

Sheltering for example may be the appropriate protective action for a puff release -- a gasecus or gaseous and particulate release -- of less than two hours duration.

(Manual of Protective Action Goides, U.S. EPA, p. 129.)

Do you still contend that sheltering of the beach population may be the appropriate protective action for a puff release of lees than two hours duration?

Resoonse to Interrogatory No. 9 Yes. As stated in the same paragraph from which the quote is taken, "(s]heltering, which can be implemented quickly, in this case may afford a greater dose savings than evacuation if evacuation cannot be completed prior to release."

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10. Do you anticipate that there might be circumstances in which transients with access to transportation would be instructed to shelter?

Response to Interrogatory No. 10 The State does not anticipate-i.e., expect "that there might be circumstances in which transients with access to transportation would be instructed to shelter." Rather, because it cannot categorically rule out the possibility that such circumstances could occur, however remote the possibility, the State does acknowledge the potential for such circumstances to occur. See the NH Response, page 5, second paragraph, through first full paragraph on page 6.

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11. Please define the term "transient beach pop'ilation" as used in the NH Response, stating whether the term applies only to f day-trippers to the beach area or whether it also includes overnight i visitors staying in motels, hotels or rental cottages.

Resoonse to Interrogatory No. 11 The term "transient beach population" includes ooth the day-trippers and "overnight visitors staying in motels, hotels or rental cottages." The term is meant to describe those individuals whose normal residence is not within the beach area and who travel from their normal residence to the beach area, regardless of their length of stay.

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12. On page 4 Ef th Nil Response it is stated, "The addition of these precautionary measures alleviates most concerns about sheltering the beach population." What State concerns does it not alleviate?

Resnonse to Interrogatorv No. 12 The concerns referenced at page 4 of the !!H Resr onse are general concerns of the State about recommending sheltering as a protective action for any population potentially at risk of radiological exposure / contamination. The implementation of precautionary measures would remove, in advance of any need to recommend protective actions, a substantial portion of the population at risk. Therefore, to the extent that concerns center on the size of the population, those concerns are lessened. They remain, however, to some degree, as long as any population remains in the beach area.

13. On p. 4 of the NH Response it is stated, "These precautionary actions and the State emphasis on getting the population out early are consistent with actions planned at other nuclear power plant sites with transient populations."

a. What are the "other nuclear power plant sites" referred to in the above sentence?

b. What is the size of the transient populations at these other sites?

c. What are .he evacuation time estimates for the transient populations at these other nuclear power plant sites?

_. What ~ is the proximity of the transient populations at these other sites to the nuclear power plant?

e. Is any sheltering available for the transient populations at these other sites, and, if so, what are the Dose Reduction Factors (DRF] of these shelters?

Response to Interrogatory No. 13 See the following chart.

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EPZ Transient Proximity of Site Pooulation ETE Transients'to Site Shelter Study a b c d e Surry (VA) 42,000 n/k 8-10 mi. None. Sheltering may be recommended.

Zion (IL) 50,000 n/k 1-5 mi. None. Shelter not recommended.

Brunswick (SC) 8,000 n/k 2-7 mi. None. P/A for transients same as for residents shelter not recommended.

Millstome (CN) 81,000 n/k 4 1/2 mi. None. Sheltering may be recommended.

No specific sheltering procedure.

Perry (OH) 30,000 n/k to 10 mi. None. Shelter not recommended. No specific shelter provided.

Davis 29,000 n/k 7-8 mi. None. Shelter not Besse (OH) recommended.

DC Cook (MI) tens of n/k to 5 mi. None. Shelter not thousands recommended for transients.

Pilgrim (MA) 29,000 n/k 1-9 mi Yes.

Identification of specific shelters with shelter factor .9.

St. Lacie (FL) 21,000 n/k n/k None. Shelter may be recommended.

Indian Point n/k n/k None. Shelter not (NY) recommended.

Palicada (M:) 19,000 n/k adjacent to site None. Shelter not recommended.

n/k - Information not known to the State.

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14. On p. 7 of the NH Response, it is stated: "It (the Shelter Study] identified a-large number of shelters that may serve as a pool fron which public shelter choices will be made." Please answer:

a. How and when will~such choices be made?

b. On what criteria will the choices be based?

Response to Interrogatory No. 14 The State i.as not yet developed a schedule for designating the shelter facilities to be identified for use by transportation dependent transients. The State intends to rely, to the extent possible, on municipal or State owned structures for the public shelter facilities. The criteria suggested on page 7 cf the NH Response to FEMA Supplemental Testimony will be considered in the review of these public buildings. Furthermore, the State continues to rely upon FEMA for technical assistance and guidance, and the State is awaiting an assessment of the shelter study documents submitted to the State by the Applicants which have been forwarded to FEMA by the New Hampshire Office of Emergency Management.

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15. Provide copies of all draft or proposed amendnents to the NHRERP concerning protective actions for the beach population that the State is presently considering and for each proposed amendment:

a. State whether the State has any present intention to adopt such amendments;

b. Describe the steps that must be taken before such amendment is adopted;

c. Provide the anticipated date by which such amendment will be adopted;

d. State whether there are any considerations against adopting such amendment, and the basis of such considerations; and

e. Provide any proposed changes to the draft amendment.

Resconse to Interrogatorv No. 15 The only proposed amendments to the NHRERP concerning protective actions for the beach population which exist in written form at this time were provided as Attachment II to the NH Response. The condition for adopting this amendment is stated on page 9 of the NH Response, second full paragraph, and is explained on the same page, third paragraph, through page 10. The State is uncertain as to what is meant by the steps referred to in subpoint b, but, should the amendment be found appropriate by the Federal Emergency Management Agency, it would be adopted by the State in a future revision of the NHRERP and the necessary page changes would be made in all copies of the Plan. The State does not know, at this time, when that sculd occur, and does not have any proposed changes to the draft amendment. There are no considerations against adoption of this amendment.

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16. Does the term "beach population" as used in the NH Response include permanent residents of the Seabrook and Hampton beach area?

Response to Interroaatory No. 16 Yes.

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17. Do you foresee any situation in which the transient beach population wculd be instructed to evacuate and the residents of the Seabrook and Hampton beach area instructed to shelter?

Response to Interrogatory No. 17 The State does not foresee this situation but does acknowledge that a potential for this situation does exist, given the unlimited nunber of accident scenarios which may be hypothesized. Therefore, the NHRERP, Rev. 2, Vol. I at page 2.6-6, describes the shelter-in-place concept which provides that:

Those at home are to shelter at home; those at work or school are to be sheltered in the workplace or school building. Transients located indoors or in private homes will be asked to shelter at the locations they are visiting if this is feasible. Transients without access to an indoor location will be advised to evacuate as quickly as possible in their own vehicles (i.e., the vehicles in which they arrived).

This NHRERP provision is amplified in the NH Respon3e at page 6, in the two full paragraphs on that page.

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18. On page 29 of Applicants' Direct Testimony No. 6 it states: l l

The result of the residential survey showed that 34 percent l of 3,036 residences in Hampton Beach and 51 percent of 758 residences in Seabrook Beach provide basement and masonry sheltering capability. The remaining percentage of residences provide sheltering characteristics at least as effective as that assumed by the NHRERP. The field survey revealed very few wood-frame residences that would not meet these sheltering characteristics.

Please produce such survey, and all documentation, notes, calculations and memoranda pertinent thereto, and for each residence surveyed:

a. Provide the address of the residence;

b. Indicate the type of residence, e.g., whether it is an apartment, house, condominium, etc.

c. Indicate whether the residence has a basement or masonry sheltering capability;

d. Indicate whether the residence does or does not "provide sheltering characteristics at least as effective as that assumed by the NHRERP."

Response to Interrogatory No. 18 The State has only the document completed by Stone and Webster and released by the Applicants in August, 1987 entitled "A Study to Identify Potential Shelters in the Beach Areas Near Seabrook Station," and an analysis of that study completed and released by the Applicants to the State in February 1988. The information requested in subparagraphs a - d, other than that contained in the shelter study, is not in the possession of the State.

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19. On what basis do you contend that the. sirens in the beach area, when used in the voice mode to instruct the beach population, can be intelligably-heard and understood by all persons in the beach area? Please provide copies of any.and all documentation, calculations and analyses including.any acoustical tests, that form, or are in any way relevant to, the basis for your response, whether or not it supports your-response.

Response to Interrogatory No. 19 The State relies on the Seabrook Station Public Alert and Notification System Final Design Report dated January 1984 for this position. This report has been served on the parties to this proceeding.

SIGNATURES I, Richard H. Strome, being first duly sworn, do depose and say that the foregoing answers are true, except insofar as they are based on information that is available to the State but no'. within my personal knowledge, as to which I, based on such information, believe them to be true.

/ /s x-( / Dx Richard H. Strome Radiological Emergency Planning Director Office of Emergency Management Sworntobeforemethisel$fb day of March, 1988:

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My Commissiot Expires: L 7, IM l

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' CERTIFICATE OP SERVICE I, George Dana Bisbee, hereby certify that on this 25th day of Marcho 1988, copies of the State of New Hampshire's Responses to NECNP Interrogatories and Attorney General James M. Shannon's Off-Site EP Interrogatories and Requests for the Production of Documents were mailed postage prepaid to the following:

• Administrative Judge Ivan W. Smith

• Administrative Judge Sheldon J.

Chairman Wolfe, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555

• Administrative Judge Gustave *Dr. Jerry Harbour A. Linenberger, Jr. Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. N.R.C. Commission Washington, DC 20555 Washington, DC 20555 Philip Ahrens, Esquire

• Thomas G. Dignan, Jr., Esquire Deputy Attorney General R. K. Gad, III, Esquire Peter J. Brann, Esquire Ropes & Gray Assistant Attorney General 225 Franklin Street Department of the Attorney General Boston, MA 02110 State House Station 6 Augusta, ME 04333 *Sherwin E. Turk, Esquire Deputy Assistant Chief

• Carol S. Sneider, Esquire Hearing Counsel Assistant Attorney General Office of the Executive Counsel Department of the Attorney General Director One Ashburton Place, 19th Floor U.S. Nuclear Regulatory Commission Boston, MA 02108 Washington, DC 20555 Ms. Diana P. Randall

• Robert A. Backus, Esquire 70 Collins Street Backus, Meyer & Solomon Seabrook, NH 03874 116 Lowell Street P.O. Box 516 Manchester, NH 03105

• Served by express mail service EP4 EEW k e8

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• Diane Curran, Esquire Harmon & Weiss 20001 S Street, N.W. Chairperson Suite 430 Board of Selectmen Washington, DC 20009-1125 Town of South Hampton East Kingston, NH 03827 Jane Doughty 5 Market Street Mr. Ed Thomas Portsmouth, NH 03801 PEMA, Region 1 John W. McCormack Post Office Brentwood Board of Selectmen and Court House RFD Dalton Road Post Office Square Brentwood, NH 03833 Boston, MA 02109 Judith H. Mizner, Esquire Charles P. Graham, Esquire Silverglate, Gertner, Baker, McKay, Murphy and Graham Fine, Good, and Mizner 100 Main Street 88 Broad Street Amesbury, MA 01913 Boston, MA 20110

• Paul McEachern, Esquire J. P. Nadeau, Esquire Matthew T. Brock, Esquire Selectmen's Office Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P. O. Box 360 Portsmouth, NH 03801 Mr. Calvin A. Canney City Manager Ms. Roberta C. Pevear City Hall The Town of Hampton Falls 125 Daniel Street Portsmouth, NH 03801 Drinkwater Road Hampton Falls, NH 03844 Mr. Angie Machiros Mrs. Sandra Gavutis Chairman of the The Town of Kensington Board of Selectmen RFD 1, Box 1154 (Route 107) Town of Newbury Kensington, NH 03827 Newbury, MA 01950 Senator Gordon J. Humphrey Peter J. Matthews U.S. Senate Mayor Washington, DC 20510 City Hall Tom Burack) Newburyport, MA 01950 (Attn:

Senator Gardon J. Humphrey William S. Lord 1 Eagle Square Board of Selectmen Suite 507 Town Hall Concord, NH 03301 Friend Street Amesbury, MA 01913

Mr. Thom2s PGwsrs Gary W. HolCGs, Esquire Town Manager Holmes & Ells Town of Exeter 47 Winnacunnet Road 10 Front Street Hampton, NH 03841 Exeter, NH 03833 Richard A. Hampe, Esquire

• H. Joseph Flynn Hampe & McNicholas Assistant General Counsel 35 Pleasant Street Office of General Counsel Concord, NH 03301 Federal Emergency Management Agency Mr. Robert Carrigg, Chairman 500 C Street, S.W. Board of Selectmen Washington, DC 20472 Town Office Atlantic Avenue North Hampton, NH 03862 Atomic Safety and Licensing Board Panel U.S. N.R.C.

Washington, DC 20555 George ;

Dana Bisbe4} I ,

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