ML20151N517
| ML20151N517 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/01/1988 |
| From: | Jonas S MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#388-6863 OL-1, NUDOCS 8808090025 | |
| Download: ML20151N517 (17) | |
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000 KEli.D SELATED COfiRF.SPottDtliu USHPC i UNITED STATES OF AMERICA y g NUCLEAR REGULATORY COMMISSIM g ,,,4 ,
ATOMIC SAFETY AND LICENSING BOARD.t; E 'A % <
DOCKEI M ^ iN Before Administrative Judges: W h" Sheldon J. Wolfe, Chairman Emmeth A. Luebke Dr. Jerry Harbour
) f In-the Matter of )
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PUBLIC SERVICE COMPANY OF ) Docket No.(s) !
NEW HAMPSHIRE, ET AL. ) 50-443/444-OL-1 (Seabrook Station, Units 1 and 2) ) On-site EP l
) August 1, 1988 L
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i MASSACHUSETTS ATTORNEY GENERAL'S ADDITIONAL RESPONSES I TO APPLICANTS' FIRST SET OF INTERROGATORIES AND RESPONSES TO APPLICANTS' SECOND SET OF INTERROGATORIES INTRODUCTLQR I On July 27, 1988, attorneys from the office of the Massachusetts Attorney General ("Mass AG") and attorneys for the Applicants met, at the request of the Atomic Safety and Licensing Board, to discuss additional information sought by the Applicants in their motion to compel.1# The first set of 1/ Applicants' Motion To Compel Answers To Interrogatories Propounded To The Attorney General For The Commonwealth Of Massachusetts, July 20, 1988.
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responses which follow result from that meeting.2#
The second set are responses to Applicants' second set of interrogatories.
The following responses are not intended as a waiver of any objection previously raised in the Mass AG's Response to First Set of Interrogatories, dated July 12, 1988. Moreover, additional responses co the Applicants' first set of ;
interrogatories are not substitutes for the initial responses p but rather supply additional information. i i I. ADDIT 10NALRESPONSES TO APPLICANTS' FIRST SET OF 1RIERROGATORIES Guideline 6: please include, with the answer to each of the interrogatories that follow, the name, institutional I affiliation and professional qualifications, if any, of the person who is answering.
ADDITIONAL REEEQESE: The Mass AG has produced to the '
Applicants curricula vitae for Gregory C. Tocci and l
Thomas G. Bouliane, acoustic consultants hired by the Mass AG
'l for the purpose of assisting in reviewing the NHY alternative notification proposals. Messrs. Tocci and Bouliane substantially assisted the Mass AG in answering Interrogatory I Responses 25, 26, 28, 35, 40 and Second Set of Interrogatories, 4 Response 1.
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2/ On July 18, 1988, the Applicants filed a "Supplemental Interrogatory." Under 10 C.F.R. S 2/740(e), the Mass AG is
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i under no duty to supplement its earlier responses. Additional responses pursuant to the parties' discussions are provided ;
herein.
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- 3. With respect to the Mass. AG's answers to each of the interrogatories 6 - 46 that follow, is that answer based upon conversations, consultations, correspondence or any other type of communication with one or more individuals or entities? If so, please:
(a) Identify each such individual or entity.
(b) State the educational and professional background of each such individual, including occupation and institutional affiliates.
(c) Describe the nature of each communication with each such individual or entity, when it occurred, and identify all other individuals or entities involved.
(d) Describe in detail the information received from each such individual or entity, and explain how it provides a basis for the answer.
(e) Identify and produce each letter, memorandum, contract, tape, note or other document related to each conversation, correspondence, or other communication with such individual or entity.
ADDITIONAL RESPONSE _2: The Mass AG communicated with the following representatives of vendort associated with the Applicant's notification system: Matt Suoboda, National Crane; Messrs. Oldston, phelps, Whelen Engineering; Don Bullard, Stedt Hydraulics; Dave McCarthy, Rodman Ford; Michael peavey, Wiggins Airways and the president of Wiggins Airways.
- 13. Please state in detail all the facts underlying the Mass AG's assertion that "the (VANS) vehicles cannot withstand and will not operate properly with the weights, amount and nature of equipment intended to be carried by the vehicles,"
and explain exactly how those facts support the assertion.
ADDITIONAL RESEONSE_11: The Mass AG's contention and initial response reflects all the knowledge and/or information that the Mats AG has at this time pertaining to this specific issue.
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- 14. Please state in detail all the facts underlying the Mass AG's assertion that "the weight distribution with the siren fully extended will cause the equipment to fall and/or the lifting mechanism to bend or break under heavy wind or precipitation conditions," define precisely what is meant by "heavy wind" and "heavy . . . precipitation", and explain exactly how those facts support the assertion.
ADDITIONAL RESPONSE 14: Included among documents submitted by Whelen to the Applicants pertaining to wind testing were the results of a test, using a Whelen 3000 siren, conducted in a wind tunnel for Florida Power & Light. In wind forces of 60 -
147 mph, that report showed that drive mechanisms failed at approximately 10 to 13 degrees rotation angle for the five siren rotating tests which were conducted. Moreover, the Applicants conducted a field pull test of the crane on March 24, 1988 which showed substantial crane deflection in heavy wind. A final qualification of the actual equipment to be used in the VANS system is still being conducted.
The terms "heavy wind" and "heavy . . . precipitation" do not lend themselves to precise definition.
With the inclusion of the aforementioned information, the Mass AG's contention and the responses to Interrogatory 14 reflect all the knowledge and/or information that the Mass AG has at this time pertaining to this specific issue.
- 15. Please state in detail all the facts underlying the Mass AG's assertion that "the telescopic crane will not reliably lift the siren to its fully extended position because of the weight of the siren and the capacity of the crane",
define exactly what is meant by "reliably", and explain exactly how those facts support the assertion.
ADDITl0NALRESEONSE_11: See Additional Response 13.
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- 16. please state in detail every fact, not discussed in a previous answer, underlying the Mass AG's assertion that "the VANS vehicles are inadequate for their intended use", and explain exactly how these facts support the assertion.
ADDITIONAL RESPONSE 16: See Additional Responses 13, 14.
- 20. please state in detail how long the Mass AG contends it will require to perform each of the following functions, for (1) optimum weather conditions and (2) poor weather, heavy traffic, or nighttime conditions, and state in detail all the facts underlying each answer and how those facts support the answer:
(a) notification of VANS driver; (b) VANS driver proceeds to vehicle; (c) VANS driver checks out vehicle and equipment; (d) VANS driver starts vehicle and leaves staging area; (e) VANS vehicle proceeds to acoustic location; (f) setup and activation of siren at acoustic location.
ADDITIONAL RESpONEE 20: The calculations as set forth in the Mass AG's Response to Applicant's First Set of Interrogatories are based on optimum weather conditions during the day or night.
- 40. please state in detail all the facts underlying the Mass AG's assertion that "any attempted informational messages for the airborne siren will be garbled and unintelligible because of the strength and size of the speaker array and amplifier system, the height of the aircraft and the effect of the helicopter's rotary blades," define exactly what is meant by "garbled and unintelligible", and explain exactly how those facts support the assertion.
ADDITIONAL RESEORSE_1Q: "Garbled" means to be so distorted as to be unintelligible. Unintelligible means unable to be understood or lacking the capacity to be understood. The informational messages of the airborne siren will be garbled and unintelligible becase the rotary action of the helicopter blades will cause air to flow past the speakers in a pulse.
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- 46. Please identify all studies, analyses or other work which Mass AG currently intends to perform or have performed in connection with any matter raised by his Amended Contention un Notification System or Dases thereunder.
ADDITIONAL _REfiEQHSE 46: The Mass AG states that this office intends to cenduct a study of the VANS route travel times and a study of tone or message coverage where the VANS siren sound output is 123 dB(C) or less.
RESEONSES_lR_ APE IfANTS_SECOND_ SET _0E_lHIERRQGATORIES
- 1. Please define exactly what is meant by "acceptable levels" of sound outpute in Mass Aq Response No. 8, citing specific decibel levels, and state in detail all the facts underlying that definition.
RESEONEE_1: 123 dB(C) or less, see Appendix 3 (at 3-8) of NUREG-0654, FEMA-REP-1, Rev. 1.
- 2. Please state whether the Mass AG, or any e.'tity or individual contracted to or cooperating with the Masc AG, has performed or intends to perform any calculation (s) to a:sess the existence or size of "uncovered areas" as that term is used in Mass AG Response No. 8. If so, please state:
(a) who performed the calculation (s), giving the name, institutional affiliation, business address, and professional qualifications, if any, of all individuals involv9d; (b) the method or manner in which the calculation (s) was performed, including but not limited to any scientific texts or practices relied upon in setting up the calculation (s);
(c) all data used in the calculation (s);
(d) all results generated by the calculation (s),
indicating which set of data produced which result.
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RESPONSE-2: No such calculations have been performed. The Mass AG intends to have a study conducted by Cavanaugh Tocci concerning tone or message coverage where the VANS sound output ,
is 123 dB(C) or less. The method has not been determined. ;
- 3. Please state in detail what the Mass AG contends are the appropriate technical design specifications for a mobile '
siren alert system such as Applicant's VANS system, for each of the following variables:
(a) weight of equipment carried; (b) amount of equipment carried; (c) nature of equipment carried; (d) weight distribution of fully extended siren; (e) stress capacity of lifting mechanism;
- (f) weight of siren; j (g) lift capacity and reliability of telescopic crane.
l RESPONSE 3: The Mass AG has no technical design i specifications but asserts that a mobile siren alert system must work reliably. As such, the weight of the various a
components and the stress and lift capacity of the telescopic crane and lifting mechanism must ensure proper and timely functioning under all circumstances, including adverse weather conditions.
> 4. Please define exactly what is meant by "time required l to pack the vehicle" in Mass AG Response No. 18(c), and state in detail all the facts underlying that definition.
j RESPONSE 4:
Mass AG's Response 18(c) should read, in pertinent part, !
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"time required te park the vehicle."
- 5. please define exactly what is meant by "extreme weather conditions" in Mass AG Response No. 22, and state how
- frequently such conditions occur in the Massachusetts portion !
of the EpZ for Seabrook Station. !
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,e *J RESPONSE 5: "(E]xtreme weather conditions," in this context, means heavy snow, freezing rain or ice. At this time, the Mass AG has not determined the frequency of such weather
- conditions in the Massachusetts area of the EPZ.
- 6. Please state in detail all the facts underlying the Mass AG's assertion that such "extreme weather conditions", as referred to in Mass AG Response No. 22, will cause "snow and ico (to) gather . . . in the sections of the crane through which its extension takes place and in the mechanism designed to rotate and oscillate the siren," indicating how much snow and ice allegedly would gather under each level of "extreme weather", and how much snow and ice would need to gather before the extension of the crane would be materially impeded.
RESPONSE _6: See Response 5.
- 7. Please state exactly where in the Design Report the Mass AG asserts that a requirement exists for use of the message mode along public beaches in Massachusetts.
RESPONSE 7: The Mass AG has not stated that a requirement exists in the Design Report for use of the message mode along Massachusetts public beaches. Rather, the Design Report (at p.
2-6) contemplates the use of a public address message system !
along public beach areas.
- 8. Please define, by percentage, exactly what is meant by "a substantial failure rate" in Mass AG Response No. 32, and state in detail all the facts underlying that definition. c
. RESEDNSE 8: In the context used in the Mass AG's earlier !
response, "substantial" does not lend itself to a precise percentage definition. Simply stated, in order for the VANS l
system to work within fifteen minutes, more than one driver per vehicle will have to be positioned at each particular staging
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i area. Otherwise, routine matters and/or unusual circumstances which cause the drivers not to be in the Staging Area offices or able to respond in a timely manner would impede timely performance.
- 9. Please state how frequently each of the "debilitating" weather conditions described in Mass AG Response No. 37 occurs in the Massachusetts portion of EPZ for Seabrook Station, and state in detail all the facts underlying that answer.
RESPONSE 9: The Mass AG has not determined at this time the frequency of these conditions.
- 10. Please define exactly what is meant by "virtually impractical", "will rarely fly", "make flight impractical" and "severe visibility problems" in Mass AG Response No. 37 and state in detail all facts underlying those definitions.
RESPONSE 10: There is a typographical error in the Mass AG's Response number 37. The word "impractical" should read "impracticable". That word, as corrected and in this context, means that notification via helicopter flight cannot be carried out where winds are in excess of 40-50 mph. "(W]ill rarely fly" means that flights during thunderstorms are infrequent occurrences. "Severe visibility problems" means that the distance which can be seen under the weather conditions specified is considerably less than the distance which can be seen absent such adverse conditions. Colonel Cox, State Army Aviation Officer for the Army National Guard, has stated to the Mass AG that, as a general rule, an aircraft such as the Jet Ranger, travelling at 40 mph, requires minimum visibility of one mile.
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- 11. Please state in detail all the facts underlying the Mass AG's assertion that "(a) pilot will never fly in freezing rain because of the ice build-up that occurs on control ,
surfaces", including but not limited to all facts concerning ;
the amount of ice build-up that occurs under each amount and duration of freezing rain.
RESEDRSI_ll: The assertion is self-explanatory. ,
Michael peavey, a pilot with Wiggins Airways, the Applicants'
- helicopter vendor, has stated in conversation with the Mass AG's office that a pilot will never fly in freezing rain or l heavy snow. Similarly, Colonel Thomas Cox has stated t'at h snow impedes visibility and that icing conditions are considered i
extremely unsafe.
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- 12. please identify all documents upon which the Muss AG ;
, has relied, does rely or intends to rely to support his
- position on the Amended Contention on Notification System.
Identify the information in each document on which the Mass AG i
has relied, does rely or intends to rely and the specific basis i and sub-basis of the contention which the information concerns.
i BESEQNSE_11: The Mass AG objects to this intertogatory l under 10 C.F.R. S 2.740(b)(2). Without waiving this objection, j the Mass AG has not determined on which documents he intends to i
! rely to support his position. Moreover, the identification requested has been supplied in conjunction with the Mass AG's !
responses to the Applicants' document requests and the l
- discussion of the parties to this action regarding tho Applicant's Motion to Compel and the Additional Responses of l
the Mass AG.
- 13. If you have not already done so in accordance with :
Instruction No. 4, please state, for each of the foregoing interrogatories, the name, institutional affiliation, and ,
! professional qualifications, if any, of the person (s) anawering.
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.o .e4 RESEQHSE_11: These are answers of the Massachusetts Attorney Genera.1.
The foregoing answers and the initial answers to the !
Applicants' first set of interrogatorios accurately set forth f information as is available to the Mass AG. ,
The Maas AG moves for a protective order from this Board i
that the discovery requested by the Applicants, to which the Mass AG objects, not be had. !
Respectfully submitted, JAMES M. SHANNON I ATTORNEY GENERAI, i
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Ste hen A6'3cnas !
Pamela Talbot Assistant Attorneys General Public Protection Division One Ashburton Place, Room 1902 Boston, Massachucetts 02108 '
(617) 727-2200 Dated: August 1, 1988 r
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GREGORY C. TOCCI Education: Tufts University, BS, 1970 Massachusetts Institute of Techn: logy, MS, 1973 Professional Member, Acoustical Society of America Affiliations: President, National Council of Acoustical Consultants Member, Institute of Noise Control Engineering Past Chairman, Greater Boston Chapter of the Acoustical Society of America Member, American Society for Testing and Materials Registration: Professional Engineer in Massachusetts Experience: As President of Cavanaugh Tocci Associates, Inc.,
Mr. Tocci is responsible for both its technical and business activities. Among the types of projects managed by Mr. Tocci are speech privacy and intelligibility studies and other building acoustics studies; mechanical system noise and vibration control; environmental impact assessment studies for residential and cbmmercial developments, and for transportation systems; worker noise exposure surveys and engineering noise abaMment programs; the design and implementation of construction noise control programs, and many types of special noise and vibration studies for building and manufacturing industries.
Mr. Tocci is active in several professional organizations, is an Invited Lecturer at the Harvard School of Public Health, and is author of the Monsanto Acoustical Glazina Desion Guide and papers published in various magazines and proc 6odings. Mr. Tocci has also lectured in several environmental and industrial seminar programs.
Recent projects for which Mr. Tocci has consulted include:
- Acoustical Glazing Product Cevelopment Studies Guardian Industries, Fullerton, CA
- Design Review & Recommendations Codex Corporation World Headquarters, Canton, MA
- Envirencontal Noise Assessment & Recommendations American Ref-Fuels Resource Recovery Facility oyster Bay, LI, NY
- Environmental Noise & Vibration Studies MBTA Track Improvement Program, Boston, MA
- Laser Laboratory Noise and Vibration Studies O Frick Chemical Laboratories Prinenton University, Princeton, NJ
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TEOMAS G. 500LIANE Education: University of Buffalo, Buffalo, New York Professional Acoustical Society of America, Member '
Affiliations: Audio Engineering Society, Member Construction Specifications Institute, Member National Council of Acoustical Consultants, Member National Sound Contractors Assoc. , Consultant Member Experience: Mr. Bouliane has been active in the implementation of sound systems for architecture since 1974. He has provided engineering and design services for several types of facilities including govern-mental, educational and musical performance auditoria, sports arenas, corporate offices and meeting rooms, hotel restaurants, ballrooms, and circulation areas, induutrial workfloors and ware-houses, worship spaces, transportation concourses, entertainment lounges.
Mr. Bouliana meets with clients to survey sound system needs, generates reports to advise clients, develops system designs and cost estimates, pre-pares bidding specifications and drawings, reviews bid responses, value-engineers proposals for cost savings, inspects and certifies completed system installations, and otherwise assists clients in the evaluation and execution of sound system solu-tions to acoustical problems.
Mr. Bouliane has presented papers bofore the Audio Engineering Society and has been published in Sound and communications.
Recent projects for which Mr. Bouliane has provided services include:
- Master Bidding Specification, -
Marriott Corporation, Washington, DC
- Speech Reinforcement System, Mosque of the Holy Prophet, Medina, SA
- Speech and Music Reinforcement System, First Assembly of God, Rockford, IL
- Sound Masking System, Federal Building, Boston, MA
- Public Address System.
South Station (Amtrak), Boston, MA
- Conference Room Sound System, l Hale & Dorr, Boston, MA L E "I
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, gEt.AT ED CORRESPON9M60 UNITED STATES OF AMERICA Nturr?
NUCLEAR REGULATORY COMMISSION U)MC 1 1
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In the Matter of ) oFrat cf -o. 9 a - .
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PUBLIC SERVICE COMPANY OF NEW ) Docket No.(s) %DIT43/444-OL-1
- HAMPSHIRE, e.t al. ) ;
(Seabrook Station, Units 1 and 2) ) ;
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CERTIFICATE OF SERVICE i
I, Stephen A. Jonas, hereby certify that on August 1, 1988, I made service of the within Massachusetts Attorney General's Additional t Responses to Applicants' First Set of Interrogatories and Responses to Applicants' Second Set of Interrogatories, by mailing copies thereof, i
postage prepaid, by first class mail, or by hand delivery as indicated by (*) to: !
I Sheldon J. Wolfe, Chairperson Dr. Emmeth A. Luebke ,
Atomic Safety & Licensing Board 5500 Friendship Boulevard '
U.S. Nuclear Regulatory Apartment 1923N Commission Chevy Chase, MD 20815 East West Towers Building 4350 East West Highway i Bethesda, MD 20814 i
, Dr. Jerry Harbour Sherwin E. Turk, Esq.
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Office of General Counsel Commission 1717 H Street East West Towers Building Washington, DC 20555 i 4350 East West Highway i Third Floor Mailroom Bethosda, MD 20814 l H. Joseph Flynn, Esq. Stephen E. Merrill Assistant General Counsel Attorney General Office of Generai Counsel George Dana Bisbee Federal Emergency Management Assistant Attorney General Agency Office of the Attorney General j 500 C Street, S.W. 25 Capitol Street j Washington, DC 20472 Concord, NH 03301 I
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Docketing and Service Paul A. Fritzsche, Esq.
U.S. Nuclear Regulatory Office of the Public Advocate Commission State House Station 112 Wa3hington, DC. 20555 Augusta, ME 04333 i'
Robetca C. Pevear Ms. Diana P. Randall' l State Representative 70 Collins Street Town of Hampton Falls Seabrook, NH 03874
'Drinkwater Road
- Hampton Falls, NH 03844 1
J Atomic Safety & Licensing Robert A. Backus, Esq.
Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 i
Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Jane Doughty
, Board Panel Scacoast Anti-Pollution League i
U.S. Nuclear Regulatory 5 Market Street Commission Portsmouth, NH 03801 Washington, DC 20555 Matthew T. Brock, Esq. Mr. J. P. Nadeau Shaines & McF3chern Board of Selectmen
, 25 Maplewood Avenue 10 Central Road 4
P.O. Box 360 Rye, NH 03870 Portsmouth, NH 03801 Ms. Sandra Gavutis, Chairperson Mr. Calvin A. Canney
- Board of Selectmen City Manager
- RFD 1, Jox 1154 City Hall Rte. 107 126 Daniel Street
) E. Kingston, NH 03827 Portsmouth, NH 03801 s
] Senator Gordon J. Humphrey Mr. Angelo Machiros, Chairman
! U.S. Senate Board of Selectmen Washington, DC 20510 25 I?igh Road (Attn: Tom Burack) Newbury, MA 10950 Senator Gordon J. Humphrey Edward Molin 1 Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Donald E. Chick Mr. William Lord Town Manager Board of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amrtbury, MA 010'3
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Brentwood Board of Selectmen Gary W. Holmes, Esq.
RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH 03841 Philip Ahrens, Esq. Ellyn Weiss, Esq.
Assistant Attorney fieneral Harmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W.
State House Stacion #6 Washington, DC 20009 Augusta, ME 04333
- Kathryn Selleck, Esq. Richard A. Hampe, Eeq.
Thomas G. Dignan, Esq. Hampe & McNicholas 1 Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth Ashad A. Ashod, Esq.
i 209 Winnacunnet Road 376 Main Street Hampton, NH 03842 Haverhill, MA 01830 William Armsttong Michael Eantosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2
- 10 Front Street South Hampton, NH 03827
- Exeter, NH 03833 h Robert Carrigg, Chairman Mrs. Anne E. Goodman, Chairperson j Board of Selectmen Board of Selectmen Town Office 13-15 Newmarket Road Atlantic Avenue Durham, NH 03824 North Hampton, NH 03862 Allen Lampet* Ivan W. Smith, Chairman Civil Defense Director Atomic Safety and Licensing Town of Brentwcod Board Panel 20 Franklin Stree? U.S. Nuclear Regulatory Commission Exeter, NH 03833 Washington, DC 20555 Chcries P. Graham, Esq. Judith H. Mizner, Esq.
McKay, Murphy & Graham Lagoulis, Clark, Hill-whilton Old post Offico Square & McGuire 100 Main Street 79 State Street Amesbury, MA 01913 Newburyport, MA 01950
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R.. Scott Hill-Whilton, Esq. Barbara A. St. Andre, Esq.
Lagoulis, Clark, Hill-Whilton Kopelman & Paige, P.C.
& McGuire 77 Franklin Street 79 State Street Boston, MA 02110 Newburyport, MA 01950 ;
Charles P. Graham, Esq. i McKay, Murphy & Graham Old Post Office Square !
100 Main Street ,
Amesbury, MA 01913 !
Stephen A. Jonar Deputy Chief i Public Protection Bureau Office of the Attorney General One Ashburton Place Boston, MA 02108 .
(617) 727-2200 l Dated: August 1, 1988 f
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