ML20205M330

New England Coalition on Nuclear Pollution First Set of Interrogatories & Request for Production of Documents to State of Nh on Rev 2 to State of Nh Radiological Emergency Response Plan.* Related Correspondence

ML20205M330
Person / Time
Site:	Seabrook
Issue date:	03/05/1987
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	NEW HAMPSHIRE, STATE OF
Shared Package
ML20205M150	List: ML20205M146 ML20205M272 ML20205M306 ML20205M330 ML20205M339
References
OL, NUDOCS 8704020347
Download: ML20205M330 (15)

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i-March 5, 1987 UNITED STATES NUCLEAR REGULATCRY COMMISSICN BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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Public Service Company of )

New Hampshire, et al. ) Docket Nos. 5 0-443 OL

) 50-444 OL (Seabrook Station, Units 1 & 2) ) OFFSITE EMERGENCY

) PLANNING ISSUES

)

NEW ENGLAND CCALITION ON NUCLEAR FOLLUTICM'S FIPST SET OF INTERFOCATORIES AND PEQUEST FCF THE PRODUCTION OF DOCUMENTS TO STATE OF NEW HAMPSHIRE OF PEVISICN 2 TO THE NEW HAMPSHIDE FADICLCGICAL EMEFCENCY FESPONSE PLAN INSTFUCTIONS PCP USE The following interrogatories are to be. answered in writing and under oath by an enployee, representative or agent of the State of New Hampshire with personal knowledge of the facts or information requested in each interrogatory. We remind you of your obligation to supplement answers to interrogatories, under 10 C . F. P . S 2.740(e).

The following definitions shall apply to these inter-rogatories:

1) " Document" shall mean any written or graphic matter of commu nica tion, however produced or reproduced, and is intended to be conprehensive and include without limitatiu. any and all cor-respondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other

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i means, computer ' da ta, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office c ommu n ica t io ns', notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, draf ts, telephone minutes, minutes of meetings, statements, calendars, j ournals, orders, confirmations ano all other written or graphic materials of any nature whatsoever.

2) " Identify" with respect to any document shall mean to state the following: the document's title, its date, the author o f the document, the person to whom to document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the present custooian of the document and of any and all copies of the document.

3) " Identify" with respect to any action or conduct shall rean state the following regarding any such action or conduct:

the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; and any document recording or documenting such action.

4) " Identify" with respect to an individual shall m.ean state the individual's name, address, employer, occupation, and title.

5) " Describe" with respect to any action or matter shall mean state the following regarding such action or matter: the

s-O substance or nature of such action or matter; the persons partic-ipating in or having knowledge of such action or matter; the' cur-rent and past' business positions and addresses of such persons; and the existence and location of any and _all documents relating 1

to such action or matter.

GENERAL INTERPCGATORIES

1) In accordance with 10 C . F. R. S 2. 740( e) , please supple-ment your answers to NECNP's Fi rst Set of Interrogatories and Requests for the Production of Documents to the State of New Hampshire on New Hampshire Radiological Emergency Pesponse Plans, filed April 3 0, 1986.

2) What is the State of New Hampshire's position on each of the contentions that have been admitted in this proceeding with respect to Revision 2 of the New Hampshire Fadiological Emergency Pesponse Plan? What is the basis for your position?

3) Cn or before Ma rch 19, 1987, please produce at the of fice of Harmon & Weiss all documents on which you rely or intend to rely during this proceeding to support your position on each of the contentions that have been admitted in this proceed-ing with respect to Revision 2 of the New Hampshire Padiological Emergency Response Plan. This includes but is not limited to all I

documents used in answers to these interrogatories, summary dis-position motions, testimony, and cross-examination of witnesses i during hearings.

4) Please identify all persons on whose factual knowledge, '

l opinions, or technica) expertise you rely or intend to rely for  ;

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your position on each of the contentions that have been admitted I

in this proceeding with respect to Revision 2 of the New.

Hampshire Radiological Emergency Response Plan.

5) Please identify all persons you may call as witnesses on each of the contentions that have.been admitted in,this pro-ceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Pesponse Plan. Please describe the sub-i

', stance of their testimony; and identify and describe any docu-ments and the portions thereof that they may rely on for their a

testimony.

l 6) On or before March 19, 1987, please produce in the of fice of Harcon & Weiss all documents in the State of New Hampshire's possession which analyze or evaluate in any way the adequacy of the New Hampshire RERP or New Hampshire's state of preparedness in the event of a radiological emergency.

7) Please identify all persons who participated in the development or draf ting of Revision 2 to the New Hampshire RERP.

j 8) Please identify all persons who are responsible for  ;

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training of emergency response personnel for implementation of Revision 2 to the New Hampshire RERP.

9) Please describe the State's program for training emer-l

gency response personnel under Revision 2 of the RERP. Identify j_ all individuals who are responsible for that program.

INTERROGATORIES REGARDING SPECIPIC CONTENTIONS 4

NECNP RERP-8 l

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. 10) Please produce all docaments supporting your calcula-tions regarding the dose reduction efffectiveness of certain institutions in the Seabrook EPZ , as described at Vol. 4, Appen-dix F of the RERP.

11) Please explain your reasons and criteria for choosing to evaluate the dose reduction effectivness of these particular institutions.

12) Cid considerations of the time in which these facilities could be evacuated influence your decision to assess the dose reduction effectiveness of these structures? If so, what part did they play, what estimates of evacuation times have you aade for these facilities, and what are your conclusions about the feasibility of safely evacuating them?

13) Has the State performed dose reduction effectivness calculations for any specific institutional structures in the EPZ, such as schools, other than those listed in the RERP? If so, please provide them. If not, what were your reasons and criteria for refraining from doing so?

14) Did considerations of the time in which these other j facilities could be evacuated influence your decision not to assess the dose reduction effectiveness of these structures? If s o, what part did they play, what estimates of evacuation times \

have you made for these facilities, and what are your conclusions about the feasibility of safely evacuating them?

NHLP-6 and HAMPTON REVISED CONTENTICN IV TO PEVISION 2 i

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15) For Each Emergency Operations Center, how many separate telephone lines are allocated to receiving calls from members of

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the public seeking transportation assistance? Are these commer-cial lines or dedicated lines?

16) For each telephone line identified above, has an opera-tot been assigned to the line? If so, identify the individual and describe his or her expertise and experience in transporta-tion, and each person's knowledge of the area. Will that person have any other responsibilities at the ECC? If so, describe those other responsibilities.

17) For each telephone line identified above, how many households have been told to call that line to request assistance? How many calls does the State expect to receive on each of these lines during a radiological emergency?

18) For each telephone line identified above, does the State intend to use the line for any f unction other than the receipt of calls requesting transportation assistance? If so, what other uses are planned?

19) Does the State plan to use the same telephone lines identified above to coordinate the activities of vehicles assigned to pick up people with special transportation needs? If not, what other means of communication will be used? Please identify the number and type of communication equipment that will be used for this purpose at each SOC, and the num ber and identity of individuals that ate assigned to that task.

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20) What advice will be given to people without transporta-tion-who call the EOC if the location of the buses is unknown?

What is the basis for this advice?

21) How will time estimates be made for the arrival at any point on the bus route?.

22) By what neans and how often will those arrival tines be commu nica ted to those people in need of transportation? Will the arrival times be verified? If so, by what means and how often?.

23) Describe the system by which the person taking calls at the ECC will keep track of who has requested help and whether they have received it yet.

24) For each person who indicates on a reply card that they will need transportation assictance, when will they be contacted with instructions? Who contacts them? Identify these individu-als.

25) Please produce copies of all planned itineraries and routes of vehicles that will provide transportation for people with special transportation needs, including location of bus stops.

26) Please identify each individual in the EPZ who is unable by virtue of age or handicap to go to a bus stop and requires pickup at home during an evacuation.

27) For each individual identified in response to the preceding interrogatory, please identify the location from which.

that person will be contacted to inform him or her of transporta-

8-tion arranaements; the specific telephone line or other.means of communication _that will be used; and the number . and identitity of-individuals that are assigned to the task.

28) Please identify each vehicle that the State of New Hampshire intends to rely on for transportation of school chil-dren, handicapped people, institutionalized people, and other people without their own transportation. Please identify the owner of the vehicle, the driver ( s) o f the vehicle, the location where it is stored, and its daily r ou te( s ) and itinerary under o rdinary circums tances. In addition, please provide copies of the routes and itineraries of each of the buses over the past two years.

29) For each vehicle described in answer to the preceding question, what is the vehicle's capacity? What equipment doer, the vehicle have for transporting handicapped people?

30) Please provide copies of the breakdown and maintenance records for each vehicle identified above.

31) Please identify which of these vehicles have radios on board. For those vehicles which have radios, identify the indi-viduals or organizations that will comaunicate with thase radios.

Identify the equipment that will be necessary to communicate with the vehicles, and where it is located.

32) Please identify each bus driver who will be relied on in a radiological emergency, the employer ( s) of that individual, and the specific vehicle that the individual will drive. If the I

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driver has not been assigned to a specific vehicle, please-explain whethe,r the driver has been assigned to a particular bus company or other vehicle - provider; and when the driver will be assigned to a specific vehicle.

33) For each driver identified in response to the preced-ing interrogatory, state whether that person is ordinarily employed as a criver and if so by whom. Is the employment part-time or full-time?

34) For each driver identified in response to the preced--

ing interrogatory, state whether the driver is experienced in driving a bus for the hanoicapped or loading students into a bus for the handicappeo, and describe the nature and duration of that experience.

35) For each driver identified above, state whether that individual has agreed to be available during a radiological emer-gency. If so, identify the parties to the agreement, provide the date of the agreement, and indicate whether it was written or oral. If the agreement was in wr iting, please provide a copy.

36) Provide copies of the regular employment contracts between drivers and the bus companies that have agreed to provide transportation service during a radiological emergency.

37) For each driver identified above, describe the means by which they will be contacted; the individual (s) who are assigned to contact them; and the location, n um be r , and type of each piece o f communication equipment that will be used to contact them to request their assistance during a radiological emergency.

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, 38) For each driver identified above, describe all steps that the State has taken to assure that drivers can be. contacted on a 24-hour basis.

39) For each driver identified above, describe all steps that the State has taken to to assure that the bus driver will be immediately available to-respond to a radiological emergency.

40) Provide any information on estimates you have made con-cerning how long it will take each of these drivers to get to the bus that they will drive. Ciscuss the basis for your estimates and provide copies of any supporting documents.

41) Have estimates been made of how long it will take to mobilize willing drivers at any time of the day? Discuss the basis for your estimates and provide copies of any supporting d oc um e n t s .

42) For those drives who reside within the Seabrook EPZ and have small children or other f amily members who require trans-portation out of the EPZ during an evacuation, please describe all arrangements that have been made for the evacuation of those family members.

43) With respect to the evacuation of school children, by whom and by what criteria will the decision be made as to whether to send buses to the staging areas or directly to the schools?

44) Identify all individuals responsible for monitoring the adequacy of transportation for schools and institutions and indi-viduals requiring special transportation, and directing the pro-i

vision of transportation for these people.

Is the responsibility divided between several people? If so, how? What other responsibilities are assigned to those individuals?

45) Please identify all organizations and individuals that the State will contact in order to arrange for the transportation of school children and other people with special transportation needs during a radiological emergency.

46) Please identify and-describe the location from which those contacts will be mader the type and number of separate pieces of communication equipment that will be used; and the num-her and identitity of individuals who are assigned to make those contacts. l i

47) Is the communication equipment described in answer to the prececing interregatory devoted exclusively to communications requesting transportation assistance? -If not, to what other uses is it assigned?

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48) Identify all bus and driver pairs that regularly carry children to ano from schools, and can be expected to be available ,

in a radiological emergency. Provide the basis for your answer i

to this question.

49) How long will it take to mobilize all the necessary l buses in case of an evacuation? What is:the basis for your estimate?

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50) Identify each driver who has been trained for implemen-tation of the NHRERP. Describe the means by which those individ-1

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I l , uals were trained, the dates on which they were trained, the identity of inoividuals who trained them, and the content.of the training program. Please provide copies of any written materials that were used. -

51) Describe any direct communications between Public Ser-Vice or the State of New Harpshire and the drivers in the Team-ster's Union.

52) Describe any communications or agreements between the Teams ter's Union and its own drivers regarding the NHREPP.

53) Provide any agreements between drivers for the Tear-sters Union and Union of ficials, Applicants, or the State of New l Hampshire.

54) Provide copies of regular employrent contracts of drivers in the Teamsters Union who will be relied on during a radiological emergency.

55) Provide all agreements or correspondence between the i Teamsters Union or Union of ficials, Applicants, or the State of New Ilampshire, regarding the possible provision of transportation services by Teamsters members during a radiological emergency.

56) Describe all arrangements that the State has made for the provision of backup buses in the event that insufficient buses are available during a radiological emergency.

57) Identify all bus and driver teams that are allocated f or the transportation of transients during the summer months.

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b response functions in the event that the Town of IIampton is l unable.or unwilling to perform them, and the roles that those f

l individuals will-take.

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) 58) Are those individuals committed exclusively to assist j in the emergency response for the Town of Hampton? If not, j_ describe their other responsibilities.

l HAMPTON REVISED CONTENTION VIII TO REVISION 2

59) NUPEG-0654 states that "the overall objective of emer-i

cency response plans is to provide dose savings (and in sorce 1

cases immediate life savings for a spectrum of accidents that j could produce offsite doses in excess of Protective Action i

i Gu idelines (PAGs) ." In this vein, NUPEG-0654 requires planners

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j to consider, inter alia, the timing and consequences of potential

, releases. What spectrum of accidents did the State consider in i

} developing Revision 2 to the N!!RERP, and what are the character-i

istics of those accidents? What quantitative dose savings result 1

] from implementation of the protective measures proposed in Revi-

{ sion 2, given each type of accident that was considered? Please j provide all data that supports your conclusion.

60) Assuming that dose reductions are achieved, describe 1

l the health effects associated with each of the accidents that-you

( considered in developing Revision 2 to the RERP.

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61) Identify and provide access to any and all of your cal-culations of potential dose consequences to the public in the event of a radiological emergency at Seabrook, and the bases for those calculations.

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62) Has the State completely ruled out sheltering of the beach population if an accident occurs during the summer? Under

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what circumstances might sheltering be ordered? Describe the criteria for making such a decision.

SAPL CONTENTION 7

63) Describe and identify the date and parties to all oral agreements for the provision of host facilities and staff for evacuees f rom the Seabrook EPZ .

64) Please identify and produce all written agreements for the provision of host facilities and staff for evacuees from the Seabrook EPZ.

65) Please identify all individuals who will be relied on to staff host facilities during a radiological emergency, and their functions.

66) Please describe all measures that will be taken at host facilities to prevent contaminated individuals from contaminating uncontaminated or less contaminated individuals.

67) Please describe all equipment and procedures for stor-ing and disposing of waste water from the washing of evacuees and their vehicles.

Whg pectfully submitted, ane Curran HARMON & WEISS 2001 "S" Street N.W. Suite 430 Wa s hing ton, D.C. 20009 (202) 328-3500 March 5,1987

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1 I certify that on March 5, 1987, copies-of the foregoing

. interrogatories were served by Federal Express or by. hand on the NRC Staf f, the Executive Director for Operations, _the Licensing Board, the State of New Hampshire, FEMA,-and Applicants; and by first-class. mail on all other partias listed on the attached ser-vice list.

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} Diane Curran 4

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