ML20207T525
| ML20207T525 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/18/1987 |
| From: | Janetos D HAMPTON, NH |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| CON-#187-2852 OL, NUDOCS 8703240098 | |
| Download: ML20207T525 (16) | |
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69 ASOCOMRESPONDENCC USNRC Dated:
March 18,1987 S7 MAR 20 P3:03 UNITED STATES OF AMERIC5 NUCLEAR REGULATORY COMMISS[pNa.
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before the F17 +
r ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
)
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
) 444-OL
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Off-site Emergency (Seabrook Station, Units 1 and 2) )
Planning Issues
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TOWN OF HAMPTON ANSWERS TO APPLICANTS' OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION QE DOCUMENTS IQ TEE TOWN DE HAMPTON NOW COMES the TOWN OF HAMPTON and answers APPLICANTS' OFF-SITE EP INTERROG ATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE TOWN OF HAMPTON dated March 5,19 87' as follows:
GENERAL RESPONSE The Town of Hampton presently lacks suf ficient inf ormation to f ully respond to Applicants' Interrogatories and Request for the Production of Documents.
By INTERVENORS' JOINT MOTION TO EXTEND HEARING SCHEDULE dated February 25, 1987, the Town of Hampton advised all parties that it will be approximately two (2) months f rom the date of receipt of discovery materials until Intervenors' expert, Doctor 8703240098 870318 PDR ADOCK 05000443 G
PDR SH AINES & McEACHERN ===oressma6 associate avvom=ces DJ03
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Thomas J. Adler, can provide a preliminary response to Applicants' y
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Interrogatories concerning Town of Hampton revised contention III.
An additional two (2) months will be required before Dr. Adler antici-pates he will be able to provide a reasonably complete response to interrogatories on this contention.
To the extent Dr.
Adler's comments and opinions may bear upon those other Hampton contentions L-admi.tted by the Board For Litigation,1 necessarily the Town presently cannot provide reasonably complete reshonses to Applicant on interro-
'gatories, addressing these contentions.
The Town of Hampton reserves the right to_ identify additional witnesses, documents and testimony to support the Town's contentions I
admitted f or litigation before the Licensing Board.
The compressed schedule precludes further response at this time.
AHS'42BS,2Q GENERAL INTERROGATORIES-l M Please identify those contentions admitted by the Board's Order of February 18, 1987 on which TOH intends to introduce evidence in this proceeding.
ANSWER:
Town of Hampton Revistid Contention III, Town of Hampton Revised Contention IV, Town of Hampton Revised Contention VI, Town of Bampton Revised Contention VIII.
1 Town of Bampton Revised Contention IV, Town of Hampton Revised Contention VI, and Town of Hampton Revised Contention VIII.
2 SMAINES & MCEACHERN - *=oresso.a6 associato. avvoewes
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For each contention ident.ified in Interrt,gatory G.1, please Please identify all persons whom TOH intends to call as witnesses.
include a summary of educational and professional background of each identified witness.
ANSWER:
A.
For all contentions identified in G.1, the Town will call the following witnesses:
Doctor Thomas J. Adler.
Doctor Adler shall testify on the issues indicated on the attachment filed herewith.
A statement of Dr. Adler's prof essional qualifications is attached hereto.
B.
Dona R. Janetos, Vice Chairman, Hampton Board of Selectmen, c/o Hampton Town Hall, Hampton, New Hampshire.
Ms. Janetos shall testify regarding the lack of adequate town personnel to carry out duties assigned under the NHRERP, including inadequate police and public works personnel to control and manage traf fic and otherwise carry out assigned duties.
Vice Chairman Janetos shall further testify regarding the inadequacy of the road system around Hampton to permit a reasonably prompt evacuation, and of her observations of population and traffic conditions in the Hampton Beach area, particularly during the summer months.
Vice Chairman Janetos may rely upon Town records identifying Town personnel and Town equipment.
C.
Herbert Moyer, Teacher, Winnacunnet High School, Hampton, New Hampshire.
Mr. Moyer shall testify regarding the problems associated with the evacuation of Hampton school students in the event of 3
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radiological emergency, including inadequate teachers and staf f to
- support, supervise, or carry out an evacuation of the student j
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-population.
Mr. Moyer shall rely on his own surveys and petitions executed by numerous EPZ teachers in opposition to the NHRERP and assigned duties set forth therein.
Mr. Moyer has a BS, with graduate course work and has taught high school for 18 years.
D.
Ann Hutchinson, Manager, Berry Transportation Company, North Hampton, New Hampshire.
Ms..Hutchinson shall testify regarding her personal observations and participation in the February 26, 1986 emergency exercise conducted by the State on the NHRERP.
M s.
Butchinson shall identify numerous deficiences in the exercise and shall rely on the log which she compiled during the course of the emergency exercise on February 26, 1986.
Ms. Hutchinson has an Associates Degree f rom UNS and has worked twenty-three (23) years for Berry Transportation.
Glen French, Executive Director, Hampton Chamber of Commerce.
E.
Mr. French shall testify regarding population estimates utilized by the Hampton Chamber of Commerce and area businesses in accordance with on the his affidavit dated February 20, 1986, previously served
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parties as an attachment to CONTENTIONS OF THE TOWN OF HAMPTON TO NEW RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR THE TOWN OF HAMPTON, HAMPSHIRE, NOVEMBER 1985.
Provide a reasonable description of the substance of the L3.
testimony of each witness on each of the contentions identified in 'the 4
SH AINES & McEACHERN -==oresso.a6 assoc.aec= avvoe=ews
f answer to Interrogatory G.l.
Please also identify all documents which will be relied on in that te stimony.
ANSWER:
See answer to Interrogatory G.2.
ANSWERS IQ INTERROGATORIES RELATED IQ SPECIFIC CONDITIONS E.l.
Identify each document relied upon, in whole or in part, for TOH revised Contention III to Revision 2 that the Evacuation Time Estimate Study (ETE) prepared by KLD Associates, Inc., Revision 2, Volume 6, is based upon:
[a] inaccurate and biased f actual data; and
[b] unreasonable or misleading assumptions; and which designates in whole or in part: [c] adequate protective measures; and [d] adequate facilities, equipment or personnel requisite to provide reasonable assurance that adquate protective measures can and will be provided.
ANSWER:
See Answer to Inte rrogatory G.2.
By way of further the Town of Hampton relies upon NEW HAMPSHIRE RESPONSE ACTIONS
- answer, TO RAC REVIEW OF STATE AND LOCAL RADIOLOGICAL EMERGENCY RESPO
- AUGUST 19 86; FEMA, FINAL EXERCISE ASSESSMENT, June 2,19 86; FEMA /RAC REVIEW OF REVISION 2, December, 1986; FEASIBILITY ASSESSMENT OF A NEW HAMPSHIRE, Arthur D.
MULTI-LEVEL PARKING GARAGE AT HAMPTON BEACH, Littl e, Inc. (February 1985); and Hampton Beach Traffic Study, August 1984.
These documents will be relied upon by the Town that the KLD ETE is based upon inaccurate and biased f actual data and unreasonable or misleading assumptions.
Pr esently, the Town has no knowledge of any other documents within the scope of this Interrogatory.
5 SH AINES & MCEACHERN. poorsso.on.a6 asecciato. aevoa avs
S-2.
Identify each document relied upon in whole or in part in Town Of Hampton Revised Contention III to provide adequate data to compute:
(1) the permanent and transient populations of Town of Hampton, ( 2) proper vehicle occupancy rates and (3) daily a.m. and road capacities for the evacuation of permanent and transient p.m.
populations from Town of Hampton under all traffic and weather conditions.
ANSWER:
Presently, to the extent the Town of Hampton intends to introduce evidence on the issues raised in Interrogatory S-2, the Town will be relying upon the opinions and conclusions of Doctor Adler which will not be available until the dates previously discussed herein.
Identify those sections of the evacuation road routes which S-3.
become impassable when a vehicle breaks down, runs out of gas, or overheats and thereby becomes disabled.
ANSWER:
Presently, to the extent the Town of Hampton intends to introduce evidence on the issues raised in Interrogatory S-3, the Town will be relying upon the opinions and conclusions of Doctor Adler which will not be available until the dates previously discussed herein.
Please provide the means by which the Town of Hampton would S-4asuch as a toxic chemical respond to a non-radiological emergency, hurricane or other severe weather emergency that could require
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SH AINES & McEACHERN. >=casssovas associatio= ance=us
sheltering or evacuation of significant segments of-the town-population.
ANSWER:- This interrogatory is-objected to on grounds it is unduly burdensome-and seeks information irrelevant to this proceeding and is not reasonably calculated to lead to the discovery of admissible evidence.
By way of further objection, the. Town states that the "non-radiological emergency" ref erenced in this Interrogatory is vague, ill-defined, and speculative; that regardless of the Town's response to a non-radiological emergency, the Town has voted not to participate in responding to an emergency at Seabrook Station; and theref or the Town's emergency response capabilities have no bearing on this proceeding.
Whether or not the Town is willing to participate in implementing the NHRERP, however, the Town, including its beach population, cannot be provided reasonable assurance of adequate protection in the event of any emergency at Seabrook.
The Town's non-radiological emergency capabilities again, are therefor irrelevant.
Additionally, even assuming this Interrogatory was not otherwise defective, it impermissibly seeks to shif t the burden for emergency planning for Seabrook Station onto the Town, in violation of'10 CFR Part 50, Appendix E.
Finally, the Applicant is already in possession of information on available Town, State and Federal personnel and equipment available to respond to a public emergency, however inadequate these sources would prove in the event of a radiological i
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- e.orssseen associaroe mons avs
emergency at Seabrook.
Applicant's Interrogatory is therefor redundant and would needlessly expend the Town's resources in providing a further response.
S-5.
Please identify the agencies, organizations, and personnel including that would be utilized to respond to such an emergency, names, addresses, and telephone numbers.
In the case of individual personnel, please provide place of employment, name of employer, address and telephone numbers.
ANSWER:
See Answer to Interrogatory S-4.
S-6.
If such an emergency would require response that would exceed the capabilities of town resources, please explain the method f or requesting outside assistance, including assistance f rom other local governments, private sources of assistance, the State of New What agencies, Hampshire, and the government of the United States.
organizations, and personnel would be utilized to provide assistance?
How would these agencies, organizations, and personnel be contacted?
Who would contact them?
ANSWER:
See Answer to Interrogatory S-4.
Please provide a list of all personnel that are available S-7.,
to the town to respond to such an emergency, including names, addresses and telephone numbers, including:
1.
All police personnel, including sworn police personnel, auxiliary police personnel, and volunteer police personnel.
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SH AtNES & MCE ACHERN. e.orssseas associate a"ca=ses
- 2.. All fire personnel, including paid, full-time fire personnel, call fire personnel, auxilia ry. fire personnel, and volunteer fire personnel.
3.. All ' emergency medical personnel, including full-time, part-4 t'ime, and volunteer.
4.
All public works personnel and other town personnel responsible for road maintenance for the town.
5.
All private contractors that provide the following services to the town.
i Snow clearance and clearance of other impediments.
a.
b.
Road maintenance.
c.
Vehicle towing.
ANSWER:
See Answer to Interrogatory S-4.
h Dated:
March 18,1987 Dona R. Janetos, ice Chairman Hampton Board of electmen Personally appeared the above-named Dona R. Janetos and swore to the truth of the foregoing statements based upon personal knowledge, information and belief.
Before me, sam. W 4mm ef f.: ? L =/Public Notary
]
ANN E. YORTY, Notary Puti.:
My Comrmssion Ex;ures August 19,1s41 P
9 SHAINES & McEACHERN
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Resource Systems Group Draft 3/13/87 l Response to Seabrook Interrogatories l Substance of Testimony Dr. Adler will provide testimony on the reliability and adequacy of assumptions used in generating the evacuation time estimates (ETE's) presented in Volume 6 of the Plan (NH RERP, rev. 2). He 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 Uoon 1)
Material presented in 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 I-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 relied upon by professionals in the areas of transportation planning and traffic engineering.
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.p Resource Systems Group Resume THOMAS L ADLER Education ComellUniversity B.S., Civil and Environmental Engineering,1972 Massachusetts Institute of Technology S.M., Transportation Systems,1975 PhD, Transportation Systems,1976 Professional Affiliations Transportation Research Board American Society of CivilEngineers l
Experience Dr. *Ihomas J. Adler, a principal of RSG, has extensive experience in planning, analyzing, and
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evaluating transponation systems at the local, regional, national and international levels.
Sincejoining the Resource Systems Group, Dr. Adler has been Principal in-Charge for over thiny 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 residential projects. He 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 independent transponation analyst and as a consultant to several major national firms such as Cambridge Systematics, Inc. (headquarters in Cambridge, MA),
Gannett Fleming Transponation Engineering (Harrisburg, PA), and Parsons Brinckerhoff (NYC).
He has published numerous articles / reports and has extensive experience as an expen wimess on a wide variety of transportation issues.
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- uno cuanwunutyct 000KETED USNP.C CERTIFICATE QE SERVICE Matthew T. Brock, one of the attorneys for*$7ht$F$n fhT.Miampton I,
herein, hereby certify that on March 18, 1987, I made service of the following documents, TOWN OF HAMPTON ANSWERS TO APPLI. CANTS,, OFF-SITE
'TO THE
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RDER by EP INTERROGATORIES AND REQUEST FOR THE PRODUCTIO TOWN OF HAMPTON and TOWN OF HAMPTON MOTION FOR depositing copies thereof with Express Mail, ' prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):
- Helen Hoyt, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814
- Judge Gustave A. Linenberger, Jr.
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission East West Towers Building 43 50 East West Highway Bethesda, MD 20814
- Dr. Jerry Harbour Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814
- Atomic Saf ety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
SH AINES & MCE ACHERN. esoresso.asassociato. agreave
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Mrs. Anne E. Goodman
~ Board of Selectmen-13-15 Newmarket Road Durham,-NH 03842 William S. Lord, Selectman Town Hall Friend Street Amesbury, MA 01913 Jane Doughty Seacoast Anti-Pollution League
- 5 Market Street
- Portsmouth, NH 03801 Rep. Roberta C. Pevear-Drinkwater Road Hampton Falls, NH 03844
- Philip _Ahrens, Esq.
Assistant Attorney General Office of the Attorney General State House Station 6 Augusta, ME 04333
- Thomas G. Dignan, Esq.
R.K. Gad II, Esq.
Ropes & Gray 225 Franklin Street Boston, MA 02110
-Robert A. Backus, Esq.
Backus, Meyer & Solomon 111 Lowell Street Manchester, NH 03105
- Sherwin E. Turk, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Tenth Floor 7735 Old Georgetown Road i
Bethesda, MD 20814 Mr. Angie Machiros, Chairman Board of Selectmen Newbury, MA 01950 2
l SH AlNES & McEACHERN.==cusso a6 assoc.avo. avvenw.,
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l H. Joseph Flynn, Esq.
Office of General Counsel Federal Emergency Management Agency 500 C Street, S.W.
Washington, D.C.
20472 9
- George Dana Bisbee, Esq.
Stephen E. Merrill, Esq.
l Office of the Attorney General State House Annex l
Concord, NH 03301
- Carol S. Sneider, Esq.
Assistant Attorney General Department of-the Attorney General-One Ashburton Place 19th Floor Boston, MA 02108 Stanley W. Knowles Board of Selectmen P.O. Box 710 North Hampton, NH 03862 J.P. Nadeau, Selectman Selectmen's Office 10 Central Road Rye, NH 03 870 Richard E. Sullivan, Mayor City Ball Newburyport, KA 01950 Alfred V. Sargent, Chairman Board of Selectmen Town of Salisbury Salisbury, MA 01950 Senator Gordon J. Bumphrey U.S. Senate Washington, D.C.
20510 (Attn:
Tom Burack)
Michael Santosuooso, Chairman i
Board of Selectmen Jewell Street l
RFD 2 I
South Hampton, NH 03 827 3
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Allen Lampert Civil Def ense Director Town of Brentwood Exeter, NH 03833 Richard A. Hampe, Esq.
Hampe and McNicholas 135 Pleasant Street Concord, NH 03301 Gary W. Holmes, Esq.
Holmes & Ellis 47 Winnacunnet Road Hampton, NH 03842 William Armstrong Civil Defense Director 10 Front Street Exeter, NH 03833 Calvin A. Canney City Manager City Hall 126 Daniel Street Portsmouth, NH 03801
- Edward A. Thomas Federal Emergency Management Agency 442 J.W. McCormack (POCH)
Boston, MA 02109 Sandra Gavutis Town of Kensington i
RFD 1, Box 1154 East Kensington, NH 03 827 Charles P. Graham, Esq.
McKay, Murphy & Graham 100 Main Street Amesbury, MA 01913
- Diane Curran, Esq.
Andrea C. Ferster, Esquire Harmon & Weiss suite 430 2001 S Street, N.W.
Washington, D.C.
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Robert _Carrigg, Chairman Board of Selectmen Town-Office Atlantic Avenue' North Hampton, NH 03862 Senator Gordon J. Humphrey One Eagle Square, Suite 507 Concord, NH 03301 (Attn: Herb Boynton)
Mr. Thomas H. Powers, III Town Manager Town of Exeter 10 Front Street Exeter, NH 03833 Mr. Peter Matthews Mayor City-Hall Newburyport, MA 01950 Brentwood Board of Selectmen RFD Dalton Road Brentwood, NH 03833 Judith H. Mizner, Esquire Silvergate, Gertner, Baker, Fine, Good & Mizner 88 Broad Street Boston, MA 02110 n,K
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Matthew T.
Brock
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