ML20150D486

Applicant Response to Commonwealth of Ma Atty General First Set of Interrogatories to Applicant Re Siren Contentions.* Certificate of Svc Encl.Related Correspondence

ML20150D486
Person / Time
Site:	Seabrook
Issue date:	07/05/1988
From:	Selleck K, George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	MASSACHUSETTS, COMMONWEALTH OF
References
CON-#388-6680 OL-1, NUDOCS 8807140019
Download: ML20150D486 (20)

Text

go j'7O. RELAIE0 CoKRESPOEDE,(LCA 000KETED Dated: Jul'yWS$ 1988 i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,88 A -8 P3 :05 before the yncg o; o s .., ;;f 00ChEi tN:i .>. : avid.

ATOMIC SAFETY AND LICENSING BOARD BRAf:C'i

) Docket Nos. 50-443-OL-1 In the Matter of ) 50-444-OL-1

)

PUBLIC SERVICE COMPANY CF ) (On-Site Emergency-Planning OF NEW HAMPSHIRE, et al. ) and Safety Issues)

)

)

(Seabrook Station, Units 1 and 2) )

)

APPLICANTS' RESPONSE TO "MASSACHUSETTS ATTORNEY GENERAL'S FIRST SET OF INTERROGATORIES TO 22P_LICANTS REGARDING SIREN CONTENTIONS" Pursuant to 10 C.F.R. 5 2.740b, Applicants respond herein to "Massachusetts Attorney General's First Set of Interrogatories to Applicants Regarding Siren Contentions".

INTERROGATORY NO. 1 Identify all persons who prepared the answers to these interrogatories and all persons who provided information for the preparation of the answers to these interrogatories.

RESPONSE

Anthony M. Callendrello Emergency Planning Manager New Hampshire Yankee Seabrook Station

! Seabrook, New Hampshire Edward Desmarais l

Issues and Change Control Supervisor l New Hampshire Yankee c

Seabrook Station i Seabrook, New Hampshire l

8807140019 000705 gg DR ADOCKOSOOOg3

)

/~ ,

O Eric Stunnick, Ph.D Manager, Arlington Operations WYLE Laboratories 2001 Jefferson Davis Highway Suite 701 Arlington, Virginia Travic Beard Senior Emergency Planner New Hampshire Yankee Seabrook Station Seabrook, New Hampshire Gary Catapano President AllComm Keene, New Hampshire John Linville New Hampshire Yankee Seabrook Station Seabrook, New Hampshire Don Johnson Yankee Atomic Electric Company Framingham, Massachusetts Applicants object to the interrogatory insofar as it seeks residential addresses.

INTERROGATORY NO. 2 Identify all persons you expect to call as expert witnesses at the hearing on the siren contention, the subject matter on which each such person is expected to testify and the substance of each such person's testimony.

RESPONSE

Witnesses have not yet been selected.

J

(.

O Q

INTERROGATORY NO. 3 Provide the following information for each of the tests, exercises, drills or other instances on which data was collected from which the VANS Route Times in Table 2-2 of the Design Report were prepared:

A. When each instance of data collection occurred; B. Where each such instance occurred by identifying precisely the routes taken for each VANS truck from the staging area to the acoustic. location; C. The equipment used including identification of the truck, outrigger or stabilizing bars, telescoping pole and siren (all by manufacturer, model type and year);

D. The person or persons responsible for collecting the data; E. Each person who drove each of the VANS vehicles during the data collection; and F. How many VANS trucks were used.

RESPONSE

Applicants object to this interrogatory insofar as it seeks the confidential and proprietary information of the locations of VANS staging areas and acoustic locations.

Applicants do not object to providing that information to the Attorney General for the Commonwealth of Massachusetts under an appropriate protective order. Applicants' motion for

( entry of a protective order and a proposed form of protective order are submitted herewith.

I Applicants will produce data sheets from which requested information other than that provided below can be derived.

I f

(

l l

! i a

/.

For the setup time listed in Table 2-2, the equipment used was one 1981 Ford Model F850 truck, a National Crane Model Series 4 ccane, and a Whelen Dual WS 4000 siren. For the transit time listed in Table 2-2, no VANS trucks were used.

INTERROGATORY NO. 4 Identify all documents providing backup information or raw data for Table 2-2 of the Design Report.

RES PONSE See response to Interrogatory No. 3.

Data was acquired in accordance with the VANS Setup Timing Test Procedure, author T. Beard, approval date April 14, 1988 and Procedure 90510, Vehicular Alert and Notification System Route Transit Data Collection, prepared under the direction of E. Desmarais, approval date April 26, l

1988. The procedures will be produced. Applicants cannot provide a complete list of each document's "addressee and every other recipient or person having knowledge of its l

! contents."

INTERROGATORY NO. 5 Define ddispatch time" as the term is used at page 2-18 of the Design Report by describing every activity required to dispatch the VANS vehicles.

l -a-l

-___ __._____*-*___m_- _ _ . __m

[, }

b

RESPONSE

The term is defined on the succeeding page. See Design Report, page 2-19.

INTERROGATORY NO. 6 Identify all future tests of the VANS route times by providing the dates and times on which those tests will occur, the places at which they will occur, the number of VANS vehicles to be tested, and the person or persons in charge of the tests.

RESPONSE

Per Procedure 90510, VANS route drive times data will be obtained during three additional seasons; summer, fall and winter. The routes will be driven from each staging area to its associated acoustic locations. To the extent this interrogatory seeks confidential VANS staging area and acoustic locations, Applicants incorporate here their objection to Interrogatory No. 3 and their motion for a protective order submitted herewith. The dates, times, and number of vehicles tested have not been determined. Tests will be conducted under the direction of E. Desmarais.

INTERROGATORY NO. 7 Identify by manufacturer (,) weight, horsepower, model and production year each VANS truck comprising the fleet of VANS vehicles described at page 2-14 of the Design Report.

1

, . 1 e

i

RESPONSE

The VANS fleet has not been conr,tructed. Applicants currently plan to use 1988 Ford Model I-800 seven litre gasoline V8 engine trucks. The weight and horsepower of the trucks as constructed and equipped is nct currently known.

INTERROGATORY NO. 8 State on what basis or bases a setup time test criteria of one minute was established, as described at page 2-22 of the Design Report.

RESPONSE

The setup time test criteria of one minute is based on observations of the activities described on pagen 2-19 and 2-22 of the Design Report.

INTERROGATORY NO. 9 Describe any changes since the April 30, 1988 Design Report in the siren speakers or any of the other equipment on the sirens in New Hampshire for which cverlapping coverage into Massachusetts is expected and the VANS sirens.

RESPONSE

No changes in the VANS siren have been made since the April 30, 1988 Design Report submittal. Figure 2-1 identifies the New Hampshire siren system and portions of that system which provide overlapping coverage in Massachusetts. The only equipment changes that occurred in New Hampshire are the replacement of WS-2000 sirens with WS-r i i

o l j

3000 sirens in accordance with the information indicated on ]

Table 2-1 of the Design Report.

INTERROGATORY NO. 10 Identify all of the staging areas, preselected routes and acoustic locations for the Massachusetts portion of the Emergency Planning Zone.

RESPONSE

Applicants incorporate here their response to Interrogatory No. 3 and their motion for protective order submitted herewith.

INTERROGATORY NO. 11 Describe all tests of the performance of any and all aspects of the VANS System in weather conditions of extreme heat and cold, icing, high winds, snow or heavy rain by providing the following information:

A. The date and time of such tests; B. The temperature, humidity and precipitation during the period of the tests; C. The location of the tests; D. The equipment tested, and E. Any test results (including identifying all documents relating to those test results).

RES PONSE Applicants object to this interrogatory as too vague in that it gives insufficient quantitative definition of the parameters involved. Without waiving the foregoing objection Applicants state as follows: Applicants will produce the

I.

data sheets referred to in response to Interrogatory No. 3, which may or may not be responsive to this interrogatory.

A field pull test to assess response of the VANS vehicle to wind load was performed at Seabrook Station on March 24, 1988 at approximately 11 a.m. The equipment tested was a hydraulic telescoping crane, National Crane Model series 4, mounted on a 1981 Ford Model F850 truck. The temperature, humidity and precipitation were not noted. No structural or stability deficiencies were observed during and after the pull test. Notes of the test results will be produced.

INTERROGATORY NO. 12 Describe all precautions taken against problems with the operation of the VANS System due to conditions described in Interrogatory 11.

RESPONSE

Applicants incorporate here their objection to

Interrogatory No. 11. Without waiving that objection, Applicants state as follows

Methods to ensure availability of the VANS under adverse weather conditions have been described in the Applicants' April 1, 1988 response to

! question 5 of the NRC request for additional information, which has been served on tne Mass AG. Further, NHY l specifications describe the envirovorr:al parameters for the VANS components.

I l l L

1 F ..  ;

l i

INTERROGATORY NO. 13 I Identify all locations of the VANS sirens or overlapping fixed pole sirens in New Hampshire at which the sound output during operation of those sirens would exceed 123 dBC.

RESPONSE

The distance where sound levels from the VANS sirens will exceed 123 dBC is presented in the Design Report in Appendix B, WYLE Test Report 88-4.

There are no locations where siren'; from New Hampshire will produce sound levels greater than 123 dBC in Massachusetts.

INTERROGATORY NO. 14 Describe any and all attempts made by the Applicants to obtain permission under local laws and ordinances for the operation of the VANS staging areas and acoustic locations and identify all documents relating to such attempts.

RESPONSE

Applicants object to this interrogatory on the ground that the informa'eion it seeks is irrelevant to the issues before this Atomic Safety and Licensing Board. Without waiving the foregoing objection, Applicants answer that they have not made any.

4

)

I, '

INTERROGATORY NO. 15 Foi each instance of data collection and each acoustic location, described in Table 2-2 of the Design Report, state the actual (as opposed to average) deployment time, broken down into dispatch time, transit time and set up time and describe the weather and traffic conditions for each such instance of data collection.

RESPONSE

Applicants will produce the data sheets referred to in response to Interrogatory No. 3 from which the requested information can be derived.

INTERROGATORY NO. 16 State whether any gaps in sound coverage occurred in the testing of the VANS sirens, state any reasons for such gaps and identify all documents describing or referring to such gaps.

RESPONSE

Applicants do not understand what Mass AG means by the imprecise word "gap." Pages 2-3 and 2-4 of the Design Report discuss the sound coverage provided in the Massachusetts portion of the Seabrook EPZ.

INTERROGATORY NO. 17 State whether and, if so, where the use of the sirens in the voice message mode could lead to overlap in sound coverage.

10-a

n

RESPONSE

Whether and where such overlap could occur has not been determined.

INTERROGATORY NO. 18 For each acoustic location, state the circumstancec under which the siren would be activated in its voice message mode.

RESPONSE

To the extent this interrogatory seeks confidential VANS acoustic locations, Applicants incorporate here their objection to Interrogatory No. 3 and their n: on for a protective order submitted herewith. Without waiving the foregoing objection, Applicants state as follows: The use of the sirens in the voice mode ic not required by the Seabrook Plan for Massachusetts Communities (SPMC); however, the capability will exist for such possible use in the circumstance described on page 3.6-10 of the SPMC.

INTERROGATORY NO. 19 For each staging area and for every hour of the day, state how many drivers will be stationed at the staging area.

RESPONSE

To the extent this interrogatory seeks confidential VANS staging area and acoustic locations, Applicants incorporate here their objection to Interrogatory No. 3 and their motion

r; 1

for a protective order submitted herewith. Without waiving the foregoing objection, Applicants state as follows: One driver for each VANS vehicle will be stationed at each staging area. The staging areas are continuously manned.

, The number of VANS assigned to each staging area is indicated in the Design Report on page 2-14 and Applicants' response to question number 20 of NRC request for additional information.

INTERROGATORY NO. 20 State how many persons will man each VANS vehicle during its operation.

RESPONSE

One.

IRTERROGATORY NO._H State the deployment time for a backup VANS vehicle to travel from Seabrook station to e&ch preselected location.

RES PONSE Formal backup VANS transit tests from Seabrook Station have not been conducted. Based on informal observations, all acoustic locations are accessible from Seabrook Station in less than 45 minutes.

INTERROGATORY NO. 22 Identify the truck outriggers or stabilizing bars, the telescoping cranes, and the remote control system to be actually used in the VANS system by stating the name of the

! [ _

r-manufacturer, the model type, the location of the manufacturer and the year the equipment was manufactured.

RESPOMEE The VANS system and vehicle fleet has not yet been constructed. At this time New Hampshire Yankee plans to utilize:

1. Crane and Stabilizers - National Crane Model 446 with two A-type boxed slide outriggers and two underframe stabilizers. The crane is a 3 section telescoping boom. Manufactured by National Crane of Waverly, Nebraska.

The remote control system is partially in place. The equipment in place includes:

1. Whelen Encoder Model 836. Manufactured in 1986 by Whelen Engineering, Chester, Connecticut.

l l 2. Transmitter / receiver Model Mastr 2. Manufactured in 1986 by General Electric Lynchburg, Virginia,

3. Transmitter / receiver Model Delta. Manufactured in 1986 by General Electric Lynchburg, Virginia.

The rest of the remote control system will be supplied in the future as part of the siren package supplied by Whelen Engineering.

INTERROGATORY NO. 23 State the manufacturer, location cf manufacturer, model r ,

D type and year of manufacture of the helicopter or helicopters to be actually used for the airborne alerting system. l

RESPONSE

Applicants object to this interrogatory on the ground that the information sought is not relevant to the issues before this Board. Without waiving the foregoing objection, however, Applicants state as follows: The helicopter (s) available for the backup airborne alerting system will be supplied from a fleet of helicopters. The fleet consists of Bell Jet Ranger Model 206 B3 helicopters manufactured from 1979 to 1983 by Bell Helicopter, Textron Inc. of Fort Worth, Texas.

INTERROGATORY NO. 24 Describe all weather conditions under which either the New Hampshire Yankee Off-Site Response Organization, the helicopter vendor, or the pilot would not permit operation of the helicopter.

RESPONSE

Applicants object to this interrogatory on the ground that the information it seeks is irrelevant to the issue.s before this Board. Without waiving the foregoing objection, however, Applicants respond as follows: Weather conditions of icing, freezing rain, gale level winds or low cloud ceiling and visibility (400 feet, 1/2 mile) could preclude s

flight. For all weather conditions the pilot complies with applicable FAA flight rules.

INTERROGATORY NO. 25 Identify the helicopter vendor and that vendor's employee with whom the Applicants have principally dealt in the agreement to provide the helicopter and pilot services.

RESPONSE

Applicants object to this interrogatory on the ground that the information it seeks is irrelevant to the issues before this Board. Without waiving the foregoing objection, however, Applicants respond as follows: See SPMC, Appendix C, page C-62, redacted, confidential information, for the identity of the vendor (who has been contacted by representatives of Mass AG), and the employee who signed the agreement.

INTERROGATORY NO. 26 If the airborne alerting system is called upon to provide backup alerting services, at what speed and altitude will the helicopter fly.

RESPONSE

Applicants object to this interrogatory on the ground that the information it seeks is irrelevant to the issues before this Board. Without waiving the foregoing objection, however, Applicants respond as follows: The helicopter will E...

v i

O fly at 40 miles per hour (ground speed) and 500 feet above ground level.

INTERROGATORY NO. 27 4

At that speed and altitude, what area, in terms of square mileage, will the helicopter cover in 15 minutes.

RESPONSE

Applicants object to this interrogatory on the ground that the information it seeks is irrelevant to the issues 4

before this Board. Without waiving the foregoing objection, however, Applicants respond as follows: 21.2 square miles.

l t

I t

l

i Jd. 05 '50 16:07 ter E<ECUTILE 071 PC2

• l_t er 'EE :s t :.: 50sti s. G=:.y  : ;5 katirst.nh As to Answers:

T George S. Thomas Vice President, Nuclear Production New Hampshire Yankee Division of Public service company of New Hampshire July L',, 1988 State of New Hampshire Rockingham county, ss.

Then appeared before me the above subscribed George S.

Thomas and made oath that he is the Vice President, Nuclear Production of New Hampshire Yankee Division, autherised to execute the foregoing responses to interrogatories on behalf of the Applicants, that he made inquiry and believes that the foregoing answers accurately set forth information as is ' ' '

available to the Applicants.

4:::

.v .

i s. : 3 * , ,' !

Before me, -

\,;'..h :' . .

3%( { Qh ['d.73'ff '

My Commiseien Expires Q C%%Q As to objections:

c Thodas G. Dignin, Jr.

Kathryn A. Selleck Jeffrey P. Trout Ropes 4 Gray 228 Franklin Street Boston, MA 02110 (617) 423-6100 cpunmal for Annlicants

=17-

gs' I ki CCLKEIR D

7 CERTIFICATE OF SERVICE I, Kathryn A. Selleck, Applicants herein, hereby certify that on July 5,one of the attorneys 1988 for t9,$ Ji -8 P3 :05 made service of the within document by mailing copies thereof, postage prepaid to: a nict .r . . G ra '

00CKEllA 4 ' M E Administrative Judge Sheldon J. Stephen E. Merrill, Esqd59AC" Wolfe, Esquire, Chairman Attorney General Atomic Safety and Licensing George Dana Bisbee, Esquire Board Panel Assistant Attorney General U.S. Nuclear Regulatory Office of the Attorney General Commission 25 Capitol Street Washington, DC 20555 Concord, NH 03301-6397 Judge Emmeth A. Luebke Dr. Jerry Harbour Atomic Safety and Licensing Atomic Safety and Lict7 sing Board Panel Board Panel 5500 Friendship Boulevard U.S. Nuclear Regulatory

. Apartment 1923N Commission Chevy Chase, Maryland 20815 Washington, DC 20555 Robert Carrigg, Chairman Diane Curran, Esquire Board of Selectmen Andrea C. Ferster, Esquire Town Office Harmon & Weiss Atlantic Avenue Suite 430 North Hampton, NH 03862 2001 S Street, N.W.

Washington, DC 20009 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of the Executive Legal Board Panel Docket (2 copies) Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 30555 Washington, DC 20555 Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 l

l l

)

i 4

• Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney 25 Maplewood Avenue General P.O. Box 360 One Ashburton Place, 19th Flr.

Portsmouth NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Kensington, NH 03827 126 Daniel Street Portsmouth, NH 03801 Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Clark, Hill-Washington, DC 20510 Whilton & McGuire (Attn: Tom Burack) 79 State Street Newburyport, MA 01950 Senator Gordon J. Humphrey Mr. Peter S. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 i Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen office of General Counsel RFD Dalton Road '

Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McN1cholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region I 79 State Street, 2nd Floor 442 John W. McCormack Post Newburyport, MA 01950 Office and Court House Post Office Square Boston, MA 02109 i

1 ]

e

.)-

Charles P. Graham, Esquire Murphy and Graham 33 Low Street Newburyport, MA 01950 y'iffyn a

A. Selleck I