ML20195D018

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

ML20195D018
Person / Time
Site:	Seabrook
Issue date:	06/16/1988
From:	Jonas S MASSACHUSETTS, COMMONWEALTH OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#288-6528 OL-1, NUDOCS 8806230015
Download: ML20195D018 (11)

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jg b kM.@dDM DOCKETED UNITED STATES OF AMERICA V5NRC NUCLEAR REGULATORY COMMISSION ATOMIC . SAFETY AND LICENSING BOARD - )0 40N 2 Before Administrative Judges: CFFICE r; ncmpy Sheldon J. Wolfe, Chairman 00ChEi m 6 ni.a m t Emmeth A. Luebke E'hi Jerry Harbour

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

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

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(Seabrook Station, Units 1 and'2) ) June 16, 1988

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MASSACHUSETTS ATTORNEY GENERAL'S FIRST SET OF INTERROGATORIES TO APPLICANTS REGARDING SIREN CONTENTIONS James M. Shannon, the Attorney General for the Commonwealth of Massachusett's ("Mass. A.G.") hereby propounds to the Applicants the following-interrogatories pursuant to 10 C.F.R.

S2.740b, to be answered under oath.

DEFINITIONS AND CONSTRUCTION As used herein, the words and phrases set out below shall have the meaning set forth as follows:

1. "Related to" or "relating to" shall mean directly or indirectly mentioning or describing, pertaining to, being connected with, or reflecting upon a stated subject matter.

2. "Persons" shall mean individuals, corporations, partnerships, joint ventures, associations, organizations or G806230015 880616 r PDR ADOCK 05000443 O PDR

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i 7 groups of-individuals.

3. "Identify" shall mean:

(a) As to an individual, to state his or.her; (i) full name; (ii) present business and residential address; (iii) present business, profession or occupation; and (iv) office title or position held during the-relevant time period.

(b) As to a person other than an individual, to' state its legal name, its date of incorporation, its address and the address of its principal place of business.

'(c) As to a document, to state:

(i) the date of its creation, execution and receipt by the. Applicants; (ii) its author or signatory; (iii)'its addressee and every other recipient or person having knowledge of its contents; (iv) its subject matter; and (v) its present location.

4. "Siren contention" means the Mass. Amended Contention l

and Bases admitted to this proceeding by the on-site Licensing Board by Memorandum and Order dated June 2, 1988.

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5 '. "Design Report" means the April 30, 1988 New Hampshire Yankee document entitled Seabrook Station Public Alert and Notification System, FEMA-REP-10 Design Report.

6. All uses of the conjunctive include the disjunctive and vice versa.

INSTRUCTIONS

1. Should any privilege or limitation on discovery be cla1aed with respect to the answers to any. interrogatories, set forth a summary of all facts and circumstances upon which such claim is based.

2. If any document referred to or required to be ,

identified in these answers has been destroyed and no copy exists within the Applicants' possession, custody or control, identify the document and date of its destruction, the person responsible for ordering destruction, the purpose of destruction, and (if applicable) produce any document retention policy that called for the destruction of the document.

INTERROGATORIES

.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.

2. Identify all persons you expect to call as expert witnesses at the heari.ng 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.

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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.

4. Identif) .11 documents providing backup information or raw data for Table 2-2 of the Design Report.

l S. Define "dispatch time" as the term is used at page l

l 2-18 of F.he Design Report by describing every activity required l

to dispatch the VANS vehicles.

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6. Identify all future tests of the VANS route times by providing the dates and times on which those tests will occur, I

l the places at which they will occur, the number of VANS l'

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i vehicles to be tested, and the person or persons in charge of the tests.

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.

8. State on what basis or bases a setup time test criteria of one minute was established, as described at page gg-2-22 of the Design Report.

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 overlapping coverage into Massachusetts is expected and the VANS sirens.

10. Identify all of the staging areas, preselected routes and acoustic locations for the Massachusetts portion of the Emergency planning Zone,

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 L- e

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u h. A E. Any test.results (including identifying all

. documents relating to those test results).

-12. Describe all precautions;taken against problems'with the_ operation of the VANS System due to conditions described in Interrogatory ll.

13. 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.

i 14. Describe any and all attempts made by the Applicants i

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.

15. For 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.

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.

17. State whether and, if so, where the use of the sirens in the voice message mode could lead to overlap in sound coverage.

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18. For each acoustic location, state the circumstances

i. under which the siren would be activated in its voice' message mode.

19. ,For each staging area and for every hour of the day, state how many_ drivers will be stationed at the staging area.

20. State how many persons will man each VANS vehicle during its operation.

21. State the deployment time for a backup VANS vehicle to travel from Seabrook station to each preselected location.

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

23. State the manufacturer, location of manufacturer, model type and year of manufacture of the helicopter or helicopters to be actually used for the airborne alerting system.

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.

25. Identify the helicopter ver. dor and that vendor's employee with whom the Applicants have principally dealt in the agreement to provide the helicopter and pilot services.

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24. If the airborne alerting system'is called upon to provide backup ~ alerting services, at what speed and altitude will the helicopter. fly.

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

JAMES M. SHANNON ATTORNEY GENERAL ,

l COMMONWEALTH OF MASSACHUSETTS Stephdf1 A. JoTlas Deputy Chief Public Protection Bureau One Ashburton place Boston, MA 02108 (617) 727-4878 Dated: June 16, 1988

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UNITED' STATES OF AMERICA 00LKEiE0 NUCLEAR REGULATORY COMMISSION USNPC

._ '88 JLN 20 P5 :49

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In'the Matter of ) o p ric g g ; g u. ,, m g y

) 00CXE7mG 4, SEgyly PUBLIC SERVICE COMPANY OF NEW ) Docket No.(s) 50-443M444-OL-1 HAMPSHIRE, et al.

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(Seabrook Station, Units 1 and 2) )

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CERTIFICATE OF SERVICE I, Stephen A. Jonas, hereby certify that on June 16, 1988, I made service of the within-Mass. A.G.'s First Set Of Interrogatories To

-Applicants Regarding Siren Contention by mailing a copy thereof, postage prepaid, by first class mail, or as indicated by an asterisk, by hand delivery, to:  :

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-Third Floor Mailroom Bethesda, MD 20814 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 4350 East West Highway Third Floor Mailroom Bethesda, MD 20814 H. Joseph Flynn, Esq. Stephen E. Merrill Assistant General 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 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

. 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. Eox 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 Paul McEachern, Esq. 7. P. Nadeau Matthew T. Brock, Esq. Board of Selectmen Shaines & McEachern~- 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P.O. Box 360 Portsmouth, NH 03801 Ms. Sandra Gavutis, Chairperson Mr. Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E. Kingston, NH 03827 Portsmouth, NH 03801 S'nator Gordon J. Humphrey Mr. Angelo Machiros, Chairman U.S. Senate Board of Selectmen Washington, DC 20510 25 High 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 Amesbury, MA 01913 4

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Brentwcod Board of Selectmen Gary W. Holmes, Esq.

RFD Dalton Road Holmes &-Ellis Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH 03841 Philip Ahrens, Esq. Diane Curran, Esq.

Assistant Attorney General Harmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W.

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

• Thomas G. Dignan, Esq. Richard A. Hampe, Esq.

R.K. Gad III, Esq. Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth Edward A. Thomas 209 Winnacunnet Road Federal Emergency Management Hampton, NH 03842 Agency 442 J.W. McCormack (POCH)

Boston, MA 02109 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 Mrs. Anne E. Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-15 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 l 20 Franklin Street U.S. Nuclear Regulatory Commission Exeter, NH 03833 Washington, DC 20555 Charles P. Graham, Esq. Judith H. Mizner, Esq.

McKay, Murphy & Graham Lagoulis, Clark, Hill-Whilton Old Post Office Square & McGuire 100 Main Street 79 State Street Amesbury, MA 01913 Newburyport, MA 01950 Stephen . Jonas Dated: June 16, 1988