ML20154L403

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Affidavit of J Story.* Discusses Allegations in Contention Bases A.3 Re Vehicular Alert & Notification Sys Vehicles. Prof Qualifications Encl
ML20154L403
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 09/17/1988
From: Story J
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Shared Package
ML20154K393 List:
References
OL-1, NUDOCS 8809260178
Download: ML20154L403 (7)
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September 17, 1988

(

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

)

i In the Matter of )

)

PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 60-444-OL

) (On-Site Emergency (Seabrook Station, Units 1 and 2) ) Planning and Safety

) Issues)

)

AFFIDAVIT OF JOSEPH STORY, II t 7, Joseph Story, II, being on oath, depose and say as follows:

1. I am a working Foreman in the Health Physics Department of New Hampshire Yankee. I participated in the selection process of the pre-selected accustic locations and participated in the transit time testing program for the spring and summer of 1988. I am personally familiar with the various roadways and traffic conditions within the Mascachusetts portion of the EPZ. In addition, I have past experienes as a truck driver and heavy equipment operator. A copy of my professional qualifications is attached hereto and marked "A".

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2. The purpose of this affidavit is to address allegations in Contention Basis A.3 that a VANS vehicle will be unable to drive intc/onto and/or set up et the preselected acoustic locations.
3. I was one of two individuals responsible for evaluating areas selected as pctential= acoustic locations to determine if a given site could be acceosed by a VANS vehicle. The criteria used to evaluate the acceptability of a given site included such considerations as sufficient room to allow the vehicles to park, adequate overhead clearance to allow boom erection and sufficient and level space for the vehicle to put out its outriggers.

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4. In August, 1988, I participated in a review of each of the acoustic locations identified in the PEMA-REP-10 2 Design Report regarding physical accessibili.ty of these sites for a VAliS vehicles. This review entailed driving a
truck with a truck-mounted telescoping crane and A-frame type outriggers to e6ch of the acoustic locations identified in the FEHA-REP-10 Design Report associated with the Alert and Notification System for the Massachusetts plune exposure EPZ.
5. At each location the truck was physically driven onto the acoustic location and outriggere deployed or traffic cones laid out in a pattern equivalent to the area required to park the truck and deploy the outriggers. Tha latter was o ;-

done where it was possible to leave tiro. marks or outrigger impre6stons on the grass or asphalt surfaces.

6. I concluded that the t.teks could be parksd cnd tne outriggers deployed at nach acoustic location. In tddition, I re-verified that there were ne overhead obstructions which would pretent the deplcyment of the siren.
7. I am familiar vita the construction of a truck and the VANS vehicle design concept. These vehicles arc commercial vehicles intended to be operated under varying weather and road surface conditicas. These vehicles, when using snow and mud tires (see Affidavit of Sebastian N. caruso at 1 13), will travel under adverce weather and road cGnditions such as snow and ice. In addition, these vehicles can drive into and setelp ct acoustic locations which are not an hard road surfaces of i concrett or blacktop.
8. Each of the six acoustic locations which the Masoachusetts Attorney General alleged will be inaccessible 1 to the VANS are, in fact, accessible to the VANS vehicles.

Each of these locations are discussed in the following paragraphs.

9. VL-02: At no time during the runs made to this location during the spring and summer of 1988 was the parking lot close to full. An area of the parking lot le not marked 1 See "Massachusetts Attorney General's Further Response to Interrogatorics 12, 13 and 20(c)" filed September 8, 1988, at 1-2.

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'l for automobile parking and is av.vitable to and is larJe

- enough to accommodate VANS vehicle setup.

10. VL-03: All VANS drivers will be trained to identify this, as well as all the other acoustic locations Mass AG is unable to locate. During the tast described in f 4 above, the truck was driven to VL-03 and the cutriggers deployed. In addition, on September 16, 1988, I observed the VANS prototype vehicle set-up at this location with l outriggers deployed and the boom fully raised. Width, incline, and stability of t!'e location did not affect VANS vehicle cat-up with *he boom tully raised.
11. VL-06: The VANS setup location is on the access road to . The incline is negligible and well within the outrigger capabil!';ies. The truck, when set up, doca not prevent egress of vehicles from . On September 16, 1980, I observed the VANS prototype vehicle set-up with ov. triggers deployed and the boom fully raised without any interference caused by trees.

i 12. VL-07: As far as can be determined from the photocopied pictures submitted by Mass AG; Mass AG representatives appear to have been in a location other than VL-07 when they thought they had located and photographed VL-

07. On September 16, 1988, I observed the VANS prototype ,

vehicle drive ovet the curbing and set-up with the outriggers deployed and the boom fully raised. The vehicle was stable on the slight incline.

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13. VL-12: During the test described in 14 above, the truck was set up at VL-12 with tne outriggers deployed.

Tnwre were no overherd obstructions prohibiting full boom extension. In addition, on September 16, 1988, I observed the VANS prototype vehicle set-up on the road shoulder

, location with the outriggers deployed and tha boom fully raised. There was no interference caused by trees.

Outrigger deployment resulted in over 17 feet of paved toad surface remaining available for passage of traffic.

14. VL-13: As the VAllS vehicle is designid for set up t on dirt, use of the paved pad at thio location is unnecessary. At no time during any of the runs conducted during the spring and summer of 1988 was there insufficient room at this location to deploy a VANS truck. In additicn, 1

on September 16, 1988, I observed the VANS protot'nu2 ve'itcle set-up at this location with the outriggers deployed and the

' boom fully raised.

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1 u u, b6 Jo ph' Stor?, M STATE OF NEW HAMPSHIRE Rockingham ss. September M, 1988 The above-subscribed Joseph Story, II, appeared before me and made op.ch that he had read the foregoing af t'idavit and that the suav.ements set forth therein are true to the best of hf3 knowledga.

Before me, sado b 3Odev,au Notary P@ lic J My Commir31on Expires: 3+ 30 is

' l

, 1 Story Attachment A, 1 of 1 i

JOSEPH STORY, II Health Physics Working Foreman Summarv of Exneriengs Mr Story joined PSNH in June of 1982 as a Health Physics Technician. Subsequently, he was promoted to a Health Physics Working Foreman. During this time his responsibilities have included the development of plans and procedures necessary to support an operational as well as a preoperational Health Physics program. He has worked on the Onsite Emergency Plan. His current position in the Emergency Response Organization is Radiological Controlm f.oordinator.

Before coming to Public Service Company of New Hampshire, Mr. Story worked as a contractor providing expertise in water processing, decontamination and health physics support. He held positions in 11 different operating nuclear power plants during this time.

Bafore working in the nuclear industry, Mr. Story worked in thre construction industry. Positions held during this time included operating heavy equipment and driving trucks similar in size and construction to the VANS trucks.

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