ML20205K419
| ML20205K419 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/25/1988 |
| From: | James Smith, George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | MASSACHUSETTS, COMMONWEALTH OF |
| References | |
| CON-#488-7394 OL, NUDOCS 8811010125 | |
| Download: ML20205K419 (238) | |
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- 93. # 0 1e a:T 28 P3:28 October 25, 1988 CF' R I . , '.
00Crtglgg.,',[,n UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LTCENSING BOARD
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In the Matter of )
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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW RAMPSHIRE, et al. ) 50-444-OL
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(Seabrook Station, Units 1 and 2) ) (Off-site Emergency
) Planning Issues)
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APPLICANTS' RESPONSE TO "(MASS AG'S] FIRST SET OF INTERROGATORIES TO APPLICANTS ON TME (SPMC]"
i Pursuant to 10 C.F.R 4 2.740b, Applicants respond to Mass AG's "First Set of 7 :ercogatories to Applicants on the Seabrook Plan for Massachusetts Communities (SPMC)."
Due to the confidential information they contain, these pleadings will bu redacted on all copies except those being 4
served on members of this Atomic Safety and Licensing Board and counsel for active parties.
Inn,erroaatory No. 1
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Identify the pwrson(s) who prepared the answers to each of the following interrogatories and all persons who provided information for the preparation of the answers to each of the 1 following interrogatories.
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l Aeolicants' Response Applicants object to this Interrogatory on the grounds that it is burdensome, as well as irrelevant, to identify "all persons who provided information for the preparation of the answers to each of the following interrogatories."
Without waiving the foregoing objections, Applicants respond as follows:
Persons Preparing and Providing Information for Inteiroaatory No. Preparation of the Following Responsesl 2 B. Aidikoff, J. Baer, A. Callendrello, W. Renz 3,7,8 E. Liaberman, J. Sobotka
, 4,15,16,17,19,20,25,27,28 R. Boyd, M. Lewis 18 C. Frank, M. Lewis ,
5,10,13,14 D. Bovino, M. Hawkins 6,34,35,38,40,45 J. Ellis, S. Perkins-Grew, 51,52,53,58 K. Jackson
? J. Ellis, P. Casey 11,21,24 R. McCormack 12 C. Frank 22 W. Thorpe 26 J. Bisson 29,30,31,32,36,39,41,42 D.Tailleart, F. Straccia 43,44,46,47,50,54,57,59 1
Persons identificd as responsible for Interrogatory No. 2 also provided overall review and final preparation of responses.
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h 33,37,48 R. Thompson l 59,56 N. Liewer
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Interroaatorv No. 2 For each of the SPMC contentions admitted, please:
(a) Describe in detail your position with respect to the coattention and all facts underlying your position; (b) State the source of each such fact. If the source I is the personal knowledge of one or more persons, identify the person (s). If the source is one or more documents, identify the document (s);
(c) Identify any expert witness who is to testify concerning the contention, state the subject matter on which the expert is expected to testify, state the substance of the facts and opinions to which the expert is expected to testify, and summarize the grounds for each opinion; (d) Identify any non-expert witness who is to testify concerning the contention, and state the substance of the facts to which the witness is expected to testifyr and l
(e) Identify any documents which reflect or refer to any type of study, calculation or analysis bearing upon the substance of the contention.
Applicants' Response See Attachment "A".
(c) Applicants object to this subpart of the interrogatory 1
insofar as it calls for the exposure of litigation strategy, attorney work product, and attorney-client privileged materials. Without waiving the foregoing objections, Applicants respond as follows: expert witnesses have not yet been selected.
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(d) See response to Interrogatory 2(c). Without waiving the foregoing objections, Applicants respond as follows:
witnesses have not yet been selected.
Interroaatory No. 3 Regarding the evacuation time estimates ("ETEs") for the Massachusetts (at page 20):
communities listed on Attachment 4 to I.P. 2.5 (a) Describe in detail how, when, and by whom those ETEs were calculated. Identify any and all documents which describe how these calculations were made.
(b) Was the IDYNEV model used to calculate thase ETEs? If so, what changes, if any, were made to the IDYNEV model itself frcm the form in which it was used to calculate the ETEs contained in Volume 6 of the NHRERP? Identify any and all documents which describe these changes.
(c) Describe all assumptions and input variables I
used in calculating the SPMC's ETEs that differed from those used in calculating the ETEs contained in Volume 6 of the NHRERP. For each new assumption or input variable, state the source of or the basis for it. Identify any and all documents which describe those new assumptions and input variables and also those which describe the bases for these changes.
l (d) Describe all efforts which have been undertaken to modify the ETE study set forth in Volume 6 of the NHRERP to account for the circumstances that will pertain in Massachusetts to an evacuation carried out pursuant to the
! SPMC. Identify any and all documents which describe these
) changes.
I l (e) In calculating the ETEs for the SPPC, what specific assumption (s) were made regarding when the traffic control posts would be staffed? E.g., was it assumed that TCPs would be staffed at the point of a beach closing 1
announcement? At the point when the order to evacuate was issued? Some other time?
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) l Annlicants' Resnonse !
(a) A complete set of ETEs was calculated just prior to and shortly following the filing of testimony for the New Hampshire hearings. The ETE entries in Attachment 4, on p. 20 of IP 2.5, Rev. O, Amendment 4 are taken from this t
set. Specifically:
1 The ETEs for 5 miles are those for Region 8.
The ETEs for 10 miles are those for Region 13.
Region 8 3.ncludes ERPA A and B.
Region 13 includes ERPA A through E.
These ETEs were calculated by Karla Sharidan of KLD t i
Associates, Inc. under the direction of Mr. Edward Lieberman, using the same version of the IDYNEV Model as was used previously for all other Saabrook Station ETE calculations.
(b) Yes. No changes to this version of the IDYNEV model were used. ;
(c) The following is a summary of changes to the '
IDYNEV input streams used to calculate ETE fur the Seabrook 1 l
Station EPZ. The following describes the sources and bases i for these changes keyed by item number:
i 1, 2 Self-explanatory 3,4,5,6 Changes made for consistency with Traffic !
Management Plan and recommended routing 7 !
Corrected prior omission
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f 8 Se1f-explanatory 9 More realistic representation of "through" traffic (i.e., external-external trips through the EPZ).
10 This change was to provide a more realistic deployment of population within f
Exeter. Due to a key-in error, the j
{ change decreased the vehicle population by 40 vehicles, which is in error. j 11 Self-explanatory The follouing represents all the changes made to i
Seabrook data sets as of September 1987. f
- 1) Scotland Road: "
r The network link representing Scotland Road in Newbury I had been defined incorrectly as (91,267). A new link i (91,263) was created to correct this error.
- 2) Byfield Residents: !
A new centroid number 2120 was created to generate 220 ;
t vehicles from Byfield on access link (186,267). l Existing centroid number 2080 was reduced by the 220 vehicles. This change improved the representation of I population deployment. E
- 3) I-95 in Hampton:
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Vehicles traveling North on I-95 will remhin on I-95 and i i not go West onto Route 51. See link (201, 238).
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i f 4) Route 101C in Hampton:
Vehicles traveling West on Route 101C will not be allowed to continue West on Route 51, evacuees will go North on I-95. See link (73, 237).
- 5) US1 in Hamptont vehicles traveling North on US1 will continue North on US1 or North on Route 151. See link (72, 71).
Route 101 in Exeter:
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Vehicles traveling West on Route 101 will continue West on Route 101. See link (310, 215).
- 7) Route 125 in Brentwood:
Added de72ination Node 80055 to allow vehicles traveling North on Route 125 to continue North. See link (300, 320).
- 8) Headways Changed headways from 3.1 seconds to 2.7 seconds on following ramps. This change reflected the ramp p capacity values in Table 5-5 of the HCM.
( 35,226) (259,258) (242,241) (235.236) (206,207)
(103,248) ( 45,253) (287,266) (249,250) (237,235)
(192,303) (108, 94) ( 45,255) (268,269) (253,255)
(212,212) (202,201) (167, 94) ( 88, 96) (278,277)
(238,235) (216,215) (206,205) (169, 96) (280,279) i n 9) . 'itialization Process:
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) Created two links (226,201) and (238,201) on I-95 to implement loading of vehicles onto the major through ;
route for initialization. Newly-created centroids 2300 i i
and 2301 will access these links. To implement this new l initle'ization process, the type 03 card was changed to t
} specify a new time period for 5 minutes (time period 1) !
and the type 02 card was changed to specify a 20-minute >
"fill" time.
- 10) Vehicle Generation:
The total number of vehicles generated by centroid 2010 [
f on link (135,136) in Exeter was increased by 104 "
vehicles, i
The total number of vehicles generated by Centroid 2014 3
on link (136,137) in Exeter was decreased by 144 '
vehicles.
- P l 11) Tourist (beach) Vehicles:
2036 2054 2063 2081 2082 2093 !
2094 2095 2105 2108 2107 2108 !
2109 2110 2111 2112 These new input streams, which document these changes, were !
provided previously to the MAG in response to production :
L requests regarding the NMRERP. !
(d) None beyond the changes described in the response to 3(c).
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? (e) The ETE does not assume a specific time that ~
the traffic guides are in place. Rather, the ETE assumes 4
that traffic guides man the TCPs when the traffic volumes l approaching that TCp attain a "significant level." By +
t "significant level" we mean the volume at which evacuation
- j. flow benefits by actions taken by the traffic guides such that the resulting evacuation times are represented in the ETE study.
Interroaatory No. 4 t
List the road crew companies currently being relied upon I to supply road crews in the event of a radiological emergency at Seabrook Station and for each crew list the following: ;
(a) The name location and business phone number of the owner or manager,t i (b) The number and kind of vehicles which the companies have agreed to provide and whether these vehicles {
have two-way radios;
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(c) The number of drivers each company has agreed '
to provider
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(d) The names, addresses, and phone numbers of I
, each of these driverst ,
j (e) Any and all known conditions, limitations, -
a reservations, or uncertainties regarding the 24-hour per day,
!. year-round availability of thesa vehicles and drivers; and ,
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(f) Any and all known conditions, limitations, t i
reservations, or uncertainties regarding where the company or the drivers have agreed to drive in the event of a t radiological emergency or what they have agreed to do. i l Aeolicants' Response !
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(a) '
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(b) 1 (c)
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Applicants object to this subpart of the Interrogatory I
insofar as it seeks residential addresses and phone numbers.
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) (e) Per the contract the contractor shall "promptly after notification of an emergency" make available all requisitioned manned vehicles.
(f) Applicants know of none.
1 Interroaatory No. 5 How many road crews will be prepositioned at each of the local Transfer Points in the Massachusetts EPZ, and at what point in the mobilization process will these road crews be dispatched to Transfer Points?
Apolicants' Resoonse Road crews are assigned and dispatched in accordance with Implementing Procedure IP 2.10 Section 5.4.7.B and 5.4.7.C.
Interrocatory No. 6 For each of the NHY OR0's Traffic Guidest s l
} (a) State the Traffic Guide's name, home and work addresses, and phone numbers.
(b) State the number of hours of experience she/he ,
has had directing actual traffic. '
Acolicants' Resoonse ;
Applicants object to subpart (a) of the interrogatory t
insofar as it seeks residential addresses and phone numbers. !
Without waiving the foregoing objection, Applicants respond as follows:
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4 l The informat; ion requested under (a) is maintained as part of a computtr data base at Seabrook Station. Because of i
the large volume of information requested, a redacted copy of a computer printout containing the requested information will be made available for inspection at seabrook station.
With regard to part (b), the number of hours of experience each traf fic guide has in directing actual traffic t is not known to Applicants. However, practical experience is part of the training offered by the ORO. The hours of practical experience are shown on the computer printout r
referred to above and are based on training sessions involving mock traffic.
Interroaatory No. 7 Have evacuation time estimates been determined for the transit dependent population, the special facilities, and schools in the Massachusetts EPZ? If so, state these ETEs and describe how each one was determined. Identify any and all documents which concern these ETEs.
1 Anelicants' Resoonsa Yes, evacuation time estimates were estimated for the groups identified in the interrogatory. The ETEs and the methodology for their determination are described in the Seabrook Station Evacuation Time Study, NHRERP, Volume 6, pages 11-1 through 11-27.
Interroaatory No. 8 In the event of a summertime emergency at Seabrook Station, does NHY's ORO intend to use the summertime ETEs set forth in Appendix 4 of I.P. 2.5 regardless of the weather,
i j size and distribution of the beach aren populations, large crowds at special event days, the time of day, or the existenea of o* her coriditions which vary from those assumed when sne ETEs were determined? If not, how aru adjustmentt
'to the ETEs to be made to account for t!.ese variations and who w!,ll make these adjustments?
Aeolicants' Resoonse
) There is no Appendix 4 to IP 2.5. Assuming the interrogatory relates to Attachment 4 of IP 2.5, tite OP O I
intends to use the summertime ETEs set forth therein subject to the instructions provided in step 5.5.4 of IP 2.5.
Interrocatory No. 9 Identify the person (s) in NHY's ORO who is most knowledgeable about:
(a) the ETEs and how they would be used in an emergency; (b) the evacuation process and the traffic management plan.
Aeolicants' Resconse Applicants do not know the specific knowledge that each ORO member has. However, persons filling the following positions are trained to be knowledgeable in the identified areas to the extent needed to implement the SPMC:
(a) Asst. Director, Response and Implementation Accident Assessment Coordinator (b) Evacuation Support Coordinator Staging Area Leader l
Interrocatory No. 10 Does the SPMC rely on the efforts of the Commonwecith of Massachusatts to post noticos and/or distribute pre-emergency informational materials to the transient population at Salisbury Beach State Reservation and along the rest of Salisbury Beach to ensure that the transients there will know what to do when and if the VANS sirens sound in the '
Massachusetts beach areas? If not, how will those transients know what to do?
Aeolicants' Resoon12 No, the program to provide public information materials to all persons including transients is described in Section 3.7.2 of the SPMC. The program includes materials that will be made available to a number of facilities visited by transients including state psrks. If despite this program, a transient is not familiar with the actions to be taken it is expected that they will seek information from other persons.
Interrocatory No. 11 With respect to the use of cones and barricades at Access Control Points and Traffic Control Points:
cones; (a) Describe the exact dimensions of the traffic barricades; (b) Describe the exact dimensions of the (c) State how many traffic cones and how many barricades NHY's ORO har avsilable, and state where these items are stored prior to an emergency.
(d) Identify any current contracts for the supply of these cones and/or barricades.
(e) In Appendix J, a note on each Traffic Control Summary and Access Control Summary (see, e.g., p. J-21) states: Three Cones May Be Used In Place Of One Barricade."
l Has the decision a"6 ready been made to use cones instead of barricades for particular TCPs and/or ACPs? If so, which ones? T.f not, when and on what basis will this decision be made, and who will make it?
Aeolicants' Resoonse '
(a) The traffic cones are 28-1/4" high overall. The j base is 14-1/2" x 14-1/2" x 1-1/4" high. The tapered portion
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of the cone varies from 2" in diameter at the top to 10-1/2" in diameter immediately above the base. i Note: All dimensions are approximate.
1 (b) There are no plans to use barricades at Access and !
Traffic Control Pointst 1 (c) NHY ORO has 850 traffic cones available for use at Access and Traffic Control Points. These cones will be stored at the Haverhill Staging Area.
(d) There ace no current contracts.
(e) The decision has been made to use cones instead of barrite. des. This decision applies to all Access and Traffic Control Points.
Interrocatory No. 12 a Point 8 in both the TCP and ACP procedures (p. J-2 and J-4) states that upon arrival at TCF2 and ACPs, the Traffic Guides are to wait at the side of the road until notified to activate the post. The procedures go on to state as follows:
"However, if traffic problems occur, expedite traffic flow and report the situation to the Evacuation Support Dispatcher." Describe what is meant by "traffic problems" and "expedite traffic flow".
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I Aeolicants' Reseense "Traffic problems" are situations to be reported and would include road work in progress, traffic already diverted, unusual road conditions, and vehicular problems i such as stalls, flat tires, or occurrence of an accident.
"Expedite traffic flow" in this context refers to offering to assist motorists with vehicular problems.
L Interrocatory No. 13 '
Describe what, if anything, NHY's ORO, using the SPMC, intends to do regarding the Gillis Bridge in the event of a radiological emergency at Seabrook Station on a day when there is heavy boating traffic on the Merrimack River.
L Aeolicants' Resoonse '
Applicants do not understand uhat the interrogatory means by "heavy boating traffic" and the impact that it may have on the Gillis Bridge.
If, during an evacuation, the Gillis Bridge was i identified as an impediment to evacuation, the situation would be evaluated and traffic rerouting would be considered and implemented as required.
Interrocatory No. 14 Describe what, if anything, NHY's ORO, using the $PMC, intends to do to notify and instruct boaters on the Merrimack i River, especially those without radios on board, in the event of a radiological emergency at Seabrook Station. l L
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Aeolicants' Resoonse Boaters on the Merrimack River are notified via the activation of the siren system (SPMC, section 3.2 at page 3.2-14). Boaters with marine band radios are expected to obtain instructions from the U.S. Coast Guard by tuning to the marine band radio channels. In accordance with pro-emergency public informaticn, boaters with AM/FM radios are expected to obtain instructions from an EBS station (SPMC, Section 3.7.3.A at page 3.7-5). Boaters without radios on the Merrimack River, upon hearing the sirens, may seek information from other boaters or individuals in the area.
Interroaatory No. 15 Identify any and all documents and correspondence which relate to the use of the host special facility during a radiological emergency at Seabrook Station.
Arolicants' RenDonse The following documents and correspondence which are in the Applicants possession relate to the use of the host facility:
- 1. Record of Conversation dated 8/20/87 between Tom Byrne, NHY and
- 2. Contract dated 9/4/87 between NHY and
- 3. Memorandum dated 8/26/88 from Tom Byrne, NHY to Mike Lewis, NHY regarding Elevator and Handicapped Ramps.
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- 4. SPMC, IP 1.6; Appendix C pp. C-76 to C-85, Appendix M.
l Interrogatory No. 16 State what arrangements have been made, if any, to ensure that when the host special facility is hosting a circus, rodeo, or other similar event, the floor space being relied upon in the SPMC will be available for SPMC purposes
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Acolicants' Resoongg Early notification uf the host special facility at the ALERT ECL is intended to allow time for preparation prior to the recommendation of protective actions, see SPMC IP 1.6.
In the event of an evacuation, the host special facility staff would remove event materials to accept evacuees.
Interrogatory No. 17 Describe how, absent pre-planning, the American Red Cross will be able to set up and staff the host special facility and the congregate care centers in a timely fashion in the event of a radiological emergency at Seabrook Station.
Aeolicants' Resoonse Planning has been performed by the American Red Crosu in anticipation of any radiological emergency.
Interrocatory No. 18 Identify all documerts and correspondence which relate to the participation of the American Red Cross in planning in Massachusetts for a radiological emergency at Seabrook Station.
Anolicants' Response
- 1. Letter - G. Gram (NHY) to R. Saydlowski (ARC), dated 06/09/88,
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I subject - phone lines at chapter house; ARC planning participation
- 2. Record of Conversation (ROC) R. Paddock (NHY) to R.
Saydlowski (ARC), dated 10/21/87 j Subject - Red Cross Volunteer Support Help
- 3. Letter - E. Brown (ARC) to E. Brown (NHY), dated 9/10/87 subject - Agreement to respond to emergency at Seabrook Station
Subject - P.O. for Consulting Services
- 5. ROC - R. Paddock (NHY) to R. Saydlowski (ARC), dated 8/20/87 Subject - P.O. for Censulting Services
- 6. Letter - J. Crafts (NHY) to R. Saydlowski (ARC), dated 8/14/87 Subject - Selection of Congregate Care Centers
- 7. Unidentified Notes - Phone call to R. Snydlovski (ARC),
name/ phone number of ARC Voluntary Consultant for Government Relations and Director of Disaster Services.
- 8. Meeting Notes - Community Interface Com3ittee Meeting, dated 8/13/67
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j Subject - Statement of Understanding with ARC
- 9. ROC - R. Paddock (NHY) to R. Saydlowski (ARC), dated 8/11/87 Subject - Certification of Congregate care Centers.
dated 8/11/87 Subject - Red Cross participation; Congregate Care Center ARC Training for NHY Employees
- 11. Meeting Notes - NHY and ARC, dated 2/10/87 Subject - Host Facilitios for Mass Care Operation by American Red Cross
- 12. Letter - R. Saydlowski (ARC) to T. Harpster (NHY), dated 11/3/88 subject - Introduction and Presentation of ARC Capabilities
- 13. American Red Cross Charter
- 14. American Red Cross Procedure $3074
- 15. Red Cross Preparedness for Nuclear Accidents, American Red Cross Eastern Operations Headquarters, Disaster Services.
Interroaatory No. 19 How much time do you estimate that it will take the American Red Cross to set up and staff the Host Special Facility and each of the congregate care centers after first being notified to do so in the event of a radiological emergency at Seabrook Station? Describe in detail your 4
reasons and/or bases for this estimate, and state the names
and positions of the American Red Cross officials who provided information which supports this estimate.
Aeolicants' Resconse Pse discussions with Robert Saydlowski, (Nuclear preparedness officer, Southern New England Area American Red Cross), staffing of the Host Special Facility will begin within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of notification and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> will be fully staffed. Staffing of the first Congregate Care Centers will be initiated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of notification. Staffing of all Congregate care Centers will be accomplished within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Interrocatory No. 20 Do you contend that the American Red Cross has undertaken some planning for its response in Massachusetts to a radiological emergency at Seabrook Station? If your answer is yes, describe in detail the nature and extent of this planning.
Aeolicants' Response See responses to Interrogatories 17 and 18.
Interrocatory No. 21 What provisions exist for back-up power at the ORO J
EOC/Seabrook Station EOF in the event of a loss of power to
- this facility.
Acolicants' Response Applicants object to this Interrogatory insofar as it seeks information regarding the Seabrook Station Eor, a subject previously litigated before the on-site Board, i
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Without waiving the foregoing objection, Applicants respond as follows:
The NHY offsite Response EOC is provided backup power i
from a diesel generator owned and maintained by New Hampshire Yankee. The Seabrook Station EOF is supplied from PSNH's Newington Station's emergency power supply.
Interroaatory No. 22 In the event of a fast-develeping radiological emergency at Seabrook Station which results in an offsite release of radiation that quickly blows west over I-95, or which threatens to do so, by what route is it anticipated that members of the media based in the Boston area will travel to the Media Center in Newington? How long is it anticipated that such a trip will take?
Aeolicants' _Resconse General diversion routes around the EPZ are specified in Appendix J of the SPMC, pg. J-162. Additionally, specific routing to the media center in Newington is provided to members of the media via personnel at the Joint Telephone Information Center using directions provided in the Joint Information Binder. The specific route recommended to the media if I-95 is closed is as follows: "Take I-93 to Concord. From Concord, take Route 4 East through DVrham into Dover, then Route 4 East into Newington. Take Exit 45, then follow standard directions." The standard directions statet "Take Exit 45 for Nimble Hill Road, Newington. Drive about a mile and you will come to the four corners. The Media Center is in the Town Hall on the left."
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to take approximately two and one half hours from the Boston l
area. I Interroaatory No. 23 In the event of a radiological emergency at Seabrook Station, what facility does ORO intend to use as a Staging (
Area, assuming no changes in the soning laws in Haverhill and i no court decisions which overturn the city's interpretation I of its zoning laws.
Anelicants' Rennense 't Applicants object to this Interrogatory on the ground !
that it calls for speculation based on events unlikely to .
occur. Applicants further object to this Interrogatory on !'
the ground that it calls for legal conclusions as to whether i t
i the Haverhill Staging Area may be used under the Haverhill
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zoning laws as interpreted by the city of Haverhill and the !
I j courts of the commonwealth of Massachusetts.
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l Interroaatory No. 24 '
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What is the capacity of the water storage tanPs in the Monitoring Trailers? -
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Each of the four water storage tanks in the Monitoring l Trailers has a capacity of 300 gallons, j Interroaatory No. 25 t
! Identify any arrangements or provisions for replacing or i
pumping storage tanks, incivding but not limited to, l personnel designated for each replacement or pumping.
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Aeolicants' Resoonse See Response to Interrogatory No. 27 regarding arrangements and proviolons for pumping storage tanks.
Interrogatory No. 26 Describe the procedure for the handling and disposal or contaminated materials, including but not limited to, personnel who would brig, label and set aside contaminated articles belonging to evacuees.
Aeolicants' Response The procedures addressing the handling and disposal of contaminated materials are SPMC, IP 2.9, IP 3.3, and IP 3.4. >
Specifically, the steps addressing the issue are steps 5.2.10, 5.2.21, 5.3.17, 5.4.4, 5.5.8, 5.5.11, 5.7.8, 5.8.3 and 5.8.8 in IP 2.9, step 5.1.15 in IP 3.3, and step 5.1.17 i in IP 3.4.
l Interrocatory No. 27 Identify any documents and/or correspondence related te I L persons employed for secvices related to the handling, i storage and/or disposal of contaminated waste water and/or !
contaminated materials.
Aeolicants' Resoonse The documents aret i
- 1. Sept. 30, 1988; George S. Thomas, N.H. Yankee Division,
, PSNH tor Radwaste Disposalt one pager confirmation that l has entered into a contract with NHY for radwaste disposal and transportation services for waste pursuant to the SPMC.
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- 2. October 13, 19881 to Mr. Jim Bertram Purchasing Department, NHY, Seabrook Station, P.O. Box 300, Seabrook, NH2 one paget respcnse time for personnel during an emergency at Seabrook Station.
i Interroaatory No. 28 i
Pleasw state separately for buses, vans, ambulances, wheelchair vans, and road crews the number of each which you contend can respond and be available for SPMC service in a radiological emergency at Seabrook Stationt j (a) Immediately upon notifications (b) One-half hour after notificationt (c) One hour after notificatient j (d) One and one-half hours after notifications i
(e) Two hours after notificationt
] (f) Three hours after notificationt (g) Four hours after notification.
t I
i Aeolicants' Resconse j
Information in the form requested is not available.
Estimated mobilization times for buses and EMS vehicles are i provided in the Evacuation Time Study, NHRERP, Volume 6, pp.
11-18, 11-19, and 11-22. The number of vehicles can be estimated using this information and that provided in the SPMC, Appendix M.
l Interroaatory No. 29 Identify all the individuals currently working for or on behalf of NHY/ORO as instructors and/or having responsibility for the training of personnel.
~25-
a.
began suchPlease work. state the date each of these individuals
- b. Please describe the prior job experience of each of these individuals from January 1, 1983 to the ;
dates set forth in response to (a) above,
- c. Please state the educational experience e.nd qualifications of each of these individuals. !
d.
Are these individuals (and/or any number of {
them) currently engaged full-time in ORO training activities?
- e. If the answer to (d) above is no for any number I of these individuals please describe their other :
activities including the name of their employers if not !
PSNH or NHY.
i f.
Please set forth the current salaries for each i of these individuals. :
- g. Please identify for each individual the subject areas in which he or she provides treining.
Acolicants' Resnonse (a) Instructors Sept. 1987 - Present NAME START DATE END DATE FULL TIME? SUh3ECT AREA f S1 Nick Liawer 2/01/88 N/A YES A,B,C,0,4,T,G,ll,I Ron Thompson 9/15/87 N/A YES A,B,C,D,E,F,G,H.I KEY To SU5 JECT ARLA(S):
A -
Emergency Plan overview B -
Emergency Managemerit C -
Transportation D -
Health Physics E -
Public Information F -
Communications o -
recilities H -
Traffic Control I -
Protective Actions (b) See resumes included as Attachment B.
(c) See resumes included as Attachment B.
(d) See response to 29(d) above.
(e) No response regoired ,
(f) Applicants object to this subpart of the interrogatory on the ground that the confidential information it seeks is r irrelevant to the issues before the Atomic Safety and l Licensing Board.
(g) See response to 29(a) above. '
Interroaatory No. 30 Identify all the individuals working for or on behalf of NHY/ORO as instructors and/or having responsibility for the training of psrsonnel from Septerher 1987 to the present who are not identified in response to the immediately preceding ,
interrogatory.
- a. Please state the date each of these indivi,$usla l began and terminated such work, i
- b. Please set forth the reasons given b3 of to each individual for the termination of such work. !
- c. Please set forth the most recent information available as to the whereabouts of each individual.
- d. Please describe the prior job experience of each of these individuals from January 1, 1983 to the date each i
began such work.
- e. P4 ease state the educational experience and qualifications of each of these individuals. ;
- f. Please identify for each individual the subject areas in which he or she provided training.
Aeolicants' Resconta (4) See Attachment C.
(b) Applicants object to disclosing the names of those individuals terminated by NHY on the ground that this-would be an impermissible invasion of privacy. See Attachment C.
(c) NHY has no information regarding whereabouts of those individuals who have not been reassigned to another assignment as Seabrook Station. (See Attachment C.)
(d) Resumes are provided on Attachment D.
(e) See response to 30(d).
(f) See Attachment C.
Interrocatorv No. 31 Please state the number of individuals selected as "qualified instructors" (Appendix K at X-6) from April 1, the present time. State the number of those who sought to 1987 to be selected as "qualified instructors" during that tire period but 4
were not selected.
- a. Please identify by name those individuals who sought to be so celected.
boolicants' Resoonse Twenty four individuals sought to be selected as qualified instructors. The names of those individuals are provided in the answers to interrogatorios 29 and 30. Three individuals were denied gr.s.lifi;atior..
I Interroaato_rv No. 32 Does NHY/ORO provide training for those individuals working as instructors and/or having responsibility for the training of personnel?
- a. Please describe the training program provided to these individuals.
- b. Please identify any document generated by or for or as consequence of this training program, including without limitation, lesson plans, tracing materials, evaluation forms and reports, Instructor Guides, and training schedules.
Acolicants' Resoonse Yes.
(a) The ORO instructor skills development class is described in the SPMC, Appendix K, Section IV-A on page K-7.
(b) The Lesson Plan for the course is "Basic Training Staff Development," LP #1334.
Interroaatory No. 33 l
Please identify all the individuals (and if appropriate the entities) involved in the preparation of the training materials described in SPMC, Section 6.0 and Appendix K.
Aeolicants' Resconsq Individuals involved in the preparation of the training materials described in the SPMC, Section 6.0 and Appendix K are listed below:
Jonathan Arms Marshall Pavey Rob Cotter Mark Poudrier Judy Gilbert John Rawlston Sheila Hertel Larry Rundlett Paul Kovach Phil Sallaway Nick Lewis Art Tate Dennis Pachulski Ron Thompson Linda Parlatore Nick Liewer Interrocatorv No. 34 Please identify any document referring to, reflecting or constituting efforts made by "Managers and Supervisors who have personnel designated as members of the (NHY/OR0]" to ensure these personnel "attend the scheduled training and are made available to participate in drills and exercises." SPMC Appendix K at K-3.
- a. Please set forth the substance of any written and/or. oral communication made to "personnel designated as members of the (NHY/OR0]" by those superior to them in the employment hierarchy referring or relating to attendance at Seabrook emergency preparedness training.
- b. Please identify any documents relied upon er consulted and reviewed in answer to (a) above.
- c. Please set forth the substance of any written and/or oral communication, not set forth in response to (a) above, among and/or between employees (including without
' limitation senior management) of NHY and PSNH referring to, relating to or cencerning the attendance of NHY/ORO personnel at training and/or methods or ways to secure that e ttendance .
- d. Please identify any documente relied upon or consulted and reviewed in answer to (c) above.
i Aeolicants' Resconse i
l a. Applicants object to this subpart of the interrogatory on
(
tha ground that it is unduly burdensome as well as unrealistic for Applicants to set Zorth the substance of "Any . .
. oral communication made to ' personnel designated i
as members of the (NHY-ORO)' by those superior to them in l the employment hierarchy referring or relating to attendance
at Seabrook emergency preparedness training." (emphasis added) Without waiving the foregoing objection, Applicants respond as follows:
See response to subpart (b).
- b. New Hamoshire Yankee:
Memo: Vacation From: E. Brown To: All Seabrook Site Employees Datet 5/13/88 Re: Carefully Planning Vacation
- Between May & June (NH-1 880293)
Public Service Comoany of New Hamoshing:
Memo: NHYOR0 From: J. Nevins To: PSNH Managers Date:
9/3/87 Re: Accommodation of Ambitious Schedule of Training
& Drills
. Memo: NHY MAERO From: L. Heaney To: PSNH Managers /UPS Date: 10/21/87 Re: Concerns Over Scheduling (Training, Walkthroughs, Drills)
, Memo: MASS ERO From: J. Nevins To: PSNH Managers /UPS i Date: 3/3/88 Re: Contindation of Support for EP Program l
! Memo: Mass. ORO Participation From: L. Heaney To: PSNH
- Div. Managers Date: 3/16/88 Re: Expedite Call-out For Drill Notification Memo: Mass. ORO From: L. Heaney To PSNH Managers /UPS Date: 3/25/88 Re: 3/32/88 Participation Notification i
Yankee Atomic Electric Comoany Telecon Memo: Haverhill Staging Area Drill To: S. Perkins Date: 3/32/88 Ra: Notification of Participants w -w w
i Memo: CFD #3 Atcondance From: R. Marcello To: J. Ellis Date: 6/13/88 Re: Follow-up on Drill Attendance (SFR 440)
Telecon Memo: EP Training From: R. Marcello To: M.
Strickland Date: 2/17/88 Re: Training Schedule Dates for Riethle, Thomas, McGee, Robinson, Stome, Perez.
- c. Applicants object to this subpart of the interrogatory on the ground that it is unduly burdensome, as well as unrealistic, for Applicants to set forth the substance of "Any . . . oral communication . . . among and/or between employees (including without limitation, senior management)of NHY and PSNH referring to, relating to or concerning the attendance of NHY/ORO personnel at training and/or methods or ways to secure that attendance."
(emphasis added). Without waiving the foregoing objection, Applicants respond as follows:
PSNH attendance summaries for February 1988 and March 1988 were provided to L. Heaney by New Hampshire Yankee.
- d. Same as "c" above.
l Interrocatory No. 35 Please describe in detail all recruitment activities engaged in by NHY and PSNH, from April 1, 1987 to the cresent, the object of which was (and is) to ensure that a certain number of individuals have been identified as ORO personnel.
l a. Please identify all documents relied upon or consulted and reviewed in answer to the above interrogatory.
I
b.
Please state the names of those individuals with responsibility for and authority over the recruitment activities as described above,
- c. Please identify all documents re'.ating to, referring to or concerning the willingnaos of employees of PSNH and NHY to volunteer or otherwise agree to be counted among ORO personnel.
Applicants' Resconse A series of meetings were held with Massachusetts Electric Company, Yankee Atomic Electric Company and Public Service of New Hampshire during July and August, 1987. These meetings consisted of an introduction by an official of one of the respective companies and/or the showing of a video tape and briefings by NHY personnel on emergency planning and principles of radiation followed by a request that those in attendance join ORO.
Applications were solicited and processed bv NHv. Subsequc.itly, periodic visits were made to each organization by NHY personnel in an effort to obtain additional support. Similar recruitment efforts were undertaken within NHY and Seabrook Station.
Additionally, meetings were held in April and May, 1988 with PSNH retirees and with United Engineers and Constructors employees.
Further details of the recruitment activities engaged in by NHY and PSNH are covered under "Subject" in item a. below.
a.
FROM IQ DATE SUBJECT J.L. Nevins PSNH Mgmt. 07/17/87 Notice of informational recruiting meeting.
l
J . L. Nevins PSNH Mgat. 07/22/87 Notice of initial recruiting meeting offered at PSNH on 7/27 and 8/4.
R.J. Harrison All PSNH 07/22/87 Letter promoting and Employees urging PSNH employees to participate on the ORO.
J.B. Nyhan 07/22/87 Worksheet documenting number of participants.
J.L. Nevins PSNH Mgat. 09/03/87 Informational memo of number of employees selected and process used to make selection.
L.J. Heaney PSNH Mgmt. 10/21/87 Update on areas of Concern. i.e.,
training schedules, walk-throughs, drills.
Video Tape Employees Introduction by R.J.
R.J. Harrison Harrison promoting participation and the importance of Seabrook Station's Evacuation Plan.
J.B. Nyhan PSNH 03/88 Provided L.J. Heaney Distribution 05/88 with Recruiting Posters advertising open ORO positions.
2 K.M. Jackson PSNH 10/88 Provided L.J. Heaney Distribution with Recruiting Posters promoting participation in the ORO.
Poster indicated next Recruiting Session on 10/12/88, urging any volunteers with concerns or questions to attend, in addition 4
to any new recruits interested in ORO assignments.
J.B. Nyhan L.J. Heaney continuous Routine tele-K.M. Jackson communications regarding personnel related issues.
K.M. Jackson L.J. Meaney 3/30/88- 'Telecopies names of present interested participants to L.J.
Meaney requiring verbal approval prior to assigning a position.
K.M. Jackson L.J. Heaney 3/18/88- Updates on new present recruits identifying positions assigned and personnel resigning from the ORO.
b.
Time F_rgmg 04/01/87 - 03/01/88 John B. Nyhan, Recruitment Manager 03/01/88 - 07/01/88 John B. Nyhan, Recruitment Manager and Kathleen M. Jackson, Emergency Planning Recruiter.
07/01/88 - Present Kathleen H. Jackson, Emergency Planning Recruiter c.
Applicants have no documentation reflecting willingness to volunteer.
Interrocatory No. 36 Please state the names of (a) the current Training Managers (b) the current subject matter experts; and (c) the Training Supervisor.
l
.. _____ _ - _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ - - - -- - - - A
l Apolicants' Resoonse (a) Current Manager in charge of EP training - Donald R.
Tailleart.
(b) Current Subject Matter Experts - John H. Lusher Guy S. Taibi Pamela A. Morse S. Joseph Ellis Kevin R. Keyes Patrick D. Casey Michael J. Bovino Joseph Bisson Robert Badger Catherine M. Frank Sheila Hertel Gary Catapano Steve Mazzola Ronald Thompson (c) Currently supervising Massachusetts training - Frederick P.
Straccia.
Interroaatory No. 37 Please indicate if any revisions in the Lesson Plans as prepared and approved by ORO personnel between September and November 1987 have been made between December 1, 1987 and the present date. If such revisions have been made, please identify those documerits that constitute those revisions and the dates such revisions were effective.
Aeolicants' Resconse ORO LESSON PLAN REVISIONS FROM 12/01/87 TO 10/14/88 MODULE REVISION DATE
- 1. Emergency Plan Overview 02/16/88 09/23/88
- 2. Emergency Management 03/16/88 04/07/88
.3. Public Notification 05/16/88-10/03/88
- 4. Dose Assessment 09/29/88
- 5. Radiation Surveys 02/04/88 03/25/88 10/06/88
- 6. Monitoring /Decon Operations 02/24/88.
10/06/88
- 7. Dosimetry Recordkeeping 04/16/88 10/06/88
- 8. EOC Operations 01/29/88 09/26/88
- 9. Staging Area Operations 02/16/88 09/26/88
- 10. Reception Center Operations 01/32/88
- 11. Traffic and Access Control 02/17/88 03/08/88 09/26/88
! 12. Transportation 02/17/88 03/08/88 09/29/88 1
- 13. Public Information 06/15/88
- 14. Medical Emergency 03/10/88
, 15. Procedure Checklists Position 33 Bus Drivers 03/10/88 <
Position 35 Amb./ Van Drivers 03/10/88 i Position 36 Road Crews 04/23/88 Position 41 Traffic Guides 03/07/88 Position 63 VANS Drivers 05/18/88 1
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- 16. Tabletop Exercises
- 10 Local EOC Licisons 09/29/88
- 12 EWF Monitoring /Decon Pers. 09/11/88 RC Monitoring /Decon Pers.
- 13 Dosimetry Recordkeepers 10/06/88 Exposure Control Coord.
- 14 Monitoring /Decon Leaders 10/11/88
- 16 Accident Assess. Coord. 09/29/83 Dose Assess. Techn.
- 21 ORO Response Director 09/26/88 A/D, Support Liaison A/D, Response & Implementation Emergency Preparedness Adv.
- 22 Rad. Health Adv. 10/04/88 Public Info. Adv.
Technical Adv.
Communications Coord.
Support Services Coord.
Evacuation Support Coord.
- 23 EOC Adm. Staff 09/26/88
- 17. Bus Company Personnel 03/22/88
- 18. Road Crews 04/23/88 19, Protective Action Decisions 04/09/88 09/29/88
- 20. Communications 03/15/88 10/0J/88
- 21. Survey Instruments 01/31/88 03/05/88 10/05/88
- Interroaatory No. 38 Please state the names of all individuals (including instructors) who received requalification craining or retraining (as described in Appendix K at K-4).
l
a.
Please state the dates on which these individuals were first trained and then retrained.
- b. Please.. identify any documents generated during or as a consequence of this retraining.
Aeolicants' Resoonse ACTUAL ORIGINAL TRAINING RETRAINING DATE 10/06/87 10/13/88 10/08/87 10/13/88 a
10/06/87 09/14/88 10/15/87 10/12/88 10/14/87 10/12/88 10/15/87 10/12/88 10/14/87 10/12/88 10/14/87 10/12/88 10/14/87 09/26/88 10/14/87 10/12/88 10/15/87 09/14/88 10/08/87 09/14/88 10/08/87 09/12/83 10/21/87 09/12/88 1
10/14/87 09/12/88 10/07/87 09/14/88
- b. Examinations, Training Class Exempt'.on Request Form (SPMC K-19).
Interrocatory No. 39 i
Please name those individuals (sic) who have held the title of Training Supervisor and Training Manager from April 1, 1987 to the present. If any of these individus1s are no longer associated with NHY ORO and/or PSNH please provide the most recent information available concerning their whereabouts.
i Anolicants' Resoonse Supervision of Massachusetts ORO Training - Frederick P. Straccia i (after 2/1/88);
]
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SL '3rvisor of EP training - Donald R. Tailleart (prior to 2/1/88);
Management of EP training - Donald R. Taillwart (after 2/1/88).
Interroaatory No. 40 Please state how many individuals have failed to successfully complete required training module (s) even after remedial training and a retest. Please describe in what fashion the assignments of these individuals have been reevaluated and adjusted as described at Appendix K at K-8. Please list the name of each such individual, the assignment before such reevaluation and the assignment after such reevaluation. Please identify any and all documents that refer to, reflect or constitute this reevaluation and adjustment of assignment.
Aeolicants' Resoonse No individuals come within the description of the first inquiry.
Three individuals were reassigned after reevaluation based on training and experience level. Applicants object to disclosing the names of those individuals who were reassigned after reevaluation based on training and experience level on the ground that this would be an impermissible invasion of privacy.
Interrocatory No. 41 Please set forth the substance of any and all comments and recommendations received by NHY ORO frvm personnel receiving training. Please identify any documents containing such communications.
Aeolicants' Response After each classroom training session, students are given the opportunity to provido comments by completing Attachment 9 of Appendix K, TRAINING PROGRAM FEEDBACK FORM. To reprodace here the substance of all commer.ts and recommendations contained in these forms would be unduly burdensome. Applicants therefore respond by producing, and taking available at Scabrook Station, the relevant forms. In addition, player comments were obtained in drills and the exercise. These will also be produced.
Interrocatorv No. 42 Please identify any and all instances in which cheating during testing was suspected or uncovered. Please identify all documents referring to or concerning such cheating.
Aeolicants' Resoonse On one occasion during a bus company personnel training session, the instructor noticed some inconsistencies in the number of students who were present and the number of names on the attendance sheets. As a result, four names were crossed off the attendance sheets. Discrepancies were also noted in some signatures on the exams and procedure sign-off sheets. As a result, three people did not receive credit for the training.
Documents referring to this occasion are listed below:
Attachment 8 - NHY ORO Training and Drill Program Attendance Sheets dated 5/1/88, pages 1, 2, and 3 for Mod. 17 at Shrewsbury, Massachusetts.
Memorandum from Nic'c Liewer to Don Tailleart dated 5/3/86 regarding bus driver training.
Memorandum from D.R. Tailleart to all EP instructors dated 6/27/88 regarding bus driver training.
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l i Interrocatory No. 43 occur between April 1, Please state whether any events occurred or were thought to ;
1987_and the present which led to changes in the manner in which tests and other evaluation materials used in the NHY ORO training program were controlled, produced, !
dissemitaated and retained.
Acoliennts' Resconse There were none.
Interrocatory No. 44 from Set forth the pass / fail rate on testa taken by all trainees April 1, 1987 to the present date.
Aeolicants' Resoonse t
A figure for the pass / fail rate on tests taken by all trainees from the start of the NHY ORO training program in 4
September, 1987 to the present date is not available. Applicants i object to this interrogatory to the extent it calls for Applicants to calculate a pass / fail rate. Egg Pennsylvania Power A_ Licht Co. (Susquehanna Steam Electric Station, Units 1 and 2),
! ALAB-613, 12 NRC 317, 334 (1980). No tests were given prior to t
- the start of the training program.
l Interrocatory No. 45 i l Please describe the procedure used to verify and evaluate i the qualifications of those individuals seeking to be associated ;
t with NHY ORO.
Aeolicant9' Resoonse ,
Information regarding ORO volunteers was gathereJ on the ORO application form. Specific information from the application related to the applicant's current job, education and related t
, , - - - r , .--,ger, _,----,.----m ----.,------~w--,n -
experience was compared to the ORO position prerequisites described in Section 2.1.1 of the SPMC. Job status of ORO applicants with their respective employers is routinely verified.
Interrouatory No. 46 Please describe the present training schedules for each training module included in the SPMC including the number of classroom and tabletop hours of initial training.
Acolicants' ReeDSngR Table 6.3-1 in the SPMC lists the required training modules for each ORO position. The list below identifies the approximate time for each module.
MODULE TITLE APPROXIMbTE TIME (HRS) 1 OVERVIEW 4 2 EMERGENCY MANAGEMENT 4 3 PUBLIC ALERT NOTIFICATION SYSTEM 2 4 DOSE /ACC. ASSESSMENT 4 5 RADIATION SURVEYS / ANALYSIS 2 6 MON /DECON OPERATIONS 2 7 DOSIMETRY RECORDKEEPING 2 8 EOC OPERATIONS 1 9 STAGING AREA OPERATIONS 1 10 RECEPTION CENTER OPERATIONS 1 11 TRAFFIC AND ACCESS CONTROL 2 12 TRANS PORTATION 2 13 PUBLIC INFORMA' lion 2 l
14 MEDICAL EMERGENCY 4 15 PROCEDURE CHECKLIST 1 16 TABLETOP 1 17 BUS DRIVER 6 18 ROAD CREW 6 19 PROTECTIVE ACTION DECISIONMAKING 2 20 COMMUNICATIONS 1 21 INSTRUMENT USE 1 Interroaatorv No. 47 Are personnel trained in and as teams? If the answer is yes, how many trainees train together? For which training modules is team training used, and for what purpose?
Aeolicants' Resconse Claesroom training is not conducted as teams. Certain training activities, such as walkthroughs, are conducted in groups with similar job functions. Personnel in those positions made up of more than one shift were drilled as teams. Refer to the SPMC, Section 6.0, for information regarding the NHY ORO training program. i Intgrrocatory No. 48 l What instruction and/or training is provided to enable the !
trainees to handle non-routine and unexpected eva"tr. (sic) What methods and materials are utilized to develop skills in responding to such events?
, Acolicants' Response During the course of the training program, trainees practice !
routine tasks repeatedly until they can be performed naturally. ,
l l
once the trainees mastered the routine tasks, they were presented scenarios in tabletop and drill settings by experienced (
instructors and controllers, which require the trainees to i respond to unanticipated etants.
Specifically, instructors and controllers stressed the following:
- 1. Trainnes should follow their procedures, but if necessary, exercise good judgment in responding to unanticipated and ;
unrehearsed situations.
l
- 2.
Trainees should communicate both vertically and laterally within the organization about such events.
- 3. Trainees should also communicate complete datails, i
The materials used by instructors included a SPudent Handbonk on l the fundamental flaws from the ASLB Partial Initial Decision of l 6
the 1986 Shoreham exercise and the instructor notes to guide the discussion.
Interrocatory No. 49 Please describe the communications training module, including: !
- c. The types of skills developed; i
- b. The types of equipment used in the modulet and
- c. The number of hours each trainee spends in hands-on i practice with each type of equipment. !
Aeolicants' Renconse The communications training module is Module 20. ,
1 1
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4 ,
i P a. Upon completion of this training module, students will be able to receive and transmit messages in compliance ;
i with FCC regulations and good radio operating practices
, using the radio equipment applicable to their position. I
- b. Types of equipment used in the module include mobile radios, portable radios, converta-coms, and base-r stations, t
f I
- c. 'The number of hours each trainee spends in hands-on i practice with each type of equipment is determined from !
participation in drills and field training, and are not !
available.
l j Interroaaterv No. 50 Are emergency response personnel trained for more than one !
specific job function? If so, what positions are "cross- ;
trained?"
i Acolicants' Resconse .
No, however, the same training modules are presented to I, t
emergency response personnel representing various job positions !
in accordance with the SPMC, Soction 6.0, Table 6.3-1, providing t i
l an overview of other positions and their functions, other l l ?
training sessions, such as tabletops, involve more than one i f
( position and permit personnel to interact and become faiailiar !
with other positions.
Interroaatory No. 51 t
What number of ORO perdonnel represents full staffing? :
l Please set forth this full-staffing number for each distinct ORO j
)
position (including those individuals with training, i i
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~46-(
O t
administrative and planning responsibilities, i.e., those with i
non-emergency response roles.) Please indicate for each month i
' beginning April 1987 up to October 1988 whether for that month !
full staffing was achieved. For those months during which full staffing was not achieved pinase indicate which ORO positions j were not fully staffed.
Aeolicants' Resnonse Full staffing levels for the ORO are presented in Section i
- 2.1.1 of the SPMC. There are no ORO positions that have non- i 1 l l emergency response roles. Training, administration and planning i
are responsibilities of NHY, not of the offsite Response :
l Organization. Attachment E shows planned primary and alternate !
staffing levels for each ORO position plus backup staffing levels !
t and indicates in which months planned staffing was not available. i Monthly data on staffing levels were not available prior to f i
l March, 1988.
[
Interrocatory No. 52
{
In answering the preceding interrogatory, were ORO personnel I who had not been "qualified" (as described in the SPMC at Section !
6 and in Appandix K at K-8) or who had not been "requalified" [
within a year of initial qualification included within the number l of oRO personnel counted in determining whether full staf fing was ;
achieved? If such individuals were counted indicate their number I and position for each month in which they were counted. ,
Aeolicants' Response Yes, they are included. The number and position for each t
i month in which the personnel were counted are not available.
Interrocatory No. 53 I Does NHY ORO have a policy of planned overstaffing of l qualified or trained personnel to mitigate the effects of ,
attrition or for any ott:er reason? on average, what length of l
time 14 reqaired to transform a "raw recruit" into a "qualiflod" '
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i I L
i individual. If the variation in such time is so great that no average time is considered by NHY ORO to be useful, please set forth the average times for each ORO position.
Acelicants' Resconsa Yes, the SPMC uses two alternate shifts with a third shift available to back up non-evacuation specific positions. For i
evacuation-specific positions, minimum staffing is 1.2 times required, with additional support available from Yankee Atomic for a second shift.
F Further, recruiting is an on-going process to mitigate any attrition, changes in assignments, or changes in requirements.
i Applicants do not have the information requested regarding ;
qualification time. Any such estimate would be speculative and would very with the specific pocition training requirements and experience level of the individual.
Interroaatorv No. 54 !
k please state how long the training period is for ned ORO personnel in the following general categories: ;
i
- a. management or supervisory positions, including directors, coordinators, advisors and leaders; ;
f
- b. technical positions, including equipment operators, '
technicians, analysis personnel; i
- c. skilled administrative positions, including liaisons; t
- d. unskilled administrative positions. l t
I
f Arolicants' Resconse The duration of classroom and tabletop training for each ORO l
position is identified in the response to Interrogatory No. 46.
Interroaatory No. 55 r
On August 12, 1988, Robert J. Harrison, ("Harrison") then President and CEO of PSNH in a sworn statement declared that:
"Instability in the willingness or ability of Public
' Service and other Joint Owners to meet their financial responsibilities to the Seabrook project jeopardizes the confidence and morale of the existing staff at Seabrook Station. The existence of NHYEC as the long term operator of Seabrook Station will likely improve that confidence and morale, retaining loyalty of the existing personnel and attracting new employees as necessary."
In referer.ca to this statement please provide the following information:
- a. The names of the individuals (s) who authored, drafted and edited this statement and those who were consulted about its substance;
- b. Any and all information available or made avaf ble to Harrison and the individuals identified in response .s (a) above on the basjs of which or in reliance on which the statement was mades :
- c. Please identify any and all documents reviewed, consulted or assembled by Harrison and the individuals identified in response to (a) above prior to August 12, 1988 which concern the subject matter of the statements ,
- d. Please identify by name and position those t
individuals that make up "the existing staff at Seabrook ,
Station"; i i
- e. Please describe in what fashion and to what extent the confidence and morale of the existing statt was t jeopardized by the purported financial instability;
- f. Please identify by position those new employcos, if i any, that Harrison and the individuals identified in
response to (a) above believed it was or in future would be necessary to attract.
Aeolicants' Resconse i
Applicants object to this Interrogatory on the ground that the information it seeks is not relevant to the subject matter of this proceeding, to wit, the admitted contentions.
Interrocatory No. 56 Specifically describe the training programs offered to and required of traffic guides, bus drivers and transfer point dispatchers as to the followings
- a. methods and equipment used to familiarize the trainees with the road systems and land geography of the EPZ
- b. methods used to develop proper skills for dealing with an evacuating populati.on that may be emotionally unstable, angry, frightened, uncooperative and/or violent;
- c. amount of time each trair.ee spends in "hands-on" practical training for directing and controlling traffic, dealing effectively with traffic impediments, and moving and placing traffic cones and barricades.
Acolicants' Resoonse
- a. Traffic Guides and Transfer Poirt Dispatchers, in addition to clausroom training identified in Table 6.3-1 of the SPMC, participate in drills where they are lasued map books and drive to traffic and I access control points and transfer points to which they could be assigned within the EPZ.
- b. Applicants object to this subpart of the interrogatory on the ground that the information 1
q1 it seeks is not relevant to the subject matter of this proceeding, to wit, the admitted contentions.
f
- q. In particular, it seeks information going to human behavior issues that were not admitted by the Board.
- c. Each Traffic Guide spends approximately four (4) hours in hands-on practical training for directing l
and controlling traffic, dealing with traffic impediments, and moving and placing traffic cones.
Mock intersections are set up in accordance with Appendix J - Traffic Management Manual. Transfer Point Dispatchers receive training in dealing with traffic impediments.
Interroaatory No. 57 Identify all entities that are providing support to NHY ORO for the implementation of the Plan and whose personnel have or will be trained by NHY ORO.
ADolicants' Response Training ham been or will be made available to entities providing support as described in the SPMC, i 2.4, 5 6.6 and Table 6.6-1 or as otherwise requested.
Interroaatory No. 56 Please identify by name all personnel from the support organizations identified in the immediately preceding interrogatory, who have been, and/or will be, trained by N!!Y ORO.
Include therein the specific dates and training modules each person is or will be offered and required to take.
h
r Acolicants' Resnonse See Attachment F.
Interroaatorv No. 59 Specifically describe the type and extent of training provided to the identified support organizations' personnel for each emergency response position occupied by those personnel as to the following
- a. The number of hours of trainings
- b. The number of follow-up sessions required;
- c. Training designed to ensure effective interaction between ORO personnel and the support organizations during an emergency;
- d. The length of time it takes to identify, train and "qualify" new support organization personnel.
Aeolica n*.s ' Resnonse of the support organizations identified in SPMC sections 2.4.
the following personnel perform Seabrook specific emergency response functions: bu= drivers, ambulance drivers, road crews, airborne alerting pilot, EBS station personnel and MS-1 hospital staff. Other support organization personnel that do not have Seabrook specific emergency response functions are offered training according to Table 6.6-1 of the SPMC. This training is not required, it is provided only if the support organization so
- desires.
(a) Bus driver training consists of Module 15 - Procedure Checklist Model 16 - Tabletcp Exerciset and Module 17 - Bus t
Driver.
Module 15 allows stud 6nts to familiarize themselves with their procedures and Module 16 has students usu their i
procedure to identify actionc taken during a simulated '
emergency situation. Module 17 covers basic emergency planning concepts such as radiation, dosimetry, dtsimetry usage, notification, mobilization, dispatching, and potential route assignmenta. See response to MAG #46 for length of training.
Airborne Alerting Pilots receive the following training in accordance with Table 6.3-1 of the SPMCs Module 1 -
Overview of Emergency Planning; Module 3 - PANS Activation; Modulo 7 - Dosimeter Recordkeeping; Model 15 - Procedure (
Checklist; Module 16 - Tabletop Exercise; and Modulw 20 -
Communications.
t Module 1 - covers basic emergency planning concepts, radiation, exposure control, notification, i communications, and protective actions.
- Module 3 - covers the Public Alert Notification System (PANS), concepts of operation and the ;
individuals associated with PANS operation.
Module 7 - : overs forms and equipment associated with !
I the monitoring of emergency workers' exposure (
and the issuance / return of equipmert j (dosimeters) used. f Module 15 - allows the airborne alerting pilots to familiarize themselves with their proceduros. l i
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i Module 16 - has students use their procedures to identify actions taken during a simulated emergency 4
situation.
Module 20 - covers receiving and transmitting messages in
, compliance with FCC regulations and good operating practices using radio equipment applicable to their positions.
For length of training, see response to MAG
- 46.
Ambulance personnel receive the following training in accordance with Table 6.3-1 of the SPMCs Module 1, 15, 16 already referenced and Module 14 - Medical Emergency.
Module 14 - cJtlines actions to be taken for a co*"aminated injured person, decisions concerning a contaminated individual versus a medical emergency and contamination control associated with a contaminated injured individual.
For length of training, see response to HAG
- 46.
1 Road crews receive the following training in accordance with Table 6.3-1 of the SPMCs Module 15 and 16 already referenced and Module 18 - Road Crews.
4 Module 18 - covers basic emergency planning concepts and t
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I reviews notification, mobilization, discusses i dosimetry issuance and usage.
For length of training, see response to MAG
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- 45.
- b. No follow-up sessions have been or are required other than annual retraining.
EBS station: Training consis*.s of MOD-1 overview of emergency planning, MOD-3 PANS Activation. MOD-7 Dosimeter Recordkeeping, MOD-13 Public Information. MOD-15 Procedure Checklist.
Module 13 - This module reviews Medla Center operations, including Rumor Control, Media Relations and f news release development at the NHY ORO ECC.
Reference airborna Alert pilots for other module listed.
For length of training, see response to intorrogatory 46.
l MS-1 Hospitals: Training consists of MOD-1 overview of Emergency Planning, MOD =29 Hospital Management of Contaminated and Injured Patients and MOD-15 Procedure Checklist.
I Module 29 - This module reviews actions to be taken for a contaminated injured individual.
- c. ORO and support organization personnel receive information on how to interface and interact with each other during classroom training, in psrticular Module 15. This 1
L interaction is practiced and/or simulat/)d during i walkthroughs and drills and evaluated for effectiveness.
- d. There are many variables in the length of time it takes to identify, train, and "qualify" new suppret organization personnel such that it is not possible to determ!ne this ,
value. [
MOTION FOR PROTECTIVE ORDER
., Applicants move that the Board issue a protective order ,
prohibiting Mass AG from obtaining discovery to the extent objected to by Applicants in Response to "(Mass AG's] First Set of Interrogatories to Applicants on the (SPMC)". !
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As to Answers
!N m-Q George S. Thomas vice President, Nuclear Production New Hampshire Yankee Division of Public service Company of New Hampshire October 25, 1988 State of New Hampshire Rockingham County, es.
Then appiared before me the above subscribed George S.
Thomas and made oath that he is the Vice President, Nuclear -
Production of New Hampshire Yankee Division, authorized to execute the feregoing responses to interrogatories on behalf of the Applicants' that he made inquiry and believes that the foregoing answers accurately sat forth information as is available to the Applicants.
Before me,
&& t M' & A. fra My Commission Expires
. 4 L ,=
As to objectionst jy d #[M [Mt ,';; , .7 5 Thomas G. Dignah, Jr. ,
George H. Lewald '
4 * '
Kathryn A. Selleck -
Jeffrey P. Trout "".','
Jay Bradford Smith ..
Kopse & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 i
Counsel for Aeolicants 57
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Introductory Resogngst f (a) Applicants' positions expressed in reaponse to Interrogatory No. 2 represent the Applicants' present understanding of the contention based on current information at hand. Please note that only essential facts which support the Applicants' position are !
identified in responding to this interrogatory, but these facts should not be considered exclusive.
(b) The SPMC, including plan, appendices, procedures and Evacuation Time Estimate Study, is a composite, self-supporting document which details both tha emergency response actions to be implemented by 0F0 and the basis i of those actions. As such, Applicants' position on all of the Intervenor contentions is deta: led in these documents. In addition the Applicant will Tely on the relevant portions of FEMA's Plan Review and 1988 Post
,; Exercise Assessment.
(c) Applicants' interrogatories to the Intervenors are proposed to elucidate the basis of the contentions and, to the extent that specific detail is provided by i Inte rvenors ' response to those interrogatories, the attached supplemental facts may chinge accordingly.
(d) To the extent that many of the contentions may be remedied by ministerial clarifications or additions of i
-~
data, such as latest school populations, the Applicants L
suggest meetings be scheduled with the Intervenors to clarify positions that may lead to stipulations that in turn may resolve the contention.
(e) For those contentions that deal with the capabilities of the Commonwealth of Massachusetts, Applicant relies on the details of the Massachusetts, CERP and the offsite plans of other nuclear power plants which affect Massacnusetts.
2-
J.I:12 (a) Applicants position on JI-1 is that the Evacuation Time Study represents accurate evacuation times. The underlying facts supporting Applicants' position include:
- A complete set of ETEs was calculated prior to, and following, the filing of testimony for the New Hampshire hearings. The ETE values in Attachment 4 of IP 2.5 are taken from this set. Specifically the ETEs for 5 miles are those for Region 8; the ETEs for 10 miles are those for Region 13; ar.J the ETEs in IP 2.5 Attachment 4 were calcula'.ed by KLD Associates, Inc. using the same version of the t
IDYNEV model used previously for other Seabrook Station ETE calculations.
- The SPMC providen for closure (May 15 through September 15) of the Parker River National Wildlife 2
Refuge on Plum Island, Plum Island Beach, and Salisbury Beach at a Site Area Emergency IP 2.5 i section 5.2.1.
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- Detailed procedures are provided within the SPMC ,
t with regard to public alert and notification which will include all areas within the Massachusetts EPZ. IP 2.13.
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- The DOI notifies park visitors of closing of the Parker River National Wildlife Refuge on Plum Island when requested by the NHY ORO. ,
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- The Plan assumes State and local officials vill put I forth their "best efforts" and follow the SPMC.
- Police chiefs in the Massachusetts EPZ communities (with exception of Amesbury) in addition to local and state public officials and private citizens were all involved in providing guidance in the development of the ETE, including discussions on the location and manpower assigned to individual TCPs. NHRERP Vol. 6. p. 1-1, 2, 3, 4.
- The ETE does not assume a specific time that the traffic guides are in place. Rather, the ETE assumes that traffic guides man the TCPs when the traffic volumes approaching that TCP attain a "significant level." By "significant level" we mean the volume at which evacuation flow benefits by actions taken by the traffic guides such that the resulting evacuation times are represented in the ETE study.
- TCP/ACP personnel are mobilized at a Site Area Emergency or General Energency and are instructed to await notification to activate traffic control.
SMPC. APP. J., J-2, 5.
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- TCP/ACPs are assigned staffing priorities. SPMC l Appendix J.
- As Applicants' Direct Testimony No. 7 in the NHRERP hearings explained, a sensitivity run was performed to examine the consequences of no TCPs being manned in Massachusetts, J
(b) The source for these facts include Applicants' Direct Testimony No. 7 in the NHRERP hearings, the SPMC, and i SPMC IP-2.5, IP 2.11. NUREG 0654/ FEMA-REP-1, Rev. 1, Supp. 1.
(c) None selected.
(d) None selected.
(e) None.
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dl-2 (a) Applicants' position on JI-2 is that the ETEs provide a realistic basis for protective action decisions. The facts underlying Applicants' current position are addressed below under JI-2A - JI-2I.
JI-2A:
NHRERP. Vol. outli.nes development of the traffic (a) - 6, control plan.
- SPMC section 3.6.5 outlines traffic and access control functions.
- SPMC IP 2.11 provides procedures for traffic support. This includes provisions for responding l
l to road impediments.
- SPMC Appendix J, NHY offsite Response Traffic Management Manual, provides procedures for traffic guides, ACP/TCP diagrams, and ACP/TCP staffing priorities.
- SPMC IP 2.10 provides procedures for deploying road crews to respond to road impediments.
- Applicants' Direct Testimony No. 7 in the NHRERP hearings providea additional information on ETEs.
(b) The source for these facts are NHRERP Vol. 6.
Applicants' Direct Testimony No. 7 in the NHRERP hearings, and the SPMC as noted.
(c) None selected.
(d) None selected.
(e) None.
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ill:2A8 (a) - .NHRERP, Vol. 5. outlines the ETE development process. Additionally, saction 2 describes demand estimati;n; Section 5 describes estimation of employee populations section 6 describes demand estimation for off-season and mid-week in-saason scenarios.
- Applicants' Direct Testimony No. 7 in the NHRERP hearings provides additional factual information on ETEs.
(b) The sources for the facts in JI-2B are Applicants; Direct Testimony No. 7, in the NHRERP hearings; NHRERP Vol. 6.
(c) None selected.
(d) None sclected.
(e) None.
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JI-2C (a) - The SPMC provides for coordination between ORO public information/ umor control staff and public information staff from other response organizations, located at the offsite Response EOC, the Joint Telephons Information Center (JTIC) und the Media Center.
- The Public Information Advisor and Public Information staff, located at the EOC, are aware of the most up-to-date information from the NHY ORO staff, and they ere strategically positioned and procedurally instructed to disseminate the most current information/ news releases /EBS messages to the Media Center and JTIC. Media Relations Assistants at the JTIC can also monitor news media broadcasts for accuracy.
- Current ETEs assumn voluntary evacuation.
(b) The sources for the facts underlying the Applicants' position on JI-2C are IP 2.12, IP 2.13, Applicants' Direct Testimony, No. 7 in the NMRERP hearings, Seabrook Station Radiological Emergency Plan ("SSr.EP"), Section 11.3 and Nuclear Production Emergency Response Manual
("NPER") ER 3.3-5.
(c) None selected.
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(d) None selected.
(e) Nona.
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JI-2D (a) The ETEs are based on an eppropJ' ate traffic flow rate l
through the intersection at Route 110/I-95/ Elm Street in l
l Amesbury.
The turn movements for this intersection are depicted on the TCP diagram for ' AM-06: SPMC.
i Appendix J.
1 (b) The source of information for JI-2D is the SPMC.
(c) None selected.
(d) None selected (e) None.
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JI-2Er SEE APPLICANTS' POSITION ON JI-2B.
)
t JI-2F (a) Vehicles will be allowed through TCPs/ACPs in accordance with the Traffic Guide Procedure in the SPMC Appendix J.
- Appendix J of the SPMC provides ACP/TCP diagrams which indicate the placement of cones at applisable ACP/TCPs.
- Applicants' Direct Testimony No. 7 in the NHRERP hearings provides additional information on implementing the traffic control plan.
- NHRERP, Vol. 6 outlines additional information on implementation of the traffic management plan.
(b) The sources of information for JI-2F are Applicants' Direct Testimony No. 7, NHRERP hearings, NHRERP Vol. 6; SPMC, Appendix J.
(c) None selected.
(d) None selected.
(o) None.
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I JI-2Gt (a) The SPMC statest
- If a Site Area Emergency or General Emergency is declared between May 15 and September 15, the NHY
! Offsite Response Organization will recommend l
l closure of Salisbury Beach, Plum Island Beach and 1
the Parker River National Wildlife Refuge on Plum Island. Sirens covering the beach areaa vill be used to alert the beach population.
- The U.S. Department of the Interior (DOI) will be notified by the NHY Offsite Responso Organization, i
i and will provide supplemental notification to the transient population at the Parker River National Wildlife Refuge on Plum Island.
- The NHY Offsite Response Organization will release an EBS message advising the general public of the closure of Salisbury Beach, Plum Island Beach and the Parker River National Wildlife Refuge. SPMC, Section 3.6.1.E.
(b) The source of information for JI-2G is the SPMC as noted.
(c) None selected.
(d) None selected.
(e) None.
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JI-2H SEE APPLICANTS' POSITIO!! ON JI-2F l
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.g. JI-2It l I
(a) special population ETrs 2nd the methodology for their i l determination atu described in the seabrook Station. :
Evacuaticii l'ine Study, NH3.ERP, Volume 6, pages 11-1 ;
through 11-27. i (b) The pource of information for JI-2I is NMRERP Volume 6. ;
i (c) None selected. L (d) rione selected. !
(e) None. j i
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. _ . . . - - . _ _ _ _ _ , . - _ _ _ . _ . _ _ _ _ _ _ _ . . _ _ _ _ . _ _ _ _ _ _ - _ _ . . _ - - . - . - _ . _ _ _ . . . ~ -- ---
Jhlt (a) Applicants' position on JI-03 is that realistic ETEs are provided for protective action decision makAng during l the summer months.
l The facts underlying Applicants' position include:
f - A real time computer based system to compute real l
time ETEs is not called for by planning guidanco in NUREG-06$4/TEMA-REP-1, Appendix 4.
- The SPMC, IP 2.5, Attachment 4, provides ETEs, including scenarios for the summer season.
l - The ETEs set forth in IP 2.5, Attachment 4 will be i used subject to the instructions provided in step 1
5.5.4 of IP 2.5.
(b) The sources for the facts underlying Applicants' position include the SPMC, NUREC-0654/TEMA-REP-1.
1 (c) None selected.
(d) None selected.
(e) None.
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Mt (a) Applicants' position on JI-4 is that the evacuation plan of the $PMC is adequate.
The facts underlying Applicants' position include:
- NHRERP, Vol. 6, outlines development of the traffic control plan.
- S PMC, section 3.6.5, outlines traffic and access control functions.
- SPHC, IP 2.11, provides procedures for traffic support.
- SPMC Appendix J. NHY Offsite Response Traffic Management Manual provides procedures for traffic ;
I guides, ACP/TCP diagrams, and ACP/TCP staf 0ing i priorities.
- Applicants' Direct Testimony, No. 7, in the NHRERP hearings provides additional information on the traffic management plan.
- S PEC , section 6, outlines training provided to the NHY Offsite Response Organization.
(b) The sources of facts underlying Applicants' position are the SPMC, Section 6, Appendix J, and Implementing Procedurest NHRERP Vol. 6, and Applicants' Direct Testimony No. 1, NHRERP hearings.
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I (c) None selected.
(d) None selected ,
(e) None.
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J1.5 t (a) Applicants' position on JI-5 is that the SPMC has adequate provisions for removal of road blockages. the underlying facts supporting Applicants' position include:
- The ACP/TCP traf fic guide procedures in Appendix J of the SPMC instruct traffic guides to report traffic problems to the Evacuation Support Dispatcher.
- Route guides for the hearing-impaired are directed to report obstacles, stalled cars or other impediments to traffic flow to the Evacuation Support Dispatcher, IP-2.11, Attachment 3.
- The EPMC provides for use of helicopters for surveillance of the evacuation routes and road inpediment spotting. IP 1.3, Attachment 1.
- Route guides assigned to buses are directed to report any obstacles, stalled cars or other
, impedirents to traffic flow by radio to the Staging f Area Leader for those buses going to schools and l
special facilities and to the Transfer Point i
Dispatcher for those assigned to Transfer Pointe.
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! IP 2.10. Attachment 3.
l - SPMC IP 2.10 and 2.11 outline procedures for 1
responding to road impediments.
i
(b) The sources relied on to support the underlying facts l
l include the SPMC and Applicants' Direct Testimony, No.
7, NHRERP hearings.
(c) None selected.
(d) None selected.
(e) NonJ.
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JI-6:
(a) Applicants' position on JI-6 is
- hat it disagrees with l
the contention and its asserted bases.
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The underlying facts suppo-ting the Applicants' position 1
are
- The SPMC provides for notifying boaters on the Merrimack River though activation of the public notification system and EBS. In addition, the USCG l at a Site Area Energency establishes and enforces a 5 mile safety zone, issues an Urgent Marine Information Broadcast to mariners and controls vessel traffic. The safety zone will be extended to 1C miles as conditions require.
- Boaters in distress can be assisted by the Harbormasters for Salisbury, Newburyport and Newbury, or other boaters.
(b) Documents supporting Applicants' position include the l
SPMC, the USCG First District Radiological Response Plan, and Annual Reports for Newbutyport, Newbury and Salisbury.
(c) None selected.
(d) None selected.
(e) None.
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J1-2:
(a) Applicants' position on JI-7 is that adequate planning has been done for the transit dependent population. The facts underlying Applicants' position include:
- Bus routes hgve been identified for the transit dependo.it population.
- Maps of each bus route are contained in SPMC, Appendix J.
- Precedures for providing transportation assistance to the transit dependent population are contained in the SPMC, IP 2.10.
(b) Sources c' the fact underlying Applicants' position are the SPMC, Appendix J, and IP 2.10.
(c) None selected.
(d) None selected (a) None.
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(a) Applicants' position en JI-8 is that adequate planning has been done for the transit dependent population in l West Newbury and salisbury. l The facts underlying Applicants' position includes i
- The SPMC, section 3.6.1.5, provides for !
l transportation assistance for residents and ,
transients requiring assistance.
- Draft Public Information materials intended for f t
l distribution to each household and facility in the [
EPZ clearly reflect the availability of evacuation j transportation services for the transit dependent {
population. j
- Sample Emergency Broadcast System messages contain f instructions and information regarding the i availability and timing of evacuation fi l transportation assistance. j
- Provisions havk been made to allow individuals !
t requiring assistance to secure additional f inforinatiots about evacuation transportation f I
l assistance by contecting the appropriate emergency reLponse organizations. l l
The sources for the facts underlying Applicants' ;
(b) l i
j position are the SPMC, Sec. 3.6, 0.'/; IPs 1.3, 2.10 and [
2.13, and the SPMC Draft Public Information materials. ,
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(d) None selected.
(a) None.
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iL~.21 (a) Applicants' position on JI-9 is that any such provisions are not needed in the SPMC. The relationship between an ORO member and the ORO is separate and distinct from the relationship between that same member and his or her full-time employer.
(b) The source for these facts include th s application form signed by ORO volunteers when joining the ORO.
(c) None selected. ,
(d) None selected.
(e) None.
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Applicants' position on .TI-10 is that it disagrees with the Contention and asserted basis.
The facts underlying Applicants' position are as follows:
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- 1. The SPMC does not rely upon any Federal agency to develop a PAR. ,
- 2. To the extent any Federal agency is relied upon to l
implement a PAR -- i.e., the USCG, FAA. ')OI --
the se agencies are at their response location at all' times to implement these emergency response functions.
l 3. The statutory responsibilities of the 12 Federal Agencies participating in the FRERP are referenced in the FRERP itself.
Sources relied on include NhRERP, Vol. 1, 4, 4B and 5, (b)
SPMC, FRERP, and the Parker River National Wildlife Refuge Standard Operating Procedures for Emergencies at l
Seabrook Nuclear Power Station.
(c) None selected.
(d) None selected.
(e) None.
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JI.lA:
(a) Applicants' position on JI-11 is that the SPMC providas adequate staffing to maintain and sustain an emergency response as called for by the regulations and the :
i regulatory guidance.
The underlying facts supporting the Applicants' position include:
- Generally, adequate staffing is ensured by two alternate chifts and a third backup shift.
- Evacuation-related position staffing is ensured by providing a minimum of 20 percent additional personnel.
- Manned vehicles identified in Appendix M constitute an adequate resource pool for implementation of the SPMC.
Members of the ORO are not members of the Seabrcok Station ERO.
(b) The sources relied on to support the underlying facts include the SPMC, Section 2.0; IP 1.1, IP 2.1, and IP 2.17; SPMC Appendices H and G; Yankee Atomic Mutual Assistance Agreements.
(c) None selected.
(d) None selected.
(e) Memo from S. Perkins-Grew to C. Frank, dated 10/6/88; 4
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Subject - Database Verification of Non-Overlap on ERO/ORO Assignments.
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JI-12:
SEE APPLICANTS' POSITION ON JI-11.
)
JI-13:
(a) Applicants' position on JI-13 is that the prerequisite experience required to hold ORO positions and the training provided by the SPMC are adequate to implement the SPMC.
The underlying facts to support this position are as follows: ,
- The results of training tabletops and drills.
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- Training instructors are qualified to provide adequate training.
- Training consists of practical walkthroughs and I
drills, not only class room training.
- Bus drivers, by the nature of their normal, everyday functions d2 have experience with children and special (handicapped) passengers.
- Sus drivers are not required to perform any function other than drivir.g a bus.
(b) The sources relied on to support these facts liiclude
(
SPMC, Soction 6.0 and Appendix K. (
(c) None selected. ;
(d) Nono selected.
(e) None.
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JI-14:
(a) Applicants' position on JI-14 is that training provided and the experience had by members of the ORO is adequate [
and therefore no one in the ORO is responding in an ad- .
hoc manner (see JI-13).
The underlying facts supporting these positions are:
- The functions required by the SPMC that might be carried out by state and local officials are .
similar to functions required in other radiological and non-radiological emergencies for which these j individuals are trained.
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- The experience of Commonwealth of Massachusetts amargency officials with emergency planning for other nuclear power plants provides familiarity
- with the decision-making concepts of the SPMC.
(b) The sources supporting the underlying facts are letters ,
i of agreement with bus providers, Massachusetts ;
comprehensive Emergency Response Plan, and $PMC, l t
Section 6.0 and Appendin K. l i
(c) None selected. r (d) None selected.
(e) None.
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JI-15:
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Mass AG has the burden of proof on this contention.
Consequently, Applicants will not be able to state their position on this contention until Mass AG states his case.
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i JI-16:
(a) Applicants' position on contention JI-16 is that the provisions in the SPMC for radiological monitoring are adequate.
The underlying facts supporting this position are that:
- The planning for radiological monitoring as described in section 3.3 of the SPMC meets the requirements in 10 CFR 50.47 (b) (9) and Appendix E (N) (E) (2) , as well as the guidance in NUREG-0654 (II.I). There is no regulatory requirement for or planning guidance that indicates that planning for the location c' monitoring points be based upon "specific local conditions."
- The SPMC at page 3.3-4 indicates that the maps are used for recording survey and monitoring data, that maps showing locations of ingestion pathway concerns are at the NHY EOC, and that these naps are used in the aasessnent process by the Accident Assessment Coordinator.
.. No decision criteris are needed to implement monitoring because the procedures for this function are implemented automatically by NHY Offsite Response Organization personnel at the Alert classification level. Estimated deployment times for Field Monitoring Teams are given in the SPMC at page 3.3-8. These procedures are wholly adequate for the direction and control of the Field Monitoring Teams. Provisions for the communication of field data from the Field Monitoring Teams to the Accident Assessment Coordinator at the EOC are included in IP 2.3. Criteria for assigning monitoring locations to the Field Monitoring Teams are included in IP 2.3. E up personnel for the Field Monitoring Teams a 41sted in Appendix H.
Prerequisite experience for the NHY Offsite Response Organization positions of Accident l Assessment Coordinator, Dose Assessment Technician,
- and Field Monitoring Teams is given in section 2.1 of the SPMC. Refer to the position statements for JI-13 and JI-14 regarding backgrounds, experienco and ttaining of these personnel.
The rerponse of the Field Monitorina Teams was u
l judged satisfactory in th3 1968 FEMA /NRC Exorcise.
1
' - Although the guidance in NUREG 0654 focuses on
! equipment, capabilities and re';oe.rces for field monitoring, there is no regulatory requirement specifying the minimum number of field teams for field monitoring activitiac within a given area for an offsite response organization. Additionally, there is no regulatory requirement that the members
of the Field Monitoring Teams work or reside within a certain radius of Seabrook Station.
- The SPMC does not ignore the impact of mobilizing and evacuating traffic on the timely availability on the Field Monitoring Teams. Timely radiological monitoring in Massachusetts is possible through the cooperative field monitoring efforts of the NHY Offsite Response Organization and license, specified in a letter of agreement in Appendix C.
- Tha SPMC provides strong assurances that dose assessment activities taking place at the EOC and EOF are coordinated, especially in light of the fact that three emergency response organizations dispatch field teams. Refer to section 3.3 of the SPMC, IP 2.3 and Utility Agreement 2 in Appendix c.
(b) The cources relied on to aupport the underlying facts are the SPMC, NUREG-0654, NHRERP, NIAT Handbook, IP 2.2, IP 2.3.
(c) None selected.
(d) None selected.
(e) None.
~36-4 L
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JI-17:
(a) It is the position of the Applicants that for a given individual or group the "range" may consist of only one protective action. There is no requirement that each and every individual or group have multiple possibilities for protective actions.
The facts underlying Applicants' position aret >
- The SPMC provides for a range of protective actions, which include beach closure, acceso control, sheltering and evacuation, for the Massachusetts portion of the EPt as required by 10 CFR 50.47 (b) (10) . ,
- The Applicants' position is consistent with the NRC staff position that "the NRC's amtrgency planning regulations do not require that sheltering be pre,vided for all accidants, at all times and at all locations within the plume exposure pathway emergency planr.ing cone." (Febt uary 18, 1988 lotter from Sherwin E. Turk, USNRC, to H. Joseph Tl' inh, FEMA).
(b) The sourcus for the underlying facts in support of Applicants' position are the SPMC, sections 3.4.2.A and >
3.6.1.E, the ETF., 10 CFR 50.47 (b) . NUREG-0654/ FEMA-REP- ,
1, Rev. 1, Supp. It February 18, 1988 letter from Sherwin E. Turk, USNRC to H. Joseph Flynn, FEMA.
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(c) None srlected.
e (d) None selected.
(e) None.
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JI-18:
(a) Applicants' position on Contention JI-18 is that the decision criteria of the SPMC for selecting protective action recommendaticas are adequate and consistent with Federal guidelines.
The facts underlying Applicants' position are:
- Section 3.4.2 of the SPMC describes the formulation of plume exposure PARS. IP 2.5, Attachment 1, provides the decision logic for PARS based upon plant conditions. Attachment 3 provides the decision logic for PAPS based upon projected doses.
Completion of Attachment 3 by the Accident Ac:assment Cooroinator provides a comparison of projected shelter vs. evacuation doses.
- The SPMC relies on a "shelter-in-place" concept.
- The shielding factor of 0.9 and the air exchange rate assumed by the thyroid dose credit fornula are used in the SPMC to reflect the lower bound of dose reduction afforded by area housing.
The SPMC ir consistent with the EPA e.nd FSA ,
guidance, i
- The SPMC considers local conditions hindering evacuation during times of high beach population, or bad weather such as blizzards and flooding I
t
- 4 conditions as detailed in SPMC, section 3.4.2, and IP 2.5, Attachments 3, 4, 6, 7 and 8.
l
- The SPMC does provide for protective action strategy that includes identification of "hot spots" after plume passage, and relocation of the general public as detailed in SPMC, sections 3.3, 3.9, IP 2.6, IP 2.4, and IP 2.2. However, the decision criteria relies upon EPA guidance, rather than NUREG-1210.
- The non-radiological risks of an evacuation have been considered by the EPA during the development of the plume exposure pathway PAGs. The PAGs have been adopted in the SPMC. (Refer to EPA-520/1 001, Appendix C, and IP 2.5, Attachments 7 and 8.)
- The SPMC provides for the timely incorpo.ation of
, sufficient meteorological data into PAR decision-making. (Refer to CPMC, section J.4.2.A, IP 2 2, L
IP 2.5, Utility Agreement ? in Apper. dix C.)
- The Plan does not rely upon sheltering the transient populstion at Plum Island. (STMC, sections 3.4.2.A and 3.6.1.E.)
(b) The sourcca of the facts underlying Applicants' position [
are the SPMC, 10 CFR 50.47, NUREG-0654, FEMA / REP-1, ,
Rev. 1, Supp. 1, EPA-520/1-75-001, EPA-520/1-78-001A,
. .- . _ _ - .. .. . .- . _ _ __ _ . = _ .. _ _ _
I NHRERP, and February 18, 1968 letter from Sherwin E.
l Turk, USNRC, to H. Joseph Flynn, FEMA.
(c) None selected. t I
(d) None selected.
(a) None.
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JI-29:
(a) Applicants' position on JI-19 is that the SPMC allows decision-makers to use sectors to identify affected downwind areas and ERPAs. Evacuation of the EPZ is by ERPA, not sector.
The facts underlying Applicants' position are as follows: ,
- The formulation and implementation of plume exposure pathway PARS are described in section 3.4.2.A of the SPMC and IP 2.5.
The salection of ERPAs in which PARS are to be implemented is consistent with the concept described in NUREG-0654 at pages 9 and 16. This concept includes a.360' region that extends out to either 2 or 5 miles, depending on the severity of l the accident. This concept aise provides for consideration of the effects of frequent wind shifts and sea breezes.
- The NHY Offaite Response Organization obtains '-
onsite meteorological data from thu setbroor Station meteorological tower at 15 minute intervals from the EOF staff (IP 2.2, IP 2.5), and regional weather data from Weather Services International through the EOF or Yankee Atomic Electric Company (IP 2.5).
~42-
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(b) The sources relied on to cupport the underlying facts include the SPMC, Seabrook Station Emergency Response l
Plan, and NUREG-0654-FEMA-REP'1.
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(c) None selected. ,
(d) None selected.
(e) None.
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JI-20:
(a) Applicants' position on JI-20 is that the ETE values contained in the SPMC are sufficient to support protective action decision making. <
The underlying facts are as follows
- IP 2.5 Attachment 4 provides estimated Evacuation !
Times. This table considers a range of variables i and provides a synopsis of the scenario upon which the estimate is based. ,
- A complete set of ETE was calculated just prior to, and shortly following the filing of testimony for the New Hanpshire hearings. The ETE entries in i Attachment 4, of IP 2.5, are taken from this set.
Specifically:
- 1. ETEs for 5 miles are those for Region 8,
- 2. ETEs for 10 miles are those for Ragion 13.
- 3. ETEs in IP 2.5 Attachment 4 were calculated by KLD Associates, Inc. using the same version of the IDYNEV model an was used previously for other Seabrook Station ETE calculations.
- The Assistant offsite Response Director refers to Attachment 8, to evaluate the impact of local conditions on implementing PARS. SPMC, IP 2.5, section 5,5.
[
- The Assistant Offsite Response Director briefs the Radiological Health Advisor on an applicable evacuation time estimate, potential constraints to ,
evacuation and considerations which may enhance the evacuation time. SPMC, IP 2.5, section b.5. !
- ETE sensitivity studies have been conducted. They are outlined in the Applicants' Direct Testimony, No. 7, for the NHRERP hearings. .
(b) The sources for the facts underlying Applicants' i
position on JI-20 are Applicants' Direct Testimony, No.
7, NHRERP hearings, NHRERP, Vol. 6; SPMC, IP 2.51 NUREG-0654, Appendix 4.
(c) None selected.
(d) Nono selected.
I (e) None.
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JI-21:
(a) The Applicants' position on JI-21 is that the SPHC contains the population figures for peak and permanent populations cf municipalities in the Massachusetts portion of the EPZ. The population figures can be readily matched with the sector and radial distance map of the Msssachusetts EPZ contained in ths SPMC, Appendix A.
The facts underlying Applicants' position are:
- Population estimates by municipalities are found in SPMC, Section 1, Table 1.3-1 and Section 3, Table 3.6-1, and are consistent with those used in the NHRERP, and reflect the July, 1987 aerial survey of the seacoast areas.
- A map showing municipalities and emargency response planning areas (ERPAs) is contained in IP 2.5.
(b) The sources of underlying facto in support of Applicants' position is the SPMC, Table 3.6-1 enti Appendix A.
(c) None selected.
(d) None selected.
(a) None.
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JI-22 (a) Applicants' position on JI-22 is that stata and local officials will use their best efforts in responding to I.
!' an emergency at seabrook station.
t (b) The source of information'for JI-22 is 10 C.F.R. t i 50.47 (c) (1) .
(c) None selected.
f (d) None selected. ,
(w) None. [
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JI-22:
(a) Applicants' position on JI-23 is that decision criteria described in the SPMC are coordinated with those in the NHRERP. The SPMC has adequate procedures to preclude deley and formulation of erroneous PARS. ,
Applicants' underlying facts to support this position include:
t
- The SPMC, the NHRERP and the MA CERP rely on the same Federal guideline; as a basis for PARS.
- Coordination is provided by LOA between NHY ERO, NHY ORO and State of New Hampshire.
- - Coordination of response activities is required procedurally for key NHY ORO personnel (SPMC) and New Hampshire officials (NHRERP). l Coordination between NHY ORO and the State of New l Hampshire was demonstrated adequately in the FEMA i l
l Graded Exercise. l!
l - There is no reg.tlatory requirement that adjacent states wit.hin an EFZ issut identical PARS. i Different PARS in different positions of the EPZ are not "conflicting."
(b) The sources relied on to support the underlying ? cs i
include EPA 250/1-75-001, 43 FR 58790, SPMC Section 3.1, !
r IP 1.1, IP 2. 5, IP 2.6, and IP 2.13, NHRERP, NUAEG-0654, i
Section J, and the MA CERP. i
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(c) None selected.
(d) Nond selected. ,
(e) None.
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21-2.4:
(a) Applicants' position on Contention JI-24 is that adequate provisions exist in the SPMC to assure prompt public notification of protective action recommendations once authorization is obtained from Commonwealth of Massachusetts officials.
The facts underlyjeg Applicants' position ares !
- The NHY ORO will seek authorization to notify the general public and implement protective actions I only from the Commonwealth of Massachusetts (SPMC at paqa 3.1-1). Authorization from EPZ municipalities is not sought by NHY ORO.
- SPMC provides for prompt notification of the public through VANS and EBS within 15 minutes of the ,
State's authorization. Refer to section 3.2 of the t
SPMC, IP 2.13, and IP 2.16.
- The provisions in the SPMC for public notification [
meet the time requirements which are recreamended in [
NUREG-0654. II.E.6 and Appendix 3(b) (2) (a) and 10 CFR 50, Appondix IV, D., 3, and also as detailed ;
in FEMA Guidance Memorandum AN-1.
(b) The sources of facts underlying Applicants' position include the SPMC, NUREG-0654/ FEMA-REP-1, Rev. 1, Supp. 1, FEMA Guidance Memorandum AN-1, EPA Manual of Protective Action Guides, EPA-520/1-75-001.
(c) None selected.
(d) None selected.
(e) None.
I
-31
JI-25:
(a) Applicants' position on JI-25 is that ORO personnel having the responsibility to make PAR recommendations are trained and qualified to carry cat their responsibilities. Appropriate procedures are in place to allow for PAR recommendations to be made prior to the arrival of the RHA.
The underlying facts supporting the Applicants' position are as follows:
- The Radiological Health Advisor is notified and reports to the NHY EOC at the Alert classification.
(SPMC, section 3.2.)
- Until relieved, the Seabrook Station Short Tern Emergency Director has the responsibility to ,
provide PARS to the commonwealth of Massachusetts (SPMC, section 3.2.5). This responsibility, which is directed by 10 CFR 50.47 and recommended by KUREG-0654 (J.7), is assumed by the onsite facility (i.e., control Room, Technical Support Center or Emergency operations Facility) which retains command and control of the onsite emergency organization.
(b) The sources supporting Applicants' underlying facts include SPMC, IP 1.1, Seabrook Station Radiological :
Emer,Jency Response Plan, Nuclear Production Emergency l l
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Response Program Manual, ER-1.5, 3.1 and 3.3, 10 CFR ,
I 50.47 and NUREG-0654.
(c) None selected. .
I (d) None selected. j (ej None. !
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JI-26:
(a) Applicants' position on JI-26 and the asserted basis is that the provisions and procedures of the SPMC for the ingestion pathway are adequate.
l The underlying facts supporting the Applicants' position are as follows:
1
- The SPMC provides for the prompt notification of i the appropriate officials concerning the nee'd for protective measures for the ingestion pathway EPz.
l Refer'to SPMC, section 3.11.IP 2.14, Attachment 71 l
- 1 IP 2.6, section 5.1; and IP 1.11, step 5.3.1.B.
- Appendix H identifies the Massachusetts agencies identified in the Massachusetts Ingestion Exposure Pathway Plan as having a role in the implementation of protective actions for the ingestion pathway.
j
- Sampling procedures included in the SPMC are consistent with the sampling procedures in NHRERP, NIAT Handbock, and the Massachusetts Ingestion l Pathway Plan.
- Samples collected by the NHY Offsite Response organizations are to be analyzed by YAEC personnel at the EOF or at Yankee Atomic Environmental Laboratory.
- The formulation of ingestion exposure pathway PARS l
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k is described in section 3.4.2.B of the SPMC and ,
IP 2.6.
~ Refer to Applicants' position on JI-13 regarding the background, cxperience and training for the Sample Collection Teams.
- Provisions in the SPMC make it unnecessary to be familiar with the local area. Refer to section 3.3 of the SPMC, Appendix L, Appendix I, and IP 2.4.
(b) The sources relied on for the facts supportin' JI-26 include SPMC, IP 2.6, IP 2.4, NHRERP, Massachusetts ;
Ingestion Exposure Pathway Plan, NIAT Handbook, FEMA Gufdince Memorandum IN-1, FEMA REP-12, NUREG-0654, FL3cral Radiological Emergency Response Plan, and the New England Compact on Radiological Health Protection. ,
l (c) None selected. ,
(d) None selected. !
(e) None. ;
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JI-27:
(a) Applicants' position on JI-27 is that the SPMC adequately establishes, defines, and coordinates the responsibilities and actions of the ORO and of other t
responding emergency organizations.
The underlying facts supporting the Applicants' position include:
- The roles of State and Ic si EOC Liaisons are l defined in the SPMC. ,
- Liaisons receive adequate training to advise f State / local officials on SPMC implementation.
1
- Routine governmental emergency response is anticipated to be within the capabilities of Commonwealth and local communities. ;
- Application of availa.ble resources, regardless of their origin, vill be in accordance with the SPMC, absent any other plan. See also positions on JI- ;
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61, JI-62, and JI-63.
l l - Mechanics of the delegation of legal authority from the Commonwealth to the ORO is detailed in the SPMC.
- Effective planning with the State of New Hampshire I is provided for in the SPMC and the NHRERP and in the conduct of joint drills and exercises.
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(b) The sources relied on to support the underlying facts include those listed under Applicants' position on JI-61 ,
I and JI-63; NUREG-0654, Rev. 1, supp. 1, pg. 2, and i I l l II.C.5; NHRERP, Vol. 4, Vol. 4A, Vol. 5; SPMC IPs 1.8 1 <
I l and 1.11.
(c) None selected. -
I (d) None selected. i (e) None. ,
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JI-28:
(a) Applicants' position on JI-28 is that the SPMC contains adequate provisions for the mobilization of ORO l personnel and the activation of the EOC, including back-up personnel.
The underlying facts supporting this position include:
l
- P:ey EOC personnel who are designated Stage 1 personnel will be notified at an Unusual Event by the NHY ORO Pager System.
l
- Acknowledgement of notification will be carried out by all ORO emergency response personnel notified [
using the Melita Emergency Telephone System (METS),
with the exception of the NHY offsite Response ,
Director, who will acknowledge notification by directly telephoning the Offsite Response EOC ,
j Contact Point.
- The SPMC at Appendix G-3 (EOC Contact Point Emergency Response Manual) provides that Stage 1 l personnel not accounted for within 15 minutes of their initial notification by pager will be l telephoned through the METS. If they cannot be contacted, alternates for their position will be l telephoned through the METS.
- METS has built-in verification capabilities for M
both pager-notified personnel and those notified by the system itself.
- Manual callout schemes have been developed to provide for notification of ORO emergency response personnel in the event the NHY Response Pager System and/or METS should fail.
See JI-11.
(b) The sources relied on for the underlying facts is the SPMC at $3.2 and Appendix G.
(c) None selected.
(d) None selected.
(e) None.
4 I
e JI-29:
(a) Applicants' position on JI-29 is that there is backup l
power for offsite communications relied upon for esergency communications with response personnel.
l The facts underlying this position are as fol2nws:
l - A diesel generator is currently in place to provide backup power for the communications systems powered from the offsite Response EOC.
- See Also Applicants' position on JI-30.
1 (b) The sources relied on to support the underlying facts is Seabrook Station Radiological Plan Program Manuti, Emergency Response ER-8,1, Emergency Equipment and Facility Inventory and Preparedness check, EOF l
l Preparedness Questionnaire.
(c) None selected.
(d) None selected.
(e) None.
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JI-30 (a) Applicants' position on JI-30 is that the SPMC does not rely too heavily on commercial telephone links for critical and essential emergency communications.
The underlying facts supporting this position are as follows:
- Initial notification of offsite authorities, including Massachusetts state entities, is made by Seabrook Station Control Room via the Nuclear Alert System (NAS) which does r.ot rely on commercial telephone line availability.
j
- As a backup to commercial telephone-based communications, the NHY ORO maintains the capability to communicate by radio with non-participating State and local governments via the existing emergency radio frequencies of the Massachusetts Governmental Interface (MAGI) radio network.
- In addition, backup communications between the NHY Offsite Response EOC and both the Massachusetts l Area I EOC and the Massachusetts State EOC is provided by the Nuclear Alert System (NAS)
I extension located at the Offsite Response EOC.
1 l
Additionally, communications between the ORO and 1
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e local EOCs is provided by cellular mobile t
telephones issued to ORO Local EOC Liaisons.
Initial notification of the Vehicular Alert and Notification System (VANG) Operators at the VANS Staging Areas will be made by the EOC Contact Point via radio.
- he
. Of fsite Response EOC communicates with the EBS radio station via dedicated telephone ring-down circuit or via a remote programming unit which aro l
indet mdent of New England Telephone Company office switching.
- Route Guides communicate with Staging Area personnel via portable radios, with commercial telephones as a backup.
(b) The sources relied on to support the underlying facts l are the SPMC, Sections 2.1, 4.1, 4.2, 4.5, 4.7, IP 2.11.
1 (c) None selected.
l (d) None selected.
(e) None.
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- 21. .31t (a) Applicants' position on JI-31 is that adequate meant i exist for lateral communications among NHY ORO field I personnel responsible for traffic management, evacuration ;
support and response to non-radiological emergencies.
The underlying facts supporting this position include:
- At least one Traffic Guide at each TCP, road crews, and all Route Guides will be issued portable radios capable of operating on the NHY ORO Emergency Radio Network. This 8-channe4 network provides the ability for these personnel to communicate directly with e. :h other, the EOC, and the ORO staging area.
- Once dispatched, ambulance / van drivers are equipped' I t
to communicat7 with the ORO Staging Area via the Medical Radio (EMS) Frequency.
l - All radio traffic on the NHY ORO Emergency .'.adio f l L l
Network is monitored by the Radio operators at the Offsite Response EOC.
- ORO field personnel have been trLined on radio use. i
( (b) Sources relied on to support these underlying facts l
include .9PMC. Section 4.5, Section 6, IP 2.11 at 5.1.3, ,
5.1.11, 5.4.7.H, IP 1.4 at Attachment 4.
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(c) None selected. I f
(d) None selected.
(e) None.
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JI-32:
(a) Applicants' position on JI-32 is that the provisions for communications with State and local response organizations as described in the Seabrook Plan for Massachusetts Communities are adequate.
The underlying facts supporting this contention include:
- The New Hampshire Yankee Offsite Response Organization (NHY ORO) has the capability to communicate via telephone with (NHY ORO)
Massachusetts Stato and local response organizations or Emergency Operations Centers (EOCs).
- The ORO also has the capability to receive and transmit via the existing emergency radio frequencies of the Massachusetts Governmental Interface (MAGI) .adio network. !
- Additional backup communications with local governments are provided through the ORO Local EOC '
Liaisons.
- Federal Communications Commission (FCC) Rules and Regulations at 47 CFR 90.145 and 47 CFR 90.421 allow private response organizations, such ar,the NHY ORO, emergency access to radio frequencies used by State and local government agencies.
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(b) The sources relied on for the underlying facts supporting this position include: SPMC, Section 4 and IP 1.4 and FCC Rules and Regulations.
(c) None selected.
(d) None selected. ,
)
(e) None.
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JI-33:
(a) Applicants' position on JI-33 is that the mechanism for providing emergency information to the public through the EBS is in place and can be activated in accordance with the Massachusetts EBS operational Plan or with provisions in the SPMC and its supporting agreements.
The underlying facts supporting this position include:
- Letters of Agreement between the NHY ORO and the EBS radio stations relied on in the SPMC are in i place to facilitate activation of the EBS system delegation of the requisite authority from appropriate Massachusetts governmental authority to the ORO to activate the EBS. A Letter of Agreement between NHY and the Massachusetts Emergency j
Broadcast System organization has also been t executed.
- The sample EBS messages relied on by the SPMC, I except supplemental Message 1, 2 and the Early School Dismissal message, clearly identify the Governor of Massachusetts or other State officials I as the source of the emerges.cy information being i
disseminated. l
- The SPMC, IP 2.13 at 5.1.6 provides for transmittal 1
of EBS messages to the appropriate Commonwealth l
officials before broadcast, allowing these
(
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=k officials the opportunity for review and/or modification.
- Consistent with the Operational Plan, the SPMC anticipates that the Governor of Massachusetts will l authorize activation of the EBS.
(b) The sources relied on for the underlying facts include IP 2.13, Attachment 4.24, Letters of Agreement, IP 2.13 i
at 5.1.6, Massachusetts 2BS Operational Plan. NUREG 1
0654/ FEMA-REP-1, Rev. 1. Supp. 1.
(c) None selected.
(d) None selected.
(e) None.
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JI-34:
i (a) Applicants' position on JI-34 is that the provisions for 1
notification and mobilization of the ORO and its support organizations and for notification of State and local .
I response organizations are adequate. 1 The underlying facts supporting the Applicants' position i includet ;
l "
- The SPMC assigns two individuals per shift to the NHY Offsite Response Contact Point position.
- The SPMC provides for the EOC Contact Point to be ;
l relieved by the Nuclear Alert System (NAS) i Communicator at ALERT (Appendix G-9, 2. 21) .
- - Implementation of the EOC Contact Point notification responsibilities is accomplished using i
automatic, mechanized systems including the Melita l Emergency Telenotification System (METS) and the NHY ORO Pager System. ,
- The SPMC at IP 1.1, coupled with procedures in the NHY Emergency Response Program Manual (NPER) at ER t
1.2, provide the same initial emergency information [
t to State officials and the ORO.
- Both the SPMC and supporting procedures developed i i
l to supplement the SPMC provide service contractors with direction on mobilizing their employees. (
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- The SPMC contains provision" for backup assignments in the event ORO personnel with support oeganization notification responsibilities are delayed or do not arrive. ORO personnel responsible for assessing staffing levels at facilities from which support service notifications are made (the Offsite Response EOC and Staging l
Area) are instructed, by procedure, to perform these assessment duties.
- The SPMC, NPER and the Massachusetts Comprehensive Emergency Response Plan provide multiple means for
( emergency notitication of Massachusetts State and local emergency response organizations.
l - The six Massachusetts EPZ communities have the 1
capabiliif to receive emergency notifications on a l 24-hour basis and do so routinely. Telephone numbers for these 24-hour contact points are listed in the SPMC, Appendix H.
- In addition, the SPMC provides for contacts with the Governor of Massachusetts (or his designee),
the Massachusetts Department of Public Health, the Massachusetts Civil Defense Agency / office of Emergency Preparedness and local emergency response otticials by the NHY Offsite Response Director or Assistant Offsite Response Directors in order to l
1 l
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' inform them of the capabilities, resources and availability of the NNY OR0.
- State and local governments are capable of notifying their contracted service organisations, such as snow removal and private ambulance companies.
! (b) The sources relied on for the underlying facts include l
SPMC at $ 3. 2. 2. 5, 54.3, 54.4, SPMC - Appendices G, H and M, IP 2.14, IP 2.10, IP 1.3, IP 1.8, IP 2.1, IP 3.2 and IP 3.1, NHY Energency Response Program Manual ER-1.2, Figure 2, the Commonwealth of Massachusetts Comprehensive Emergency Response Plan, the Town of West 1
Newbury Comprehensive Emergency Management Plan, the NHY I Massachusetts Support Plan for service providers.
(c) None selected.
l (d) None selected.
(e) None.
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21-258 (a) Applicants' position on JI-35 is that the sample emergency messages in the Seabrook Plan for Massachusetts Communities (SPMC) and the procedures therein for disseminating such messages are adequate.
The facts underlying Applicants' position include:
- The sample Emergency Broadcast System (EBS) nessages to be utilized in accordance with SPMC, IP l 2.13 comply with the applicable regulatory guidance l
and were developed with assistance provided by the Federal Emergency Management Agency (FEMA).
- IP 2.13 directs the ORO Public Notification Coordinator to contact the New Hampshire State EOC
, Operations Officer at the State EOC in Concord and 1
the "appropriate Massachusetts official," to establish coordination of EBS message issuance.
- Provisions for the coordination of emergency messages with local governments are included in the responsibilities of the Local EOC Liaison and the Local EOC Liaison Coordinator, as described in IP 1.8.
- All sample EBS messages, with the exception of Supplemental Messages 1, 2 and the Delayed School Dismissal message, identify the Governor of Massachusetts or other State officials as the l
l I
r source of the emergency information being disseminated.
- All ORC-generated public information intended for i
I release at the time of an emergency, including EBS messages and news releases provided to the media, are subject to review by the NHY offsite Response l Director. IP 2.12 at 5.2.2.d and IP 2.13 at 5.1.10.d.
- Consistency between public information issved b" l other response organizations and that generated by the ORO is ensured by the Public Information ;
1 Coordinator (PIC), per IP 2.12 at 5.3.4. r
- Specific response actions for the public are included in all sample EBS messages which include a sheltering PAR. These include instructions to maximize the benefits of sheltering space (e.g.,
l l close windows, shut off air exchange oystems, go to l room with fewest windows and doors).
l - Sample EBS messages which include an evacuation PAR clearly identify the major evacuation routes i I (Rot'.tes 1 and 1A, Interstates 95 and 495) leading to Reception Centers. They also advise listeners ,
l l l Lhat Traffic Guides will assist in directing i
motoricts to these routes. l l
l
- Sample EBS messages address beach populations, c
I ~72- ,
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i
. (b) The sources supp7tting the underlying facts include the j l SPMC, and IP 2.13, 1.8 and 2.12 and sample EBS messages. !
l (c) None selected. ;
e (d) None selefted.
I (e) None.
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JI.-36:
(a) Applicants' position on JI-36 is that there are numerous.
provisions in the SPMC for coordinating the activities y of ORO public information paraonnel located at the New Hampshire Yankee Offsite Response Energency Operations Center (EOC) and those at the Media Center, located at the Town Hall in Newington, NH.
The facts underlying Applicanta' position include:
- SPMC IP 2.12 provides specific instruction to the Public Information Advisor at the Eoc and to the Public Information Coordinator at the Media Center for coordinating and disseminating public information, including news releases. IP 2.12 also provides for coordination between ORO public information staff at these two facilities.
- The Media Relations Assistants, located at the Joint Telephone Information Center (JIIC), are the only ORO personnel responsible for communicating directly with the press by telephone. There is a Media Relations Policy Guide for guidance in responding to media inquiries.
(b) The sources relied on for the underlying facts include the SPMC. IP 2.12 at 5.3.3, IP 2.12 at 5. 3. 4, IP 2.12 at 5.1.6, IP 2.12 at Attachment 1-1A, Ip 2.12 at 5.1.4 IP 2.12 at 5.1.5.6, IP 2.12 at 5.2.2.E, IP 2.13 at t
l
5.1.5.A.2, IP 2.12 at Attachment 1-10, IP 2.12 at 5.1.4, IP 2.12 at 5.1.5.c, IP 2.12 at 5.2.2.E, IP 2.13 at 5.1.5.D.2, IP 2.12 at Attachment 7.1-D, IP 2.12 at 5.3.4, IP 2.12 at 5.1.6, IP 2.12 at Attachment 11, Media Relations Policy Guide.
l l (c) None selected.
l (d) Nonc selected.
(e) None.
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JI-37:
(a) Applicants' position on JI-37 is that provisions exist in both the Seabrook Station Radiological Emergency Plan (onsite plan) and the seabrook Plan for Massachusetts Communities to provide information, or access to information, to non-participating State and 3ccal governmants and their officials, j The facts underlying Applicants' poLition include:
! - The Seabrook Station Radiological Emergency Plan allows access to the EOF by Massachusetts officials and provides for their interface with utility personnel once inside.
- A "Massachusetts State Government Room" is provided at the EOC where Commonwealth representatives will be provided with or have access to all available emergency information.
(b) The sources supporting the underlying facts are NHY Nuclear Production Emergency Response Prcgram Manual ER-3.3, ER-3.3, IP 2 14, IP 1.11 IP 1.8, IP 1.1, IP 2.13, SPHC at Sec. 2.1 and Appendix G.
(c) None selected.
(d) None selected.
(e) None.
JI-38:
(a) Applicants' position on JI-38 is that there are adequate procedures in the seabrook Plan for Massachusetts Communities for coordination of rumor control efforts l
l between the various official sources of emergency l
l information.
l The facts underlying Applicants' position include:
The Public Information Advisor at the EOC is responsiblo for transmitting approved news releases to the Public Information Coordinatcr at the Media Center. The SPMC at IP 2.12 directs the ORO Publi:
Information Coordinator to contact lead Seabrook Station ERO, State and rederal public information personnel prior to the dissemination of news l releases.
- The structure of the ORO Rukor Control staff is depicted on the ORO organization chart (Plan, l
Tigure 2.1-1) and the responsibilities of each staffer are described in the SPMC at section 2.0.
- The "Rumor Control Policy Guide" (IP 2.12, Attachsent 14) provides the Rumor Control Assistants with guidance on how to respond to public inquiries on the emergency, including using approved NHV ORO, Seabrook Station, and State of 1
1 1
l f
l New Hampshire news releases in responding to rumors.
- The NHY Energency Response Plan Program Manual at ER-3.5 describes provisions for the conduct of news briefings at the Media Center, ERO personnel participating in news briefings include both public information specialists and technical experts.
- Technical experts are also assigned a role in the preliminary planning of EBS messages. This is ensured by IP 2.1, 5.1.8, where the Public Notification Coordinator uses input from the Radiological Health Advisor and the Technical Advisor for message planning purposes.
(b) The sources relied on for these underlying facts include SPMC, IP 2.12, SPMC, rigure 2.1-1, "Rumor contr eil Policy Guide," IP 2.12, Attachment 14, IP 2,1 and the Nuclear Production Emergency Response Program Manual at ER 3.5.
(c) None selected.
(d) None selected.
(e) None.
JI-39:
(a) Applicants' position on JI-39 is that provisions in the SPMC regarding the availability of pre-emergency information for the public meet all regulatory requirements.
The underlying facts supperting this position are as follows:
- Emergency information will be made available to transients in several different formats. These formats include emergency information printed on sdhesive labels and distributed to businesses and facilities frequented by transients public information posters and signs for display in areas frequented by transients and in locations with public bulletin boards, such as libraries and post offices fliers with information on evacuation routes, Reception Center locations, emergency protective actions and notification methods, to be nada available to businesses and facilities frequented by transienter and a second flier containing emergency bus route information. All of these materials will be printed in both English and French. In addition, a card to request more informatica vill be distributed to businesses and facilities frequented by transients.
- NHY has a program in place to identify and make arrangements for any emergency assistance the special needs population in the Massachusetts EPE may require. NHY will conduct a periodic sp6cial needs survey by mail to identify residents who require special help .in an energency, as described in the SPMC, Sect. 3.7.2.
- All components of the Public Information Material l
are clearly labeled "emergency" information. The Emergency plan Information calendar has a retention
! statement on the front and back covers and on the l
first page which instruct the recipient to save the material for reference in an emergency. Retention statements appear on other materials as well.
- The Emergency Ilan Inferintion calendar includes a two-page section which discusses the harmful and potentially life threatening effects of a radiological release.
l l
- Components of the Public Information Materials (PIM) clearly state that the emergency plan for the Massachusetts EPZ has been developed by NHY and that, in the event of an emergency, the ORO would recommend protective actions to Massachusetts 1
i l
I officials and etand ready to assist in their ;
implementation.
- PIM contains information regarding evacuation [
l l procedures for school children. l 1
- Contrary to MAC-24, basis (d.8), incorporated into -
JI-39 by reference, the PIM includes specific instruction on how to maximise the benefits of a j i
sheltering PAR as well as instructions for ;
implementing ad-hoc respiratory protection. !
- There is no regulatory requirement for instructicns f to pet owners in any of the applicable guidance !
(NUREG-0654, Planning Standard C or TEMA REP-11 l Guidance Memorar.dum) . However, the PIM does [
r include instructions for the protection of pets. [
(b) The sources for the underlying facts which support the 1
Applicants position include draft SPMC PIM, SPMC at i 3.7, TEMA REP-11. ;
(c) None selected.
(d) None selected. ,
I (e) wone. ;
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i JI-40 l
(a) Applicants' position on JI-40 is that the SPMC and its l l Implementing Procedures, cocpled with the ongoing NHY l Public Information program, provide adequate means for ,
the notification for the hearing impaired.
l f I The facts underlying Applicants' position include [
- NHY has developed a program to identify the special !
1 !
l needs popuistion and any special assistance they may require. The program includes a periodic special needs mail survey of the Massachusetts EPZ, ;
t the firct of which has been completed. In !
l addition, the program includes seeking support from f
special needs advocacy groups in this f identification process, through a community [
1 ,
outreach campaign. This program is described in the SPMC at i 3.7. :
l All Route cuides have been trained and drilled on i i
hearing-izpaired notification responsibilities, I
which are described in IP 2.10 of the SPMC. ;
- Route cuides with hearing-impaired notification j responsibilities will be issued maps (both t'avn and
{
evacuatir n route maps) to facilitate their aTrival l at assigned locations. L l
l
- The SPMC includes provisions to facilitate the flow l of emergency workers / vehicles, including Route !
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Guids , qugh Access Control Points. Route Gu carry badges identifying them as OAO er my orkers.
Rcuc .dec are provided portable radios allowing them to communicate any special help requests of hearing-impaired individuals to the Evacuation Support Dispatcher.
- Prescripted notification messages found in IP 2.10 are used to provide emergency instructions to the hearing Japaired. As an additional measure, neighbors are asked to check on their hearing-impaired neighbors or co-workers to make sure they understand emergency instructions. Advice to this effect will be disseminated to the public prior to an emergency through the Public Information Material (PIM).
(b) Tne scurces for the underlying facts include SPMC, 1
Appendix J, SPMC Plan at 3.7.2F, IP 2.10.
(c) None selected.
(d) None selected.
(e) None.
l i
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)
l JI-41 to JI-43:
l Applicants do not state their position on these j contentions because no discovery may be taken with respect to these contentions. l, I
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J I
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JI-44A and JI-44B See "Applicants' Motion for Summary Disposition of Joint Intervenor Contentions 44A and 44B," dated October 7, 1988.
)
JI-45:
(a) Applicants' position on JI-45 is that adequate protective measures ca.t and will be taken in a timely fashion for schools and day care centers.
The facts underlying Applicants' position include:
- Emergency response plans for schools, day care centers and nursery schools have been prepared for each type of facility in the EPZ, and contain information specific to the individual facilities.
Such plans have been provided to facility administrators for review and comment with concurrent offers to provide assistance in tailoring the plans to the needs ol' specific facilities.
- The incorrect procedure reference cited in MAG-47, Basis B, was an editorial error in Amendment 3 corrected in subsequent amendments of the SPMC. IP 1.9 establishes the positions involved while IP 2.7 instructs the individuals involved how to respond to protective action recommendations.
- Protective action recommendations are not
, disseminated by ORO personnel until approved by state officials.
- Existing bus company letters of agreement provido the resources to effect an evacuation of all Massachusetts EPZ schools.
- School and special facility enrollments in Appendix M reflect 1987-88 enrollments.
- Notifications of school superintendents begin at the ALERT classification.
- Six ORO School Liaisons are designated to notify public and private schools.
- Sheltering guidance for schools is offered in the individual facility plans, in instructional messages provided by the School Liaisons, and in EBS message texts.
- The SFMC assumes the ORO may be called upon to provide 100 percent of the resources required to evacuate schools, but clearly intends that school districts utilize available district transportation resource and seek assistance from the ORO as necessary. This option is outlined in the individual facility plans and School Liaison contacts messages.
- Estimated arrival times for buses at schools are provided for in IP 2.10.
(b) The sources for the facts underlying Applicants' position are the applicable sections of the SPMc, as cited.
)
(c) None selected. -
(d) None selected.
(e) None.
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JI-46:
(a) Applicants' position on JI-46 is that adequate protective measures can and will be taken for patients in the two hospitals within the Massachusetts EPZ and for contaminated, injured individuals.
The facts underlying Applicants' position include:
- The SPMC, Appendix M, reflects available space in host hospitals to receive evacuees from Amesbury and Anna Jaques Hospitals.
SPMC EPZ hospital plans and host hospital plans provide for the efficient coordination of hospital evacuation. Sufficient transportation resources are under agreement.
- Hospitals capable of treating contaminated, injured individuals are identified in SPMC, Appendix M.
(b) The sources for the facts underlying Applicants' position are the applicable sections of the SPMC cited.
(c) None selected.
(d) None selected.
(e) None.
~89-
)
+5 JI-47:
(a) Applicants' position on JI-47 is that adequa+e protective measures can and will be taken 1 n institutionalized persons who cannot be evacuated.
The facts underlying Applicants' position are The ORO may in accordance with the SPMC and in coordination with institution administrators recommend sheltering as the desired protective action.
- EPZ hospital facilities afford dose reduction in the event that the shelter option is deemed advisable.
Dosimetry and KI provisions are contained in the SPMC Amendment 6.
(b) The sources for the facts underlying Applicants' position are the SPMC, Sec. 3.6.
(c) None selected.
(d) None selected.
(e) None.
I I
~
JI-48:
(a) Applicants' position on JI-48 is that the SPMC provides adequately for the identification of the special needs resident population, for assessing the type of assistance required, and for updating and verifying the information.
The facts underlying Applicants' position include:
The SPMC, Appendix M, contains the latest special needs resident population information based un the results of a survey mailed to each EPZ housshold.
The updating of this information is an ongoing process.
Confidentiality of the special needs information is maintained within NHY.
The Appendix M listings contain the necessary information regarding the needs of individuals to support a determination of the appropriate emergency assistance required. The need for assistance is verified by special population liaisons when an emergency is declared.
- The special needs data is updated periodically in accordance with NUREG-0654 guidance.
(b) The sources for the facts underlying Applicants' position are the SPMC, Sec. 3.6. NUREG-0654.
(c) None selected.
(d) None selected.
(e) None.
1
~92~
JI-49:
(a) Applicants position on JI-49 is that adequate protective measures can and will be taken for the special needs resident population.
The facts underlying Applicants' position include:
- The Special Population Liaison for each community will make notifications to the non-institutionalized special population.
The NHY ORO maintains sufficient resources to ensure that local needs for specia. evacuation vehicles are met.
- The NHY ORO will stage and dispatch ambulances to non-institutionalized persons from its staging area.
- ORO Route Guides will provide notification and the capability to summon assistance, if needed, for those with hearing impairments.
- The American Red Cross provides for the needs of those individuals relocated to congregate care facilities.
- Evacuation transportation resources for all schools and special facilities in the Town of Newbury have been identified in the SPMC, Amendment 6, Appendix M.
- 4 (b) The sources of the facts underlying Applicants' position are the SPMC, Section 3.6 and IP 1.6, 1.9, 1.10, 2.7, Appendix M.
(c) None selected.
(d) None selected.
E (e) None. l L
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JI-50:
(a) Applicants' position on JI-50 is that the SPMC has identified the special facilities in the EPZ Which may require assistunce and that protective measures can and will be implemented for the special facilities in a timely and effective manner.
The facts underlying Applicants' position are:
- The SPMC, Amendment 6, Appendix M, contains the current listing of all EPZ special facilities.
- There is no regulatory requirement for facility-specific plans.
- Appropriate evacuation transportation resources for each facility have been identified based on the type of patient / resident at each facility.
- The incorrect procedure reference cited in MAG-54, Basis D, was an editorial error in Amendment 3 corrected in subsequent Amendments of the SPMC. IP 1.10 establishes the positions referenced, and IP 2.7 instructs personnel on protective action implementation.
- Special population notifications are made from the ORO staging area.
- PS$tective action recommendations are not disseminated by ORO personnel until approved by state officials.
-f5-
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Existing bus and ambulance company letters of agreement provide sufficient resources to effect an evacuation of all EPZ special facilities.
l Use of evacuation bed buses has been eliminated I from the SPMC.
l . >'
- Sheltering instructions provided for in the ,
l individual facility plans (Appendix F) as well as in Special Population Liaison contact messages
! provide for shelter implementation. Provisions for supplying KI and dosimetry are outlined in the SPMC.
(b) The sources for the facts underlying Applicants' i position are the SPMC, Soc. 3.4.2 and IP 2.14; Appendix l
I C; and IP 1.10 and 2.7.
(c) None selected.
(d) None selected.
j (e) None.
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JI-51:
(a) Applicants' position on JI-51 is that the SPMC has adequate provisions for making the host special facilities available in a tirely fashion and the host special facility is adequate for the care of special needs individuals.
The facts underlying Applicants' position are:
The letter of agreement between NHY and the host special facility states that the facilitj will be made available for use upon the declaration of an emergency. The SPMC does not rely upon the immediate availability of those areas used for special events in order to initially house those evacuated special populations designated for the facility.
An elevator will be installed for access to the second floor of the facility.
- The SPMC anticipates that the children evacuated to the host special facility from schools and day care centers will be only temporarily housed there until they are released to the custody of their parents or guardians. Nursing home patients and other special needs individuals will be moved if needed to specialized mass care facilities or released to family members.
1 The American Red Cross will meet the commitments of
'its charter in providing mass care services in the event of an evacuation related to Seabrook Station.
- Administrators of EPZ special facilities are free to make arrangemants for providing alternate host facilities for their clients during an evacuation.
The host special facility identified in the plan meets the ARC criteria for use as a mass care shelter.
(b) The sources for the facts underlying Applicants' position are the SPMC, Appendix C, Appendix F and Individual Special Facility Plans, the American Red Cross charter, American Red Cross procedure #3074.
(c) None selected.
(d) None selected.
(e) None.
i
J.J-ji2 (u) Applicants' position on JI-52 is that the Emergency Operations Facility, the Emergency Operations Center and the Media Center are adaquate, accessible facilities.
The underlying facts to support the Applicants' position include:
- The EOF and the EOC are provided with backup power.
Commonwealth officials are notified of the emergency at the Unusual Event.
- Alternatives (diversion route or helicopter transport) are available to Commonwealth officials.
- All Commonwealth officials will be allowed through access control enforced by the State of New Hampshire.
(b) The uources relied on to support the underlying facts include the SPMC, Sections 3.0, 5.0, Appendix J, IP 1.3, the NHRERP, Vol. 2, Vol. 6, the SSREP, p. 6-2 ER-1.2, ER-2.0. SPMC, Appendix C.
(c) None selected.
(d) None selected.
(e) None.
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JI-53:
See Response to Interrogatory 23.
J. . ;
-100-
e JI-54:
(a) Applicants' position on JI-54 is that the American Red Cross ( ARC) will respond to an emergency at Seabrook Station.
The underlying facts to support the Applicants',pos.iticn include:
A letter of understanding exists between the NH" l ORO and the American Red Cross.
l -
ARC will provide mass care services and will cooperate with private organizations including NHY.
l Planning was carried out by NHY using ARC l guidelines.
1 Means for notifying the ARC during an emergency are provided in the SPMC (Section 2.0, Section 3.0; IP 1.1 and IP 1.6).
l
- Training on the operation of mass care facilities is internal to ARC.
- A list of certified shelter managers in Massachusetts is already available to ARC through its existing planning for nuclear power plant and other type emergencies.
(b) The sources relied on to support the underlying facts include the SPMC, Sections 2.0, 3.0; IP 1.11 and 1.6; and Appendix C, ARC procedures $3074.
(c) None selected.
-101-
[
I
(d) None selected.
(e) None selected.
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-102- I
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JI-55:
(a) Applicants' position on JI-55 is that the SPMC provides reasonable assurance that an adequate number of buses, ambulances, wheelchair vans, vans, tow trucks and associated drivers are available to respond in s tircely fashion to an emergency situation at Seabrook Station.
The underlying facts to support the Applicants position are as follows:
- NHY has reached agreement with P. sufficient number of vehicle providers to ensure that the numher of manned vehicles available to the ORO provides a pool of resources from which the ORO may draw to meet the needs of an emergency response.
- Vehicle drivers are notified by the management of the supporting company.
- IP 2.10 is designed to provide guidance in the identification and assignment of available resources to needs identified during the course of an emergency.
- Personnel responsible for providing dosimetry and dispatch of vehicle drivers are mobilized at an Alert event classification in order to be in position to perform these functions should conditions degrade.
-103-b
Contract personnel are provided training under the provisions of the SPMC.
The conduct of NHY in negotiating agreements and recruiting personnel did not include misrepresentations as alleged by the contention.
Agreements with service providers contain the terms under which they shall provide stated services. As part of the annual review process, such agreements are reviewed and updated as needed.
Transportation resources under agreement will meet the needs of special facilities.
- The number of transit dependent persons is derived from population estimates provided by the ETE.
(b) The sources relied upon to support these facts include SPMC, IP 1.31 IP 1.91 IP 1.10; IP 2.1; IP 2.7; IP 2.10; and Appendix Mt NHRERP, Volume 6. Also see responso to Town of Amesbury Interrogatory Nos. 7 and 8.
(c) None selected.
(d) None selected.
(e) None.
-104-
JI-56:
(a) Applicants' position on JI-56 is that the SPMC includes l4 adequate provisions for radiological monitoring and 1
l Decontamination of evacuees and emergency workers.
The underlying facts in support of Applicants' position are
- Monitoring / Decontamination Leaders are notified and report to the Staging Area at the Alert classification, and go to monitoring trailers upon declaration of Site l Area Emergency. lionitoring/ Decontamination Personnel eport directly to monitoring trailers upon notification l at 'te Area Emergency (SPMC, section 2.1, Figure 2.1-1 1
and Tat.9 3 *
- The description of the Monitoring Trailers is provided by section 5.2.4 of the SPMC, Figuras 5.2.9 and 5.2.10, j IP 3.3 and IP 3.4. The number of monitoring stations per trailer at the Reception Center is designed to monitor 20% of the population in the Massachusetto portion of the EPZ within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. There is no time requirement for monitoring of emergency workers.
- SPMC does not rely solely upon showering as a decontamination method. Other decontamination methodo 1
provided by the SPMC include the use of wet wipes, washing area with mild soap, and a change of clothing.
l 1 -105-l . _ . _ _ _
showering is used only after simpler, less disruptive methods fail. (SPMC at p. 3.5-9 and in IP 2.9.)
l l
l The number of radiation survey instruments listed in Appendix I supports the number of instruments required for monitoring activities as described in section 3.5.3 l
and by IP 2.9.
(b) The source of underlying facts in support of Applicants'
) position is the SPMC as cited and NUREG-0654.
l (c) None selected.
(d) None selected.
(e) None.
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t
-106-i
JI-57:
(a) Applicant's position on JI-57 is that the SPMC provides adequate means for handling and disposal of contaminated i
waste water and materials.
The underlying facts in support of Applicants' position are
- Radioactive waste genersted during the emergency phase of an accident is set aside for licensed disposal during the recovery phase. (SPMC at pages 3.5-6 and 3.5-10) Procedures addressing the !
handling and disposal of contaminated wastes are IP 2.9, IP 3.3 and IP 3.4. Disposal of contaminated waste is to be coordinated by the Radiological Health Advisor with NHY. Disposal and transportation services will be provided by a licensed disposal firm and will be consistent with codes and regulations for psckagirag/ transport / processing of contaminated waste.
- A current contract has been entered into between NHY and a licensed disposal firm for contaminated waste disposal and transportation services.
(b) The source for the underlying facts supporting Applicants' position is the SPMC as cited and Appendix c.
-107-(
(c) None selected.
(d) None selected.
(e) None.
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-108-(
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I i
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l J.1-lliA:
(a) The Applicants' position on JI-58 is that LOAs and other j documentation between the NHY ORO and service providers constitute an adequate basis for provision of sufficient l l
resources for the required emergency response. l The underlying facts to support the Applicants' position include:
- As part of the annual plan review cycle, all letters of agreement and contracts are reviewed and l
( updated as necessary. l l
l - All agreements with service providers are l considered to be valid. See Applicants' position i
on JI-59 and JI-11.
(b) The sources relied on to support the underlying facts l
include the SPMC, Section 7.2; IP 1.1. IP 2.17, Appendix C. l l
(c) None selected. t (d) None selected. !
(e) None. !
-109-
I t
JI-59 i (a), (b) The Applicants' position on JI-59 is that the IDAs l
and contracts which form the underlying basis of ,
this contention have not been rejected by the Bankruptcy court. !
(c) None selected. [
i.
(d) None c. elected. t (e) None.
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-110-I
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JI-60:
(a) Applicants' position on JI-60 is that the SPMC provides for adequa'ce equipmet.- and equipment transportation to Newbury Salisbury and West Newbury at the time of an emergency.
The facts underlying the Applicants' positions include:
Appendix I of the SPMC is the equipment inventory for the ORO.
Appendix J of the SPMC contains the procedures for obtaining, transporting, cnd setting op traffic and ,
access control equipment.
Blinking light cones and barricades are not listed in the inventory or maintained in stock as they are
! not used by the SPMC.
(b) The sources for the facts underlying Applicants' position include SPMC Appendix I, Appendix J, IP 3.2 and NHRERP, Vol . 6.
(c) None selected.
(d) None selected.
(e) No r_ e .
-111-
JI-61:
(a) Applicants' position on JI-61 is that the State and local response under SPMC Mode 1 is not ad hoc.
The underlying facts to support the Applicants' position include:
- The conceptual basis of the SPMC incorporates the presumption that State and local officials will "generally follow" t?:0 SPMC, absent any other plans.
- The SPMC provides State and Local EOC Liaisons to explain the plan to responding State / local governments who have not participated in planning.
Therefore, the SPMC itself is the blueprint for State and local agencies to follow.
- The Commonwealth's emergency decision-making structure is already prepared in accordance with the Massachusetts CERP for radiological and other emergency responses.
- Local officials are familiar with the resources available within their communities ana their own decision-making chain of command, therefore, response is not ad hoc.
(b) The sources relied on to support the underlying facts include those shown under positions on JI 27 and JI 63, i
-112-f --
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Massachusetts CERP esp. Appendix 3, CERPs Town of Amesbury, Town of west tiewbury.
(c) None selected.
(d) None selected.
(e) None.
-113-
U in21 (a) Applicants' position on JI-62 is that the SPMC was expressly designed to facilitate early and purposeful integration of utility /ORO with state / local emergency response decision-making and implementation.
(b) The source of the f.ncts underlying Applicants' position are the SPMC, Section 3.1 and Tables 2.2-1 and 2.2-2.
(c) None selected.
(d) None selected.
(e) None.
-114-
JI-63 (a) Applicants' position on JI-63 is that the SPMC does not rely on state or local resources to implement the SPMC, but has the capability to integrate these resources as i they may become available.
The underlying facts to support the Applicants' position include:
Integration of state / local response capabilities l with those of the NHY Offsite Response Organization is addressed in the SPMC, Section 3.1.
The Seabrook Plan for Massachusetts communities does not rely on this support and maintains the capability to implement these duties if the state l
l and local government are unable or unwilling to do so.
l l
(b) The sources relied on to support the underlying facts j include Sections 1.0, 2.0, 3.0; SPMC; IP 1.1, IP 2.14; NUREG-0654.
(c) None selected.
(d) None selected.
(e) None.
1 l
t
-115-1
ATTACHMENT B RESUME NICHOLAS X. LIEWEH
" EDUCATION .
1972 - 1982 U.S. Navy Training Schools including the Following:
Machinist Mate 'A' School 01G Prototype Nuclear Power Tralning Unit Naval Nuclear Power School Emergency Welding School Gauge Calibration School Career Counseling School Quality Control School Submarme QA Inspector 1970 - 1971 University of Arkansas 1970 Subiaco Academy; Graduated 1983 Mohegan Community College: Associate in Art Oeqree EXPERIENCE February 1988 - Present Seatrook Nuclear Station Emergency Plan Instructor Seatrook. NH the Responsible for the Emergency Planning and Training activities associatee with Sestrook Nuclear Power Station: Review and evslustfort of offsite emergency response plans and procacures: Review and revision of lesson plans and implementation of anc, serving training programs for the utility's Offsite Response Organization (ORO) as a Controller / Evaluator for activities associated with the FEMA Graced Exercise Program.
August 1987 - January 1988 Peach Bottom Atomic Power Station Peasn tettom. PA GET/HP Instructor Health Physics and worker Assigned to Project Radiation Protection Group (PRPG).
HP lob coverage. Al. ARA for wortrars lesson plan development. In the following areas:Once training commenced gave instruction in and HP's, and ractation work permits.
the following areas: GET, GRT, and HP orientation training -- which included A1. ARA.
Instrumentation and procedure training. All personnel were given project specifics training, which detailed the NRC and PECo's comrnitment to excellence. SWR and a pipe replacement overview. Presented het particle training to workers and a specific Mot porticle lesson to HP's.
January 1987 - July 1957 Seabreak Nuclear Station General Employee Training Instructor Sestreek. NH Instruction of power plant and contractor personnel on radiation. risks. security, Rewrote respiratory protection, radiological procedures and practical factors.
plant's GET exam bank.
Three Mlle island Nuclear Generating Station October 1948 - January 1987 Senior Health Physics Technician Middletown, PA Reactor / Auxiliary tullJing outage coverage. Extensive ecverage for turbine maintenance during overhaul.
Page 2 NICHOLAS K. LIEWER EXPERIENCE (continued)
Nuclear Support Services. Inc. Septembst 1986 H:rsney PA Office Staffing Assistant .
March 1986 - July 1986 Seabrook Nuclear Station General Employee Training Instructor Seabrook, NH instruction of power plant and contractor personnel on radiation. risks, security.
respiratory protection, radiological procedures anc practical factors.
Connecticut yankee Atomic Power Station Decemoer 1985 - March 1986 ALARA Supervisor Haddam Neck. CT Descon-Assigned to the Connecticut Yankee Nuclear Power Station's ALARA department. 2esocnsioihtles l sible for ALARA reviews. RWP coding tracking ano dose assessment. '
also inctucea the supervision of the ALARA worn force.
March 1985 - November .985 North Anna Nuclear Powur Plant General Employee Training instructor Mineral. VA instruction of power plant and Contractor personnet on radiation, risks. security, Operated respiratory protection. raalological procedures, and practical factors.
and maintained a dynatech Frontier 260B Fit Booth.
Three Mlle Island Nuclear Generating Stati'on December 1984 - March 1985 Senior Health Physics Technician Middletown. PA l Routine health physics coverage.
Connecticut yankee Atomic Power Station July 1984 - November 1984 Health Physic Supervisor
' Heddam Neck CT Supervision of Health Physics To:nnicians during refueling Provided outage. involved containment coveragewith for i in-process and training of new HP Technicians.
miscellaneous work in loops and steam generator eddy current testing.
Three Mlle Island Nuclear Generating Station March 1983 - July 1984 L
Senior Health Physics Technician Middletow.T. PA Coverage of steam generator eddy current. RWP writing reactor building entry coverage / support. Routine /special radiation elr and contamination surveys.
May 1982 - March 1983 U.S. Navy First Class Petty Officer - Machinery USS Alexander Hamilton (SSEN-617) Dlvielen Olrectly responsible for supervision of eighteen subordinates who maintained 'he engine room in a constant state of readineas witil3 performin0 major repairs and main-tenance to associated e quipment. Assisted in the preparation and presentation of the revision of the r7echanical sysWms engineering department lesson plans and department question bank. Alto, assisted in the planning and scheduling of major prt-mary plant maintenance, such as charging pump reflef vatve replacement, steam genera-tot tellet valve testing and maintaining all QA records and documentation associated therewitit.
I RONALD ALAN THOMPSON 7/88 i
B C*1VE i i
I Graduated from Grove City College, Grove City, PA, j
/ DUCAT 80N Bachelor of Arts Degree in Economics. i j
I ummmmmmmmmmmmer l EXPERIENCE Seabrook Station, Seabrook, NH j Senior '.:ngineer - Developed and conducted training [
f5/88to for volunteers participating in a utility sponsored l jpresent offsite emergency plan.in preparation for a FEMA j evaluated exercise, j l
j 1
i Completed a Job Analysis for the onsite emergency l response organization. j Brunswick Steam Electric Plant, Southport, NC f
] !
4/86 to Emergency Planning Instructor - Conducted a Job :
9/87 Task Analysis for the site emergency organization. !
i Developed and conducted emergency plan training f courses for onsite groups. !
i vogtle Nuclear Powe" Station, Augusta, GA 3/86 to Emergency Planning Instructor - Revised and conducted 4/86 cmergency plan training courses in preparation for an j NRC evaluated exercise, Page 1 of 3 f
i I __,
l
! RONALD ALAN THOMPSON l
\
Palo Verda Nuclear Generhting Station, Phoenix, AZ f6/85to Radiation Protection Technician Instructor -
l 2/86 f Developed tcchnician training courses for INPO Accreditation.
i
! Completed a two week Instructor Training Courso j and a two week CANBERRA Gamma Spectroscopy course. ,
i
' I 12/84 to Lead General Employeo Training Instructor - !
6/85 Coordinated training on Radiation Work Practices, Yire Brigade, Energency Planning, Site Access Arraining, and First Aid /CPR.
- i 6/84 to Radiation Protection Technician Instructor -
12/84 Developed and conducted training for Radiation
' Protection Technicians. \
A 10/83 to General Enployee Training Instructor - Developed !
6/84 and conducted Radiation Worker Practices training, i i
}
Callaway Nuclear Statio'n, Columbia, MO i l
1/83 to Radiological Enginter - Coordinated the development i 9/83 of the Emergency Plan Manual Calculation Dose l I
Assessment Procedures.
l N _ _ . . !
Page 2 of 3 f
y ATTACHMENT C .
ORO INSTRUCTORS Sept. 1987 Sept. 1988 START END SUBJECT Helig DAIL. DAIX ARTA(1), REASON Jon Arms 8/03/87 12/30/87 A. R. C. End of contract.
D F. C, 1
D6nnis Brendel 9/08/87 7/25/88 A. D. F. End of contract.
C Cary Catapano 8/03/87 N/A F See Note (1).
Ken conover 5/04/88 8/19/88 A, C E. Received another F. C. H assignment.
Rob Cotter 8/03/87 7/29/88 A, C, D, End of contract.
E, F. C.
H 2/01/88 3/23/88 E Terminated.
Rose Frost 8/03/87 N/A F Available if needed, not currently assigned.
5/04/88 7/22/88 AE Terminated.
Sheila Hertel 8/03/87 N/A A C, E. See Note (1).
F. C. H Paul Kovach 8/03/87 7/21/88 A, B, C, End of contract.
E F. C.
H Nick Lewis 9/01/87 12/31/87 A, C, D, End of contract.
F. C H Dennis Fachulski 8/31/87 7/29/88 A, C, D. End of contract.
F. C H
(
Linda Paraltore 8/03/87 7/01/88 A,C D, End of contract.
F, C, H, I
Karshalle Pavey 8/03/87 12/18/87 A, 8, C. End of contract.
E, F. C.
H Mark Poudrier 1/04/88 9,'02/88 A,C D, End of contract.
F. C H l
l John Rawlston 1/18/88 5/11/88 A, C, D. Death in family.
l E, F. C, H
Larry Rundlett 2/05/88 N/A A, C, D. See Note (1).
F C, H Pat Ryan 8/03/87 N/A F. H See Note (1).
1/22/88 2/22/88 D. F. C Terainated.
Art Tate 1/18/88 4/29/88 A, B, C, Received another D E,F, assignment.
l CH 1
Ron Thurlow 8/03/87 9/08/88 D, F, I Kathy VonWald 8/03/87 N/A A See Note (1).
KEY TO SUILJECT AREA (S):
1 A E Plan Overview F. Communications B Emergency Management C Facilities C Transportation H Traffic Control D Health Physics I - Protective Actions E Public Information l
1
NOTE:
- 1. Individual has been reassigned to another assignment at Seabrook station. They are, however, availe.ble to perform training when
. requested.
-3
ATTACHP2NT D RESLHES _0RO. INSTRUCTORS (Note: Personal internation has been redacted.)
L/99855.31d
{
l O i INPELLkcowwmY JONATHAN A. ARMS Senior Engineer B.S. in Radiological Health Physics EDUCAi!ON Lniversity of Lowell Lowell, l'.assachusetts Mr. Ams is a Senior Engineer in the Power Services EXPERIENCE Of vision with a strong background in Emergency Planning, Health Physics Avaiting, and Operational Health Physics. Mr. Ams' recent responsibilities incluce revision of Operations, Maintenance, and Health Physics procedures at Pilgrim Nuclear Power Station, cut to the radiological impact of Hydrogen Water Chemistry. k'ith Impell, Mr. Ams has also been responsible for development of plume exposure pathway and ingestion exposure pathway radiological emergency response plans and implementing procedures . development of emergency preparedness scenarios, interfacing with Civil Defense Directors and Housing Authority Of rectors, and providing controller / evaluator support for emergencyAdditionally Mr. Ams has preparecness exercises.
performed comprehensive aucits of Health Physics programs.
Prior to joining Impell, Mr. Ams held the position of Corporate Radiation Protection Specialist for Mississippi Power & Light's Grand Gulf Nuclear Station, where he perfomed appraisals of the Health 9hysics program for the Vice President, Nuclear Operations. The appraisals not only identified deficiencies but identified root causes and provided prioritized practical corrective action recommendatiot.s. His emergency preparedness responsibilities included perfoming dose assessment and making protective action recommendations,
, training offsite monitoring teams, and performing appraisals of Health Physics emergency preparedness Additionally, and hospital emergency preparedness.
Mr. Ams was responsible for writing Health Physics procedures, and for the reporting of radioactive effluent releases.
22s sRCm.Q HOLLOW RC AD
- MLLv1LLL Ntw YORK 11747
- tst6) 42o s200
t JONATHAN A A;tMS Senior Engineer PAGE TWO I
EXPERIENCE Prior to this, Pr. Arms served as Supervisor of (Continued) Health Physics Records and Desimetry at the Pilgrim Nuclear Power Station, where he was responsible for l the supervision of a staff of ten Health Physics <
records and dosinetry clerks and technicians. His ,
responsibilities also included management of the l
i exposure evaluation reports prog Sm and management of the TLD quality assurance program. Additionally, lir. Ams was responsible for the developeent and writing of ractation protection procedures.
!!r. Arms is also an AhS! 3.1 Cualified Health Physics Technician, having provided refueling outage Health Physics job coverage at Indian Point Unit !!,
Pilgrim, and Rancno Seco Nuclear Power Stations.
SPECIAL TRAINING: Kepner Tregoe Problem Solving and Decision 14aking -
l Kepner Tregoe, Inc.
Corporate Coenunications - Mississippi Power & Light f Company Health Physics Auditor Training - Radiation l
Protection Associates, Inc. [
ALARA - General Dynamics [
i Respiratory Protection for Nuclear Power Plants -
Radiation Protection Associates, Inc. f
( i' Internal Dostmetry (J.ii. Poston - Instructor) -
Technical Management Resources, Inc. ;
Nuclear Power Plant Systems (6 weks) - Mississippi i Power 4 Light Company ;
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l 8'
- 1 l "
DENNIS BRENDAL Manager Cperations Support Division. General Energy Systems POSITION:
Corporation Doctorate in Philosophy in Environmental Health Sciences.
EDUCATION:
University of Michigan, 1972 Master of Science in Environmental Health Science. University of Michigan. 196T Bachelor of Arts in Chemistry, Esporia State University, Kansas. 1964 and Experienced Health Physicist. Emergency Planner. Chemist, QUALIFICATICHS Manager with over 12 years in the nuclear power industry plus SUMMMARY another 7 years working with radioactive saterial as 6 health Emergency planning experience has included pnysicist/ chemist. Pre-TM1 experience both pre-TM! and post-TM! involvement.
included the initial development of an emergency planning program for WNP-2 including responsibilities for b 3
for Dairyland Power to obtain a full power license forPost Lacrosse.
J emergency planning program for a DOE production He also/ par-power reactor into a program comparaD1e to NRC criteria.
ticipated in over seven special major audits of the DOE reactor l saf ety systems and emergency planning progree Mr. by n Science Foundation as a result of the Chernobyl accident.
Brendal has extensive experience in working with feders),
J state, and local emergency planning agencies and po)itica) entities.
l
! Prior to joining GENSYS, Mr. Brendal was Director of the Safety PROFESSIONAL E.xPERIENCE and Environmental Engineering Department for UNC N Industries.
vities of UNC's safety progrees for the DOE M reactor at Hanford in the areas of emergency planning, health physics,
, environmental programs, nuclear safety, safety assessment He and analysis (PRA), occupational safety, and fireOvring protection.
this
, managed a professional staff of 105 people. period
- Safety for three of the past four years.
J
- Prior to UNC Industries. Mr. Brendal was Vice President Environeental Affairs and Safety for the Bunker Hill Company.
- He directed the environmental progrees, industrial hygiene program and the Plant and Mine Safety Department for Ounkera Hill's lead smelter. Zinc plant, l
C/LK1463
'* n- %
e 2
eines. In addition, he als'o directed the compenies forestry business. He had extensive contact with the Idaho State Legislature, Congressional delegations, Env<rannental Protection Agency, Idaho State Department of Health and He Welfare, and Occupations) Safety and Health Agency (OSHA).
was successful in increasing Sunker Hi11's forestry business by 250% in a 2 year period and in obtaintne numerou: variances He from EPA CSHA, and State lens and regulatory Standards.
was the chairman of the Idaho Mining Association Environmental Committee.
Prior to Bunker Hill, Mr. Brenda) was the Manager. Radiological He was Programs for Washington Public Pcwor f.upply System. ;
responsible for the development of the radiological pr0 gram and l the emergency preparecness program for WNP 2 as an This NTOL plant and for the other four plants inunder construction.
the development and ieplemen-included direct involvement tation of the emergency progres ircluding extensive interface The activities with local, state, and federal ugencies.
emergency preparedness program was in the final stages of acceptance by the NRC when TMt occurred.
Prior to Washington Public Power Supply Systes. Mr. Brendal was an Environmental !cientist with Dairyland Power Cooperative.
He provided environmental expertise in the areas of radiation, water, sir, meteorology, noise, and solid wasteHeforwas therespon- nuclear and fossil units operated by Dairyland Power.
sible f or implementing extensive modifications to existing fossil units to eeet curr9nt water, air, and solid waste regu-This involved '41gnificant interf ace activities with lations. He was also responsible local, state, and f eder41 ogencies.
for the development of the company energency plans or LeCrosse to obtain a full power license and f or the development of an emergency plan for the companies hydroelectric plant to eeet l Federa) Power Comeir.ston requirements.
f Prior to Dairyland Power, Mr. Brenda) worked as a university !
health physicist / chemist at the University of Michigan imple-menting various environmental monitoring progress Before this, for theas a he worked University of Michigan Reactor.
Supervising Cnenist for the state of Kansas (eplementing the environments) program including the State environmental -
radiation rionitoring progree. ,
l I
I C/LK1463.1
{ _ . --
Professional Qualifications of Cary J. Catapano ,
President. Allcoea Inc. ~
My name is Cary J. Catapane I am the Frest-dent of A11Com Inc., a company specialtaing in design of emergency communi-cations systems founded by re in July of 1984 I am certified by the National Association of Radio and Telecomunica-ilons Engineers (NARTE) as Ce .munications Engineer with special skill endorse-cents in three areas: Land Mobile Systems. Land Mobile Interference and Analysis and Suppression, and Inside Plant Telephone Engineering. I am also a senior member of NARTE.
I hole a "Lifetime" TCC Cenersi. Class Radiotelephone Engineering license and I am certified as an R.T. Engineering Technician by the National Associa-tien of Eusiness and Educational Radio (NABER). I am also a rember of NABERS Prof essional Mobile Radio Service Section.
I have studied electrical engineering at Suffolk Com,. unity College and t
other related curriculum at feene State College and Nathaniel Hawthorne College.
I am a 1970 graduate of L.A. Vilson Tech where I studied Radio and Television Electronic Comunications.
I have additional special education in the following areast microwave radio system design, telephone systems, telephone syster.s traffic theory and network design. I have also participated in 14 special training seminars covering all aspects of the land mobile coe. unications field. I have deve-loped engineering progra-s to aid in the prediction and elteinstion of the I
j harmful interference cauced by undesired radio transmissions.
Since July of 1955 my company has been employed by New Hampshire Yankee to conduct an evaluation of the comunications networks utilized by the coemunities involved with the Seabrook Station Radiological Emergency Response Plan. I assumed the lead responsibility for this project which consisted of four phases. The objectives of Phase I were to study and identify the types of systems currently in place and identify existir! problem areas.
This first phase involved extensive field work and interviews with public saf ety of ficials of the states, counties, and local municipalities. Phase 2 invelved the analysis of this information in order to determine the effect that the additional RERP communications would have on the existing systems and to formulate the engineering changes. Subsequent seetings were held again with public saf ety of ficials to review the recomendations. Phase 3 involved ,
the instalh tien test and debug of all of the equipment. Phase 4 will involve further refinement of these systems, documentation and training.
Prior to my beginning this project my firm assisted Veruent Yankee in the relocation of their Emergency Operations Pacility to its new location.
My responsibility was for the design and installation of the radio comunica.
tions rystems for this facility and to minimize and eliminate any interference We also that resulted from the co. location of coanunications facilities.
perfon sed this same function for Yankee Atomic Electric Company's emergency operations f acility for the Rowe. MA Nuclear Power Ple it. As part of this current project I have assisted the utility and the State af New Hamps. hire wi'.h design and installation of the communications networks for the energency
<perations facility and the State's Incident Tield Office. Ve also provided the same assistance to the Comonwealth of Massachusetts.
Prior to my founding A11Com Inc. I was esp 19yed as the General Manager
)
2 I .
t of HEV Coe.+.unicatins. Inc. as part of my duties shile at HEV April of 1981 ,
to the August rf 19821 vas the project manager and engineer for the design e
and installation of the emergency comunications systems that form the back-bone of the public notification system and emergency convounications networks j for 34 eunicipalities and 3 state civil defense agencies involved with the Vereont Yankee Nuclear Power Plant and Yankee Atomic Electric Company. Rove.
j HA Nuclear Power Plant. This project involved an assessment of the existing l
comunications capabilities, extensive interviews with local public safety l
of ficials, the design of new comunications systems and integration with exist- i l
ing systems.
I had the lead responsibility for the entire project including i the training and docueentation shich included two comprehensive technical manuals which provide the foundation f or the utilities FDIA-43 submittals. , [
]
l During the initial phase of this project much of the existing guidance for the design of public notification systees and emergency comunications systems i
[
did not exist. I provided technical support to Yankee Atomic Electric Company in draf ting ceenents to TDtA's proposed guidance for the acceptance of alert f i
and notification systems. !
As part of this project I also designed a special system in cooperation with NOAA (National Weather Service) which links vital information from the National Vesther Service of fices in Burlington. Vermont to over 8,000 Alert receivers located approximately 100 miles away in some of the residences within the Emergency Planning Zones of both plants. This systes operates 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
365 days a year, My firm currently has the responsibility for the surveillance and main-tenance prograss for these systees. Since early,1982 " Sy have been in opera-ter 9 M).
tion functioning with a very high percentage of opr i
f .
i f'
- I have also participated in six full scale federally witnessed emergency exercises and many nueerous full scale drills providing comunications support (troubleshooting, diagnosis and emergency repair) to the utilities and state agencies. My firm currently provides these emergency comunications support services to three nuclear power f ar111 ties in New England.
Prior to the Seabrook project, while at A11Com and HEV. I had been ;
called in as an expert to "debug" rany types of comunications systems that !
j were not functioning as intended. Also during this time I designed and in-This work included f stalled rany types of electronic comunications systems. l j
projects for state agencies, electric utilities, county governrents local i' public safety agencies and regional fire mutual aid compacts, business and industrial concerns. Vith divestiture of the Bell System this work grew to '
include the design and installation of telephone networks and increasing I currently hold tech-liaison work with the Bell Operation'Co.npany (NYNEX).
nical certifications f or f our dif ferent manuf acturers of telephone systems f I
including two sophisticated PABX systems.
\
=================== l i
ummun u- -- -- ---u- -
un-un .
w .,
- s KENNETH W. CONOVER l
l
SUMMARY
f Mr. Conover has over 16 years of emergency preparednese and fire I protection experience with over 11 years of this directly related to planning for nuclear power plants. He has developed '
specialized knowledge related to the following compliance standards, offsite radiological energency plans and procedure developnent, exercise design and evaluation, radiological survey '
instruments, training programs, communication systems, l
notification and varning systems, and nulti-hazards planning.
l Mr. Conover has been an active member of the Fire Service for t over 16 years. He is one of 30 fire protection and energency planning professienals nationwide that have been requested to ,
serve on the National Advisory Committee for SARA Titi III to '
develop incident command standards for the Fire Service. He will - <
be ccmpleting his work on this comnittee
- on or about March 21, :
1988. '
l EQt1 CATION Fublic Administration Course, Cincinnati Technical College l
EXPERIENCE t I
~i f 1981 - Present United Energy Services Corporation j Hr. Conover has been assisting Yankee Atomic Electric Company i with the revision of state and local planners in preparation i annual drills at the Yankee Row and Vermont Yankee Plants. H.
also developed and conducted training for local fire companies '
and other energency planning personnel in the Ep2's for both of these plants.
1986 - 1987 CYGNA Energy Services l Prior to joining United Energy Services Corporation, Mr. Conover f was a Lead Project Manager coordinating offsite development of !
county / local radiological energency plans and procedures in i support of the Shearon Harris Nuclear Power Plant. :
I Responsibilities included in-depth review and analysis of l
existing emergency and fire protection plans and standard I operation procedures; identification of deficienciest development i
__ _.-_ _ __ ._ _ _ _ _ . . _ . _ . .- _ ___ _ _ _ _ _ _ _ _ _ . _ . _ ._, _l
l t
ROBERT COTTER Principal Engineer ,
B.S. in Radiological Sciences - 1984 EDUCATION: University of Lowell, Lowell, Ha, Currently enrolled in Radiological Health Physics Graduate Program, University of Lowell Lowell Ha.
Mr. Cotter is a Principal Engineer in the EXPERIENCE: Radiological Service Division. Mr. Cotter has a strong background in Technical Health Physics and Computer Softwsre Development.
l Prior to joining lepell Corporation, Hr. Cotter was employed by Nuclear Support Services at the Oyster treek Huclear Generating Station. He cerformed verification / documentation of Radiological Assessment Computer Program and wrote the Emergency Dose Calculation Procedure. He also worked on an Internal Dost Assessment project which was presented at the 1986 Health Physics Society Hetting. He developed computer sof tware to calculate committed effective dose equivalents and HPC-hours. He also performed skin dose calculations and shielding calculations using the "QAD-H00" coecuter code.
Prior to his work at Oyster Creek, Mr. Cotter worker for Bosten Edison Company at Pilgrim $tation. He assisted in INPO recommended program development.
He perforacd QA Audits on all radiological procedures and participated in the 1984 Emergency Planning Annual Esercise.
Earlier nuclear related esperience included Health Physics Technician duties at a University Research Reactor and High Level Radiation Sacteria Reduction P.esearch.
l
, % .% b Y I M
- s b-
- .RIE NCC g,
un emergenes management consulting firm f
. present Pluri . rid ,
- of f ering the following services to government and irscustr): Excretta j Procecure Development /'teview; Emergere) Prog *am Assessment /
Public Inf erination and Community Awntro eist Prepar ation/ Control /C s alvatir.n F.arcutive Oriefing;. l Training / Seminar /workanop Development / Presentation I Senior Consultant. M
. J997 liaison, and pruject services ic
@ Resconsible fer marketinc. clientActivities primarily involved develuoment of non nuclear m6tkets.
market position within tne chemicht iadustry. Project estignments incluned cevelopment of ECC implementing procecures and assucistec lessen plans for j
Perry Nuclear Power Plant, emergrocv esercise/oreceration/ control at sescrul j nuclear sowot plan's in Pennsylwania. Oosignett hoJ cu.autnored several cuolic 1
inf ur n's tion sound / slice programs fur r.ucle a r t swer cla tst M n
m the Chemical N'anufseturers Association's "Cominunity Lmergenes the CM A's Response Exerciss Program Hanc0 cck";
i f '
emergency exercise viceo; performed site ai'd community emergency program assessments; na d contributec to the Emergency Response Concept Plan for the U. S. Army's chemical westens disposal program.
f il 19Br. Activities primurity involved working with licensed and certified f' M.
reactor operators to design /cevelop technical training programs and related j Project assignments included assisting in the covelopment
' support materials, uf college-level programs for reacter operators that totaled forty three credit ;
hours vpproved for transfer by the American Cous cil of Accreditation. '
)
- :'kCR
'F OR M ATION ANS) certified nuclear Cvellt) system aud! cr. certified coment pistol Instructor and member of AENS A.
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- i l ttelis avord of Italian derivaden meanies a group of artisans and craftsmen.
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! trform al.1 services offered in this propon!. hu provided emergency management senices to 6 avernment agencies and utilities Ier more than eleven years in the area of pitaning. emergency esponse operaticas,disuter recovery, and heard citignion. Geference Qualifications s i
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) Meaperience includes: emergency program asseuments for the U.S. Army's
' temicalvespons dispou! progra:o and contribution to the Emergency Response Concept; I sis decilitarir.ation program: direction and production of a nationally racognized Nuclear t J
afety progrsm which reduced audited violation rates by 59%: develop'nent andof them f I i t
' everal nucleat pover plant locations in Pennsylvania and Ohio.,
' reduced over 300 training and information programs. including a series of n:.ne video tal
- ertified nucletr qua.lity control auditor training program.and served as a field cameracan t tirector. American forces Vietnam Network, = - . .w l m d 4 . F t' " i5e g g;t q.IYp,n./- W . w .= w .- y w . - j I i
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QUALITICATIONS SUMMAPY l 1 Supervisory ability with experience in the development, implementation, and '
l . management of programs.
E MPLOYMENT EXPERIENCE JULY 1987 - Green Mountain Security Service. Seabrook Station, Seabrook, j t
PRESENT N.H. !
Plans /Prerrars Supervisor. Responsible for the development and I r evision of Security tepartcent plans and procedures. Coordinate !
procedural changes and review through station and contract j j security f orce management. Supervise the Protected Area Access [
Control Program. j 1
DEC. 1984 - Grgen Mountain Security Service, Seabrook Station, Seabrook, JULY 1987 N . A.
Access Cecrdinaion Supervisor. Directed ' assignment and issue of ke{ cards f or protected and vital area access. Dev elo pe d , imple-mented, and monitored departmental procedures relating to stat' ion e mergencies and evacuation. Responsible for training, data collection and input f or the Automatic Dialing Alerting System.
j Formulated and coordinated.'the entry of personnel data into the J
s tation security computer. Performed supervisory reviews of the total clearance process to ensure compliance with federal and c or porate gui6elines. t t
f f A U', . 1983 ,, Rockingh.am Security, Seabrook Station, Seabrook, N.H. ;
j DEC. 1984 Security of ficer. All phases of security-related duties, I t
i ncluding radio dispatch, routine patrols, canine handling ,
energency response, personnel and visitor access control.
1982-1983 Amesbury Wrsing and Retirement Hose, Maple St., Mestury, Ka.
C ertified Nurse's Aide. Administered personal care to 8-12 patients daily, all levels of care. l l
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i EDUCATION [
M AR . 1985- University Sys tes of N.H. , School for Lif elong Learning PRESENT As sociate 's Deg ree Program
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JAN. 1985- Vermont Criminal Justice Training Council, tav Enforcement T ES, 1988 Leadership Course 1986-1987 University of N.H. , Nrham, N.H. (Through D.C.E.)
4 1974-197e Amesbury High School, Asesbury, Ma.
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Whas ten years of energency pteparedness experience in the connercial nuclear power industry. She has been very involved in the development of offset radiological energency response plans and has developed extensive trainino procrans for utility and local energency response persennel. 6 planning, training and cer.nunication skills has allowed her to effectively interface with state, local, and utility personnel for eleven different nuclear power plants.
EDUCATION B.A. Speech Arts, Glassboro State College LicENsts .
Licensed Teacher, State of New Jersey EXPr4TENer 10/87 - present United Energy Services Corporatien Supervising Engineer - Responsible for the develepnent and inplenentation of an offsite training progra= review and evaluation of local radiological energency respense plans: plan meditications.
Develcped an in-depth offsite training program for tventy-three (23) Iccal nunicipalities in m and M to support incidents at the m and cf Stations. Specific responsibilities included the developmen training natrices, lessen plan developr.ent and inplenentatica, previde an independent assesstent of the status of the 1ccel raciological energency respense plants. Identified plan weakness and/or deficiencies. Developed crcss-references in accordance with federal criteria.
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PAGE 2 .,
Exter.sively nodified eleven (11) local radiolo ical energency uch it ce 1 utility personnel to meet their critical path target date issuing updated plans to energency canagement officials.
8/86 - 10/87 Cygna Inergy Services Technical censultant - Respcnsible for the design, develepnent and inplenentatien of both ccunty specific and utility corporate l
connunicatiens training progra st developnent of a narrated slide progran; p-ocedure nodifications; and centro 11ing/ evaluating cperational aspects of public information facilities.
Develeped a county specific of fsite training progra: to support responses to incidents at Shearon Harris Nuclear pcVer Plant and
'all-hezards' contingencies. Specific responsibilities included developnent of training natrices, schedules, and lesson plans; coordination of training naterialst and inplementation.
Developed a county specific narrated siide progran fer local governnent officials and agencies within a ten nile radius of Shearon Harris Nuclear Power Plant.
Responsibilities included the develep ent* of the written texts; slide story boarding supervisien of slide design, photcgraphy and graphics; narrater selection and production staff coordination.
Developed a utility corperate connunications training progran B.
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suppert responses to incidents at Shearon Harris and H.
Robinson Nuclear Power plant, and. Burnswick Steam Electric Plant.
- Responsibilities ineguded lessen plan developnents artverk supervisien; scheduling and i=plementation.
Modified utility corporate cen=unications role specific procedures into viable verking decu=ents. Responsibilities included ferrat design: cc:nent incorporatient and training en procedure use.
Participated as centroller/evaluater at each Joint Public Infernatien Center fer the aferementioned plants during all drills and exercises.
PAGE 3 .
10/84 - 8/86 Impell Corporation Senior Engineer - Responsible for development of radiological energency response plans; of fsite training prograns; implementing pro.cedures; drill and exercise preparation; training of r ergency response personnel and video assisted training scripts.
Developed offsite radiolocical emergency response plans for local municipalities 6withir. a ten mile radius of Respons.ailities included development of the written text, incorporation of state and FEMA review connents; information gathering from local government officials and department heads; and consultant to emergency response planning comnittees.
As Training Lead, responsibilities included development of an offsite training program; lesson. plans, schedules, and natrices; co, ordination and design of artwork; tracking; and inplementation.
Developed offsite implementing procedures for emergency operations center personnel to support responses to incidents at Indian Point Nuclear Power Station. Procedures included EOC operations, security access, Eoc floor nanagement, radiological controls and =aintenance.
Assisted onsite energency planning management staff at Indian Point Huclear Power Statien with drill and exercise preparation, including development of scenario and exercise procedure booklets for controllers and observers. Participated as controller /
observer for all mini-drills and exercises.
Responsible for training Long Island Lighting company employees to support responses to incidents at Shorehan Nuclear Pcwer Station. With the assistance of video training nodules, e=ergency response training courses include general knowledge, site specific ove-view, und energency connunications.
' Developed several video assisted training scripts for Florida Power and Light Company for offsite e=ergency response personnel within a ten mile radius of Turkey Point and St. Lucis Nuclear j Power Plants. Script topics included radiological emergency
) response organization - an integrated network, radiological energency cc.=unications, and emergency protective action response.
PAGE 4
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7/84 - 9/84 Dresdner Associates Energency Planning / Training Specialist - Responsible for developmont of numerous slide assisted training scripts for offsite emergency response personnel to support responses to incidents at Oystcr Creek Nuclear Generating Station. Script topics included fundamental concepts of radiation, basic nuclear power plant infor:ation, and emergency planning (both generic and agency specific).
Stone and Webster Engineering Corporation 1/78 - 3/84 Emergency Planner / Trainer - Developed and implemented an of fsite training progra: for e=orgency response personnel to support responsec to incidents at Zinner Nuclear Power Station.
Responsibilities included develop =ent.of lesson plans on the following topics; radiological e.mergency response plan overview, radiation and desitetry, decontamination principles and procedures, notification / verification, and potassiu= , iodide use; de'velopment of matrices, schedules, checklists, and records for docu=entation purposes; and training implementation.
Participated in several workshops lecturing on emergency planning zones, the energency classification system, and emergency response functions for local, ager.cy/ department personnel, elected officials, and the =edia.
l Developed nunerous narrated slide programs for training purposes for local government officials and agencies to support responses to incidents at Haddam Neck Plant, Millstone Nuclear Power l
Station, and Salen Nuclear Generating Station.
i Responsible for the development and narration of the written texts, synchroni:ation of the slide progra=s, photo session scheduling and supervisien of slide design and de relop=ert.
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! Developed an energency broadcast systen prograh utilization by radio station personnni to support responses to incidents at Sales Nuc, lear Generating Station.
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Developed various documents constituting mutual statements of agree =ent in reference to e:ergency assistance porticipation.
I SHEILA HERTEL ~ l l
Currently in the Associate of Science program, EDUCATION College of Lake County Seminar of Handling Contaminated Injury Victims, by sy,/
TRAINING Radiation Hanagement Corporation s Hs. Hertel is a Radiological Emergency Response PROFESSIONAL Planner in the Operations Support Olvision with EXPERIENCE practical experience in emergency planning, document control and records management, security administration, and general administration.
EMERGENCY PLANNING Hs, Hertel was a Radiological Emergency Planner assigned to Boston Edison's Pilgrim Nuclear Plant. She reviewed and revised Town Plans for the EPZ towns surrounding the plant.
She developed Emergency Response checklists for local of ficials and Special Facility Evacuation /.
Sheltering procedures for nursing homes and hospitals within the EPZ.
Ms. Hertel also assisted the utility at Seabrook Nuclear Plant reviewing ar.d revising Special Facility Plans for the State of Massachusetts.
As an Emergency Medical Coordinator at Toledo Edison's Davis Besse Plant, Ms. Hertel reviewed and revised hospital ambulance and first-ald procedures both on-site and off-site. She coordinated and assisted in conducting training to plant first-ald responders, plant health physics technicians, hospital personnel, and ambulance crews in the handiing and treatment of contaminated / injured i persons. She was responsible for medical scenario development and drills for plant and local hospitals. Ms. Hertel managed and edited the development of the Davis Besse Nuclear Safety <
Guidelines andShe coordinated tours for local was also responsible for
- medVcal
- support groups.
- , interfacing with off-site medical support groups.
Ms. Hertel was a Radiolog'ical Emergency Planner assigned to Commonwealth *dison's Quad C!tiesIn this Nuclear Station.
revised the State Plans for Illinois and Iowa, !
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- f. l SHEILA HERTEL PAGE TH0 revised and developed county and municipal
. PROFESSIONAL response procedures (SOPS), developed training EXPERIENCE (Cont'd) lesson plans, conducted classroom training, and provided drill and exercise assistance.
DOCUMENT CONTROL /RECOROS MANAGD4ENT Hs.
Hartel was responsible for Design / Document '
Control for Impell-managed recirculation pipe replacement project at Commonwealth Edison's Dresden Station where she utilized a state-She of-the-art computerized tracking system.
i also handled file closecuts in a project to toplement IE 79-14 requirements for Commonwealth Edison. Ms. Hertel managed the Impell regional Technical Libr.ry, including the procuring, updating, and computerized cataloging of technical references.
SECURITY ADMINISTRATION Hs. Hertel performed various administrative duties relating to nuclear security at Texas Utilities' Comanche Peak Plant, including processing security clearances; badging new employees, and procuring soeciality supplies. She was also responsible for coordinating and conputerized tracking of records and documentation required for site security clearances for Impell employees.
GENERAL ADMINISTRATION Hs Hertel performed I
various ad 'nistrative functions connected with offics 6 ;;ement, including billing, time and expense vuounting, and procurement of technical referens.s. supplies, and materials. Prior to her experience as an emergency planner, she administratively supported various emergency planning project teams, developing Emergency Planning Zone maps and Emergency Responsibility l Matrices, designing Emergency Notification Flow i
Diagrams, and developing Training Modules.
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- ?-44 iT :: :z-PAU1. JOSEPH KCVACH IMPELt. CORPORATION '
SENIOR ENGINEEP.
E n T I. C 2h I* I O N Master of Science. Rad tation Healch Physt:s 1979 Callege of Chemical and Nuclear Enstneering Universit/ of Cinctnnatt,Cinctnnett.CH 1977 Sachelor of Science.BLological Sciente Saint Francis College t.cretto. P A . .
Various industrial training in the areas of management. instructor chemistry,caergency development.'"MI-1 piant Systams and emergenc y Dreparedness and health phystes .
M b wr' n T Tr n c E CORPORATE D4ERGENCY PLANNER,GPU Nuclear Corporation Pres ent Harrtaburg,PA.
Haintain compliance wLth f ederal and state requistions. promote consistency and ensure high state of emergency readiness : at Three Mile Island and Cyster Crask sites including
- adr',4- car projects assigned by the corporata Manage: , .
Daere,wncy Preparedness to ensura proper and timely response and s.o ensure to the Divtsion Director and upper management achiavement of departmental goals and objectives
- develop GPU Nuclear Corporation Emergency Plan;revtse ar.d saintain the Plan consistent with f odseral, state and corporate requir3eents
- interface with government and industry organizations to information maintain promote cooperation and exchange ofand contracts with of fsite erergency
'. etters of Agreement support organtsations
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- deve4cp, review and concur with des > gn cha/tges to plant emergency communications sy terns,Czergency Plan Impicmanting instructions procedures, Administrative procedures and Survet11ance Preparedness managers by performing
- assist site Emergency tr.atning, scenario development, drill observation and coordination,and audits 1982 - 85 D1ERGENCY Pl.ANNER,GPU Nuclear Corwration I
Three Mile Island,Middletown PA Maintain compliance with federal regulations Unitsand high 1 and 2 state of 2ncluding :
i earrgency readle,ess at Three Mile Island
- editor f or revisions to TMI-1 and THI-2 E:nergency Plans
- matntain Emergency Plan Implernenting Procedures for communtentions and recordkeeping, environmental monitoring, post-accident RCS sampling and analysis, activation of EACC, 4
emergency assembly areas and corporatu support l l
- supervise maintenance of emergency communications systems l sncluding montnly testin7,and system modification / repair; !
! assist to perform communicator traininq l
- observe drills and exercises: coordinate annual radiation !
monitorino drill with THI and PA BRP l
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NICHOLAS R. LEWIS Lehigh University - B.S. Mechanical Engineering ELUCATION - B.A. Applied Sciences, Geophysics ,
EXPERIENCE Mr. Lewis has designed, developed and implemented ;
emergency planningLILCO training for the public contracted the Company to ir. formation staff. !
provide all the training associated with moving the
! Emergency News Center from a leased hotel facility to a dedicated LILCO facility. Mr. Lewis led this effort, and was the Lead Controller for two He coordinated approximately I
' subsequent ENC drills.and prepared the simulators, the two hundred people, scenario, briefed controllers and wrote the drill report. Mr. Lewis has observed and controlled on-site drlila at Shoreham, revised OPIP procedures, wrote and developed memory aids (vallet cards) for j the onsite emergency organization, trained vehicle and personnel monitoring and decontamination personnel, and is a LERO instructor.
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Mr. Lewis was previously employed with Impell :
Corporation, where he worked for several clients l including Toledo Edison, RG&E and LILCO. He prepared 1
dose calculations and aging packages for Davis-Besse's EQ program, participated in emergency preparedness drills for Ginna, and taught fundamental j radiation principles to Shorehan's LERO organization. Mr. Lewis has performed numerous to system walkdowns at both BWRs and PWRs relatin Appendix R fire protection projects and systems analysis.
In licensing, Mr. Lewis assisted the Licensing 1
Supervisor assignment.
at Shoreham for an extended fieldHe became the NRC's King of Prussia office, and prepared submittals for the VP-Nucient operations's signature. This experience afforded him a broad exposure to many facets of nuclear operations, and developed his technical and presentation skills.
Prior employment was with Pennsylvania Power & Light Co. (Susgehanna 1 and 2), Westinghouse Nuclear International (Belgium and Switzerland) and the US f
i Peace Corps (Yemen Arab Republic).
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O W PELLLW OENNIS J. PACHULSKI Senior Engineer New York State Regents College, Albany, N.Y.
EDUCATION Prfsently. working $cwag BS degree.
H.C. Technical High School, New York, Graduated 1965 Mili tary U.S. Naval Nuclear Power School, Bainbridge, MO U.S. Naval Nuclear Power School. West Milton, NY Engineering Laboratory Technician Industry _
Instructor Development Cou'.se, PNSY 1980 Principles of Training 5ystem Development. INPO, Atlanta, GA 1985 Advanced Gama Spectroscopy, Quantum Technology, Atlanta, GA 1986 Level I Radiochemistry, Power Safety International, Lynchburg, VA,1987 Internal Dosimetry, Hydronuclear Services,1987 Mr. Pachulski currently is a Senior Engineer in the He EXPERIENCE Power Services Division of our New York office.
has been in the field of nL' clear and health physics for over twenty-two years. Mr. Pachulski has extensive experience 6 ._-
in training and emergency" e" ' ~;; ;.;P, W.
preparedness.
in the area of radiolo ical training and !JL.
tn i ni na . Prior to jo ning Impell, Mr. Pachulski held the following positions:
Nuclear Training Specialist' 1985-1987 Responsible for training of Health Physics Personnel at Pilgrim Nuclear Power Station including material development and revision as well as actual training of Health Physics supervisors and technicians.
225 eRO AD HOLLOW ROAD ' MLLVILLt.Ntw YORK.117a7
- tstol 420 3200
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DENNIS J. PACHULSKI Senior Engineer l PAGE Tdo l
EXPERIENCE Instrumental in development of material required to receive INPO ac:reditation for Health Physics (Continued) program (June 1966). Also respor.sible for emerceney plan training of station's emergency organization.
hw mant. roller curing severa s emergenu pian drills and exercises. Acted, when required, in position of Radiological Controls Supervisor in support of plant activities.
1983-1985 Health Physics Technician Responsiole for ensuring proper radiological controls during plant operations and shutdown concitions. Duties include raciological coverage of plant maintenance, RWP processing, instrument calibration, snipnents of radioactive materials, and review and rewriting of station procedures. Served i4rch-June of 1984 as temporary Health Physics Supervisor during Pilgrim's refueling and recirc pipe changeout outage. :toutinely coordinated the efforts of a'pproximately fifty contractor and house H.P. techs in support of the outage. Actively involved in the setting up of procedures to perfom tasks necessary to complete the outage and surveillance of these operations when in progress.
1977-tyJ3 Training Specialist Radiological,5upport Division (1980-1983)
Responsible for radiological control technician qualifications to NAVSHIPS 389-0288 and local requirement publications. This includes initial qualifications, continuing education and reverifications of radiological control technicians. Courses taught include: Basic Health Physics Article 106 of NAVSHIPS 389-026d and group
- problem solving seminars. Specific areas of specialization include Maa Rem reduction, contamination control (use of custom butit contamination containment enclosu *es) and reactor plant systems. Co11atarai duties include working with Emergency Preparedness Depcrtment in mock exercise data generation and trair.ing both supervisors and radiological controls technicians in
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DENNIS J. PACHULSK!
Senior Engineer PAGE THREE EXPERIENCE both initial and follow up response actions. He.d !
(Continueu) position of Acting Supervisory Training Specialist. '
In this capacity responsible for the academic ,
perfomance of 23 raciological control technician trainees.
Instructor Radiation Worker Raciological support otvision (1979-1980)
Responsible for radiation worker qualifications as definec in Article 108 NAYSHIPS 389-0288. Include !
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l initial qualification, periodic refresher training, and requalification of the radiological work force. i Developed training courses in the use of !
i contamination containment enclosures and portable liquid collection facilities. Deeply involved in !
the training of energency response personnel. j Radiological Control Technician (1977-1979) f I
QualtfieQ to Article 105 HAY 5 HIPS 389-0228. !
Responsible ~for on site radiological controls during overhaul of nuclear submarines. Held position of i
lead technician at the radiological repair '
facility. Responsible for the actions of twelve radiological control technicians. Received superior achievement awards for support of several major overhaul projects.
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l f {f co0Iy50s LINDA H. PARLAIORE Principal Engineer M.S. in Health Physics EDUCATION University of Florida, 1987 Gainesville. Plorida B.S. in Biology 1978 College of Mount Saint Vincent.
Riverdale. New York Ms. Par.. tore is a ?rincipal Eng.neer in the Radiological EXPERIEM E Services Section of I=pell's Northeast Regional office in New Yerg. Currett work responsibility involves exposure including dosimetry selection, control procecure developcent, steps to be taken to c:inimize andassisting She is also cor. trol exposure, and with guidelines records canage=ent.
for environ = ental and ingestion pathway sample collection, ,
establishing field conitoring kits and routine inventory checks.
As a Health Physics Instructor, Ms. Parlatore was responsible for development and presentation of the Health Physics Technician Training Program at the Ljmerick GeneratingActual work Station for the Philadelphia Electric Company.
included developsent of lesson plans. classroom presentations, and conducting laboratory exercises using radiation moni-toring and counting equipment. Ms. Parlatore also has experience as a health physics controller and evaluator during emergency preparedness drills.
As a rese reh assistant at a University Neutron Activation Analysis Laboratory, Ms. Parlatore was responsible for establishing and implementing written procedures for gamma ,
spectroscopy equipment calibrations, sample pre-paration and analysis, development of radionuclide libraries, and perferming reactor fluz calculations.
Ms. Parlatore's prior errerience t.ncludes the development and implementation of community 4.tucation programs on energy, nuclear power, and radittion safety provided by The Pennsylvania State University.
In addition, Ms. Parlatore holds teaching certificates in the States of New York, New Jersey, and Pennsylvania.
pr/351 225 BROAD HOLLOW ROAD
- MLLVILLL Ntw YORK ll?d7 *(516) 420 3200
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MAtHELLE PAVEY
. l B.S., Environmental Health - 1983 ;
EOUCAT!0N Purdue University !
Ms. Pavey is a nommer of the Operations support i PROFESSIONAL Division at Impe11 Corporation. Ms. Pavey EXPERIENCE served as a Radiological Engineer in the Operational Health Physics Section during the :
Connonwealth Edison Recirculation Piping Replacement Outage at Oresden Station. Ms. i Pavey's responsibilities included the review, ,
i evaluation and f ollow-up of contamination '
reports and various station procedural reports.
Ms. Pavey also monitored dosimetry, including the implementation and trending of electronic i dosimetry. '
Ms. Pavey has worked as an Emergency Plan .
, Coordinator for each nuclear power station in the Statt of Illinois. Ms. Pavey actively I.
participated in the development of the first volume of Standard operating Procedures (50P's),
formal training modules and 4,5LB Licensing suppcrt f or the Syron Station. During the Syron :
Plaa update, Ms. Pavey served as Project '
Engineer. Her responsibilities included plan i and 50P review, forwal training scheduling and l instruction, and of f site exercise scenario "
development.
'i Concurrent with the Byron ef fort Ms. Pavey served as Project Englneer for the traidwood e Off site Emergency Planning Project. In this r I
capacity. Mt. Pavey served 45 the lead interf ace between State, County, Municipal Agencies and t i officials involved with the Illinois Plan for Ms. Pavey l Radiological Accidents (!PRA). i assisted tha State of Iowa in the development of i ten 50P's and develope 4 exercise of f site dose ,
calculations for the Osas Cities offsite
. Emergency Plan and Exercise, respectively. P
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At the Clinton Power Station, Ms. Pavey servee '
as Lead Trainer for the following offsite :
classes: . Emergency Worker, County Executive.
j Municipal Executive. Traffic and Access Control, l,
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MASHELLE PAVEY Page Two Shelter and Evacuation, and Dispatcher. Ms.
PROFESSIONAL Pavey also coordinated two tabletoo exercises EXPERIENCE (Cont'd)
' prior to the successful Clinton NTOL.
Ms. Pavey has participated as a controller .6 the Dre>4:r. 6yron. Sraidwoo1. Quad Cities.
LaSalle, Zion and Clinton Exercises.
Prior to joining Impell. Ms. Pavey attended Purdue University where she was awarded a Her Bachelor's Degree in Environmental Health.
major field of study was Reactor Health Physics
- with related coursewort in environmental and occupational safety, environmental monitoring, shielding and dose assessment, bionucleonics and radiological emergency response planning.
Ms. Pavey's experience also included working as a Laboratory Assistant at Fermilab whert she was involved in the development and instruction of radiati6n training programs, contamination surveys and internal lad appraisals.
Ms. Pavey served an internship at Additionally,iversity Radiologica' 'cntrol the Purdue Un Office. In this capacity, she per. semed laboratory surveys, instrument calibrations, and controlled radioactive materials.
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Sen u.i gine > ,
EDUCATIC!1 8.S.,Radiolov- ics, University of ' ;
9PER E?lCE Hr. Foudrier cut '
4 Senior Engineer in the Power Servi' 'st'A of Our New York office. He ha. , ' i years of nuclear industry experience, of whit !ls main concentrated area is Radiological / Health Physics. Mr. Poudrier nas extensive training exoerience in Radiological / Health Physics. He has traineo large oiversified groues cf people including plant staffs, corporate, emereen:y workers, state, local, and county government officials.
In addition, he has a strong ba:' Aground in Health Physics Training progra.as and procedures writing. Prior to joining Impell, Hr. Foudrier held the following positions:
1984 - 1987 General Dhvties Corecratien As a memeer of the Health Physics Services Depart::ent, Mr. Poudrier provided a wide range of technical and trairing services to comercial and government nuclear clients. Representative projectsinclude:
Health Physics Technician Task Analysis -
performed table > top task analysis for Cleveland Electric Illuminating Company, Reviewed JTA data for technical accuracy a9d usefuiress for Sacramento Huaicipal Ut'.!ity District, New York Power Authority, and U.S. Department of Energy.
Advance Health Physics Training Program -
developed training materials on state-of-the-art decontamination and respiratory protection prograss for USNRC power reactor health physicists.
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MARK R. FCVORIER Senior Engineer PAGE TWO EXPER:ESCE Plant Staff Training - conducted courses fer radiation (Continuec) protection and radwaste technicians at Iowa Electric Light and Power Company, Niagara Hohawk Power Corporation and Philadelphia Electric Comoany; including courses in Classical Physics, Thermodynamics, Nuclear Physics. Health Physics Theory. Basic and Advanceo Radiation Protection.
and Radiological Haste Shipping. Conducted Radiological Protection Assessment training course for quality assurance personnel at Niagara Mohan Power Corporation. Conoucted General Employee Training, Respiratory Protection Equipment Training, and Chemical Saf ety Training for plant staff at Cleveland Electric Illuminating Company. He has used formal 03T training methods anc classroom instruction.
Technician Training Program Development -
developed performance-based training materials for Cleveland Electric 111uminating Ccmpany.
Sacramentb Hunicipal Utility 01 strict, and New York Power Authority; including courses in Respiratory Protection. Whole Body Counting, Oosimetry Program Compliance and Licensed Source Control Procedures. Included application of INPO guidelines and. federal regulations.
Hr. Poudrier was responsible for training the utilities on-site Emergency Response Organization. The audience ranged from Corporate Vice-Presidents to technicians.
1980 - 1983 Combustion Engineering Power Systems. Inc. - As a Radiological Engineer in the Field Services Division Hr. Poudrier was responsible for providing a wide variety of radiation protection services to client utilities. He prepared
- Station Orders, Program Procedures. Implementing Procedures and recordkeeping systems for ALARA, Counting Lab and Radiological Survey Programs at Southern California Edison. He revised Health Physics Procedures for Consumers Power Company, Public Service Electric and Gas Ccmpany,
( Baltimore Gas and Electric Company, and Southern California Edison. He also managed the General Employee Training Program at Pacific Gas and l Electric.
z _ . , , '_ P 07 s zar os: 4s l HARK R. POJORIER l Senior Engineer l
l PAGE THREE l
LICENSES AND Hember, National Registry of Radiation Protection CERTIFICATI0is Technologists S
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CANDIDATI:
The canuidate has over fourteen (14) years of . experience specializing in applied radiation protection, training, caergency preparedness, and radicactive wasta management. He is adept at health physics, radwaste management and emer-gency preparedness, program development and implementation.
His applied experience includes implementation of radiologi .
cal control programs using the evaluation and interpretationa of field data and the utilization of this information for -
program enhancements.
Work rreerience
.,_ Most recently, the candidate was a Manager of support Serv-ices with a large nuclear industry consulting firm. Services provided include corporate and plant support, productivity reviews, program and procedure development, training, radia-tion protection, radiological engineering, emergency preparedness, and radiological wasta management.
Previously, the candidate worked for a leading southeast utility assisting the training department in theHis radiologi-respon-cal asp,i:n i emergency preparedness training.
sibilities included review of the policies, programs, course structure, and development of course outlines associated lesson plans as well as course examinations. He also was responsibis for the presentation of the developed training materials and the evaluation of students.
In addition to his training activities in the training department utilized the department, the health physics candidate to assist them in applied health physics and radiological controls. His experience and performance in these areas contributed to the overall program upgrade of-fort of the department.
The candidate has over twelve (12) years at operating PWR ,
and BWR's. He held positions of ' progressive responsibility including seven (7) years as a health physics supervisor,
' over a year (1) as an assistant health )hysics superv)sor and over a year (1) as an assir, tant healta physics unit au-parvisor.
At a prior assignment, the candidate was responsible for su-parvising the performance of required surveillances. His ex-periance includes radiation monitoring, instrumentation, counting room techniques, and radiation contamination sur-voys for normal and emergency conditions. Pe has par-ticipated in numerous outages and has supervf sed personnel during routine outage and emergency conditiona.
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The candidate has conducted training for h'ealth physics orientation, emergency preparedness, and radiation protec-tion technicians. He has trained craft workers NRC in radiation and INPO protection practices. He is familiar on radiation protection and has developed with both guidelines programs and procedures to meet their criteria.
The candidate developed the in-plant procedures associated with radiological emergency conditions. He implementedHethem has during actual emergency events on several occasions.
participated in nur.ercus drills. His organization's perfor-mance was noted by the NRC as being excellent.
Education B.S. Physics l A.S. Nuclear technology tienificant Accerelishments
. Health Physics Supervisor
. Emergency operations Participant
. Training course Development .
. Program Audit
. Radiological Waste Hanagement Membershies Health Physica Society l
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LAWRENCE 5. RUNDLETT l -
P.O. Box 250 Kingfield, Maine 04947 Education University of Maine, Po'rtland, Maine Unconditional Graduate Degree Candidate of Hasters of Mathematics Applied Numerical Analysis, Chemistry and Educational Methods 1
1972-1973 Bostcn University, Enston, MA Northeastern University, Boston, MA Undergraduate Studies Graduate Studies in Mathematics, in Mathematics and Education.
Educatien Administration and B.S. Mathematics 1964 - 1968 Curriculum 1968 - 1969 Orono High School, Orono, ME University of Haine, Crono, ME Graduated 1961 Mathematics, Zoological Studies, Education 1961 - 1964
.* peerience May 12, 1987 HMM Associates to 336 Baker Avenue
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Concord, MA 01742 m a a nt-N o w t Y ,t9 T Pilgrim Nuclear Power Station, Plymouth, MA Etercenev Pro,n njnest Training:
Responsibilities include job and task analysis for program development; coordination and instruction of onsite and corporate response teams; scheduling initial and requalification training; job encumbant responsibility, evaluation and acknowledgement HECInc.,Dethesda,HY' June 7,1986 to Braidwood Nelear Power Seatkon January 3,1987 Craidwood, Illinois Trainina_0evetoement Scerial.ist INPO Accreditation, Chemistry and Health Physics
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Lawrence S. Rundlett
- Page 2 February 10, 1986 MEC Inc., Bethesca, MD Davis-Besse Nuclear Power Station Oak Harbor, CH to Hay 3, 1986 Trainina Oevele vent Seecialist INPO Accreditation, Chemistry & Health Physics June 26, 1985 Bartlett Nuclear ,
Vermont Yankee Vernon, VT to November, 1985 Health Physics Trainino Censultant Design, Cevelocment, and Implementation of General Employee Training Program:
Respiratory Protection Training January 8. 'J85 Quadrex Corporation Wolf Creek Generating Statica, Burlington, KS to June 24, 1985 Health obvsics Trainina Censultant Assist in the development, design, and implementation of Emergency Preparedness Plan; drill evaluation / controller; Sof t-ware dose projection in-put data, corporate level duty responsibilities and training, interview position specific individuals for training validation Radiation Protection, and Respiratory Protection.
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' August 15. 1984 NUMANCO Beaver Valley Power Station, Shippingport, PA to Healtn Physi a _Trainina censultant
' October 28. 1984 Radiation Horker Training, General Employee Training, Station Orientation
- 4 arch 16, 1983 Kui Engineering to Oettnit Ewlson, Newport, HI Health physics /Radiochemistr_y_Trainirc Consultant June 29,1984 i Responsibilities included design, development, and lepismentation of a Muclear Chemistry Course that meets and conforms to Nuclear Regulatory Commission guidelines and also satisfies BHR peculiarities, (Course is
/ complete and documented.)
1 u --- - - -
Lawrence S. Rundlett Page 3 Developed and designed the Iost Accident Sampling System Kai Eng. (cont.)
Course and have thus far met with the milestone criterion with both job and netos enalyst:,, in conformance with radiochemistry post LOCA conditions.
Has appointed as Radiochemistry Control Officer with the Emergency Operating facility in the event of site emergency response.
RAD Services, Inc. 500 Penn Ave., Pittsburgh, Pennsylvania Hay 14, 1981 to Ir3 inino Seecialist Responsibilities of familiarizing radiological personnel March 10. 1983 of site description and location of potential radiological hazardt, general emoloyee indoctrination, and implementation of 10 CFR SO Quality Assurance and Quality Control. I was also been assigned the task of revising the Radiation Horker Training lesson plan to conform to Reg Guide 8.29 guidelines, which plan, upon completion was accepted and is presently being used j;j throughout the system. My immediate responsibility was providing training to approximately 3200 employtes on radiolcaical parameters, implications, and conditions during Salem's annual outage,
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1 Lawrence S. Rundlett Page 4 N
h ADDENDUM SPECIFIC SUPPORT EXPERIENCE Emergency Preparedness Training .
Performance based training program developer / job and task analysis.
Health Physics technician progression training.
Chemistry and Radiochemistry INPO accreditation.
General Employee training program developer review of radiation protection, ALARA, and emergency preparedness procedures.
Respiratory Protection training.
Laboratory Instrumentation training and lesson plan developer.
Efuergency preparedness response drill evaluation / controller.
Consultant mathematics and physics lesson plan developer for U.S. Navy upward mobility candidate.
Qualified In ANSI 18.1
) Technical Instructional Training Certificate - 1984 Articles 106 - 108 NAVSHIPS 389 - 0288 National Teachers Association and Council Award for Mathematics and Scientists /two consecutive years
9ESUME ADDENDUM _
LAWRENCE 5. RUNDLETT
!. Managerial / Supervisor Background Mathematics Department Head - Cover Public Schools, Dover, New Hampshire 3 years.
Develoceo training matrix to meet national scholastic norms.
Budget maintanence to fit conservative and economical practicality.
!!. Education r
i University of Maine, Portland, Maine - Unconditional Graduate Degree Candidate (
of Masters of Mathematics, Apolied Numerical Analysis, Chemistry and Educational Pethods, 1972-1973 Northeastern University, Boston, Massachusetts - Graduate studies in Mathematics, Education Administration and Curriculum, 1968-1969 Boston University, Boston, Massachusetts - Undergraduate Studies in Mathematics and Education, B.S. Mathematics, 1964-1968 111. Job Related - Emergency Plan Career excerience - 11 years nuclear 6 years Emergency Planning and E.R.O. -
PSELG Salem New Jersey, KE&G Wolf Creek, Kansas, Detroit Edison Newport, Michigan, Boston Edison Plymouth, Massachusetts.
Developec recommendations based on problem recognition to effective E-Plan training.
Identified organizational structure and functional responsibilities within the Enrgency Response Organization.
Assistec in the design and development of security based E-Plan and maintained control of training implementation from qualification to requalification utility wide.
Trained two persons deep per facility response to all emergency classifications.
Initial notification of E-Plan encumbants to deactivation of facility..
I IV. Commitment Related (INPO-10CFR50)
E-Plan job and task analysis for program development - Boston Edison and Wolf Creek, Kansas.
Coordination and instruction of both onsite and offsite corporate response teams.
Table talk discussion and walk through training for each encumbant affixed to Emergency Response Organization Packet Construction designed to support and enhanc skills and knowledge of each position per primary and secondary support facility.
V. Specific Related I Scheduling ir.itial and requalification training PSE&G - Wolf Creek - Boston Edisor
- e. Dose assessment and dose projection software computer based model - Wolf Creel Kansas, i
- b. Propogation of Class A extended model fixed to source term - meteoragical -
plant data parameters to conform to EPA.FDA plume exposure EPZ (Hewlett-Packard),
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Field monitoring team methodology to integrated dose projection from d.
mathematical computation of X/Q values - Wolf Creek.Orill contr Boston Edison, e, PASS training (Sentry) and Radiochemistry training.
I Radiochemistry controller of EOF laboratory - Detroit Edison.
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.aummun.
OBJECTIVE To obtain a senior management position on the security force a t Seabrook Station.
WORK EXPERIENCE .
July 1986 to CREEN HOUNTAIN SECURITY SERVICES, INC.
present CAS /SAS Supervisor _ay Seabrook Station, Seabrook, N.H.
Provide direction to CAS/SAS of ficers on all shif ts, ensure compliance of CAS/SAS personnel training with corporate and company guidelines, review and update applicable procedures.
Provide alarm assessment reports, and ensure standardization -
of Central and Secondary Alarm Stations. Qualified instruc- ' '
tor in CAS/SAS procedures. ,
August 1985 to cuard Island Supervisor f or CMSS at seabrook Station July 1986 Managed Guard Island operations, including computer termina.\
use, personnel access /agress, badge and keycard issue, detection equipment and vehicle search procedures.
e 195:0 to 1985 ROCKINGHAM SECURITY, INC.
l Security Of ficer at Seabrook Station. Responsibilities
! i n c lud ed :
Enforcement of site regulations Protection of property in restricted access areas Working with attack canines l
Assisting in handling the drug dog Radio dispatching Kain Cate Operations T.affic control .
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- Qualification as Zone leader Qualification as Asst. Zone IAader
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Road Supervisor -
Certifed dog handler and trainer Assisted owner in caring for dogs l
Conducted training session for attack and drug dogs
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i EDUCATION
- Lotus 1-2-3, introductory and advanced training in use of personal computers. DOS Compute r Cente r , Newing ton , N.H.
- Nuclear Securit y Of fice- training, Response Force Training 1986 Technical Vriting School, Seabrook Station: Certificate of Achievement
- Deputy Sherif f's Training, Benningten YT Kilitary Training: Air Base Ground Defense Combat School; Security Specialists' Course
- Burr and Barton Seminary, Manchester, VI, graduated 1976 l
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FDUCATION 1983 1964 Bridpwater State College, MMored in Earth %
Graunate Studies Tederal Emsrgency Manapment Agency. Career 1982 Develo> ment in Emergsney Management, Phases I IV (F. wly Staff Cc&ge) ,
Bridgewate. hte OcIlege Bachelor cf 8deace Anthropology. . Dean's 19 90
!Jst University d Iowell . Ra M^W e al Defense OffLeer Inst.
2990 Middgan TechnologicalUniversity -Introduction to Lajolseal Momtarms.
'.iaw Jtac . Bureau of Radiation Protection -Decantamination Cent
.danser cla,u Stone & Webster Engineering Co - Basic P=rLbgkal Safety Clan EEFERit dh P < jears of Emergency Planake experience, ans and ane-half years of whkh was
& s stater as an Assocate Sdantistin the Emergency Ph=ing Group, reviewed plan
- ained emergency response per-nal snel and Perimcodin tha areas of training both E .a & Webskr New Yor'sprepared ud5ce i
locr. unerrene . respam,e personnel for PuhBe Service Electric and. Ga 1 .c drilh.
h==v Nuclea:
...wwsd ami updated procedures for the folbem' a utilitiesr Gu J rwar Shh; and W_6<=6 Public Service Ocmpany Kewannee Nudear Power Statke.
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Wepared trandng documenta sad edited does assessment (Appan<hr Trainedlocalecmmunibs within the I eEPA I) ecmputer for Nertheast Utilities Service Company ion,4W4ng peparing route. alerting procedures l area of tln Millstone Nuclesr Powsr.8 tat usi erseustbn rcules.
May1967 8eptember1987 x w,.ne u r-% --r.Mnn 0;,shn Inmach hMM C
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) training support to
< tho#ean%N nt the recirc.. piping
.. r,ami, s.,,.rt .a. m ar I Nonsaber 1986.J:' 7 LT fFhO Rutfear Poa han OakMarbe.N aze:22hpea.ute Em r,e,,,,dne.e-are
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Manh1966 May 1986%uerrh Fuels 1 ice -- PiaM Ge OK -
F-i.. m Pimaner Deties included: Developed offsite Emargency Preparedness prooodrares/ "Tw '*
February 181986. March 271966Lrth Anna helaar Power Plant MinaralVA.
General hatavaa Tr taine Instru,.wr Daties included: Insmtetion of Power Plant and Catractor per.onnal on Ra dia Security, Respiratory Preh; Radioycal Procedures, and Practieel Factors.
March 18,1965. December 20.1985 ana wrr , p...r P1.nt utn. rat VA.
North > heL, : Train +ne In L&
Dearn Instruction of Power Plant and Centreeter per.annel on Radiation,
R'.gl%
Daties .ac.inded:
Sucurity, Respiratory Pretection, P Nae %1 Prh and Practical Factors.
August 1964 March 1985 Q = a h - h % =t h
$Ye D.: Responsible for inventory antral and materW retrimi at starug. Fac M
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Consulting Engineer Exoerience Milestene_s.
o Twenty years health physics reactor operations, and emergency preparedness (EP) experience o On-site and off-site EP Training experience o industry emergency preparedness (utility and INPO) o Senacr EP Analyst for State of Texas Exoerienen Descriction Emergency the candidate is the assignment, At his current for a large nuclear industry services firm.
Preparedness Manager he is responsible for the coordination of In this capacity, During a support to client utilities.
emergency preparedness assignment at a vestern utility, he was responsible recent tield of all onsite emergency response organisation for the training of lessun plans. In addition, he graded was a personnel and upgrading various traininy drilla and an NRC controller Prior in to assignment the utility hadreinspectiun rec 11ved violation exercise. in onsite EP Training.
NRC following from the NRC the cancadates upgrade of the program removed this violation.
candidate was a Project Manager with the Previous to this, the Fover Operations (INFO). While there, he Institute of Nuclear evaluated the effectiveness of emergency preparedness programs power reactore in the' U.s.
major portiorss of the IMPO Doseorganisation Asessement workshops and wrote utility emergency Manual. Be evaluated and exercises, and made during drills 3 ottactiveness recommendations f or improvament.
this, the candicate was a Senior Emergency Preparedness control Prior to state radiation Analyst with a large southwestern he wrote the health physics portions of program. While there, fixed nuclear facilities. Ne energency response plan for for persons assigned duties in the emargency the conducted training served during driru. and and as a controller ?.'ield organization Training he conducted includec Dose Management Assemamen sn i Law exercises.
and control, Sheltes Monitoring, command Entorcement Procedures
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- Page 2 of 2 purchased, and supervised the systems He also designed, a state of the art mobile radiation testing of integration and measurements laboratory for the state.
utility, the candidate participated in the At a Northeasternemergency plan and it's ineplementing procedursa.
and writing of the protection training program He deveinpec a respiratory of health physics assisted with the claustoom instruction .
technicians.
Previously, the candidate utility.
was assigned as a radiological engineerHe de to a northeastern of work packages. In addition. Fe '
performed ALARA reviews technicians during health physics supervised contract post-accident recovery operations.
candidate was in the U.S. Navy nuclear Prior to this, the program. During tnis period, he was a health physics supervisorHe also received operator.
and .as qualified as aNavyreactor Instructor Training School. Ne by the certification in the decommissioning of two reactor facilities and participated the dimmantling and buraal of one.
Education M.A. Administration B.A. Economics A.S. Science Power Plant Operators School U.S. Army Nucles Continutnc Educatich o DSWRC Radiological Inspectors Course o Reactor Accident Assessment - FEMA o Transportations of Hasardous Materials - U.S. DOT o Symptom Based Emergency Operating Frocedures - INP0
Ad %de CANDIDATE The candidate is a nuclear professional with over twenty years of hands o'n experience in emergency preparedness, health physics, and reactor operations. He has written both onsite and offaite emergency plans and procedures; developed health physics, and emergency preparedness training a radiological engineer and as materials; performed as health physics supervisor; and served as a reactor operator (Navy).
Work Excerience ths candidate is the Emergency At his current assign =ent, nuclear industry services Preparedness firm.
Manager for a largeIn this capacity, he is responsible for th tion of emergency preparedness support to client utilities.
During a field assignment at a western utility, he was responsible for the training ofInalladdition, onsite emergency he was a con-response organization personnel.
troller in various training drills and a NRC grade:d exer-
" c.. s e .
Previous to this, the candidate was a Project ManagerWhi'.'.e with the Institute of Nuclear Power Operations (INPO).
there, he evaluated the ef fectiveness of emergency prepar.ad -
He coordinated ness two dose programs at power assessment reactorsand workshops in the U.S. major portions of wrote He evaluated utility emer-the INPO Dose Assessment Manual.
gancy organization effectiveness during drills and exer-I cises, and made recommendations for improvement. .
Prior to this, the candidate was a Senior Emergency Preparedness Analyst with Whilea large there, southwestern he wrote state radia-the health tion control physics program.the portions of Re emergency response plan for fixed '
nuclear facilities. conducted training for persons as-signed duties in the emergency organization and served as a l controller during drills and exercises. He designed, pur-chased, and supervised the systems integration and testir4
' of a state of the art mobile radiation measurements laboratory.
At a northeastern utility, the candidate participated in the .
writing of the emergency plan and it's :,aplementing proca-dures. He developed a respiratory protection training l program and assisted with the classroom instruction of health physics technicians.
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4 Previo0 sly, the candidate was assigned as a radiological Na developed en-the AIARA ;
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l program and performed AIARA health pervised contract reviews, of work physics packagem.addn technicians '~~ !
during post-acc:, dent recovery operations. >
Prior to this, the candidate was in the U.S. Navy nuclear i program. During this period, he was a health physicsHesuper- par-visim and was qualified as a reactor operator.
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ticipated in the decommissioning of two reactor facilities !
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1 and the dismantling and burial of one. >
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Education l i M.A. Administration J j B.A. Economics i
! A.S. Science U.s. Army Nuclear Power Plant operators School i l l sienificant Accannlinh==nta I l
. Project Manager (Emergency. Preparedness) INTO !
. Wrote State Emergency Plan t j
. Wrote Utility Emergency Plan i
. Realth Physics Supervisor T j . Reactor Operator !
. Training course Development i
' . Reactor Decommissioning and Dismantling ,
,i J l eantinuine Education l
, USNRC Radiological Inspectors Course !
) . Reactor Accident Assessment - FBtA '
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. Transportation of Essardous Materials - U.S. DOT i
. Sympton Based Emergency Operating Procedures - INFO , ,
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1 Manhatabins j Bealth Physics Seelety American Nuclear Seoiety ,
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RONALD H. THURLOW -
l PROFESSIONAL bBJECTIVE: To increase my experience in the field of Radiological Science, i EDUCATION: baiversity of Lowell, Lowell, MA -
! B.S. ln Radiological Health Physics l M3y 1984 l Major Courses Completed: i talculus I, II, 111 Intro to Radiological Sciences I, II l Fundamentals of Electricity Differential Equations !
Physics I, !!, !!! duelear Instrumentation I, II l Physics Lab I, II, III Fortran Programing i Chemistry Technical & Scientific Writing Chemistry Lab Pamalian Physiology Physics of Radiation Mamalian Physiology Lab Physics of Nuclei Health Physics Internship I, II College Writing I, II Industrial Safety Biology I, II Statistics l
Newburyport High School,, Newburyport, M Gradaated 1980 l
EXTRACURRICULAR
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pSki Club, Karate Club, Radiological Health Physics Society.
i ACTIVITIES: ! was trained as a Radioloolcal Defense Monitor for the City of Newburyport Civil befense in 1978.
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AVAILABILITY '
Jur,e 1, 1983. .-
DATE:
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RONALD M. THURLOW N0alth Physics Internship I: I perfomed radiation and contamination surveys in biology labs, source room, counting room, and the research reactor. I also calibrated instruments. I performed whole body counts on people incoporating a multichannel analyzer.
Health Physics InternshA* II: Under the direction of Dr. George Chabot I did reperc on Fricke Dosimeters, using a Cobo1*,-60 irradiator.
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SCHNElDER EC Manning and hesume Current 10-22 86 Menepoment Services KATHERINE E. VON WALD .
l Education 1982 B. A., General Studies J
University of Maryland ,
Co11ege Park, Maryland Experience 4/83 to Present St.hneider/EC Planning & Management Services Harrisburg, Pennsylvania Senior Planner / Trainer. Responsible for providing guidance and technical assistance to project staff assigned responsibility for emergency preparedness planning, procedure preparation, personnel training and drill / exercise operational readiness; conducting varicus projnt tasks as recuired to support project !
objectives; and scheduling / coordinating various elements of project tasks. Recent project assignments have included: ,
- managing project team efforts for New Hampshire ,
radiological emergency response program training, '
drill and exercise preparation in support of Seabrool '
Station;
- developing, scheduling and conducting trainint ';
programs for New Hampshire Civil Defense Agency it preparation for the 1986 Seabrook Matton gradet exercisa;
- preparation of station public relations procedure foi the Callaway Plant, local EOC operational readiness emergency worker lesson plan development, drill ani exercise progras' objective / scenario development drill / exercise controllet- functions, and resultan' implementing procedure upgrade; Y~m.m,.,
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- assistance in the development of nuclear technology, radiatic,n principles, and protective action sections of lesson plans for the training of agencies, organi-rations and local officials involved in response to incidents at the Limerick Generating Station;
- conduct of radiological emergency preparedness train-ing for those emergency response personnel located within the vicinity of the Peach Botten Atomic Power !
Station; _ , _ ,. , , l
- emergency planning. training and exercise preparation for the Callaway Plant 1985 exercise;
- review and revision of municipal radiological emer-gency response plans for incidents at the Peach tottom Atomic Power Station; and ,
- evaluation of drill / exercise participant performance i in support of the Limerick Generating Station.
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Certifications Instructional Systems Design Certification Program. '
September 1984 1
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Attachment F has been redacted.
Sf CERTIFICATE OF SERVICE I, Jay Bradford Smith, one of the attorneys for the Applicar.ts herein, hereby certify that on October'25' 1988, I ,
made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (oe, where indicated, by depositing in the United Statas mail, first class postage paid, addressed to):
Administrative Judge Ivan W. Smith Robert Carrigg, Chairman Chairman, Atomic Safety and Board of Selectnen Licensing Board Panel Town office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Judge Gustave A. Linenberger Diane Curran, Esquire l
Atomic Safety and Licensing Andrea C. Forster, Esquire Board Panel Harmon & Weiss U.S. Nuclear Regulatory Suite 430 Commission 2001 S Street, N.W.
East West Towers Building Washington, DC 20009 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General commission office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board panel Docket (2 :opies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building One White Flint North, 15th Fl.
4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel 116 Lowell Street U.S. Nuclear Regulatory P. O. Box 516 Commission Manchester, NH 03105 Washington, DC 20555
l Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Salectman's office '
Department of ths Attorney 10 central Road General Rye, NH 03870 Augusta, NE 04333 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 Fl.
Portsmouth, NH 03801 Boston, MA 02108 l Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 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. Humphre) 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 Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Gary W. Nolmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 Mr. Richard R. Donovan Judith H. Mitner, Esquire i Federal Emergency Management 79 State Street, 2nd Floor Agency Newburyport, MA 01950 !
Federal Regional Center 130 228th Street, S.W.
Bothell, Washington 98021-9796 Ashod N. Amirian, Esquire 376 Main Street Haverhill, MA 01830 '
Robert R. Pierce, Esquire John H. Frye, III, Alternate Atomic Safety and Licensing Chairman Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel commission U.S. Nuclear Regulatory East West Towers Building Commission #
4350 East West Highway East West Towers Building Bethesda, MD 20814 4350 East West Highway ;
Bethesda, MD 20814 James H. Carpenter, Alternate Technical Member Atomic Safety and Licensing l Board Panel U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 A pa s)-s.EA Jay Bradford' Smith i
(*= Ordinary U.S. First Class Mail) l i
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