ML20197J985
| ML20197J985 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/14/1986 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | NEW HAMPSHIRE, STATE OF |
| Shared Package | |
| ML20197J958 | List: |
| References | |
| OL, NUDOCS 8605200226 | |
| Download: ML20197J985 (21) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAR
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In the Matter of
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Public Service Company of
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New Hampshire, et al.
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Docket Nos. 50-443 OL
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50-444 OL (Seabrook Station, Units 1& 2)
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0FFSITE EMERGENCY
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PLANNING
_____________________________________)
NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S RESPONSE TO THE STATE OF NEW HAMPSHIRE'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS AND MOTION FOR A PROTECTIVE ORDER Introduction The New England Coalition on Nuclear Pollution ("NECNP")
submits the following answers to the State of New Hampshire's interrogatories and request for the production of documents.
We note that in some cases, because NECNP is still in the process of developing its case, or because information from the State is incomplete, NECNP is unable to fully answer the interrogatories.
In those cases, we will supplement our answers as soon as the relevant information is available, as required by 10 C.F.R. 2.740(e).
Pursuant to 10 C.F.R. 2.740(c), NECNP also moves for a protective order that discovery not be had on the interrogatories to which NECNP objects below.
The reasons for NECNP's chjections are stated in the response to the interrogatories.
GENERAL INTERROGATORIES 8605200226 860514
{DR ADOCK 05000443 PDR
G.1 Please identify those contentions admitted by the Board's Order of April 1, 1986 on which you intend to introduce evidence in this proceeding.
ANSWER: NECNP has not yet determined the contentions on which it will introduce evidence in this proceeding.
When we do, we will promptly supplement our answers to these interrogatories.
G.2 For each contention identified in Interrogatory G.1, please identify all persons whom you intend to call as witnesses.
Please include a summary of the educational and professional background of each identified witness.
ANSWER:
See answer to G.I.
G.3 Provide a reasonable description of the substance of the testimony of each witness on each of the contentions identified in the answer to Interrogatory G.1.
Please also identify all documents which will be relied on in that testimony.
ANSWER:
See Answer to G.I.
INTERROGATORIES RELATED TO SPECIFIC CONTENTIONS CONTENTION NECNP RERP-2 RERP-2.1 Please identify all areas in the NHRERP where the State requires federal assistance.
In your response please specify all of the "particular functions that the State cannot carry out, and the equipment and number of qualifications of federal personnel needed to carry them out."
ANSWER:
NECNP is unable to identify all areas in the NHRERP where the State requires federal assistance because it is impossible to discern from the RERP what is the total extent and nature of the State's needs for federal assistance.
The RERP lists " anticipated" needs for federal assistance in the areas of Coast Guard support, FAA support, and shellfish contamination screening.
$ 1.4.5.
The RERP also vaguely states that the State
will seek technical support that includes " technical advice and radiological monitoring" ( g1.4.2), and contains a table listing numerous agencies that will provide that technical support (Figure 1.4-1); but it does not describe the nature or extent of the technical support.
The RERP also indicates that the State will use " nontechnical" Federal support ( 51.4.2) and lists the agencies responsible for nontechnical support (Figure 1.4-1); but the nature of the expected need for nontechnical support is not described.
NECNP does not know what constitute all of the particular functions that the State cannot carry out, and the equipment and number and qualifications of federal personnel needed to carry them out.
Given the lack of information in the current plan, it would be impossible for NECNP to perform such an evaluation.
In any event, NECNP considers that it is the responsibility of the State to identify and evaluate the extent and nature of its needs for federal assistance.
RERP-2.2 What specific provisions must a letter of agreement for federal assistance contain?
Please identify all documents supporting this response.
ANSWER:
A letter of agreement or contract between the State and a federal agency should contain:
1.
An agreement regarding the type of equipment and number of pieces of equipment that will be provided to the State by the federal agency during a radiological emergency at Seabrook; 2.
An agreement regarding the skills, qualifications and number of personnel that will be provided to the State by the federal agency during a radiological emergency at Seabrook;
3.
Designation of the means by which equipment and personnel will be transported to the Seabrook emergency planning zone; 4.
A provision stating the time in which the federal agency expects to be able to deliver the personnel or equipment to the Seabrook EPZ.
CONTENTION NECNP RERP-3 RERP-3.1 Has NECNP estimated the number of French-speaking Canadians present on the New Hampshire beaches on any given day?
If so, in NECNP's estimation, what is the peak population of French-speaking Canadians during a hot summer weekend?
What is the mean peak population of French-speaking Canadians during a hot summer weekend?
Please explain the basis for these estimates, and identify all documents in support of the estimate.
ANSWER:
No.
CONTENTION NECNP RERP-10 RERP-10.1 Please indicate the number of monitoring teams which, in the opinion of the NECNP, would be adequate to carry out ground level radiation monitoring in the EPZ, specifying the number of such teams needed for each of the monitoring activities identified in Section (a) of the basis to this contention.
Please explain the basis of this response and identify all supporting documents.
ANSWER:
NECNP does not know the exact number of monitoring teams which would be adequate to carry out ground level radiation monitoring in the EPZ.
However, we believe that the three two person teams provided by the RERP are not adequate to provide a rapid assessment of the scope of the plume that could be used in early decisions regarding protective actions.
HERP at Table 2.5.-4.
Moreover, the State intends to use field monitoring data to project the dose to the Ingestion Pathway Zone.
The grid map provided in the RERP at 2.5-9 shows an area of approximately 350 square miles, which could not possibly be monitored thoroughly by such a small number of personnel.
This response is based on Section 2.5 of the New Hampshire HERP and NUREG-0654,
$ II.I.7-9 and 11.
HERP-10.2 What, in the opinion of the NECNP, is an appropriate time in which monitoring teams should be deployed to support protective action decision-making?
Please explain the basis for this response, and identify all supporting documents.
ANSWER:
Monitoring teams should be deployed early enough so that the state can make " rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways."
NUREG-0654, {
II.I.8.
RERP-10.3 What is the basis for NECNP's assertion that there is no assurance that DPHS laboratories will be available on a twenty-four hour basis?
ANSWER:
This interrogatory relates to NECNP contention RERP-10(e), which NECNP withdrew at the March 25 and 26, 1986, prehearing conference.
NECNP no longer asserts that the DPHS laboratories will not be available on a 24-hour basis.
RERP-10.4 Please indicate which ground level radiation monitoring locations would, in the opinion of NECNP, be appropriate for the Seabrook EPZ.
Please also describe how such locations should be selected.
ANSWER:
NECNP objects to this interrogatory to the extent that it attempts to require NECNP to perform the State's function of identifying monitoring locations for the Seabrook EPZ.
We note that the HERP states that monitoring teams will be directed to to " pre-selected monitoring points" but does not state what those points are.
HERP at 2.5-7.
NECNP has neither the resources nor the obligation to identify suitable monitoring locations in the Seabrook EPZ.
The criteria that should be applied in choosing monitoring locations are found in NUREG-0654, 65 II.I.8 and 11.1.11.
The locations should be chosen so that the state can make a " rapid" assessment of the actual or potential radiological hazards through liquid or gaseous release pathways.
The state should also be able to locate and track the airborne radioactive plume.
CONTENTION NECNP RERP-12 RERP-12.1 How should radioprotective drugs be administered to institutionalized persons?
In your response please indicate, without limitation, the quantity of such drugs that should be kept on hand, how it should be stored, and how it should be distributed.
ANSWER:
The State should distribute to each institution in the Seabrook EPZ sufficient quantities of radioprotective drugs to protect each person in the institution for at least a week.
The drugs should be stored at the institutions, in the care of the lead administrators, and under such conditions as are necessary to preserve their effectiveness, with directions that the drugs should not be administered unless ordered by the State during a radiological emergency.
CONTENTION NECNP NHLP-2(a)
NHLP 2(a).1 Please explain how the police forces in each of the New Hampshire towns in the Seabrook EPZ are insufficiently staffed to carry out the followiag functions:
(a)
Public alert and notification; (b)
Traffic control: and (c)
Security at emergency facilities and evacuated areas.
ANSWER:
Brentwood:
The town of Brentwood has 10 part-time police officers and one police cruiser.
Brentwood RERP at C-1.
The police department is responsible for providing traffic control and security, as well as a backup means of public alerting.
Po' ice officers must monitor key intersections in town and report congestion to the EOC.
RERP at IV-36.
They must review evacuation routes along with available personnel and resources.
RERP at IV-35.
During and after an evacuation, they must maintain patrols to provide security.
Id.
If necessary, they must also control access to the contaminated-equipment impoundment area designated by the Road Agent.
Id.
The plan gives no indication as to how ten people with only one car can perform all of these functions.
East Kingston:
The town of East Kingston has four police officers and one police cruiser.
During an emergency, the police department would have more responsibilities than could be fulfilled by four people with one car.
The police department must receive and transmit notification of an emergency; staff the EOC; maintain security at the EOC; support the Fire Chief in public alerting; dispatch patrols to notify people outdoors if sheltering is recommended; maintain security patrols during an evacuation; control access to the contaminated equipment impoundment' area; and control traffic at the intersection of Route 107 and Route 108.
- g-Exeter:
The town of Exeter has 22 officers and seven vehicles.
The police department's responsibilities include ensuring the completion of emergency notification; staffing the EOC; maintaining security at the EOC: activating the public alert systen; ensuring that people requiring special notification are contacted; feeding emergency workers; dispatching patrols to warn people outside'to take shelter and to ensure that all windows, doors, and ventilation systems in the EOC are secured; staffing up to six traffic control points; and if necessary, controlling access to the contaminated equipment impoundment area.
The town has neither sufficient personnel nor transportation to fulfill all of these functions.
Greenland:
The police department in Greenland has three officers and two cruisers.
The police department's duties include receiving and transmitting notification of an emergency; staffing the town EOC and providing security for the EOC; staffing two traffic control points; maintaining security before and after an evacuation; and, if necessary, controlling access to the contaminated-equipment impoundment area designate by the Highway Agent.
HERP at IV IV-42.
The plan thus requires more than three people to be in different places at the same time.
Hampton:
See basis for Contention NHLP-2(a).
Hampton Falls:
The town of Hampton Falls has one full-time officer and three part-time officers, and is equipped with one police cruiser.
HERP at IV-35.
According to the plan for Hampton Falls, the Police Chief is responsible for providing traffic control, security and a backup means of public alerting.
He must also complete any notifications that have not yet been performed and provide security for the Emergency Operations Center.
In an emergency, the Chief must report to the EOC.
He must also assign another police officer for EOC security.
RERP at IV-35.
That leaves two officers who are required to support the Fire Chief in public alerting, as needed; monitor key intersections; and maintain patrols to provide security during and after an evacuation.
The police officer on duty also has responsibility for notification of emergency personnel during an emergency.
There are neither enough officers or vehicles to support all of these functions.
Kensington:
The town of Kensington has six pa r t -- t ime police officers and one police cruiser.
The police department's duties inclode staffing the EOC: maintaining security at the EOC:
supporting the Fire Chief in public alerting; monitoring traffic intersections to deal with possible congestion; and maintaining security patrols during and after evacuation.
On its face, this list of responsibilities cannot be fulfilled with Kensington's limited staff and single vehicle.
Kingston:
The town of Kingston has ten police officers and one cruiser.
The police department is responsible, inter alia, for receipt and transmittal of notification of emergencies; staffing the EOC; maintaining EOC security; ensuring people requiring special notification are contacted; notifying institutions and non-auto-owning individuals; supporting the Fire Chief in public
}
alerting; ensuring that vehicles are provided to evacuate families without automobiles and families with special transportation needs; monitoring key roadway intersections for congestion; directing dispatch of buses; maintaining security patrols; and if necessary, controlling access to the contaminated equipment impoundment area.
On its face, the plan requires more than ten individuals with one vehicle to carry out all of these responsibilities.
Newton:
The town of Newton has ten police officers and two cruisers, which are given essentially the same responsibilities as for the police department in the town of Kensington.
Although NECNP has not evaluated the adequacy of personnel for these tasks, it is clear that the various tasks of patrolling the town, monitoring intersections, and assisting with notification, cannot be fulfilled with only two vehicles.
Newfields:
The town of Newfields has five police officers and two cruisers, which are given essentially the same responsibilities as for the police department in the town of Kensington.
As with the town of Kensington, the emergency plan lists more tasks than can be completed by the number of personnel in the police department.
Two vehicles are also inadequate for patrolling the town, assisting with public alerting, and monitoring traffic intersections.
North Hampton:
North Hampton has eleven police officers and three cruisers to perform essentially the same functions as for j
the town of Kensington, except that the North Hampton police must i
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staff three traffic control points during an evacuation.
At this time, NECNP has not evaluated the adequacy of personnel to perform these functions.
However, it is clear that the provision of three vehicles is inadequate to assure that the police department can staff traffic control points, patrol the town, and assist in ro4te notification.
Portsmouth:
NECNP has not yet evaluated the adequacy of the Hye police department's staffing to perform the responsibilities assigned to it by the Hye RERP.
We will supplement our answers to this interrogatory when we have done so.
Hve:
Rye has between 25 and 28 police officers and two cruisers.
NECNP has not yet evaluated the adequacy of the Hye police department's staffing to perform the responsibilities assigned to it by the Rye HEHP.
However, it is clear that the Rye police cannot monitor four separate traffic intersections, patrol the town, or support the Fire Chief in public alerting with only two vehicles.
Stratham:
The town of Strathan has four police officers and one cruiser to staff the EOC; maintain security at the EOC; support the Fire Chief in public alerting; staff one traffic control point; maintain security patrols during and after an evacuation; and control access to the contaminated equipment impoundment area.
These responsibilities clearly require more than four people and one car.
South Hampton:
South Hampton has three police officers and one cruiser to carry out a list of res.sonsibilities similar to those for the Kensington police department.
There are clearly more full-time tasks than people to fill them, and not enough vehicles to provide transportation for traffic control, security patrols, and public alerting.
NHLP 2(a).2 In the estimation of NECNP, how many police officers are necessary for each Town in the EPZ to carry out the following functions:
(a)
Public alert and modification (b)
Traffic control; and (c)
Security at emergency facilities and evacuated areas.
ANSWER:
NECNP objects to this interrogatory on the ground that it-seeks to compel NECNP to calculate the number of police officers that would provide adequate protection to the public health and safety during a radiological emergency.
NECNP has provided a basis for its contention that the police departments in the Seabrook NECNP are insufficiently staffed to perform their assigned functions, and that therefore there is no reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
It is the State's responsibility to demonstrate that adequate staffing exists.
NHLP 2(a).3 Please identify all documents relating to the staffing requirements for police officers for all New Hampshire towns in the Seabrook EPZ.
ANSWER:
NECNP is unaware of any documents other than the radiological response plans for the New Hampshire local governments.
CONTENTION NECNP NHLP 2(d)
r.
NHLP 2(d).1 Please provide the name and addresses of the two towing companies that said they were never informed that they were listed in the plan, and the name of the person who furnished this information.
ANSWER:
NECNP spoke to Dave Lavoie of Dave's Garage, 321 Ocean Boulevard, Hampton, New Hampshire; and to Dan Ploth of Lymon's Auto, 700 Lafayette Street, Hampton, New Hampshire.
NHLP 2(d).2 Please provide the name avd' address of the company, and the name and address of the owner of the towing company referred to in the basis to Contention NHLP 2(d) who stated that none of his employees would stay to assist in a radiological emergency.
ANSWER:
Dave Lavoie.
See answer to NHLP2(d).1.
NHLP 2(d).3 Please provide the name and address of the company listed as having towing equipment which told NECNP that it contracts its towing from another company, and does not have its own vehicles.
t.U:W E R :
NECNP spoke with an individual at the Hampton 66 towing company in Hampton, New Hampshire.
We did not 1 carn the man's name in the conversation.
However, we called Hampton 66 again this week, and the statement was confirmed by Peter Moulton, an employee.
CONTENTION NECNP NHLP 2(g)
NHLP 2(g).1 Please explain how the fire department personnel in each of the New Hampshire towns in the Seabrook EPZ are insufficiently staffed to carry out the following functions:
(a)
Monitoring evacuation; (b)
Decontamination of effected persons; (c)
Operating and maintaining the EOC or the Public Alert System; and (d)
Assessing emergency transportation needs.
ANSWEH:
At this time, NECNP has developed this contention only to the extent described in the basis for Contention NHLP 2(g).
We will supplement our answer to this interrogatory as we develop our position on the issues raised in this contention.
NHLP 2(g).2 In the estimation of NECNP, how many fire department personnel are required for each town to carry out the following functions:
(a)
Monitoring evacuation; (b)
Decontamination of effected persons; (c)
Operating and maintaining the EOC or the Public Alert System; and (d)
Assessing emergency transportation needs.
ANSWER:
NECNP objects to this interrogatory on the ground that it seeks to compel NECNP to calculate the number of fire department personnel that would provide adequate protection to the public health and safety during a radiological emergency.
NECNP has provided a basis for its contention that the fire departments in the Seabrook NECNP are insufficiently staffed to perform their assigned functions, and that therefore there is no reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
It is the State's responsibility to demonstrate that adequate staffing exists.
NHLP 2(g).3 Please identify by name and address the Hampton Fire Department employees who stated to NECNP that they will not perform their official duties in the event of a radiological emergency at Seabrook Station.
Please also provide the names and addresses of any other permanent fire department employees of the New Hampshire towns in the Seabrook EPZ who have indicated they "may refuse to report to their jobs during an emergency" at Seabrook Station.
Please indicate the reasons given by such employees for not carrying out their assigned responsibilities in the event of a radiological emergency at Seabrook Station.
ANSWER:
No individual fire department employee has informed NECNP that he or she will not perform his or her official duties in the event of a radiological emergency at Seabrook Station.
In a telephone conversation in 1983, Chief Kuncho of the Hampton Fire Department informed Diane Curran that some of his employees told him that they would be reluctant to return to the Seabrook EPZ during a radiological emergency.
CONTENTION NECNP NHLP 2(h)
NHLP 2(h).1 Please explain why, in addition to the specific examples given in the basis of this contention, local emergency workers may not be " reachable" in the event of a radiological emergency at Seabrook.
Is this issue of notification of local emergency volunteers any different for a radiological emergency than for non-radiological emergencies that require notification of local emergency response personnel?
If so, please explain why.
If not, please explain why notification of 1.ocal emergency workers is sufficient for non-radiologir.al emergencies, but insufficient for radiological emergencies.
ANSWER:
At this time, NECNP has not identified examples of officials wh6 nay be unreachable during an emergency. other than those that are listed in the basis of Contention NHLP-2(h).
We will update our answers to these interrogatories as we discover new examples.
NECNP does not believe that the ability to notify of emergency responne personnel of a radiological emergency is any different than the ability to notify them of a nonradiological emergency.
The factors that make these individuals difficult to reach are not affected by the radiological or nonradiological character of the emergency that they are called upon to respend I
(
I
to.
NHLP 2(h).2_
Please describe fully the methods used and results obtained in the 1983 survey conducted by NECNP of emergency response workers.
Please also identify all documents relating to that survey.
ANSWER:
In the summer of 1983 Diane Curran, attorney for NECNP, interviewed selectmen from South Hampton (Ann Verge) and Kensington (Sandra Gavutis), regarding the emergency plans for the Seabrook Emergency Planning Zone.
In the course of the interview, Ms. Verge and Ms. Gavutis identified emergency planning officials who might not be easily reached during an emergency.
These included the individuals listed in contention NHLP 2(h).
In addition to the emergency plans for the towns of South Hampton and Kensington, the documents that relate to the interview consist of Ms. Curran's notes, which constitute privileged attorney work product, and NECNP's offsite emergency planning contentions that were filed in 1983 and 1986.
NHLP 2(h).3 Do local officials believe that (a) the " paging notification systems that will be relied upon to contact emergency personnel are weak and unreliable" as the "Voorhees Report" stated, and (b) that the paging system does not satisfy any NRC notification requirement?
Please erplain how the paging notification system must be modified to satisfy the notification requirements.
Please identify all local officials who assert that the provisions in the NHRERP for paging emergency response personnel are inadequate.
ANSWER:
The Voorhees report states that all but one town expressed concern about " spotty paging or alerting of potential evacuation workers."
The Voorhees report did not identify the local officials who made the statements, and NECNP does not know of other officials who have made such statements.
NHLP 2(h).4 Please indicate which emergency response organizations NECNP called, besides the Town of Seabrook Highway Department, where there was no one to answer the phone.
Please explain any other basis for NECNP's statement that the NHRERP provides "no assurance that someone will actually be there to answer to the phone."
ANSWER:
None.
The additional basis for this contention is that due to the low or part-time staffing of some local offices, it is likely that the offices will not be occupied at all times during the day.
For instance, the South Hampton town hall, whose telephone number is listed as the " work phone" for the Board of Selectmen and the Civil Defense Director, is only open on a part-time basis.
CONTENTION NECNP NHLP (2){i)
EH.LP 2(i).1 Please explain how "the emergency response may break down" unless alternates are specified for local emergency response personnel.
ANSWER:
It is simple common sense that if a person who is responsible for one aspect of the emergency response is not available to perform that task, it may not be accomplished.
In that event, the emergency response might not be complete or adequate.
_NHLP 2(i).2 Which positions, in NECNP's estimation, are "important" and would require alternates?
ANSWER:
The important positions are those which, if not carried out, would jeopardize the health and safety of the public in a radiological emergency.
Examples are listed in the basis to Contention NHLP-2(1).
NHLP 2(i).3 Are the unfilled alternate positions referred to in the basis of this contention expected to be filled?
If.so, when?
If not, why not?
_ o ANSWER:
NECNP has no basis for guessing, nor is it required to anticipate the behavior of the State.
CONTENTION NECNP NHLP 2(j)
NHLP 2(j).1 What posts " crucial to an effective emergency response" must be filled?
ANSWER:
The crucial posts are listed in NUREG-0654, 5 II.A.2.a.
NHLP 2(J).2 Which such positions are at present not filled?
ANSWER:
NECNP objects to this interrogatory on the ground that it attempts to make NECNP gather information that can easily be obtained by the State.
All that is necessary is to review Appendix A of each local plan, which lists the " key members" of each town's emergency response organizations.
Where the name of a position is followed by a blank space, the position has not been filled.
NHLP 2(j).3 Are the unfilled positions listed in the basis of this contention expected to be filled?
If so, when?
If not.why not?
ANSWER:
NECNP has no information that would allow us to predict the actions of the State in this regard.
CONTENTION NECNP NHLP 3(a)
NHLP 3(a).1 Please explain why "most of the towns" in the Seabrook EPZ have no pagers.
Also please explain why towns without a sufficient number of pagers cannot obtain additional ones.
ANSWER:
Each local plan contains an " Appendix J," which lists the existing inventory of municipal services.
In reviewing Appendix J.
NECNP found that most of the plans did not list pocket pagers as part of the town's inventory.
NECNP objects to
. L the second part of the interrogatory on the grounds that it is irrelevant to the contention and calls for an opinion.
NECNP does not contend that more pagers cannot be obtained, but rather that some of the towns do not currently possess them.
NHLP 3(a).2 Please explain why it may be " impossible" for the contact person to use a radio at the South Hampton EOC.
ANSWER:
If the South Hampton EOC is not yet set up or open, it'may not be accessible to the contact person.
NHLP 3(a).3 Please explain how time-consuming it may be for the contact person to use a radio at the South Hampton EOC.
ANSWER:
There are a number of factors that may make it time-consuming to use the EOC, including travelling to the EOC, waiting for the EOC to be opened, and waiting for others who are already using the EOC radio.
CONTENTION NENCP NHLP 4
.NHLP 4.1 Has NECNP conducted a survey of the Seabrook EPZ towns to identify individuals with special notification needs?
If so, please indicate the numbers of such individuals, and describe how the NHRERP should provide for them.
Please describe how the survey was conducted, and identify all documents relating to the survey.
ANSWER:
No.
CONTENTION NECNP NHLP-6 NHLP 6.1 Please explain the basis of NECNP's statement that the commercial telephone systems are vulnerable in the event of a radiological emergency.
Please identify all documents supporting this response.
ANSWER:
According to a representative of the Chesapeake and Potomac Telephone Company, if central commercial telephone circuits become overloaded, calls cannot be put through even though the intended recipient of the call is not using his or her
telephone.
NHLP 6.2 Does NECNP disagree with the estimated number of persons with special transportation needs identified in the NHRERP?
Has NECNP conducted any survey of the number of persons with special transportation needs?
Please also identify all documents relating to the number of emergency vehicles necessary for an emergency at Seabrook.
ANSWER:
At this time, NECNP has not attempted to verify the accuracy of the~NHRERP's estimates of the number of persons with special transportation needs, nor has NECNP conducted any survey of the number of persons with special transportation needs.
Other than the plans themselves, NECNP knows of no other documents relating to the number of emergency vehicles necessary for an emergency at Seabrook.
NHLP 6.4 How many vehicles should be made available for emergency transportation in the Seabrook EPZ in the event of a radiological emergency?
ANSWER:
NECNP objects to this interrogatory on the ground that it seeks to shift to NECNP the State's burden of determining the number of vehicles necessary for emergency transportation in the Seabrook EPZ.
NECNP has not made such a calculation, nor is it required to.
NHLP 6.5 What percentage of buses, in the opinion of NECNP, that transport persons to the beaches for summer day trips then leave the area for the day?
Where do these buses go after they leave the beach area?
Please explain the basis of these responses, and identify any supporting documents.
ANSWER:
NECNP does not know the exact percentage of buses that transport people to the beaches for summer day trips.
We understand from conversations with Glenn French, Chairman of the Hampton Beach Chamber of Commerce, that the number is significant.
NHLP 6.6 Has NECNP made an estimate of the number of persons who are bused to the New Hampshire beaches for summer day trips?
If so, how was this number arrived at?
Please identify all documents supporting this response.
ANSWER:
See answer to NHLP 6.5, above.
I affirm that the answers to these interrogatories are true to the best of my information and belief.
A Ix Diane Curran HARMON & WEISS 2001 S Street, N.W.
Suite 430 Washington, D.C.
20009 (202) 328-3500 May 14, 1986 e
. _ _ _