ML20205R562
| ML20205R562 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/01/1988 |
| From: | Selleck K, George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | MASSACHUSETTS, COMMONWEALTH OF |
| References | |
| CON-#488-7463 OL, NUDOCS 8811100066 | |
| Download: ML20205R562 (61) | |
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- 88 O -8 P4 :47 REDACTED DOCUMENT UNkkSTATESOFl AMERICA ER no -
( NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD l
)
In the Matter of )
l )
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL
)
(Seabrook Station, Units 1 and 2) ) (Off-site Emergency
) Planning Issues)
)
APPLICANTS' RESPONSE TO "(MASS AG's]
SECOND SET OF INTERROGATORIES TO APPLICANTS ON THE (SPMC)"
Pursuant to 10 CFR I 2.740b, Applicants respond to
"[ Mass AG's) Second Set of Interrogatories to Applicants on j the (SPMC)" as follows:
- 1. As To "Delinitions and Instructions" The information provided in these answers is information in the possession of Public Service Company of New Hampshire, New Hampshire Division at Seabrook Station (hdHY"), and employees and contractors thereof. Applicants object to the definition of "NHY" suggestad by Mass AG insofar as it goes SDohN O
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to all of NHY's "agents", as that term is too broad and the search entailed would be unduly burdensome.
Applicants object to Mass AG's "Definition and Instruction" paragraph f, which would have Applicants describe documents that were once in Applicants' possession.
This unbounded request is absurd; Applicants cannot possibly begin to detail the notes, drafts, correspondence, and other
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kinds of documents which once existed but of which Applicants do not maintain copies currently, and which might provide information in response to Mass AG's interrogatories.
Due to the confidential information they contain certain answers will be redacted on all copies except those being served on members of this Atomic Safety and Licensing Board and counsel for active parties.
- 2. As to Specific Interrogatories Interroaatory No. 1 Please describe in detail the purpose of the "generic" plans listed in Appendix F of the SPMC and how you and/or the ORO intend to use them. For each such "generic" plan, please list the name and address of each and every individual, company, or organization to which these "generic" plans have been provided, the dates the plans were provided, and the substance of any response received.
Aeolicants' Response The purpose of the supporting plans was to establish standardizec emergency response procedures for each type of special facility in the EPZ as well as for each type of resource provider. These plans were designed for use by the
/
L facility or resource provider and provided: planning f background; a description of the actions to be taken in a radiological emergency; and information describing how the
{ facility will interface with the ono.
With the exceptions listed below, copies of the supporting plans were distributed for comment to all of the facilities / providers listed in Appendix M either by mail or during personal contacts made between January and April 1988.
Two summer camps, Camp Sea Haven in Newburyport, and Adelynrood in Newbury, and two summer school programs, the Greater Newburyport ARC Summer Special Education program and the Greater Newburyport Educational Collaborative Summer School Program were identified, but they were not in operation during the initial plan distribution. Plans have been prepared and planning efforts are continuing with these facilities.
A variety of responses were received. Several comments were recorded and incorporated in the plans. In some cases, the plans were returned to NHY. To reproduce here the substance of all comments and recommendations contained in these documents would be unduly burdensome. Applicants therefore respond by producing, and by making available at Seabrook Station, documents containing the comments that were received and recorded.
r Interrocatory No. 2 Do you contend that any schools have site-specific radiological emergency response plans (RERPs)? If so, identify each school and state for each whether you have a copy of said plan.
Acclicants' Resconse Applicants assume that this interrogatory refers to site I
specific radiological emergency response plans developed by organizations other than NHY. Radiological emergency response plans were developed for schools as part of the l
planning efforts of the Commonwealth and the EPZ communities fer Seabrook Station. Applicants are unaware of the current status of these plans. Applicants have copies of the draft plans.
In addition, Applicants provided for comment specific or generic support plans to each of the public schools, private .
a schools, day care centers, and nurseries listed in Appendix I Although some of these plans were returned to NHY, M.
Applicants are not aware of the disposition of these plans other than those provided to facilities that have elected to
) participate in planning. Applicants have copies of 'he plans ,
that were distributed.
Interrocatory No. 3 l For any of the schools which have no institution-specific RERPs, do you contend that local governments or ,
school officials have engaged in some planning for protecting the health and safety of their students from a radiological emergency? If so, state which local governments and/or
schools have done so anu, for each, describe the type and extent of planning undertaken and identify any and all documents which describe this planning.
Acolicants' Response Yes, to the extent identified in response to inter ogatory No. 2.
Interrocatory No. 4 Identify each school which has agreed to cooperate with the ORO during a radiolojical emergency and will allow its students to board ORO's buses and be transported by them.
Aeolicants' Responsg i During a radiological emergency, schools would be recipients of emergency services. As sv.ch, ORO will make transportation resources available during an emergency, and it is assumed that the schools will cooperate and allow their students to be transported.
l Interrocatory No. 5 The SPMC at Plan sec. 3.4-4 and I.P. 2.5, sec. 5.2, p. 7 state that ORO will consider recommending the precautionary action of "early evacuation of schools." No mention is made of other possible precautionary actions, i.e., (1) early dismissal of schools and (2) early evacuation of some schools combined with early dismissal of others. Have these two precautionary actions been excluded from consideration in the SPMC? If so, state the reason (s) for this exclusion. If not, identify those sections of the SPMC which indicate how (what criteria are applied), when, and by whom such precautionary actions will be considered and implemented.
Aeolicants' Resconse The SPMC does not rely upon early dismissal as a precautionary or protective action. This is consistent with FEMA Guidance Memorandum EV-2.
)
Interroaatory No. 6 I Idantify the person (s) in NHY's ORO who is most knowledgeable about the SPMC's plans and procedures for schools and day care centers in the Massachusetts EPZ.
Aeolicants' Resnonse Applicants do not know the specific knowledge that each ORO member has. However, persons filling the following
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positions are trained to be knowledgeable in the identified areas to the extent needed to implement the SPMCs ORO School Coordinator. See response to interrogatory
) No. 17.
Interrocatory No. 7 The SPMC at Plan sec. 3.4-4 and I.P. 2.5, sec. 5.2, p. 7 generally describes the factors to be considered when ORO is considering whether to recommend early evacuation of the schools. With respect to these factorst (a) What combination of plant conditions (stable
) vs. unstable) , wind direction or projected wind shif ts, and degrce of readiness of available resources to support early evacuation of schools would prompt ORO to
, recommend early evacuation of schools, and explain your reasons.
(b) What combination of these factors will prompt ORO to recommend against an early evacuation of the schools, and explain your reasons.
Aeolicants' Response The factors to be considered are contained in the SPMC provisions cited in the interrogatory. The infinite number of possible combinations of plant conditions, wind directions, projected wind shifts and degrees of resource l
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availability precludes a. response to the sub-elements of this interrogatory.
Interroaatory No. 8 Do you contend that if a school in the Massachusetts EPZ has no institution-specific RERP and has engaged in no prior planning for a radiological emergency the implementation of a the SPMC by NHY's ORO fully compensates for the lack of prior ,
planning at the school and provides reasonable assurance that adequate protective measures can and will be taken for the children in school there? If not, what prior planning is necessary by the schools to ensure that adequate protective ,
measures can and will be taken?
Acolicants' Resoonse t Yes.
1 Interroaatory No. 9 For schools in the Massachusetts EPZ which heve engaged in no prior planning for a radiological emergency, does the SPMC depend or rely upon the administrators and *.eachers at these schools to behave and respond in certain says to implement the SPMC for the children in their senools in the event of a radiological emergency at Seabrook Station? If
} so, describe specifically the administrator and teacher behavior (s) and/or response (s) the SPMC depends or relies upon for each of the precautionary and protective actions g ,
which may be recommended for schools under the SPMC.
Acolicants' Resoonse Applicants object to this interrogatory insofar as it seeks information regarding human behavior issues, a subject previously litigated. Without waiving the foregoing objection, Applicanta respond as follows:
School administrators and teachers are recipients of emergency response services and ars not depended upon or relied upon to implement the SPMC.
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During any emergency situation, school administrators t and teachers will respond by carrying out their professional duties and responsibilities with regard to the protection of the childro 'Inder their supervision.
I Interrocatory No. 1Q For schools in the Massachusetts EPZ which have engaged in no prior planning for a radiological emergency, does the SPMC depend or rely upon the regular school bus drivers for these schools to behave and respond in certain ways to t implement the SPMC in the event of a radiological emergency at Seabrook Station? If so, describe specifically the bus driver behavior and/or responses the SPMC depends or relies upon for each of the precautionary and protective actions i which may be recommended for schools under the SPMC.
t Aeolicants' Resconse Applicants object to this interrogatory insofar as it seeks information regarding human behavior issues, a subject previously litigated. Without waiving the foregoing
) objection, Applicants respond as follows:
No.
Interrocatory No. 11 Have estimates been made of how long it will take ORO's buses to get to schools in the Massachusetts EPZ after a decision is made to evacuate the schools? If so, state what these estimates are and how they were derived. Identify any and all documents which pertain to those estimatus.
Aeolicants' Response No, not in the form suggested by the interrogatory.
Estimates of the range of times for the dispatch of buses to schools are contained in NHRERP Volume 6 Section 11.
I Interroaatorv No. 12 Do you admit that each School Liaison will share a commercial telephone at the Staging Area with either a Special Population Liaison or a Local EOC Liaison? If the answer is no, please reconcile your answer with the arrangement for telephones depicted on the Stagirig Area Operational Layout, I.P. 3.2, Attachment 5.
Acolicants' Response Consistent with the commitmen: made by NHY to FEMA, one telephone line has been installed at the staging area for i
each ORO School Liaison, Special Population Liaison and Local EOC Liaison. Figures in the SPMC depicting the Staging Area Layout (Figure 5.2-4 and IP 3.2, Attachment 5) will be revised accordingly.
Interrocatory No. 13 I
Please list the name and address of each of the companies currently being relied upon by ORO to supply buses t and/or vans in the event of a radiological emergency at J Seabrook Station, and for each company identify the number of buses and vans whicht 3
(a) will always be immediately available (with drivers) upon notification by ORO, even if buses have other scheduled assignments; (b) will be available (with drivers) only after completing a transport job which the company has a prior commitment to drivert (c) will be available (with drivers) under certain other conditions (please identify).
Acolicants' Resoonse (REDACTED)
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l Interrocatory No. 14
( For each bus or van company listed in the prior interrogatory, list the names, addresses, and phone numbers of each driver who has agreed to drive a bus or van into the EPZ in the event of a radiological emergency at Seabrook.
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For each such driver, list the ORO training courses each has taken whether the driver passed the courses, and the dates I
these courses were taken.
ADolicants Resoonig Applicants object to this interrogatory to the extent that it seeks home addresses and home phone numbers. The drivers' interests in the privacy of this information are i real and substantial. Applicants also object to this interrogatory insofar as it seeks information not relevant to the subject matter of this proceeding, i.e., the admitted contentions, but solely about issues of human behavior 4
excluded by the Board. Without waiving the foregoing objection, Applicants respond as follows:
Names of bus or van drivers, by company, are listed on a computer printcut which includes the dates on which specific training courses were taken. To reproduce here the substance of all the information contained in the computer printouts would be unduly burdensome. Applicants therefore respond by reproducing and by making available at Seabrook Station the computer printouts. The printouts also contain the resulting grades for each person. Testing requirements for passing are provided in Appendix K, i V. Note that the requirements were t
i revised in page Amendment 3. Where no date is shown, those persons have yet to receive training.
Interrocatory No. 15 I Please identify the person in NHY's ORO who is most familiar with the current arrangements, contractual and otherwise, with the bus and van companies being relied upon by the SPMC.
Aeolicants' Resoonse Applicants do not know the specific knowledge that each j l
ORO member has. However, persons filling the following l
positions are trained to be knowledgeable in the identified areas to the extent needed to implement the SPMCs ORO Bus Company Liaison.
Interroaatory No. 16 i
Describe the method by which the bus transportation needs in Appendix M were determined for each of the schools in the Massachusetts EPZ?
Aeolicants' Resoonse The planning basis for determining bus transportation needs for public and private schools was to add the total number of faculty and staff per facility to total student enrollments per facility as of October 1, 1987. The number of buses was determined by dividing the sum by a bus capacity of 60 for elementary schools and by 50 for secondary schools.
Fractional results were rounded up to the next highest whole number, i
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f Day care center and nursery school transportation needs were calculated by determining the total licensed capacity of each facility and the number of staff employed (based on listings maintained by the Commonwealth of Massachusetts, Executive Of fice of Human Services, Of fice for Children, and/or communicatione with individual facilities) and dividing the total Day Care / Nursery School population in each j town by 60.
Interroaatory No. 17
$ Please list the names, addresses, and business phone 4
numbers for 4
ADolicants' Resoonse
- Applicants object to this interrogatory to the extent that it seeks home addresses. The percons' interests in the privacy of this information are real and substantial.
Without waiving the foregoing objection, Applicants respond as follows:
(REDACTED)
Interroaat,ory No. 18 i
Explain the "code" numbers assigned to each of the 4 schools and day care centers in Appendix M and what these
! code numbers are used for.
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Aeolicants' Resconde l The codes numbers are explained in SPMC, IP 2.10, Attachment 1, page 21. The code numbers are used by the ORO l
Bus Company Liaison to record information on the transportation requirements for each EPZ community at the time of emergency.
Interroaatory No. 19 Please explain the system of priorities, if any, which School Liaisons will use in making their calls to schools and ,
day care centers (i.e., in what order the calls will be made).
Aeolicants' Resconse school Liaisons will make their calls in the order of the list in Appendix M.
Interrocatorv No. 20 What efforts if any, will ORO make during a radiological L emergency to notify schools which the School Liaisons are i unable to reach because the telephone (s) at the schools are continuously busy?
Aeolicants' Resoonse The School Liaison would continue to try to contact the facility. In addition, VANS, EBS, and tone alert radios (which will be offered to all schools) will be activated.
Interrocatory No. 21 Please identify any studios or other documents which assess, analyze, estimate, critique, or otherwise concern the suitability of using the schools in the Massachusetts EPZ as protectivo shelters during a radiological emergency at Seabrock Station.
t ADolicants' ResDonso Protective Sheltering in the Seabrook EPZ, Massachusetto Civil Defense Agency, undated, Kelly, Robert B.; Kowalik, Leo F., Jr., and Barry, Joanne M.
Interroaatory No. 22 As described in the original MAG 47(M), it is not clear whether School Liaisons will "verify" a school's transportation requirements by obtaining (a) the total number of buses which would be needed to transport all the students in the school or (b) the number of buses which, in addition to those available to the school, are needed to ensure that all students can be transported. Please describa what number the Liaisons are seeking and state whether Liaisons are to
- I encourage schools to use their own buses or not?
Anolicants' Respongs In accordance with IP 1.9 and IP 2.7, School Liaisons verify the total number of vehicles required to evacuate schools and day care conters.
In IPs 1.9 and 2.7, School Liaisons are directed to inquire of the facility whether the facility is using its own transportation resources to assist with an evacuation.
Schools are free to engage their own transportation resources as they may be available. The SPMC ther provides for supplementing the transportation needs of individual facilities in whole or in part from the pool of ORO transportation resources as may be necessary.
,Interrocatory No. 23 After a School Liaison reads the School Protective Action Message set forth as Attachment 1 to I.P. 2.7 and 4
informs a school that ORO "will have the vehicles you
l identify dispatched to your school to support your immediate
' evacuation," if the school administrator asks, "How soon can ou get those buses here?" what will the School Liaison say n response?
Acolicants' Resoonse j If a school administrator requests information about the j l
bus arrival times for a particular facility, the School
! Liaison will obtain that information by calling the School Coordinator at the EOC and call the school administrator back with the information when it is received.
Interroaatory No. 24 Do you contend that the Commonwealth of Massachusetts I and/or the six Massachusetts EPZ communities, acting in a Mode 1 response without ORO involvement, can implement the SPMC's plans and procedures for school children in a timely fashion? If your answer is yes, please describe how this can be done and, in doing so, address each of these potential obstacles to a timely implementations (1) the fact that all SPMC procedures for school coordinators and school liaisons are written for ORO personnel who in carrying out their tasks after calling the schools interface only with other ORO personnel (e.g., ORO's Bus Company Liaison);
(2) the fact that no state or local officials have the names or phone numbers of any of the bus companies being relied upon under the SPMC; (3) the likelihood that state and local officials will not have copies of the SPMC's plans and procedures for schools when the emergency beings; (4) the fact that the Letters of Agreement with the bus companies run between the companies at the Seabrook Joint Owners and not between the companies and the state or the local governments.
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Aeolicants' Response No, the SPMC does not contemplate "a Mode 1 response without ORO involvement." See SPMC section 3.1.
Jnterroaatory No. 25 The SPMC is silent on the issue of who will supervise the boarding of school children onto the ORO buses. Will ORO personnel do this? If not, describe in detail who will.
Aeolicants' Resoonsa
, Applicants incorporate herein their response to interrogatory No. 9.
\
Interrocatory No. 26 Pleas 1 identify the current host school facility or facilities. For each facility provide the name, address, capabilities, contact person and phone number.
Aeolicants' Resoonse Applicants object to this interrogatory to the extent that it seeks home phone numbers. The privacy interests of the contact persons are real and substantial. Without waiving the foregoing objection, Applicants respond as follows:
(REDACTED)
Interroaatory No. 27 Were a first shift School Liaison ever to fail to show up for duty, would the ORO seek to bring in a back-up Liaison, divide the work of all School Liaisons up among the Liaisons who did report for duty, or take some other compensatory action (please describe).
At>licants' Resconse Section 2.1 of the SPMC, Utility organizations, describes the NHY Offsite Response Organization. Section
2.1.1 states
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Generally, positions will be staffed using two alternate shifts, with a third shift available as a backup.
Should the situation described above occur, the ORO would mobilize backup personnel per SPMC, IP 2.1 and Appendix G. Until backup personnel arrived, the ORO might be required
{ to take interim actions (i.e., dividing the work load among other trained personnel) to perform emergency response I
functions in a timely manner.
Interroaatory No. 28 l
In the event of a real radiological emergency, in what period of time doe.s NHY's ORO expect to be able to complete y the process of relaying a message from the School Coordinator 1 to the School Liaisons and then to all of the schools (including day care / nursery schools) listed in Appendix M.
Please describe how this time expectation was calculated or estimated.
ADoliriants' Resoonsa j l i These calls would take less than one hour. [
27 schools ,
1 i 76 day cares
, 103 Total calls x 3 minutos/ call = 309 min. / 6 liaisons - ;
51.1 min. + 3 min, for School Coordinator to call School f
4 Liaison - 54.5 min.
I i
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Interroaatory No. 29 Identify the person (s) in NHY's ORO who is most knowledgeable about the SPMC's plans and procedures for protecting those in the hospitals, nursing homes, and other apacial facilities (not including schools).
Acolicants' Resoonse Applicants do not know the specific knowledge that each ORO member han. Hovaver, persons filling the following positions are trained to be knowledgeable in the identified areas to the extent needed to implement the SPMCs ORO Special Population Coordinator.
4 Interroaatory No. 30 List the current host hospitals expected to accept hospital and/or nursing home patients from the Massachusetts portion of the EPZ. For each hospital listed, provide the number of patients in each medical classification which the 4
hospital is prepared to accept and state the time duration over which the hospital is prepared to keep the patients.
Aeolicants' Resoonse (REDACTED)
Interroaatory No. 31 List the current hospitals which are prepared to and have agreed to accept contaminated, contaminatsc-injured, and/or excessively exposed general population evacuees.
( Aeolicants' Response MS-1 hospitals are identified in response to I
irterrogatory No. 30.
Interroaatorv No,_11 For each hospital listed in response to the last inte rrogato ry, list how many of each of the following types 4
of patients can be treated per hour I (a) contaminated patients; (b) contaminated-injured patientst j (c) excessively exposed patients.
Atsolicants' Resconse See Appendix M at M-1.
Interroaatorv No. 33 For each of the host hospitals, describe in detail the facilities and equipment available for monitoring and decontaminating evacuees in each of the hose (sic) hospitals I and the arrangements made for receiving, evaluating, and j treating contaminated injured individuals. '
Acolicants' Respongs The SPMC, Appendix M, identifies four "host" hospitals.
In addition, the primary and backup MS-1 hospitals are designated as host hospitals. Both MS-1 hospitals have full capabilities for handling radiologically contaminated injured patients as defined under the MS-1 criteria, including monitoring and decontamination prccedures.
Under the SPMC, during an emnrgency, individuals i
evacuated from the EPZ who require immediate or continuing medical treatment or care will be taken first to an MS-1 designated hospital for monitoring and, if necessary, decontamination. After processing by the MS-1 facility, patients may then b3 transferred to a non-MS-1 host hospital.
See SPMC, Section 3.6.1.C.
Patients evacuated from EPZ hospitals and nursing homes who do not require continuing medical care during the
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evacuation will be taken first to a designated Reception Center for monitoring. If decontamination is required and t+e individual cannot be accommodated at the Reception Centers, they will be taken to an MS-1 hospital.
I Interrocatory No. 34
{ Identify which of the hospitals is the primary (MS-1)
I hospital for the evaluation and emergency treatment of "contaminated injured" members of the general public.
Aeolicants' Response 4
Applicants incorporate herein their response to interrogatory No. 30.
Interrocatory No. 35
! List the names and addresses of the current companies relied upon by the SPMC to provide ambulances or other vehicles for medical transport during a radiological emergency. For each company also provide the total number of drivers and the total number of other ambulance personnel who have agreed to travel into the Seabrook EPZ during an emergency response. Indicate for each cor?any whether the drivers and accompanying personnel have signed letters of agreement indicating a willingness to provide such services.
If no such agreements exist, what assurances do you have that the driver and other personnel will respond in a radiological emergency.
Aeolicants' Responst Applicants object to the last part of this interrogatory insofar as it seeks information not relevant to the subject matter of this proceeding, i.e., the admitted contentions, but solely about issues of human behavior excluded by the Board. Applicants answer the rest of this interrogatory as 4
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t follows:
(REDACTED)
Interroaatorv No. 36 Pisase identify the current host special facility or facilities. For each facility provide the name, address,
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capabilities, contact person and phone number.
Applicants' Response Applicants incorporate herein their response to L
interrogatory No. 26.
Interroaatorv No. 37 I
Do you contend that Amesbury Hospital, Anna Jaques Hospital, or any of the nursing homes or other special facilities in the Massachusetts EPE have institution-specific radiological (sic? emergency response plans? If yes, identify the hosp:,tal(s), nursing home(s)or other special facilities having such plans and state whether you have a copy of each such plan.
Annlicants' Rannonsa l Applicants assume that the interrogatory rufers to site specific radiological emergency response plans developed by organizations other than NHY. Radiological emergency response plans were developed for special facilities as part of the planning efforts of the Commonwealth and the EP2 communities for Seabrook Station. Applicants are unaware of the current status of these plans. Applicants have copies of the draft plans. See also the response to interrogatory Nos. 1 and 2.
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Interroaatory No. 38 Pursuant to the SPMC, who will care for those in the Massachusetts EPZ hospitals and other special facilities who can not be evacuated?
Aeolicants' Resoonse The care and supervision of individual patients /
residents in hospitals and special facilities remains the responsibility of the facility administrators.
Interroaatory No. 39 Identify the person (s) in NHY's ORO who is most 3
knowledgeable about the SPMC's plans and procedures for those persons in the Massachusetts EPZ who may have special notification, evacuation or other needs.
Aeolicants' Response Applicants incorporate herein their response to interrogatory No. 29.
Interroaatorv No. 40 Explain the meaning of the priority codes assigned to each special needs individual listed in Appendix M, and explain how these codes will be used.
Aeolicants' Response Priority codes indicate the order in which to call special needs individuals and are based upon the type of need and transportation requirement.
Interroaatggry No. 41 When was the last special needs survey conducted and when do you expect that the next one will be conducted? How frequently will such surveys be conducted?
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Aeolicants' Resoonse l The last special needs survey was conducted during the period June 1987 to Septembot '?07. The manner in which the Special Needs List will be kept updated is discussed in t'o SPMC, Section 3.6.c Special Population /Special Facilities.
l Interrocatory No._11 1
Regarding the last special needs survey, identify the persons or organization (s) that conducted the survey, and state how many surveys were mailed out and how many completed survey were (sic) returned?
Aeolicants' Re sooris e The last Special Needs Survey was done by International Survey Research Corporation.
Initially, 21,042 surveys were mailed. A second mailing of 17,599 surveys was performed, for a total of 38,641 su rveys . A total of 653 completed responses identified households with impaired individuals.
Interrocatory No. 43 Do you have any information concerning whether upon receipt of the Special Needs Survey there were special needs l
individuals who refused to complete the survey, completed it with factually incorrect information and returned it, and/or turned in their surveys to advocacy groups. If so, please describe this information and identify any and all documents which concern such events and/or indicate that such things Lay have happened.
Aeolicants' Resoonse Applicants have no information regarding special needs i
individuals who may have completed and returned the survey 4
(
with factually incorrect information or turned their surveys f
ovor to advocacy groups.
NHY possesses approximately 12 letters and two documented phone calls indicating an unwillingness of some I
individuals to complete the survey form. These documents will be produced.
The initial survey mailings produced preliminary findings that there were 653 households which indicated they had one or more individuals with impairments. This information was subject to verification efforts in the spring of 1988 which resulted in the confirmation of 352 impaired individuals. The difference between these two numbers reflect those surveys where it was found that the responder required further clarification of the information requested.
Interroaatory No. 44 Secelon 3.7.2(f) of the SPMC (p. 3.7-3) indicates that a Spe cial N )eds Poster was distributed in the f all of 1987 to var ious advocacy groups in the six Massachusetts EPZ multicipalities as well as agencies surrounding the EPZ.
P',same identify these advocacy groups and agencies by name end addre'es.
Aeolicants' ResDonse The computerized mailing list used for the distribution of the Special Needs Poster to advocacy groups contains the names of approximately 380 such organizations (including some duplicate entrees). Applicants will produce this document.
Interroaatory No. 45 Appendix M, p. M-17 (Amendment 6), indicates the number of mobility-impaired people with special transportation needs (a) for each town; and (b) the total number of such people in all six towns. The sum of the numbers set forth for each town, however, is substantially less than the number given as the total. Please account for this discrepancy (sic) and state the correct numbers for each town and the total.
Aeolicants' Response The discrepancy is due to administrative and arithmetical error. The numbers for each town are: Amesbury
- 67, Merrimac - 33, Newbury - 27, Salisbury - 53, Newburyport - 132, West Newbury - 8. The total is 320.
Interroaatorv No. 46 Appendix M, p. M-17 (Amendment 6), Note C indicates that the sources for the data on the mobility-impaired population were a special needs survey by International Survey Research Company, "by personal knowledge and references," and through a special needs hotline. Regarding these sources (a) Where is International Survey Research Company located, and who was the person there who was principally responsible for conducting the surveys (b) State how many mobility-impaired persons were identifico through each of these three sourcest (c) Describe what efforto were taken, if any to verify the information about those with mobility impairments obtained from these three sources.
Applicants' Resnonse a) International Survey Research (ISR) is located in Chicagc., Illinois. John Hoskin and Gary Berger of ISR were principally responsible for overseeing the conduct of the Special Needs Survey.
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b) Applicants incorporate herein their responsa to interrogatory No. 47.
Contacts through the Special Needs Hotlino and "by personal knowledge and references" confirmed data already gathered by the special Needs Survey.
c) See response to (b) above.
Interroaatory No. 47 Identify all the sources used to obtain the names, addresses, and other information about persons in the Massachusetts EPZ with sensory impairments and persons with mental / emotional impairments and state how many persons were identified through each of these sources. For each such sources, (sic) also describe what efforts were taken, if any, to verify the information acquired about those with sensory-impairments obtained from that source.
Annlicants' Renconne The Special Needs Survey conducted by mail from June to September, 1987 by International Survey Research Corporation of Chicago, IL, utilized utility customer billing records for Amesbury, Newbury, Newburyport, West Newbury, Salisbury, Byfield and Saliubury Beach. . voter registration lists were used for the survey in the Town of Merrimac.
The survey efforts identified 653 households where those responding indicated one or more people with impairments resided. In May, 1988, a telephone survey was undertaken to verify the information on the survey questionnaire. Where survey responders could not be contacted or declined to
cooperate, the original information on the survey questionna. ire was retained as valid.
The result of this verification was the identification of 352 individuals with impairments that required special notification and/or transportation during an emergency.
Interrogatory No. 48 I Do you have any intention to chanco the methods used to identify persons in the Massachusetts EPZ with special needs?
If so, please describe these changes.
Apolicants' Response No.
Interrogatory No. 49 How many unredacted copies of the special needs population listings contained in Appendix M exist, who has them, and what steps have been taken to assure the security of this information?
Applicants' Resoonse (REDACTED)
Interrocatory No. 50 Are the original Special Needs Surveys that were returned still being maintlined? If so, who has them, where are they located, and what steps have been taken to assure the security of this information? ,
Apolicants' Resconse ,
(REDACTED)
While the survey forms and computer printouts were in the possession of International Survey Research Corporation, they were kept in locked areas on the company's premises vnen not being used or reviewed by ISn personnel.
L Interroaatory No. 51 From the time the Special Needs Surveys were returned, for each step in the process of collecting the completed su rveys , analyzing them, compiling the data, and producing the special population listings contained in Appendix M, states (a) How many people had access to the acquired information; (b) Whether copies were made of the surveys of the information acquired; and ,
(c) What steps were taken to assure the security of the acquired information.
Apolicants' Resoonse a) The number of people with access to the Special Needs Survey data varied depending on the internal use being made of the survey results, but is estimated at 20-25 individuals. Access was limited to those NHY personnel directly involved with the analysis, verification and processing of the data for use in developing the SPMC.
The holders of 33 unredacted copies of the SPMC have access to the information. i b) Two copies were made of the original computer printout of the Special Needs Survey results for use in the verification process, c) Applicants incorporate horain their response to interrogatory No. 50. ,
Interrocatory No. 52 What date (sic) gathering efforts, if any, have you or your agents undertaken to identify individuals willing and i
)
{ capable of assisting handicapped persons in the Massachusetts EPZ in the event of a radiological emergency at Seabrook Station?
Aeolicants' Resoonse ,
Other than recruitment of ORO personnel for this purpose, no additional data gathering efforts have been undertaken.
Interroaator, No. 53 Describe any and all steps, if any, your (sic) or your agents have taken to have persons with handicaps, their families, and/or agencies serving or advocating for the handicapped rev,'ev the SPMC's plans and procedures for protecting persons with handicaps. Descrite the result of this review process and identify any and all communications and other documents you and your agenus have which concern this review process.
Aeolicants' Resoonse No such review process has been undertaken. ,
Interroaatory No. 54 Has the NHY ORO found an alternate location for the staging area apar: from the one at 145 water Street in Haverhill, MA? If so, identify the location selected.
Aeolicants' Rescoase ,
A simulated mock-up in Salem, New Hampshire was used in the June 28 - 29, 1988 Exercise, but NHY does not consider s this to be an alternate location.
t Interroaatory No. 55 t
Do you contend that in the event of a radiological l emergency at Seabrook Station, 145 water Street in Haverhill, <
Mass., will be made available to NHY's ORO for use as a i staging area? If zo, please describe who will have the legal authority to authorize use of this property as a staging area J
and cite the legal basis to support the conclusion that this person can lawfully authorize this use in that circumstance.
Aeolicants' Resconse Applicants object to this interrogatory to the extent that it seeks to peruse the legal files and work product of Applicants and their counsel and calls for legal conclusions.
Without waiving the foragoing objections, Applicants refer the Mass AG to the Order issued by the Land Court on October 31, 1988 and state that Applicants contend that 145 Water Street in Haverhill, Mass. will be available.
Interroaatory No._5,1 Identify the person in NHY's ORO who is most knowledgeable about the SPMC's plans and procedures for monitoring and decontaminating evacuees at the Reception Centers.
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 implemont the SPMC:
Monitoring / Decontamination Leaders.
Interroaatory No. 57 Where are the ORO's two (2) dedicated monitoring trailers for general public evacuees to be stored when they are not in use during a radiological emergency?
Acolicants' Respongs The Monitoring Trailers are parked at the Reception Centers.
1 Interrocatorv No. 58 What routes are the monitoring trailers to traverse to get to their respective reception center locations (provide maps or describe in detail)?
ADolicants' ResDonse Applicants incorporate herein their response to interrogatory No. 57.
Interroaatory No. 59 Have problem location along the routes traversed by the monitucing trailers been identified (e.g. difficult to negotiate corners)? If so, identify the locations, describe the problems, and describe what plan have (sic) been ?.ade to provide traffic control or other assistance at those locations?
Acolicants' Resconse Applicants incorporate herein their response to interrogatory No. 57.
Interrocatory No. (Q What vehicles are to move the monitoring trailers, and where are these vehicles stored? If they are to be supplied by a contracted provider, name this company (or companies) and state its address, contact person, and phone number.
l Applicants' Resoonse Applicants incorporate herein their response to interrogatory No. 57.
Interrocatory No. 61 Have the drivers who will be doponded upon to =cvo the trailers during a radiological emergency had training in i
driving the anticipated routes with the trailers in tow? If so, please describe. Have they driven practice runs over the entire routes with the monitoring trailers in tow? If so, on what day of the week and time of day were these practice runs conducted, and how long did each run take? Have alternate drivers been trained?
Acolicants' Resconse Applicants incorporate herein their response to interrogatory No. 57.
Interrocatory No. 62 What are the outer dimensions of the monitoring trailers? How much square footage of floor space does each provide inside?
Aeolicants' Response Outer dimension: 45' -
1" long x 8' - 0" wide x 13' high Interior square footage: 339.25 square feet Interrocatory No. 63 Describe in detail how NH"'s ORO proposes to monitor 8,300 evacuees within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> at each of these trailers.
What is the assumed monitoring time per individual? How does this compare to the actual time experienced during drills and exercises?
Aeolicants' Resoonse d
The SPMC at section 3.5.3 and IP 2.9 provides the details for monitoring evacuees.
The assumed monitoring time is 70 ceconds, which includes 60 second frisk plus 10 seconds for the individuals to step up to and away from the monitoring station.
Therefore 51 people per hour per station x 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> x 14 stations = 8568 people.
The actual monitoring experienced during drills and exercises was compared to the assumed monitoring time on two occasions. During a practice exercise, the average monitoring rate was 35 individuals per hour per station, which indicated that the actual time was longer than the assumed time. During the FEMA graded exercise, the average monitoring rate was 54.7 evacuees per hour per station, which indicates that the actual time was slightly shorter than the assumed time.
l Interrocatory No. 64 How many people does NHY's ORO assume could be decontaminated within a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period at each trailer? What is the assumed average time per decontamination shower? Is any accounting made in this assumption of some people needing to be showered a second or third time?
Aeolicants' Resconse No assumption has been made for the number of people who could be decontaminated within a 12-hour period at each trailer.
! The assumed showering time is lo minutes.
No.
Interrocatory No. 65 How many monitoring and decontamination personnel are to work inside each trailer? How many square feet is each of those individuals assumed to occupy? Describo (or provide a diagram)of the routing scheme for evacuees through the trailer that keeps the contaminated individtals adequately separated from those who are found to be uncontaminated.
[ Aeolicants' _Rgeconse l
The number of personnel working inside the trailers is l provided in IP 2.9 at steps 5.2.9 and 5.3.7.
I l
No assumption has been made.
The trailer flow paths are provided in IP 3.3 and IP 3.4.
Interroaatory No. 66 Where are nursing home residents, hospital patients, day care center children, jail inmates, those with mental / emotional impairments, and persons in other special facilities to be monitored and decontaminated? Describe in detail which personnel are to be responsible for handling each of these types of special facility evacuees and the facilities that will be employed in the task of monitoring and, if necessary, decontaminating them?
Aeolicants' Resoonso Individuals evacuated by ORO in vehicles other than ambulances are transported first to the designated Reception 1
l Centers for monitoring and, if necessary, decontamination.
The monitoring and decontamination activities are performed by the ORO personnel assigned to these Reception facilities in accordance with IP 2.9. For facilities descriptions see IP 3.4 and SPMC section 5.2.4. If decontatsination cannot be performed on any individual at the Reception; Center, for any 1
reason, they we,uld be directed to an MS-1 Hospital for processing. Applicants also incorporate herein their l
response to interrogatory No. 33.
( Interrocatory No. 67 What is the total number of emergency workers that could potentially require monitori7g and decontamination at the Emergency Worker Facility (EWF) (a) if NHY's ORO is authorized to implement the Plan and no State or local emergency responders are involved, (b)if the State and local responders are involved, but ORO personnel are not, and (c)if
both ORO personnel and State and local responders are involved n the emergency response (e.g., as when state troopers arrive in the middle of the emergency and replace ORO traffic guides).
Aeolicants' Resoonse l
a) Approximately 150 ORO personnel per shift return to the EWF for monitoring and decontamination, if
! needed.
i b) Applicants do not have the information requested.
c) See response (b).
Interrocatory No. 68 l
Where is the EWF trailer to be stored when . '.s not in use during a radiological emergency?
Aeolicants' Resoonse The trailer will be parked at the staging area in Haverhill, Massachusetts.
Interrocatory No. 69
, Along what route is the EWF trailer to be transported to
[ the staging area (provide a map or describe in detail)? Have problem locations along this route been identified (e.g.,
difficult to negotiate corners) and have plans been made to provide traffic control or other assistance at those
( locations?
Apolicants' Resoonse
[
Applicants incorporate herein their response to interrogatory No. 68.
Interrocatory No. 70 What vehicle is to be used to transport the EWF trailer?
Where in it stored when not in uso during a radiological emergency? If it is to be supplied by a contracted provider,
l name the company and state its address, contact person, and phone number.
Aeolicants' Response Applicants incorporate herein their response to interrogatory No. 68.
Interrocatory No. 71 1
1 Has the driver who will be depended upon to move the EWF trailer during a radiological emergency had training (sic) in driving the tow vehicle with the trailer? Has a practice run
- or runs been driven over the entire route with the trailer in l tow? Have any alternate drivers been trained?
l Applicants' Resoonse Applicants incorporate herein their response to interrogatory No. 68.
Interrocatory No. 72 Has an alternate location for the EWF been located in the event that the staging area in the City of Haverhill is not available?
Aeolicants' Resoonse A simulated mock-up in Salem, New Hampshire was used in the June 28 - 29 Exercise, but NHY does not consider this to be an alternate location.
Interrocatory No. 73 i
How many emergency workers (EWs) does NHY's ORO assume can be monitored at this EWF during a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period? What is the assumed monitoring time per EW? How does this compare to the actual monitoring times experienced during drills and exercises?
l
L Aeolicants' Response The NHY ORO makes no assumption regarding the number of emergency workers who can be monitored during a 12-hour period. The assumed monitoring time per IP 2.9 is about one minute per emergency worker. No drill or exercise data exist to compare the actual monitoring time at the EWF to the assumed monitoring time.
Interrocatory No. 74 What provisions have been made for monitoring and decontaminating the special needs individuals who are to be given special evacuation assistance from their homes?
Describe the facilities and personnel for these functions in detail.
Aeolicants' Response Special needs individuals not requiring medical assistance will be transported to the appropriate reception center for monitoring and decontamination. Those requiring l medical aseistance will be sent to an appropriate MS-1 Hospital. The facilitics and personnel are described in the SPMC section 5.2.4, IP ?.9, and TP 3.4. Applicants also incorporate herein their respor.se to interrogatory No. 33.
Interrocatory No. 75 Describe in detail the type and number of survey meters available at the monitoring trailers and the EWF trailers.
Describe the detection capabilities and ranges of each of those types of instruments.
f
(
r Acolicants' Resogngt
( Range or Number Per Number at Emergency Detection Monitoring Worker Eauinment Iygg Cacability Trailer Eaqility Bicron Fris-Tek Count Rate Meter 0-50K cpm 26 12 Aptoc-PT126B Geiger Mueller <5000dpm/100cm2 26 12 Tube RM-14 Count Rate Meter 0-50K cpm 2 2 HP-210 Geiger Mueller <5000dpm/100cm2 4 4 ,
E-140N Count Rate Meter 0-50K cpm 2 2 RO-2 Ion Chamber with 0-5000 mR/hr 0 1 Counter Interrocatorv No. 76 At each of these facilities, how are intractable contamination problems (e.g., internal contamination) to be dealt with? Who at each facility is to decido upon the .. ',' ,
appropriate course of treatment? What radiological health -
~
3 experts ar (sic) to be consulted in arriving at appropriate ..
treatment choices under Mode 1, Mode 2 and "mixed mode" i scenarios?
Aeolicants' Resoonse Individuals having contamination which cannot be removed [ 1' '
'1 2 after three decontamination attempts or suspected of having ,
1 internal contamination are entered into a Radiological l Screening Program in accordance with IP 2.9, Steps 5.2.16 and 5.3.12.
The Radiological Health Advisor determines actions required in accordance with IP 2.8, Step 5.1.5.
S w--.....- . . .
r i
Radiological Health Advisor will consult with
( radiological health experts available at the time of an emergency in accor-lance with IP 2.8.
Interrocatory No. 77 Describe in detail the provisions for appropriately packaging and storing contaminated (sic) articles at the monitoring trailers. How is one individual to guard the articles belonging, potentially, to thousands of evacuees?
How are these articles to be disposed of ultimately? What contracts are currently in effect with waste disposal companies (identify the companies.)
ADolicants' Resoonse Applicants incorporate herein their responses to interrogatories No. 26 and 27 to Mass AG's First Set of Interrogatories to Applicants on the SPMC. See also IP 2.9 at step 5.5.3.
One individual assigned to guard articles is adequate
- because the access to the area where these articles would be stored is controlled.
I If articles c m be decontaminated in accordance with IP 2.9 stop 5.5.3, they will be returned to the owners. If not, they will be handled as contaminated waste.
Interrocatory No. 78 What plans does the ORO have for either pumping out or replacing the storage tanks for waste water at each of the l monitoring trailers and the EWF? Where is the water in the tanks ultimately to be disposed? What person or entity will bear the ultimate responsibility for disposal of this waste water?
l L
Aeolicants' Resoonse Applicants incorporate herein their response to interrogatory No. 27 of Mass AG's First Sist of Interroga-tories to Applicants on the SPMC.
Interroaatorv No. 79 Have the estimated timei ~ traversing each of the bus routes in the six (6) Massachusrt .ts communities been calculated? If so, please list chese estimates (or provide documents which contain them.)
Acolicants' Response Yes. See SPMC, IT T.10, Atte.nhment 9, Transfer Point Dispatching Form.
t Interroaatory No._12
, Has any effort bTen made to calculate the additional radiation dosages that would likely be received by those _
transit-dependent ind,'viduals who would have to stand outside .-
along bus route awaif'ig transport over the dose absorbed by the rest of the popuietion? If so, how has this information ,,~ , ~
I been factored into protective action decision-making?
Acolicants' Response No.
Interroaato ry_fio . 81 During inclement weather conditions such as severe <
winter storms, is there an alternate plan for assisting the transit-dependent population?
Acolicants' Responan ,
The viability of conducting an evacuation for the ,
general population (including transit dependent) under severe -
weather conditions is considered in the Protective Action Recommendation process. See SPMC, IP 2.5.
1 5
Interrocatory No. 82 How are transit-dependent evacuees to be located along the roadways if the evacuation takes place during the night?
Aeolicants' Resoonse All vehicles employed for this task have headlights. In addition, the Route Guide would assist the driver in locating evacuees along the road way.
Interrocatory No. 83 What consideration, if any, has been given to the hardship older citizens would have to endure in waiting outdoor; in inclement weather and the potential adverse I impact on their health in so doing?
Aeolicants' Response t
In order to minimize outdoor waiting times for any individual bus route starting times are provided in the EBS messages.
) Interrocatory No. 81 Provide a matched listing of each special facility in the Massachusetts portion of the EPZ (and its population)with its host facility showing the capacity of the host facility to accept each category of evacuees.
Applicants' Respongg Soo SPMC, Appendix M.
Interrocatory No. 85 Detail which specific personnel are to be relied upon for loading nursing home residents and hospital patientr. onto emergency vehicles.
4
) 41
l Acolicants' Resoonse The SPMC assumes that CRO personnel will be assisted by i facility staff as they carry out their professional duties and responsibilities with regard to the protection of persons under their care.
Interroaatory No. 86 i
What specific plans exist for the integration and deployment of federal monitoring and assessment personnel?
Acolicants' Resoonse The Federal Radiological Emergency Response Plan (50 FR 46541) and SPMC, Section 3.3 and IP 1.1.
ID.1;.9 rroaatory No. 87 Please identify by name and position those 01.0 personnel
} whose responsibility it is to request federal monitoring and assessment assistance.
I (a) Identify what procedures, if any, these personnel would consult or refer to in making such request (s).
(b) Pleasn describe the relationship that presently exists between ORO and the Department of Enet'gy
(c) Please identify and describe the substance of any l communications running between ORO, the DOE and the NRC from September 1, 1987 to the present concerning such federal assistance.
Anolicants' Response
)
l Assistant Offsite Responsq Director - Support Liaison.
See SPHO, Appendix H at page M-3 for names of persons filling this position.
a) Section 2.3 of the SPMC and Implementing Procedure 1.1 NHY Of fsite Response Director / Assistant, b) Contacts between the NHY ORO and the NRC are conducted through the Seabrook Station Emergency Response Organization (ERO).
Contacts between NHY ORO and the Department of Energy b (DOE) are through the Radiological Health Technical 4
Advisor in the New Hampshire State EOC.
c) There have been no such communications.
Interrocatory No. 38
{
Please identify the specific locations, if any, within i the Massachusetts EPZ which have been identified as possible j~..
l or probable monitoring locations.
~
Aonlicants' Resconse No specific monitoring locations have been identified.
Interrocatory No. 8% ,
With reference to the following docurent Egidance on
) Offsite Emercency Radiation Measurement Systems Phase 1 -
Airborne Release, FEMA REP-2, Rev. 1, July 1987 please provide the following information:
(a) What provisions exist for the deployment of trained /
emergency monitoring personnel at relocation centers in host areas for monitoring all arriving evacuees known to have been exposed to high levels of radiation as described at i 6.42?
(b) Does ORO have adequate monitoring resources to maintain deployed survey terms (sic) in the plume d
43
EPZ for a minimum of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> as set forth in 5 6.5? If the SPMC is relying on either federal or state assistance to be available before that time please indicato:
(1) whether the assistance relied upon is federal and/or state; (2) from what physical locations the governmental assistance is expected to originate from; (3) the response time from notification to arrival for such governmental assistance; and ,
(4) the bases for the answers to (1) -
(3) above.
1 (c) Does the manpower for the ORO survey teams come from within a radius of approximately 20 miles from the reactor site as recommended in 5 6.5? Are onsite reactor facility staff relied upon for such manpower? If not, why not?
(d) Please identify and describe survey team deployment 4 plans as described in 5 6.6 created for the - -
Massachusetts EPZ. Please indicate the constraints identified in 5 6.6 which were recognized in '
creating these plans. .
(e) Please describe what procedures exist to insure . )k that field monitoring will be concentrated at the edges of evacuated areas to ensure that the evacuated area is large enough as described in 5 What effort has been made to identify f ,
6.6. ,
possible monitoring locations at the edges of those areas in the Massachusetts EPZ which the ORO would or could recommend be evacuated in accordance with the SPMC?
(f) Has any planning been done to accomplish simultaneous monitoring at presolected monitoring ,
points as described in 5 6.6.7? ,
(g) Please identify and describe any logistics plans as described in 5 6.8 created for the Massachusetts EPZ.
(h) Does the ORO have sufficient monitoring equipment defined as the amount required to provide the needed measurements for any set of release and b
meteorology variations? What amount of monitoring
- is sufficient in light of the geography and f meteorology of the Seabrook site?
f Aeolicants' Resoonse f (a) As por SPMC at page 2.1-11, the -
i
) Monitoring / Decontamination Personnel report directly to the reception centers upon notification.
)
(b) Yes. The SPMC does not rely on either federal or state o
assistance for field surveys.
(c) Some of the manpower support for the ORO survey teams I comes from within a 20 mile radius. Some Seabrook Station employees, who do not have a role in the onsite emergency response organization have been recruited as members of Field Monitoring Teams.
{
(d) Field Monitoring Team survey strategies are developed
) based on the constraints identified in IP 2.3.
(e) Field Monitoring as conducted by NHY ORO's Field -
Monitoring Teams in described in the SPMC at Sectior 1.3 and IP 2.3. Consideration for assigning monitoring ,
locations to the Field Monitoring Teams are provided in
~
IP 2.3 at step 5.1.2.
(f) No. There are no pre-selected monitoring points.
1 (g)
Logistic plans include pre-positioning of equipment at .
the Staging Area and availability of back-up personnel. -
(h) Yes. A minimum of two teams.
b
Interrocatory No. 90 Please identify for each of the following types of equipment: (1) the number available, (2) the present location, (3) the maintenance performed during the last 12 months and (4) the current calibration if applicable:
j (a) portable radiation monitoring instruments; ,, .
air samplers; *
(b)
(c) dose rate meters; (d) beta / gamma survey meters; and -
(e) dual channel analyzers. )
Acolicants' Resoonse The numbers and locations, by facility, of the equipment are provided in the SPMC, Appendix I.
The last calibration date and maintenance records will be made available for review pursuant to the Mass AG's Request for Production of Documents. -
Interrocatory No. 91 '
'~
Describe the circumstances that would or could occasion .'
the shift to real-time radiological monitoring for purposes of generating protective action recommendations. Please identify by name and position the ORO official who would make .-
this decision. What procedures, if any, would this official '
consult or refer to in making this decision.
Acolicants' Response 49, The circumstances are described in the SPMC at page 3.4-
)
- 4. The individuals who would make this decision are the Radiological Health Advisor and the Accident Assessment Coordinator, who follow IP 1,2, 1.12, 2.2, 2.3 and 2.5. ,
a Interrocatory No. 92
/
How uany field monitoring teams are available under the control of: -
(a) the state of New Hampshire;
- (b) the ORO; and (c) the licensee pursuant to the Seabrook Station e, Radiological Response Plan?
Aeolicants' Response Field monitoring teams are available in the following quantities:
i State of New Hampshire: 3 por 12-hour shift.
a) b) The ORO: 2 por 12-hour shift.
c) The licensee pursuant to the Seabrook Station Radiological Response Plan: 3 per 12-hour shift.
Interrocatory No. 93 I How will the activities of the various field monitoring teams identified in the immediately preceding interrogatory be coordinated? Who is responsible for such coordination?
Acolicants' Resoonse ,
The activities of the field teams are coordinated at the EOF as described in the SPMC (section 3.3 at pago 3.3-10, IP 4
2.3 at steps 5.1.2.D and 5.2.2, and Appendix C at Utility Agreement 2). The personnel responsible for the coordination are the Accident Assessment Coordinator and/or the Field Team Dispatcher for the NHY Offsite Response Organization, the IFO 1
Monitoring Team Coordinator for the State of New Hampshiro, ,
and the Seabrook Station Offsite Monitoring Team Coordinator. -
2
l Interrocatory No. 94 What factors led to the determination to provide 2 field monitoring teams in the SPMC?
Acolicants' Response h The SPMC provides two Field Monitoring Teams because two teams provide a sufficient number of field surveys and air I samples to support the confirmation of or adjustment to dose projections and PAR development. Further, this number of teams is consistent with the number used by the Commonwealth of Massachusetts and the NIAT.
Interrocatory No. 95 Are the field monitoring teams described in the SPMC mobile? If the answer is yes, please identify what vehicles are available for use by these teams and where these vehicles are stored.
Acolicants' Response 4
Yes. The Field Monitoring Teams would use personal vehicles.
Interrocatory No. 96 Have any estimates been made as to the time needed from the decision to deploy the field monitoring teams to the communication of actual field-data to the appropriate
' personnel? If yes, what are those estimates?
Acolicants' Response No.
Interrocatory No. 97 Please describe and provide the dates of all drills conducted with ORO field monitoring teams.
L (a) Please indicate which of these drills, if any, involved hands-on practice with monitoring equipment.
(b) Please indicate which of these drills, if any, involved physical deployment of these teams. Where were the teams sent?
Aeolicants' Resconne 1
l The following is a list of all drills conducted with ORO l field monitoring teams:
1987 Rad Monitoring / Health Physics Walkthrough 12/07/87 Rad Monitoring / Health Physics Drill 12/09/87 Rad Monitoring / Health Physics Drill 12/10/87 1988 88-03-035CF Combined Functional 88-03 04/29/88 88-03-036CF Combined Functional 88-04 05/24/88 88-03-045DR Dress Rehearsal 06/10/88 88-03-037EX Graded Exercise 06/28/88 88-03-047CD Radiological Monitoring 10/19/88 The basis scope facilities for Field Monitoring Teams during each of the drills listed above was as follows:
Field Team members reported to their emergency facility Team members performed field kit inventories -
Team members were briefed on postulated emergency conditions Teams were deployed to actual locations with instructions on monitoring to be performed Teams performed monitoring techniques in the field with radiation and radioactive contamination '
detection equipment Teams demonstrated radio communications Teamn demoristrated contamination control practices
- Teams demonstrated documentation practices Teams demonstrated return / personal monitoring / debriefing at conclusion.
(a) Every drill and walkthrough listed above involved "hands-on" gas of monitoring equipment.
( -
ha...
)
(b) Field teams were physically deployed to various locations within the Massachucetts Plume EPZ in each of the drills and the walkthrough.
Interrocatorv No. 98 Please identify the locations of work and residence for those ORO personnel identified as field monitoring teams.
Have any estimates been made concerning the time needed for I these personnel to be mobilized in the event of an emergency?
What are those estimates?
Acolicants' Response Applicants object to this interrogatory to the extent l that it seeks home addresses. The individuals' interests i; the privncy of this information are real and substantial.
Without waiving the foregoing objection, Applicants respond as follows:
(REDACTED)
Interroaatory No. 99 a Please describe the primary means of communication ,
l linking the ORO field-monitoring teams with:
4 (a) each othert ,
l (b) monitoring teams from the State of New Hampshire; -
l (c) federal monitoring teams; (d) monitoring teams provided by the Commonwealth; and (e) the ORO EOC.
Aeolicants' Resoonan (a) The ORO Field Monitoring Teams can communicate with each other using their radios. If necessary, information can
1
~
be relayed from one team to another by an Emergency Response Organization Communicator at the EOF.
(b) The ORO Field Monitoring Teams operate on the same radio channel as the NHDPH monitoring teams. Communication i with the NHDPH teams can be direct or information can be relayed via the ERO Communicator at the EOF.
(c) Federal monitoring teams have their own
. =
communications capabilities, which are separate from the ORO teams. Information from the federal teams to the ORO teams must be relayed from the Federal Radiological Monitoring and Assessment Center to the ORO EOC to the ORO teams.
(d) Monitoring Teams sont by the Commonwealth of Massachusetts can be issued radios at the EOF. These radios e will allow the NIAT/MDPH teams to operate on tha same channels as the ORO Field Monitoring Teams, EOF and NH teams.
(e) vdo Field Monitoring Teams communicate via radio with the ERO Communicator in the EOF, who relays all information from these teams to the NHY ORO Field Team Dispatcher. The Field Team Dispatcher provides all data from the Field Monitoring Teams to the Accident Assessment Coordinator in the NHY EOC.
Interrocatory No. 100 What planning has been done to ensure that federal or state monitoring assistance teams are able to communicate data to the ORO EOC? -
/
l Acolicants' Resoonse Data from State monitoring teams are communicated the ORO EOC through several means.
- 1. The SPMC at Figure 5.2-2 shows a room with telephones ,
and radio is reserved for Massachusetts officials.
- 2. Field kits and radios are available for NIAT/MDPH field teams at the EOF. The radios operate on the same frequency as the radios used by the ORO, Ssabrook Station and New Hampshire field teams. 4
- 3. The SPMC provides three Massachusetts State Liaisons who e
report to the Massachusetts EOC, Area I EOC and MDPH, and can relay field data collected by Massachusetts field teams to the EOC.
- 4. The Assistant Offsite Response Director, Support Liaison, provides a communication link between the ORO and State organizations.
Data from Federal monitoring teams are communicated primarily to the ORO EOC through two means.
- 1. The Assistant Offsite Response Director, Support Liaison, provides a communication link between the ORO and Federal organizations through FEMA. Data collected by Federal field teams can reach the ORO EOC through the gg FEMA-ORO interface.
~52-
L
)
f Interroaatory No. 101 Has any time study for implementing a sheltering PAR
{ been done:
(a) for any sector or sectors of the Massachusetts EPZ; or (b) for any portion or portions of the Massachusetts EPZ population? ,
Applicants' Response (a) No.
(b) No.
Interroaatory No. 102 Has any study been conducted to determine the shelter protection factor of dwellings outside the beach areas e~ the Massachusetts EPZ?
Aeolicants' Response l No.
Interroaatory No. 103 On what basis was a 0.9 dose reduction factor assumed in determining the relative benefits to be assigned to a sheltering protective action recommendation?
Acolicants' Resoonse A dose reduction factor of 0.9 is based upon the value assigned to a wood frame house with no basement.
Interrocatory No. 104 In calculating projected dose to the population as a result of evacuation in comparison with sheltering or any other alternative protective action what portion of the projected dose was the result of groundshine, including radioactive material on the skin of those evacuating ab vell as in the automobiles in which they are evacuating?
Acolicants' Response ,
None.
Interroaatory No. 105 ,
Please identify and describe all studies or analyses the purpose of which was to compare the projected dose to the population in the event of an accident at Seabrook Station assuming different protective action recommendations were made and followed.
Acolicants' Resoonse Applicants object to this interrogatory on the grounds that it seeks information not releva.2 to the subject matter of this proceeding, i.e., the admitted contentions on the SPMC. The Board has excluded litigation of comparisons of projected dose savings. N.H. Hearings 11/16/87 Tr. 5608-09, 11/18/87 Tr. 5961.
Interrocatorv No. 106 Please identify and describe any studies or analyses ~
conducted since September 1987 the purpose of which was to estimate the air exchange rate for dwellings in the ..
Massachusetts EPZ. What air exchange rate has been assumed for the dwellings in the Massachusetts EPZ?
l Aeolicants' Response l
l There have been no special studies or analyses conducted since September 1987 to estimate air exchange rate for dwellings in the Massachusetts EPZ.
Two exchanges por hour.
Interrocatory No. 107 Please identify and describe any efforts made for the Massachusetts EPZ to identify those specific Treas in which
\
the sheltering protection afforded by the existing housing stock is higher than .9.
Acolicants' Resoonse See Stone hobster Shelter Study, dated Augtst, 1987.
Interroaatory No. 108 l
- Please describe the consideration, if any, given to a l protective action that combines sheltering with rapid identification af te r plume passage of"hot spots"and relocation as described in NUREG-1210.
(a) If this strategy has not been adopted for the Massachusetts EPZ please explain the basis i~or this decision.
(b) Please identify and describe any studies or analyses referred to or consulted in answering (a) -
above.
(c) If this strategy has not been rejected and/or is considered a viable available option open to ORO to recommend for portions of the Massachusetts EPZ, please describe what procedures and what equipment and personnel exist for its implementation.
Aeolicants' Rosconse a) No consideration is given to any material described in NUREG-1210 since as stated in the document preface l
"(T]hese materials do n21 provide guidance or license requirements for NRC licenseos" (emphasis in original).
Instead, the strategy developed is based on EPA ,
relocation guidance. EPA (520/1-75-001) Chapter 7, Draft #4194c 6/3/86.
b) None.
c) Equipment and pr,rsonr91 requirements are contained in
- c. ,
W c
i l
l l
l l Sections 3.3.2 and 3.3.4 of the SPMC, IPs 2.2, 2.4 and I
l 2.5.
l Interrocatory No. 109 Please identify the sources of meteorological '
information on which ORO intends to rely during a radiological emergency at Se.tbrook.
Aeolicante' Resocnse The sources of meteorological information on which ORO relies are the Seabrook Station meteorological tower and Weather Services International (WSI). Weather conditions and information are also available from field workers.
Interrocetory No. 110 For each source of information identified in the immediately preceding interrogatory please describe the communication link between ORO and that source.
Aeolicants' Rosconse Information from the Seabrook Station meteorologic instrument tower is input directly into the Main Plant l
l computer System. This information is available at the MPCS terminal at the Seabrook Station EOF. At the EOF, the information is entered on the METPAC Input Data Logs (ER 5.3) 1 which, in addition to the actual METPAC printout sheets, are ..
l periodically (i.e., at 15 minuto intervals) distributed to ,
ORO accident assessment staff by the Dose Assessment Specialist (ERO).
Information from Weather Services International is ,
obtained via modem or commercial tolophcne service. Weather r m -
, a 0*
b conditions and information are also available from field workers.
l Interrocatory No. 111 Please identify and describe any studies and analyses y' concerning seabrook site meteorology.
Aeolicants' Resconse Applicants object to this interrogatory on the ground that the information it seeks goes to matters that should
~
properly be before the onsite Board.
Interrocatory No. 112 What assumptions have been made concerning the frequency of wind-shifts within 2 miles of the Seabrook plant? Within 5 miles? What is the basis for these assunptions?
Aeolicants' Resoonso None. *
- 3. Motion for Protectivo Order ,,
Applicants move that this Board enter a protective order .
that the discovery objected to in the above responses not be , ..
had. ,
1
- O i
g b
o l
b
~
0
- "tev or'sa 19: 32 r+w.E-PGt< p.2 Do to Cnswerst
-. ( et Y George S( Thomas Vice President, Nuclear Production, New Hampshire Yankee Division of Public Service Company of New Hampshire 9evcaber 1, 1988 tnto cf New Hampshire Skingham County, ss Then appeared before me the above-subscribed George S.
ThCT O and made oath that he is the Vice President, Nuclear PrCdustion of New Hampshire Yanxee utvision, Aut.horised to
- x cute the foregoing answers to interrogatories on behalf of the Applicants, that he made inquiry and believes that the foregoing answ ra accurately set forth information as is available to the Applicants. .
Before me, A J ^
My :ommission Ex'p ires: s ,
etAma n Muse 0MuR.Nuesy peas-1s. t0 cbjeetions ter ommunseen meses peanmer 4 less, .-
{
. The aa G. Dignan, Jr.
Georile H. Lavald Kathryn A. selleck Jeffrey Penfield Trout Jay Bradford Smith l
Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 l
i
! Nt m rt-l 1 der l
'88 W/ -8 P4 :47 ;
CERTIFICATE OF SERVICE
.; M t: -
I, Kathryn A. Selleck, one of the attorneys [for,the ,
Applicants herein, hereby certify that on November 1, 1988, I made service of the within document by depositing copies thereof with Federal Express, prepaid, for del'$very to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):
Administrative Judge Ivan W. Smith Robert Carrigg, Chairman r Chairman, Atomic Safety and Board of Selectmen l Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue ,
Commission North Hampton, NH 03862 ,- t East West Towers Building
. 4350 East West Highway :
! Bethesda, MD 20814 l
Judge Gustave A. Linenberger Diana Curran, Esquire l Atomic Safety and Licensing Andrea C. Ferster, Esquire Board Panel Harmon & Weiss , ,
U.S. Nuclear Regulatory Suite 430 Commission 2001 S Street, N.W.
East West Towers Building Washington, DC 20e09 4350 East West Highway i 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 20fel4 Adjudicatory File Sherwin E. Turk, Esquire ,
Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory
- i U.S. Nuclear Regulatory Commission Commission L East West Towers Building One White Flint North, 15th Fl. l 4350 East West Highway 11555 Rockville Pike ;
Bethesda, MD 20814 Rockville, MD 20852 t
- Atomic Safety and Licensing Robert A. Backus, Esquire
- Appeal Board Panel 116 Lowell Street l' U.S. Nuclear Regulatory P. O. Box 516 Commission Manchester, NH 03105 !
Washington, DC 20555 f
I l
Philip Ahrens, Esquire Mr. J . P. Nadeau Assistant Attorney General Selectman's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 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 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. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 507 Kopelman & Paige, P.C.
Concord, NH 03301 77 Franklin Street (Attn Herb Boynton) Boston, MA 02110 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 l 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. Holmes, Esquire Richard A. Hampe, Esquire Holrds & Ells Hampe and McNicholas i 47 Winnacunnet Road 35 Pleasant Street !
Hampton, NH 03841 Concord, NH 03301 l
Mr. Richard R. Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street, 2nd Floor Agency Newburyport, MA 01950 Federal Regional Center 130 228th Street, S.W.
Bothell, Washington 98021-9796 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 Commissioa 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. Carper,ter, Alternate Technical Member Atomic Safety and Licensing Board Panel -
U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Kath(yn A. Selleck
(*= Ordinary U.S. First Class Mail) 4 9