ML20198A151
| ML20198A151 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/14/1986 |
| From: | Bisbee G, Strome R, Wallace W NEW HAMPSHIRE, STATE OF |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| Shared Package | |
| ML20198A132 | List: |
| References | |
| OL, NUDOCS 8605200345 | |
| Download: ML20198A151 (35) | |
Text
met.ATED CUNHON""M 591 L ">i 9 x(P UNITED STATES OF AMERICA -
? D NUCLEAR REGULATORY COMMISSION N
, # 19 .
- f before the [ " N
.y ATOMIC SAFETY AND LICENSING BOARD ,l/
a u, ;
, /,
In the matter of: )
)
)
PUBLIC SERVICE COMPANY OF ) Docket Nos.: 50-443 OL NEW HAMPSHIRE ) and (Seabrook Station, Units 1 and 2 ) 50-444 OL
) May 14, 1986 STATE OF NEW HAMPSHIRE'S ANSWERS TO NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE STATE OF NEW HAMPSHIRE ON EMERGENCY PLANNING FOR THE STATE OF NEW HAMPSHIRE The State of New Hampshire hereby responds to New England Coalition on Nuclear Pollution's Interrogatories and Requests for Documents to the State of New Hampshire on Emergency Planning for tne State of New Hampshire.
ANSWERS TO INTERROGATORIES Interrogatory No. 1 With respect to each contention and subpart thereof admitted by the Licensing Board's order >f April 1, 1986, please provide the following information.
Interrogatory 1(a) What is the State of New Hampshire's position with respect to each contention and its subparts? Descrice in detail the C6052OO345 860514 PDH ADDCK 05000443 O PDR
reasons for;your position. Identify any relevant portions of the state and local plans that are under revision or which the state expects to change at any time in the future?
Interrogatory 1(b) Identify and provide access to all documents on which you rely during this proceeding to support your position on each of these contentions. This includes all documents used in answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings.
s Interrogatory-1(c) Identify all persons on whose factual knowledge, 4
opinions, or technical expertise you rely for your position on each contention and subpart thereof.
Interrogator'y 1(d) Identify all persons you may call as witnesses on each of these contentions during these proceedings; describe the suostance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.
I Interrogatory No. 2 Please identify and provide access to all documents not identified in response to interrogatory 1(b) that evaluate or discuss the adequacy of emergency planning and preparedness with respect to 4 any of the c'ontentions admitted by the Licensing Board's April 1, 1986, prehearing conference order.
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Response toI Interrogatories 1(a) - 1(d) and 2:
Contention Hampton IV The State will provide adequate emergency equipment to support an evacuation in the event of a radiological emergency. The NHRERP provides for transportation of non-auto owning individuals and vacationers without acceptable transport.
Even though the State anticipates that many vacationers will have access to some form of acceptable transportation (cars, vans, buses) as they used this transportation to enter the area, and that non-auto owning individuals will have access to the same trensportation used in non-emergency situations, the State has entered into numerous agreements with transportation companies to provide van and bus transport from the EPZ communities to the reception centers. Of the pool of buses and vans available under the agreements, it is anticipated that sufficient numbers will be availaole to Hampton. Should these prove inadequate for the numoer of people needing transport, for whatever reason not presently envisioned,/ additional vans and buses will be made available from the pool. With regard to special needs, NHCDA Will verify the demand for special needs vehicles that will be needed in an emergency. Based on that verification, steps will be taken to satisfy the requirement under the same Letter of Agreement and pool arrangement described for i
buses and vans.
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_ Contention Hampton VI i- The State does not agree witn the population figures provided in this contention and relies on those provided in the KLD Study.
- , The State anticipates that there are adequate public works and police personnel availaole to perform the tasks assigned them in the i
RERP. If there are not sufficient public works anc police personnel to carry out these duties, the NHRERP provides that additional personnel will De assigned sucn responsioilities.
Also, in the event that the Hampton Selectmen cannot be reached or adequately trained, the State will provide compensatory manpower and/or services.
1 Contention Hampton VIII The NHRERP provides for "a range of protective actions" for the Seabrook plume exposure EPZ, and that guidelines for the choice of protective actions are in place, pursuant to 10 C.F.R. Section 50.47(b)(10). As required by 10 C.F.R. Section 50.47(b)(8), the r I
facilities and equipment for protective actions are provided for in
.the NHRERP.
Contention Hampton Falls 1 i
The State trusts that in the event of an actual raciological l emergency at Seabrook Station, the officials of the Town of Hampton 2
Falls would respond and implement the radiological emergency response plan. The NHRERP provides, in any event, that the State will provide any compensatory manpower facilities and equipment. See " State 4
l Compensatory Plan"; NHCDA Procedures for Local Liaisons, Vol. 4, b NHRERP.
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Contention Hampton Falls 2 The State anticipates that the Town of Hampton Falls possesses the necessary manpower to carry out the duties assigned the Town under the RERP.
The NHRERP provides, in any event, that the State will provide any compensatory manpower facilities and equipment. See " State Compensatory Plan"; NHCDA Procedures for Local Liaisons, Vol. 4, NHRERP.
Contention Hampton Falls 4 To the extent that the Town of Hampton Falls cannot agree on the designation of Town officials to ensure that certain emergency response functions are properly carried out, the NHRERP provides tnat the State will provide any necessary compensatory manpower resources. " State Compensatory Plan"; NHCDA Procedures for Local Liaisons, NHRERP, Vol. 4.
Contention Kensington 1 The State anticipates that the Town of Kensington will have a sufficient number of trained personnel to fulfill the Town's responsibilities in the event of a radiological emergency at Seabrook Station.
To the extent that the Town of Kensington lacks the necessary emergency resonse personnel because of vacant alternate positions, the NHRERP provides, in any event, that the State will provide any compensatory manpower facilities and equipment. See " State Compensatory Plan"; NHCDA Procedures for Local Liaisons, Vol. 4, NHRERP.
Contention Kensington 2 Revision 1 of the NHRERP will reflect that the primary point of notification for the Town of Kensington is the police officer on duty or on call.
In the event no one from the Town of Kensington is available to serve as the notification link, the NHRERP provides that the IFO Local Liaison'for the Town of Kensington will notify the appropriate persons and institutions with the Town of Kensington. " State Compensatory Plan"; NHCDA Procedures for Local Li.aisons, Vol. 4, NHRERP. .
Contention Kensington 4
, See the State's answer to Interrogatory 5, infra.
Contention Kensington 6 Volume 5 of the NHRERP includes Letters of Agreements with bus companies rdpresenting an availability of over 600 vehicles at any given moment.
The State has obtained and will incorporate in Vol. 5 of the NHRERP, Letter of Agreement with the New Hampshire Towing Association,j relative to the provision of towing services in tne event of a radiological emergency at Seabrook Station.
Contention Kensington 7 See the State's response to Interrogatory 6(c) - 6(e), infra.
Contention Kensington 10 The Sta'te of New Hampshire is at. enable to moving the phone to the second floor command post of the Kensington EOC. Therefore, the communications problem identified by the Town in this contention should no $onger be in issue.
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7-Contention Rye 2 The Rannie Webster home (d/b/a Whispering Pines Nursing Home) has only recently received its nursing home license from the State.
Reference to this facility, therefore, was omitted from early versions of the plan. It is now being incorporated into the Special Facilities section of the Rye RERP. Therefore, this contention should no longer be in issue.
Contention South Hampton 1 The Town of South Hampton Willing, the State will work out any necessary agreement with the Town in conformance with NUREG-0654, Item I.A.3. Barring that, the NHRERP provides that the State will provide any compensatory manpower facilities and equipment. See
" State Compensatory Plan"; NHCDA Procedures for Local Liaisons, Vol.
4, NHRERP.
Contention South Hampton 2 J
The Town of South Hampton should have a sufficient number of personnel to provide for twenty-four hour continuous operation after the declaration of an emergency. To the extent that such manpower is lacking, hoyever, the NHRERP provides that the State will provide any compensatory manpower facilities and equipment. See " State Compensatory Plan"; NHCDA Procedures for Local Liaisons, Vol. 4, NHRERP.
Contention South Hampton 3 Volume'S of the NHRERP contains Letters of Agreements with j transportation companies.
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I Contention South Hampton 6 The State has been, and remains, willing to provide for an acceptable location for the Soutn Hampton EOC, including the provision of a generator and adequate communications with schools and the State EOC.
Absent the Town of South Hampton's agreement to the location of and accommodations for its EOC, the NHRERP provides that the State will provide any compensatory manpower facilities and equipment. See
" State Compensatory Plan"; NHCDA Procedures for Local Liaisons, Vol.
4, NHRERP.
Contention South Hampton 8 The State has conducted a survey to identify the mobility impaired and transport dependant individuals in the EPZ. At a minimum, it will Drovide transportation to those identified by the survey and whose need has been verified. Letters of Agreements with Dus companies and emergency case providers are contained in Vol. 5 of the State Plan.
j NECNP Contentions RERP-2, RERP-3, RERP-8, and RERP-12 See the answers provided to interrogatories based on these 4
contentions, infra.
NECNP Contention RERP-10 See tne State's May 6, 1986 answers to SAPL's Interrogatory 1(a)
- 1(h).
Contention NHLP - 2 (a) The State anticipates that local police forces are sufficient to carry out the duties assigned to them under the plan.
These consist primarily of traftic control snould evacuation be necessary. Access control will be carried out by State personnel.
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1 (d) Letters of Agreement for provisions of school buses and towing facilities are now included in Volume 5 of the plan. The State has and will be providing a signed copy of the Letter of Agreement with the New Hampshire Towing Association.
(f) The State anticipates that the local highway departments have sufficient personnel and resources to fulfill their responsibilities under the New Hampshire RERP. The NHRERP provides, in any event, that the State will provide any compensatory manpower facilities and equipment. See " State Compensatory Plan"; NHCDA Procedures for Local Liaisons, Vol. 4, NHRERP.
(g) The State anticipates that the local communities have sufficient fire department manpower and resources to carry out those 1
duties assigned local fire personnel under the RERP.
The NHRERP provides that the State will provide any compensatory manpower and resources. " State compensatory Plan"; NHCDA Procedures for Local Liaisons, Vol. 4, NHRERP.
(h) The State anticipates that local officials and emergency responders can be notified and that they can respond in a timely fashion.
In the event that they are not, the NHRERP provides that the State will provide any compensatory manpower facilities and equipment. See " State Compensatory Plan"; NHCDA Procedures for Local Liaisons, Vol. 4, NHRERP.
1 (i) and (j) See the State's answer to Kensington-1, supra.
Contention NHLP - 3 See the State's answer to NECNP Contention NHLP-2(h), supra Contention NHLP - 4 Those with special notification needs will be provided with the special equipment required to meet their needs. NHRERP at 2.1-10.
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Contention llHLP - 6 The special needs population will be provided for to the extent that local resources are insufficient to meet their needs, the state is committed, in any event, to provide any compensatory manpower facilities and equipment. See " State Compensatory Plan"; NHCDA ProcedureshorLocalLiaisons,Vol. 4, NHRERP.
Contentions SAPL 5, 7, 8, 16, 17, 18, 25 See the State of New Hampshire's May 6, 1986 answers to SAPL's Interrogatories in the NHRERP.
Contention SAPL 14 See tne State's answer to Interrogatory 4, infra.
The following persons were relied upon in formulating these responses:
- 1. Michael A. Nawo) (as to notification, communications, transportation, letters of agreement, shelter).
- 2. Nic'k Pishon (as to questions relating to buses and letters of agreement).
- 3. David Deans (as to federal assistance)
- 4. John Bonds (as to KI, monitoring, shelter)
The Stape has not determined which, if any, expert (or fact) witnesses may be called in this proceeding.
The State has notitied the parties of all revisions to the NHRERP. It will continue to do so as to all future revisions.
Interrogatory No. 3 With respect to NECNP contention RERP-2, please provide the following information, t
Interrogatory 3(a) Identify all areas in which the state will require federal assistance during a radiological emergency.
Response
The areas in which the State of New Hampshire may require j federal assistance are described in Section 1.4.5 of the NHRERP,
" Anticipated Needs For Federal Assistance." Three areas are cited:
the New Hampshire emergency response organization depends upon the U.S. Coast Guard to regulate boating activities during an emergency; New Hampshire depends upon FAA support to restrict tne Seabrook EPZ from overfli.ghts in the event of an emergency; and the State may be dependent upon federal resources to undertake shellfish monitoring should this be necessary.
Additional federal help, while not necessary to cover a specific resource requirement, could also be requested depending upon the nature and d'uration of an emergency (e.g. FRMAP may be implemented to augment the State's accident assessment capabilities). The procedure for initiating requests for this type of help are described in 51.4.4 of the NHRERP.
l l Interrogatory 3(b) Describe the equipment and/or services that the 1-state expects to request from the federal government.
Response
The resources and/or services to be provided by the U.S. Coast Guard are described in their procedures (NHRERP Vol. 4, S19). The resources and/or services to De provided by the FAA are the use of existing FAA communication systems and personnel to restrict flights I
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through air space above the EPZ. In addition the State may be dependent upon federal laboratory resources to analyze shellfish samples for radiological contamination. The State has not provided specifications for equipment to undertake this effort. Instead, the State will rely first upon the New England Radiological Assistance Compact states to identify and coordinate the provision of shellrish sample analysis, should it be required.
Interrogatory 3(c) What is the expected time of arrival for each a
category of equipment and services, and how is that arrival time determined?
Response
The FAA resources are in place. There is no travel time requirement for obtaining the required assistance from the FAA.
The U.S. Coast Guard resources are also readily available. The broadcast to mariners requires no travel. It can be implemented by telephone. Travel for U.S. Coast Guard personnel from Boston to the IFO at Newington Station should take approximately one hour. This travel time could be reduced should the Coast Guard elect to travel by helicopter (if one is available at the time). Travel times for vessels and crews to be used depend upon availability of vessels and crews at Merrimac Station, Gloucester Station and Portsmouth Station, and upon marine conditions at the time. The State estimates that the first responders could be available offshore of the EPZ within an hour of notification and that several vessels could be available, if necessary, within two to three hours.
The State has undertaken no analysis of travel times for l shellfish analysis. Travel times would depend upon the federal 2
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laboratory facility to be used. Regardless of the facility selected the State estimates that shellfish sample analysis could be i undertaken.within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of identifying the need to have it undertaken.
Interrogatory 3(d) Describe all existing arrangements for federal aid.
Response
Existing arrangements for federal assistance are described in the NHRERP. See Vol. #1 Sl.4.4, Vol. #1 S1.4.5, Vol. #4 S19, and
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Vol. #5. The State may also choose to useeresources available through implementation of the Federal Radiological Emergency Response Plan (FRERP; 50 Fed. Reg. 46542 (November.U', 1985)).
Interrogatory 3(e) Describe all arrangements for federal aid that the state expects to make in the future, f s
Response
The State does not plan to seek additi6nal federal assistance at this time.
Interrogatory 3(f) Identify and produce all documents tnat demonstrate that the state has or is making arr'angements for federal assistance in the event of a radiological emergency.
Response: .
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See the responses to Interrogatories 3(d) and 3(e) above.
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Interrogatony No. 4 With respect to NECNP contention RERP-3, please provide the following information.
f Interrogatory 4(a) Identify and provide access to all pre-emergency instructional material that the state intends to use in the Seabrook Emergency Planning Zone.
Interrogatory 4(b) Describe the locations at wnich each type of instructional material will be placed.
Response to Interrogatories 4(a) and 4(b):
Pre-emergency instructional materials and locations at which they will De placed include the following:
(1) Public information calendar (including special needs card and self-sticking label)-mailed to EPZ residents.
(2) English language flyers - delivered to EPZ commercial establishments (restaurants, hotels, motels, rooming houses, schools, camps, healtp care facilities, private recreational facilities, other businesses and municipal facilities).
(3) French /English language flyers - same distribution as described as in the answer to (2) above.
(4) Englisn language posters - same distribution as descrioed in i
the answer to (2) above.
(5) French /English language posters - same cistribution as described in the answer to (2) above.
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- > p. e l $. 3 (6) Eng4ish language self-sticking labels - same distribution as Av ,
,( described in the answer to (2) above.
3%'f, (7) French /English language self-sticking labels - same
'l distribution as des'cribed in the answer to (2) above.
g- (8) Bus route maps - same distribution as described in the
}1 ' answer to ( N)-above.
, (9) Business reply cards for requesting additional materials -
same distribution
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as described in the answer to (2) above.
, -(10)-English language metal signs - placed at beaches, parks,
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state forest.s, and'other public recreational areas.
-(11) French /English language metal signs - same distribution as
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descr1 bed'intheanhwerto (10) above.
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(12) Telephone directory advertisements - placed in telephone w'r ,
directories serving-EPZ communities.
.The dra't pre-emergency instructional materials, except for the f
bus route maps, have already been distributed to the parties in this proceeding.
' -Interrogatory 4(c) Describe the quantity of eacn type of instructional material to be placed at each location.
Response
The following.are the estimated quantities of public information
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materials to be distributed or placed:
(1) EPZ' Residents Mailing Direct mail of calendar (including special needs card and decal) to each EPZ resident.
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(2) Hand Delivery to Selected EPZ Commercial Establishments To employers of 50+ people, seacoast restaurants, hotels, motels, rooming houses, schools, camps, health care facilities:
letter from State Civil Defense Director, 50 flyers, 50 decals, 50 bus maps, 5 posters, business reply card to order additional materials.
(3) Direct Mail to Other EPZ Commercial Establishments The other commercial establishments in the EPZ will receive a letter from State Civil Defense Director, flyer, poster, bus map, decal, business reply card to order additional materials.
(4) Posting in Beaches and other Recreational Areas Emergency notification signs (in total, 29 in English and 24 in French /English) will be posted in beaches, parks, state forests, and other recreational areas. The information Dooths at these areas will also display posters (20 in English; 8 in French /English) and have flyers (5000 in English; 3000 in French /English) and stickers (500 in English; 250 in French /English) available.
(5) Hand Delivery to Town Offices in EPZ The following material is to be distributed to all town halls and tourist information offices: letter from State Civil Defense Director, 50 flyers, 25 bus maps, 5 posters, 10 decals, business reply cards to order more information.
(6) Telephone Directory Advertising Two-page advertisements are to be placed in the Portsmouth, Newburyport, and Haverhill White Pages.
Interrogatory No. 5 With, respect to NECNP contention RERP-8, please provide the following information.
Interrogatory 5(a) Identify and provide access to all studies, assessments, and calculations, regarding the effectiveness and/or capaci,ty of buildings in the Seabrook emergency planning zone for sheltering from radiological releases. -
Response: '
The State relies upon the " Shelter-in-Place" concept for sheltering the general population, which provides for sheltering at the location for which the sheltering instruction is given. See d
Section 2.6.5, NHRERP, Vol. 1, for additional discussion of this concept.
The State has carried out an assessment of special facilities (the Rockingham County Jail, hospitals and nursing homes licensed by the State) to determine their specific abilities to effect a cose reduction for patients, residents, inmates, and staff. The results of this assessment are presented in Figure 5 of Appendix F, NHCDA 4
Procedures, Vol. 4, NHRERP, and Figure 5 of Appendix U, DPHS
. Procedures, Vol. 4, NHRERP. A similar sheltering study has recently been conducted at the Phillips Exeter Academy.
, In addition, the State relies upon shelter effectiveness information contained in federal publications that include EPA 520/1-75-001 Rev. June 1980, NUREG/CR-ll31, and FEMA TD-15. All of these documents are available for inspection, by appointment, at NHCDA offices at the State Office Park South, Concord, New Hampshire.
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Interrogatory 5(b) Identify and provide access to all documents showing the criteria for designation of shelters during a radiological emergency.
Response:
- See~the selection criteria for making protective action
,- decisions in Section 2.6, NHRERP, Vol. 1; Appendix F, NHCDA Procedures; and Appendix 0, DPHS Prdcedures, NHRERP, Vol. 4.
Interrogatory 5(c) Identify and provide access to all documents, including maps, that show the locations of buildings that the state intends to be used for sheltering during a radiological emergency.
Response
As noted in the response to Interrogatory 5(a) above, the State relies, for the general population, on the " Shelter-in-Place" concept, which precludes the need for designation of large public or private facilities for mass sheltering. There are, therefore, no
-documents or maps that snow the locations of Duildings that the state intends to be used for sheltering during a radiological emergency.
Figuref 5, Appendix F, NHCDA Procedures, and Figure 5, Appendix U, DPHS Procedures identify the location of Duildings housing special populations - patients of hospitals, residents of nursing homes, and inmates of the Rockingham County Jail - which may be designated by the State as shelters for these populations and the staff which serve them.
Interrogatory 5(d) Describe the oasis for the state's conclusion that
" generally, sheltering can provide protection for two to five hours." (RERP at 2.6-7)
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Interrogatory 5(d)(1) To what extent is your assessment based on studies of sheltering facilities in the Seabrook EPZ.
Interrogatory 5(d)(ii) Explain the basis for the change in the current state Radiological Emergency Response Plan ("RERP") from the previous plan, which estimated that sheltering would be effective for only two hours.
Interrogatory 5(d)(iii) Identify and provide access to any documents on which you, rely for your conclusion that sheltering can provide protection for two to five hours.
Response to Interrogatories 5(d)(i) - 5(d)(iii):
The quoted statement was intended to serve as a generalization of how long sheltering may_ue used. The range of time intends to point out that preparation for shelter would be minimal, in that the need for shelter supplies or special preparation would not ce necessary. It does not mean that sheltering will only be implemented for a 2-5 hoyr period, nor does it mean that sheltering will oe implemented for this period, or some part of it, if other factors indicate that sneltering ought not to be considered at all. As Section 2.6.5 of the State Plan explains, sheltering in domestic, woodframe structures (i.e., " Shelter-in-Place" rather than mass sheltering) i's a valuable protective action that can be implemented quickly and whicn offers a significant dose reduction to residents for a range of radioactive release levels and weather condition combinationd.
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The range of "2-5 hours" rather than "up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />" better approximates the period of time that sheltering might be used as a protective action.
The general guidance upon which Section 2.6 is based are "The Manual for Protective Action Guidelines for Nuclear Incidents", EPA
-520/1-75-001 and Protective Action Evaluation, Part 1 + ll, The effectiveness of sheltering as a protective action against nuclear accidents involving Gaseous Release, EPA 520/1-78-001-A+B.
Interrogatory 5(e) Describe and explain the basis for the statement that "The main reason sheltering is a valuable protective action is that it can be implemented quickly, usually in a matter of minutes."
RERP at 2.6-7.
Response
Shelter-in-place can be implemented by activating the public alert and notification system and providing appropriate instructions over the broadcast media. Shelter-in-place can be implemented within minutes from the time the protective action decision is made.
NHRERP, Vol. 1, Section 2.6.5.
Interrogatory 5(f) Identify and provide access to any calculations performed by the state of New Hampshire regarding the time necessary for transients in the EPZ to take shelter in public buildings, as provided in RERP at 2.6-8.
Response
The State has performed no such calculations. For a radiological emergency at Seanrook, the State will direct transients 1 l
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4 to leave the EPZ as quickly as possible should they not have homes, cabins, or hotel / motel accommodations readily available in the area.
The State Plan does not provide for the State to direct transients to
- seek' directions to a nearby public building in the event of a radiological emergency at Seabrook Station.
Interrogatory 5(g) The RERP states that "
The dose reduction from which an individual benefits by sheltering is a function of how well 4 the structure is sealed and tod long the Plume takes to travel over the area." RERP at 2.6-7. Identify and provide access to any and ,
all calculations of how these factors would affect dose reductions
- during a radiological accident at the SeaorooK plant.
Response
No such general calculations have oeen done.
Calculations are done during accident assessment, whicn is generally described in Section 2.5, NHRERP, Vol. 1. The variables j used in such calculations, and their definitions, however, are p identified in Section 2.6.7 (at 2.6-22), NHRERP, Vol. 1. Appendix F i
to the NHCDA Procedures, and Appendix U to the DPHS Procedures, in Vol'. 4 of tne NHRERP, describe the protective action decision criteria and provide the protective action recommendation worksheets which reflect tnese variables.
Tecnnical guidance for these calculations is provided in tne federal publications identified in the response to Interrogatory 5(a) l dDove, and in other appendices to the DPHS Procedures.
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Interrogatoly 5(h) Describe the procedural steps by which the Governer-(sic) will consider and/or recommend sheltering as a protective action during a radiological emergency at Seabrook.
Response
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The procedural steps are described in procedures for the
. pirector, NHCDA, and Director, DPHS NHRERP, Vol. 4. These procedures are generally described in Section 1.3, NHRERP, Vol. 1. The general
. decision-making process is provided graphically and narratively in Section 2.6, NHRERP, Vol. 1.
Interrogatory 5(i) Identify all individuals who will be consulted by the Governer (sic) in making a decision regarding whether to order sheltering and the type of sheltering measures to be taken.
Response
The State cannot predict who "will be" consulted by the Governor. The NHRERP provides, however, that the Governor will consult at least with the Director of the NHCDA, or his designee, and with the Director of the DPHS, or his designee. As explained in Section 2.6/ of the State Plan, these two individuals have the responsibility of presenting protective action recommendations to the Governor and for providing any necessary assistance in his decision making. The Governor will be able to consult with any of the State and federal agency representatives at the State EOC, and with others i
as he sees fit by telepnone or radio.
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4 Interrogatory 5(i) Identify all documents to be used by the Governer I
(sic) or his advisors in making a decision regarding whether to order sheltering and the type of sheltering measures to be taken.
Response: i The New Hampshire Rad'ological i Emergency Response Plan.
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Interrogatory 5(k) Identifyallarea$wheretheGoverner (sic) may recommend sheltering, inclu'ded but not limited to public shelters.
(See RERP at 2.6-7.)
Response
As noted in the responses to Interrogatories 5(a) and 5(c) 4 above, the State relies upon the " Shelter-in-Place" concept for the general population; it has no intention of directing the general population to public shelters. A shelter in place recommendation may be given for any area in the EPZ.
Interrogatory 5(1) List all groups who may oe given "special instructions" and describe all special instructions that may be given.
RESPONSE
l Special instruction should be given to all occupants of the EPZ during an emergency. The content of a sps:cial instructions message would provide specific advice pertaining to specific groups of people or'certain areas of the EPZ, or both, as the emergency makes necessary. No specific group nor any specific set of instructions has been selected in advance to cover all contingencies. The I
reference to "special instructions" at Vol. 1, page 2.6 of the NHRERP is intended to provide the flexibility to provide specific instructions,to any group of individuals with the EPZ. Sample EBS and ERBS messages can be found in Vol. 4 of the NHRERP, the NHCDA Procedures, Appendix F.
Interrogatory 5(m) DescriDe and identify the so'urce of tne
" shelter-in-place" concept described at RERP page 2.6-7, and list all other nuclear facilities at which you are aware that it is used.
Response
The shelter-in-place concept was first used by NHCDA as part of its emergency planning for the New Hampshire portion of the Vermont Yankee EPZ. The State uses the concept at both Vermont Yankee and Seabrook Station. The State has no knowledge of which other nuclear power plant sites use this, or a similar, concept, nor does the State anticipate undertaking studies to obtain this information.
Interrogatory 5(n) Identify the state parks and outdoor recreation areas described in the third full paragraph on page 2.6-B, and the number of individuals in each park or recreation area.
Response
State parks and outdoor recreation areas are listed in Volume 4, Appendix A of the DRED Procedures. The State has not calculated the number of people using each of these facilities. The peak population of the EPZ is provided, however, in the local RERPs, generally in Table 1.
i Interrogatory 5(o) Describe the means by which " individuals located in State parks and outdoor recreation areas will be asked to leave open areas and leave the EPZ or enter one of the shelters made available in the lo. cal communities." RERP at 2.6-8 Response: ,
As noted in the response to Interrogatory 5(f) above, for an emergency at Seabrook that results in a decision to shelter, transients will not be directed to local public shelters. As to the means that the State will use to ask individuals in State parks and outdoor recreation areas to leave the EPZ, emergency workers in State parks and outdoor recreation areas will be able to make use of the Public Notification System outlined in Section 2.1 of the RERP. A voice message may be presented over the siren system after the notification signal. Those individuals who have access to either an AM or FM radio also can receive emergency broadcast messages.
Furthermore, DRED employees can instruct the beach population to leave the beach area and the EPZ.
Interrogatory 5(p) Describe and identify the location of each shelter that will be made available to individuals in parks and outdoor recreation areas. Include in your description the capacity of each shelter, your evaluation of its effectiveness for sheltering against radiation, and the basis for that evaluation.
Response
No such public shelter is identified in the NHRERP.
As noted in the responses to Interrogatories 5(f) and 5(o) aoove, individuals in parks and outdoor recreation areas will not be
-. . - . . - . ._ . . . . _ .-. . . . ~_- - - . . -- _ - . .
directed tolpuolic shelters should an emergency at Seabrook require a decision to shelter. Rather, they will, if they do not have nomes, cabins, or hotel / motel accommodations in the area, be directed to leave the EPZ.
Interrogatory No. 6 With respect to NECNP contention RERP-12,' please provide the following information.
Interrogatory 6(a) Identify and deacribe the criteria by which the a
State of New Hampshire intends to choose protective actions for.
5 hospitals, nursing homes, schools, and jails in the event of a
. radiological emergency at Seabrook. If these criteria differ for
- individual institutions or types of institutions, describe the manner in which the'y differ, i
i Interrogatory 6(b) Describe the circumstances under which the state would not order an evacuation of the institutions described in interrogatory 6 (a) above.
Interrogatory 6(c) Are the criteria and circumstances described in your answers to interrogatories 6 (a) and (b) above any different i
from the criteria to be used for protective actions for the general public? If ho, describe in detail the manner in which they differ.
1 i
4 S
i
i l l Response to, Interrogatories 6(a) - 6(c):
NECNP Contention RERP-12 pertains solely to the New Hampshire RERP's " provision of radioprotective drugs for institutionalized persons and emergency workers." Memorandum and Order, April 29, ,
1986, at 62. These interrogatories pertain to the criteria used in choosing protective actions generally, and they, therefore, exceed
! the scope of the admitted contention in that the provision of radioprotective drugs is but one of the protective actions available .
- to the State. The State of New Hampshire objects to the scope of i
interrogatories 6(a) - 6(c) on the ground that they are irrelevant to the contention.
Interrogatory 6(d) What provision, if any, has the State made for tne distribution of radioprotective drugs to persons institutionalized in hospitals,-nursing homes, jails and schools in the Seabrook EPZ?
Interrogatory 6(e) State the rationale for your answer to interrogatory 6 (d) above and identify all documents on wnich you rely to supqort your rationale.
Response to Interrogatories 6(d) and 6(e):
As to institutionalized persons:
1 Potassium iodide (KI) will be made available for ingestion by institutiona'lized individuals, who are defined as patients in hospitals, residents in nursing homes licensed oy DPHS, individuals i
i i
l l f who are confined in a house of correction, or the staff of the l hospitals, nursing homes, or the house of correction. The State will l
L provide sufficient quantities to each such facility for all such persons. Potassium iodide will only be taken after instruction to co so by the Director, DPHS, or his designee. For patients and I
residents of nursing homes, KI will be taken only if the individual's physician has determined that the use of potassium iodide is l-l appropriate for the individual.
Section 2.7 of the NHRERP, Vol. 1, generally describes the decision criteria to implement the State's policy on Potassium l Iodide. This section will De revised to specifically reflect the l availability of KI for institutionalized individuals. The Director, l
i DPHS, Procedures and Appendix K to those Procedures, Vol. 4, NHRERP, implement the State's policy on potassium iodide. Appendix K will be revised to specifically reflect the availability of KI for institutionalized individuals.
The rationale for making potassium iodide available to ,
institutionalized individuals (as defined in 6 (d) above) stems from the State's concern tnat, if such individuals are sheltered while tne i general population is evacuated, and if the emergency includes the release of radiciodines but at a level below the protective action l guide for evacuation (see Figure 4, Appendix F, NHCDA Procedures and 1
i Figure 4, Appendix U, DPHS Procedures, Vol. 4, NHRERP), then some level of thyroid protection should be availaole to these individuals.
Schools and jails, other than the Rockinghala County Jail, are not subject to separate criteria for selecting protective actions.
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_ _ _ - , . - _ . _ _ _ , _ _ _ , , _ . _ . . , _ _ . , . _ _ _ _ _ . . _ _ . _ _. _ ~ _ _ _ _ _ _ _ . _ _ .
The State's policy on distribution of potassium iodide to institutionalized persons is stated in a letter from Dr William T.
Wallace, Director,-DPHS, to Richard H. Strome, Director, NHCDA, dated
- April 23, 1986.
As to emergency workers:
Section 2.7.3, NHRERP, Vol. 1, specifies that "KI will be stored in the local EOCs and at the IFO/EOFs. Based on actual and anticipated releases, DPHS will determine when KI shall be distributed to state and local emergency workers" (At 2.7-3. This policy was stated in a letter from Dr. William T. Wallace, Director, DPHS to former director, NHCDA, Mrs. Eileen Foley, on December 3, 1981 (copy on file with the Assistant Director for Planning, Office of the Director, DPHS). This policy was restated, with clarification on the meaning of " emergency worker," in letters from Dr Wallace to Richard H. Strome, Director, NHCDA, on October 31, 1983 and September
+
17, 1985, and April 23,-1986. Implementing procedure for this policy is found in the procedures for the Director, DPHS, NHRERP, Vol. 4.
Appendix K of the DPHS Procedures, NHRERP, Vol. 4, provides further information on KI and its use in the event of a release.
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l Motion For Protective Order The State of New Hampshire hereby moves the Board for a-protective order that no answers are required as to Interrogatories 6(a) through 6(c). Inasmuch as these interrogatories inquire into-the protective action decision-making criteria for special facilities,.'they exceed the scope of NECNP Contention RERP-12. ,
i
Signatures As to Answers to Interrogatories 3 and 6:
Dr. William T. Wallace, Jr., M.D., M.P.H.
As to Answer to Interrogatory 4: Richard H. Strome As to Answers to Interrogatories 1, 2 and 5:
Dr. William T. Wallace, Jr. and Richard H. Strome I, William T. Wallace, Jr., M.D., M.P.H., being first duly sworn, do depose and say that the foregoing answets are true, except insofar as they are based on information that is available to the State but not within my personal knowledge, as to which I, based on such information, believe them to be true.
k D William T.
W-80 Wallace, d .%
Jt., M.D., M.P.H.
Director, DPHS Division of Public Health Services Sworn'to before me this 14[.hdayofPay,1986:
$. A _
Notary ublic' vie q +4 My Commission E;tpires. (>w M 10.1'190 W AA M L M C,Jn);euet:;wy ..
bSM?NbD..cN$s,4c;.,10, I J);h
I, Richard H. Strome, being first duly sworn, do depose and say that the foregoing answers are true, except inaofar as they are cased on information that is available to the State but not within my personal knowledge, as to which I, based on such information, believe them to be true.
sf1 [
J f' *}-t ;====:s~~
Richard ti . Strome Director, Civil Defense Agency Sworn to before me this 1 th day of May, 1986:
0 04 t'e t a r y 1";b l i c- # AYw My Commission Ex ires: J. i c) , , q 90 CHARLES E. S:.tc, jage, g ,;, p y ,, jan ,0, i My_Cean;33;on,c,p
O As to Objections and Motion for Protective Order:
I I
%% \%9th DatLb i
George Dana Bisbee'-
Assistant Attorney General Environmental Protection Bureau Office of the Attorney General 25 Capitol Street
- Concord, NH 03301-6397 Telephone (603) 271-3678 k
l l
i
r CERTIFICATE OF SERVICE I, Geo day Hof 14eus/ gge , Dana 1986, BisDee, herebyof I made service certify that ondocument the witnin the I by mailing copies t4preot , postage prepaid, to:
Administrative Judge Helen Hoyt Administrative Judge Sheldon J.
Chairperson Wolfe, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory .U.S. huclear Regulatory Commission Commiasion Washington, DC 20555 Washington, DC 20555 -
Dr. Emmeth A. Luecke Dr. Jerry Harbour Atomic _ Safety and Licensing Atomic Safety and Licensing Board Panel Boaro Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, tK: ,
20555 Washi.igton, DC 20555 Philip Ahrens, Esquire Thomas J. Dignan, Jr., Esquire Deputy Attorney General R. K. Gad, III, Esquire Department of the Attorney General Ropes & Gray State-House Station 6 225 Franklin Street Augusta, ME 04333 Boston, MA 02110 Carol S. Sneider, Esquire Sherwin E. Turk, Esquire Assistant Attorney General Deputy Assistant Cntef Department of the Attorney General Hearing Counsel One Ashourton Place, 19tn Floor Office of the Executive Counsel Boston, MA 02108 Director U.S. Nuclear Regulatory Coumission Ms. Diana P. Randall Wasnington, DC 20555 70 Collins Street Seabrook, NH 03874 Robert A. Backus, Esquire Backus, Meyer & Solomon
- Diane Curran, Esquire 116 Lowell Street Harmon & Weibs P. O. Box 516 20001 S Street, N.W. Manchester, NH 03105 Suite 430 Washington, DC 20009 Anne Verge, Chairperson Board of Selectmen Jane Doughty Apt. 2056 Old English 5 Market Street Dover, :;H 03820 Portsmouth, NH 03801 1
- Served by Federal Express
Paul McEachern, Esquire Matthew T. Brock, Esquire J. P. Nadeau, Esquire Shaines & MgEachern Selectmen's Office 25 Maplewoo6 Avenue 10 Central Road P. O. Box 360 Rye, NH 03870 Portsmoutn, NH 03801 Mr. Calvin A. Canney Ms. RODerta C. Pevear City Manager The Town of 'Hampton Falls City Hall Drinkwater Road 125 Daniel Street Hampton Falls, NH 03844 Portsmouth, NH 03801 Mrs. Sandra'Gavutis Mr. Angie Machiros The Town of Kensington Chairman of the RFD 1, Box 1154 (Route 107) Board of Selectmen Kensington, NH 03827 Town ot Newbury Newbury, MA 01950 Senator Gordon J. Humphrey Mr. Richard E. Sullivan U.S. Senate Mayor Washington, DC 20510 City Hall (Attn: Tom'Burack) Newburyport, MA 01950 Senator Gordon J. Humphrey William S. Lord 1 Pillsbury Street Board of Selectmen Concord, NH 03301 Town Hall (Attn: Herb Boynton) Friend Street Amesbury, MA 01913 Mr. Thomas Powers Brentwood Board of Selectmen Town Manager RFD Dalton Road Town of Exeter Brentwood, NH 03833 10 Front Street Exeter, NH 03833 Gary W. Holmes, Esquire Holmes & Ells H. Josepn Flynn 47 Winnacunnet Roao Assistant General Counsel Hampton, NH 03841 Office of General Counsel Federal Emeggency Management Richard A. Hampe, Esquire Agency ' Hampe & McNicnolas 500 C Street, S.W. 35 Pleasant Street Washington, DC 20472 Concord, NH 03301 Mr. Ed Thomas FEMA, Region I John W. McCormack Post Office and Court House Post Office Square Boston, MA 1 02109 ,
George' Dana Bibbee
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