ML20206M349
| ML20206M349 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/14/1987 |
| From: | Strome R NEW HAMPSHIRE, STATE OF |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| References | |
| CON-#287-3119 OL, NUDOCS 8704200091 | |
| Download: ML20206M349 (14) | |
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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 17 ART 15 P3:14 Before the Nuclear Regulatory Commission OfflCE 0r huh fan y 00CKETit.G & M?vlCL BRANCH
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In the Matter of
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Docket Nos. 50-443-OL e
)
and PUBLIC SERVICE COMPANY OF
)
50-444-OL NEW HAMPSHIRE
)
(Off-Site Emergency (Seabrook Station, Units 1 and 2
)
Planning Issues)
)
THE STATE OF NEW HAMPSHIRE'S RESPONSE TO NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S SECOND SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO STATE OF NEW HAMPSHIRE ON REVISION 2 TO THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY-RESPONSE PLAN The State of New Hampshire maintains that it is not obligated to respond to discovery requests on the New Hampshire Radiological Emergency Response Plan (NHRERP) because it filed no contentions on the NHRERP and does not intend to present evidence during this phase of the licensing proceeding.
Notwithstanding this continuing objection, the State does not object to providing responses voluntarily to NECNP's second discovery request on the NHRERP.1 1This was the position stated by the undersigned counsel during the April 3, 1987 telephone conference on NECNP's Motion for Leave to File a Second Set of Interrogatories.
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Interrogatory No. 1 In response to Hampton's First Set of Interrogatories on Revision 2, Interrogatory 2(1), you state that " drivers serving students with special needs, the disabled, or the medically impaired are expected to be capable of providing services to these individuals based upon previous training or related work experience."
Please describe the nature of the " previous training" referred to in this answer, and when this training took place.
Please describe the types of related work experience that are considered to demonstrate capability.
Does the state consider related work experience to be an adequate substitute for training?
Response
The State of New Hampshire is confident that drivers provided by.
transportation companies who are responsible on a day to day basis for the safe and efficient operation of those vehicles will be able to provide the same type of service in the event of an emergency.
Those drivers from state agencies, Teamsters Local 633 and other services who provide a supplementary pool of drivers are also by virtue of their day to day experience on the job, capable of providing safe and efficient transportation service.
It is the State's position that persons holding a current valid light commercial, commercial or commercial tractor trailer license are capable of performing the services required to drive a bus or similar vehicle in the event of an emergency.
The State considers "related work experience" and " common sense" adequate bases for emergency I
response.
By adding training, the quality of emergency response can f
be further enhanced.
The NHRERP provides such a training program.
i e
m Interrogatory No. 2 With respect to Interrogatory 1 above, do training and related work experience include expertise with transporting physically handicapped individuals in buses, including carrying individuals and manipulating wheelchair hookups?
Response
Each bus company and/or school unit provides training to bus drivers.
During that training those drivers that would be providing services to handicapped children are given training to ensure proper handling of these students.
It is the driver's prime responsibility to drive the vehicle.
If special consideration needs to be given to the loading of a vehicle, support personnel are provided for this purpose.
For example, when loading a bus at a nursing home the staff of the nursing home would be available and trained to configure and load the bus.
When loading special needs individuals who may be at home, a team of trained emergency response personnel would travel with the bus to configure it and to assist in loading the special needs individuals.
If buses tasked with bus route pickup encounter any " handicapped in'dividuals" who have decided to ride a bus but who have not previously made their special needs known, it is likely that they will be able to advise the bus driver, other emergency response personnel, or even other passengers on the bus what assistance they might need in boarding the bus.
They would also likely be familiar with the operation of equipment needed to assist them.
e
. t Interrogatory No. 3 Please describe the State's means, if any, for verifying whether bus drivers identified in response to Interrogatory 2 have had previous training or related work experience.
Response
The State has no means of verifying previous training or work experiences.
Training is, or will be, provided to sufficient drivers for the number of buses needed to support a potential evacuation.
Interrogatory No. 4 In answer to Hampton 2(1), you state that sufficient EMS personnel will be available to assist normal route drivers, or members of the Teamsters Union, who do not have direct training for handling disabled or medically impaired persons.
How many EMS personnel are available?
For each EMS person, it is his or her exclusive responsibility to assist bus drivers, or does that individual have other responsibilities such as driving ambulances or assisting ambulance drivers?
Response
There are approximately 500 trained EMS personnel in State EMS Region III.
Approximately 380 of these would be available to provide assistance in loading buses.
After loading buses, these individuals would be part of the manpower resource pool which would be available to provide services other than driving ambulances or assisting ambulance drivers.
Interrogatory No. 5 please identify all bus drivers who have been trained for an emergency response during a radiological accident at Seabrook.
o
Response
Individual names of bus drivers who have been trained for an emergency response during a radiological emergency at Seabrook are kept in a training files at the offices of the New Hampshire Civil Defense Agency.
The following information is submitted by type of individual trained as of April 1, 1987.
A)
State Department of Transportation Personnel 126 B)
Bus Transportation Company Personnel 204 C)
Other Transportation Providers 19 TOTAL Trained to Date 349 Interrogatory No. 6 Please provide the date on which each bus driver was trained, and identify the individual who was responsible for training on that date.
Response
The following information is submitted showing training statistics that correspond to #5 above.
Number Date Trained Type of Personnel Instructors 01/20/86 23 bus transportation Vonwald/Coogan 01/21/86 24 bus transportation Vonwald/Coogan 02/07/86 14 bus transportation Vonwald/Coogan 02/18/86 33 bus transportation Vonwald 03/18/86 14 bus transportation Vonwald 03/06/86 18 bus transportation Vonvald 03/26/86 15 bus transportation Vonwald/Coogan 03/27/86 9
bus transportation Vonwald
Number Date Trained Type of Personnel Instructors 01/21/07 9
other transportation Vigliani/coogan providers 01/22/87 14 bus transportation Morrison/Coogan 02/04/87 9
bus transportation Morrison 02/05/87 3
bus transportation Morrison 02/21/87 10 other transportation Patterson providers 02/23/87 28 bus transportation VonWald/Coogan 03/10/87 29 D.O.T.
Thorpe /Coogan 03/11/87 21 D.O.T.
Vigliani/Coogan 03/12/87 51 D.O.T.
VonWald/Coogan 03/13/87 25 D.O.T.
Vigliani Interrogatory No. 7 Do the bus drivers identified in response to Interrogatory 5 constitute all ous drivers who may be called upon during a radiological emergency at Seabrook?
If not, how many other bus drivers have not been trained?
Does the State plan to train them?
When will they be trained?
Response
The bus drivers identified in response to Interrogatory No. 5 do not constitute the only bus drivers who may be called upon during a radiological emergency at Seabrook.
Additional bus drivers are being trained over the next several months.
An annual update training session is also offered to the drivers.
Approximately 500 bus drivers would be required to provide drivers for the number of buses that are available under letters of agreement.
The state intends to train at least that number of drivers, and more to ensure that a sufficient number of drivers are available.
v Interrogatory No. 8 In response to Hampton's First Set of Interrogatories on Revision 2, Interrogatory 8, you stated that the State has no compensatory plan and that the State is prepared to use as many of its personnel and as much of its equipment as may be necessary to implement any required compensatory actions.
Given that the RERP lists only " key" emergency response personnel, it is not possible to determine from the plans how many or what types of other personnel may be required.
For each town in the EPZ, please provide the State's calculation of the maximum number of additional personnel that may be required to compensate when the town fails to or has difficulty in implementing its plan.
What is the basis for your answer?
Response
A resource assessment program is being conducted to identify the range of potential resource needs and where these resources can be found to support the New Hampshire RERP.
The first compilation of this data was published early in-April, 1987.
Figure 3.1-1 of this resource assessment shows a survey of resources that may be required in municipalities that may not participate in an emergency response or who have indicated that they may not have adequate resources to implement their plans.
Figure 3.1-2 is a survey by state agency of the personnel that would provide the resource support to implement appropriate protection in their community, i
Interrogatory No. 9 i
Please provide your calculations of how many State agency personnel are available to take compensatory actions under the NHRERP.
How many of these personnel have been trained to implement the NHRERP?
Have they received general training or training for specific tasks?
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Response
There are approximately 12,045 state employees.
Section 1.3 of Vol. 1 of the NHRERP. outlines the responsibilities of each state agency.
Volume 4, 4A and 4B contain procedures and lists of key personnel and the locations where they work.
Section 2.4 of the NHRERP outlines the facilities which are used to implement the RERP.
Training records for those key employees who have been assigned specific tasks are available at New Hampshire Civil Defense Agency Headquarters.
Compensatory actions are assigned as an adjunct to existing procedures either for an individual or an agency as an extension of duties already being performed.
i Both general and specific training has been or will be given to these key employees and agencies who are assigned responsibility in J
the RERP.
r Interrogatory No. 10 i
For the personnel identified in response to Interrogatory 9, please identify the location (s) of the State office (s) where they work.
Response
See Response to Interrogatory No. 9.
Interrogatory No. 11 Please provide all calculations of how long it would take State agency personnel to get to the EPZ and begin to implement emergency response functions.
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Response
Many of the responders are stationed in the EPZ on a daily basis.
Some would travel from Concord, approximately a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> drive.
For full implementation of the RERP, approximately 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> would be needed.
This figure is based upon exercises and drills that have been conducted.
Interrogatory No. 12 Please identify, describe and provide access to all " mutual aid agreements with neighboring states" identified in response to Hampton's First Set of Interrogatories on Revision 2, Interrogatory 8.
I
Response
i The mutual aid agreements referred to in New Hampshire's Response to Hampton Interrogatory No. 8 consist of:
The Interstate Civil Defense Compact, the substance of which is set forth in N.H.
RSA Ch. 108.
The New England State Police Assistance Compact (RSA Ch. 106-D), and the New England Radiological Health Compact (RSA Ch.
125-B).
Interrogatory No. 13 In addition to documents identified in answer to NECNP First Set of Interrogatories on Revision 2, Interrogatory 51, please identify, describe, and provide access to any documents reflecting direct communications between the State of New Hampshire and the leadership of the Teamsters Union concerning the provision of buses and drivers during a radiological emergency.
. ~
Response
Letter of. July 10, 1986 from Richard Vachon, Business Agent, Teamsters Union Local 633 of New Hampshire, to Nicholas J. Pishon of the NHCDA, with enclosed listing of Teamsters Union members available in an emergency.
Interrogatory No. 14 In response to Massachusetts' First Set of Interrogatories on Revision 2, Interrogatory 91, you state that "(i]t is the position of the State of New Hampshire that sheltering is feasible using public facilities for that portion of the transient summer beach population unable to evacuate."
What is the maximum portion of the transient summer beach population that could feasibly be sheltered?
Please explain the basis for your answer.
Response
The State has no calculation of the maximum portion of the transient summer beach population that might be unable to evacuate, nor does it have any calculation on the maximum portion of that.
population that could feasibly be sheltered.
The quoted statement was made in reference to the RERP provision for an ad hoc decision.
(Section 2.6.5, Volume 1.-)
The State simply assumes that the population in question, i.e.
the " day-trippers,"
arrived at the beaches and that the same transportation would be readily available to them when they left.
If, however, that transportation were not readily available, no other mechanism
j.
were available to transport them, and no shelter were readily available to them, then a decision could be made to provide sheltering in public facilities or to assist them in leaving the area.
Interrogatory No. 15 Please provide your calculations of the total transient summer beach population and describe the basis therefor.
Response
See NHRERP, Volume 6, Appendix M.
In the column entitled Training, the numbers listed for each municipality multiplied by the vehicle occupancy rate of 2.4 will provide the transient population.
Interrogatory No. 16 Please identify, describe and provide access to all documents that you rely on or consider in answering these interrogatories.
Response
All such documents are available for inspection during work b' trs (8:30 AM to 4:30 PM) at the Civil Defense Agency headquarters, 7 Pleasant Street, Concord, NH 03301.
.-- I, Richard H.
Strome, being first duly sworn, do depose and say that the foregoing answers are true, except insofar as they are based on information that is available to the State but not within my personal knowledge, as to which I, based on such information, believe them to be true.
.O
~h Rich h H.
Strome Director, Civil Defense Agency Sworn to before me this l44hday of April, 1987:
S I I BItlYT (10 Notary Public
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My Commission Expires: hthu ). lrgg (J
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t CERTIFICATE OF SERVICE DC'.XE! t ?
MT4 I, George Dana Bisbee, hereby certify that on this 14 th day of April, 1987, I made service of the within State of New Hampshire's Response to New England Coalition on Nuclear Pollution's Second gyt 8% 15 P3 :14 Interrogatories and Request for the Production of Documents to State of Naw Hampshire on Revision 2 to the New Hampshire Radiological Emergency Response Planby mailing copies thereof, postage prepaid, to:
OFFict + 3,,._ g,
00CKElIN5u *;; esg; Administrative Judge Helen Hoyt Administrative Judge Sheldon J.
Chairperson Wolfe, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Administrative Judge Gustave Dr. Jerry Harbour A.
Linenberger, Jr.
Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S.
Nuclear Regulatory U.S.
N.R.C.
Commission Washington, DC 20555 Washington, DC 20555 Philip Ahrens, Esquire Thomas G. Dignan, Jr.,
Esquire Deputy Attorney General R.
K. Gad, III, Esquire Peter J.
Brann, Esquire Ropes & Gray Assistant Attorney General 225 Franklin Street Dnpartment of the Attorney General
- Boston, MA 02110 State House Station 6 Augusta, ME 04333 Sherwin E. Turk, Esquire Deputy Assistant Chief Carol S.
Sneider, Esquire Hearing Counsel Assistant Attorney General Office of the Executive Counsel Department of the Attorney General Director One Ashburton Place, 19th Floor U.S. Nuclear Regulatory Commission Boston, MA 02108 Washington, DC 20555 Ms. Diana P.
Randall Robert A.
Backus, Esquire 70 Collins Street Backus, Meyer & Solomon Seabrook, NH 03874 116 Lowell Street P.O. Box 516 eDiane Curran, Esquire Manchester, NH 03105 Harmon & Weiss 20001 S Street, N.W.
Chairperson Suite 430 Board of Selectmen Washington, DC 20009-1125 Town of South Hampton East Kingston, NH 03827 Jane Doughty 5 Market Street Mr. Ed Thomas Portsmouth, NH 03801 FEMA, Region 1 John W.
McCormack Post Office Brentwood Board of Selectmen and Court House RFD Dalton Road Post Office Square Brentwood, NH 03833 Boston, MA 02109
- Sorved by express mail
A i
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Judith H.
Mizner, Esquire Charles P.
Graham, Esquire Silverglate, Gertner, Baker, McKay, Murphy and Graham Fine, Good, and Mizner 100 Main Street 88 Broad Street Amesbury, MA 01913 Boston, MA 20110 Paul McEachern, Esquire J.
P.
Nadeau, Esquire Matthew T.
Brock, Esquire Selectmen's Office Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P. O. Box 360 Portsmouth, NH 03801 Mr. Calvin A. Canney City Manager Ms. Roberta C.
Pevear City Hall The Town of Hampton Falls 125 Daniel Street Drinkwater Road Portsmouth, NH 03801 Hampton Falls, NH 03844 Mr. Angie Machiros Mrs. Sandra Gavutis Chairman of the The Town of Kensington Board of Selectmen RFD 1, Box 1154 (Route 107)
Town of Newbury Kensington, NH 03827 Newbury, MA 01950 Senator Gordon J.
Humphrey Peter.J. Matthews U.S. Senate Mayor Washington, DC 20510 City Hall (Attn:
Tom Burack)
Newburyport, MA 01950 Sanator Gordon J.
Humphrey William S.
Lord 1 Eagle Square Board of Selectmen Suite 507 Town Hall Concord, NH 03301 Friend Street Amesbury, MA 01913 Mr. Thomas Powers Gary W.
Holmes, Esquire Town Manager Holmes & Ells Town of Exeter 47 Winnacunnet Road 10 Front Street Hampton, NH 03841 Exeter, NH 03833 Richard A.
Hampe, Esquire H. Joseph Flynn Hampe & McNicholas Assistant General Counsel 35 Pleasant Street Office of General Counsel Concord, NH 03301 Federal Emergency Management Agency Mr. Robert Carrigg, Chairman 500 C Street, S.W.
Board of Selectmen Washington, DC 20472 Town Office Atlantic Avenue North Hampton, NH 03862 l
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