ML20205T444

Affidavit of Fh Anderson Re South Hampton Contention 8, New England Coalition on Nuclear Pollution Contention 4 & Seacoast Anti-Pollution League Contentions 18 & 25 Re Offsite Emergency Planning.Certificate of Svc Encl

ML20205T444
Person / Time
Site:	Seabrook
Issue date:	06/06/1986
From:	Anderson F AFFILIATION NOT ASSIGNED, IDEAS & INFORMATION, INC., INTERNATIONAL DATA CORP.
To:
Shared Package
ML20205T415	List: ML20205T411 ML20205T424 ML20205T429 ML20205T444
References
82-471-02-OL, 82-471-2-OL, OL, NUDOCS 8606130213
Download: ML20205T444 (4)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION /

[ I f?ff' (9, ATOMIC SAFETY AND LICENSING BOARD f

r Before Administrative Judge!

Helen F. Hoyt, Chairperson

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Emmeth A. Luabke Jerry Harbour

• W ',to 6'ITTY In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY ) (ASLB No. 82-471-02-OL) 0F NEW H MPSHIRE, et al. ) (Offsite Emergency

) Planning)

(Seabrook Station, Units 1 and 2 ) June 6, 1986 i

l l AFFIDAVIT OF FREDERICK H. ANDERSON, JR.

l (CONTENTION SOUTH HAMPTON-8, NECP CONTENTION NHLP-4, AND CONTENTIONS SAPL 18 AND 25 i

i I, FREDERICK H. ANDERSON, JR., being on oath, depose and say -

as follows:

1. I am President of Ideas + Information, Inc. (Exeter, NH) and Director of International Services at International Data Corporation (Framingham, MA).

2. I have had 20 years experience in the design and implementation of questionnaires for personal interviews, telephone interviews, and mail surveys.

3. I have reviewed the affidavit of Richard H. Strome of the New Ba:npshire Civil Defense Agency (NHCDA) as well as the the original questionnaire referred to the Motion by Public Service Company of New Hampshire (the Applicant) for dismissal of the contentions listed above. I have also intervied officials of Exeter & Hampton Electric Company, a utility which provided the  ;

majority of names used in the survey conducted by NHCDA.

8606130213 860609 PDR ADOCK 05000443 g PDR wd; z,- Y. f

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4. Mr. Strome states that the questionnaire was mailed to 33,812

" households." Given that those receiving the questionnaire were those paying bills to Exeter & Hampton Electric or Public Service Company, there is no indication that "special needs" persons living in apartments or those staying on motels would have been identified by the survey.

5. Given that many of those owning property within the EPZ may not have been living within the EPZ at the time the survey was sent (the last two weeks of March, 1986) becuase of the seasonal nature of many of the residences involved, there is no indication that "special needs" persons living in those dwellings were identified.

6. Potential respondents were not given sufficient motivation to respond to the survey. They were not told "if you don't respond you will not be able to be evacuated in the event of an accident at Seabrook." The questionnaire instead referred to an unknown

" emergency" and a response was requested "so we can plan ahead."

7. The NHCDA has not indicated the accuracy of the "special directions" information provided by respondents, or tested this information at least on a sampling basis.

8. The questionnaire design was such that there was no way to determine overlapping in responses to the questions which tried to determine the " number of people" with various types of special needs.

9. The question of those who "need a ride during an emergency"  !

again would have to be specific in terms of the nature of the emergency, the likely month, day of the week, and time of the emergency, in order to truly measure this need.

10. The question on those who "need notification in addition to the l

siren system, because of hearing impairment" asks the respondent to speculate because as of this date the siran system has not h been audibly tested.

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11. The question on "need special help because of other health conditions" is ambiguous because of the lack of definition of special help." To some this may have meant "need an j ambulance," and those who made this assumption may not have also checked the " ambulance" box below the question.

12. Because the questionnaire was apparently only in English, it would probably not have caused a response from those within the EPZ who only read French, Spanish, or other languages or do not read at all.

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13. Because of the methodology (mail survey) the questionnaire would not have identified the "special needs" of the thousands of transients in the area, many of whom may have the needs specified in the questionnaire (lack of transportation, hearing impairment, other health condition, inability to understand English).

14. Apparently only one questionnaire was ever sent to the lists used by NHCDA. Even multiple mailings (say one a month) would not locate all special needs people, but a single mailing is very unlikely to locate even a majority of these people.

15. Based on the foregoing, it is my opinion that there does not exist reasonable assurance that "special needs" persons in the Seabrook Plume Exposure EPZ can and will be identified.

Frederick H. Anderson, Jr.

STATE OF NEW HAMPSHIRE ROCKINGHAM, SS. June 6, 1986 The above-subscribed Frederick H. Anderson, Jr. appeared before me and mde oath that he had read the foregoing affidavit and that the statements j set forth therein are true to the best of his knowledge.

j Before me, i

} ~L .%,L s O,f NotaryTPublic l 7 My Commission Expites BENJAMIN J. D;4GOST!NO, JR., NOT/.RY PUBUC MY COMMISSION EXPERES AUGUST 3,1989 i

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. CERTIFICATE OF SERVICE AND SERVICE LIST Jose Asst.Gn.Cnsl. Helen Hoyt. Chm.

• Thomas Dignan, Esq.*

Fcd. ph Flynndgmt.

Emerg. Agcy. Admn. Judge Ropes & Gray 500 C.St. So. West Atomic Safety & Lic Brd. 225 Franklin St.

Washington, DC 20472 USNRC Boston, MA 02110 Washington, DC 20555 Office of Selectmen Dr. Jerry Harbour

• Docketing & Serv. Sec.

• Town of Hainpton Falls Admin. Judge Office of the Secretary Hampton Falls, NH 03844 Atomic Safety & Lic Brd. USNRC USNRC Washington, DC 20555 Washington, DC 20555

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• Dr. Emmeth A. Luebke

• Jane Doughty Office of Exec. Legl. Dr. Admin Judge SAPL USNRC Atomic Safety & Lic. Brd* 5 Market Street Wahsington, DC 20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq. Paul McEachern, Esq. George Dana Bisbee, Esq.

Asst. Atty. General Matthew Brock, Esq. Attorney General's OFF.

State House, Sta. #6 25 Maplemod Ave. State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsnouth, MI 03801 Carol Sneider, Esq. , Asst. AG Diane Curran, Esq. William S. Lord One Ashburton Place, Harmon, Weiss Board of Selectmen 19th Flocr 20001 S Street NW Suite 430 Tom Hall-Friend St.

Boston, MA 02108 Washington, DC 20009 Amesbury, MA 01913 Richard A. Hampe, Esq. , Maynard Young, Chainmn Sandra Gauvutis New Hampshire Civil Defense Board of Selectmen Town of Kingston =

Agency 10 Central Road Box 1154 Hanpe & McNicholas Rye, MI 03870 East Kensington, NH 03827 3 35 Pleasant St.

Concord, MI 03301 Edward Thomas

• Mr. Robert Harrison i FEMA Pres & Chief Exec. Officer 442 J.W. McCormack (POCH) PSCO Boston, MA 02109 P.O. Box 330 Manchester, NH 03105 l Roberta Pevear l State Rep.-Town of Hangt Falls Drinkwater Road Hanpton Falls, NH 03844 l

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