ML20198E181
| ML20198E181 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/20/1986 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| Shared Package | |
| ML20198E125 | List: |
| References | |
| OL, NUDOCS 8605270308 | |
| Download: ML20198E181 (30) | |
Text
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.. - f; ELATED CORRESPONUkfn% l May 20, 1986 ?
UNITED STATES NUCLEAR REGULATORY COMMISSION / gg["
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD N gg.ht
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In the Matter of ) ggf\
Public Service Company of )
New Hampshire, et al. ) Docket Nos. 50-443 OL
) 50-444 OL (Seabrook Station, Units 1 & 2) ) OFFSITE EMERGENCY
) PLANNING
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NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S RESPONSE TO APPLICANTS' INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS AND MOTION FOR A PROTECTIVE ORDER The New England Coalition on Nuclear Pollution submits the following answers to Applicants interrogatories and requests for the production of documents. Where NECNP has not fully answered a question because it has incomplete information, has not developed its position, or has not yet engaged an expert witness, those answers will be supplemented as soon as the information is available.
NECNP also objects to some of Applicants' interrogatories, for reasons which are stated in the answer to each particular interrogatory that is objected to. Pursuant to 10 C . F . R.
2.740(c), NECNP moves for a protective order that discovery not be had on those interrogatories to which it objects.
General Interrogatories G-1 through G-3. These interrogatories seek information regarding the identity of individuals and documents relied on by NECNP in answering Applicants' specific interrogatories. Where NECNP possesses responsive information, it is provided in NECNP's answers to the 8605270308 860520 PDR ADOCK 05000443 Q PDR -
specific interrogatories.
G-4. ANSWER: No.
G-5. ANSWER: NECNP does not know.
G-6. ANSWER: NECNP does not know.
G-7. ANSWER: NECNP does not know.
G-8.- ANSWER: NECNP does not know.
G-9. ANSWER: NECNP does not know.
Specific Interrogatories I-1 through XII-8. These interrogatories seek information regarding NECNP's position on the contentions filed by parties other than NECNP. At this time, NECNP does not intend to litigate the contentions of any of the other parties. If NECNP should change that position for any of the other parties' contentions, we will respond promptly to the relevant interrogatories.
XIII-1. Does NECNP intend to litigate Contention NECNP RERP-2 ( Federal Assistance) ? )
ANSWER: Yes.
XIII-2. Please list each and every respect in which NECNP contends that New Hampshire intends to rely upon federal assistance for which there is no description contained in the NHRERP. Please describe each and every basis upon which NECNP relies for its assertion that New Hampshire intends to rely upon federal assistance in such respect.
ANSWER: NECNP is unable to identify each and eveggrespect in which New Hampshire intends to rely on 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
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assistance. The RERP lists " anticipated" needs for federal assistance in the areas of Coast Guard support, FAA support, and shellfish contamination screening. S 1.4.5. The RERP also vaguely states that the State will seek technical support that includes " technical advice and radiological monitoring" (S 1.4.2), 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 (S 1.4.2) 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.
XIII-3. Please identify each respect in which NECNP contends that New Hampshire intends to rely upon federal assistance for which NECNP contends the materials contained in the NHRERP are inadequate to comply with the applicable regulations. For each such respect, describe each and every addition to, deletion from or modification of the NHRERP that NECNP contends is required in order to bring the NHRERP
- j. into compliance.
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4-ANSWER: See answer to Interrogatory XIII-2.
XIII-4. If the State of New Hampshire obtains a letter of agreement from the U.S. Coast Guard indicating the Coast Guard's agreement to regulate boat traffic within the plume exposure EPZ , would that letter eliminate the concern of NECNP regarding contention NECNP RERP-2?
ANSWER: No.
XIII-5. If the answer to the preceding interrogatory is no, identify additional letters which are required. In this e n ume ra t ion, relate the need for any such letter to the New Hampshire RERP and, in particular, to resources identified in the RERP which are inadequate and require backup from a Federal agency.
ANSWER: As discussed in response to Interrogatory XIII-2, the State must specifically identify all areas in which it requires federal assistance and obtain letters of agreement from those agencies.
XIII-6. Does NECNP intend to offer the testimony of any expert witness with respect to this contention?
ANSWER: At this time, NECNP has not determined whether it will offer expert testimony on this contention. If and when NECNP arranges for the testimony of an expert witness, we will i
supplement our answer to this interrogatory.
XIV-1. Does NECNP intend to litigate Contention NECNP RERP-3(d) (French Speaking)?
ANSWER: Yes.
XIV-2. Has NECNP conducted any study or survey to determine the number of French-speaking people (who do not speak or understand English) who may be in the plume exposure EPZ?
If so, provide a copy of the study or survey, or in the i absence of a report, describe the study or survey and its i conclusions.
ANSWER: NECNP has interviewed Beverly Hollingworth, owner
, of the Hollingworth Motor Inn in Hampton, New Hampshire; and 4
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Glenn French, Chairman of the Hampton Beach Chamber of Commerce, who informed NECNP that the number of French Canadians visiting the Hampton Beach are during the summer is significant.-
XIV-3. Is NECNP aware of any studies or surveys conducted by others which provide estimates of the number of French-speaking people (who do not speak or understand English) who may be in the plume exposure EPZ? Provide copies of any such studies or surveys or, in the absence of reports, describe the study (ies) or survey (s) and its ( their) conclusions.
ANSWER: No.
XIV-4. On what other data does NECNP rely for its assertion that "a significant propor tion of summer tourists in the Seabrook area are French-speaking Canadians. . ."? Please quantify what NECNP contends is "a significant proportion."
ANSWER: None. NECNP has not attempted to quantify the number of French. Canadian tourists who visit the Seabrook area.
XIV-5. Of the French-speaking Canadians who may be in the Seabrook area, provide an estimate of the fraction which understands English and provide all bases on which NECNP relies for the estimate.
ANSWER: NECNP has not made such an estimate.
XIV-6. Does NECNP intend to offer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XV-1. Does NECNP intend to litigate Contention NECNP RERP-8 (Shelters)?)
ANSWER: Yes.
XV-2. Has NECNP reviewed Appendix F to the NHCDA procedures, " Protective Action Decision Cr iteria?"
AliSWER: Yes.
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- 6-XV-3. If the State relied on a whole body shielding factor of 0.9 in its evaluation of sheltering effectiveness, would NECNP acknowledge that use of such a factor conservatively characterizes the nature of the structures in the Seabrook Station plume exposure EPZ? Explain the basis for the response.
ANSWER: NECNP does not know.
XV-4. Does NECNP intend to offer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to In terrogatory XIII-6.
XVI-1. Does NECNP intend to litigate Contention NECNP RERP-10(a) (Monitoring: Staffing)?
ANSWER: Yes.
XVI-2. liow many monitoring teams does NECNP conteno is necessary to determine ground level radiation in the EPZ?
Explain the basis for the response.
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. RERP 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.
7-This response is based on Section 2.5 of the New !!ampshire RERP and NUREG-0654, S II.I.7-9 and 11.
XVI-3. If NECNP has no basis for estimating the number of monitoring teams required (see question XVI-2), how is it concluded that three teams are " woefully i nadequ a te? "
ANSWER: See answer to Interrogatory XVI-2.
XVI-4. lias NECNP considered in its evaluation that teams from Seabrook Station would be available to conduct offsite monitoring? If not, why not?
ANSWER: No. NECNP is aware of no such provision in the State RERP.
XVI-5. Does consideration of the availability of monitoring teams from Seabrook Station influence the judgement of NECNP about adequacy of monitoring capability? If so, in what way? If not, why not?
ANSWER: No. The potential ad hoc availability of monitoring teams from Seabrook Station does not provide adequate assurance that the need for additional monitoring capacity will actually be met.
XVI-6. Does NECNP contend that monitoring to determine potential ingestion exposure is required to be conducted on the same time scale as monitoring for the purpose of determining exposure from airborne radioactivity? Explain the reasons for the response.
ANSWER: No. Measurements of airborne radioactivity should be made as rapidly as possible for use in decisions regarding protective actions. Although it should be accomplished as quickly as possible, monitoring for potential ingestion exposure is not as urgent because the State can interdict consumption or sale of food and water until it obtains the results of the tests.
XVI-7. Does NECNP contend that, with respect to monitoring to determine potential ingestion exposure, the NHRERP is inadequate (either " woe f ully" or otherwise) ?
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ANSWER: Yes.
XVI-8. Does NECNP intend to offer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XVII-1. Does NECNP intend to litigate Contention NECNP RERP-10(b) (Monitoring: Locations)? (If the answer to this I'
interrogatory is an unqualified negative, you may proceed to Interrogatory XVIII-1.)
4 ANSWER: Yes.
1 j XVII-2. Would NECNP agree that a technique other than predesignateo monitoring locations could result in adequate monitoring of the EPZ? If not, why not?
1 ANSWER: Yes.
XVII-3. Does NECNP intend to offer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XVIII-1. Does NECNP intend to litigate Contention NECNP RERP-10(d) (Monitoring: Response Times)?
, ANSWER: Yes.
. XVIII-2. With respect to monitoring to determine potential i plume exposure, what does NECNP consider to be the minimum acceptable time to deploy monitoring teams from theftime a decision is made to do so? Provide a basis for your j response.
1 1 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 i
through liquid or gaseous release pathways." NUREG-0654, S II.I.8.
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XVIII-3. With respect to monitoring to determine potential plume exposure, what ooes NECNP understand to be the purpose of monitoring?
ANSWER: The Statc's apparent purpose is to determine the impact area of the plume and changes in backg round radiation.
See RERP, Table 2.5-4. The measurements will also be used to verify dispersion calculations, supplement utility monitoring activities, and determine the location and nature of plume impacts. RERP at 2.5-3.
XVIII-4. With respect to monitoring to determine potential plume exposure, is it possible to reach rational decisions on protective actions without data from field monitoring?
If not, why not?
ANSWER: Yes, to a limited extent. However, there are some circumstances in which rational decisions could not be made without data from field moni*oring. Fo r instance in accidents involving rapid releases, in which people have been ordered to shelter, the State must rapidly determine the areas that have been heavily contaminated so that the people sheltering there can be quickly relocated. In addition, any decisions that are not based in part on field data must be made conservatively.
XVIII-5. With respect to monitoring to determine potential plume exposure, in determining the deployment time of monitoring personnel, did NECNP consider the availability of monitoring teams constituted f rom personnel at Seabrook Station? If not, why not?
ANSWER: See answer to In ter rogatories XVI-4 andXVI-5.
XVIII-6. With respect to monitoring to determine potention (sic) ingestion exposure, what does NECNP consider to be the minimum acceptable time to deploy monitoring teams from the time a decision is made to do so? Provide a basis for your response.
ANSWER: See answer to Interrogatory XVIII-2.
XVIII-7. With respect to monitoring to determine potention (sic) ingestion exposure, what does NECNP understand to be the purpose of monitoring?
ANSWER: NECNP understands the purpose of field monitoring to be the determination of the levels of individual radioactive isotopes deposited by the Plume. RERP a t 2.5-1 -- 2.5-2.
XVIII-8. With respect to monitoring to determine potention (sic) ingestion exposure, is it possible to reach rational decisions on protect' s actions without data from field monitoring? If not, s ar/ not?
ANSWER: NECNP does not know the answer to this question.
XVIII-9. With respect to monitoring to determine potention ingestion exposure, in determining the deployment time of monitoring personnel, did NECNP consider the availability of monitoring teams constituted f rom personnel at Seabrook Station? If not, why not?
ANSWER: See Answer to Interrogatories XVI-4 and XVI-5.
XVIII-10. Does NECNP intend to of fer the' testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XIX-1. Does NECNP intend to litigate Contention NECNP RERP-12 (KI)?)
ANSWER: Yes.
XIX-2. Define what is meant by " institutionalized persons" in this contention.
ANSWER: NECNP considers that institutionalzed persons include any individuals in public or private institutions such as hospitals, nursing homes, schools, jails, and other facilities, who may not be evacuated with the general public during a radiological emergency at Seabrook.
XIX-3. Does NECNP intend to of fer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XX-1. Does NECNP intend to litigate Contention NECNP NilLP-2(a) (Police Personnel)?)
ANSWER: Yes.
XX-2. Does NECNP have evidence of instances where police in any of the EPZ towns have been unable to fulfill their assigned responsibilities due to lack of personnel? Provide the details of each incident.
ANSWER: No.
XX-4. Of what relevance is the 1980 evacuation analysis by Alan M. Voorhees and Associates since it precedes the existence of the local emergency plans?
ANSWER: It is unlikely that the number of personnel and resources in the police departments in the Seabrook EPZ have grown appreciably since the Voorhees Report was prepared.
Therefore NECNP considers the Voorhees Report's description of the perceptions of police officials regarding their capability to respond to an accident at the Seabrook plant to remain relevant to this contention.
XX-5. Separately for each of the police departments in the Towns of Greenland, New Castle, Newfields, Rye, Hampton Falls, South Hampton, Kensington, Stratham, East Kingston, Brentwood, Kingston and Exeter please state: (i) does NECNP contend that the department is unable to perform the duties specified in their respective emergency response plans and (ii) each and every reason why NECNP so contends.
ANSWER: Brentwood: The town of Brentwood has 10 part-time police officers and one police cruiser. Br entwood RERP a t C-1.
. The police department is responsible for providing. traffic control and security, as well as a backup means of public alerting. . Police officers must monitor key intersections in town and report congestion to the EOC. RERP a t IV-3 6. They must review evacuation routes along with available personnel and
-resources. RERP a t 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.
Exeter: The town of Exeter has 22 of ficers and seven vehicles.
The police department's responsibilities include ensuring the completion of emergency notification; staf fing the EOC; maintaining security at the EOC; activating the public alert
system; 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 a re 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. RERP a t IV IV-4 2. The plan thus requires more than three people to be in different places at the same time.
Hampton Falls: The town of Hampton Falls has one f ull-time officer and three part-time officers, and is equipped with one police cruiser. RERP a t IV-3 5. 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 of ficer for EOC security. RERP
a t 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 of ficers or vehicles to support all of these functions.
Kensington: The town of Kensington has six part-time police officers and one police cruiser. The police department's duties include staf fing 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
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. equipment impoundment area. On its face, the plan requires more than ten individuals with one vehicle to carry out all of these responsibilities.
Newfields: The town of Newfields has five police of ficers 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.
Rye: Rye has between 25 and 28 police officers and two cruisers.
NECHP has not yet evaluated the -adequacy of the Rye police department's staf fing to perform the responsibilities assigned to it by the Rye RERP. 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 Stratham has four police of ficers and one cruiser to staf f 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 4
cruiser to carry out a list of responsibilities 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.
XX-6. For each of the towns listed in the foregoing
, interrogatory, state the number of police officers that j'
NECNP contends is necessary for the police department to carry out the functions assigned to it under the New Hampshire emergency plans.
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 i
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 Applicants' and the State's burden to demonstrate that adequate staffing
- exists.
XX-7. Does NECNP intend to of f er the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XXI-1. Does NECNP intend to litigate Contention NECNP NHLP-2(d) (Response of Private Support Organizations)?
ANSWER: Yes.
i XXI-2. Has NECNP contacted or had communication with any of the organizations referred to in this contention? If so,
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please list each such contact, and for each such contact please state: (i) the date of the contact, ( i i) the identity of the person contacted, (iii) whether the communication was oral or in writing, (iv) if in writing, please identify the writing, (v) if oral, please identify all parties to the communication and provide in as much detail as NECNP possesses what was said by each.
ANSWER: Yes. On or about February 20, 1986, Rhonda Kranz, a paralegal with the firm of Harmon & Weiss, coversed by telephone with Dave Lavoie of Dave's Garage, 3 21 Ocean Boulevard, Hampton, New flampshire; Dan Ploth of Lymon's Auto, 700 La f ayette Street, Hamp ton, New Hampshire; a unidentified individual at the Hampton 6 6 towing company in Hampton, New Hampshire; Fr and DeFreeze, of Frank's Garage, 747 Laf ayette Street, Hamp ton , New Hampshire; and an unidentified individual at Hampton Tire in Hampton, New Hampshire.
Mr. Lavoie stated that he was never told that his company was listed in the llampton RERP; that he did not believe that his employees would stay to assist in an emergency; that if the preparers of the plan had asked him he would have said so; that he has four wreckers that would be available, but that his employees would not drive them; that it doesn't matter how many wreckers one has, because in an evacuation wreckers would be blocked by stalled traf fic; and that during the summer, it can take up to two hours to go one mile in the Hampton Beach area.
Mr. Ploth stated that he did not know his company was listed in the plan; that it had never been discussed with him or any of his employees; that his company has one wrecker; that there is only one official wrecker driver; and that the nwnber of wreckers available would not make any difference- in an evacuation.
. The person at Hampton 66 said .that company has no wrecker and that it gets towing services from another company.
Mr. DeFreeze said that he was called about his company's inclusion in the Hampton RERP; that he has two wreckers which he thinks he ccald find people to drive; and that he can be reached during the night in an emergency.
The person at Hampton Tire said there is one person who runs the towing operation; that person also works for-the police department; the company has one wrecker; and that he did not know whether the company had been contacted regarding its inclusion in the plan.
XXI-3. Does NECNP contend that any of the bus companies referred to in the New Hampshire plans were unaware of their being included therein? If so, identify each bus company as to which NECNP so contends and provide the basis (including all information required above regarding communications) upon which NECNP relies for its contention.
ANSWER: NECNP does not know whether any of the bus companies were unaware of their being included in the New Hampshire plans.
XXI-4 Does NECNP contend that any towing company referred to in the New Hampshire plans does not have its own vehicle?
If so, identify the towing company as to which NECNP so contends and provide the basis (including all information required above regarding communications) upon which NECNP relies for its contention.
ANSWER: See answer to Interrogatory XXI-2.
XXI-5. Does NECNP intend to of fer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XXII-1. Does NECNP intend to litigate Contention NECNP NHLP-2(g) (Fi re Department Personnel) ?
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. ANSWER: Yes.
XXII-2. Identify all instances known to NECNP in which fire department personnel in the town of Kingston, Greenland, New Castle, Newfields, Stratham, East Kingston, Br e n two od, Hampton Falls, Seabrook, Rye, Kensington or Hampton were not reachable in the event of a fire or other emergency.
ANSWER: NECNP does not know of any past instances.
X X I I- 6. Of what relevance to this Contention is the Voorhees Report which predates the Town RERPs by several years?
ANSWER: See answer to Interrogatory XX-4.
XXII-7. Does NECNP intend to of fer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XXIII-1. Does NECNP intend to litigate Contention NECNP NHLP-2(h) (Other Local Personnel)?
ANSWER: Yes.
- XXIII-2. Separately for each of the towns in the Seabrook EPZ, please list each and every telephone owned or operated by the town or any department or agency thereof, or which is capable of being answered at any location at which town business is conducted (including any private homes for which town business is ever transacted or at which meetings of town officials are ever conducted), and for each such telephone states (i) the telephone number, (ii) the location of each extension from which that number is capable of being accessed, (iii) the person who is recorded as the subscriber in respect of the number, and (iv) the occasions or purposes for which such telephone is used.
ANSWER: NECNP does not possess the information requested by this interrogatory.
XXIII-3. Separately for each of the towns in the Seabrook EPZ, please provide the make, model, frequency (ies) (both transmit and receive), rated power, control or console location, and antenna location of each radio transceiver, radio repeater, radio monitor, radio scanner and radio paging device owned or operated by town or any official or department thereof.
- ANSWER: See answer to Interrogatory XXIII-2.
XXIII-4. Does NECNP contend that any portion of the Seabrook EPZ has weak or inadequate coverage via the initial notification paging system? If so, then for each such area, please identify the area either by supplying a map with the area depicted or outlined or by supplying sufficient geographic data as to permit the area to be located on a topographic map. In addition, for each area, please describe the engineering theories and rational or survey method (s) utilized by NECNP, or by any other person or organization on which NECNP relies, to identify the asserted area of poor coverage. Please also identify by name, address and telephone number any person of whom NECNP is aware who claims to have knowledge of such asserted poor coverage.
ANSWER: At this time, NECNP does not know whether any' portion of the Seabrook EPZ has weak or inadequate coverage via the initial notification paging system. We note, however, that as discussed in the basis for Contention NHLP 2(h), the Voorhees Report states that local officials have questioned the ef fectiveness of pagers (at 10); and that some officials may be outside of the EPZ during an emergency.
XXIII-5. Has the South Hampton Board of Selectmen taken action to appoint a Civil Defense Director who is more likely to be readily available? If not, why not?
ANSWER: NECNP does not know.
XXIII-6. If the South Hampton Board of Selectmen have not yet taken steps such as the example cited in the preceding interrogatory, does NECNP know of any reason why such action could not be taken in the reasonably near future?
ANSWER: No.
XXIII-7. Would it be possible to identify and train one or more alternates for the position of CDD in Kensington to provide greater assurance that someone will be available to fill that position in an emergency? If not, why not?
ANSWER: Yes.
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. XXIII-8. In the event of an emergency in the Town of Kensington, would it be possible for any single selectman to direct emergency operations? Identify by name any selectman who NECNP contends is incapable of managing the emergency situation.
ANSWER: NECNP does not know.
XXIII-9. Does NECNP intend to offer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XXIV-1. Does NECNP intend to litigate Contention NECNP NHLP-2(i) (Backup Personnel) ?
ANSWER: Yes.
XXIV-2. Does NECNP intend to of fer the testimony of any expert witnass with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XXV-1. Does NECNP intend to litigate Contention NECNP NHLP-2(j) (Designations)?
ANSWER: Yes.
XXV-2. Does NECNP intend to of fer the testimony of any expert witness with respect to this contention?
ANSWER: No.
XXVI-1. Does NECNP intend to litigate Contention NECNP NHLP-3(a) (Response Organization Notification) ?
ANSWER: Yes.
XXVI-2. With regard to notification by Rockingham County
- Dispatch during off-duty hours of the Fire or Police Dispatcher on duty or on call in the Towns of Brentwood, East Kingston, New Ca s tle, Newton and Newfields
- (i) provide all data known to NECNP regarding any instance known to NECNP where the individual on duty or on call could not be contacted (ii) provide all data known to NECNP regarding any instances when a responsible official has not been available in an emergency (e.g., fire or police action).
ANSWER: NECNP does not have any such data.
XXVI-3. Has South Hampton made any recommendations to improve the reliability of notification? If not, why not?
ANSWER: NECNP does not know of any.
XXVI-4. Has Kensington made any recommendations to improve the reliability of notification? If not, why not?
ANSWER: NECNP does not know of any.
XXVI-5. List those towns which NECNP contends have no pagers. If pagers were provided to those towns, would the towns accept them and use them during an emergency?
ANSWER: According to Part J of Appendix C of the local emergency plans, the following towns have no pagers: Kingston, Stratham, Greenland, East Kingston, Exeter, Hampton Falls, South Hampton, New fields, Nor th Hamp ton, and Brentwood. NECNP does not know whether the towns would accept pagers if offered them.
XXVI-6. Please identify by name, residence and business '
address and residence and business telephone nwnber of each individual whom NECNP contends: (A) is a person to whom notification is to be given under any plan, and (B) who lives or resides outside of the broadcast range of all oft (i) the Rockingnam County Dispatch Center radio system, (ii) '
the Seacoast region fire network radio system, (iii) the City of Portsmouth police radio system, (iv) the New Hampshire State Police High-Band radio system, (v) the New i Hampshire Civil Defense radio systems, and (vi) the radio
- paging systems of the commercial radio common carriers operating in the states of New Hampshire, Maine and/or Massachusetts.
ANSWER: NECNP does not know.
XXVI-7. Has NECNP conducted any study or experiment for the purpose of determining the range at which broadcasts j transmitted by the Rockingham County Dispatch Center are
, capable of being received? Has NECNP conducted a study for i the purpose of determining the range at which the broadcasts of any radio system are capable of being received? If so, ,
please describe the study or experiment and identify any document in which the study or experiment or the results thereof is described or referred to. ,
e
- ANSWER: No.
XXVI-8. Is NECNP aware of any study of the type described in the foregoing interrogatory performed by any person? If so, please supply the same information.
ANSWER: No.
XXVI-9. Please identify each and every case in which NECNP contends that come.ercial telephone lines are intended to function as the primary communications link in the local plan for any town in the Seabrook EPZ. Fo r each such . case, please explain in. detail why NECNP contends that commercial telephone lines are the primary link.
ANSWER: NECNP asserts that each New Hampshire town in the Seabrook EPZ -relies to some extent on commercial telephone as a primary communication link. The-basis for this assertion is the statement in Section II.C of each plan that: "Often the commercial telephone system is the primary communications link and the radio system serves as a backup." The plans do not identify which particular communication links are principally made by commercial telephone. However, Figures 7 and 8 of che plans show that in some cases, commercial telephone is the only link in some aspects of a town's internal and/or external communication schemes. See, e.g., plans for Kingston, Seabrook, Hampton, Portsmouth, North Hampton, Newfields, South Hampton, Hampton Falls, Exeter, East Kingston, Greenland, Rye, Kensington, and Newton.
XXVI-10. Please describe in detail each and every instance in which NECNP contends that telephone service in any of the Seabrook EPZ towns was interrupted, cutoff, overloaded or performed in some manner other than normal during the last five years.
24 -
ANSWER: NECNP does not know of any past instances.
XXVI-11. Separately for each instance described in response to the foregoing interrogatory please state whether NECNP contends that the instance resulted in the implementation of "line load control, " and for each such instance state: (i) the starting and ending time of "line load control, " (ii) each central of fice that NECNP contends was af fected by "line load control," and (iii) any effect that NECNP contends that the implementation of "line load control" had upon emergency or law enforcement communications or response. Please also identify any and all documents of which NECNP is aware that describe, evaluate or refer to any instance of the implementation of "line load control" and identify each and every source of data or information relied upon by NECNP with respect to this topic.
ANSWER: See answer to Interrogatory XXVI-10.
XXVI-12. Does NECNP contend that there has occurred any instance in the last five years in which a law enforcement person or agency has been unable to communicate with the Rockingham Dispatch Center because of the failure of established modes of communication therewith? ...
ANSWER: No.
XXVI-13. Does NECNP contend that a loss of AC-power in the Seabrook EPZ would affect the functioning of the commercial telephone system in any respect? If so, then for each such respect please stater (a) the central office (s) that NECNP contends would be affected, (b) whether, and if so how, NECNP contends the effect would affect residential customers, (c) whether, and if so how, NECNP contends the effect would affect commercial or industrial customers, and (d) whether, and if so how, NECNP contends the effect would affect public safety agencies or personnel.
ANSWER: NECNP does not know.
XXVI-14. Does NECNP contend that a loss of AC-power in the Seabrook EPZ would affect the functioning of any law-enforcement or public safety radio system in any respect?
If so, then separately for each such respect stater (a) the agency (ies) that NECNP contends would be af fects, (b) the manner in which NECNP contends the system would be af fected, and (c), if NECNP contends that the agency lacks the means to respond to any such effect promptly and without significant interruption of communication capability, each and overy reason why NECNP contends the agency lacks such means.
. ~ -
O ANSWER: NECNP does not know.
XXVI-15. Has NECNP undertaken any study or other effort to update or to determine the continuing validity of the Voorhees Report, which predates the publication of the local emergency plans by several years? Is NECNP aware of any such study or effort undertaken by any other person? If so in either case, please (a) describe the study or effort, (b) identify the person (s) by whom it was performed, (c) identify any source of information regarding the study or ef fort upon which NECNP relies, and (d) identify each and every document known to NECNP that describes, analyzes, or refers to the study or effort or the results thereof.
ANSWER: No.
XXVI-16. Does NECNP intend to of fer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XXVII-1. Does NECNP intend to litigate Contention NECNP NHLP-4(e) (Special Needs)?
ANSWER: Yes.
XXVII-2. Characterize people who NECNP contends have special notification needs.
ANSWER: People with special notification needs are those who, by virtue of circumstances, location, or physical condition, could not receive initial notification and instruction by the audible alerting system described in section II.C. of the RERPs for the New Hampshire towns.
XXVII-3 Does NECNP know if notification systems, equipment or procedures have been planned or implemented at any other nuclear plant site for individuals with special notification needs? If so, describe all such systems, equipment or procedures known to NECNP.
ANSWER: No.
XXVII-4. For each system described in response to the foregoing interrogatory state whether NECNP would regard the same system adequate if employed in the Seabrook EPZ and, if not, why not.
26 -
ANSWER: See answer to Interrogatory XXVII-3. J XXVII-5. Does NECNP intend to offer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6.
XXVIII-1. Does NECNP intend to litigate Contention NECNP NHLP-6 (Special Needs Population)?
ANSWER: Yes.
XXVIII-2. Provide all data which NECNP contends supports the proposition that "the telephone system in the EOC may be overloaded." In particular, indicate whether this assertion is supported by experience in any of the towns with the EPZ .
If so, provide the details of each occurrence.
ANSWER: This assertion is based on the examples given in the basis for the contention. In addition, NECNP consulted a representative of the Chesapeake and Potomac Telephone Company, who stated that if central commercial telephone circuits become overloaded, calls cannot be put through even though the receiver of the call is not using his or her telephone.
XXVIII-4. If the answer to the preccGing interrogatory is yes, explain any shortcomings that NECNP contends exist in "orchestrat[ing] the evacuation of people with special needs."
ANSWER: See the basis for Contention NHLP-6.
XXVIII-5. Provide estimates of the number of tourists who are bussed to the beaches for summer day trips. Explain the bases and identify all documentation for these estimates.
ANSWER: NECNP has not made any numerical estimates.
XXVIII-6. Does NECNP intend to of fer the testimony of any expert witness with respect to this contention?
ANSWER: See answer to Interrogatory XIII-6'.
1
- I I a f firm that the foregoing answers are true to the best of my knowledge and belief. I also submit any objections to these interrogatories.
Diane Curran HARMON & WEISS 2001 S Street, N. W.
l Suite 4 30 Washington, D. C. 20009 (202) 328-3500 May 20, 1986
_, _ . _ _ - .- _ - _= _ - _ - .
. ,?
/'
. CERTIFICATE OF SERVICE I certify that on May 20, 1986, cppies of "New England Coalition on Nuclear Pollution's Response to Applicants' Interrogatories and Request for the Production of Documents" and "NECNP's Mo tion f or Leave to File Answers to Interrogatories Out of Time" were served on the following by first-class mail or as otherwise indicated:
- Helen Hoyt, Esq. Rep. Roberta C. Pevear Admi n,is tcative, Judge Drinkwater Road Atomic Safety and Licensing Board Hampton Falls, NH 03844 U. S . Nuclear Regulatory Commission Washington, D. C . 20555
- Dr. Emmeth A. Luebke Phillip Ah rens, Esq.
Administrative Judge .
a Assistant Attorney Atomic Safety and Licensing Board '
General U.S. Nuclear Regulatory Commission State House, Station #6 Augusta, ME 04333 Washington, D.C. 20555
- Dr. Jerry Harbour Rober t A. Backus, Esq.
Administrative Judge 111 Lowell Street Atomic Safety and Licenning Manchester, NH 03105 Board U.S. Nuclear Regulatory Commission ** Thomas G. Dignan, Esq.
Washington, D. C . 20555 R.K. Gad, III, Esq.
Ropes and Gray Atomic Safety and Licensing :225 Franklin Street Board Panel Boston, MA 02110 U.S. Nuclear Regulatory Commission Washington, D. C . 20555 Atomic Safety and Licensing Appeal Board Panel Mrs. Anne E. Goodman U.S. Nuclear Regulatory Board of Selectmen Commission 13-15 New Ma rket Rd. Washington, D. C . 20555 Durham, NH 03824 s Docketing and Service *Sherwin E. Turk, Esq.
U.S. Nuclear Regulatory Of fice of the Executive Commission -
Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission William S. Lord, Selectman Wa s h'ington, D.C. 20555 Town Hall - Friend Street Amesbury, MA 01913 Mr. Angie Machiros, Chairman Board of Selectmen Jane Doughty . Newbury, MA 01950 SAPL '
5 Market St.
Portsmouth, NH 03801 O
e b
, ._ - . , - , _ _ - 4 - , - __ ..
i Carol S . Sneider, Esquire *H. Joseph Flynn, Esq.
Assistant Attorney Of fice of General Counsel General Federal Emergency Department of the Attorney Management Agency General 500 C Street, SW l Ashburton Place, 19th Floor Washington, D. C . 20472 Boston, MA 02108
- George Dana Bisbee, Esq.
Edward A. Thomas Stephen E. Merrill, Esq.
FEMA Assistant Attorneys General 442 J.W. McCormack (POCH) State flouse Annex Boston, MA 02109 Concord, Nil 03301 J. P. Nadeu, Selectman Allen Lampert Town of Rye Civil Defense Director 155 Washington Road Town of Brentwood Rye, Nil 03870 Exeter, Nil 03833 Sandra Gavutis Richard A. Hampe, Esq.
Town of Kensington Hampe and McNicholas RFD 1 Box 1154 35 Pleasant Street East Kensington, NH 03827 Concord, NI! 03301 Richard E. Sullivan, Mayor Gary W. Holmes, Esquire City IIall Holmes & Ellis Newburyport, MA 01950 47 Winnacunent Rd Hampton, NH 03842 Alfred V. Sargent, Chairman Board of Selectmen William Armstrong Town of Salisbury, MA 01950 Civil Defense Director 10 Front Street Senator Gordon J. Humphrey Exeter, NH 03833 U.S. Senate Washington, D. C . 20510 Calvin A. Canney
( At tn: Tom Burack) City Manager City Hall Selectment of Northampton 126 Daniel Street Town of Northampton Portsmouth, NH 03801 New Hampshire 03862 Senator Gordon J. Humphrey Mathew T. Brock, Esq.
1 Pillsbury Street Shaines & McEachern Concord, NH 03301 P.O. Box 360 Maplewood Ave.
Michael Santosuosso, Chairman Portsmouth, NH 03801 Board of Selectmen Mr. Robert Carrigg, Chairman Jewell St. , RFD #2 Board _of Selectmen South Hampton, NH 03842 Town office Atlantic Avenue North Hampton, NH 03862
- - By Federal Express Diane Curran
o 2-Ca rol S. Sneider, Esquire *H. Joseph Flynn, Esq.
Assistant Attorney Of fice of General Counsel General Federal Emergency Department of the Attorney Management Agency General 500 C Street, SW l Ashburton Place, 19th Floor Washington, D.C. 20472 Boston, MA 02108 ,
- George Dana Bisbee, Esq.
Edward A. Thomas Stephen E. Merrill, Esq.
FEMA Assistant Attorneys General 442 J.W. McCormack (POCH) State House Annex Boston, MA 02109 Concord, NH 03301
, J. P. Nadeu, Selectman Allen Lampert Town of Rye Civil Defense Director 155 Washington Road Town of Brentwood Rye, NH 03870 Exeter, NH 03833 Sandra Gavutis Richard A. Hampe, Esq.
Town of Kensington Hampe and McNicholas RFD 1 Box 1154 35 Pleasant Street East Kensington, NH 03827 Concord, NH 03301 Richard E. Sullivan, Mayor Gary W. Holmes, Es qu ire City Hall Holmes & Ellis Newburyport, MA 01950 47 Winnacunent Rd Hampton, NH 03842 Alfred V. Sargent, Chairman Board of Selectmen William Armstrong Town of Salisbury, MA 01950 Civil Defense Director 10 Front Street Senator Gordon J. Humphrey Exeter, NH 03833 U.S. Senate Washington, D. C . 20510 Calvin A. Canney
( At tn: Tom Burack) City Manager City Hall Selectment of Northampton 126 Daniel Street Town of Northampton Portsmouth, NH 03801 New. Hampshire 03862 Senator Gordon J. Humphrey Mathew T. Brock, Esq.
1 Pillsbury Street Shaines & McEachern Concord, NH 03301 P.O. Box 360 Maplewood Ave.
Michael Santosuosso, Chairman Portsmouth, NH 03801 Board of Selectmen Mr. Robert Carrigg, Chairman Jewell St. , RFD #2 Board _of Selectmen South Hampton, NH 03842 Town office Atlantic Avenue
- - By Messenger
- - By Federal Express .
Diane Curran l