ML20197G824

Answers to State of Nh First Set of Interrogatories & Request for Production of Documents on State of Nh Radiological Emergency Response Plans.Related Correspondence

ML20197G824
Person / Time
Site:	Seabrook
Issue date:	05/14/1986
From:	Doughty J SEACOAST ANTI-POLLUTION LEAGUE
To:
Shared Package
ML20197G818	List: ML20197G814 ML20197G824 ML20197G832 ML20197G840
References
OL, NUDOCS 8605160425
Download: ML20197G824 (10)

Text

__ _ _ _ _ _ - _ _ _ _ _ _ _ _ - - _ _ .

, f, g coKR Filed: May 14, 1986 s , ,, m

, /

)

S UNITED STATES OF AMERICA J' .d 4S@

3 .. y y

NUCLEAR REGULATORY COMMISSION i l' GM b

\ fo i; before the ,

?

[/

ATO',1IC SAFETY AND LICENSING BOARD '

'ui at In the Matter of PUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL NEW HAMPSHIRE, et al 50-444 OL (Seabrook Station, Units 1 and 2) (Off-Site EP)

SEACOAST ANTI-POLLUTION LEAGUE'S ANSWERS TO THE STATE OF NEW HAMPSHIRE'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE SEACOAST ANTI-POLLUTION LEAGUE ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN The Seacoast Anti-Pollution League hereby responds to the State of New Hampshire's First Set of Interrogatories and Request for Production of Documents to the Seacoast Anti-Pollution League on the New Hampshire Radiological Emergency Response Plan.

l GENERAL INTERROGATORIES 1

G-1 SAPL is definitely intending to introduce evidence on  !

SAPL's Contention No. 7. SAPL hopes to bring evidence, )

in addition, on SAPL Contentions 5, 8, 16, 17 and 25, 1 though no specific witnesses are yet confirmed. SAPL is l waiving SAPL Content ion No.14. SAPL will waive Contention j No. 18 if SAPL's Contentions No. 27 and 28 are admitted. l G-2 The only confirmed witness thus f ar is for SAPL Contention No. 7. l l

• EW 8988g,

Identification is as follows:

Dr. Donald L. Herzberg Rt. 1, RFD 173 Norwich, VT 05055 Dr. Herzberg is employed as Chief of Nuclear Medicine at Dartmouth-Hitchcock Medical Center, where he practices diagnostic radiology and nuclear medicine.

Dr. Herzberg's education is as follows:

Washington University St. Louis, Missouri Medical School 1964-68 MD University of Texas Medical Branch Galveston, Texas Radiology Residency 1969-72 Dr. Herzberg's full-time professional employment, since 1969, in addition to his residency, has been as follows:

U.S. Air Force - 1972-74 University of Arkansas for Medical Services-1974-80 Dartmouth-Hitchcock Medical Center-1980 to present Dr. Herzberg is a member of the following organizations:

Society of Nuclear Medicine American College of Nuclear Physicians Radiologie Society of North America American College of Radiology American Institute of Ultrasound in Medicine Dr. Herzberg possesses 5 licenses, including a N.H.

license.

G-3 Dr. Herzberg will testify both as to the problems involved in decontaminating individuals and as to the numbers of contaminated persons who can realistically be dealt with within a given time frame.

SAPL does not yet know which, if any, documents will be relied upon in Dr. Herzberg's testimony beyond the N.H.

RERP.

i l

INTERROGATORIES RELATED TO SPECIFIC CONTENTIONS r

Contention SAPL 5 J

l SAPL 5.1 i

! The significance of ground Ievel radiation monitoring is i that it provides a data base upon which to base a confirmation of estimates of radiological releases made on the basis of on-s i te measurements. The EPA " Manual of Protect ive Action Guides and Protective Actions for Nuclear Incidents" states:

. Detection and measurement at locations off-site are necessary to update and/or confirm predictions about the i movement of the release in the environment. (emphasis added)

SAPL 5.2 l ,

! The confirmatory data radiological monitoring provides is 4 necessary to ensure that the proj ections f rom on-site are indeed' reliable. Protective action recommendations not based upon reliable data may not serve to protect the public. The_ basis

. of this response is the above-mentioned EPA " Manual of Protective l

~

Action Guides" and NUREG-0654. NRC regulations and the accompanying guidance in NUREG-0654 contemplate timely monitoring. NUREG-0654 at II.I.8. . states that "Each organization, where appropriate, shall provide methods, equipment and exertise to make rapid assessments of the actual or potential magnitude and locations of radiological hazards ,

through liquid or gaseous release pathways." (emphasis added) i Field monitoring is important because the state might 3 inadvertently order the evacuation of the wrong sections of the EPZ and neglect to evacuate the appropriate sections (See the

" Regions" specified in KLD Progress No. 2 at'54). The State j indeed might only have ordered that_ people should shelter. in i

place when the actual doses should have prompted an evacuation ,

j order. Further, monitor ing might reveal.that an evacuation t order should be made for communities beyond the 10-mile EPZ.

In the discussion of_the rationale for a 10-mile EPZ, NUREG-0654 states

" detailed planning within 10 miles would provide a substantial base for expansion of . response ef forts -in the  :

event that this proved necessary." Monitoring could be necessary to determine if an expanded evacuation were necessary under _ the circumstances of the accident.

SAPL 5.3 SAPL objects to this question in that it seeks to place-SAPL in the posture of developing the plan for the state.

E- _ _ - _ . _ . - _ _ _ . _ _ _ ~ _ . _ , . _ _ _ _ . _ - _ _ _ _ _ . . _ - , _ _ _

However, wi thout waiving this obj ect ion, SAPL asser ts that there should be sufficient monitoring teams to ensure the " rapid assessment" required at NUREG-0654 II.I.8. and to ensure continuous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day operations as NUREG-0654 II.A.4.

provides. Radiolgoical monitoring personnel should have sufficient back-up so they can be withdrawn f rom duty when they have been exposed to the permissible dose limits.

CONTENTION SAPL 7 SAPL 7.1 SAPL objects to this question on the same grounds that it objected to the question at SAPL 5.3 above. Without waiving this objection, SAPL asserts that there ought to be specific information regarding the deployment of specified expert individuals, in sufficient numbers, to each specific decontamination center. The capacity, staffing, showeis, and equipment for each decontamination center must be greatly augmented to meet realistic proj ec t ed demands that could be placed on each center under the spectrum of accident conditions that are, under the regulations, to serve as the basis of planning.

In SAPL's opinion, there must be provisions for isolating contaminated was te water f rom showers. Further, there must be trained medical personnel on hand who can ascertain whether or not radiation readings result from external or internal contaminants and who can supervise the administration of KI.

Medical personnel would be able to initiate referrals of internally contaminated, excessively exposed and/or wounded individuals to medical facilities.

There must also be large numbers of vehicle washing facilities, sufficient again to meet realist ic proj ections of demand. Again, too, there mus t be provisions for isolat ing the contaminated water resulting from vehicle decontamination.

A large capacity shielded area must be provided for storage capacity for contaminated belongings and trained personnel to handle those contaminated materials must be assigned in adequate numbers.

T SAPL 7.2 SAPL objects to this question for the same reason that it objected to the question at SAPL 5.3 above. However, without waiving objection, SAPL's response is as follows:

SAPL realizes that what SAPL believes is necessary to treat emergency workers' contaminated wounds goes beyond what is requieed by the NRC's response to the Guard remand. However, SAPL hopes that the State will, of its own initiative, require

a more careful review of the capability to treat contaminated emergency workers' wounds in order to ensure the protection of these people. SAPL believes that a specific medical facility should be dedicated to the treatment of emergency workers contaminat ed wounds. The f acility should have suf ficient expert medical personnel, equipment, showers and was te s torage capaci ty to meet a conservat ive (i.e. , high) demand that might be placed on the facility based on the number of emergency workers to be deployed. SAPL believes that construction of a new facility f or this purpose would not be unreasonable, since the f acilit ies named in the State plan could very likely be overburdened.

SAPL 7.3 SAPL again objects to this question on the same basis that it objected to the question at SAPL 5.3. Without waiving this objection, SAPL responds that it certainly does not believe that a statement of the utility's commitment, unsupported by any detail, to dispose of all the material constitutes an adequate means of ensuring that the health and safety of the public will be protected. SAPL believes that the State of New Hampshire and the NRC have the duty to determine prfor to licensing specifically where the wastes will end up. The Seabrook site is not a suitable location for the ultimate storage of these wastes. An above-ground storage facility built for the purpose of isolating radioactive wastesand with the facilities for appropriately packaging the wastes would, in SAPL's opinion, be the minimum required. It goes without saying that the f acility should be operated by an entity licensed and inspected by the NRC.

Transport of wastes should only be allowed by appropriately licensed and inspected carr iers and some sor t of manif es t sys t em ought to be developed to ensure that no wastes are misappropriated or misplaced in transit.

CONTENTION SAPL 8 SAPL 8.1 SAPL would obj ect to explaining where modi fications should be made in the NHRERP for the same grounds as set forth in response to Interrogatory SAPL 5.3. Without waiving that objection, SAPL informs the State that the areas that SAPL is contending are inadequately staffed by the State are radiological monitoring functions (both field monitoring and evacuee moni toring), t raf fic control f unct ions and any f unct ions wherein State personnel would stand in the place of local communi ty personnel . The bases are set out in sections of SAPL Content ion Nos. 5, 8, and 8A. Addi t ionally, the KLD s tudy relys on 81 local and interstate guides for traffic control posts i l

1 in N.H. communi t ies and an addi t ional 27 at Access Cont rol Pos ts in N.H. Therefore, 108 t raf fic control personnel are required.

Troop A of the N.H. State Police has only 37 officers assigned at present.

SAPL 8.2 SAPL would object again to this question for the same reasons supporting SAPL's objection to Interrogatory 5.3.

Wi thout waiving obj ect ion, SAPL's response is: see the response to SAPL 8.6 below.

SAPL 8.3 The October 29, 1985 let ter to the Governor of New Hampshire noted in SAPL : Contention No. 8 from the Town of Hampton selectmen stated that the department heads in the Town had notified the selectmen of manpower deficiencies. Mr. George Hardardt, Public Works Director, noted at a meeting to discuss the plans called by the selectmen that he did not have enough town personnel to carryout his responsibilities under the plan.

Fire Chief Newman G. Goodwin, Jr. of North Hampton wrote a letter to the editor of local papers on January 8, 1986 that expressed his concern about lack of manpower, as well as other concerns.

Walter Shivik, a selectman in South Hampton, has also expressed his concerns about lack of manpower. Representative Roberta Pevear, Civil Director of Hampton Falls has on numerous occasions expressed her concerns in various public forums and in the press about the lack of sufficient manpower in Hampton Falls to carry out the plans.

SAPL 8.4 '

It is SAPL's understanding that the town has planned to rely upon mutual aid when local police are not available. Under the conditions of a radiological emergency, surrounding towns i

would need their own equipment and manpower to attempt to meet their own responsibilities.

SAPL 8.5 (a) SAPL does not know.

(b) See above. I (c) SAPL would presume due to a deficiency of volunteers or paid personnel.

SAPL 8.6 SAPL again obj ects to this Interrogatory on the.same basis on which it obj ected to Interrogatory SAPL 5.3. Without waiving objection, the response is as follows:

SAPL does not have the specific numbers to answer this question. SAPL has relied upon the judgment of local officials that aver that they do not have sufficient manpower to carryout their plans. SAPL would also hold that all of the basic positions (e.g., Civil Defense Director, RADEF Officer) should be filled at a minimum.

SAPL believes that local officials who are fully informed of the nature of radiological emergencies are in the best position to ascertain the needs of their communitles and the State should pay careful heed to local officials statements about manpower deficiencies.

CONTENTION SAPL 14 As mentioned above, SAPL is waiving Contention No. 14.

CONTENTION SAPL 16 SAPL 16.1 No.

SAPL 16.2 SAPL bases this conclusion on common sense. If a release that was projected to be of short duration was imminent, there

?

would be insuf ficient time to ef f ect an evacuation and the only strategy that would be available on short notice to achieve dose reductions in the population near the reactor would be sheltering. NUREG-0396, " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants" states that shorter release ini t iat ion t imes are typically associated with the more severe Reactor Safety Study accident sequences and with design basis events of much smaller consequences. (p.

18)

SAPL 16.3 SAPL should perhaps more precisely have said that the level of protection for special facilities was not adequately evaluated in the NHRERP. Figure 5 in Appendix F to Civil Def ense Procedures in the NHRERP only provides Dose Reduction Factors for the special facilities excluding schools. SAPL would not agree with these factors, for example the .1 DRF for the Home for Aged Women in Portsmouth, which would allow an outside proj ected whole body dose of 50 rems before an evacuat ion would be ordered.

Further, until receiving the State's May 6, 1986 reply to SAPL's interrogatories, SAPL did not know that a DRF of .9 had been selected for homes, schools and other units. The original NHRERP served on all parties did not contain this specific information and the original Volume 4 did not even contain an Appendix U. SAPL did not receive Appendix U until April 28, 1986 and does not find Figure 1A in Appendix U. SAPL will need additional time to evaluate this new information.

SAPL 16.4 The inadequacies of the Kensington Elementary School as a shelter are described in the basis to SAPL's Contention No. 16.

An adequate shelter would be a shelter with a low air infiltrat ion rate and a sufficient dose reduction factor. Ideally, the shelter would have an air filtration system.

CONTENTION SAPL 17 SAPL 17.1 The basis of SAPL's statement regarding the number of phone lines was an examination of the diagrams at Figure 7 in each l of them 17 N.H. local community RERP's and conversations with certain town of ficials. The basis of SAPL's contention regarding 1 the potential overload of the commercial phone sys tem was a I conversation with Mr. Paul Labonte of New England Telephone Company.

l SAPL 17.2 I SAPL objects to this question on the same basis on which, an object ion was made to Interroga tory SAPL 5.3. Wi thout waiving objection, SAPL responds that this answer must be reasonably determined on a town by town basis, taking into consideration such factors as the numbers of special facilities and numbers of people with special transportation needs. The number of lines installed should be suf ficient to assure that all emergency communications can be carried out promptly, as NUREG-0654

Planning Standard F states ought be done. Emergency response organization phones should have priority status.

SAPL 17.3 In SAPL's opinion, there must be some procedure and/or equipment to provide back-up capability for communication at each juncture in the scheme of communications where the commercial phone system is relied upon as the primary means of communication. Further, there needs to be some system, procedure and/or equipment that would allow citizens of each municipality to reques t ass istance when needed. See again NUREG-0654 Planning S t andar d F and al s o NUREG-0 65 4 II .J.10. g. The lat ter speci fies trat there mus t be means of relocat ion. The public mus t have a w .y of secur ing those means f rom emergency responders if needed.

CONTENTION SAPL 18.1 SAPL intends to waive Contention 18 i f SAPL's Cont ent ions No. 27 and 28 are admitted.

Further. SAPL objects to this question on the same basis that SAPL objected to Interrogatory 5.3. Without waiving its objection, the answer is that SAPL has not yet made these determinations.

CDNTENTION SAPL 25 SAPL 25.1 SAPL has not surveyed the EPZ to identify residents with special transportation needs. SAPL has heard of certain individuals who will need special transportation help, but has not kept a lis t of such individuals. Please see also the basis for SAPL's Contention No. 25.

SAPL 25.2 Again, SAPL objects to this Interrogatory on the same basis on which it obj ected to Interrogatory SAPL 5.3 above. Without waiving this objection, SAPL asserts that well informed local officials have the best knowledge of the needs of their towns and the state should pay careful heed to the statements of local of ficials about manpower deficiencies. SAPL would ref er to the contentions of Hampton, Rye, Kensington, So. Hampton and Hampton Falls, and also to a let ter by the Board of Selectmen of Hampton to Governor John Sununu dated October 29, 1985.

s SAPL 25.3 The NilRERP should provide for the special transportation needs of individuals in such a manner as to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency as per 10 CFR 650.47(a)(1). The guidance at NUREG-0654 II.J.10.g. requires that there be means of relocation. The NHRERP should pro'. ride a workable means of relocation for those with special transportation needs.

Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE Dated: 5l24 % By: Ou [mTld-h 8 s Jade Doughty OG STATE OF NEW HAMPSHIRE COUNTY OF h 1 Then personally appeared the above-named Jane Doughty and acknowledged that the foregoing statements by her subscribed are true and correct to the best of her knowledge and belief. Before me.

(++c L Notary Public Jr ! ! cc c f t h e "eac<

sheson Duchanne, Notary Pubes My Conwnission Empires h 12. t988 l

l I

i l

. - .