ML20207T521

Seacoast Anti-Pollution League Answers to Applicant Offsite Emergency Preparedness Interrogatories & Request for Production of Documents of 870305.* Responds to Questions Re Offsite Emergency Preparedness.Certificate of Svc Encl

ML20207T521
Person / Time
Site:	Seabrook
Issue date:	03/17/1987
From:	Doughty J SEACOAST ANTI-POLLUTION LEAGUE
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#187-2850 OL, NUDOCS 8703240094
Download: ML20207T521 (8)

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filed: March 190CKlHEl USHRC UNITED STATES OF AMERICA gg -

NUCLEAR REGULATORY COMMISSION OFFICE OF 5tCFt N'r before the 00CKEithG r. SE:ivifJ.

BidHC!t ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY OF' Docket Nos. 50-433-OL NEW HAMPSHIRE, et al y p ,yy)fy99 gp (Seabrook Station, Unit 1) (Off-Site EP)

SEACOAST ANTI-POLLUTION LEAGUE'S ANSWERS TO APPLICANTS' OFFSITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS OF MARCH 5,1987 l

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SEACOAST ANTI-POLLUTION LEAGUE'S ANSWERS TO APPLICANTS ' OFFSITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS OF MARCH 5,1987 The Seacoast Anti-Pollution League hereby responds to Applicants'-Off-Site EP Interrogatories and Request for the Production'of Documents to Seacoast Anti-Pollution League (SAPL)"

of . March 5,1987. Pursuant to 10 CFR Section 2.740(e) , SAPL will-supplement its responses as further information becones available.

The hearing schedule as presently constituted has not afforded SAPL sufficient opportunity to prepare.its case on offsite emergency planning issues. 1/

GENERAL INTERROGATORIES Gd SAPL intends to litigate all of its admitted contentions identified in the Board 's Order of February 18, 1987 and also Hampton's Revised Contention III to Revision 2. Insofar as the introduction of direct evidence is concerned, SAPL has not yet had sufficient time to arrive at a definite determination of all of the contentions on which it plans to offer direct evidence. SAPL knows at this time that it will offer direct evidence on SAPL Contentions 31, 7, 8 and 8A. It is likely that SAPL will offer direct evidence on all of its contentions.

G.a.2 SAPL Contention 31 Witnesses

1) a) Thomas J. Adler b) P.O. Box 1104, Route 5 South, Norwich, VT 05055 c) Resource Systems Group d) Principal A summary of the educational and professional back-ground of the witness is attached (see Attachment A) .

SAPL may bring an additional witness or witnesses on this contention, but that has not yet been confirmed.

SAPL Contention 7 Witnesses

1) a) Donald L. Herzberg b) Rt. 1, RFD 173, Norwich, VT 05055 c) Dartmouth-Hitchcock Medical Center d) Chief of Nuclear Medicine A summary of the educational and professional background of this witness was provided to all parties to this proceeding 1/ See "Intervenors' Joint Motion for Immediate Stay of ASLB Proceedings" filed December 22, 1986, "Intervenors ' Joint Motion to Extend Hearing Schedule" filed February 25, 1987 and Attorney General James M. Shannon's objection to and motion for reconsideration of hearing schedule filed March 2, 1987 in which SAPL joined on March 5,1987.

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.in " Seacoast Anti-Pollution League's Answers to Applicants' Off-Site .EP ' Interrogatories and Request for the Production of Documents to Seacoast Anti-Pollution League, Inc. . (Set No.1) "

filed May 12, 1986.

SAPL may bring-an additional witness or witnesses.on this -

contention, but that has not yet been confirmed.

SAPL Contentions 8 and 8A Witnesses

'l) a) Representative Roberta Pevear b) Drinkwater Road, Hampton Falls, NH 03844 -

c and d) Rep. Pevear is an elected Representative of the 1 Towns of Hampton and Hampton Falls in the New Hampshire General Court and is also the Civil Defense Director of Hampto.. Falls..

Representative Pevear has been Civil Defense Director of Hampton Falls since 1980 and an elected official since 1979.

2) a) Walter F. Shivik b) RFD 2, Box 12, South Hampton, NH 03827 c and d) Mr. Shivik is a self-employed consulting engineer.-

He has been a selectman in South Hampton since 1981 Mr. Shivik holds a Bacheloroof Science Degree from the U. S. Merchant Marine Academy, an M.S. in Mechanical

. Engineering.from the University of New Hampshire and he is a registered professional engineer in the State of New Hampshire.

3) a) Chief Andrew Christie b) 185 Kensington Road, Hampton Falls, NH 03844 c) Employed by the town of Hampton Falls d) Chief of Police Chief Christie is a graduate of Exeter High School. He has taken college level courses at the University of New Hampshire and Northeastern University. He has been a police officer in the seacoast since April 1, 1964 and has been the Chief of Police in Hampton Falls'since April.1, 1975.

4) a) Sandra Gavutis b) RD 1 Box 1154, Kensington, NH 03827 c and d) Serves as a Selectman for the Town of Kensington.

Also is employed at the House of Travel in Hampton, N.H.

Mrs. Gavutis holds an Associates Degree from McIntosh Business College in Haverhill, Massachusetts. She was elected selectman in the Town of Kensington in 1980 and has served in that capacity to'the present. She has been employed for two years at the House of Travel in Hampton.

SAPL may bring an additional witness or witnesses on these contentions but that has not yet been confirmed.

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'Redref ted Contention 115, ~ Contention 16, Contention 18.

Contention 25, Contention 33 and Contention 34 i

SAPL has'not yet confirmed witnesses for these contentions.

SAPL Contention 37

1) a) Thomas J. Adler b-d). See the information provided at SAPL_ Contention 31 above.

Eatoton's Revised Contention III to Rev. 2 Same as response for SAPL Contention 31 above.

fLa.1 SAPL Contention 31 The substance of testimony and documents relied on by witness

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Thomas J.. Alder are.provided at Attachment A-1. Mr. Adler may also rely on " Report on-Survey of Eeach-Goers at Hampton Beach, Summer of 1983" from David W. Moore, Co-Director, UNE Poll.

SAPL Contention 7 Donald L. .Herzberg, M.D. Will provide testimony on the

! . inadequacy of personnel and equipment (including that for

l. collection and storage of radioactively contaminated water) to i accomplish monitoring and_ decontamination of emergency workers and

'the public reasonably _ expected to seek such services at decontamination centers in a radiological emergency. His

, testimony relies on NHRERP Rev. 2. Additional documents will be cited if and when identified.

SAPL' Contentions 8 and BA

1) Representative Pevear will provide testimony on the inadequacy of manpower to carry out an adequate radiological emergency response in the Town of Hampton Falls under either the regular or compensatory provisions of NHRERP Rev. 2. Her testimony will rely upon NHRERP Rev. 2. Additional documents will be cited if and when identified for use in her testimony.

2) Walter F. Shivik will provide testimony on the inadequacy of manpower to carry out an adequate radiological emergency response in the Town of South Hampton under either the regular or compensatory provisions of NHRERP Rev. 2. His l testimony will rely upon NHREP Rev. 2 and an appointments ledger

! for the Town of South Hampton. Additional documents will be cited if and when identified for use in his testimony.

3) Chief Andrew Christie will provide testimony on the l inadequacy of manpower in the Town of Hampton Falls police force l to carry out an adequate radiological emergency response in the I town. Documents upon which Chief Christie may rely will be cited l '

if and when identified.

4. Mrs. Gavutis will provide testimony on the inadequacy of manpower to carry out an adequate radiological emergency response in the Town of Kensington under either the regular or compensatory

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G provisions of NHRERP Rev. 2. Her testimony will rely upon'NHRERP-Rev. 2a Additional documents will be cited if and when identified forLuae'in heritestimony.

INTERROGATORIES RRLATED TO SPECIFIC CONTENTIONS ,

r SAPL Contentions 8 and BA 3:1 SAPL objects to.the relevance of this interrogatory-because it focuses on non-radiological emergencies which are not '

related to the matters inLlitigation in this. proceeding. Without

' waiving objection, SAPL responds as follows: SAPL has not:

researched the provisions that the 17 local New Hampshire communities may have for responding to non-radiological >

emergencies such as toxic chemical spills, hurricanes, or other-

. severe weather conditions.

E 2 SAPL objects to the relevance of this interrogatory 4 insof ar as it focuses on non-radiological energencies not related to the matters in litigation in'this' proceeding. Without waiving objection, SAPL responds as follows: SAPL has not researched the measures that are.in_ place to ensure that local officials are available to make immediate protective response decisions on a 24-hour basis and that local police, fire and public works officials

-are staffed to implement protective actions on a 24-hour basis for non-radiologcal emergencies.

SAPL Contention 34 In referring to " traffic counts and local business figurec,"

SAPL was quoting the October 29, 1965 letter to Governor Sununu from Hampton Selectmen. A copy of that letter was appended to.

" Seacoast Anti-Pollution League's Contentions on Revision 2 of the New Hampshire Radiological Emergency Response Plan" filed November 26, 1986. SAPL also would point to the February 20,~1986  ;

Affidavit of Glen French appended to " Contentions of the Town of' Hampton to Radiological Emergency Response Plan for the Town of Hampton, New Hampshire, November, 1985" filed February 21, 1986.

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' Respectfully submitted,'

SEACOAST ANTI-POLLUTION LEAGUE iDATED [# link 11 M M' BY - be 4ah3%

Jane' Doughty H

-() ch ST TE OF.NEW HAMPSHIRE COUNTY OF HILLSBOROUGH Then personally appeared the above named Jane Doughty and acknowledged that the foregoing statements by her: subscribed.are true and correct to the best of her knowledge and belief.

'Before me eviu._f Noteri Fablic/ Justice of the Peace I . hereby certify that copies of the Seacoast Anti-Pollution-League's Answers to Applicants' Offsite EP Interrogatories and

. Request for the Production of Documents of March 5,1987 have been sent this date, first class postage prepaid to all parties on the enclosed service list.

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Robert A. Backus March 17,1987 4

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. . ATTACliMENT A Resource Systems Group Resume TilOMAS1 ADLER Education , Cornell University ILS., Civil and Envimnmental Engineering,1972 Massachusetts lustitute of Technology S.M., Transportation Systems,1975 PhD, Transportation Systems,1976 Professional Affiliations Transportation llesearch Board American Society of Civil Engineers Exocrience Dr. Thomas J. Adler, a principal of RSG, has extensive experience in planning, analyzing, and evaluating transpenation systems at the local, regional, national and international levels.

Since joining the Resource Systems Group, Dr. Adler has been Principal-in-Charge for over thirty

. projects ranging in scale from the market assessment of a proposed $8 billion high speed passenger rail system to traffic impact studies of small commercial and n:sidential projects. Ile has been heavily involved both in the technical work on all of these projects and in maintaining schedules and budget controls.

For ten years prior to joining RSG, Dr. Adler was on the faculty of the Thayer School of Engineering at Dartmouth College, teaching in the areas of transportation planning / engineering and computer-based modeling methods, and directing a major program of transportation research in the Resource Policy Center, sponsored by the U.S. Department of Transportation and others. Over that period, he also served as an inde >cndent transponation analyst and as a consultant to several major national firms such as Cambrit ge Systematics, Inc. (headcluarters in Cambridge, M A),

Gannett Fleming Transportation Enginecrmg (llarrisburg, PA), and Parsons Brinckerhoff(NYC).

He has published numerous articles / reports and has extensive experience as an expert witness on a wide variety of transportation issues, i

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ATTACHMENT A-1 Resource Systems Group Dntft 3/13/87 l Response to Scabrook Interrogatoriesl Su!2 stance of Testimony Dr. Adler will provide testimony on the reliabiIity and adequacy of assumptions used in generating the evacuation time c.aimates (El'E's) presented in Volume 6 of the Phm (Nil REllP, rev. 2). lie will also present evidence as to the effects of those assumptions in increasing or decreasing ETE's for the various scenarios presented in Volume 6.

Documents Relied Unon

1) Material presented .a Volume 6 of the Plan (rev. 2 and/or most recent revision available).

2) Input data used in Volume 6, as supplied in response to Massachusetts Attorney General's interrogatories.

3) Documentation for the 1 DYNEV Model, as distributed by FEMA.

3) ' Highway Capacity Manual, Special Report 209, Transportation Research Board, Washington, D.C.,1985.

4) Other reference material as commonly relic 1 transportation planning and traffic engmeer$mg. upon by professionals in the areas of I

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CERTIFICATE'OF SERVICE AND SERVICE LIST

.i Asst.Gn.Cnsl. Helen Hoyt. Chm.

• Thon9:MfdEhnan, Esq.

• Joseph Fad. Flynnlgmt.

Emerg. A Agcy. Admn. Judge Ropesi" Dray 500 C.St. So. West Atomic Safety & Lic Brd. 225 Franklin St. .

Washington, DC 20472 USNRC. W s W 3 1,p M 10 Washington, DC 20555 Office of Selectmen Town of Hampton Falls Dr. Jerry Harbour

• Adnin, Judge hh;bNk^hrv. Sec.

Of f14tANCE the Secretary Hampton Falls, NH 03844 Atomic Safety & Lic Brd. USNFC USNRC Washington, DC 20555 Washington, DC 20555 Shenvin E. Turk, Esq.

Office of Exec. Legl. Dr. Dr. Gustave A. Linenberger

• Jane' Doughty Admin Judge SAPL USNRC 5 h!arket Street Atomic Safety & Lic. Brd.

Washington, D.C. 20555 USNRC Portsmouth, NH. 03801 Washington, DC 20555

.Phillip Ahrens, Esq. Paul nicEachern, Esq. George Dana Bisbee, Esq.

Asst. Atty. General Shtthew Brock, Esq. Attorney General's OFFe State House , Sta. #G 251hplewood Ave. State of New Hampshire

! Augusta, h!E 04333 P.O. Box 360 Concord, NH 03301 Portsmouth, MI 03801 Carol Sneider, Esq. , Asst. AG Diane C trran, Esq. William S. Iord One Ashburton Place, Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NT Suite 430 Town Hall-Friend St.

Boston , h!A 02108 Washington, DC 20009 Anesbury,11A 01913 Richard A. Hampe, Esq. Ahynard Young, Chairman Sandra. Cavutis New Hampshire Civil Deiense Board of Selectnen Town of Kensington L Agency 10 Central Road Box 1154 IIampe & hicNicholas Rye, Mi 03870 East Kingston, N.H. 0382:

33 Pleasant St Concord, NI 03301 Judith H. Mizner, Esq. Edward Thomas hIr. Robert Harrison Silverglate, Gertner, FDIA Pres. & Chief Exec. Officer Baker, Fine, Good & Mizner 442 J.W. h!cConnack (POCH) PSCO 88 Broad Street Boston, h!A 02109 P.O. Box 330 l

Boston, MA 02110 hhnchester, NH 03105 Roberta Pevear l

State Rep.-Town of Hartpt Falls Drinlovater Road Hanpton Falls, Nh 03S44 l

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