ML20204B506
| ML20204B506 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/18/1987 |
| From: | Chan E NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| Shared Package | |
| ML20204B512 | List: |
| References | |
| CON-#187-2860 OL, NUDOCS 8703250080 | |
| Download: ML20204B506 (14) | |
Text
E- .
28'$8 -
meo coaaeSeOnons March '18, kkC UNITED STATES OF AMERICA .. .
NUCLEAR REGULATORY COMMISSION '87 MAR 23 P3 :12 DEFORE THE ATOMIC SAFETY AND LICENSING BOARD hh[, ' I[
EN/t. i In the Matter of )
) Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF ) 50-444 OL NEW HAMPSHIRE, et al. ) Off-site Emergency Planning
)
(Seabrook Station, Units 1 and 2 )
NRC STAFF'S RESPONSE TO NECNP'S FIRST SET OF INTERROGATORIES AND REQ: JEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF AND THE EXECUTIVR DIRECTOR OF OPERATIONS ON REVISION 2 TO THE NEW HAMPSHIRE RADIOInntCAL EMERGENCY RESPONSE PLAN The NRC Staff (" Staff") hereby responds to "New England Coalition on Nuclear Pollution's First Set of Interrogatories and Requests for the Production of Documents to the Executive Director and the NRC Staff on the New Hampshire Radiological Emergency Response Plans ," filed March 5,1987.
Interrogatories addressed to the Staff are governed by the need-based discovery provisions of 10 C.F.R. A 2.720(h)(2)(ii) --
requiring a formal finding of necessity by the presiding officer II --
1/ 10 C.F.R. I 2.720(h)(2)(li) provides in relevant part:
[A] party may file with the presiding officer written interrogatories to be answered by NRC personnel with knowledge of the facts designated bv the Executive Director for Operations. Upon a finding by the presiding (FOOTNOTE CONTINUED ON NEXT PAGE) 8703250080 070318
{DR ADOCK 05000443 ~\
PDR u)$0)
]
rather than the general discovery provisions of 10 C.F.R. I 2.740. Since most Staff documents related to licensing actions are publicly available under Commission regulations, there is little need for formal discovery against the Staff. See Pennsylvania Power and Light Company (Susquehanna Steam Electric Station, Units 1 and 2), ALAB-613,12 NRC 317, 323 (1980) (discovery against Staff on "different footing" than discovery against other parties; Staff documents publicly available pursuant to 10 C.F.R. I 2.790). Except as specifically objected to herein, the Staff in this case voluntarily responds to the propounded interrogatories, notwithstanding NECNP's failure to seek a required finding by the presiding officer that the answers to the interrogatories are "necessery to a proper decision" and "are not reasonably obtainable from any other source." In so doing, the Staff reserves its rights to require full compliance with the Commission's regulations in future discovery.
INTERROGATO2Y 1 In accordance with 10 C.F.R. I 2.740(e), please supplement your answers to NECNP's First Set of Interrogatories and Requests for the Production of Documents to the NRC Staff on New Hampshire Radiological Emergency Response Plans, filed April 30, 1986 (FOOTNOTE CONTINUED FROM PREVIOUS PAGE) officer that soswers to the interrogatories are necessary to a proper decision in the proceeding and that answers to the interroga-tories are not reasonably obtainable from any other source, the presiding officer may require that the staff answer the interrogatories.
1
ODJECTION The Staff objects to Interrogatory 1 which requests additional discovery on contentions admitted in April 1986. The discovery period for those contentions closed almost a year ago and NECNP should not he permitted to expand the scope of discovery based solely on the
. February 18, 1987 admission of different contentions b INTERROGATORY 2 What is the NRC Staff's position on each of the contentions that has been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan? What is the basis for your position?
RESPONSE
The Staff has not formulated any positions with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan. The admitted contentions relate to offsite emergency planning and preparedness matters which , under a Memorandum of Understanding between the Nuclear Regulatory Commission and the Federal Emergency Management Agency (FEMA), are within the scope of FEMA's review.
Ilowever, the Staff intends to retain a consultant to review and respond to the admitted contentions concerning evacuation time estimates ("ETE").
The Staff does not possess any information, nor has the Staff developed a position concerning the adequacy of the New Hampshire Radiological Emer-gency Response Plan within the scope of the admitted contentions, which a
2/
~
Insofar as the Staff objects to the instant interrogatories, the Staff hereby requests that the Licensing Board issue a protective order pursuant to 10 C.F.R. I 2.740(c) precluding further discovery with respect to these matters.
is different from the position and/or the information in FEMA's possession.
INTERROGATORY 3 Please identify all documents on which you rely or intend to rely cluring this proceeding to support your position on each of the conten-tions that has been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan. This includes but is not limited to all documents used in answers to these 1 interrogatories, summary disposition testimony, and cross-examination of witnesses during hearings.
For any such documents that are not available to the public pursuant to 10 C.F.R . I 2.790, NECNP requests that the EDO produce those documents at the offices of Harmon & Weiss on or before March 19, 1987.
RESPONSE
See Response to Interrogatory 2.
INTERROGATORY 4 Please identify all documents not identified in response to the previous interrogatory which analyze or evaluate in any way the adequacy cf the New Ilampshire RERP or New Hampshire's state of preparedness in the event of a radiological emergency. In so doing, plesse state whether these documents are available to the public pursuant to 10 C.F.R.
f 2.790.
For any such documents that are not available to the public pursuant i to 10 C.F.R R 2.790, NECNP requests that the EDO produce those documents at the office of Harmon & Weiss or or before March 19, 1987.
i RESPONSE See Response to Interroratory 2.
t INTERROGATORY 5 l
Please identify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to rely for your position on each of l the contentions that has been admitted in this proceeding with respect to l Revision 2 of the New Hampshire Radiological Response Plan.
l l
l L
I'
RESPONSE
The Staff intends to retain and rely on the factual knowledge, opinions or technical expertise of a consultant, Dr. Thomas Urbanik, II, for the review and respond to the admitted contentions concerning evacuation time estimates ("ETE"). A copy of Dr. Urbanik's Curriculum Vitae is attached to this response.
INTERROGATORY 6 Please identify all persons you may call as witnesses on each of the contentions that have been admitted in. this proceeding with respect to Revision 2 of the New Ilampshire Radiological Emergency Redponse Plan.
Please describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.
RESPONSE
The Staff intends to call Dr. Thomas Urbanik on the contentions relating to ETE's. Since the Staff has not formulated any position with respect to the admitted contentions, the Staff is not in a position to describe the substance of his testimony nor to identify or describe any documents upon which he may rely for this testimony.
Respectfully submitted.
. v_
Elaine 1. Chan Counsel for NRC Staff Dated at Bethesda, Maryland this 18th day of March,1987
- 7. -
i CURRICULUM VITAE URBANIK I-I, Thomas P.E., Ph.D. UFFICE PHONE: 409/845-1535 HOMEADDiiESS: 12. Post Oak Bend Rd. HOME PHONE: 409/690-6795 College Station, Texas 77840 Birthdate: February 15, 1946 Citizenship: U.S. -
S.S. No.: 079-36-0185 Marital Status: Married, 2 Sons PROFESSIONAL INTERESTS: Traffic Engineering Transportation Planning Evacuation Planning Highway Design / Safety Public Transportation EDUCATION:
l Ph.D., Civil Engineering, Texas A&M University,1982 l M.S., Transportation Engineering, Purdue University,1971
- B.S., Civil Engineering, Syracuse University, 1969
, B.S., Forest Engineering New York State College of Environmental Science and Forestry,1968 i
I PROFESSIONAL LICENSES:
1 Registered Professional Engineer, Michigan No. 22008 Registered Professional Engineer, Texas No. 42384 EXPERIENCE:
1982-1986 Lecturer -
Depar.tment of Civil Engineering Civil Systems Group l Texas A&tt University l College Station, Texas 77843-3136 Undergraduate instruction in transportation engineering and planning, traffic engineering, and highway design.
l Program Manager - Transport Operations l ,
Texas Transportation Institute Texas A&M University l College Station, Texas 77843-3135 l
l Duties and responsibilities are to provide specific direction to progran in its conduct of transportation research projects for fed-eral, state, and local transportation agencies, l
l l
F The range of transportation projects include: traffic engineering,
! transportation planning, highway safety, public transportation, and
. transportation systems management.
?Nanagemen't responsibilities are to identify and pursue research opportunities, locate and recommend staff, monitor research activities to meet budget and project objectives, develop overall program funding, provide an annual staff review (15 personnel),
supervise preparation of proposals, develop writing and communica
- tion skills of the program staff, review and allocate work, coor-dinate equipment and staffing needs, recommend and approve perti-nent expenditures for annual budget of approximately $600,000.
1976-1982 Assistant Research Engineer conducted research, prepared proposals, and provided project super-vision on research activities. Responsible for final report preparation and presentation. Research areas included traffic l engineering, transportation planning, public transportation and l evaluation planning.
1972-1976 l
Traffic Engineer City of Ann Arbor Department of Streets, Traffic and Parking Ann Arbor,- Michigan Responsible to Director of Streets Traffic and Parking, Ann Arbor, Michigan. Responsible supervisory and professional traffic engi-neering work in directing the traffic engineering function of the department. Work involved responsibility for the application of professional engineering skill and knowledge to difficult traffic engineering problems in traffic regulation and control, street use.
street lighting, geometrics, parking, school safety, curb cuts, and related traffic engineering activities. Was directly responsible fer the supervision of the traffic signal and traffic sign mainte-nance personnel.
1971-1972 Transportation Planning Engineer City of Ann Arbor l . Traffic Engineering and Transportation Department Ann Arbor, Michigan i
Responsible to Director of Traffic Engineering and Transportation,
( Ann Arbor, Michigan. Reviewed transportation aspects of all plans
r o
for development in the city. Staff member to the Ann Arbor Trans- ,
portation Authority responsible for budget and union negotiations. '
Staff Cardinator for the planning, design, implementation, and op-eration of the Dial-A-Ride demand-responsive demonstration project.
i.
1970-1971 <
Research Assistant Joint Highway Research Project
- Purdue University
. West Lafayette Indiana Conducted research concerning high-way related grade crossings.
Designed attitudinal questionnaire concerning public transportation for a home interview survey in Lafayette, Indiana. Also analyzed survey results for inclusion in a report on public transportation in Lafayette, Indiana SOCIETY MEMBERSHIP:
Transportation Research Board Institute of . Transportation Engineers American Society of Civil Engineers American Society for Engineering Education HONOR SOCIETIES Chi Epsilon CURRENT COH;41TTEE MEMBERSHIP Chairman, Institute of Traffic Engineers, Texas Section, Committee on Continuing Education Member. Transportation Research Board, Committee on Intercity Bus Transportation .
PUBLIC SERVICE Member, We11 born Community Center, Board of Directors CONTINUING EDUCATION / PROFESSIONAL DEVELOPMENT Association of oil Pipelines, Educators Tour, July 1984 The University of Michigan, Bureau of Industrial Relations, Graduate School of Business Administration, Principles of Effective Superviscry Management U.S. Department of Transportation Federal Highway Administration, Digit-al Computer-Urban Traffic Control / Bus Priority System (UTCS/ BPS)
Course.
T s
Evacuation Planning Transportation Analysis for on: Evacuati An l'ndependent Assessment of March State-of-the-Art, Evacu ITE Journal tiInstitu Scenario Station, in the Emergency a Planning on Times ZoD.C., 1986. ,
For a Peak Popu 2903, 1982.
with others, U.S. Nuclear ne of Regulatory the Seabrook CoNuclear Powe CLEAR (Calculates Logical Evacuati mmission, NUREG/CR-mates, with otherstation on Network Model for the And Response). Calc l Transpor A Generic -
Analysis of Techniques u ation of Evacuation for Estimati2504
- Times Esti-on, NUREG/CR- October ,
NUREG/CR-1745 Planning Zones, with others 1980 Analysis others of Evau, cation .Times U.S.Around Nuclear 52 Regulatory Com 1980. , U.S. Nuclear Regulatory Commission. Nuclear Power
, Texas Hurricane Evacuation Study, uncil,1978.
The Coas Public Transportation Analysis of Rural Public Transport tiDep 1069-1F, August 1982.
a Intercity Bus Riders in Texas.nsportation TranspoTechnical Report '
The Intercity Bus Industry in rtation the UResea S
0965-1 F, 1981. Department of Highways and Publi. . and Texas,rc Bryan-College Metropolitan Planning c Station Organizatio Transportation.
Energy Technical Reportwi Conti ngenc Dryan-College Station Transit Impropolitan Plan 1980 Ann Arbor1973.
Authority, Dial-A-Ride Project Final Rvement Plan, with others, M Ann Arbor 136, 1973 Dial-A-Ride Operations eport Ann Arbor Transportation The Greater Lafayette Area Bus Transit S. Highway Resea Research Project Purdue University tudy, with others, Joint Highway
, 1971, Elderly and Handicapped Transportation o
Guidelines forDeEvaluation of H with others, State Evaluation Diane of Selected Humanansportation, Ser iReport 106 TransportationBul lard. , Sta te 1980. Departmentv of ces Transportation Providers, with Highways Cost-Effectivenes, of Accessible Fix d R s
and Pub l ic
- Soegard, Technical Report , 1979. 1061-1F e - oute Buses in Te
~
F Michigan Department of civil Service Principles of Public Sector Labor
, Relations.
l CURRENT RESEARCH E
" Cost-Ef fectiveness Analysis for Ranking New Interchanges and Highway Railroad Grade Separations", Texas State Department of Highways and Public Transportation .
l " Automated Transit Ridership Data Collection". Texas State Department of Highways and Public Transportation.
" Computerized Dispatch Aids for Small Public Transportation Providers",
Texas State Department of Highways and Public Transportation.
l " Safety and Operational Evaluation of Shoulders on Urban Freeways,"
l Texas State Papartment of Highways and Public Transportation.
" Traffic Engineering / Transportation Planning Relative to Evacuation-Time l
Estimates", Battelle Pacific Northwest Laboratories.
" Evaluation of Transportation Analysis Techniques used for Estimating l Evacuation Timer at Nuclear Power Plant Sites". Battelle Pacific Northwest Laboratories.
PUBLICATIONS AND PAPERS l
Traffic Engineering Understanding Forced Flow, ITE Journal, Institute of Transportation Engineers, Washington, D.C., October 1986.
l Safety and Operational Evaluation of Shoulders on Urban Freeways, With Carlos R. Bonilla, Texas State Department of Highways and Public Transportation, Research Report Number 395-1. Austin, Texas , August 1986.
The Effectiveness of using Freeway Shoulders for Traffic, With Wes Lum, District 6-District 7 Joint Annual Meeting, Institute of Transportation Engineers Vancouver, B.C., Canada, July 1986.
Ef fects of Shoulder Reductions on Highway Safety With Wes Lum, American Society of Civil Engineers, Specialty Conference on Effectiveness of Highway Safety Improvements, Nashville, Tennessee, March 1986.
Speed / Volume Relationships on Texas Highways, State Department of Highways and Public Transportation, Research Report 327-1F, Austin, Texas, October 1983.
l Priority Treatment of Buses at Traffic Signals. Transportation Engineering November 1977.
l Priority Treatment of High-Occupancy Vehicles on Arterial Streets.
State Department of Highways and Public Transportation, Report 205-5, 1977.
I Evaluation of Alternative Concepts for Priority Use of Urban Freeways in Texas, State Department of Highways and Public Transportation, Report l 205-1, 1977.
Driver Information Systems for Highway-Railway Grade Crossings, with l K.W. Heathington, Highway Research Record Number 414, 1972.
(w Transportation of the Elderly and Handicapped in Texas: A Case Study, s with Jose A. Soegard. State Department of Highways and Pu bl ic Transportation, Technical Report 1056-2F,1979.
Tota.1 Accessibility Versus Equivalent Mobility of the Handicapped.
Institute of Transportation Engineers, Compendium of Technical Papers, 49th Annual Meeting,1979.
Survey of Vehicles and Equipment for Elderly and Handicapped Trans-portation. State Department of Highways and Public Transpor-tation.
Technical Report 1056-1, 1978. ..
Corpus Christi Elderly and Handicapped Transportation Study, with R.W.
Holder, City of Corpus Christi, Texas,1978.
PRESENTATIONS Presentation entitled Shoulder Reductions on Urban Freeway, ASCE Specialty Conference, " Shaping the Future of American Highways", San Diego, CA, April 15-17, 1985. !
Presented seminar on transportation analysis at Emergency Preparedness Plans and Programs Workshop Battelle Pacific Northwest Laboratories.
Williamsburg, VA. :
Presentation on Evacuation. Transportation, and Traffic Control, National Emergency Training Center. Emergency Management Institute Evacuation Planning and Response Actions Simulation Course.
Emmitsburg, Maryland, July 8-12, 1985.
EXTENSION:
Texas Engineering Extension Service, Instructor on various courses including basic traffic engineering, geometric design of highways and highway capacity.
University of California at Berkely, Institute of Transportation Studies, Extension Programs, Guest Lecturer, highway capacity courses presented to California Department of Transportation.
EXPERT WITNESS Presented expert testimony before the Atomic Safety and Licensing Board, U.S. Nuclear Regulatory Commission, concerning evacuation times at several i nuclear power plant sites including Three-Mile Island' Diablo Canyon, Indian l Point Seabrook and Shoreham.
l l
1 - -o.. , -cm _m _ __ - -.#. .
._x_ m .- -__m e
UNITED STATES OF AMERICA NUCLI?AR REGULATORY COMMISSION BEFORE T!!E ATOMIC SAFETY AND LICENSING ROARD in the Matter of )
) Docket Nos. 50-443 OL PilBLIC SERVICE COMPANY M ) 50-444 OL NEW HAMPSIIIDE, g al. ) Off-site Emergency Planning
)
(Seabrook Station, Units 1 and 2 )
AFFIDAVIT OF DONALD J. PERROTTI I, Donald J. Perrotti, being duly sworn, hereby state that I am employed as Emergency Preparedness Specialist, Emergency Preparedness Branch, Division of Emergency Preparedness and Engineering Response, in the Office of Inspection and Enforcement, Nuclear Regulatory Commission. A statement of my professio tal qualifications is attached.
The information reflected in the Staff's responses to interrogatories 1 and 2, contained in the "NRC Stcff's Response to NECMP's First Set of Interrogatories and Requests for the Production of Documents to the NRC Staff and the Executive Director of Operations on Revision 2 to the New Hampshire Radiological Emergency Response Plan" attached hereto, is true and correct to the best of my knowledge, information and belief.
ona d J. Perrotti d
Subscribed and sworn to before me this 18th day of March,1987 j
Notary Public Ply commission expires: 7//fB
'I
p . . 1
. l DONALD J. PERROTTI OFFICE OF INSPECTION AND RNFORCEMENT STATEMENT OF PROFESSIONAL QUALIFICATIONS ,
I am employed as an Emergency Preparedness Specialist in the Emergency Preparedness Branch, Division of Emergency Preparedness and !
Engineering P.esponse, Office of Inspection and Enforcement. U.S. l Nuclear Regulatory Commission. I have responsibility for the review and ,
evaluation of radiological emergency plans submitted by reactor applicants and licensees to assure that proposed plans meet the regulatory requirements and guldence of the Commission. I also function as a Team ;
Leader and Team Member on Emergency Preparedness Appraisal Teams engaged in the onsite inspection of the implementation phase of licensee emergency programs. I observe nuclear power plant emergency drills and exercises involving State and local government response agencies and participate in interagency critiques. I served as the staff's expert witness for onsite emergency planning during the evidentiary hearings for the Waterford 3 and Perry 1 operating licenses and for the Clinch River l Breeder Reactor construction permit.
From December 1976 to October 1980 I was employed at the NRC's ,
Region II Office of Inspection and Enforcement in Atlanta, Ooorgia. I l was the lead inspector for Region !! emergency planning inspections at t nuclear power reactors and fuel facilities. My responsibilities included ,
planning, conducting and documenting inspections of licensees' emergency ;
plans and procedures, emergency facilities and equipment, emergency ;
training, tests and drills, and coordination with offatte support agencies, i From April 1977 to August 1978, I assisted my immediate supervisor who served as Chairman of the Federal Regional Advisory Committee (RAC) in the review of Etate RadioloFical Emergency Plans. During October 1978 I 1
assisted in the review and approval of emergency plans for two nuclear l fuel facilitics. During the period of March - Autrust,1979, I participated f in the Commission's coverage of environmental monitoring programs at 4
- Three Mile Island, where I served as Emergency Monitoring Team Leaderg l l In that capacity, I was responsible for coordination with State and Federal l agencies engaged in measurement and evaluation of environmental
! radioactivity levels in the vicinity of the TMI nuclear plant. ;
i From 1973 to 1976, I was employed at Florida Power and Light Company's Turkey Point Nuclear Power Plant, as Health Physics !
i instructor. My duties included radiation safety training of plant ;
personnel (general employees and technicians), special project reports i
- such as providing background material for management comment on l l proposed changes to the Code of Federal Regulations, and maintaining !
- radiation exposure records for plant personnel. l l
l From 1953 to 1973, I served in the United States Army. As a l l member of the U.S. Army Engineer Reactors Group during the period '
I 1961 - 1973, I performed a variety of jobs with varying degrees of responsibility as rank and erperience were gained. Among my more responsible jobs were shift health physics technician at the PM-3A Naval l
i
7 e
nuclear power plant in McMurdo. Antarctia (1965-1966). Senior Health Physics / Process Chemistry instructor at Ft. Belvoir, Virginia (1966-1972),
and Project Officer for the SM-1 Army nuclear power plant (1972-1973).
I received an Associate of Arts Degree from the New York State Regents, Albany, NY, in 1973. In addition, I attended Army service schools including Special Nuclear Weapor.s Disposal and the 52-week Nuclear Power Plant Operators course. I have completed the following U.S. Public Health Service courses:
Basic Radiological Health Radionuclide Analysis by Garnma Spectroscopy Environmental Radiation Surveillance Analysis of Radionuclides in Water Occupaticnal Radiation Protection Chemical Analysis for Water Quality Statistical Methods -
Quality Control in the Laboratory Operational Aspects of Radiation Surveillance Reactor Hazards Evaluation I attended the " Radiological Emergency Response Operations" course et the Nevada Test Site, the " Planning for Nuclear Energencies" course at liarvard University, and the " Advanced Management Radiation Accidents" course at the University of New Mexico School of Medicine.
I have successfully completed the NRC's Pressurized Water Reactor Technology Bolling Water Reactor Technology Probability Risk Assessment (PRA) Fundamentals, PRA Derspective for Emergency Planning and Response and PRA for Inspection Application courses.
I am and have been a member of the Health Physics Society since 1974.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _