ML20154D710

Commonwealth of Ma Atty General Further Responses to Interrogatories 12,18 & 20(e).* W/Certificate of Svc.Related Correspondence

ML20154D710
Person / Time
Site:	Seabrook
Issue date:	09/09/1988
From:	Jonas S MASSACHUSETTS, COMMONWEALTH OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#388-7069 OL-1, NUDOCS 8809160071
Download: ML20154D710 (8)

Text

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.i RELATED CORRESPONDENCA DOLMETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY. COMMISSION

'88 SEP 14 P3 :50 ATOMIC SAFETY AND LICENSING BOARD g rv:.. -- n. ,

Before the Administrative Judges: MEN '$. '

' 'd Sheldon J. Wolfe, Chairman Emmeth A. Lubke Dr. Jerry Harbour

)

In the Matter of ) Docket Nos.

) 50-443-OL-1 PUBLIC SERVICE COMPANY ) 50-444'-OL-1 OF NEW HAMPSHIRE, EI AL. ) (On-Site EP)

) September 9, 1988 (Seabrook Station, Units 1 and 2) )

)

MASSACHUSETTS ATTORNEY GENERAL'S FURTHER RESPONSES TO INTERRQGATORIES 12, 18 AND 2QIgl

12. Please state in detail all the facts underlying the Mass AG's assertion that "the fourteen VANS locations are physically inaccessible to the VANS equipment", define precisely what is meant by "physically inaccessible," and explain exactly how those facts support the assertion.

Response 12: On August 10, 1988, representatives of the i

Mass AG's office viewed the acoustic locations and took photographs showing the accessibility, or lack thereof, of each such location. Based on that information, the Mass AG believes that the following locations are inaccessible: VL-02; VL-03; VL-06: VL-07; VL-12; VL-13. Copies of these photos are attached hereto.

8809160071 E90909 j gDR ADOCK 0%y3 6

VL-02: This acoustic location is a parking lot which the Mass AG contends wi.ll be substantially full during many crowded beach days and therefore no room will exist for the VANS vehicle to set up.

VL-03: This acoustic location is completely unmarked, very difficult to find and the dirt road is neither wide enough to accommodate the VANS vehicle nor level and stable enough for subsequent setup.

VL-06: This acoustic location is the access road to a well-used facility. The VANS truck cannot park on the road but rather must use the side of the road. The sides are at an incline, which makes setup of the siren inpractical, and are overgrown by trees which makes the full extension of the siren impossible.

VL-07: The acoustic location is off an exit ramp on I-95. The VANS truck cannot park on the exit ramp because it would block traffic, reover, it cannot set up off the exit Amp because the ramp is curbed and because the land off the ramp falls off at a sharp incline. The VANS truck cannot function on that kind of incline.

VL-12: This acoustic location is off the side of a road where no acceptable shoulder exists and where tree overgrowth presents the full extension of the siren. The shoulder where the VANS truck would be set up is rutted, uneven, overgrown by weeds and too narrow for the tr'tck.

VL-13: This acoustic location utilizes a paved parking pad when in fact that pad is often i fully occupied with automobiles, leaving l little, if any, room for a VANS truck.  !

18. please state in detail all the facts, analyses and estimates underlying the Mass AG's assertion that "the time l needed for driver alert, dispatch, route transit, setup and activation in accordance with NRC regulations will exceed 15 ;

minutes for many of the VANS vehicles in optimum weather '

conditions," and explain exactly how those facts support the assertion. ,

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Response 18: In an earlie. response, the Mass AG estimated that performance of various functions inherent in completion of VANS siren notification (i e., dispatch, set-up, activation) would entail a total of nine (9) minutes. SRg Mass AG Response to First Set of Interrogatories, No. 20. Thus, actual transit time can be no greater than six (6) minutes in order for the VANS system to work within the prescribed fifteen (15) minute time frame.

Based on transit times supplied by the Applicants and based on transit times recorded by representatives of the Mass AG's office during a preliminary investigation, the following VANS transit routes take longer than 6 minutes: VL-01; VI -03 ;

VL-07; VL-06; VL-09; VL-10; VL-ll; VL-12; VL-13; VL-16S.

Whereas the aforementioned routes were timed both by the Applicants and the Mass AG during light to moderate traffic and at times when beaches were not frequented, the transit time involved when beaches are populated and/or during heavier traffic flow and/or during adversa weather would result in significantly longer transit times. In those cases, the aforementioned routes would be even further out of the prescribed time frame and other routes which may have previously taken less than six (6) minutes would similarily fall out of the required range.

In addition, the Mass AG has produced a recently prepared copy of the timing of VANS routes collected during the e

preliminary investigation referred to above. The information described in this response as well as previous responses to this interrogatory comprises the factual basis for the allegations referred to by the Applicants in Interrogatory 18.

20. Please state in detail how long the Mass AG contends it will require to perform . . . the following function (s), for (1) optimum weather conditions and (2) poor weather, heavy traffic, or nighttime conditions, and state in detail all the facts underlying (subsection (e)) and how those facts support the answer: (e) VANS vehicle proceeds to acoustic location; Response 20(e): Egg Response to Interrogatory 18.

The foregoing answers and all previous answers to the Applicants' interrogatories and renuests for production accurately set forth information as is available to the Mass AG.

Respectfully submitted, JAMES M. SHANNON ATTORNEY GENERAL COMMONWEALTH OF MASSACHUSETTS By: .

Step 6r.n A. Jonas Assistant Attorney General Deputy Bureau Chief Public Protection Bureau l One Ashburton Place, 19th Floor Boston, MA 02108 (617) 727-2200 DATED: September 9, 1988

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DCLKETE0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

?83 SP 14 P3 30 Ia the flatter of Ii'

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PUBLIC SERVICE COMPANY OF net! ) Docket No.(s) I HAMPSHIRE, at al. ) 50-443/444-OL-1 (Seabrook Station, Units 1 and 2) ) (On-site EP)

)

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CERTIFICATE OF SERVICE I, Stephen A. Jonas, hereby certify that on September 9, 1988, I made service of the within MASSACHUSETTS ATTORNEY GENERAL'S FURTHER 1

RESPONSES TO INTERROGATORIES 12, 18 AND 20(E), by first class mail, or l l

by Federal Express as indicated by (*), or by hand delivery as l

indicated by (**), to:

Sheldon J. Wolfe, Chairperson Dr. Emmeth A. Luebke

, Atomic Safety & Licensing Board 5500 Friendship Boulevard l U.S. Nuclear Regulatory Apartment 1923N l Commission Chevy Chase, MD 20815 East West Towers Building 4350 East West Highway Bcthesda, MD 20814 l

Dr. Jerry Harbour Sherwin E. Turk, Esq.

Atomic S6fety b Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Office of Genercl Counsel Commission 1717 H Street East West Towcrs Building Washington, DC 20555 4350 Eact West Highway .

( Third Floor Mailroom Bethesda, MD 20814 H. Joseph Flynn, Esq. Stephen E. Merrill Assistant Genet &l Counsel Attorney General Office of General Counsel George Dana Bisbee Federal Emergency Management Assistant Attorney General Agency Office of the Attorney General 500 C Street, S.W, 25 Capitol Street Washington, DC ?,0472 Concord, NH 03301

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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 washington, DC. 20555 Augusta, ME 04333 Roberta C. Pevear Ms. Diana P. Randall State Representative 70 Collins Street Town of Hampton Falls Seabrook, NH 03874 Drinkwater Road Hampton Falls, NH 03844 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 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.S. Nuclear Regulatory 5 Market Street Commission Portsmouth, Nh 03801 Washington, DC 20555 Matthew T. Brock, Esq. Mr. J. P. Nadeau Shaines & McEachern Board of Selectmen 25 Maplewood Avenue 10 Central Road P.O. Box 360 Rye, NH 03870 Portsmouth, NH 03801 Ms. Seidra Gavutis, Chairperson Mr. Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 12C Daniel Street E. Kingston, NH 03827 Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. Angelo Machiros, Chairman U.S. Senate Board of Selectmen Washington, DC 20510 25 High Road (Attn: Tom Surack) 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 Amesbury, MA 01913

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i Brentwood Board of Selectmen Gary W. Holmes, Esq.

RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet Road Hatcpton, NH 03841 Philip Ahrens, Esq. Ellyn Weiss, Esq.

Assistant Attornev General Harmon & Weiss Department of th ttorney Suite 430 General 2001 S Street, N.W.

State House Station #6 Washington, DC 20009 Augusta, ME 04333

• • Kathryn Selleck, Esq. Richard A. Hampe, Esq.

Thomas G. Dignan, Esq. Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth Ashad A. Ashod, Esq.

209 Winnacunnet Road 376 Main Street Hampton, NH 03842 Haverhill, MA 01830 William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2 10 Front Street South Hampton, NH 03827 Exeter, NH 03833 Robert Carrigg, Chairman Anne E. Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-1S Newmarket Road Atlantic Avenue Durham, NH 03824 North Hampton, NH 03862 Allen Lampert Ivan W. Smith, Chairman Civil Defense Director Atomic Safety and Licensing Town of Brentwood Board Panel 20 Franklin Street U.S. NtJ1 ear Regulatory Commission Exeter, NH 03833 Washington, DC 20555 Charles P. Graham, Esq. Judith H. Mizner, Esq.

Murphy & Graham Lagoulis, Clark, Hill-Whilton 33 Low Street & McGuire Newburyrort, MA 01950 79 State Street Newburyport, MA 019SO

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R. Scott Hill-Whilton, Esq. Barbara A. St. Andre, Esq.

Lagoulis, Clark, Hill-Whilton Kopelman & Paige, P.C.

& McGuire 77 .?'canklin Street 79 State Street Boston, MA 02110 Newburyport, MA 01950

• Sheldon J. Wolfe 1110 Wimbledon Drive McLern, VA 22101 Steph'en A 4 onas Assistant Attorney General Deputy Bureau Chief Public Protection Bureau Office of the Attorney General One Ashburton Place Boston, MA 02108 (617) 727-2200 Dated: September 9, 1988