ML20205G035
| ML20205G035 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/24/1988 |
| From: | James Smith, George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | AMESBURY, MA |
| References | |
| CON-#488-7369 OL, NUDOCS 8810280180 | |
| Download: ML20205G035 (57) | |
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@,$*TM bobN4P5 ills UNITED STATES OF AMERICA OCN O a "NT pm-NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOAPD In the Matter of ) .
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL -
) '
(Seabrook Station, Units 1 and 2) ) (Off-site Emergency
) Planning Issues)
)
APPLICANTS' RESPONSE TO "(TOA'S) FIRST 1 SET OF INTERROGATORIES . . . TO l THE APPLICANTS ON (SPMC)"
Pursuant to 10 C.F.R. 5 2.740b, Applicants respond to the "First Set of Interrogatories . . . to the App).1: ants en the Seabrook Plare for Msssachusetts Communit.f.es (SFMJ) ** of l
che Tovn of Amesbury (TOA) as follovs.1
- 1. As to TOA's "Instructior.s for Ur.e".
The rules of prt.ctice do not require, a s TOA apparently b411 eves, that euch interrogatory be answered by an individual "with personal knowledge of the facts or 1 Applicants will respond to TOA's request for production of documents in the time alloted by the rule, 10 C.F.R. I 2.741.
8810200100 not024 PDR 0 ADOCK 05000443 PDR I)S03
information requested in each interrogstory." ToA filing at
- 1. Applicants' answe s, in accordance with 10 C.F.R. 5 2.740b, are "by any officer or agent, who shall furnish such information as is available to the party."
Applicants' object to the proposed definitions provided in paragraphs 2-5 of the "Instructions for Use" on the grounds that such definitions are overbroad and burdensome.
Applicants will identify a natural person by providing the individual's name, title, and business address. Applicants will identify a corporation or other entity that is not a naturel person by providing name and address. Applicants will identify any action, conduct or matter, depending on the action, conduct or matter involved, in such manner as to sufficiently describe the action. Applicants will identify a document by providing its title and date.
- 2. As to Specific Interrogatories.
Interroq3to ry No. 1 With respect to each contention and basie edmitted by the Licensing Board regarding the SPMC, please provide the following inforriations
- a. Whht is the Applicants' position with respect to each contention and basis? Identify the reasons for your position.
- b. Identify all persons you may call as witnesses concerning the SPMC litigation; the particular contention or basis on which each will testify; the subject matter on which
( ach will testify; the substance of each witness' testimonyt the grounds for each opinion or testimony; and identify any documents, indicating tha relevant portion and citation, that er'h witness will rely upon to support his testimony, and any 2-
(
e i
documents which Applicants will offer into evidence through i
each witness.
t
- c. Identify all persons on whose factual knowledge, opinions, or technical expertise you rely for your position ;
on each contention and basis. For each, state the substance '
of the knowledge, opinions, or technical expertise that Applicants rely on. >
Aeolicants' Resoonse t Applicants object to so much of this interrogatory as !
calls for the exposure of litigat!.on strategy, attorney work product, and attorney-client privileged materials.
Applicants further object on the grounds that it is overly l broad and burdensome. Without waiving the foregoing objections, Applicants respond as follows: Witnesses and .
1 documentary exhibits have not yet been selected. As to Applicants' positions on contentions, see Attachment A to "Applicants' Response to Mass AG's First Set of Interrogatories to Applicants on the (SPMC)."
Interroce,Lorv No. 1 Identify any portions of the SPMC that are under
! revision or are expected to be revised in the futuro.
l Identify the purpose, substance, and expected dr,te of acch revision.
Aeolicants' Reeponse Under the provisions of the SPMC at Section 7.2.5, NHY is committed to review and revise the SPMC, at a minimum, on an annual basis. At this time, NHY has proposed to make certain plan / procedure changes as described in NHY's letter 4
(NYN-88131) dated October 4, 1988 to the NRC, a copy of which has been served on all parties to this proceeding. In !
addition, NHY has proposed certain plan / procedure changes to resolve issues identified in the draft review and evaluation of the Seabrook Plan for Massachusetts communities dated September 9, 1988, prepared by the Federal Emergency Management Agency, Region 1. Those proposed changeb nre I attached to this response as Attachment A.
i While no other revisions are currently proposed, any portions of the SPMC may be subject to revision in accordance with SPMC, Section 7.2.5. The SPMC may be revised as a ;
j result of proceedings before the ASLB. ,
Interroaatory No. 1 l i
Identify and produce all amended, supplemental or additional letters of agreement relied upon by Applicants for parsonnel, transportation, or other resources to implement the SPMC, and not previously served upon Intervenors.
ADplicinL1' ResDonfia !
l Additional or updated agreements which do not currently appear in the SPMC, but will also be produced, are with the l following companies:
l DATE SIGNED DATE SIGNED BY ENTITIES BY NHY__ OTHER PARTY 10/26/87 10/22/87 10/02/87 08/26/87 I 10/13/87 10/08/87 l l
l i
i
~4-
?
l .
-l 10/o8/s? 10/02/87 o i 10/21/87 09/27/87 j l
12/02/87 10/26/87 l' 10/02/87 09/23/87 {
10/02/87 09/30/87 10/02/87 09/09/87 10/08/87 10/02/87 l 10/02/87 09/23/87 !
t 10/02/87 09/15/87 l 10/22/87 10/16/87 h 10/02/87 09/30/87 01/05/88 12/30/87 t i
10/20/87 10/15/87 10/29/87 10/15/87 ;
10/02/87 08/24/87 10/02/87 08/28/87 l 09/01/87 09/01/87 [
.i 09/11/87 09/11/87 08/23/e8 I 05/13/87 05/11/88 08/18/88 09/30/87 09/28/87
- O8/12/87 08/12/87 l 09/14/87 09/14/87 i
I i
f l
_ - - . . . - . , , . ~ - - . . _ - . . . - . . - -
r-09/02/87 08/31/87 10/03/88 10/03/87 06/20/88 06/01/88 06/24/88 06/23/88 !
06/27/88 06/24/88 07/25/88 06/24/88 !
i 07/19/88 05/01/88 5 05/03/88 05/03/88 :
09/30/88 1
j 08/26/88 08/28/87 09/14/87 09/14/87 l 1
Interroaatory No. 4 Identify any letters of agreement that have been rescinded or abrogated.
{ Acolicants' Respenso I
I Interreaatory No . _,1 i
State the total number of manned vehicles in each i category that are necessary, in a severe, fast-break release, j to implemont the SPMC for the Town of Amenbury: busee.,
) ambulances, special needs vehicles, other vehicles. Identify j and produce all documents, and state every fact or opinion
! upon which you rely to support this answer.
i l Aeolicants' ResDonse l Consistent with NUREG-0654/ FEMA-REP-1, the planning basis is independent of specific accident sequences.
4
~. --
Therefore, the SPMC is not based specifically on a severe, fast break release or on any specific accident sequencer and the interrogatory as stated cannot be answered. Disragarding the reference to a "severe, fast break release," the Applicants' response is as follows:
See response to Interrogatory No. 7.
Interroaatory No. 6 Sthte the total number of manned vehicles in each category the.t are available for actual use in a severe, fast-break release, to imp! ament the SPMC for the Town of Amosbury: buses, ambulancas, special needs vehicles, other vehicles. Identify and produce all documents, and state every fact or opinion upo) which you rely to support this answer.
boolicants' Pesconse Conaistent with NUREG-0694/ FEMA-REP-1, the planning basis is independent of specific accident sequences.
Therefore, the SPMC is not based specifically on a severe, faut break release or on any specific accident sequencot and
- the inter'ogatory us scated cannot be c;iswered. Disregarding i
l the reference to a "severe, fast break releaao," the
! Applicantui response is as follows:
1 l Vehic)es available for use for the Town of Amesbury era
- drawn from the pool of resources identified in the response
! to Interrogatory No. 8.
i i
t .
I i
l Interrocatory No. 7 i For all towns within the Massachusetts EPZ, including 5
TOA, state the total number of manned vehicles necessary, in a severe fast-break release, to implement the SPMC: buses, ambulances, special needs vehicles, other vehicles. Identify and produce all documents, and state every fact or opinion upon which you rely to support this answers.
Acolicants' Resoonse I
consistent with NUREG-0654/ FEMA-REP-1, the planning ,
basis is independent of specific accident sequences.
Therefore, the SPMC is not based specifically on a severe, fast break release or on any specific accident sequence; and l the interrogatory as stated cannot be answered. Disregarding l the reference to a "severe, fast break release," the l Applicants' response is as follows:
Depending upon the protective action recommendation, if any, the total number of manned vehicles required will vary, for each category from zero to the numbers reflected in the GPMC, Appendix H at pages M-16, M-17 and M-18 as corrected to indicate a total need of 366 buses rather than the 297 listed
, at M-18. Documents relied upon ares
- 1. The SUNC, Appendix M ('ncluding footnotes at M-17)
- 2. The results of the special needs survey at reflected in Appendix M.
Interroaatory (fo. 8 For all towns within the Massachusetts EPZ, including ToA, state the total number of nanned vehicles claimed available for actual use, in a severe, f ast-break emergeac-l, to implement the SPMCs buses, ambulances, special needs vehicles, other vehicles. Identify and produce all documents,and state every fact or opinion upon which you rely to support this answer.
Acolicants' Resconse Consistent with NUREG-0654/ FEMA-REP-1, the planning basis is independent of specific accident sequences.
Therafore, the SPMC is not based specifically on a severe, fast break release or on any specific accident sequencer and the interrogatory as stated cannot be answered. Disregarding the reference to a "severe, fast break release," the Applicants' response is as follows:
The total numbers of manned vehicles under agr61 ment are Buses 441 Ambulances 60 Ambulettes 4 Critical Care Units 2 Wheelchair Vans 61 Wheelchair Suses 1 Road Crews 17 other Vehicles (station wagons, vans and half buses) 230
, Agreements which form the basis of the above given numbers
! are in place with the following companies:
DATE SIGNED DATED SIGNED BY COMPANY BY NHY OTHER PARTY 10/26/87 10/22/87 10/02/87 08/26/87 10/13/87 10/08/87 10/08/87 10/02/87 10/21/87 09/27/87
O 12/02/87 10/26/87 10/02/87 09/23/87 01/02/87 09/30/87 10/02/87 09/09/87 08/26/87 08/26/87 08/20/87 10/08/87 10/02/87 4
10/02/87 09/23/87 10/02/87 09/15/87 08/03/87 08/26/87 12/21/87 11/19/87 10/22/87 10/16/87 1
10/02/87 09/30/87
) 01/05/87 12/30/87 10/20/87 10/15/87 j 10/29/87 10/15/87 i
10/02/87 08/24/87 10/02/87 08/28/67 l
Interroaatory No. 9 1
j For each school located within the Town of Amesbury, state the total number of personnel in each category who are l necessary, in a severe, fast-break release, to implement the SPMC and/or assist students in undertaking protective actions: teachers, school administrators, other school e
personnel, ORO personnel. For each category, identify under the SPMC, the particular actions or duties to be performed.
i 1
j 1
._ -. _ _ _ . - . _ _ . _ . . _ . . _ _ . . . . . _ ,,_ _ , _ . _ . . . _ _ . - ~. _ .__ ._
1 Identify and produce every document, and state every fact or opinion, upon which you rely to support this answer.
! Acolicants' Response Consistent with NUREG-0654/ FEMA-REP-1, the planning basis is independent of specific accident sequences.
Therefore, the SPMC is not based specifically on a severe, fast break release or on any specific accident sequence; and the interrogatory as stated cannot be answered. Disregarding the reference to a "severo, fast break release," the Applicants' response is as follows:
See response to Interrogatory 11.
i Interrocatory No. 10 For each school located within the Town of Amesbury, state the total number of personnel in each category who are available, in a severe, fast-break release, to implement the SPMC and/or assist students in undertaking protective
- actions
- teachers, school administrators, other school personnel, ORO personnel. For each category, identify the particular actions or duties to be performed. Identify and produce every document, and state every fact or opinion, upon l which you rely to support this answer.
Acolicants' Response Consistent with NUREG-0654/ FEMA-rep-1, the planning basis is independent of specific accident sequences.
Therefore, the SPMC is not based specifically en a severe, fast break release or on any specific accident sequence; and the interrogatory as stated cannot be answered. Disregarding the reference to a "severe, fast break release," the Applicants' response is as follows:
See response to Interrogatory 12. .
Interrocatory No. 11 For each school located within the Massachusetts EPZ, including those in TOA, state the total number of personnel in each category who are necessary, in a severe, fast-break 1
release, to implement the SPMC and/or assist students in undertaking protective actions: teachers, school administrators, other school personnel, ORO personnel. For I each category, identify under the SPMC, the particular actions or duties to be performed. Identify and produce ;
every document, and state every fact or opinion upon which you rely to support this answer.
Aeolicants' Resoonse Consistent with NUREG-0654/ FEMA-REP-1, the planning basis is independent of specific accident sequences, j Therefore, the SPMC is not based specifically on a severe, d
fast break release or on any specific accident sequence; and the interrogatory as stated cannot be answered. Disregarding the reference a "severe, fast break release," the F Applicants' response is as follows.
Personnel necessary to implement the SPMC or to assist school j i
students in undertaking protective actions, including l evacuation, are: '
For all Massachusetts EPZ schools: 1 ORO School Coordinator i
l per shift.
l 1 t I
r 4 !
1 l
l l
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A. Amesbury School District 1 ORO school liaison per shift i superintendent or assistant superintendent of schools
- 1. Horace Mann School - 6 bus drivers 1 route guide '
1 administrative staff
- 2. Amesbury Elementary School - 9 bus drivers $
1 route guide [
1 administrative staff l l
- 3. Charles cashman School - 12 bus drivers 1 route guide 1 administrative staff 1
- 4. Amesbury Middle School - 11 bus drivers j 1 route guide l 1 administrative staff
- 5. Amesbury High School - 15 bus drivers 1 route guide 1 administrative staff j 6. Seventh Day Adventist School - 1 bus driver
- 1 route guide i
1 administrative staff B. Newburyport School District - 1 ORO School Liaison per shift I superintendent or j assistant of schools 1
j 1. Belleville School - 11 bus drivers j 1 route guide j 1 administrative staff
- 2. Brown School - 5 bus drivers 1 route guide 1 administrative staff
- 3. Kelly School - 3 bus drivers 1 route guide
- 1 administrative staff l
i
l l
- 4. Rupert A. Nock Middle School - 18 bus drivers j 1 route guide 1 administrative staff
- 5. Newburyport High School - 17 bus drivers 1 route guide 1 principal !
1 administrative staff
- 6. Immaculate Conception School - 4 bus drivers 1 route guide 1 administrative staff
- 7. Greater Newburyport Ed.
Collaberative (summer) - 5 bus drivers 1 route guide 1 administrative staff
- 8. Greater Newburyport ARC (summer) Special Ed. Program - 2 mini-bus drivers 1 route guide ,
1 administrative staff 1
Source: SPMC - Appendix M Special Procedures - RERP for Newburyport Schools Special Procedures - RERP for Immaculate Conception School ;
i C. Pentucket Regional School District - 1 superintendent or i assistant superintendent of schools j
q 1. West Newbury - 1 ORO School Liaison per shift .
1 I
- a) Pentucket Regional Sr. High - 12 bus drivers (
) 1 route guide j
! I administrative j staff l b) Pentucket Regional Jr. High - 11 bus drivers e 1 route guide 1 administra-
. tive staff 1
i i
l 1
1
c) Dr.' John C. Page School - 9 bus drivers 1 route guide 1 administrative staff
- 2. Merr'.mac - 1 ORO School Liaison per shift a) Dr. F. Sweetsir School - 4 bus drivers 9
1 route guide 1 administrative staff b) Donaghue School - 6 bus drivers 1 route guide 1 administrative staff Source: SPMC - Appendix M)
Special Procedures - RERP for Pentucket Regional School Special Procedures - RERP for Essex North Christian School D. Triton Regional School District - 1 superintendent or a assistant superin-l tendent of schools 1
) 1. Newbury - 1 ORO School Liaison per shif t a) Byfield School - 2 bus drivers 1 route guide i 1 administrative staff I
b) Newbury Elementary School - 8 bus drivars 1 route guide 1 administrative staff c) Woodbridge School - 2 bus drivers 4 1 route guide 1 administrative staff
]
j d) Triton Regional Jr.-Sr. High School -
27 bus drivers
- 1 route guide i 1 administrative staff l
I I
I f
e) Governor Dummer School - 10 bus drivers 1 route guide 1 administrative staff
- 2. Salisbury - 1 ORO School Liaison per shift a) Salisbury Memorial Elementary - 13 bus drivers 1 route guido 1 administra-tive staff b) Plains School - 2 bus drivers 1 route guide 1 administrative staff Source: Special Procedure - RERP for Gov. Dummer Academy SPMC - Appendix M Special Procedure - RERP for Triton Regional School District i
See response to TOA Interrogatory No. 12 for references to
, particular actions or duties to be performed.
Interroaatory No. 12 i
i For each school located within the Massachusetts EPZ, including those in TOA, state thc total number of personnel in each category who are available, in a severe, fast-break 1 release, to implement the SPMC and/or assist students in i undertaking protective actions: teachers, school l aaministrators, other school personnel, ORO personnel. For each category, identify the particular actions or duties to j be performed. Identify and produce avery document, and state evary fact or opinion, upon which you rely to support this answer.
t Aeolicants' Resoonse Consistent with NUREG-0654/ FEMA-REP-1, the planning basis is independent of specific accident sequences.
Therefore, the SPMC is not based specifically on a severe, fast break release or on any specific accident sequence; and the interrogatory as stated cannot be answered. Disregarding the reference to a "severe, fast break release," the Applicants' response is as follows:
The following personnel are available to implement the SPMC in undertaking protective actions for schools:
3 ORO School Coordinators 21 ORO School Liaisons 205 ORO Route Guides See response to TOA Interrogatory No. 8 for bus resource information.
The particular actions or dutius to be performed are identified in SPMC, Section 2.1.2.
Note: Personnel are not preassigned to any particular school. Therefore, Applicants have responded by stating total staffing.
Sources: SPMC, Section 2.1.1, Appendix H, Appendix M, and current agreements with bus providers.
To Applicants' current knowledge, the following personnel are available to assist school students in undertaking protective actions:
PERSONNEL AVAILABLE TO ASSIST SCHOOL CHILDREN A.MESBURY 1GiOOL DISTRICT SCHOOL SUPERINTENDENT SCHOOLADMINISTRATORS TOTAL STAFF Central Office 1 1 High School 1 75 17-
Middle School 2 65 Amesbury Elementary 2 62 Cashman School 1 50 Horace Mann School 1 20 PRIVATE SCHOOL:
7th Day Adventist 1 1 PENTUCKET REGIONAL Merrimac/
W. Newbury SCHOOL SUPERINTENDENT SCHOOL ADMINISTRATORS TOTAL STAFF Central Office 1 1 Dr. Sweetsir 1 15 Donaghue 1 17 John Page 1 35 Pentucket Jr. H.S. 2 78 Pentucket Sr. H.S. 2 90 PRIVATE SCHOOL:
Essex North 1 8 Christian School i
NEVBURYP0kT )
SCHOOL DISTRICT SCHOOL SUPERINTENDENT SCHOOL ADMINISTRATOPS TOTAL STAFF Central Office 1 1 Brown School 1 22 Belleville School 2 36 Kelley School 1 14 i Nock Middle 2 89 High School 2 73 C.N. Summer ARC 1 4 C.N. Suminer School 1 21 PRIVATE SCHOOL: ^
Iminaculate Con.
ception 1 13 -
TRITON REGIONA1.
SCHOOL DISTRICT SCHOOL SUPERINTENDENT SCHOOL ADMINISTRATORS TOTAL STAFF Central Office 1 1 Byfield School 1 5 l
Newbury Elementary 1 25 i Woodbridge School 1 4 l t
18 i
Salisbury Elementary 2 60 Plains School 1 6 ;
I PRIVATE SCHOOL:
Gov. Dummer Academy 2 131 !
Interroaatory No. 13 Identify and produce all documents, and provide all j relevant citations to the SPMC, which explain or set forth
, emergency response plans or procedures for schools located within Massachusetts EPZ. l Acolicants' Resoonse Documents available f
- 1. SPMC - Appendix M
- 2. Special Procedures - RERP for Amesbury Public School
- 3. 3pecial Procedures - RERP for Seventh Day Adventist l
- 4. Special Procedures - RERP for Newburyport Public School
- 5. Special Procedures - RERP for Immaculate Conception School l l
- 6. Special Procedures - RERP for Triton Regional [
School
- 7. Special Procedures - RERP for Gov. Dummer Academy
- 8. Special Procedures - RERP for Pentucket Regional School
- 9. Special Procedures - RERP for Essex North Christian School 1
- 10. SPMC - Section 3.6 - IP 1.9 and 2.7
- 11. SPMC - Implementing Procedures - IP 1.9 and IP 2.7
- 12. SPMC - Appendix F - RERP Generic Massachusetts Public School Plan
- 13. SPMC - Appendix F - REEP Generic Massachusetts Private School Plan Interroaatory No. 14 For each special needs facility, other than schools, located within the Town of Amesbury, including TOA Hospital, state the total number of personnel in each category necessary,in a severe, fast-break release, to implement the SPMC and/or assist those with special needs to undertake protective actions doctors, nurses, other medical personnel, ORO personnel. For each category, identify the particular actions or duties to be performed. Identify and produce avery document, and state every fact or opinion upon which you rely to support this answer.
Aeolicants' Response Consistent with NUREG-0654/ FEMA-REP-1, the planning basis is independent of specific accident sequences.
Therefore, the SPMC is not based specifically on a severe, fast break release or on any specific accident sequence; and the interrogatory as stated cannot be answored. Disregarding the reference to a "severe, fast break release," the Applicants' response is as follows:
Special needs facility staff, to the extent available at the time of an emergency, are considered to be recipients of emergency response assistance and, therefore, are expected to l
assist those with special needs. For Amesbury Special Needs Facilities (including nursing homes, hospitals, other elderly facilities and mentally ill/ retarded facilities see Appendix M, Rev. O, Amendment 6, pp. M-27 through M-29) the following ORO personnel are responsible for dir6ct contact in support of facility emergency response One special population liaison will support the Town of Amesbury's special needs facilities (see IP 1.10 and 2.7 for responsibilities).
Amesbury Nursing and Retirement Home - One Route Guide (see IP 2.10 and 2.11 for responsibilities); eight ambulance personnel (see IP 2.10 for responsibilities),
two bus drivers (see IP 2.10 for responsibilities),
three van drivers (see IP 2.10 for responsibilities),
One bus driver (see IP 2.10 for responsibilities); one Route Guide (see IP 2.10 for responsibilities).
Hillside Rest Home - One bus driver (see IP 2.10 for responsibilities); one Route Guide (see IP 2.10 and 2.11 for responsibilities).
Maplewood Manor - One Route Guide (see IP 2.10 and 2.11 for responsibilities); six smbulance personnel (see IP 2.10 for responsibilities); two bus drivers (see IP 2.10 for responsibilities); six chairvan drivers (see IP 2.10 for responsibilities).
S Harbor School (Pleasant Valley Road) - One bus driver (see IP 2.10 for responsibilities); one Route Guide (see IP 2.10 for responsibilities).
Harbor School (River Road) - One bus driver (see IP 2.10 for responsibilities); one Route Guide (see IP 2.10 for responsibilities). ,
M. R. Residence (23-25 Winter Street) - One bus driver (see IP 2.10 for responsibilities); one Route Guide (see IP 2.10 and 2.11 for responsibilities).
Heritage Vale - One Route Guide (see IP 2.10 and 2.11 for responsibilities).
Pow Wow Villa - One bus driver (see IP 2.10 fc.
responsibilities); one Route Guide (see IP 2.10 and 2.11 for responsibilities).
M. I. Residence (119 Highland Street) - one van driver (see IP 2.10 for responsibilities); one Route Guide (see IP 2.10 and 2.11 for responsibilities).
Amesbury Hospital - 26 ambulance personnel (see IP 2.10 for responsibilities); two bus drivers (see IP 2.10 for romponsibilities); one Route Guide (see IP 2.10 and 2.11 for responsibilities).
For Amesbury Day Care Centers / Nurseries (see Appendix M, Rev. O, Amendment 6, pp. M-22 through M-26) the following ORO personnel are responsible for direct contact in support of facility emergency response:
i
O One school Liaison will support the Town of Amesbury's day care / nursery facilities (see IP 1.9 and 2.7 for responsibilities).
Seven bus drivers (see IP 2.10 for responsibilities).
Seven Route Guides (see IP 2.10 and 2.11 for responsibilities).
Inte rrenatory No. 15 For each special needs facility, other than scnools, located within the Town of Amesbury, including TOA hospital, state tPd total number of personnel in each category who are availabl6 fer actual use, in a severe, fast-break release, to implement the CPMC and/or to assist those with special needs to undertaxv protective actions: doctors, nurses, other medical personnel, ORO personnel. For each category, state the particular actions or duties to be performed. Identify and produce every document, and state every fact or opinion, upon which you rely to support this answer.
Acolicants' Resoonse Consistent with NUREG-0654/ FEMA-REP-1, the planning basis is independent of specific accident sequences.
Therefore, the SPMC is not based specifically on a severe, fast break release or on any specific accident sequences and the interrogatory as stated cannot be answered. Disregarding the reference to a "severe, fast break release," the Applicants' response is as follows:
Total staffing, including backups, includes 18 Special Populations Liaison.
l I
Total staffing, including backups, includes 21 School r r
Liaisons.
Total staffing, including backup, includes 205 Route ;
Guides.
See response to Interrogatory No. 8 for ;
transportation resource information.
See response to Interrogatory No. 14 for the actions or duties to be performed.
Note: Personnel are not preassigned to any particular special needs facility. Therefore, Applicants have responded by stating total staffing.
Interrocatory No. 16 Identify and produce all documents, and provide all relevant citr.tions to the SPMC, which explain or set forth emergency response plans or rocedures for special needs facilities, other than schnois, located within the Town of Amesbury, including TOA Hospital.
Acolicants' Resconse New Hampshire Yankee has distributed support plans to Day Care / Nurseries and Special Facilities listed in Appendix M, Rev. O, Amendment 6, pp. M-22 through M-29.
SPECIAL NEEDS FACILITIES
- 1. Special Procedures / Plans For:
Residence, 23-25 Winter Street Heritage Vale Pow-Wow Villa The Harbor School (Pleasant Valley Road)
O The Harbor School (River Road)
Eastwood Rest Home Residence, 119 Highland Street
- 2. Generic Nursing Home Plan Fort Amesbury Nursing and Retirement Home Hillside Rest Home Maplewood Manor Nursing Home
- 3. Generic EPZ Hospital Plan Fort Amesbury Hospital DAY CARE / NURSERIES
- 1. Special Procedure / Plan Fort Little Lad's and Lassia's Day Care Center (Linda McDormand)
D. Blades Day Care Center J. Yasi Day Care Center S. Dragonas Day Care D. Notargiacomo Day Care Center R. Terry Day Care Center D. Toleos Day care Center G. Willett Day care Center K. Sferruza Day Care Center Sheila Taylor Day Care Center D. Perkins Day Care Center K. Scott Day Care Center J. h:Intire Day Care Center l
K. Miele Day Care Center D. Millette Day Care Center K. Muse Day Care Center D. Fournier Day Care Center E. Fournier Day Care Center '
i J. Fournier Day Care Center
]
l
- K. Fournier Day Care Center i
e Amesbury Headstart Day Care center '
e i -
E. Hove Day Care Center t A. Hutchinson Day Care Center N. Elander Day Care Center l
D. Dore Day Care Center ,
Interrocatory No. 17 t
I State whether Applicants are in possession, or have knowledge, of any admissions by the Town of Amesbury and/or c any of its officials, agents, employees or personnel '
- regarding the SPMC and/or the adequacy or inadequacy of ,
l emergency planning for Town of Amesbury or the Seabrook EPZ.
If you answer yes, identify and produce each such document and identify the Forson making each admission, its date, and substance.
Acolicants' Response Applicants are presently providing all documents in its possession relevant to this proceeding in response to
- existing document requests.
Applicants object to this interrogatory on the ground
! that it calls for legal corclusions on the content of these i
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e i l
documents as to what statements could constitute "admissions" of TCA and thus also calls for attorney work product and trial preparation materials. The request is particularly unjustifiable when the information sought is, by definition, in the interrogating party's hands.
Interroaatory No. 18 Identify the procedure for determining specific resources available for actual use in the event of an emergency, as referenced at page 182 of APPLICANTS' RES PONSES TO INTERVENORS' CONTENTIONS ON THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES (SPMC), dated April 26, 1988, (hereinafter "Response"). Estimate the time necessary for 1 completion of this procedure.
i Acolicants' Response
]
i The procedure for determining these resources is outlined in IP 2.10 at steps 5.1.3.A through 5.1.3.C.
1 It is estimated that the indicated steps would take l
- place within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Inte rroaato ry No. 19 i In its Response, Applicants state "the SPMC is i structured on the theory that governmental agencies only are i called upon to do what they would be required to do every day in the absence of an emergency at Seabrook." Response, p.
i 183. With respect to the Town of Amesbury, identify all TOA a
personnel which, under the SPMC, may be "called upon" in the 1 event of an emergency at Seabrook Station. For each person,
- state the activity, function or service to be performed.
Identify and produce all documents, and state all facts and opinions upon which Applicants rely to support their answer.
)
I
- l 1
Annlican_ts' Resnonne SPMC, Sections 2.2.1 and 2.4.2.F identify organizations i and personnel, and their functions, who may be called upon in the Town of Amesbury in ihn event of an energency at Seabrook f Station. Applicants rely on the SPMC sections cited. i.
Interrocatory No. 20 As referenced in 10 C.F.R. I 50.47 (c) (1) (iii) (B) ,
identify the "best efforts" that, in Applicants' opinion, TOA will make in the event of a radiological emergency at Seabrook Station. Identify and produce all documents, and state all facts and opinions upon which Applicants rely to support this answer.
Annlicants' Response Applicants object to this interrogatory on the ground that it would have Applicants speculate about the t'uture behavior of particular individuals in a way not countenanced by the regulations.
Without waiving the foregoing objection, Applicants respond as follows:
Applicants assume that TOA will do anything it can within its capabilities to protect its citizens.
Interroaatory No. 21 Identify and explain the training in traffic control provided to ORO staff who may staff traffic control points in an actual emergency.
i i
Aeolicants' Reamonse Training modules provided to Traffic Guides are shown on Taole 6.3-1 of the SPMC. Modules are individually described in Section 6.3.11, 6.3.15 and 6.3.16 of the SPMC.
Each trainee sponds approximately four (4) hours in hands-on practical training for directing and controlling traffic (traffic guides), dealing with traffic impedimento (traffic guides and trarisfer point dispatchers), and moving
- and placing traffic cones (traffic guides). Mock a
j intersections are set up in accordance with SPMC, Appendix J
- - Traffic Management Manual.
I i
9 Interroaatory No. 22 i
Identify each ORO traffic guide with prior experience in
) traffic management or control. For each, state the nature
, and extent of experience.
Applicants' Resconse
]
1 Employer and
- . h Business Address Title / Deet. Police Excerigng,g i
j dated 07/31/87
- part time police officer for 5 years.
l Per application dated 07/28/87 military police &
traffic control exp.
Per application dated 08/12/87 Aux./
Special police 29-
officer for the town of Belmont.
Per application dated 07/30/87 certified part.
time police officer NH & Aux state trooper for NH.
Per application dated 05/11/88 military police the army.
Per application dated 07/27/88 polir,e officer experience.
Per application dated 08/07/87 member of Nashua emerg. team vbich helped police with traffic control and road service.
Per application dated 07/27/88 has security experience Per application dated 08/19/88 has security experience Per application dated 9/23/87 has security experience Per application dated 08/10/87 has security experience Per application dated 08/12/87 has security experience 30
Per application dated 08/08/87 has '
security experience Per application dated 08/03/87 has security experience ;
Per application dated 07/23/87 has ,
security experience Per application dated 08/06/87 bas >
security experience Per application dated 08/01/87 has l security experience i
Per application dated 08/12/87 has security experience ;
d Per application i dated 08/04/87 has ;
security experience !
. i 4
Per application l dated 08/14/87 has security experience Per application dated 08/02/87 has i security experience 1
Per application :
j dated 0$/09/88 has !
, security experience :
4 1
6 l Per application !
dated 08/01/87 has l security experience i I
J Per application t I
dated 04/19/88 has j security experience ;
1 ,
I .
j 31- l l
Per application dated 07/28/87 has security experience Per application dated 05/06/88 has
. security experience Per application dated 05/06/88 has security experience l Per application i
dated 07/28/87 has security experience
]
] Per application
] dated 08/06/87 has security experierce 3 Per application dated 08/06/87 has 1 security experience a Per application dated 08/04/87 has security experience Per application i dated 07/29/87 has I security experience l Per application i dated 07/20/87 has experience as a a
volunteer fireman Per application
- dated 02/17/88 has exper;ence as a i
a volunteer fireman Per application 4
dated 07/24/87 has experience as a volunteer fireman 12 6
1
Per ap).?tcation dated 07/28/87 has experience as a volunteer fireman Per application dated 07/28/87 has experience as a ;
volunteer fireman '
Per application dated 03/07/88 has experience as a volunteer firetean Per application ,
dated 05/16/88 has experience as a r volunteer fireman Per application dated 05/05/88 has experience as a volunteer fireman Per application dated 07/23/87 ht; ,
experience as a ,
volunteer fireman t Per application ,
dated 07/30/87 has experienn as a i volunteer firensn Interroaatory No. 23 Identify each ORO traffic guide who has been, or la presently, employed as a police officer.
Aeolicants' Resconse Employer and Lu.c Business Address Title / Dept. Police Experience Per application dated 07/31/87 part time police 33-
O J
officer for 5 years.
Per application dated 07/28/87 military police &
traffic control exp, Per application dated 08/12/87 Aux./
Special police officer for the town of Belmont.
Per appitcation dated 07/30/87 l certified part.
4 time police officer NH & Aux, state trooper for NH.
Per application dated 05/11/88 military police the army.
- Per application i dated 07/27/88 1 police officer f experience.
i l Interroaattirv No. 24 I
For TOA, identify how each traffic control point in the SPMC and the number of traffic gtides for each traffic control point, were determined.
Amelicancs' Reoponse The method utill ed for determining traffic control points and the number of traffic guides is explained in Section 8 of the Evacuation Time Study.
Interrocatory No. 25 Identify how traffic control point B-AM-06 will be managed or controlled in an actual emergency at Seabrook, including all relevant SPMC citations.
Aeolicants' Resoonse See SPMC Appendix J, page J-28.
IInte rroc atory No. 26 Identify and produce all documents (1) on which you rely to answer these interrogatories or (2) which Applicants intend to offer as exhibits in this proceeding for any purpose.
Aeolicants' Resoongt ,
Documents on which Applicants rely for answers to the i preceding interrogatories are identified in the individual interrogatory responses. ,
Applicants object to subpart (2) of this interrogatory on the ground that it is repetitive of Interrogatory lb and it seeks litigation strategy, work product, and attorney-client privileged naterials.
a
MOTION FOR PROTECTIVE ORDER Applicants move that the Board issue a protective order prohibiting TOA from obtaining discovery to the extent objected to by Applicants in Response to "(TOA's) First Set l of Interrogatories to Applicants on the (SPMC)."
I i
.36-
/
CC 14
- 69 16: 31 G7. E-N44~ 2.I As to answere
~
Cecrge S. Tho6ae Vice President, Nuclear Production New Hampshire Yankee Division of Public Service Company of New Hampshire State of New Hampshire Rockingham County, es.
Then appeared before se the above subscribed George s. Thomas and made oath that he le the Vice President, Nuclear Production of New Haapahire Yankee Division, authorized to execute the foregoing Response to "[T0A's]
First Set of Interrogatorise . . . to the App 11cante on ($PMC)" on behalf of the App 11cante that he a6de inquiry and believes that the foregoing answere accurately set forth information se la available to the App 11cante.
Before me, '.
y' _
% A 8., S A9 & T My Commise @ Expires: March' #.1990 ,
As to objectionet
._/m Bs/J W Thonae 0. Dignan, Jr.
George H. Lewald Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith Ropes & Orsy
$26 Franklin Street Boston, MA 06110 (017) 433-4100
-se-
Attachment A
.' 3 .
yg }
_" .? [.) ;! D 4 .- @ ' :? y ', ,
> E 'O a 1 Pubile Senace of New HammerWre
.aw -r esnire et. nee Division Sectemoer 28, 1988 Richard W. Donovan RAC Chairman for Seabrook Nuclear Pcwer Plant Exercise Federal Emergency Management Agency Federal Regional Center Bothell . '4ashington 98021-9796
Dear Mr. Onnovan:
Enclosed is the NHY ORO technical assistance response to the craft Review and Evaluation of the Seabrook Plan for Masscenusetts Communities' dated Septemoer 9. 1988 and prepared by the Federal Emergency Management Agency, Region 1. The response provides NHY ORO's plan to resolve issues identied in the report and an intended completion schedule.
Thank yco for your continued assistance.
Sincerely,
/ !
f n.3.0 / dram-n Georgt fiacutiveDirectoryof W ergency Preparedness and Ccmmunity Relations Enclosure GRG:s1s cc: Mr. W1111am Lazarus, NRC Region !
l l
l l
l P O. Box 300. Seaeroom. NH 03874 . Teleonone i603) 474 9574
1988 PLAN REVIEW DRAFT REPORT RES0luTION TRACKING APPROVAL:
0 . ORO N = Naine Nii = New llampshire REPORI REFERENCE PAGE REPORT ISSUE CCI CORRECTION ACTION APPROVAL AFFECTED SECIl0NS NUMBER ITEM NO. NUN 8ER Altnough Table 2.0-1 in- Table 2.0-1 will be revised in the next 1 A.I.a dicates t*.at NHY ORO com- plan amendment to correctly reflect that ORO municates with the USCG communications with the USCG and FAA are and the FAA, the Plan coordinated through NiiOLN.
states in Section 3.1 that "requests to the USCG and FAA will be co-crdinated through the host state for Seabrook, New Hampshire.
We find Table 2.01- to be Table 2.0-1 will be revised in the next 6 A.2.a incomplete and inade- plan amendment to: ORD quate: the D01 is not 1. include D01 as a federal response l listed as a Federal re- agency and its primary responsiblitty sponse agency, and the in public alerting; USCG and FAA are not 2. Indicate the primary responsibilities listed as being assigned assigned to the USCG and FAA; the primary responsiblit- 3. add YAEC for providing assistance in ty assigned them in the monitoring /decon. (expusure control);
concept of operations. 4. Include paranthetical note that evac-Table 2.0-1 omits the uation includes provision of trans-responsibilities assigned portation researces under contract to regional utilities by with NHY OR0; the Yankee Atomic Nutual S. expand the heading for CCC to include Assistance Plan in social services and add support role Section 2.1.1 for notif t- to Local EOC Coordinator.
cation, radiological ex- Additionally, Section 2.1.1 of the Plan posure control, and traf- will be revised,*in the next amenenent fic control. We could to clarify the role of the Yankee Mutual page No. OR0-1 C/SSS1/0.1
1988 PLAN REVIEW DRAFT REPORI RESOLUTION TRACKING APPROVAL:
0 = ORO M = Maine Nil = New Itampshire REPORI REFERENCE PAGE REPORT ISSUE CCI CORRECTION ACTION APPROVAt AFFECTED SEC110NS NUMBER ITEM NO. -
NUMBER Section 2.1.1 for nottf t- Assistance Plan in providing technical 6 A.2.a cation, radiological ex- support and the provisions which have ORO (cont'd) posure control, and traf- been made to provide non-technical fic control. We could support (traffic control, notification).
not locate the functions of social services and transportation.
We recommend that Table 2.0-1 he revised to the DOI and to include the primary responsibil-ity designations for the DOI USCG, the Yankee Atomic Mutual Assistance Plan, and FAA.
We note that Attachment IP 2.14 Attachment 4 will be revised in 16 C.5 4 to IP 2.14 directs the the next amendment to correctly reflect ORO Local EOC Llatsons to re- that the school and special population quest authorization from liaisons do not report to the local Local EOC officials for EOCs.
Page No. DRD-2 C/SS51/0.2
t 1988 PLAN REVIEW
' DRAFI REPORI RESOLUTION TRACKING d
APPROVAL:
0 ORO i N = Naine
- NH = New Hampshire
! iiiP0ff! REilRENCE PAGE REPORT ISSUE CCT CORRECTION ACTION APPROVAL AFFECTED SECTIONS j NUNBER ITEN NO. N'JNBER school and special popu-l 16 C.S lations to report to ORO
) (cont'd) local EOCs, which is in-
! consistent with the con-cept of operations for this function that was changed in Amendment 6.
- We could not locate Copies of the leases for the VANS 24 E.6 leases or Letters of Staging Area are available for review 020 Inadequate Agreements for VANS Sta- and will be included in the plan of ging Areas in Appendix C. record Appendix C in the next amendment.
We could not locate Figure 5.2-12, which is Copies of the VANS Staging Area layout supposed to be the VANS diagrams are available for review and Staging Area layout. will be included in the plan of record in the next amendment.
(1) Tone alert radios are to be offered to schools, As stated in the plan, distribution of day care centers, nursing tone alert radios will not occur until homes, hospitals, medical licensed for operation above 5 percent facilities, campgrounds, power.
businesses with 50 or more employees at one localica, and other selected factitties with- '
In the plume EPZ as a Page No. ORO-3 _
C/SS*A70.3
1988 PLAN REVIEW DRAFI REPORT RESOLUTION TRACKING APPROVAL:
02 ORO M = Maine NH New Hampshire itEPORI REFERENCE PAGE REPORT ISSUE CCT CORRECTION ACTION APPROVAL ,AFFECTED SECTIONS MUMBER ITEM NO. NUMBER backup system (p.
24 E.6 3.2-15). These tone ORO Inadegaate alert radios have not (cont'd) been distributed at this time.
The Vehicular Alert and The Vehicular Alert and Nottitcation Nottitcation System 15 System is scheduled for completion upon not operational at this license to operate above 5 percent time. power.
The Plan does not address The plan does not address ORO direct -
28 F.1.b communications with local communication with the local governments ORO governments in New in New Hampshire, in order to adhere to Hampshire. the command and control concepts out -
lined in the IG1RERP. Overall, the state figure 4.0-1 states that will coordinate any actions necessary on MAGI is an additional Dehalf of the locals and in this manner backup casumnications maintain positive control of the link between the New response resources.
Hampshire State EOC and the ORO EOC, which is MAGI is a multi-component radio system inconsistent with the which RACES is one component. However, statement in Appendix H to avoid confusion, Figure 4.0-1 will bc (p. H-91) that RACES is revised, in the next amendment to indi-the link. cate that RACES, the more specific designation, is $he backup communica-
, tions link.
Page No. ORO-4
. C/5% I/0.4 I
1988 PLAN REVIEW DRAFT REPORT RESOLUTION TRACKING APPROVAL:
0 = ORO M = Maine NH = New Itampshire REPORE REFE9ENCE -
PAGE REPORT ISSUE CCI CORRECTION ACTION APPROVAL AFFECTED SECTIONS NUMBER ITEM NO. NUMBER
~-~
Figure 4.0-1 states that NAGI ts a multi-component radio system 1 29 F.1.c MAGI 15 a communications of which RACES is one component. How- ORO link between the ORO EOC ever, to avoid confusion, figure 4.0-1 and FEMA, which is incon- will be revised, in the next amendment, sistent with the state- to indicate that RACES, the more specif-ment in Appendix H (p. ic designation, is the connunications H-82) that RACES is the link.
link.
We could not locate the Cellular mobile telephones are only pro-30 F.1.d legend on Figure 4.0-1 vided to the Local EOC Liaisons and ORO ORO for cellular mobile tele- Directors. This will be added to Figure phones. 4.0-1 in the next amendment. Addition-ally, cordless telephones are available The figures showing the in the Monitoring Tra11ers and EWF.
layout of the Monitoring Figures 5.2-9 and 5.2-10 will be revised Trailers (Figure 5.2-9) in the next amendment, to reflect this.
and the Emergency Worker Fact 11ty (Figure 5.2-10) do to show any commur.1-cations equipment in these trailers.
Not all communications The field communications radio system 32 F.3 systems described else- does include the stated radio networks ORO where are expressly con- and as such, is included in the appro-tained in the testing priate testing schedule.
schedule. These are the I
Page No. ORO- 5 _
C/SSS1/0.5
1988 PLAN REVIEW DRAFT REPORT RESOLUTION TRACKING APPROVAL:
0 = ORO M = Haine Nil = New Hampshire REPORI REFERENCE PAGE REPORT ISSUE CCI CORRECTION ACTION APPROVAt AffECTED SECTIONS NUMBER ITEN NO. NUMBER NHY ORO Emergency Radio 32 f.3 Network, the PSNH Radio ORO (cont'd) Network, Marine Sand Radio, American Red Cross radio, and EMS radio. It is assumed that these radio systems are in-cluded in the "fleid -
Radio Communications System" referred to in the testing schedule.
If not, then there is no testing schedule for these radio systems.
~~
We could not locate the Appendix L includes in the fourth field
~
35 G.2 distributton list for the of the printout whether the farm is ORO Inadequate Farmer's Brochure located inside the plume EPl. The list-(Appendix L). Ing of positive responses constitutts the distribution list for the farmer's The public education pro- Brochure. A note will be added to the gram has not been imple- text of Appendix L. In the next amend-mented. ment, to identify this as the distribu-tion list for the farmer's Brochure.
The public education program will be effectise once licensed to operate above 5 percent power.'
Page No. ORO-6 _
C/SS54/0.6
l 1988 PLAN REVIEW DRAFI REPORT RESOLUTION TRACKING APPROVAL:
04 ORO N = Na1ne NH = New Hampshire
~
li(P0RI REFERENCE PAGE REPORT ISSUE CCT CORRECTION ACTION APPROVAL AFFECTED SECTIONS NUMBER ITEN NO. NUNBER .
We could not determine IP 2.12 will be revised, in the next 37 G.4.4 from IP 2.12 how the NHY amendment, to indicate how the EOC and ORO Offsite Response EOC and JTIC receive other organizations new the JTIC receive copies releases.
of other organizations' new releases from the Media Center.
The Plan does not contatri The forinat and content of the inventory 43 H.ll lists of emergency kits Lists will be reviewed and revised, as ORO according by the general necessary, for the 1989 annual update.
category specified in this criteria.
The procedure for air During an emergency, stiver zeolite 47 I.9 sampling using the porta- cartridges are provided, which do not ORO ble air sampler does not have a specific affinity ist noble include purging of the gases. Therefore, purging is not nec- :
cartridges prior to essary, and is a marginal contributor counting. when counted.
The Table 3.3-1 checklist Iable 3.3-1 and IP 2.3 checklists for and the IP 2.3 checklist field team kit inventory will be should be consistent with revised, in the next amendaent, to be respect to quantiti?s of consistent.
supplies: e.g., suggest using 30 silver zeolite cartridges for both checklists.
PJge No. ORO / , _
' C/S% 1/0./ t
1988 PLAN REVIEW DRAFT REPORT RESOLUTION TRACKING APPROVAL:
Oa ORO M = Maine Nil = New llampshire REPORI REFERENCE PAGE REPORT ISSUE CCI CORRECTION ACTION APPROVAL AFFECTED SFCIl0NS NUMBER ITEN NO. NUMBER The field survey / air 48 1.10 sample calculation work- Refer to Attachment 1. OR0 sheet. IP 2.2, page 41, should have a time de-pendent dose conversion factor to use with the gross cpm todine measure-ment. This will help -
prevent over estimation of lodine exposure rates.
The ingestion PAR sec- The modcling tools used to determine Lions lacks any discus- the sample plan will be described in ston of distance and dir- the plan and detailed in the procedures ection or the type of PAR in the next plan amendment.
to be considered (Preven-tive or Emergency}. ,__
~Ihe Plan describes a _lhe Vehicular Alert and Notification 54 J.9 Vehicular Alert and System 15 schedule for completion upon ORO Inadequate Notification System that license to operate above 5 percent would be utilized to power.
alert the public. We note that the Vehicular Alert and Nottftcation System is not available for use.
Appropriate Alert and Nottftcation systems have not been established. Page No. ORO-8 C/SS54/0.8
1988 PLAN REVIEW DRAFI REPORI RLSQLUTION TRACKING APPROVAL:
0 = ORO M = Maine NH = New ilampshire REPORT REFERENCE PAGE REPORT ISSUE CCT CORRECTION ACTION APPROVAL AFFECTED SECIl0NS NUMBER ITEM NO. HUMBER A map of pre-selected A comparable grid system has been estab-55 J.10.a radiological sampilng and lished and has been adopted by the ORO monitoring points was not States of New Hampshire and Maine, as found. See statement in well as the onsite organization. As I.8. provided in the J.10.a criteria, this system meets the provision of an equiva-lent uniform system and is described in each of offstte plans.
Population distributton Population distributton data will be 55 J.10.b around Seabrook Station provided in a map form by ERPA, in the ORD is shown in tabular next amendment.
(rather than map) form for the six towns in the plume exposure EPZ in Table 1.3-1 and Table 3.6-1.
Pending installation of The Vehtcular Alert and Nottf tcation 56 J.10.c the Vehicular Alert and System is scheduled for completion upon ORO Inadequate Nottf1 cation System, this license to operate above 5 percent element is inadequate. power.
There currently exists 9 bus compantes 60 J.10.g We could not deteomine with 1 yard a piece. The number of ORO how many bus yards there yards is not specifically stated in the were. plan or procedures, as the location of buses available to respond at the tiac of an emergency may vary and the Bus Company Liaison's procedure direct him to accoasnodate the number of yards available at the time of resp 3nse with the 12 Bus Dispatchers provided in the Organization, per the plan.
Page Nc. ORO-9 C /SS';1/0.9
1988 PLAN REVIEW DRAFT REPORT RESOLUTION TRACKING APPROVAL:
0 = ORO M = Maine NH = New Hampshire REPORT REFERENCE -
PAGE REPORT ISSUE CCI CORRECTION ACTION APPROVAL AFFECTED SECTIONS NUMBER ITEM NO. NUMBER
+ Although we located The separate ETEs for the Massachusetts 64 J.10.1 separate estimates for beaches are subsumed in the ETE for the ORO the Massachusetts beaches town. The PAR decision-making process (ETE Table 10-9 p. does not include the separate provision 10-11), these are not of evacuation of the beaches only, an embodied in the relevant evacuation is ordered by town (or more procedure for determining precisely a ccabination of towns in the PARS (IP 2.5. Att. 4). fona of an ERPA). The options of an Furthenmore, we could not evacuation PAR 1s limited to one or both determine whether the of two ERPAs. The ETEs do include the evacuation time estimate entire refuge in its demand estimate per included the entire the Applicant's Direct Testimony Number Parker River National 7, p. 34.
Wildlife Refuge in its demand estimate and Provistoas for the Water Safety Zone are evacuation time estimate described in the U.S. Coast Guard Plan, for Plus Island. We including messages to boaters. Harbor could not locate an locations would be determined by the evacuation time estimate USCG at the time of the emergency based for boaters. conditions and wind direction.
IP 2.10 (Att. 2) assigns The priority system for evacuating priorities for evacuating special facilities is being reviewed and special factittles. We the plan in section 3.6 will be revised could not locate in the in the ;989 annual update to state the Plan the methodology usea basis for determining the special factl-to assign those prior- itles priorttles. Based on lessons -
lties. NHY indicated learned from the exercise and other com-Page No. OR0- 10 _
C/SSS4/0.10
1988 PLAN REVIEW DRAFT REPORT RESOLUTION TRACKING APPROVAL:
0 ORO M = Maine Nil - New ilampshire REPORI RtFERENCE PAGE REPORT ISSUE CCT CORRECTION ACTION APPROVAt AFFECTED SECTIONS NUMBER ITEM NO. NUMBER 64 J.10.1 during conversations witti ments received, the priority scheme is (cont'd) FEMA staff ... however, being reassessed to account for the ERPA individual evacuation affected, the type of special popula-time estimates for these tion, and the facility location.
fac111ttes were not in- Furthermore, prowlsions to coordinate cluded in the method- the priority system with the notifica-3 logy for detenntning tions provided by the School and Special Population Liaisons are being made.
these priorttles. We could not determine the effect of the placement The differences between the ETE study of road crews upon the and the SPMC are being reviewed and the capacity to remove ETE is being evaluated for revision to traffic impediments be- reflect the current planning concepts.
cause four of the five (i.e.. road crew placement, Iransfer transfer points do not Point locations) coincide with the recommended tow truck locations (in the ETE).
The ETE specifies a strategy for providing transportation assistance to the transient depen-dent persons. This strategy specifies certain transfer point Page No. ORO-Il__
C/SS5170.ll
C
= ..;.
1988 PLAN REVIEW DRAFT REPORT RESOLUTION TRACKING APPROVAL:
0 = ORO N = Naine NH = New Hampshire REPORI REFERENCE PAGE REPORT ISSUE CCT CORRECTION ACTION APPROVAL AFFECTED SECTIONS NUMBER ITEM NO. NUMBER 64 J.10.1 locations which may be (cont'd) different from those spectfled by the NHY ORO transportation plan (IP 2.10). Because different transfer point locations are used, the route travel times are no longer consistent with the ETE strategy (compar-ison of Table 11-8A, ETE, and Att. 9. IP 2.10).
~
Reference to the Yankee Appendix f will be revised in the next 100 P.6 Atomic Mutual Assistance amendment to include the Yankee Mutual Plan could not be located Asststance Plan and delete that the in Appendix F. The Parker River and EBS station p34ns are Parker River National under development.
Wtidlife Refuse Emergency Response Plan and the EBS Station Plan are listed as being "under develop-ment."
Page No. ORO-12 C/SS5470.I2
1988 PLAN REVIEW DRAFT REPORT RESOLUTION TEACKING APPROVAL:
0 = ORO M = Maine NH = New ilampshire REPORI REFERENCE PAGE REPORT ISSUE CCT CORRECTION ACTION APPROVAL AFFECTED SECTIONS NL9eBER ITEM NO. NUNBER A-1 REP 11 Revise text of PI mater- The text of the PI materials will be ORO thru tal in the mark-ups pro- printed in the form as proposed prior A-29 vided (7/27/88). to issuance.
A-17 REP 11 In order to avoid the In completing the calendar, the. survey ORO Item 32 possible loss of the sur- card will be attached.
vey card / sticker prior to the initial reading of document, we recommend that the postage paid card be either sewn or stapled to the document.
A-25 REP 11 Insufficient information Upon printing the colors will then be ORO Item 51 to evaluate proposed available for evaluation.
color use, for color blind persons, at this time.
8-7 REP 11 Consider including the A retention statement will be added on ORO Item 8 words "Read and Save" in the front and back of the document.
the retention statement Place retention statement on the front and back sides of the document.
Page No. OR0-13 C/S% UO.13
.4 . . . !
1988 PLAN REVIEW ORarr REPORT RESOLUTION TRACKING APPROVAL:
0 = ORD N = Ma be ist - New Hampshire
~
REPORI REFERENCE PAGE REPORT ISSUE CCI CORRECTION ACTION APPROVAL AFFECTED SECTIONS NUMBER ITEN NO. NUMBER 8-10 REP 11 Change the location of The order of presentation of the radia- ORO Item 17 the information on radia- tion information will be revised.
4 18 tion and its effects to avoid delaying the presentation of tagsrtant emergency information.
The order of presentattosi 8-11 REP 11 of the sections "about The order of presentation of the ORO Item 20 safety at Seabrook" and Radiation information will be revised.
"distracts and interrupts the presentation of more vital instruction and in-formation. Reposition the referenced page else-where in the document.
We reconnend that the 8-13 REP 11 appropriate order of sec- The order of presentation will be ORO Item 23 tions be reviewed and revised.
revised to ensure that vital Emergency Instruc-tion precede other infor-nation.
Review and revise vocabu-8-13 REP 11 lary with stapler word The choice of vocabulary will be re- ORO Ites 24 choices. This restruc- viewed and revised to lower the reading turlag in the text would level.
significantly leprove the readability of the docu-ment. .
Page No. ORO-lj_,
. .. s 1988 PLAN REVIEW DRAFT REPORI RESOLUTION TRACKING APPROVAL:
0 = ORO N = Mats..
NH = New Hampshire REPORI REFERENCE .
PAGE REPORT ISSUE CCT CORRECTION ACTION APPROVAL AFFECTED SECTIONS j
Nt yER ITEN NO. NUNBER 8-14 REP 11 Restructure sentence The sentence length will be reviewed ORO Item 25 length. This effort and revised, with the vocabulary, to would enhance readability lower the reading the reading level.
and emergency utility.
As mentioned elsewhere, B-15 REP 11 restructure text, vocabu- The text will be restructured along ORO Item 29 lary and sentence length. with revision to the vocabulary and Target readability for sentence length, to lower the reading grade 9 or below. Ut for- level.
tunate.ly, the current reading level of many of the passages may present problems for marginal readers and hamper the emergency utility of the document.
B-21 REP 11 Develop appropriate Charts, tables and other artwork will be ORO Itot 44. charts, tables, maps and developed, once the text is finalized 45 & 49 artwork. and will be made available for review prior to printing.
Page No. ORO - I S_,
C/SSS470.15 1
1988 PLAN REVIEW DRAFT REPORT RESOLUTION TRACKING APPROVAL:
0 - DRO M = Maine Nil = New ilampshire REPORT REFERENCE PAGE REPORT ISSUE CCT CORRECTION ACTION APPROVAt AFFECTED SECTIONS NUMBER ITEM NO. NUMBER 8-24 REP 11 Color use cannot be Upon printing, the colors will then be ORO ltem 51 judged at this time. available for evaluation.
~
Page No. ORO-16 C/SSS470.16
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t ao.n,s.
CERTIFICATE OF SERVICE
'88 g;T 26 PS :38 I, Jay Bradford Smith, one of the attorneys for the Applicants herein, hereby certify that on October 24, 1988, I made service of the within document by mailing copies
thereof, postage prepaid, to: GuCm ja :,,4 Administrative Judge Ivan W. Smith, Stephen E. Merrill, Esquire Chairperson Attorney General Atomic Safety and Licensing George Dana Bisbee, Esquire Board Panel Assistant Attorney General U.S. Nuclear Regulatory Office of the Attorney General Commission 25 Capitol Street Washington, DC 20555 Concord, NH 03301-6397 Judge Gustave A. Linenberger, Jr. Dr. Jerry Harbour Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Robert Carrigg, Chairman Diane Curran, Esquire Board of Selectmen Andrea C. Forster, Esquire Town Office Harmon & Weiss Atlantic Avenue Suite 430 North Hampton, NH 03862 2001 S Street, N.W.
Washington, DC 20009 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of the Executive Legal Board Panel Docket (2 copies) Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory '
Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street i
Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 '
Philip Ahrens, Esquire Mr. J. P. Nadeau Selectman's Office ;
Assistant Attorney General Department of the Attorney 10 Central Road .
General Rye, NH 03870 Augusta, ME 04333 i
I l
i f
4 5
e Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney 25 Maplewood Avenue General P.O. Box 360 One Ashburton Place, 19th Fir.
Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Kensington, NH 03827 126 Daniel Street Portsmouth, NH 03801 Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Clark, Hill-Washington, DC 20510 Whilton & McGuire (Attn Tom Burack) 79 State Street Newburyport, MA 01950 Senator Gordon.J. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 507 Kopelman & Paige, P.C.
Concord, NH 03301 77 Franklin Street (Attn: Herb Boynton) Boston, MA 02110 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Foderal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmas & Ells Hampe and McNicholas 47 Winnacunnet Road 3b Pleasant Street Hampton, NH 03841 Concord, NH 03301 Mr. Richard R. Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street, 2nd Floor Agency Newburyport, MA 01950 Federal Regional Center 130 228th Street, S.W.
Bothell, Washington 98021-9796 O
5 t
Ashod N. Amirian, Esquire 376 Main Street John H. Frye, III, Alternate Haverhill, MA 01830 Chairman Robert R. Pierce, Esquire Atomic Safety and Licensing Board Panel Atomic Safety and Licensing U.S.
Board Panel Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 James H. Carpenter, Alternate Technical Member Atomic Safety and Licensing Board Panel b.S.
NuclearDC Washington, Regulatory Commission 20555 A S..o</ a &c = k Jay Bradford $mith -