ML20207T532

Applicants Response to Interrogatories Re State of Nh Radiological Emergency Response Plan Rev 2,propounded to Them by Other Parties.* Certificate of Svc Encl.Related Correspondence

ML20207T532
Person / Time
Site:	Seabrook
Issue date:	03/18/1987
From:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	HAMPTON, NH, MASSACHUSETTS, COMMONWEALTH OF, SEACOAST ANTI-POLLUTION LEAGUE
References
CON-#187-2854 OL, NUDOCS 8703240106
Download: ML20207T532 (296)

Text

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dt.LA4 tu UO4f tttbl Of t UtNQi March 18, 1987 00CHETED UNITED STATES OF AMERICA USMC NUCLEAR REGULATORY COMMISSION p g g p4 before the gFflCECTSAt.fAgy ATOMIC SAFETY AND LICENSING BOARD OCKEig.jt PVICf.

)

In the Matter of ) I

)

PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE. et al. ) 50-444-OL

)

(Seabrook Station. Units 1 and 2) ) Offsite Emergency Planning

) Issues I

l APPLICANTS' RESPONSE TO INTERROGATORIES I RE: NHRERP REV. 2 PROPOUNDED TO THEM BY OTHER PARTIES O ,

l KO 3 PDR L/099LK.1

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/ TOWN OF HAMPTON r U

APPLICANTS' INTERROGATORIES t

s

1. With respect to each contention and subpart thereof filed by the Town s

of Hampton and admitted by the Licensing Board's order of February 18, 1987, t, 4

please provide the following information: , d

a. What is Applicant's position with respect to each contention and

• its subparts? Describe in detail the reasons for.your position.

b. Identify and provide access to all documents and the Data Base on which you rely to support your position on each of these conten- '

tions. This includes the Data Base used, or to be used, in your ,

i answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearinzs.'

c. Identify all persons on whose factual knowledge, opinions, or technical expertise you rely for your position 'on each contention and subpart thereof. ,

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O,

d. Identify all persons you may call as witnesses on each ofithese

• contentions during these proceedings: describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their, testimony.

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RESPONSE

si

a. TOH Revised Contention III to Revision 2 contends that the >

4 Evacuation Time Estimate (ETE) prepared by KLD Associates. Inc.

(KLD) Revision 2. Vol. 6 is based on ineccurate/ biased data and assumptions,doesnotcomplywithNRCregulatI'onsandfailsto provide adequate facilities equipment or personnel. Asserted as bases ares ,

(a) ETE lacks adequate data to compute permanent and transient population estimates.

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TOWN OF HAMPTON APPLICANTS' INTERROGATORIES

RESPONSE

(continued)

(b) ETE inadequately compensates for adverse inclement weather conditions.

(c) ETE employs unsupported assumptions when computing road net-work capacity concerning impediments to traffic, insufficient i traffic control, point control, through traffic, highway accessible capabilities, spontaneous evacuations local weekend work schedules, disabled vehicles.

'I' (d) ETE preparation time (notification times, beach to car times.

j staging area preparation time, understatement of impact of workers returning home).

(e) Growth of EPZ population and vehicles, population distribu-tion will soon be outdated.

(f) ETE assumes evacuees will go to designated host communities.

TOH III 11/19/86 addition ETE provides inadequate information to allow proper review

a. No account of time for ACP/TCP personnel to question drivers

b. Assumes traffic lights will stay green

c. Falls to include " light" traffic in simulation model

d. Disabled cars on narrow roads limits passage

e. ETE not increased for non-complying persons

f. Only low speed accJdents assumed

g. Sensitivity tests not conducted for accidents, snow or traffic

't jams

h. Adequacy of simulation model cannot be critiqued without addi-tional information n

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'QJ O) TOWN OF HAMPTON APPLICANTS' INTERROGATORIES ,

RESPONSE

(continued)

Applicants' Position is that the KLD ETE meets regulatory directives and guidelines and provides adequate and suitable information for the decision makers, at the time of an incident, to employ in their judgment process to determine what adequate protective measures may be implemented. As to the bases asserted for TOH contentions of October 31, 1986:

a.-d. Applicants maintain the KLD ETE speaks for itself, its findings are supported by the available evidence and its assumptions reasonable,

e. RERPs are continuing documents with frequent updates. The NHRERP does not use population projections as a planning bases. Vol. 1

$ 33 describes how the Director NHCDA will ensure that the plan will be reviewed at least annually and kept current,

f. Access Control Points / Traffic Control Points control the direction of vehicles to desired points in the EPZ, public information O materials provide evacuation route information to tourists, once out of the EPZ it is an option for evacuees to refer to reception g ,

centers. Naps are provided to bus drivers.

i Applicants' Position on TOH III 11/19/86 supplemental bases is as follows:

i a. Evaccus are provided evacuation information via brochures and I c(t!c'idsTs; Energeacy Broadcast Station messages for evacuation refer these documents to provide this information. Sec RERP Vol. 4 G-34.

b. Traffic Control Points will control movement of traffic in appropriate directions.

c. 3,000 additional (through) traffic or highway figures RERP Vol. 6, 2-27. Aerial films at the time of maximum parking capacity (2:00

> p.m.) identify only 300 moving cars in Hampton Beach, only 40% of total parking capacity.

di No evacuation route roadways within the EPZ are of such a nature as to prevent vehicular movement around a disabled vehicle.

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l I TOWN OF HAMPTON APPLICANTS' INTERROGATORIES

RESPONSE

(continued)

e. Persons not immediately responding to an evacuation order would potentially decrease ETE. It is assumed that in light of protec-tive action recommendation and orders of responsible officials that the majority of individuals would comply with instructions although no regulatory bases require this,

f. Emergency vehicles would enter the EPZ in initial response time frames and would use free lanes for travel.

g. Disabled vehicles would be removed (pushed) or towed to the side of the road to maintain egress capabilities: 204 reduction for rain 254 for snow.

h. No specific information is provided under this (TOH) subjective observation.

b. Those documents which have not already been served on the parties prior

(~} to issuance of the Town of Hampton Interrogatories or specifically V

I included with the responses to interrogatories will be made available for inspection and copying at the Seabrook Station or at KLD's office.

Please contact Mr. William J. Daley at (603) 474-9252, extension 2057, to arrange for document inspection.

c. Persons on whose factual knowledge, opinions, or technical expertise the Applicants rely or presently intend to rely for their position on contentions that have been admitted are the following:

1. Richard Strome, Director (TOH Piv. III, TOH III, TOH IV, TOH Rev.

VI. TOH Rev. III)

New Hampshire Civil Defense Agency 107 S. Pleasant Street Concord, NH 03301

2. William T. Wallace Director (TOH-VIII)

Division of Public Health Services NH Department of Health and Human Services 6 Hazen Drive Concord, NH 03301

3. Edward B. Lieberman, Vice President (TOH Rev. III TOH III, TOH IV, TOH Rev. IV)

KLD Associates

() 300 Broadway Huntington Station, New York 11746 L/063LS.I.3

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TOWN OF HAMPTON APPLICANTS' INTERROGATORIES

RESPONSE

(continued)

4. Dennis S. M11eti (TOH Rev. III TON III. TOH IV. TOH Rev. IV)

Associate Professor, Department of Sociology Director, Hazards Assessment Laboratory Colorado State University Fort Collins, Colorado 80523

5. Anthony M. Callendrello (All Contentions)

Manager, Emergency Planning Seabrook Station P.O. Box 300 Lafayette Road Seabrook, NH 03874

6. Paul Frechette. Technical Manager (All Contentions)

Seabrook Station P.O. Box 300 Lafayette Road O Seabrook, NH 03874

7. John Baer, Consultant (All Contentions)

Seabrook Station P.O. Box 300 Lafayette Road Seabrook, NH 03874

d. Witnesses have not been selected.

TOH Revised Contention IV to Revision 2 contends: that Revision 2 fails to provide adequate emergency equipment, adequate protective response and a correction of deficiencies in emergency response capabilities identified during the emergency exercise. 10 CFR 950.47(1)(18)(10)(14)[ sic).

Asserted for bases are:

(a) Inadequate buses or Emergency Medical Service Vehicles (bus / driver pairs)

(b) RERP Rev. 2 does not correct exercise deficiencies (c) The special needs annual survey did not adequately identify spe-cial needs persons.

() (d) Bus routes are inadequate for the transit of dependent persons.

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TOWN OF HAMPTON V APPLICANTS' INTERROGATORIES

RESPONSE

(continued)

Applicants' Position is that RERP Revision 2 does not fail to meet NRC 10 CFR 50.47 regulations.

(a) Adequate bus / driver pairs have been identified to meet transpor-tation needs.

(b) Adequate emergency medical ambulance services are being identified for handicapped general public and institutionalized persons.

(c) An increase by 50% of special needs populations identified by the survey is provided to over-allow for transportation needs.

(d) Mobility impaired are identified and tests maintained prior to an emergency. Adequate transportation has been identified for the transit of dependent transients (bus routes or rider sharing).

KLD estimates only 24 of transients would require transportation assistance.

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(,,) b. Those documents which have not already been served on the parties prior to issuance of the Town of Hampton Interrogatories or specifically included with the response to interrogatory will be made available for inspection and copying at the Seabrook Station or at KLD's office.

Please contact Mr. William J. Daley at (603) 474-9252, extension 2057, to arrange for document inspection.

c. Persons on whose factual knowledge, opinions, or technical expertise the Applicants rely or presently intend to rely for their position on contentions that have been admitted are the following:

1. Richard Strome. Director (TOH Rev. III, TOH III, TOH IV. TOH Rev.

VI . T0:1 Rev. III)

New Hampshire Civil Defens'e Agency l 107 S. Pleasant Street Concord, NH 03301 l

2. William T. Wallace, Director (TOH-VIII)

Division of Public Health Services NH Department of Health and Human Services 6 Hazen Drive Concord, NH 03301 O

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-p TOWN OF HAMPTON k APPLICANTS' INTERROGATORIES I

RESPONSE

(continued)

3. Edward B. Lieberman, Vice President (TON Rev. III. TOH III, T0H IV. TOH Rev. IV)

KLD Associates 300 Broadway Huntington Station, New York 11746

4. Dennis S. Mileti (TOH Rev. III, TOH III, TOH IV TOH Rev. IV)

Associate Professor Department of Sociology Director, Hazards Assessment Laboratory Colorado State University Fort Collins, Colorado 80523

5. Anthony M. Callendrello (All Contentions)

Manager Emergency Planning Seabrcok Station P.O.' Box 300 Lafayette Road

() 6.

Seabrook, NH 03874 Paul Prechette. Technical Manager (All Contentions)

Seabrook Station P.O. Box 300 Lafayette Road Seabrook, NH 03874

7. John Baer, Consultant (All Contentions)

Seabrook Station P.O. Box 300 Lafayette Road Seabrook, NH 03874

d. Witnesses have not been selected.

TCH Revised Contention VI to Revision 2 contends that RERP Rev. 2 fails to demonstrate personnel are available to respond or to augment their initial response on a continuous basis in the event of radiological emergency.

10 CFR 5 50.47(b)(11)(10). Asserted for bases are:

(a) Inadequate local police to perform functions and (b) Inadequate State Police to backup local functions.

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O TOWN OF HAMPTON APPLICANTS' INTERROGATORIES .

RESPONSE

(continued)

Applicants' Position on TOH Revised VI is that RERP Rev. 2 meets regulatory requiremente (a) Adequate law enforcement personnel are available to carry out RERP Rev. 2 assignments.

(b) Local police functions are asserted by State personnel when necessary. Procedures exist for troops to receive personnel sup-port from other State Troops and agencies. Troop A IFO Representative initiates a call to State Police EDC liaison if additional troopers are needed from other parts of the state.

b. Those documents which have not already been served on the parties prior to issuance of the Town of Hampton Interrogatories or specifically included with the response to interrogatory will.be made available for inspection and copying at the Seabrook Station or at KLD's office.

Please contact Mr. William J. Daley at (603) 474-9252, extension 2057, O to arrange for document inspection.

c. Persons on whose factual knowledge, opinions, or technical expertise the Applicants rely or presently intend to rely for their position on contentions that have been admitted are the following:

1. Richard Strome. Director (TOH Rev. III, TOH III, TOH IV TOH Rev.

VI, TOH Rev. III)

New Hampshire Civil Defense Agency 107 S. Pleasant Street Concord, NH 03301

2. William T. Wallace, Director (TOH-VIII)

Division of Public Health Services NH Department of Health and Human Services 6 Hazen Drive Concord, NH 03301

3. Edward B. Lieberman, Vice President (TOH Rev. III, TOH III TOH IV. TOH Rev. IV)

KLD Associates 300 Broadway Huntington Station, New York 11746 O

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TOWN OF HAMPTON APPLICANTS' INTERROGATORIES-EESPONSE (continued)

4. Dennis S. Mileti (TOH Rev. III. TOH III, TOH IV. TOH Rev. IV)

Associate Professor, Department of Sociology Director, Hazards Assessment Laboratory Colorado State University Fort Collins, Colorado 80523

5. Anthony M. Callendrello (All Contentions)

Manager, Energency Planning Seabrook Station P.O. Box 300 Lafayette Road

.l.

Seabrook, NH 03874

6. Paul Frechette, Technical Manager (All Contentions)

Seabrook Station P.O. Box 300 O Lafayette Road Seabrook, NH 03874

7. John Baer, Consultant (All Contentions)

Seabrook Station P.O. Box 300 Lafayette Road Seabrook, NH 03874

d. Witnesses have not been selected.

TOH Revised Contention VIII to Revision _2 contends that Revision 2 fails to provide adequate emergency equipment, facilities or personnel to support an emergency response and fails to demonstrate that adequate protective responses can be laplemented in the event of radiological energency.

10 CFR 50.47(1)(8)(10).

i Asserted as basis therefore is that reasonable assurance has not been provided that adequate provisions have been made for the use of sheltering as a protective action for the beach population.

Applicants' position is whether sheltering facilities are physically L adequate is not an appropriate subject for litigation. What is valuable to decision makers is to know that facilities, if any, are available on which to base a decision to shelter or to evacuate in order to reduce doses L/063LS.I.8

I TOWN OF HAMPTON d APPLICANTS' INTERROGATORIES

RESPONSE

(continued) during potential passage of airborne radioactivity. There is no provision in 10 CFR 4 50.47, Part 50 Appendix E. NUREG-0654 or Annex E which requires construction of or individualized evaluation of buildings to determine their adequacy for sheltering. The protective action recommendations to be taken in the event of a radiological emergency shelter vs evacuation is based on the prognosis for the accident, time constraints and existing con-ditions. See NHRERP Rev. 2, Vol. 1, 2.6.5-2.6.11, Vols. 4 and 4A Appendices F and U respectively indicate evacuation for beach populations as the preferred protective action between May 15 and September 15 as time and circumstances allow.

b. Those documents which have not already been served on the parties prior-to issuance of the Town of Hampton Interrogatories or specifically included with the response to interrogatory will be made available for inspection and copying at the Seabrook Station or at KLD's office.

Please contact Mr. William J. Daley at (603) 474-9252, extension 2057, to arrange for document inspection.

c. Persons on whose factual knowledge, opinions, or technical expertise the Applicants rely or presently intend to rely for their position on contentions that have been admitted are the following:

1. Richard Strome, Director (TOH Rev. III, TOH III, TOH IV, TOH Rev.

VI, TOH Rev. III)

New Hampshire Civil Defense Agency 107 S. Pleasant Street Concord, NH 03301

2. William T. Wallace, Director (TOH-VIII)

Division of Public Health Services NH Department of Health and Human Services 6 Hazen Drive Concord, NH 03301

3. Edward B. Lieberman, Vice President (TOH Rev. III, TOH III, TOH IV TOH Rev. IV)

KLD Associates 300 Broadway Huntington Station, New York 11746 O

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TOWN OF HAMPTON APPLICANTS' INTERROGATORIES RESPONSE ,

l (continued)

4. Dennir S. Mileti (TON Rev. III, TOH III, TOH IV TON Rev. IV)

Associate Professor, Department of Sociology Director, Hazards Assessment Laboratory Colorado State University Fort Collins, Colorado 80523

5. Anthony M. Callendrello (All Contentions)

Manager Emergency Planning Seabrook Station P.O. Box 300 Lafayette Road Seabrook, NH 03874  !

6. Paul Frechette, Technical Manager (All Contentions)

Seabrook Station P.O. Box 300 Lafayette Road Seabrook, NH 03874

7. John Baer, Consultant (All Contentions)

Seabrook Station P.O. Box 300 Lafayette Road Seabrook, NH 03874

d. Witnesses have not been selected.

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l TOWN OF HAMPTON APPLICANTS' INTERROGATORIES (continued)

2. Please explain and provide the Data Base for each of.the following facts, statements, assumptions or conclusions'in the NHRERP Revision 2, and identify and provide reasonable access to all documents on which you rely to support your answers to this interrogatory:

a. That the number of persons comprising the Town of Hampton resident population is 13,234. Please define " resident population" and fully explain and provide _the Data Base for why this figure dif-fers from that used in prior drafts of the NHRERP and identify all personn included within this population figure.

+ b. That the number of persons comprising the Town of Hampton peak summer weekend population is 36,635. Please define " peak summer i

weekend population" and fully explain and provide the Data Base

' for why this figure differs from that used in prior drafts of the NHRERP and identify all persons included in this population figure,

c. That the number of persons comprising the Town of Hampton peak summer midweek population is 34,337. Please define " peak summer midweek population" and fully explain and provide the Data Base for why this figure differs from that used in prior drafts of the NHRERP and identify all persons included within this population figure.

d. That there will be a vehicle occupancy rate of 2.4 persons during an evacuation,

e. That ETE will be reduced by twenty (204) percent for rain,

f. That ETE will be reduced by twenty-five (25%) percent for snow.

g. That all roads will remain passable during evacuation.

i h. That recommended traffic control tactics will be in effect during an evacuation.

1. That there will be three thousand (3,000) "through" vehicles tra-veling through the EPZ at the time of the evacuation.

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TOWN OF HANPTON APPLICANTS' INTERROGATORIES (continued)

j. That twenty-five (25%) percent of the EPZ population will spon-taneously evacuate.

k. That evacuees will in fact evacuate to their assigned host com-munities.

1. That the bus drivers identified by Letters of Agreement, including the Teamsters, have the training and experience to evacuate the disabled, medically impaired, and student populations.

RESPONSE

a. The number of 13,234 residents for the Town of Hampton appears in NHRERP Volume 6, Table 2-1 on page 2-9. This figure was based upon the estimate of 13,000 residents provided by the Hampton Town Clerk in early 1985. This figure was projected forward to 1986 by O applying a growth rate of 1.8 percent which, in turn, was obtained by calculating the annual growth rates based on data for the years 1980 and 1985 provided by the State. The Applicants define resi-dent population in the same way as the Town Clerk of Hampton does.

Prior drafts of the NHRERP were compiled by others; the estimates in the current plan were developed independently from estimates in any other plan,

b. The estimate of persons occupying the Town of Hampton during a peak suaner weekend is 36,635. These persons are made up of per-manent residents, transients, and employees who are within the area on the weekend. As noted earlier, the resident population is 13,234. The number of emplcyees who are within the area and who will evacuate numbers 1,092. This last figure is 70 percent of the 1,560 employees for the Town of Hampton which are in the next l

to last column of Table 5-3 of Volume 6 of the NKRERP. The remaining number of 22,309 persons are those who are transients, i most of whom are in the Hampton Beach area. The definition of '

resident population is given in response to subpart (a). Also, refer to the answer to subpart (a) in connection with the dif-I ference between the figures in this report and the prior ones.

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TOWN OF HAMPTON (x-

\ APPLICANTS' INTERROGATORIES (continued)

RESPONSE

(continued)

The figure cited in the intr.rogatory reflects a mistyped sta-

~

c.

tistic in the Town Plan. Cne correct figure is 31,337. Of this number, the resident population comprises 13,234 persons, number of evacuating employees is 1,560, and the remaining population consists of transients, the vast majority of which are at the beach.

d. The premise of the interrogatory is incorrect. The occupancy rate of 2.4 persons per vehicle applies only to beach area traffic and other transients, not to resident traffic. Refer to discussion on page 4-8 of NRRERP Volume 6.

e. The premise of the interrogatory is incorrect. During rain it is estimated that the capacity of the highway system will be reduced by 20 percent which translates into an increase in ETE. Note the differences in evacuation time, for example, between Scenario 2 and Scenario 1. Also, refer to discussion on page 3-1 of NHRERP Volume 6.

f. The premise of the interrogatory is incorrect. The presence of snow reduces the capacity of the highway system by an estimated 25 percent. This reduction in capacity translates into an increase in ETE. Refer to the discussion on page 3-1 of NHRERP Volume 6, and compare the ETE for Scenario 7 with that of Scenario 5.

g. This is a postulate which is used as the basis for calculating the ETE.

h. The ETE assumes that traffic control measures will be in effect at the time the evacuation is ordered, based upon the high probabi-lity that 'there will be sufficient time between official notifica-tion to man TCPs and the public Order to Evacuate, allowing the traffic control personne1 to be mobilized and positioned.

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i. The primary routes servicing external-external trips through the Seabrook Station EPZ are the Interstate Routes 95 and 495. All other routes within the EPZ, which could be interpreted as through routes (e.g., Routes 1, 107, 108), are two-lane roads which are not relatively attractive to through travelers. About 160 lane-miles are'provided by these express routes:

(

o I-495: 2 miles G 4 lanes; 5 miles G 6 lanes

[ o I-95: 13 miles 9 8 lanes; 2 miles 9 6 lanes I

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TOWN OF HAMPTON APPLICANTS' INTERROGATORIES (continued)

RESPONSE

(continued)

The calculations of ETE for the summer scenarios assume that the accident takes place when the beaches are at maximum usage, roughly at 2:00 PM. When developing the inputs to the IDYNEV model, it was estimated that 3000 through vehicles, not otherwise counted, would be on the network at this time. This estimate was based an observations made while traveling the network.

Specifically, it appeared that volumes on I-95 and on I-495 were traveling at Levels of Service (LOS) that did not exceed LOS B or C. The associated range of density is 13-30 passenger cars per mile per lane. Thus, the total number of vehicles on these high-ways is between 2080 and 4800, many of which are not through vehicles. In a situation where access control is implemented prior to the Order to Evacuate (OTE), this estimate of 3000 through vehicles represents those who entered the EPZ prior to the implementation of access control and have not as yet completed their travel through the EPZ by the time the OTE is given. At that time, the number of through vehicles within the network could O be substantially less than the number which occupied the network at the time the access controls are applied.

Direct observations of traffic flow on these major routes at that time, supported by aerial films taken after the ETE calculations were undertaken on July 4 and 5, 1986 at approximately 2:00 P.M.,

indicate that traffic volume is very low - at LOS A and B. The associated range of traffic density is less than 20 passenger cars per mile in each lane.

Thus, based on these later observations, the total number of vehicles on these highways at this time is less than or equal to approximately 3200 passenger cars (20 x 180). Many of these cars, of course, belong to EPZ residents, tourists and employees who have already been counted. It is seen, therefore, that the estimate of 3000 through vehicles - not already counted -

is a conservative one.

Traffic on these highways during the off-season generally does not i exceed the volume associated with LOS C, regardless of time of day. Thus, the estimate of 3000 through vehicles is applicable j throughout the year.

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, TOWN OF HAMPTON APPLICANTS' INTERROGATORIES (continued).

RESPONSE

(continued)

-The NHRERP calls for access control points to be established at the periphery of the EPZ which will divert traffic from entering i the EPZ from points outside except, of course, those vehicles which will participate in the evacuation NHRERP (Volume 1, page 2.6-16).

J. The basis for the assumption on page 10-3 that 25 percent of' the population within the EPZ, but outside the region ordered to

evacuate, will spontaneously evacuate. contrary to instructions, is the substance of discussions held between Mr. Lieberman and Dr.

Dennis Mileti, a nationally renowned expert on the subject of

. human behavior during emergencies.

k. Two points within the ETE and NHRERP in general must be raised in response to this interrogatory.

1. The traffic control points are established to " facilitate evac-uating traffic movements which serve to expedite travel out of the EPZ along routes, which the analysis has found to be most

effective." (Volume 6, page 7-1) Hence, direction is provided throughout the EPZ along designated routes.

2. Once outside of the ETE, there is no mandatory requirement placed on individual citizens to report to a host community.

Reception centers are established for the evacuating public to provide " services for any evacuated population in need of public assistance (Volume 1, page 1.6-6). The EBS messages which advise evacuation provide information as to what services are available at the Reception Centers (Volume 4, page G-31 and page G-37). However, it is an option for evacuating persons to report to Reception Centers for assistance.

I 1. Bus drivers including the Teamsters pool and the ambulance drivers I receive appropriate training including an overview of the RERP and emergency response organization, notification, emergency classifi-cation levels, protective actions, location of staging areas, basic radiation concepts and radiological exposure control, including use of dosimeters (see NKRERP, Volume 1, Section 3.2).

The special needs of the disabled or medically impaired will be met by the use of EMS or Public Safety personnel escorting the drivers when and if needed.

Drivers involved in the evacuation of the student population

[

receive the training described above. School officials receive training as described in NHRERP, Volume 1. Section 3.2.

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TOWN OF HAMPTON p

't h APPLICANTS' INTERROGATORIES

' (continued)

3. ?rev.ae the total number. and the Data Base used to compute the following:

a. Town of Hampton peak beach penulation.

b. Town of Hampton transit dependent population.

c. Town of Hampton transient population.

d. Town of flampton school population, including pupils teachers and administrators.

e. Town of Hampton special needs population,

f. Vehicles to be evacuated from the Town of Hampton, including emergency vehicles, under each scenario identified by KLD in its ETE.

% g. For each population group identified.in interrogatories 3(al-(e),

number and provide the Data Base for each such group in the entire EPZ.

RESPONSE

a. The Town of Hampton peak beach population is given in the response to 2b and 2c.

J b. The Town of Hampton transit dependent population has been esti-mated by a survey conducted by New Hampshire Civil Defense Agency.

Their estimate for this group of evacuees is.664.

c. The Town of Hampton transient population for various scenarios is given in Appendix M of NHRERP, Volume 6, assuming a person per vehicle ratio of 2.4.

d. Based on data collected ~from schools in the Town of Hampton in 1986 and the Hampton School District Annual Report 1986-87, there are approximately 2,700 public and private school students, teachers. and administrators.

e. Based on the Hampton RERP, Volume 18,Section IV, Attachment 1 to Public Works Director's Emergency Procedure, the current special needs population figure for the Town of Hampton is 819.

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TOWN OF HAMPTON APPLICANTS' INTERROGATORIES

(continued)-

RESPONSE

(continued) l l

f. The. number of private vehicles evacuating from the Town of Hampton for each of the scenarios is given in Appendix M. The number of emergency vehicles needed for special facilities within Hampton is found in Volume 18A, at Appendix F Attachment B of the Seacoast Health Center Plan. .The number of special needs persons has been identified by the NHCDA Special Ha'p Needs Survey. The results of that survey are available through the NHCDA. Attachment 1 to the Public Works Director's Emergency Procedures in Volume 18 gives an overall listing of Hampton's transportation requirements. The number of busee required for the transit-dependent population, other than those in special facilities, is given in Table 11-7, Volume 6, and is equal to 8.

g. The peak beach population may be found in Table 2-2 on page 2-11.

This peak of 25,470 cars applies to the entire EPZ. The asso-clated number of persons may be found by multiplying by 2.4. The transit dependent population for the entire EPZ is given in Table 11-6 on page 11-10. The transient populations for the EPZ are given in the " roses" of Section 10 on Figures 10-6b, 10-7b, and 10-8b. The EPZ school population figures may be found as an attachment to the Emergency Procedures,Section IV of each local plan, under the appropriate EOC position. Special needs popula-tion for all towns have been identified by the NHCDA Special Help 1 Needs Survey. The results of this survey are available for inspection at the offices of the NHCDA.

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TOWN OF HAMPTON l

APPLICANTS INTERROGATORIES (continued)

4. Identify, describe, and provide the Data Base to support any change in the population figures, for each group identified in Interrogatory 83, between l

the NHRERP Revision 2 and all prior drafts of the NHRERP. l

RESPONSE

The latest population figures have been compiled as the result of indepen-dent studies made by KLD. There is no data base of the type requested.

O l

j L/063LS.4

TOWN OF HAMPTON APPLICANTS' INTERROGATORIES '

(continued)

5. Please identify and describe whether the NHRERP Revision 2 makes provi-sion to modify or provide alternative protective responses if the wind direction or weather should change during an emergency. _ Identify the relevant sections of the NHRERP and provide the Data Base to support your answer.

RESPONSE

The METPAC dispersion model, referenced in NHRERP, Volume 1 Section 2.5 and Volume 4A, Appendix N, provides for 15-minute incremental updates on current meteorological conditions, which will allow decision makers to modify protective action recommendations. NHRERP, Volume 4A, Appendix U,' instructs decision makers to consider extending protective actions to other areas of the EPZ based upon meteorological conditions.

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TOWN OF HAMPTON APPLICANTS' INTERROGATORIES (continued)

6. Please identify and describe whether the NHRERP Revision 2 addresses or otherwise makes provision for population growth within the EPZ. Identify rele-vant sections of the NHRERP and provide th- Data Base to support your answer.

RESPONSE

The NHRERP does not use population projections as a planning basis nor is this required by regulation or by planning guidance. The NHRERP, Volume 1 Section 3.3.3, describes how the Director, NHCDA, will ensure that the plan will be reviewed at least annually and kept current. Hampton RERP, Volume 18, page 3-8 assigns responsibility for annual review and revision of the Hampton RERP to the Civil Defense Director.

l L

O L/063LS.6

O TOWN OF HAMPTON i

APPLICANTS' INTERROGATORIES (continued)

7. Please identify and describe whether^ sheltering may be used as a pro-tective* response for any population group or groups between May 15th and September 15th of each year. Identify and explain whether sheltering during said time period will be utilized or relied on in any manner to satisfy the cri-teria for licensing set forth in 10 CFR 5 50.47(a)(1). Provide the Data Base to support your answer.

RESPONSE

The NHRERP, Volume 1 Section 2.6.5 describes the use of sheltering as a

() protective measure. Sheltering will be utilized as a protective action option available to decision makers for any population group during any time of the year as time available to decision makers and accident conditions would dictate.

NHRERP, Volumes 4 and 4A, Appendices F and U respectively, indicate evacuation for beach populations as the preferred protective action between May 15 and September 15 as time and circumstances allow.

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TOWN OF RAMPTON

' U[) .

APPLICANTS' INTERROGATORIES *

(continued) l 8. With respect to the Compensatory Plan, please identify, describe. and k

provide the Data Base, for the following:

a. All personnel, identified by title and position: equipment; evac-uation and emergency vehicles; and all other resources of whatever kind or description, which Applicant believes are available to carry out the Compensatory Plan, in the event a municipality or municipalities are unable or unwilling to implement the NHRERP.

b. The present location of the each person, vehicle, item of equip-ment or resource identified in Answer 88(a).

c. The name, title, and position of every school teacher, administra-tor, or other school official who has volunteered to carry out NHRERP duties, and identify, describe, and provide the complete Data Base in support of your answers.

The name, title, and position of any medical, special needs or

) d.

health care facility staff, employees, or administrators, including any person employed at the Seacoast Health Center, who have volunteered to carry out any NHRERP duties, and identify, describe, and provide the Data Base in support of your answer.

RESPONSE

a. The specific State agencies that would provide assistance to local comaunities are identified in NHRERP, Volume 2. Appendix G. The number of personnel and the equipment available to provide assistance are identified in the applicable agency procedures in NHRERP, Volumes 4 and 4B. The Traffic Management Manual of the State of New Hampshire identifies numbers of law enforcement per-sonnel available for assistance.

b. Applicants do not know the answer to this interrogatory.

c. Objected to as being beyond the scope of an admitted contention.

The interrogatory has no regulatory basis,

d. Objection, see c. above.

L/063LS.8

TOWN OF HAMPTON

([}

APPLICANTS' INTERROGATORIES (continued)

9. Identify and describe all corrective actions of whatever kind under-taken by, or on behalf of Applicant with respect to the deficiencies identified by FEMA in its Final Exercise Assessment. February 26, 1986. Identify and describe all such deficiencies, or any deficiencies identified by FEMA at any time, which Applicant believes still require corrective action and the nat'ure of such corrective action, which Applicant intends to undertake.

RESPONSE

Corrective actions undertaken, or intended to be undertaken, by the State

() of New Hampshire with assistance from Applicants, with respect to deficiencies identified by FEMA in its Final Exercise Assessment. February 26, 1986, are identified and described in the work plan provided to the FEMA /RAC on July 1, 1986. New Hampshire Response Actions to RAC Review of State and Local Radiological Emergency Response Plans, August 1986, transmitted to FEMA on September 8, 1986, incorporates responses to the Final Exercise Assessment into the State responses to FEMA /RAC comments.

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1

TOWN OF HAMPTON

(~}

V APPLICANTS' INTERROGATORIES (continued).

10. Identify and describe all corrective actions of whatever kind under-taken by, or on behalf of. Applicant with respect to the RAC comments and recom- l mendations in RAC REVIEW OF THE STATE OF NEW RAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR SEABROOK. Identify and describe any such RAC comments or recommendations, or comments or recommendations made by RAC at any time, which Applicant believes still require corrective action and the nature of the correc-tive action that Applicant intends to undertake.

RESPONSE

Corrective actions undertaken, or intended to be undertaken, by the State of New Hampshire, with assistance from Applicants, are identified and described (v) in the following documents:

a. Work Plan submitted to the FEMA /RAC by the State of New Hampshire on July 1, 1986.

b. New Hampshire Response Actions to RAC Review of State and Local Radiological Emergency Response Plans - August 1986, transmitted to FEMA September 8, 1986.

c. Draft State Response to the Review of the State of New Hampshire Radiological Emergency Response Plan for Seabrook (Rev. 2, 8/86).

l I

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TOWN OF HAMPTON

\

\ APPLICANTS' INTERROGATORIES (continued)

11. Identify and produce for inspection and copying at the offices of Shaines & McEachern, P.A., 25 Maplewood Avenue. Portsmouth, New Hampshire 03801, all documents upon which you rely to support your answers to interrogatories 1 through 10.

RESPONSE

Those documents which have not already been served on the parties prior to issuance of Town of Hampton's interrogatories or specifically included with the response to an interrogatory will be made available for inspection and copying at the Seabrook Station or the KLD office in Huntington Station, NY. Please

_/N contact Mr. William J. Daley at (603) 474-9252, extension 2057, to arrange for i

document inspection.

O L/063LS.11

e NASS ATTORNEY GENERAL U APPLICANTS' INTERROGATORIES

1. Describe in detail your positloa with respect to each contention to be litigated by the Attorney General and each subpart of each such contention.

Describe in detail the reasons for your position.

RESPONSE

Applicants incorporate by reference their answers to: TOH Interrogatory 1(a) to Applicants in respect to TOH Revised Contention III, TOH Revised Contention VI and TOH Revised Contention VIII; NECNP General Interrogatory 2 to Applicants in respect to NECNP Contention RERP-8; SAPL General Interrogatory A(b) to Applicants in respect to SAPL Revised Contention 31, Reasserted SAPL Contention 8, SAPL Contention 8a, Reasserted SAPL Contention 18, SAPL Contention 33, and SAPL Contention 34.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

2. Identify and produce all documents on which you have relied, do rely, or will rely to support your position on each of these contentions. Identify the information in each document on which you have relied, do rely, or will rely and the specific subpart of each contention which that informati'en concerns.

RESPONSE

Those documents which have not already been served on the parties prior.to issuance of the MASS AG interrogatories or specifically included with the response to an interrogatory will be made available for inspection and copying at the Seabrook Station or at KLD's office. Please contact Mr. William J. Daley at (603) 474-9252, extension 2057 to arrange for document inspection.

f L/065LS.2

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) l

3. Statewhetheryouhaverelied,dorely,orwillNelyonanystudy, I

calculation, or analysis to support your position on each of these contentions.

l If so, please: -

a. Describe the nature of the study, calculation or analysis and O' identify any documents that discuss or describe the study, calcu-lation or analysis;

b. Identify the persons who performed the study, calculation or.

analysis;

c. State when and where the study, calculation or analysis was performed;

d. Describe in detail the information or data that was studied, calculated or analyzed;

e. _ Describe the results of the study, calculation or analysis;

f. Explain how such study, calculation, or analysis provides support for your position on each of these contentions.

RESPONS5 Any studies, calculations or analyses on which the Applicants currently intend to rely on have been identified in the response to interrogatories t hereinafter. Applicants reserve the right to use such additiona? pertinent i

documents if and when they become available.

L/065LS.3 i'

\

MASS ATTORN3Y GENERAL

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. APPLICANTS' INTERROGATORIES (continued)

T s

4. Do you intend to offer the testimony of any expert' witness with-If so, 4 , respect to any contention to be litigated by the Attorney Gene'ral?

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l please: s J s 4[= ,,

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$a.  ; identify each expert witness who you intend to present with respect to each subpart of each such contention';c 4 b. State the substance of the facts to which each expert witness is

[' expected to testify;

c. State the substance of the opinion or opinions to which each e.ypertwitnessisexpectedtotestify;

d. .Qrovideasuamaryof.tNegroundsforeachopiniontowhicheach expert witness is expected to testify; State whether the facts and opinions listed in response to the O e.

' foregoing are conta!6rd in any document; a

f. State whether the opinion of any expert witness is based in whole

- or in part on any scientific rule or principle, and, if:so, set forth such rule or principle;

g. ; State whether the opinion of any expert witness is based in whole or in part on any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon; and

h. State whether the opinion of any expert witr.ess is based in whole or in part upon any scientific or engineering book or other publi-cation, and, if so, identify the book or publication.

RESPONSE

Witnesses have not been selected. ,t W:

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s L/065LS.4

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c. MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES ,

(continued)

5. Do you intend to offer the testimony of any non-expert witness with respect to any contention to be litigated by the Attorney General? If so. l please:

a. Identify each non-expert witness who you intend to present with respect to each subpart of each such contention;

b. State the substance of the facts to which each non-expert witness is expected to testify; and

c. State whether the facts listed in response to the foregoing are contained in any document, and produce the same.

RESPONSE

O Witnesses have not been selected.

O L/065LS.5

MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

6. Identify and produce all documents in which you or any agent on your behalf have assessed the adequacy of state and local emergency plans with respect to any contention to be litigated by the Attorney General. Include in your response any documents concerning steps which have been taken or will be taken by the State of New Hampshire or the Applicants to address inadequacies in any past or currect local plans.

RESPONSE

The documents which assess the adequacy of state and local emergency plans are as follows:

gs a. FEMA technical review of New Hampshire's draft State and local

() planning for Seabrook, dated June 27, 1985.

b. FEMA /RAC review of the December, 1985 submission of the New Hampshire State Plans, dated April 30, 1986.

c. Draft RAC review of February, it 4 submissions by New Hampshire, dated April 30, 1986.

d. FEMA /RAC review of the New Hampshire submissions of February, 1986 and draft FEMA /RAC review of the New Hampshire' submission of April 16, 1986 dated June 2, 1986.

e. FEMA /RAC comments on the NHRERP changes submitted to FEMA on April 30, 1986 (transmitted to NHCDA under copy of the August 8, 1986 letter from Edward Thomas to Richard Strome).

f. FEMA /RAC review of Revision 2 of the NHRERP of August 1986, dated December, 1986.

g. Final Report, Independent Review of the Seabrook Station Emergency Preparedness Program, prepared for New Hampshire Yankee Division by the Independent Review Team, dated October, 1985.

h. IRT Report 8030 transmitted via IRT-86-024 dated 2/13/86, subject:

Offsite Emergency Plans.

O- Applicants incorporate by reference their response to Interrogatory 2.

L/065LS.6

MASS ATTORNEY GENERAL O

APPLICANTS' INTERROGATORIES (continued)

7. Are peak summer day evacuation time estimates for the populations within two miles, five miles and ten miles of the Seabrook plant longer than the average two-mile, five-mile, and ten-mile EPZ evacuation time estimates for nuclear power plants in this country?

RESPONSh This interrogatory is objected to. To begin with it is not relevant or reasonably designed to seek information which would be relevant to any conten-tion admitted in the proceeding. The Commission has made patently clear that f- the regulations do not, and were never intended, to set some absolute level of t

safety to be attained at all sites. As the Commission recently stated in a Notice of Rulemaking:

"The existing emergency planning regulation does not require that plans achieve any pre-established minimum dose savings in the event of an accident.

For example, approved emergency plans with full state and local governmental cooperation have highly variable evacuation time estimates ranging from several hours to over ten hours and the projected dose savings for such plans would very widely. Thus the regulation is inherently variable in effect and there are no bright-line, mandatory minimum projected dose savings or evacuation time limits which could be viewed e.s performance stan-dards for emergency plans in the existing regula-tions." Proposed Rule. Licensing of Nuclear Power Plants where State and/or Local Governments Decline to Cooperate in Offsite Emergency Planning. Fed Reg. 52 FR 6980 (March 6, 1987). (Emphasis Added.)

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See also, Long Island Lighting Company (Shoreham Nuclear Power Station, CLI-86-13, 24 NRC 22 (1986); Southern California Edison Company (San Onofre Nuclear Power Station,-Units 1 and 2), CLI-83-10, 17 NRC 528, 533 (1983). In short any comparison of the Seabrook site with any other site for any purpose is wholly irrelevant to any emergency planning issue. The objection should be sustained on that ground.

In addition, this interrogatory requires the Applicants to do analyses which they have not done and would have no reason for doing themselves for any pur- f pose. As a result the interrogatory is objected to as burdensome and no answer should be required for this separate and wholly adequate reason. Pennsylvania Power & Light Co. ( Susquehanna Steam Electric Station, Units 1 and 1),

ALAB-613, 12 NRC 317, 334 (1980)

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O L/065LS.7.1

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O APPLICANTS' INTERROGATORIES (continued) )

8. Please provide the names of all nuclear power plants that have longer evacuation time estimates for populations located within two miles, five miles or ten miles of those plants than does the Seabrook reactor. Include those o

respective time estimates for each plant.

RESPONSE ,

Objection. Same as Interrogatory No. 7.

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L/065LS.8

MASS ATTORNEY GENERAL O APPLICANTS' INTERROGATORIES (continued)

9. Is population density greater for the areas within two alles, five  !

miles, and ten miles of the Geabrook plant than the average population densities l for areas within two miles, five miles and ten miles of all other nuclear reac-l tors in this country?

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l

RESPONSE

Objection. Same as Interrogatory No. 7.

O P

O L/065LS.9

NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES *

(continued)

10. Please provide the names of all nuclear power plants in this country that have higher population densities in the areas within two miles, five miles-or ten miles of the plants than does the Seabrook reactor.

RESPONSE

Objection. Same as interrogatory No. 7.

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NASS ATTORNEY GENERAL

. APPLICANTS' INTERROGATORIES (continued) I

11. Is there a larger summer transient population within two miles, five miles or ten miles of the Seabrook plant than there is with two miles, five alles, or ten miles of all other operating reactors in this country?

RESPONSE

Objection. Same as Interrogatory No. 7.

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I

.V[] MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 1 I

l

12. Please identify all nuclear power plants in this country that have a larger summer transient population than does the Seabrook plant for the areas located within two miles, five miles, or ten miles of the plant, and for each of those reactors indicate what provisions, if any, have been made to shelter the transient population; where such population is situated with respect to that reactor; the average dose reduction factor of shelters used for that population; evacuation time estimates for that population if it were to be evacuated; the location with respect to the transient population of any sheltering they will be expected to use: whether that population is predominantly a beach population:

( whether sufficient siteltering capacity exists to shelter the entire transient population; and if s'ufficient capacity does not exist to enable the sheltering of the entire population, state for what percentage of the population sufficient sheltering capacity exists.

RESPONSE

Objection. Same as Interrogatory No.7.

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=4 NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) i

13. Will emergency planning for the area within ten miles of the.Seabrook- l l

plant effectuate less " dose reduction" than the average dose reduction for all

-other nuclear plants in this country, assuming comparable radiological releases in the event of an accident?

RESPONSE.

Objection. Same as Interrogatory No. 7.

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

14. Compare the average dose reduction expected to be effectuated for the summer transient beach population within ten miles of the Seabrook plant to the average dose reduction expected to be effectuated for persons within ten miles

! of all other reactors in this country, assuming comparable radiological releases in the event of an accident.

RESPONSE

Objection. Same as Interrogatory No. 7.

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. . . _ _ , ~ . . . _ _ . . - . , _ - _ _

NASS ATTORNEY GENERAL ~

APPLICANTS' INTERROGATORIES *

(continued)

15. Please provide the basis for your response to interrogatories 13-14 and any documents relevant to your responses.

RESPONSE l Objection. Same as Inte;rogatory No. 7 I 4* . cf

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MASS ATTORNEY GENERAL

.O APPLICANTS' INTERROGATORIES (continued)

16. Do homes within the Seabrook ten-mile EPZ have on the average a lower dose reduction factor than do homes around all other nuclear reactors in this country?

RESPONSE

Objection. Same as Interrogatory No. 7.

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L/065LS.16

MASS ATTORNEY GENERAL (q.,)_

APPLICANTS' INTERROGATORIES *

(continued)

20. Did you pay KLD Associates, or Edward Lieberman, or any employee of KLD Associates any money after January 1. 1985. for any reason other than as payment for conducting the ETE study? If so, detail the amounts, to whom, and the reasons for these pasments. Identify and produce all documents, including contracts, which relate to these payments.

RESPONSE

No. All payments made to date are for activities associated with the ETE i

study. Some of these payments involved activities other than the original con-duct of the study such as responding to RAC comments on the ETE study. In addi-(

tion, other services including assistance in responding to interrogatories have been performed by KLD. Some billings have not yet been invoiced.

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1 L/065LS.20

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) i

$- .21. State whether any employee or agent of yours communicated orally during the period from January 1, 1985, through September 1, 1986, with Edward B. Lieberman or any other officer, agent, employee or person acting or pur-porting to act on behalf of KLD Associates.

RESPONSE

Yes.

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L/065LS.21

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l NASS ATTCKNEY GENERAL d APPLICANTS' INTERROGATORIES (continued)

22. If you answer the previous interrogatory affirmatively, as to each communication:

a. state whether made in person or by telephone;

b. state the date and place;

c. state the content of the communication as disclosed in any cor-porate or internal record;

d. identify each person who part icipated in the communication or who had knowledge thereof;

e. identify and produce each document referring or relating to the subject matter of subparagraph (c) hereof.

RESPONSE

Corporate records do not exist documenting the oral communications between the Applicants or their agents and KLD. While Applicants do acknowledge that such communications did occur they are unable, for each communication, to respond in the detail requested by paragraphs (a) - (e).

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES

• I (continued)

23. Identify and produce each document passing between any employee or agent of yours and Edward B. Lieberman or any other officer, agent, employee or other person acting or purporting to act on behalf of KLD Associates during the period from January 1, 1985, to September 1, 1986, referring or relating in any way to terms and conditions of payment to Mr. Lieberman or KLD Associates for conducting an ETE study; instructions, guidance, criticisms, or suggestions to Mr. Lieberman or KLD Associates in conducting an ETE study or in drafting Volume 6 of the NHRERP-Revision 2: data supplied to Mr. Lieberman or KLD Associates having anything to do with the ETE study; or inquiries or reports from Mr.

Lieberman or KLD Associates regarding any aspect of the ETE study.

RESPONSE

a. For contractural matters - see response to Interrogatories Nos. 19 and 20.

b. The Applicants have no documents which provided instructions, guidance, criticisas or suggestions to KLD regarding the matters of the interroga-tory.

c. A review of our files identified four letters (Attachments 23-1, -2, -3,

-4) which were mailed to the Applicants or NHCDA with a copy to the Applicants. All other correspondence in our files was mailed to MCDA, In regard to document production of correspondence other than that attached the Attorney General should contact MCDA.

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ATTACIDENTS 23-1 KLD ASSOCIATES INCORPORATED 300 BROADWAY HUNTINGTON STATION, NY 11746 (516) 549-9803 March 3, 1986 Mr. Tony calandrello Seabrook Station Nucreal Power Plant c/o Education Center Seabrook, NH 03874

Dear Mr. Calandrello,

Enclosed are three copies of a Preliminary Edition of Progress Report No. 6 entitled,

" Evacuation Plan Update for Seabrook Station" We will shortly conduct a field curvey of these proposed Access Control Posts in order to describe them in greater detail.

Yours truly, ry Edward Lieberman, P.E.

Vice President EL:ab Encl.

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ATTACIDENTS 23-2 KLD ASSOCIATES INCORPORATED 300 BROADWAY HUNTINGTON STATION, NY 11746 (516) 549-9803 April 11, 1986 l

l Mr. Tony Calandrello Seabrook Station Nuclear Power Plant c/o Education Center Seabrook Station Nuclear Power Plant Seabrook, NH 03874

Dear Tony,

I noticed, after the fact, that Table 42 was omitted from Progress Report No. 7. This Table is enclosed.

Please excuse this oversight.

Edward Lieberman i Vice President EL:ab Encl.

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ATTACIDENTS 23-3 KLD ASSOCIATES

(<-j> INCORPORATED 3% BROADWAY HUNTINGToN STATION, NY 11746 (516) 543-9803 May 30, 1986 Mr. Michael M. Nawoj, Director -

Technological Hazards Division New Hampshire Civil Defense Agency State Office Park South 107 Pleasant Street Concord, NH 03301 RE: Telecon of 26 May, 1986

Dear Mike,

The purpose of this letter is to outline the differences between the draft Final Report entitled, Seabrook Station I. Evacuation Time Estimates and

. Traffic Management Plan Update which was published 1 May 1986, and the seven Progress Reports which were published in sequence from November 1985 through April 1986.

As noted in the Preface of the draft Final Report, these differences reflect editorial changes and extensions. None of these changes, in our view, substantively impacts the contents of these Progress Reports. We indicate the relationship between the draft Final Report and the earlier Progress Reports in the following text.

Section 1 Text was added to provide a more complete description of the EPZ -- see Section 1.2. The General Highway Map was extended to show the EPZ boundary and Figure 1-2 was added to provide an overview of the geographical region around Seabrook Station.

Table 1-1, providing climatic information was also added.

Section 1-3 presented an overview of the activities performed so as to orient the reader. Figure 1-3 is new and presents the

(""}

(_/ evacuation network, showing the direction of evacuating traffic;

-_ . _ . _ ___ ___ __.__ . _ _ . _ _ _ _ _ _ ~ . . _ _ _ _ _ _ _ _ _ _ _ _ .

h - < -- =+-a a-s - e .u .s+-s x --- - - a - - - .m.-. > .a Page 2

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all origin centroids,. links and nodes; all communities and their boundaries and all ERPA boundaries; as well as the 2, 5 and 10-mile circular areas centered at Seabrook Station. This. map, in color, serves as a valuable reference for the reader.

Section 2 This section is'a direct copy of Section 4 of Progress Report- ~

No. 1. The lone exception is the removal of the subsection on-f- Manufacturing and Industrial Employment which was obsoleted by information received subsequently and documented in Progress Report No. 2.

, Section 3 This section is a direct copy of Section 5 of Progress Report-No. 1. We added Table 3-1 in response to a request by FEMA. The sub-section on recommended highway improvements was added as L suggested in NUREG 0654. A sub-section on ocean fog was added.

Section 6 of Progress Report No. I was discarded as it was obsoleted by later studies.

Section 4 1

This section is a direct copy of Section 8 of Progress Report i No. 2.

Section 5 This section is a direct copy of Section 9 of Progress Report No. 2.

Section 6 f

This section is a direct copy of Section 9 of. Progress Report No. 2.

4

{ Section 7 This section is a direct copy of Section 11 of Progress Report No. 2. One paragraph was omitted and some text was ,

changed to indicate that these controls were no longer i " preliminary". ,

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Page 3:

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$1Q14.on 8 l This section is a concatenation of Sections 16 and 17 of

. Progress Report No. 4, suitably-updated to reflect comments by police chiefs of communities within the EPZ. The discussion of n evacuation route signing was extended to provide for an

- alternative to permanent installations.

Section 9 This section is a direct copy of Section 21 of Progress

, -~ Report No. 6.. The ACP within Newington just south of Pease AFB was removed as it was considered to be unnecessary by N.H. State Police. Those TCP within the EPZ which would also serve as ACP under specific circumstances, were identified in a new Table 9-5.

b Section 10 ,

This section synthesites the contents of Progress Reports l Nos.~3 and 5. The sensitivity studies in Section 14 of Progress e Report No. 3 which dealt with Scenarios 11 were discarded. The

.results obtained for these scenarios indicted that the implementation of additional controls would not yield benefits in

. the form of significantly reduced ETE and would consume personnel

resources which would likely be more effective elsewhere. The other sensitivity study results were retained.

The bulk of this section is a direct copy of Section 19 of Progress Report No. 5. Additional sensitivity studies addressed l the prospect of an "Immediate" General Emergency, as compared

with the Planning Basis which asserts a time lag of 25 minutes between the sounding of the sirens and the order to Evacuate.

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! The " roses" of Figures 32 through 41 in Progress Report No. 5 1 were reviewed and refined. Any changes in the numerics were extremely small and not at all substantive, with one exception:

) on some roses, the demand associated with the Seabrook '

(greyhound) Park was inadvertantly omitted.

Table 10-10 includes the ETE for the Special Population grouping and the Confirmation Time.

Section 11 This section is a direct copy of Section 23 in Progress

Report No. 7, with some editorial changes. Tables 32 in Section 23 were moved into Section 10 of the draft Final Report.

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Page 4 0

Sections 12 and 13 These sections are direct copies of Section 24 and 25, respectively, of Progress Report No. 7.

Other other changes are editorial in nature. Changes in text were designed to correct typo errors and to clarify communication with the reader.

I trust the above summary is responsive to your request. If you have any questions, let me know.

Yours trul.y,

=-/

f}kJkEM l Edward Lieberman, P.E.

Vice President EL:ab ec: T. Calandrelle B. Hausner O

ATTACHMENTS 23-4

,r g KLD ASSOCIATES INCORPORATED 300 BRO ADWAY HUNTINGTON STATION, NY 11746 (516) 549-9803 June 4, 1986 Mr. Michael M. Nawoj, Director -

Technological Hazards Division New Hampshire Civil Defense Agency State Office Park South 107 Pleasant Street Concord, NH 03301

Dear Mike:

Under separate cover we are sending 56 copies of a revised draft final report. These revisions are an enhancement of the earlier draft which contains some additional information requested by FEMA and some additional editing to improve the quality of the writing in a few sections. -

O' v

These revisions contain no changes in the ETE or in the der and estimation or capacity estimation, relative to the first draft. There has been some refinement in the statistics in the roses (Figures 10-5 through 10-14b) but these changes are not substantive. We have also added better reproductions of the colored maps.

If you have any questions, please let me know.

Yours truly, k D.1[.l $ h ^' W '*p L Edward Lieberman, P.E.

Vice President EL:ld cc: T. 6 B. Hausnor l

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

I

24. Identify and produce each document, not identified in response to prior interrogatories, that evaluates or discusses the adequacy, reliability, or the sensitivity of KLD's ETE study or any aspect or subpart of this study.

l RESPONSE l To '.r.: best of Applicants' knowledge, KLD Associates, Inc. has cor. ducted the following sensitivity analyses subsequent to publication of NHRERP, Rev. 2:

1. Sensitivity analysis of the effects of major road blockages on ETE.

2. Sensitivity analysis of the effects of non-compliance of evacuees with O evacuation route instructions.

3. Sensitivity analysis of the effects of different levels of spontaneous evacuation on ETE.

4. Applicants incorporate by reference the response to Interrogatory 82 for production of documents.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

25. Do you support the KLD finding that, at mid-day with good weather on a summer weekend in 1987 when the beach area population is at its highest expected levels, and assuming that the evacuation of the beaches begins 20 minutes before a general order to evacuate the entire EPZ is given, the entire population within the entire EPZ can in fact be evacuated within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 15 minutes after the general order to evacuate is given? If you do support this finding, state all reasons why you believe this finding is accurate, identifying all experts, other persons, and documents upon which you rely. If you do not agree with or support this KLD finding, state how long you contend such an evacuation would take, and identify all experts, other persons, and documents upon which you rely.

RESPONSE

Yes. Refer to NHRERP Volume 6, Section 10 for information supporting this position. (Note that the Introduction in Volume 6 specifies that the estimates were prepared for data available in the 1986 timeframe. The Applicants believe that this data is representative for the 1987 timeframe requested). The Applicants rely solely on the information in Volume 6 for this conclusion.

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NASS ATTORNEY GENERAL

%/ APPLICANTS' INTERROGATORIES *

(continued)

26. How long would an estimated evacuation time for the entire EPZ in the manner assumed in the previous interrogatory, have to be before you would agree that adequate protective measure cannot be taken to protect the public health and safety? State your reasons in detail for this answer, and identify all experts, other persons, studies and documents upon which you rely.

RESPONSE

This interrogatory is objected to. As pointed out in our objection to Interrogatory No. 7, the Commission has made it clear that: "there are no bright-line, mandatory minimum projected dose savings or evacuation time limits which could be viewed as performance standards for emergency plans in the existing regulations",

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

27. Do you contend that the NHRERP-Revision 2, as drafted and dated August 1986, without further revision, meets the standard contained in 10 C.F.R 9 50.47(a) that emergency plans be adequate for the NRC to find "that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency"?

a. If your answer is "no," state what revisions in the plan are necessary to meet this standard and whether these revisions have been made.

b. State what responses you (1) have taken, and (ii) intend to take, prior to the off-site EP hearings to respond to the inadequacies identified in the FEMA /RAC Review of Revision 2 of the NHRERP.

RESPONSE

Yes,

a. Not Applicable

b. Proposed corrective actions intended to be undertaken in response to FEMA /RAC comments on NHRERP, Revision 2, are described in Draft.

State Response to the Review of the State of New Hampshire Radiological Emergency Response Plan for Seabrook (Rev. 2, 8/86).

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NASS ATTORNEY GENERAL w

s APPLICANTS' INTERROGATORIES (continued)

28. Assuming an accident when beaches are at or near capacity and assuming implementation of Revision 2 of NHRERP, do you contend that KLD's ETE study demonstrates that evacuation times are short enough to prevent all fatalities among members of the beach population under all accident sequences? If not, state how many early fatalities would occur, and specify under which accident sequences these fatalities would occur.

RESPONSB This interrogatory is objected to. As pointed out in our objection to Interrogatory No. 7 the Commission has made it clear that: "there are no

(

bright-line, mandatory minimum projected dose savings or evacuation time limits which could be viewed as performance standards for emergency plans in the existing regulations". Furthermore until the questioner describes the accident to be assumed and numerous other parameters, such as wind direction etc. It is impossible to answer the question.

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p MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) l l

29. Do you contend that the number of early fatalities likely to be caused by a serious radiological emergency at the Seabrook plant is not a relevant fac-tor in determining whether there is " reasonable assurance that adequate protec-tive measures can and will be taken in the event of a radiological emergency"?

Explain your answer. If there is a limit to the number of likely early fatall-ties beyond which you would agree that an evacuation plan does not offer such

" reasonable assurance," state that limit.

RESPONSE

Objection. As stated earlier with respect to Interrogatories 7 and 28, there simply are, as a matter of law, no mandatory minimum dose savings to be achieved. Thus as a matter of law, there is no basis for inquiring as to what level of radiological dose or consequences from assumed dose must be exceeded i

before plans would be deemed inadequate for a given event. Furthermore the question as phrased is impossible to answer until such time as the questioner defines precisely what " serious radiological emergency" is to be assumed and the parameters, such as weather and wind direction, which are to be assumed as of the time the " emergency" occurs.

O L/005LS.29

NASS ATTORNEY GENERAL (3

APPLICANTS' INTERROGATORIES (continued)

30. On what basis does KLD estimate (Vol. 6, pg. 2-27) or assume (Vol. 6, pg. 10-3) that there will be 3000 vehicles traveling through the EPZ when an Alert is announced? Identify all experts, other persons, and documents including aerial photos, upon which KLD relied in making this estimate or assumption.

RESPONSE

The primary routes servicing external-external trips through the Seabrook Station EPZ are the Interstate Routes 95 and 495. All other routes within the EPZ, which could be interpreted as through routes (e.g., Routes 1, 107, 108), are two-lane roads which are not relatively attractive to through travelers.

About 160 lane-miles are provided by these expreca routes:

o I-495: 2 miles 9 4 lanes; 5 miles 9 6 lanes o I-95: 13 miles 9 8 lanes; 2 miles 9 6 lanes The calculations of ETE for the summer scenarios assume that the accident takes place when the beaches are at maximum usage, roughly at 2:00 PM. When

)

developing the inputs to the IDYNEV model, it was estimated that 3000 through j i

vehicles, not otherwise counted, would be on the network at this time. This estimate was based on observations made while traveling the network. Specifically, it appeared that volumes on I-95 and on I-495 were traveling at Levels of Service The associated range of density is 13-30 (LOS) that did not exceed LOS B or C.

passenger cars per mile per lane. Thus, the total number of vehicles on these highways is between 2080 and 4800, many of which are not through vehicles.

L/065LS.30 l

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Of course. this estimate of 3000 through vehicles represents those who entered the EPZ prior to the implementation of access control gnd have not as yet completed their travel through the EPZ by the time the Order To Evacuate (OTE) is given. At that time, the number of through vehicles within the network could be substantially less than the number which occupied the network at the time the access controls are applied. Thus, it is seen that the number of external-external vehicles on the EPZ network at the OTE should not exceed the 3000 estimate, and may be substantially less.

Direct observations of traffic flow on these major routes at that time, supported by aerial films taken after the ETE calculations were undertaken, on July 4 and 5, 1986 at approximately 2:00 P.M., indicate that traffic volume is very low - LOS A and B. The associated range of traffic density is less than 20 passenger cars per mile in each lane.

Thus, based on these later observations, the total number of vehicles on these highways at this time is less than or equal to approximately 3200 passenger passenger cars (20 x 160). Many of these cars, of course, belong to EPZ residents, tourists and employees who have already been counted. It is seen, f

therefore, that the estimate of 3,000 through vehicles -- not already counted --

is a conservative one (i.e., on the high side).

Traffic on these highways during the off-season generally does not exceed i

l the volume associated with LOS C, regardless of time of day. Thus, the estimate

]

1 of 3,000 through vehicles is applicable throughout the year.

1 The NHRERP calls for access control points to be established at the per-j 1phery of the EPZ which will divert traffic from entering the EPZ from points

! outside except, of course, those vehicles which will participate in the evacu-ation NHRERP (Vol. 1, 2.6-16).

L/065LS.30.1 f

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O NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

31. In computing ETE's was the IDYNEV System programmed to assume that there were 3000 vehicles traveling through the EPZ at the time of an Alert? If so, describe in detail the distribution of these vehicles inside the EPZ which the modsl was programmed to assume.

RESPONSB No. The model was not " programmed to assume that there were 3000 vehicles i

traveling through the EPZ at the time of an Alert." The inputs to the model were designed to generate 3000 vehicles traveling through the EPZ at the time of an Alert. These vehicles would be moving evenly along evacuation paths at the time of the Alert.

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MASS ATTORNEY GENERAL

[

APPLICANTS' INTERROGATORIES (continued)

32. Identify the aerial films mentioned on pg. 10-16 of Volume 6 of NHRERP-Revision 2 by stating when they were taken, by whos. and who has this film. Produce this film.

RESPONSE

The films were taken by Lowry Aerial Photography Service in August 1985 and are in the possession of KLD. The film will be made available for inspection at KLD's offices (see response to interrogatory No. 2).

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q NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

33. Do you contend that the estimates of vehicle demand displayed in Figures 2-4, 2-5, and 2-8 of Volume 6 of Revision 2 of NHRERP, based on numbers estimated for the NRC by M. Kaltman in 1981, are reliable 7

a. If you answer in the affirmative, state your ressons and identify any experts, other persons, studies, or other documents upon which your reasons are based.

b. Identify any other experts, persons, studies, or other documents which contain information about vehicle demand which differs in any way from that contained in Figures 2-4, 2-5, and 2-8 of Volume 6 of NHRERP.

RESPONSE

O Yes.

a. See discussion on pages 2-14, and 2-20 of NHRERP Volume 6.

b. We are not aware of any such information.

O L/065LS.33

MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

34. Identify and produce all documents which indicate or project the popu-lation of the following groups inside the EPZ: (a) in the period 1985-86 (b) in the suaser of 1987. (c) in the next five (5) years, or (d) over the expected operating life of the Seabrook plant:

1. Permanent resident population

2. Employee population

3. Seasonal population

4. Transient tourist population

5. Peak beach going population

6. Transit dependent population Sources of actual population or estimates are referenced in Appendix E of NHRERP Volume 6. Projections of resident population over the operating life of the plant are contained in the Seabrook Station Final Safety Analysis Report, Chapter 2.1.

O L/065LS.34

5 MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES *

(continued) i

35. Identify and produce any documents which calculate or project when, as a result of population growth, the ETE's contained in Volume 6 of NNRERP may ,

become unreliable.

RESPONSE

1 1

We are not aware of any documents.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

36. For each New Hampshire town which is not participating in evacuation planning, (1) state the name, city or town of residence, name of employer, job title or position, and location of usual work site for each traffic guide. bus driver, or other emergency worker the State of New Hampshire intends to mobilize to perform an emergency response functions (2) describe for each such person I

which traffic control post or other function each said person has been assigned and (3) lint for such person how long it is estimated it will take to travel to the assigned duty post: (a) from said person's home and (b) from said person's usual work site.

RESPONSE

objection. This question seeks a level of detail not required by the regu-lations or NUREG-0654. The pools which will be drawn upon are listed in the

, NHRERP Volume 2 Appendix G. No more is required or relevant.

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NASS ATTORNgY GgNgRAL APPLICANTS' INTgRROGATOR!gS (continued)

37. In calculating that an Immediate General Emergency would extend the ETE's by 20-30 minutes (see pg. 10-16 of Volume 6), how soon after the eva-cuation order is given did KLD assume that all traffic management and control measures would be in effect? State your basis for this answer and identify any documents and experts upon which you rely for your answer.

RESPONSE

In conducting this sensitivity study. XLD assumed that the routing of traf-fic would be the same as the routing of traffic under the planning basis. The planning basis is defined on page 4-1 in Volume 6 of NHRERP and explained further on page 4-2. Consistent with the planning basis, the sensitivity study of the lamediate General Emergency scenario calls for the Order to Evacuate (OTE) to be given 10 minutes after the General Emergency is declared. Between that point in time and the time for a substantive number of evacuees to gain access to the highway, will be a further time lag of approximately 15 minutes. This time lag is documented in Table 4-2 on page 4-16 of Volume 6 of the plan in which is shown that by 15 minutes only 9' percent of the beach area population will have started their evacuation trips (see Distribution E) while only 5 percent of the general resident pop 11ation will have started on their evacuation trip (see Distribution D). On this basis then. New Hampshire Police personnel would have approximately 25 minutes from the OTE to the onset of congestion to man the high priority traffic control post (TCP) which is most leportant for guiding evacuees.

L/065LS.37

NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

RESPONSE

(continued)

Sensitivity runs have been performed to quantify the effects on ETE of traf-fic control measures not being in effect. These tests indicate a reduction of about one hour in ETE within 2 miles of the station, a smaller reduction in ETE for those within 5 alles of the station and no change in ETE for the EPZ as a whole during the summer.'Those reductions in ETE reflect the fact that some evacuees from the beaches to the south of the Station will use Route 1, south-bound; under the controlled evacuation, these evacuees are restricted to use I-95. This restriction, in turn, was responsive to requests made by police chiefs in Newburyport and Newbury to route traffic from the north in such a way as to keep Route 1 uncongested. Again, the computed analyses of non-compliance cases reveal that the ETEs are not adversely impacted by any absences of guides at TCPs. The lone exception to this rule is TCP D-MA-02, which will be manned with State Police personnel and is assigned the highest priority.

It can be concluded that, based upon the 25 minute lead time available for traffic guides to man the most critical Traffic Control Post in the EPZ plus the sensitivity studies on route compliance which is described above, it is reasonable to espect that the estimates given on page 10-16 of Volume 6 of NNRERP represent reasonable expectation of ETE under the unusual circumstances of an immediate General Energency.

O L/065LS.37.1

MASS ATTORNEY GENERAL (O) APPLICANTS' INTERROGATORIES

! (continued)

38. What is the basis for the assumption, noted on pg. 10-3 of Volume 6 of NHRERP, that 25 percent of the population within the EPZ. but outside the region ordered to evacuate, will spontaneously evacuate, contrary to instructions?

Identify any surveys, studies or experts upon which you rely in asking this

(

assumption.

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RESPONSE

l The figure of 25 percent for spontaneous evacuation was obtained from a nationally-renowned expert on the subject of human behavior during emergencies.

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l MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) ,

39. In calculating ETE's with the "25 percent" assumption noted above in Interrogatory 38, was it assumed that those who would spontaneously evacuate would be randomly distributed throughout that portion of the EPZ not ordered to evacuate? If not, what distribution was assumed? In either event, state the basis for this assumption and identify any surveys, studies, and experts upon which you rely for this assumption.

RESPON8E In executing the IDYNEV model to estimate ETE, the 25 percent factor was applied uniformly throughout that portion of the EPZ which was not ordered to evacuate. The expert upon whom Mr. Lieberman relied was Dr. Dennis Mileti.

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j NASS ATTORNEY GENERAL APPLICANTA' INTERROGATORIES f (continued) t a

h

40. Have any studies or surveys been conducted since the nuclear reactor accident at Chernobyl to see what effect this event has had on KLD's 25% spon-taneous evacuation assumption? If so. Identify any such studies or surveys.

RESPONSE

We are not aware of any studies or surveys, i

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

41. Did the KLD study contained in Volume 6 of Revision 2 of the NHRERP assume or take into account in any sanner that some portion of the population beyond the EPZ would also sponte.neously evacuate, taking up some roadway capa-city beyond the EPZ and thereby impeding evacuation progress out of the EPZ? If so, describe how this was taken into account. Identify any studies or surveys, conducted both before and after Volume 6 was published, which you have gathered on this topic.

RESPONSE

No.

O L/065LS.41

NASS ATTORNEY OSNERAL APPLICANTS' INTERROGATORIES (continued) 42, in Volume 6 of the NHRERP-Revision 2. Appendices F and 0 are not entirely legible. Produce a legible copy of each. [

I asSP0mSa

'l A copy of Appendices F and 0 to Volume 6 will be provided under separate i

cover.

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p NASS ATTORNEY GENERAL APPLICANTS' INTERROGATOR!sS (continued)

43. Describe in detail the methodology for the telephone survey described in Appendices F and 0 of Volume 6 of Revision 2 of NHRERP. including, inter 3113, who conducted it, what the instructions were to each telephone survey researcher, what was the sample strategy used to select the numbers called, how many calls were made altogether to produce the 1300 responses included in the tabulation (App. F) the schedule of actual phone calls attempted and phone calls completed by time of day and day of week, what methods were applied to ensure against having a non-response bias in the survey, and what validity and reliability tests were applied to assess the representativeness of the responses O obtained. Also identify who has the actual survey data sheets. Produce all b written descriptions of the survey, the survey methodology, all drafts of the survey instruments. Instructions given to the survey researchers, all computer readable data sheets produced by thee, all computer print-outs, all documents assessing, reviewing, validating, or critiqueing the results, and all correspon-dence regarding this telephone survey, identifying each correspondent.

RESPONSE

Methodology consisted of a stratified randon sampling procedure undertaken through the medius of a telephone survey by an experienced market research organisation. The details of this survey which include the survey instrument, a cos-p11ation of the telephone exchanges used and of the interviews completed, appear in Appendix F. A portion of the subsequent analysis of the raw data and its organisation into a statistical format, which was undertaken by KLD Associates.

L/065LS.43

appears as Appendix 0 in Volume 6. Other survey data are presented in Section l

V 2.4 and 5 of the Plan.

The First %rket Research Corporation of Boston conducted the study based on a survey instrument drafted by KLD and subsequently refined by First Market Research Corp. Each survey reseacher was instructed to adhere to the final fore  :

of the survey instrument as developed by First Market Research. The sampling procedure used automatic, random telephone dialing equipment. The number of calls is documented below.

A total of 10.567 random dialinas were made using the randos dialing equip-ment. Most of these dialings generated numbers which were not assigned to any telephone. A total of 3582 connections were made of which 562 were ineligible since the households were located outside the EPZ. Of the remaining 3020 calls.

! 769 respondents refused to participate.

51 calls were terminated before the survey was completed.

1

( 816 calls were answered by persons other than head of household (mostly children). Repeated calls back to I

these numbers did not lead to connections with an adult, and l

1382 interviews were completed.

Thus, only 2202 calls were connected to adults in households within the EPZ, of which 1382 calls led to completed interviews, represents a 63 per cent com-plation rate. This rate is typical of telephone surveys. See Ites A on page l E-13 of NHRERP Volume 6.

Calls were completed during evening hours during the week, and during the day on weekends. The entire survey was completed in four days.

Documentation to support additional inquiries is available for inspection at

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

44. Have you. XLD. or anyone else conducted any other telephone or in-person survey research or poll to assess, on re-assess, trip generation time or any other aspect of the expected evacuation behavior of persons residing within the Seabrook EPZ7 If so, please identify and produce all documentation relating to such surveys.

R58PON88 Yes. See NMRERP Volume 6. Section 4 and Appendix E. No re-assessment has been conducted. See response to Interrogatory 43.

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fG MASS ATTORNgY GsNERAL k APPLICANTS' INTgAROGATOR!sS (continued)

45. In conducting the ETE study, did KLD assume that all commuting workers would return home in their normal time frames? State the basis for your answer and identify any studies, experts, and other information upon which you rely for your answer.

RESPONSE

Yes.

It must be pointed out that " normal circumstances" represent peak hou. con-ditions when other comeuters are occupying the roadways over the same time frame as those who are returning to their homes within the EPZ. If an order to eva-cuate occurs prior to the normal peak period then those returning hoes to the EPZ will be occupying the roadways while workers who live elsewhere remain on their jobs. Consequently, under those circumstances, the trip home should take somewhat less time than during the " normal" peak traffic period. Furthermore, it is highly unlikely that other travelers, who might be going to, or through the EPZ, would actually make their trips under energency conditions. This reduction in other trip-saking also tends to shorten work-to-hosis travel time.

Travel against the direction of evacuating traffic will not have an effect i

on major highways such as 1-95, 1-495 since the two directions of traffic are physically separated and traffic in one direction has no lopect on the other.

On surface roads there could be some frictional effects but these would be counter-balanced by the factors discussed in the preceding paragraph. Again, it L/065LS.45

NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIgS (continued)

RESPONSE

(continued) must be emphasized that the cones do not block desired turning movements in any direction. As noted on NHRERP Volume 6, page 7-1: "There are always legitimate reasons for a driver to prefer a direction other than that indicated. For example: He/she may be traveling home from work or from another location, to join other family members preliminary to evacuating." Later, the plan states, "The implementation of a plan must provide room for the application of sound judgment. The traffic cones and barriers are deployed as indicated in the sketches of Appendix ! (NHRERP Volume 6), so that there remains room for vehicles to maneuver through these guides. That is, cones and barriers will not physically obstruct passage."

It is thus seen that the plan is designed to accommodate commuters who will 4

be returning home and that they will not encounter any blockage which will ob-struct their movements to their homes from work.

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I MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES j (continued) l

46. Do you agree that Basis 8 to SAPL's Revised Contention No. 31 contains an accurate statement of the number of traffic guides needed in New Hampshire for Traffic Control Posts and Access Control Points? If not, state what you contend the accurate numbers are, and identify the source or sources of your information.

RESP JON Yes.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) ,

3

47. List the names and home addresses, employment addresses, and traffic control assignments of each of the New Hampshire traffic control personnel.

RESPONSE

See the response to Interrogatory 36.

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

48. Identify and produce copies of all the instructional sheets, manuals, or guides which have been given to these New Hampshire traffic control person-nel.

RESPONSE

A. Specific instructions for traffic control personnel are contained in:

1. NHRERP, Volume 4B, State Police, Troop A Procedures and Appendix D to the procedures.

2. NHRERP, Volumes 16-32,Section IV, Police Chief Procedures.

3. Traffic Management Manual of the State of New Hampshire.

B. NHRERP, Volume 1 Section 3.2, describes training given to traffic control personnel.

C. The applicable training materials are:

Radiological Emergency Response Training New Hampshire Civil Defense Agency Module 1 Basic RERP Radiological Emergency Response Training New Hanpshire Civil Defense Agency Module 2 Radiological Exposure Control Radiological Emergency Response Training New Hampshire Civil Defense Agency Module 13 r- Traffic Management f

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

49. Does Revision 2 of the NHRERP reflect the specific assignment of the tow trucks recommended in Table 12-1 of Volume 6 of Revision 2 of the NHRERP7 If your answer is yes, state where and how these assignments are reflected, and list the name, home and business address, and specific location assigned for each tow truck driver.

RESPONSE

No.

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

50. Have any surveys or other studies been conducted to assess the impact of role conflict on those traffic control personnel, bus and tow truck drivers, or law enforcement, and other emergency workers who have families residing within the EPZ7 If so, identify and produce said studies.

RESPONSE

Applicants are aware of no such surveys or studies.

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MASS ATTORNEY GENERAL O APPLICANTS' INTERROGATORIES (continued)

51. Have any studies or surveys been conducted to assess any aspect of the likely evacuation behavior of the beach-going or other transient population inside the EPZ7 If so, identify and produce said study.

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RESPONSE

See the response to Interrogatory 50.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES *

(continued)

52. At page 11-18 of Volume 6 of Revision 2 of the NHRERP lt is noted that a " telephone survey" of organizations which own and operate buses was under-taken to obtain estimates of mobilization time,

a. Produce a copy of the survey methodology and the survey instrument or form;

b. If none exist, describe the methodology in detail, specifying the question asked;

c. Describe when this survey occurred and who conducted it;

d. Produce the survey data collection sheets identifying for each the name and address of the company called;

e. If no survey data sheets exist, list each bus company called, who was spoken to, the questions asked and the responses given;

f. Describe how, if at all, the results of this telephone survey were checked for reliability;

g. Identify and describe any follow-up studies that have been or will be done to re-assess or refine the estimates of bus mobilization time utilized in Volume 6 of the NHRERP-Revision 2.

RESPONSB a.-f. Because of the limited amount of information which was sought, there was no need to develop a formal survey instrument or metho-dology. Specifically, only one question was asked: How long would it take to mobilize your bus drivers after notification? To the best of KLD's recollection, this survey was conducted in the i

! spring of 1986; no formal copies were maintained of the interviews or the results obtained since these results were transferred imme-diately to the final form which appears in Volume 6. The names of the bus companies were furnished to KLD by New Hampshire Civil Defense Agency, but KLD did not retained this information since it was discarded along with the data sheets described above. While there was no way to check the reliability of these returns, KLD O did engage in extended discussions over this matter with each L/065LS.52

MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)'

RESPONSE

(continued) respondent. During the course of these discussions. KLD empha-sized the need for accurate and reliable information and always fed back the responses obtained to confirm that the respondent felt comfortable with the information that he or she gave. KLD also ascertained that the person was either a manager or a respon-sible employee of the firm to ensure that the information was reliable.

g. A telephone survey of bus companies under letter of agreement with the NHCDA at that time was conducted in early 1987. The purpose of the survey was to verify bus mobilization and travel time to transportation staging areas.

i L/065LS.52.1 1

MASS ATTORNEY GENERAL

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APPLICANTS' INTERROGATORIES (continued)

53. Produce copies of all instructions and instructional materials which will be or have been provided to bus drivers (a) prior to an accident and (b) at staging areas upon their arrival during an evacuation.

RESPONSE

A. The materials to be provided prior to an accident are:

Radiological Emergency Response Training New Hampshire Civil Defense Agency Module 1 Basic RERP Module 2 Radiological Exposure Control Module 19 Transportation Overview t

B. The Material to be provided at staging areas are:

1. Emergency Worker Infoination to be issued with dosimeters and Dosimetry-KI Report Form.

2. Map to local staging areas.

3. Maps to destinations.

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l NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

54. What is the number of transit dependent persons in the EPZ which you contend should be utilized in calculating ETE's and the need for transit assistance vehicles? Describe in detail: (a) the methodology used to calculate this number, and (b) all assumptions made in conducting this calculation and the reasons, documentation, studies, and experts supporting these assumptions.

Produce all documents and studies which you have relied on or have reviewed in calculating the number of transit dependent persons.

l

RESPONSE

IO') The methodology and the number of transit dependent persons in the EPZ uti-lized in calculating ETEs is contained in NHRERP, Volume 8. Section 11.

1 The number of transit dependent persons in the EPZ utilized for calculating the need for assistance vehicles was determined by the NHCDA survey. The survey 4

instruments used are available for inspection at the Seabrook Station. (See j response to Interrogatory 2).

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"N MASS ATTORNEY GENERAL (G APPLICANTS' INTERROGATORIES (continued) ,

55. Produce each of the records, studies, photos, slides, reports, and other documents referenced in Appendix E of Volume 6 of the NHRERP-Revision 2.

RESPONSE

The specified documents will be made available for inspection at the KLD office (See response to Interrogatory 2).

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O L/065LS.55

NASS ATTORNEY GENhRAL APPLICANTS' INTERROGATORIES (continued) ,

56. Produce all correspondence and documents passing between you and FEMA since your receipt of the FEMA /RAC Review of Seabrook Station Evacuation Time Estimates and Traffic Management Plan Update contained in the State of New Hampshire Radiological Emergency Response Plan (Rev. 2-8/86).

RESPONSE

There has been no correspondence or document passing between the Applicants and FEMA related to the NHRERP Volume 6. Revision 2.

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L/065LS.56

NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

57. List and describe each and every change that you have made to Volume 6 4 of the NHRERP-Revision 2 since it was published.

t i RESPONSE  :

No changes have been made.

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k NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

17. Compare the average dose reduction factor of homes within the Seabrook i

ten-mile EPZ beach area to average dose reduction factors of homes around other reactors.

RESPONSE

1 Objection. Same as Interrogatory No. 7.

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4 NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 4

18. Please provide the basis for your responses to interrogatories 16-17 and any documents relevant to your response.

4

RESPONSE

i Objection. Same as Interrogatory No. 7.

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NASS ATTORNEY GENERAL rm APPLICANTS' INTERROGATORIES (continued)

19. Describe in detail your relationship with KLD Associates and Edward B.

Lieberman since January 1, 1985, detailing the amounts, if any, you have paid to KLD Associates, to Mr. Lieberman, and others, to conduct the evacuation time study contained in Volume 6 of the New Hampshire Radiological Emergency Response Plan (NHRERP) Revision 2. Produce all contracts and other documents which describe the relationship.

i RESPONSB At the request of the Massachusetts Civil Defense Agency New Hampshire Yankee contracted with KLD Associates to update the evacuation time estimate

(

for the Seabrook Station EPZ. Attachments 19-1, 19-2 and 19-3 describe the relationship.

The total payments to KLD Associates from New Hampshire Yankee are tabulated below. No payment has ever been made directly to Mr. Lieberman or others.

Time Period Total Payment 1/1/85 - 06/30/85 0 7/1/85 - 12/31/85 142,176.81 1/1/86 - 06/30/86 220,849.78 7/1/86 - 08/31/86 55,374.29 9/1/86 - 02/28/87 42,407.02 (Invoiced) l l

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h!rb AUu ^' '" 1M5 g Attachment 19-1 THE COMMONWEALTH OF MASSACHUSETTS ot ","c ,#

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EXECUTIVE DEPARTMENT f --

e, E C;viL CEFENSE AGENCY AND CFFICE CF EutRGENCY patoaaEONESS $ ."s%~ * '

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MICH AEL S. DUKAKIS August 15, 1985 ac8ERT1 BOULAY 0,nE;T a GOVERNCm Mr. Edward Brown, President New Hampshire Yankee Company P.O. Box 300 Seabrook, New Hampshire 03874

Dear Mr. Brown:

As the local Advisory Committees continue to progress with the revision of State and Local Emergency Response Plans, it has become apparent that an updated Evac-uation Time Estimate (ETE) projected to the year 2020 be completed. -

- In view of the fact that it has been several

[ ) years since demographic and traffic data, upon which the ETE's

's are based, have been reviewed, an update based upon the most current data and information available should be prepared.

Since work on the plans is proceeding at a rapid pace, I feel that this effort should be completed as quickly and competently as possible.

Inasmuch as our current budgetary restrictions preclude this Agency from undertaking such a' task, it is re-quested that the New Hampshire Yankee retain an independent, respected firm to develop this study.

Please let me know as soon as possible if this can be accomplished.

Sincerely, s

Ro ert .s ou

• - Director

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b Attachment 19-2' Rurb nuG 191985 c THE COMM JNWEALTH OF MASSACHUSETTS h -

h EXECUTIVE DEPARTMENT 7, ,51*

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[^1 Crpt CEFENSE A 1ENCY AND OFFICE OF EMERGENCY PMEPAAEDNESS [ i t j q 400 WOmCESTER ROAO / \ 'j [, .,

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MICHAEL S. DUKAMS ROBERT J. BOULAY Gov ERNCR ClAECTCA August 16, 1985 Mr. Edward Brown, President New Hampshire Yankee Company P..O. Box 300 Seabrook, New Hampshire 03874

Dear Mr. Brown:

As a follow up to both my letter of August 15, and a telephone conversa-tien with your director of emergency planning on the same date, I wish to set forth, for your consideration, two additional conditions relating to the proposed update of the Seabrook evaluation time estimate.

First, I propose that the firm selected to conduct the ETE update will

- operate under the direct control of my office. Secondly, the firm retained to conduct the update should be required to meet with the six E.P.Z. Planning Committees on a regular basis to solicit and address the Committees' Concerns and to brief the Committees on the status of the update.

Again, please let me know as soon as possible if this can be accomplished.

Sincerely,

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MbV Robert J.\Bquia ,

. Director RJB/seb O

Attachmnt 19-3 Public SeMce of New Nmpshire NEW HAMPSHIRE i/C.:_. sil!SION August 19, 1985 NHY #850702 Mr. Robert J. Boulay, Director The Commonwealth of Massachusetts Civil Defense Agency & Of fice of Emergency Preparedness 400 Worcester Road P. O. Box 1496 Framingham, Massachusetts 01701

Dear Mr. Boulay:

p) In response to your letters of August 15 and 16, we will retain an independent experienced firm to conduct the requested update to the Evacuation Time Estimate (ETE).

We agree that the firm selected will operate under the direct control of your of fice and will meet with the six (6) EPZ Planning Committees on a regular basis to solicit and address the committees' concerns and to brief the committees on the status of the update.

Sincerely, d n :-

Edward A. Brown President EAB:bes s ..

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P O Box 300 _ Secbrook.NH 03874 Tefechene(6031474-9521

l NASS ATTORNEY GENERAL O APPLICANTS' INTERROGATORIES (continued) l-

58. List and describe each and every step you or KLD have taken to address ,

the issues raised in the FEMA /RAC Review of Volume 6 to the NHRERP-Revision 2.

RESPONSES See response to Interrogatory No. 27.

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1 MASS ATTORNEY GENERAL APPLICANTS' INTERK0GATORIES (continued)

59. Produce all documents relating to the survey of all residents of New Hampshire conducted in June 1986 by the New Hampshire Civil Defense Agency and referenced on page 11-9 of Volume 6 of the NHRERP-Revision 2. This production should include the survey instrument, methodology, sample strategy, measures of its validity and reliability, data collection sheets, computer print-outs, and tabulations of results.

RESPONSE

We assume this production request is directed to the State of NH only.

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L/065LS.59

NASS ATTORNEY GENERAL T

APPLICANTS' INTERROGATORIES (continued)

60. Produce the transcript of the audio cassettes made by KLD personnel as they drove the entire highway system within the EPZ and portions beyond, as I referenced on pg. 1-10 of Volume 6 of the NHRERP-Revision 2.

RESPONSE

The transcripts of the audio cassette made by KLD personnel referenced were discarded after the input streams to the IDYNEV model were developed and checked. The audio tapes have since been reused on other projects.

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L/065LS.60

NASS ATTORNEY GENERAL O APPLICANTS' INTERROGATORIES ,

(continued)

61. Produce all additional information and studies which update or refine the highway characteristics documented in the field survey described in the pre-vlous interrogatory.

RESPONSE

l None exist.

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

62. Please provide any other documents, including aerial photos, you or KLD have reviewed regarding the size of the beach population which were not listed in Appendix E of Volume 6 of the NHRE'.P-Revision 2.

RESPONSE

Aerial photos were taken on July 4 and 5, 1986 of beach populations and highways in the EPZ. These photos will be made available for inspection at KLD's office (See response to Interrogatory 2). No other documents were reviewed.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

63. Do you admit that the NHRSRP contains no contingencies which permit the redirection of evacuating vehicles in response to a change in plume direc-J

' tion? If your answer is negative, explain in detail what these contingencies are and how they would be implemented. Identify any person, expert, and docu-I ment upon which you rely for your answer.

RESPONSE

The NHRERP provides for predesignated evacuation routes. The plans are sufficiently flexible to allow the evaluation and recommendation of the redirec-() tion of evacuees. However, given the routes available, it is difficult to envi-sion a situation where a change in wind direction would result in a redirection of vehicles on the move. It might result in the commencement of evacuation of a i

new section; but this would not result in a change in direction of evacuations I already underway.

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l MASS ATTORNgY GgNgAAL i

-; O APPLICANTS' INTgRROGATORigS (continued) 1 a

r

64. Describe in detail what traffic guides have been instructed to do:

a. when evacuating drivers seek to go in a direction described on the ,

intersection sketches as " movement discouraged";

b. when evacuating drivers stop, thereby blocking a line of vehicles.

to speak to the traffic guide for any reason (complain, ask direc-tions, seek assistance, etc);

c. When evacuating drivers stop to obey traffic lights and stop signs;

d. when evacuating drivers seek to disobey traffic lights and stop signs;

e. when an accident or a breakdown occurs which blocks or impedes 4

traffic through an intersection.

RESPOIISE i

See response to Interrogatory 848 1

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NASS ATTORNEY GENERAL i APPLICANTS' INTERROGATORIES i j

(continued) j i l s

4 65. Will traffic control guides be stopping drivers to question and direct l

l them to appropriate evacuation routes and host communities?

j RESPONSE No.

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, MASS ATTORNEY GENERAL 4

APPLICANTS' INTERROGATORIES (continued) i

66. Identify and produce each and every document, including correspon-4 dence, which pertains, directly or indirectly, to any contention to be litigated 1

l by the Attorney General and was exchanged between you and FEMA since your receipt of the FEMA /RAC Review of the NHRERP-Revision 2.

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RESPONSE

i See response to Interrogatory 56.

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MASS ATTORNEY GENERAL O APPLICANTS' INTERROGATORIES

(continued)  !

l

67. Describe each change which has been or will be made to the NHRERP Revision 2 since it was published and which pertains, directly or indirectly, to any contention to be litigated by the Attorney General. If said changes are noted in any documents, produce said documents.

RESPONSE

No changes to the NHRERP Revision 2 have been made. See response to Interrogatory #27 for proposed corrective actions. ._

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

68. Produce computer readable listings of-all input files and-data necessary to reproduce: (a) the IDYNEV runs documented in Volume 6 of the NilRERP-Revision 2: and (b) any subsequent runs, conducted in response to.the FEMA /RAC review of Revisiuh 2 or for any other reasons, relating to refining.

Correcting,' supplementing, updating, testing, or revising the evacuation time estimates contained in Volume 6 of the NHRERP-Revision 2. Indicate whether the computer readable listings produced in response to (a) are identical to the data files currently stored at FEMA in Washington, D.C.

RESPONSE

('T U Given sufficient notice beforehand. KLD will store all of the requested files on one or more magnetic tapes: cost for computer time, materials and labor to be borne by the requesting party.

/

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FEMA has been provided the flies which they have requested. Files requested herein may be of greater quantities than those provided to FEMA. Those files

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which are in common to the two requests are identical.

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s-MASS ATTORNEY GENERAL O. APPLICANTS' INTERROGATORIES (continued) 1

\

69. Produce paper copies of the IDYNEV outputs produced in the runs spe-cified in the previous interrogatory.

' RESPONSE The IDYNEV paper outputs are available for viewing at the KLD office. (See

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response to Interrogatory 2). ,

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NASS ATTORNEY GENERAL

. sf ,/)~ APPLICANTS' INTERROGATORIES (continued)

70. Produce all empirical data, studies, or surveys used to support the snow clearance time estimates shown on page 4-20 of Volume 6 of the NHRERP-Revision 2. Indicate what personnel, by name, address, and employment position, will be used for snow clearance and if NHRERP-Revision 2 depends upon the same personnel to perform other emergency response tasks.

1 RESPONSB As discussed on p. 4-20 (NHRERP Volume 6), the snow clearance time distribu-tion is postulated based on undocumented informal discussions with those who reside in the area. It is also based on the premise that individuals will clear their driveways using hand shovels or snow blowers. No additional personnel are

' assigned to perform these activities other than the people who reside in these dwellings, except possibly for private contractors who ordinarily provide such services.

Regarding snow clearance on roads, the personnel assigned those duties are identified by organization in NHRERP Volume 16-32, Appendix C.

L/065LS.70

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES *

(continued)

71. Describe in detail the telephone inquiries of hotel / motel managers referenced on page 6-1 of Volume 6 of the NHRERP-Revision 2, and produce copies of all related documents, including those which contain the dates calls were made, test of the question asked, the tabulated responses, and the list of the hotels / motels called. If no documentation exists, state who was called, when calls were made, what questions were asked, and what response each call j produced.

RESPONSE .

The referenced telephone survey included contact with major hotels within

(

! the EPZ regarding occupancy rates, both summer and off-season, the percent of guests who go to the beaches on fair weather days, and an indication of the 4

extent to which parties using the same vehicle occupied separate rooms.

Information gathered during these phone calls was tabulated for incorporation within the ETE, and is reflected in those sections of the ETE concerning the above cited items of interest. Existing documentation gathered during this telephone survey is available for observa' tion at the office of KLD Associates.

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l MASS ATTORNEY GENERAL I APPLICANTS' INTERROGATORIE~

(continued)

72. In computing evacuation time estimates, what, if any, data was included in the computation regarding estimates of the time required to set out cones, signs, and barricades? Indicate by name, address and employment posi-tion, the personnel designated to set out such cones, signs and barricades.

RESPONSE

The computations do not consider that the time to deploy cones and barrica-des is a contributing factor to evacuation or travel time.

The request for names, addresses, and employment position for these tasks seeks a level of detail not required by regulations or NUREG-0654. The pools which will be drawn upon are listed in NHRERP Volume 4B, Department of Transpor-tation Procedures and Volumes 18 through 32, Appendix C. No more is required or relevant.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

73. List the anticipated storage locations for cones, signs, and barricades.

RESPONSE

As described in NHRERP Volumes 16-32,Section II, cones, signs and barri-cades will be stored and maintained in municipal facilities of each community.

As described in NHRERP Volume 1. Section 1.3.3, cones, signs and barricades for the State's use during an emergency will be stored at New Hampshire Department of Transportation (DOT) garages near or within the EPZ.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

74. Is it your position that sheltering will never be relied upon as a protective action for the summer transient beach population located within ten miles of the Seabrook plant, or for any portion of that population?

RESPONSE

No. ,

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r NASS ATTORNEY GENERAL O] APPLICANTS' INTERROGATORIES (continued)

75. If sheltering is to be relied upon as a protective response option only for a portion of the summer beach population, please identify that portion of the population, and the basis for any determination that sheltering should be a response option for that portion and not the remaining portion of the tran-sient summer beach population.

RESPONSE

NHRERP, Volume 1 Section 2.6.5 does not provide for different protective action recommendations with regard to shelter for any portion of the beach t

population.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES * '

(continued)

76. Please provide any documents you have reviewed that are relevant to the conclusion (s), set forth in response to interrogatory 74 that sheltering will or will not ever be relied upon as a protective response for the transient sunser beach population.

RESPONSE

The document relevant to Applicants' response to Interrogatory #74 is NHRERP Volume 1, Section 2.6 and Volume 6.

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[ MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

77. Please identify all documents you intend to rely upon to support your 4

position that sheltering will or will not be used as a protective response for

- the transient sunser beach population.

R5SPONSE i

See response to Interrogatory #76.

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O MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES f (continued)

78. Unless your answer to interrogatory 74 is an unqualified yes, describe when and under what circumstances, including types of accident sequences and meteorological conditions, you anticipate that sheltering will be relied upon as a protective action for the summer transient beach population.

RESPONSE

NHRERP Volume 1. Section 2.6.7 describes the decision criteria for selecting the option of sheltering as a protective action.

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NASS ATTORNEY GENERAL n

APPLICANTS' INTERROGATORIES

('

(continued)

79. Please provide any plans you have relative to sheltering the transient summer beach population, and indicate if, how, and when you intend to amend or add to those plans in any way.

. RESPONSE The NHRERP Volumes 1, 16 and 18 provide for the continuus of protective responses that would be implemented to protect the health and safety of the public, including seasonal beach populations, in the event of a radiological emergency.

The plans in NHRERP Volumes 1, 16 and 18 will be updated periodically as t described in NHRERP Volume 1, Section 3.3.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

80. If no plans for sheltering the transient summer beach population currently exist, please indicate if. when and how you intend to develop any plans for sheltering the transient summer beach population located within ten miles of the Seabrook plant.

RESPONSB Not Applicable. See response to #79.

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'NASS ATTORNEY GENERAL A

APPLICANTS' INTERROGATORIES

'Q (continued) .

81. If the transient summer beach population, or any portion thereof is instructed to shelter, how, by whom and on what basis will that decision to shelter the beach population be made? Please provide any documents on which you intend to rely in making that decision.

RESPONSE

The decision to shelter would be made by the Governor based upon the cri-teria specified in NHRERP Volume 1 Section 2.6.7. As described in NHRERP Volume 1 Section 2.6.5, New Hampshire employs the " shelter-in-place" concept which is implemented on a " municipality-by-municipality" basis. Each town will be advised of the recommended course of action and implementation of the protec-tive action will be in accordance with the RERPs and procedures governing the actions of the involved parties (refer to the individual RERP, NHRERP Volume 1, Section 2.8.7 and Volume 4A, Appendix U).

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O L/065LS.81 1

NASS ATTORNEY GENERAL i APPLICANTS' INTERROGATORIES (continued)

82. If the transient summer beach population, or any portion thereof, is instructed to evacuate, how, by whom and on what basis will that decision to evacuate the beach population be made? Please provide any documents on which l- you intend to rely in making that decision.

RESPONSB The decision to evacuate is based upon the results of the same assessments described in the response to Interrogatory 81. Documents used in the decision to evacuate are as previously cited.

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

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83. Please describe your methods for estimating radiation releases.

! RESPONSE i

Refer to NHRERP Volume 1. Section 2.5 and to the Seabrook Station l

l Radiological Emergency Plan. Chapter 10.  ;

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APPLICANTS' INTERROGATORIES (continued) 4

84. Please describe, and provide all documents pertaining to, all meteoro-logical models to be used for projecting doses off-site.

RESPONSE

I As described in NHRERP Volume 1, Section 2.5, the METPAC computer program is the primary method used to predict dispersion and off-site dose estimates.

The S8 NETPAC Technical Description and the SB METPAC User Manual describe the 4

computer software package which evaluates the off-site consequences of a radiological release. Also refer to NHRERP, Volume 4A Appendices 0. P and Q, which describe additional methodology.

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NASS ATTORNEY GENERAL O

V APPLICANTS' INTERROGATORIES (continued)

85. Please describe any provisions in the plans, and the means available, to monitor during an emergency the public's compliance with the State's protec-tive action instructions, including whether there is a capability and an intent to monitor during the course of an emergency in which the public is instructed to shelter the numbers of persons evacuating from the area.

RESPONSE

There are no such provisions in the plans.

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MASS ATTORNEY GENERAL I APPLICANTS' INTERROGATORIES 4 (continued) .

86. Is it your position that sheltering should never be relied upon as a protective response action for the transient sunser beach population located l

i within ten miles of the Seabrook piant, or for any portion of tha.t population?

, RESPONSE No.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

87. Unless your answer to interrogatory 86 is an unqualified yes, describe under what circumstances, and for what portion of the population, sheltering should be used as a protective response for the transient summer beach popula- l tion.

' RESPONSE Refer to the response to Interrogatory 75.

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MASS ATT0ftNEY GENERAL APPLICAllTS' INTERROGATORIES (continued)

88. Please provide the basi,s for your determination that sheltering should or should not ever be used as a protective response option for all, or any por-tion of, the transient suaner beach population.

RESPOIISE The basis is in NHRERP Volume 1, Section 2.6.7.

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NASS ATTORNEY GENERAL APPLICANTS' INTERit0GATORIES (continued)  !

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89. Please provide any documents you have reviewed that are in any way relevant to the conclusion (s) set forth in response to interrogatory 86.

4 R581W5 See response to Interrogatory 76. ,

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NASS ATToltNEY GENERAL APPLICAllTS' INTERit0GATORIES l (continued) 1

90. Please identify all documents you intend to rely upon to support your i i

position that sheltering should or should not ever be used as a protective ll response option for each portion of the transient sunser beach population '

located within ten alles of the Seabrook plant.

RESPollSE See response to Interrogatory 876.

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18488 ATTORIIEY GEIIERAL APPLICAlfrS' INTEltit0GATORIES l (continued) ,

91. Is it your position that sheltering of the transient summer beach population is feasible at all beach areas located within ten alles of the plant?

RESPONSE

4 The question as phrased. is not susceptible of an answer given the lack of several critical parameters including, but not limited to, the number of persons assumed to be on the beaches, the time of day, and the season, etc.

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APPLICAIFFS' INTERROGATORIES l (continued)  !

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92. Please identify those beach areas within ten alles of the Seabrook j plant for which sheltering of the transient population would not be a feasible response.

• i RESPQERE ,

See response to Interrogatory #91. ,

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NASS ATTORNEY GENERAL APPLICANT 8' IlrFERR0GATORIES (continued)

93. Please provide that basis for your determination that sheltering of ,

the transient beach population, or a particular portion thereof, is or is not feasible.

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RESPONS$

i Refer to the response to Interrogatory 76.  ;

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MASS Aff0Ril5Y GEllEllAL APPLICAllTS' IllTERIIOGATORIES (continued)

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94. Please provide any documents you have reviewed that are in any way relevant to the conclusion (s) set forth in response to interrogatory 90.

RESPONSE

If the query is to Interrogatory 91 - see response to Interrogatory 76.

Otherwise Applicants are unable to answer the question as written.

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APPLICARTs' IllfMRR0GATORIES -

(continued) s

95. Please identify all documents you intend to rely upcn to support' your position that sheltering of the transient summer beach population, or any por-tion thereof, located within ten miles of the Seabrook plant is or is not feasible.

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Refer to the response to Interrogatory 76. t 1

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97. iPlease provide the basis'for your response to interrogatory 96 that adequate pt.ysical facilities =do or do not exist.

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The basis for the response to Interrogatory 96 is in the documents cited in the response to Interrogatory 76.

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NASS ATTORNEY GENERAL O APPLICANTS' INTERROGATORIES (continued)

98. Please provide any documents you have reviewed that are in any way relevant to the conclusion (s) set forth in response to interrogatory 96.

RESPONSE

See response to Interrogatory 76.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

99. Please identify all documents you intend to rely upon to support your position that adequate physical facilities do or do not exist to shelter the entire peak transient summer beach population.

RESPONSE

I Refer to the response to Interrogatory 76.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

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100. Please identify all facilities that could be used to shelter the tran-sient suaser beach population and provide the. dose reduction factor for each, identifying for each the basis for your determination of the dose reduction fac-tor and providing all computations, materials, photographs, notes and other materials relied upon or reviewed in determining the dose reduction factor of each building or facility.

RESPONSE

The Applicants do not have the information requested regarding all facill-l ties. However, some facilities that could be used to shelter the beach popula-I tion are identified in a report entitled "A Study to Identify Potential Shelters in the Beach Areas near Seabrook Station", which was performed by Stone &

Webster Engineering' Corporation for New Hampshire Yankee in March 1986. This 4

study also evaluated the facility to determine the dose reduction factor.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) ,

101. Is is your position that sheltering of the transient summer beach population located within ten miles of the Seabrook plant could never be an ade-quate protective response action for that population, or for any portion of that population, under any plausible accident scenario?

RESPONSE

No.

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NASS ATTORNEY GENERAL APPLICAlfrS' INTERROGATORIES (continued) i 102. Please provide the basis for your response to interrogatory 101, and unless your answer to that interrogatory is an unqualified yes, state under what circumstances, including accident sequences and meteorological conditions, sheltering could provide an adequate protective response for the transient summer beach population, or any portion thereof, located within ten alles of the Seabrook plant.

RESPONSE

See response to Interrogatory 76.

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NASS ATToltNEY GENERAL APPLICANTS' INTERit0GATORIES (continued) 103. Please provide any documents you have reviewed that are in any way relevant to the conclusions set forth in response to interrogatories 101 and 102.

RESPONSE

Refer to the response to Interrogatory 76.

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NASS ATTORNEY GBIERAL APPLICANTS' INTERROGATORIES (continued) 104. Please identify all documents you intend to rely upon to support your position that sheltering of the transient sunser beach population could or could not ever be an adequate protective response option for that population.

RESPONSE

Refer to the response to Interrogatory 76.

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NASS ATTORNEY GENERAL O' APPLICANTS' INTERROGATORIES (continued) 105. Is it your position with regard to the transient summer beach popula-tion, or for any portion of that population, that the protective response of sheltering could never achieve the same level of dose reduction as the protec-tive response of evacuation?

RESPONSE

No.

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MASS ATTOItHEY GENERAL APPLICANTS' INTERIt0GATORIES (continued) 106. Please provide the basis for your response to interrogatory 105.

kESIWSE See response to Interrogatory 76.

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NASS ATf0RNEY GENERAL  !

APPLICANTS' INTERROGATORIES (continued) 107. Please provide any documents you have reviewed that are relevant to the conclusion (s) set forth in response to interrogatory 105.

RESPONSE

Refer to the response to Interrogatory 76.

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 108. Please identify all documents you intend to rely upon to support your l position set forth in response to interrogatory 105.

RESP 0ftSE Refer to the response to Interrogatory 76.

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 109. Is it your position that with respect to the transient summer beach population the protective response of evacuation will in all cases provide an adequate level of protection?

RESPONSE

Not necessarily. In some cases evacuation may not be necessary, and in other cases evacuation in combination with other measures may be the most desirable course of action to take.

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l NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) l 110. Is it your position that for the transient summer beach population the protective response of evacuation will in all cases be an adequate protective measure?

RESPONSE

Not necessarily. In some cases evacuation may not be necessary and la other cases evacuation in combination with other measures may be the most

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desirable course of action to take.

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NASS ATTORNEY GENERAL

, APPLICANTS' INTERROGATORIES (continued) ,

111. Please define your use of the terms " adequate" and " adequate level of protection" with respect to your response to interrogatory 109 and define your use of the term " adequate protective measure" with respect to your response to interrogatory 1107 RESPONS5

" Adequate": lawfully and reasonably sufficient; " adequate le' vel of protection": that level of dose reduction reasonably achievable in the cir-cuestances, given the resources available; " adequate protective measure": that measure which will best achieve the maximum reasonably achievable dose reduction in the circumstances given the resources available.

L/065LS.111

HASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 112. Please provide the bases for your response to interrogatories 109 and 110, including all documents you rely upon in support of those responses.

l RasPouss The responses are supported by those documents identified in the response to Interrogatory 76.

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l NASS ATTORNEY GEISRAL APPLICANTS' INTERROGATORIES (continued) 112a. If your answer to either interrogatory 109 or 110 is anything but an unqualified yes, please identify and describe those situations for which the

response of evacuation will not be " adequate" or achieve an " adequate level of protection" and the manner in which the response will not be adequate?

RESPONSE

As described in NHRERP Volume 1. Sections 2.6.5 and 2.6.7 the preferred course of action (i.e., sheltering and/or evacuation) is based upon minimizing

the dose to the general public.

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NASS ATT0ltNBy c.mummar.

APPLICAlrFS' INTERit0GATORIES (continued) 113. If your answers to interrogatories 109 and 110 are anything but an unqualified yes, please describe what, if any, other or additional actions will be taken to protect the population in those situations where the protective response of evacuation is not deemed by you to be an adequate protective measure or expected to achieve an adequate level of protection? -

RESPOIISE Refer To the response to Interrogatory 112a.

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 114. Is it your position that with respect to the off-site population no early fatalities, defined herein as death from radiation exposure within thirty to sixty days, could results from an accident at Seabrook, and, if not, how many early fatalities might result in your view of a worst-case scenario?

R5SPON!$5 Objection. As noted earlier, the regulations do not require any particular level of protection to be achieved in any particular circumstances; nor do the regulations require or assume that there must be a demonstration of absolute safety in all or any circumstances. See authorities cited with respect to objection to Interrogatory 7. Thus the position of the applicant as to whether or not there would or would not be early fatalities in some " worst case sce-nario" is irrelevant and is not something that could lead to the discovery of admissible evidence.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 115. Please define " worst-case scenario" as used by you to respond to interrogatory 114.

RESPONSE

In light of the objection to Interrogatory No. 114, no response.is possible.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 118. Please provide all data, charts, and statistics you have indicating types of accident sequences and scenarios (under varying meteorological con-ditions) that alght result in fatalities to the off-site population within ten miles of the Seabrook plant, and the numbers of such possible fatalities.

RESPONSE

Objection. As noted earlier, the regulations do not require any particular -

level of protection to be achieved in any particular circumstances; nor do the regulations require or assume that there must be a demonstration of absolute safety in all or any circumstances. See authorities cited with respect to objection to Interrogatory No. 7 l

O L/065LS.116

MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 117. Please provide all documents you have reviewed indicating what effect, if any, the protective responses of sheltering and evacuation will have on the numbers of fatalities or incidents of serious radiation illness that might result from the accident sequences and scenarios identified in response to 4

interrogatory 116.

• RESPONSB In light of the objection to Interrogatory No. 116, no answer is required.

In addition, as framed the question is incapable of answer because Interrogatory l No. 116 is a straight production request and did not require that anything be

" identified".

O L/065LS.117

NASS ATTORNEY ARME8Ar.

APPLICANTS' INTERROGATORIES

.(continued) 118. Please describe separately for the general population within ten miles of the Seabrook plant, for the permanent population within five miles of the plant, for the permanent population within two miles of the plant, and for the transient summer beach population within ten, five, and two miles of the plant, under what circumstances, and for what types of accident sequences and sce-nacios, and meteorological conditions, the protective response of sheltering i

1 will be prescribed.

RESPONSE

The information requested is in NHRERP Volume 1. Section 2.6.7 and NHRERP Volume 4A, Appendix U.

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IIASS ATFORIIEY GEllERAL APPLICAllTS' IllTERit0GATORIES (continued) 119. Please describe when, including under what types of accident sequences and scenarios and meteorological conditions, the protective response of sheltering would, if used instead of just evacuat4on for the transient summer beach population, result in lower radiation exposure to that population.

RESPOIISE See response to Interrogatorf #118.

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NAS8 ATTORNEY GENERAL APPLICANT 8' INTERROGATORIES (continued) 120. In determining whether to shelter or immediately evacuate persons in the beach area, including the permanent population and overnight visitors, what considerations, if any, will be given to meteorological conditions along the shore?

RESPONSE

Refer to NHRERP Volume 1, Section 2.5, Section 2.6.7 and Volume 4A Appendix U.

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NASS ATICItNEY GENERAL APPLICANTS' INTERROGATORIES (continued) l 121. Please describe and identify what equipment or other means you have for plume tracking and for monitoring weather and wind conditions throughout the EPZ and specifically along the shore.

R8SPONSE Refer to NHRERP Volume 1, Section 2.5; Volume 4A, Appendices C, G, N (SB NETPAC User Manual), 0, P,and Q; and Seabrook Station Emergency Response Plan, Chapter 6 and 10.

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Q APPLICANTS' INTERN 0GATORIES (continued) ,. v

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122. If the protective response of sheltering is ove.y to be used for any portion of the transient shmaer beac's population, please describe, and provide '-

any materials not included in the NHD2RP that are relevant to, how that popula-tion will be instructed to take shelter, the precise wording of any instruc-tions, and how and by whom they will be directed specifically where to go for shelter?

BEI M s,  ;

NHRERP, Volume 1. Section 2.3; Volutie 2. Appendix L; and Volume 4 Appendix G describe how the population will be hatructed, the pre' drafted wording of ,

O Instructions, and by whom instruction.a will be provided. There are no other

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4 23. If tra protective response of sheltering were to be employed for the 7:f

, transient summer beach population, please provide any data you have, or other- i

' wise your opinion, on how rapidly such sheltering would be effectuated?

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RESPONSE  ;

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f . Applac~mts have no data on this matter on which to base an opinion.

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1 MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 124. In situations where the general population is directed to take

shelter, precisely what instructions will be given to the transient summer beach population, assuming the beaches have not already been closed?

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-1 RESPONSE NHRERP, Volume 4. Appendix G, contains specific' instructions for this c

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l MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) ,

125. In situations where the transient beach population, but not the general population, is directed to evacuate, precisely what instructions. if any, will be given to permanent residents and overnight visitors in the beach areas?

RESPONSE

NHRERP, Volume 4, Appendix G contains sample messages. Appendix G provides for modification of sample messages to ensure that adequate information is

. relayed to the public.

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-() L/065LS.125 l

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NASS ATTORNEY GENERAL APPLICAirFS' INTERROGATORIES (continued) l 126. Is it your opinion that the New Hampshire Radiological Emergency Response Plan [NHRERP) provides in any manner for the possibility of an accident resulting in a large-scale early (within several hours) release of radiation?

If so, please identify those sections and pages of the plan which do so provide.

RESPONSE

Yes. NHRERP Volume 4A, Appendix U, and Volume 1, Section 2.6.7.

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 127. In the event of an accident at the Seabrook plant that does result in a large-scale early release of radiation on a peak summer weekend day, what pro-tective response actions will the following populations be instructed to take:

(a) the transient summer beach population; (b) the non-transient beach popula-tion, including overnight visitors; and (c) the general population.

RESPONSE

Refer to NHRERP Volume 1. Section 2.6.7 and Volume 4A, Appendix U.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued)

- 128. In the event of an anticipated small-scale short release of radiation on a peak summer weekend day, what respected protective response actions will the transient summer beach population, non-transient beach population and'the general population be instructed to take assuming for each of these populations that the release will occur: (a) within thirty minutes of notification of off-site authorities: (b) within one hour of notification of off-site authorities; and (c) within two hours of notification of off-site authorities.

RESPONS5 i -

As described in NHRERP Volume 1, Section 2.6.7 and Volume 4A, Appendix U, the response is dictated by those specific conditions being experienced.

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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 129. Is' it your opinion that the transient beach population can in all cases be evacuated in time to avoid any radiation exposure to that population?

RESPONSE

No.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) .

130. Please provide the basis for your response to interrogatory 129 and any documents relied upon to support that response.

RESPONSE

Refer to NHRERP Volume 1. Sections 2.6.3 and 2.6.7.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES l (continued) 131. Is it your position that the transient beach population can in all cases be evacuated in time to avoid the incurrence of radiation exposures in excess of 200 rem by that entire population?

RESPONSE

Objection. As noted earlier, the regulations do not require any particular level of protection to be achieved in any particular circumstances; nor do the regulations require or assume that there must be a demonstration of absolute safety in all or any circumstances. See authorities cited with respect to objection to Interrogatory 7. Thus the Applicants' position requested is irre-l levant.

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MASS ATTORNEY GENERAL O APPLICANTS' INTERROGATORIES (continued) 132. Please provide the basis for your response to interrogatory 131 and all documents you rely on to support that response.

RESPONSE

In light of the objection to Interrogatory No. 131, no answer is required.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 133. Is it your position that in the event of a large-scale release of radiation that for the transient summer beach population the protective response of evacuation will be an adequate protective response action?

RESPONSE

Yes.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 134. Please provide the basis for your response to interrogatory 133 and all documents you rely on to support that response.

RESPONSE

Refer to NHRERP Volume 1, Section 2.6.7: NKRERP Volume 4A, Appendix U; NHRERP Volume 6.

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HASS ATTORNEY GENERAL O APPLICANTS' INTERROGATORIES (continued) 135. In the event the transient sunser beach population, or any portion .

thereof, is instructed to shelter, please describe: (a) what provisions or plans, if any, have been made to evacuate such persons from those shelters, including the timing of such evacuation, and if the evacuation is to be

' staggered, how such persons will be instructed when to leave the shelters; (b) how the transient population will get to cars after sheltering, or specifically what other transportation might be provided to evacuate this population and from where that transportation will be obtained; (c) any provisions for washing off or otherwise decontaminating the transient population and,their cars; and (d)

any special provisions or plans not already specified herein that take into account the possibility that the population could upon exit from the shelters be i

exposed to radiation, from ground deposition or an overhead plume, after exit from the shelters.

RESPONS8 Evacuation, subsequent to sheltering, would be implemented according to NMRERP Volume 1, Section 2.6.7. Implementation will be conducted in accordance with the applicable procedures contained in NRRERP, Volumes 4, 4A, 48, and local l

, RERPs.

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HASS ATTORIIEY GENEltAL APPLICANTS' INTERROGATORIES (continued) 136. Please identify and provide copies of all photographs, including aerial photographs, of the beach area mithin ten miles of the Seabrook plant that are in your possession or that have been provided by yo'u to, or used by, or are in the possession of any entity, agency, person, firm, or business, including KLD Associates, that has at any time been retained, contracted with, or paid for by you to perform any activity relative to emergency planning.

1 1

i RESP 0lISE Aerial photographs of the Seabrook Station EPZ beach area, which were taken in July and August, 1979, are in the possession of the Applicants and are l

available for inspection. Additional photographs are in the possession of KLD i

Associates and can be inspected at its office.

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NASS ATTORNEY nava m .

Ci APPLICANTS' INTERROGATORIES (continued) 137. Please identify, by indicating on maps or otherwise, each and every possible parking space in the beach area within ten miles of the Seabrook plant that KLD Associates identified or counted in determining the peak numbers of vehicles, or other figures relevant to the number of persons, in the EPZ beach areas. .

RESPONSB These can be identified by viewing the aerial photographs which will be available for your inspection at the KLD office (see response to Interrogatory No. 2).

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NASS ATTOIIIIBY GENERAL O- APPLICAirFS' Ilf7 ERIT 0GATORIES (continued) 138. Please identify and provide copies of all surveys performed by you or relied upon by you to identify, or calculate, or that is in any way relevant to a determination of, any population figure provided in the NHRERP, including Volume 6.

RESP 01185 Telephone surveys completed by KLD for hotels, campgrounds, documents listed in Appendix E, aerial photographs. KLD surveys with the Town Clerks, telephone requests to NN Labor Services and Employment Bureaus, US Census Bureau were used to support population estimates in Volume 6. Survey documents will be available for inspection at the office of KLD. (See Response to Interrogatory No. 2.)

O L/065LS.138

NASS ATTORNEY asummar.

APPLICANTS' INTERROGATORIES l (continued) I i

l 139. With respect to any surveys identified in interrogatory 138 please provide: all data generated by such surveys all drafts of such surveys, including drafts of all proposed questions whether used or not used; and any notes, documents, data, memoranda, or correspondence that are in any way rele- ,

vant to such surveys and please identify: all methodologies employed; assump-

tions used; all persons or entitles involved in performing or devising such surveys and the names, addresses and phone numbers of all persons surveyed.

RESPONSE

Documents identified in Interrogatory 138 will be available for inspection at the offices of KLD: any information relevant to these documents will be pro-vided upon request at that time.

Methodologies varied baIsed on the type of survey conducted:

1. Structured telephone survey, by First Market Research of Boston.

Subsequently software was developed to process this data which was

stored on magnetic tape. These results were then analyzed as indi-cated in the plan. Ms. Karla Sheridan performed the software develop-ment and implementation.

2. To the best of his recollection, written survey of the Department of i Resources and Economic Development Division of Parks and Recreation, State of New Hampshire, conducted by Mr. Edward Lieberman.

3. Letter received from Town of Naapton indicating average sewage flow per day in July 1984 and 1985.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) ,

RESPONSE

(continued)

4. Interviews with Town officials and Police Chiefs and members of public planning commissions, including 20 Police Chiefs in New Hampshire and Massachusetts, Rockingham County Officials, several Boards of Selectmen, several town managers, and public works officials.

5. Surveys by E. Lieberman of the highway system and of the beach areas.

6. Review of aerial photographs and slides to estimate parking capacity, parking usage and person density on the beaches.

7. Telephone surveys to bus vendors to obtain estimates of bus driver mobilization times (performed by both KLD and NHCDA).

8. Survey of traffic movements on the beach roadways by Merrimac Engineering Services under subcontract using automatic traffic recor-ders. In addition, estimates were made of vehicle occupancy.

O 9. Surveys by E. Lieberman to estimate number of vehicles per dwelling in the major beach areas in New Hampshire and Massachusetts. In addi-tion, extensive onsite surveys of vehicle occupancy in the beach areas were conducted.

10. Visits of E. Lieberman to Greyhound Park to estimate parking capacity and person capacity of the facility.

Permanent documentation relevant to the ETE, including the names, addresses, and telephone numbers of all persons surveyed, are contained within NHRERP Volume 6. Entitles involved in the completion of the surveys, depending on sur-voy type included in the KLD, Merrimac Engineering Services, First Market Research Services and/or NHCDA. Assumptions were not used in acquiring the data all survey data was empirically developed and utilized, i

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l MASS ATTORNEY GENP#AL APPLICANTS' INTERROGATORIES (continued) 140. Please provide all documents, notes, calculations or other material  !

that have been used by you in determining, or that are in any way relevant to, any of the population figures provided in the NHRERP, including population figures for the suaner beach area population, and identify for each such document provide the population figure to which it relates and the manner in which it relates to that population figure.

RESPONSE

The bases for populatiUn estimates used in NHRERP are provided and discussed i in NHRERP, Volume 6, Sections 2, 4, 5 and Appendices E and H.

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NASS ATTORNEY GENERAL l APPLICANTS' IlrFERROGATORIES

_(continued) 141. Please identify and provide all documents, notes, calculations, metho-i dology, or other material used, looked at, or listened to by KLD Associates in determining any population figure or other population-related statistic, such as numbers of automobiles or buses, indicated in Volume 6 of the NKRERP, and iden-tify for each document so provided the figure or statistic to which it relates and the manner in which it relates to that statistic.

RESPONSE

Most of this requested information is provided in responses to Interrogatories 138 and 139. Refer to the calculation of NKRERP, Volume 6,

( Exhibit 2-1 for Applicants' estimates of persons / cars / residences for evacuating residences. The estimate of 2.4 persons / vehicle for beach area traffic was developed from onsite surveys, and estimates of 1.16 persons / car for employees based upon census data.

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NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES O" (continued) 142. Please produce all records of the on-site interviews with emergency planning personnel noted on page 1-2 of Volume 6 of the NHRERP-Revision 2 and state whether these are the same on-site interviews described on page 1-11 of this volume. If not, please produce records for these interviews as well.

RESPONSE

The onsite interviews referenced at p. 1-2 and 1-11 (NHRERP, Volume 6) are the same.

Applicants cannot produce any such records. The KLD Associates' overall approach in acquiring and documenting information is to transfer such rough I

notes as are pertinent into the form of progress reports. Seven such progress reports were published and reviewed with Civil Defense Agencies in both the State of New Hampshire and Massachusetts, Citizen Emergency Planning Committees, State Police and other interested parties. The original handwritten notes are usually discarded.

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NASS ATFORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) l 143. Please produce the demographic data obtained from the State Planning l Office noted on page 1-2 of Volume 6 of the NHRERP-Revision 2.

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RESPONSB ,

i The demographic data obtained from the State Planning Office has been listed in Appendix E and in Section 5 of Volume 6.

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NASS ATTORHgY OgNgRAL O

y APPLICAirFS' INTERROGATORIES (continued) ,

144. Please produce the survey instruments, methodology, data collected, and all documentation pertaining to the field surveys at the beach areas described in the last paragraph of page 1-10 of Volume 6 of NHRERP-Revision 2.

RESPONSB It is KLD's usual practice to transfer all information obtained in the field to permanent media such as magnetic tape or floppy disks and then to discard the source as being redundant and replaced material.

~

The methodology for collecting the field survey data 1s described on NHRERP Volume 6 page 1-10, 1-11. In general, this data is collected by direct obser-vation with the information recorded in real time on audio cassette and then transcribed to paper, or using automatic traffic recording equipment as noted earlier, or by sketching the geometrics of a section of roadway or an intersec-tion as indicated in Appendices I and L, or by taking notes in handwritten form on a tablet.

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NASS ATTORNEY GENERAL APPLICANTS' IlrTERR0GATORIES (continued) i 145. In the last full paragraph at the bottom of page 1-11 of Volume 6. It

- is note that "[d]emographic data was obtained from several sources." Please list these sources and produce the date obtained from each.

RE8PONSE 4

See response to Interrogatories Nos. 138, 139, 140, 141, and 143.

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NASS ATFORNEY GENERAL

' APPLICANTS' INTERROGATORIES (continued) 146. On Exhibit 2-1 of page 2-5 of Volume 6 of the NHRERP-Revision 2, where did the numbers 0.87, 0.98, 0.86, 0.78 come from and identify the assumptions, experts, studies, or other sources upon which they are based.

RESPONSE

The number 0.87 represents the percentage of single person house.1 olds who own cars. If you refer to the histogram in the upper left hand cornnr on page 2-7, you will note that 13 percent of 1 person households do not have cars.

Similarly the 0.98 represents the percentage of two person households who own at least one car. This can be seen by noting the histogram in the upper right' hand O corner on page 2-7 indicates that 2 percent of such households own 0 car's. The 0.86 represents the 86 percent of five person households that own two or more cars and the 0.78 figure represents the 78 percent of six plus person households that own two or more cars. The source of this material is the telephone survey which is documented in NHRERP. Volume 6. Appendices E. F and G.

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1 MASS ATTORNEY GENERAL I

APPLICANTS' INTamannATORIES (continued) 147. To clarify the " Note" to Table 2-1 on page 2-9 of Volume 6. state whether the state data used was for the two years 1980 and 1985 or the six years 1980 through 1985.

RESPoll85

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The computation of compound annual rates were undertaken by using the State data for the two years 1980'and 1985.

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NASS ATTORNEY GENERAL APPLICANTS' IlffERROGATORIES (continued) 148. Explain why, as stated on page 2-24 of Volume 8 "it is not reasonable to assume that gli lots servicing retail establishments are filled to capacity on a day when the weather attracts people to the beach area." Identify any

,a data, assumptions, experts, or other sources on which you rely.

l nasPouss i

The conclusion that all lots are not filled to capacity on a day when the weather attracts people to the beach area was based on comments made in the Kaltaan Report and on direct observation of these lots by Mr. Lieberman during the summer of 1988. '

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MASS ATTORHEY GENERAL

> APPLICANTS' IlffSRMCGATORIES

-(continued) ,

t 149. Assuming that Seabrook Unit 1 is licensed and becomes operational:

(a) how many employees will work there and (b) how unny tourists, including school children, are expected to visit the plan on an average weekday during the school year?

RESPONSE

When Seabrook Station is operating, plant staffing will constat of approximately 850 full-time personnel.

The maximum number of tourists, including nchool childrin who are expected to visit Seabrook Station on an overage weekdap is approxiantely 130 peqple, 4

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NASS ATTOItIIEY GENEltAL

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, APPLICANTS' INTIltit0GATOItIES f

, ,- (continued)

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150.

- i. In the " Note."'at the bottom of page 4-9 of Volume 6, describe what is Seant by the term " normalized" and explain how the " don't know" responses were distributed?

t RESP 00185 The term " normalized" means that effectively the " don't know" responses were discarded; the distribution shown represents positive responses.

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m, NASS ATTORNEY GENERAL O' APPLICANTS' INTrnannATORIES (continued) 151. Please produce all the source materials relied upon to produ'ce Tables 5-1 and 5-2 of Volume 8 and describe the methodology employed and all assump- s tions used for projecting 1986 employment data in Table 5-1. O

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RESPONSI The technique for projecting 1986 employment data was to take the' annual growth rate based on the data provided for 1980 and 1984 and extrapolate the -

1984 data forward two years. As explained in response to Interrogatory No. 142, {

i source material was usually discarded after the information was transferred to a permanent storage medium.

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NASS ATTORNEY GENERAL i APPLICANTS' INTERROGATORIES (continued) 152. Describe the basis for making the three assumptions about weekend employment made on the bottom half of page 5-6 of Volume 6.

RESPONSE

As stated on page 5-6, we do not have data for the percentage of employees during the weekends in each town. The estimates that are made are based upon an observed level of tourist activity during the summer in the various towns. The attempt here is to use what Applicants consider to be upper bound estimates reflecting the kind of employment which we have observed as well as the seasonal aspects of the economy in the EPZ.

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NEW ENGLAND COALITION ON NUCLEAR POLLUTION

. . APPLICANTS' INTERROGATORIES (continued)

1. In accordance with 10 C.F.R. 5 2.740(e), please supplement your answers to NECNP's First Set of Interrogatories and Requests for the Production of Documents to Applicants on New Hampshire Radiological Emergency Response Plans, filed April 30, 1986.

RESPONSE

No answer supplements of whicit Applicants are aware are presently called for under 10 CFR 5 2.740(e).

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NEN ENGLAND COALITION ON NUCLEAR POLLUTION CI' APPLICANTS' INTERROGATORIES (continued)

2. What is Applicants' position on each of the contentions that has been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan? What is the basis for your position?

RESPONSE

The Applicants'. positions on NECNP Amended Contentions RERP-8 and NHLP-6.

and TON Revised Contentions III, IV, VI and VIII in which NECNP was permitted to join, which contentions were admitted by the Atomic Safety and Licensing Board with limitations as set-forth in the Board's Memorandum and Order of February 18, 1987, follow below. Applicants object to so much of the NECNP's Interrogatory 2 as it requests Applicants to state their position here in regard to other intervenors' contentions.

NECNP Contention No. RERP-8 contends that NHRERP Revision 2 presents an ina-dequate evaluation of sheltering and choice between protective measures does not satisfy 10 CFR 550.47 (b) 4, 10. As a basis for its contention, it states that NHRERP, Revision 2 includes virtually no assessment of sheltering facility capa-city.

l The Applicants' position is that there is no provision in 10 CFR $ 50.47 Part 50 Appendix E. NUREG 0654 or Annex E which requires individualized evalu-ation of buildings to determine their adequacy and capacity for sheltering.

NHRERP, Revision 2. Volume 1 (pages 2.6-7 through 2.6-11) and Volume 4 (Appendix F, Figure 4) meet applicable regulations.

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NEW ENGLAND COALITION ON NUCLEAR POLLUTION n

k_,) APPLICANTS' INTERROGATORIES (continued) ,

NECNP Contention No. NHLP-6 contends that NHRERP Revision 2 makes inadequate provisions for evacuation of the special needs populations. It suggests, as a basis, that providing a telephone number to call for those requiring relocation assistance is inadequate because of the vulnerability of telephone systems in the event of an emergency and the possibility of system overload. Furthermore, if the telephones work, there is no assurance of assistance.

The Applicants' position is that the NHRERP Revision 2 procedures are ade-quate for the purposes intended. Furthermore, no regulatory provision is at issue.

TOH Contention-Nos. III, VI and VIII The Applicants' positions as to TOH Revised Contention III to Revision 2, TOH Revised Contention VI to Revision 2 and TOH Revised Contention VIII to Revision 2 all as admitted with limitations by the Atomic Safety and Licensing Board as set forth in the Board's Memorandum and Order of February 18, 1987 are set forth in response to interrogatories propounded by TOH and are incorporated here by reference as though separately stated herein.

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NEW ENGLAND COALITION ON NUCLEAR POLLUTION APPLICANTS' INTERROGATORIES (continued)

3. On or before March 19, 1987, please produce at the office of Harmon &

Weiss all documents on which you rely or intend to rely during this proceeding to support your position on each of the contentions that have been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan. This includes but is not limited to all documents used in answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings.

RESPONSE

f- ~ The Applicants object to production of documents at Harmon & Weiss. Those documents which have not already been served on the parties prior to issuance of NECNP's interrogatories or specifically included with the response to an interrogatory will be made available for inspection and copying at Seabrook Station or KLD's office in Huntington Station, NY. Please contact Mr. William J. Daley at (603)474-9521. Extension 2057 to arrange for document inspection.

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NEW ENGLAND COALITION ON NUCLEAR POLLUTION  !

l APPLICANTS' INTERROGATORIES O' (continued) 4

4. Please identify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to rely for your position on each of the contentions that has been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan.

RESPONSE

a. Persons on whose factual knowledge, opinions, or technical expertise the Applicants rely or presently intend to rely for their position on contentions that have been admitted are the following:

1. Richard Strome Director (RERP-8, NHLP-8, TOH-VI, TOH-VIII)

New Hampshire Civil Defense Agency 107 S. Pleasant Street Concord, NH 03301

2. William T. Wallace, Director (RERP-8. TOH-VIII)

Division of Public Health Services NH Department of Health and Human Services 6 Hazen Drive Concord, NH 03301

3. Edward B. Lieberman, Vice President (TOH-III)

KLD Associates 300 Broadway Huntington Station, New York 11746

4. Dennis S. M11eti (TOH-III)

Associate Professor, Department of Sociology Director, Hazards Assessment Laboratory Colorado State University Fort Collins, Colorado 80523

5. Gary Catapano, President (NHLP-6)

ALLCOMM, Inc.

Route 32, 381 Old Homestead Highway North Swanzey, NH 03431 i

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NEW ENGLAND COALITION ON NUCI, EAR POLLUTION APPLICANTS' INTERROGATORIES (continued)

RESPONSE

(continued)

6. Anthony M. Callendrello (All Contentions)

Manager, Emergency Planning Seabrook Station P.O. Box 300 Lafayette Road Seabrook, NH 03874

7. Paul Frechette, Technical Manager (All Contentions)

Seabrook Station P.O. Box 300 Lafayette Road' Seabrook, NH 03874

8. John Baer, Consultant (All Contentions)

Seabrook Station O P.O. Box 300 Lafayette Road Seabrook, NH 03874

b. The Applicants are not limited to reliance-on the persons named above, and reserve the right to utilize additional people, j

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NEW ENGLAND COALITION ON NUCLEAR POLLUTION APPLICANTS' INTERROGATORIES (continued)

5. Please identify all persons you may call'as witnesses on each of the contentions that has been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan. Please describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.

RESPONSE

Witnesses have not yet been selected.

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NEW ENGLAND COALITION ON NUCLEAR POLLUTION Q. APPLICANTS' INTERROGATORIES (coittinued) ,

6. On or before March 19. 1987, please produce in the office of Harmon &

Weiss all documents in the Applicants' possession which analyze or evaluate in any way the adequacy of the New Hampshire RERP or New Hampshire's state of pre-paredness in the event of a radiological emergency.

RESPONSE

Applicants incorporate by reference their response to Interrogatory 3.

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l NEW ENGLAND COALITION ON NUCLEAR POLLUTION APPLICANTS' INTERROGATORIES (continued)

7. Please identify all persons who participated in the development or drafting of Revision 2 to the New Hampshire RERP.

RESPONSE

Attachment 7-1 is, to the best of Applicants' knowledge, a list of non-clerical personnel who have assisted NHCDA in drafting Revision 2 of the NHRERP.

Applicants do not represent that Attachment 7-1 is an exhaustive list of all NHCDA personnel who participated in the drafting of Revision 2.

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ATTACIBENT 7-1 PERSONNEL ASSISTING NHCDA WITH DEVELOPMENT OF REV. 2 OF THE NHRERP

! ALLCOMM Interstate Technical Services Inc. New Hampshire Yankee

R

ute 32 P.O. Box 901 P.O. Box 300 i Homestead Higway Nashua, NH 03061 Seabrook, NH 03874 S:=tnzey, NH 03431 j Chetwynd, S. Callendrello, A.

( Catapano, G. Mankow, J. Harpster, T.L.

Crawford, S.

] Smith, L.

j Impell Corporation. Schneider 225 Broad Hollow Road EC Planning and Management Services j BNC Strategies Melville, NY 11747 Riverside Office Center 3 1866 Mass. Avenue Suite 11 2101 North Front Street j Lexington, MA 02173 Bisson, J. Harrisburg, PA 17110 Capone, P.

Thurler, K. Chin D. Baer, J.

Chu, S. Dunlap, W.

I Conklin, C. Dunn, D.

l Ebssco Services Inc. Cotter, T. Enoch, J.

Prechette, P. Heizer, B.

j Envirosphere Hanson, S. Lloyd, C.

160 Chubb Avenue Krasner, K. Long, J.

Lyndhurst, NJ 07071 Musico, B. Steele, T.

Starkman, C. VonWald, K.

Filipowicz, D. Weber, R.

Kollar, W.

Willant, G.

Stone & Webster Engineering Corp.

KLD Associates P.O.. Box 2325 19 08 300 Broadway Boston, MA 02107 336 Baker Avenue Huntington Station, NY 11746 Concord, MA 01742 Ahern,'D.

Leiberman, E. County, E.

Berens, R. Fairclough, D.

Lischinsky, L. NH Civil Defense Agency Smallcomb, J.

McCandless, S. State Office Park South Walker, A.

Rainey, J. 107 Pleasant Street Young, L.

Renz, W. Concord, NH 03301 Sinclair, M.

Swiren. B. Coogan, G. C/LS1244-

i

)

A g NEW ENGLAND COALITION ON NUCLEAR POLLUTION i

%) APPLICANTS' INTERROGATORIES i (continued) i

8. Please identify all persons who are responsible for training of emergency. response personnel for implementation of Revision 2 to the New Hampshire RERP.

RESPONSE

Personnel Involved With Training Agency / Company Adams, Pip - Fireman Manchester Fire Department, Manchester, NH Coogan, Gerald - Consultant Consultant to NHCDA, 107 S. Pleasant St.,

Concord, NH Deans, David - Sr. Field Rep. NHCDA, 107 S. Pleasant St., Concord, NH Jeffries, Robert - Field Rep. NHCDA, 107 S. Pleasant St., Concord, NH Morrison, David - Consultant Schneider/EC Planning & Management Patterson, Robert - Consultant Schneider/EC Planning & Management Thorpe, Willian - Consultant Schneider/EC Planning & Management Vigliani, Mario - Consultant HMM Associates Von Wald, Katherine - Consultant Schneider/EC Planning & Management O ,

L/072LS.8

NEW ENGLAND COALITION ON NUCLEAR POLLUTION APPLICANTS' INTERROGATORIES (continued)

9. Please describe all plans for training emergency response personnel under Revision 2 of the RERP. Identify all individuals who are responsible for that program.

RESPONSE

Plans for training emergency response personnel under Revision 2 of the NHRERP are described in NHRERP, Volume 1, Section 3.2. The NHCDA Emergency Planning Coordinator is identified in Sections 3.2 - 3.3 as the person respon-sible for the training program. Refer to response to Interrogatory 8.

d 9

L/072LS.9 j i

m NEW ENGLAND COALITION ON NUCLEAR POLLUTION APPLICANTS' INTERROGATORIES *

(continued)

INTERROGATORIES REGARDING SPECIFIC CONTENTIONS NHLP-6 and HAMPTON REVISED CONTENTION IV TO REVISION 2 .

10. Identify, describe and/or produce any communications or agreements between the Teamsters Union and its member drivers regarding the NHRERP.

RESPONSE

The Applicants object to NECNP Interrogatory 10 for the reason that it seeks information beyond the purview of Offsite Emergency Planning hearings " law of the case" as established by rulings of the Atomic Safety and Licensing Board.

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L/072LS.10

, - - - - - -a-, -, , , , . , , . , , - - , ,

NElf ENGLAND C0ALITI008 ON NUCLEAR POLLUTION APPLICANTS' INTERROGATORIES (continued)

11. Provide copies of regular employment contracts of drivers in the Teamsters Union who will be relied on during a radiological emergency.

RESPONSE

The Applicants incorporate, by reference, their objection to NECNP Interrogatory 10.

1 0

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i L/072LS.11

O NEW ENGLAND COALITION ON NUCLEAR POLLUTION U APPLICANTS' INTERROGATORIES (continued)

12. Provide all agreements or correspondence between the Teamsters Union or Union officials, Applicants, or the State of New Hampshire, regarding the possible provision of transportation services by Teamsters members during a radiological emergency.

RESPONSE

The letter of agreement with the Teamsters Union Local 633 is contained in NHRERP, Volume 5.

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s NEW ENGLAND COALITION ON NUCLEAR POLLUTION APPLICANTS' INTERROGATORIES (continued)

HAMPTON REVISED CONTENTION VIII TO REVISION 2

13. NUREG-0654 states that "the overall objective of emergency response plans is to provide dose savings (and in some cases immediate life savings) for a spectrum of accidents that could produce offsite doses in excess of Protective Action Guidelines (PAGs)." In this vein, NUREG-0654 requires planners to con-sider, inter alia, the timing and consequences of potential releases. What j spectrum of accidents did Applicants consider in developing Revision 2,to the NHRERP, and what are the characteristics of those accidents? What quantitative dose savings result from implementation of the protective measures proposed in

/ Revision 2 given each type of accident that was considered? Please provide all data that supports your conclusion.

RESPONSE

The passage from which the quotation in this interrogatory was excerpted (NUREG-0654, Planning Basis, page 6) goes on to say "No single specific accident i

sequence should be isolated as the one for which to plan because each accident could have different consequences, both in nature and degree". NUREG-0654 calls for planning based on a spectrum of accidents (e.g., see NUREG-0654, Appendix I and NHRERP, Volume 2 Appendix A). It is this spectrum which the NHRERP con-siders.

There is no requirement to make a prediction of dose savings for any par-

ticular accident within this spectrum nor has this been done.

L/072LS.13

NEW ENGLAND COALITION ON NUCLEAR POLLUTION APPLICANTS' INTERROGATORIES (continued)

14. Assuming that dose reductions are achieved, describe the health effects associated with each of the accidents that you considered in developing Revision 2 to the RERP.

RESPONSE

Refer to response to Interrogatory 13.

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L/072LS.14

O NEW ENGLAND COALITION ON NUCLEAR POLLUTION APPLICANTS' INTERROGATORIES .

. (continued)

15. Identify and provide access to any and all of Applicants' calculations of potential dose consequences to the public in the event of a radiological emergency at Seabrook, and the bases for those calculations.

RESPONSE

The Applicants object to NECNP Interrogatory 15 for the reason that it is without regulatory basis.

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L/072LS.15 l

.. GENERAL-INTERROGATORIES SAPL A. For each and every one of the admitted SAPL Contentions (*'s 31, 7, 8, 8A, Redrafted 15, 16, 18, 25, 33, 34, and 37), provide the following information:

a. What witnesses do the Applicants intend to have testify with respect to this contention?

b. What position does the Applicants intend to take on this contention and what is the basis of this position?

c. What documents will be used in support of the Applicants position on this contention?

RESPONSE

a. Witnesses have not yet been selected.

b. The position Applicants intend to take with respect to these conten-tions is as follows:

SAPL Contention No. 7 O Reasserted SAPL Contention 7 contends that State and local plans fail to meet the requirements of 10 CFR 50.47 (b)(11), 50.47 (b)(10) and NUREG - 0654 because means of evacuee and emergency worker decontamination supplies and equipment have not been shown, and there has been no showing that adequate means for waste disposal exist.

Summary disposition has restricted this contention to availability of decontamination personnel and equipment at reception centers and for collection and storage of contaminated water.

Applicants' position is that State and local plans meet appli-cable regulations and guidelines and that there will be adequate per-sonnel and equipment available at reception centers. Further, Applicants' position is that weste water dilution is adequate under State law and regulation as opposed to storage.

SAPL Contention 8 and 8A Reasserted SAPL Contentions 8 and 8A contend that State and local plans fall to meet the requirements of 10 CPR $ 50.47 (a)(1), 50.47 (b)(2) and NUREG - 0654 in that there is no demonstration that adequate personnel resources exist to fully implement the State, local, and com-pensatory response efforts. Furthermore, the potential removal of emergency workers from the field prior to the populace being evacuated results in a serious conceptual flaw of the plans.

L/092LK.1

I Applicants' position is that State and local plans meet the appli-

. () cable regulations and guidelines and that there will be adequate per-sonnel resources to implement the plans. Further, Applicants' position i

is that emergency workers receiving exposure levels of 5 R will be replaced in the field or authorized to receive in excess of SR up to a higher threshold, if-their position is essential to supporting eva-cuation efforts.

Redrafted SAPL Contention No. 15 Contends that Letters of Agreement LOAs in NHRERP, Rev. 2,. Volume 5 are adequate. As bases SAPL asserts:

1. Pease AFB and Portsmouth Navy Yard Agreements are not in Rev. 2.

2. No LOAs with Reception Centers, mass care facilities; and LOAs are missing for some host special. facilities.

3. No LOAs with Rockingham County for Dispatch Center

4. No LOAs with NE Telephone

5. Teamsters LOA does not assure sufficient drivers.

6. OMNE letter is not current.

Applicants' position is:

1. The Department of Defense is identified as a Federal support agency which will provide military assistance, in the form of manpower, technical support and logistical support, including

air-lift services and telecommunication support as identified in the Federal Radiological Energency Response Plan 50 Fed Reg 46542 November 6, 1985, as requested by FEMA. Pease AFB and

( Portsmouth Navy Yard are Department of Defense establishments.

l

' 2. No LOAs are required with Reception Centers under the law of the case. No LOAs are required with pertinent mass care faci-11 ties. The missing host special medical facilities LOAs will be located or re-issued.

3. Rockingham County Dispatch Center is a governmental entity and no LOA is required.

4. A LOA with New England Telephone Company (NET) is not required because NET is not assigned a responsibility under NHRERP. The Teamsters LOA is sufficient as is.

,5. If needed the OMNE letter will be updated.

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Reasserted SAPL Contention No. 16

() Contends that the New Hampshire State and local plans do not make adequate provisions for sheltering various segments of the populace in the EPZ and therefore the plans fall to meet the requirements of 10 CFR 50.47 (a)(1) & 50.47 (b)(10) and NUREG - 0654 Items II J.10.a and m.

SAPL states as basis for Contention 16 that no information is given with regard to schools and day care centers.

Applicants' position is that NHRERP Rev. 2 meets applicable regula-tions and guidelines. Schools and day care centers are included within sheltering factors for the general public. See Volume 4, and Volume 1 Table 2.6-3.

Note "125" Rea whole body dose is listed in Volume 1, Table 2.6-3

, for the Wentworth Home. This should be corrected to read "12.5".

1 SAPL Contention No. 18

. Contends the NHRERP Rev. 2 significantly miscalculates the numbers of non-auto public which has resulted in an under assessment of regular j and special need buses. Therefore NHRERP Rev. 2 fails to meet 10 CFR  ;

$50.47 (a)(1), (b)(8) and NUREG - 0654. Ites II.J.10.9, Appendix 4. I

! p. 4-3. -

Applicants' position is the bus need estimates in NHRERP Rev. 2 are accurate and well founded. Moreover, bus resources exceed total need.

NHRERP Rev. 2 meets applicable NRC regulations and guidelines.

SAPL Contention 25 Contends that State and local radiological emergency response

, plans are lacking in their provisions for protecting persons whose mobility is impaired due to institutional or other confinement; Category I (Advanced Care Required) and Category IV (School Bus) patients are inadequately provided for by way of letter of agreements; the Exeter Hospital Radiological Emergency Response Plan is discrimi-nating in its treatment of patients aged 55 years old or considered too critical for transport; letters of agreement are not in place with host senior citizens homes, reception centers, or mass care facilities; l that O'Brien Ambulance will not participate in response activities; l also SAPL wishes to preserve its objection to the adequacy of the

! system devised to identify special needs persons and therefore do not ,

meet the requirements of 10 CFR 50.47 (a)(1), 50.47(b)(8) and NUREG ,

-0654. Item II.J.10.d. i l

Applicants' position in reference to so much of the contention that '

has been admitted by the Board is that State and local plans adequately I provide for the reasonable assurance for the provision of protective actions for mobility-impaired persons; the contention aisrepresents the

! L/092LK.3 i

l i

i .

categorization system used in identifying patients at all host facill-

% ties: Exeter Hospitals Radiological Emergency Response Plan provides for the most appropriate protective actions for all its potential patients; letters of agreement are in place for all but two host health-care facilities; and sufficient ambulance resources are available by way of letter of agreement.

1 l SAPL Contention No. 31 1

Contends that Volume 6 of NHRERP Revision 2 the KLD ETE Report does not meet the 10 CFR 50.47 (a) (1) (b)10, NUREG-0654 Item II J.2.

10, i, h, and 1 and Appendix 4 because KLD ETE underestimates EPZ and subpart (Region) evacuation times. As contention basis, SAPL asserts:

1. KLD estimates of 3,000 "through" vehicles on highway inade-quate, unclear if 3,000 vehicles factored into time estimate calculations; when and by whom aerial photos of Hampton Beach showing 300 vehicles on roadway taken unstated.

2. Use by KLD of figures from Kaltaan, 1981 report unreliable due to area growth (vehicle / dwelling for seasonal units, vehicles at campgrounds, vehicles for overnight accommodations).

3. Resident and employee population growth not provided for over the ters of the plant's life span, j 4. Unrealistic to assume traffic control measures will be in

effect during evacuation; state resources would not be mobi-lized quickly enough, assumptions used by KLD that ETE would be extended only 20-30 minutes with immediate General Emergency "are not carefully elucidated".

l 5. KLD estimate falls to account empirically for 254 spontaneous j evacuation rate, or account for traffic outside of EPZ spon-taneously evacuating.

6. Due to low telephone survey call completion rate, no valid basis for notification times, commencement of evacuation trips, average vehicle occupancy.

7. Assumes workers can return home in normal time frames.

i

8. Total of 146 traffic guides are needed for TCPs and ACPs:

l NHRERP does not support adequate numbers.

9. KLD estimate assumes no affect of stalled vehicles, recommenda-tion for placement of tow trucks not indicated in NHRERP, only two of the tow truck locations are within EPZ, no indication given for how long a tow truck would take to respond.

L/092LK.4 l

J

10.KLD time estimate report. ignores effect of hilly topography west of I-95, choke points at bridges over rivers and streams.

11. Mobilization times for buses are not reasonable, particularly during off-business hours. Survey and replies not in appendices.

12. Number of transit dependents underestimated.

13. Loading times for boarding special facilities too short; loading non-ambulatory persons omitted, no estimate of non-institution-alized, non-aabulatory persons.

14. Collected data re: road geometrics should confira roadway widths 4

equal to or greater than assumed.

15. Calculation of transit dependent based directly on per cent of time average vehicle is inoperable incorrect.

16. Simulation model seriously defective,

a. Traffic control information is unclear,

b. Loading

! 17. Estimate of 2.6 persons / vehicle for residents unrealistic, not supported by August 1985 and July 4, 1986 actual vehicle counts on.

O 18. Insufficient empirical base of transient population inferring from beach blankets and parking spaces.

Applicants' Position is that the KLD ETE satisfies NRC regulations and guidelines and provides adequate and appropriate information for the decision makers, at the time of an incident, to-employ their judgment processes to deter-eine what adequate protective measures may be implemented. As to the bases asserted for SAPL Revised 21

1. The KLD estimate of 3,000 EPZ through vehicles is a reasonable assumption.

l

2. Kaltaan's figures are sufficient for the purposes employed.

l

3. RERPs are continuing documents with frequent updates. The RERP is reviewed at least annually and kept current. Population projections are not used as a planning base.

4. Troop A has procedures in place to request back-up police and other state assistance.

5. No regulatory requirement to consider protective action planning beyond the established EPZ.

L/092LK.5 w

4

/'"% 6. Bases simply suggest a point of view.

U 7. Commuters returning to.their homes would have minimal impact on evacuating vehicles; 2-way traffic is to be mafntained during an evacuation to accommodate emergency vehicles, therefore no i vehicles would be moving against evacuating traffic: ACPs would l limit entrance to an evacuating area to emergency vehicles and residents returning to prepare to evacuate.

l

8. Traffic guides are identified in adequate numbers with back-up to local by state, and State Troop A with other troops.

~

9. Stalled vehicles are typically moved to the side of the road under normal circumstances; past history demonstrates assistance by other evacuees in removing the vehicle to main-tain access. Truck services have been identified and are in place via LOAs.

10. Reference Volume 6, page 1-5, discusses topography (hills) with relation to a general discussion of countryside versus direct bearing on evacuation time estimates.

12. Mobilization times are reasonable. See No. 14.

13.KLD adjusced transit dependent figures fr'on 3 percent to 2.5 percent of population based on site-specific data (survey);

figures are similar to the NHCDA survey (Section VI, RAC Comments, 1986). -

14.The loading time for special facilities is estimated as four times that provided by the Highway Capacity Manual (Volume 6, page 11-21) for urban bus boarding. Non-institutionalized per-sons with special transportation needs are identified yearly by way of the survey.

15.17-18. Assert personal viewpoints and are without regulatory bases.

19. Actual vehicle counts were accomplished on beach access roads during the July 4th weekend, 1986 and August 1985 (Volume 6, pages 4-6 8). Exhibit 2-1 provides an estimate of the persons /

vehicle for evacuation of permanent residents.

20. Transient population estimates have a rational basis.

SAPL Contention No. 33 i Contends that the NHRERP fails to meet the requirements of 10 CFR S 50.47 (d)(1), 50.47 (b)(8), 50.47 (b)(9), 50.47(b)(10) and NUREG-0654 in that there is no demonstration that adequate provisions for the L/092LK.6

._. . . ~.- - - . . . . - - - . - . . -

. n registration and monitoring of evacuees at reception c'nters e will be l f~s conducted within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period. This is due,to reducing the l A_,)

q number of reception centers from six to four communities to. provide  ;

support for this effort and that.the processing rate of evacuees has ~

i not been established in the plans. '

I s p Applicants' position;is that the K!FIRP meets the app'11 cable regulations and guidelines and that there will be adequate personnel

.and equipment resources and facilities to support the registration and monitoring of evacuees at reception centers within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> t period. _

SAPL Contention No. 34

. Contends.that State and local plans do not meet.the requirements s .. j of NUREG - 0654 Item II.J.10.b and Appendix 4 that there be maps showing the population distribution around the facility, that popula-tion estimates identified in Rev. 2 have been erroneously reduced, and therefore provide no reasonable nasurance that adequate protective i measures can and will be .taken pursuant to 10 CFR 50.47 (a)(1) and 50.47 (b)(10).

• i Applicants' position is that population figures are accurate, based on the most recently available, locally-provided population estimates. ,

Maps depicting population distribution by sector, as recommended by

NUREG-0654. Item II.J.10.b., are included within the NHRERP. Further- ,

more Applicants' position is that the contention misstates the total I population figures as identified in the NKRERP. Table 1 of Volume 18, contains a typographical error which will be corrected.

SAPL Contention 37 ,

N 1 Contends that State and local plans fail to meet the requiresents of 10 CFR $50.47 (a)(1), 50.47 (b)(3), 50.47 (b)(10) and NUREG-0658 in that there is no demonstration that an adequate nutber of emergener -

vehicles, drivers and support personnel will be"avaliable to support evacuation efforts, nor is there provided assurance of the effective use of available emergency vehicles. There are insufficient numbers of emergency vehicles as demonstrated in the lack of supporting letters s of agreement. This is coupled with the. fact that traffic congestion will result in the delay of thosa vehiciss completing their assign-ments.

Applicants' position is that the NMRERP meets the appplicable i regulations and guidelines and that there will be adequate personnel and emergency vehicle resources to support evacuation offorts. Further,

! Applicants' position is that traffic congestion will not constrain emergency vehicles from completing their assignments.

L/092LK.7

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91, j

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c. Thore cocuments which have not already been served on the parties prior l to issuancJ of-the MASS AG-interrogatories or specifically included with the  ;

response'to an interrogatory will be made available for inspection and copying at the Seabrook Station er at KLD's office. Please contact Mr. William J. Daley j *at.(603) 474-9252, extetision 2057 to arrange for document inspection.

l l B. For each and every' witness identified in answer to subpart a above, prov.do the following information:

a. Name

b. AdEress

c. Preserat profession'al or employment affiliation

4.. ,/ /

~

d. Curriculum vita ,

, RESPONSE a

> ' See response to General' Interrogatory A.a

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9: a x

f? . (? ^ a SEACOAST ANTI-POLLUTION LEAGUE

~

APPLICANTS' INTERROGATORIES  !'

1. Provide a detailed explanation as to how the number of "through" 1 1

vehiclesintheEPAhighwaynetworkattibtimeoftheor,derdoevacuatewas5~2

's calculated. Was this 3,000 estimate included in the calculations which resulted in the time estimates?

< RESPONSE

)

a. The primary routes servicing external-external trips through the Seabrook D- N., Station EPZ are the Interstate Routes 95 and 495. All other routes within the '

EPZ which could be interpreted as through routes (e.g., Ro'utes 1, 107, 108) are

~ two-lane roads which are not relatively attractive to through travelers. About- ! !

O

'(s,) 160 lane-miles are provided by these express routes.

o I-495: 2 miles G 4 lanes; 5 miles 9 6 lanes o I-95: 13 miles G 8 lanes; 2 miles G 6 lanes The calculations of ETE for the summer scenarios assume that the accident takes place when the beaches are at maximum usage, roughly at 2:00 PM. When developing the inputs to the IDYNEV model, it was e++.iaated that 3000 through vehicles, not otherwise counted, would be on SEP acte rk at this time. This estimate was based on observations made while travesang the network.

Specifically, it appeared that volumes on I-95 and on I-495 were traveling at l

Levels of Service (LOS3 that did not exceed LOS B or C. The associated range of density is 13-30 passenger cars per mile per lane, thus, the total number of

/

vehicles on the highways is between 2080 and 4800, many of which are not through

,()' vehicles.

L/071LS.1 c ,

/

SEACOAST ANTI-POLLUTION LEAGUE j APPLICANTS' INTERROGATORIES (continued)

R5SPONSE (continued)

For the situation where access control is implemented prior to the Order to Evacuate (OTE), then this estimate of 3000 through vehicles represents those who entered the EPZ prior to the laplementation of access control and have not as yet completed their travel through the EPZ by the time the OTE is given. At

.that time, the number of through vehicles within the network could be substan-tially less than the number which occupied the network at the time the access controls are applied. Thus, it is seen that the number of external-external vehicles on the EPZ network at the OTE should not exceed the 3000 estimate, and

( any be substantially less.

Direct observations of traffic flow on these major routes at that time, sup-ported by aerial films taken on July 4 and 5, 1986 at approximately 2:00 P.M.,

which was after the ETE calculations were undertaken, indicate that traffic volume is very low. Specifically, traffic is operating at LOS A and B. The associated range of traffic density is less than 20 passenger cars per mile in each lane.

Thus, based on these later observations, the total number of vehicles on these highways at this time is less than or equal to approximately 3200 passenger cars (20 x 160). Many of these cars, of course, belong to EPZ resi-dents, tourists and employees who have already been counted. It is seen, there-fore, that the estimate of 3,000 through vehicles -- not already counted -- is a conservative one.

L/071LS.I.1 j

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SEACOAST ANTI-POLLUTION LEAGUE

• APPLICANTS' INTERROGATORIES (continued) ,

l

RESPONSE

(continued)

Traffic on these highways during the off-season generally does not exceed the volume associated with LOS C, regardless of time of day. Thus, the estimate of 3,000 through vehicles is applicable throughout the year.

The NHRERP calls for access control points to be established at the periphery of the EPZ which will divert traffic fron entering the EPZ from points j outside except, of course, those vehicles which will participate in the evacu-ation (NHRERP Volumes 1, p. 2.6-16).

1 O b. Yes.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

2. Provide copies of all of the aerial photographs KLD looked at of the Seabrook EPZ. By whom were the aerial photographs used in the KLD Report taken?

Who provided the aerial photographs to KLD? When were the photographs taken (provide specific date(s) and time (s) of day)? (Answers should be provided both for the aerial films from which the 300 cars in the beach area were counted (see Vol. 6, p. 10-16) and the aerla1 photographs referenced at Vol. 6, p. 2-10).

RESPONSE

Copies of aerial photographs are available. Lowry Aerial Photography Service, South Hamilton, M provided the aerial photographs to KLD. The aerial photos referenced on pages 10-16 were taken on Sunday August 11, 1985, early afternoon (p. E-5).

The 300 cars were on Hampton Beach, not the entire beach area. The aerial photos referenced on p. 2-10 are these same aerial photos.

Note: All citations are to NHRERP Volume 6.

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SEACOAST ANTI-POLLUTION LEAGUE

' APPLICANTS' INTERROGATORIES (continued)

3. Provide any and all sources of information and documents relied upon to generate the KLD estimates of:

a. vehicles per dwelling at seasonal housing units

b. counts of overnight accommodation units

c. numbers of vehicles at campgrounds s

Provide page references to documents cited in response to parts a, b, and c above.

RESPONSE

a. This was done by direct observation in an on-foot survey which O recorded a value of 2.6 vehicles per dwelling (NHRER, Volume 6,

p. E-10).

b. Figures 2-6 and 2-7 of NHRERP Volume 6 (Kaltman Report referenced at E-10 of Volume 6).

c. Figure 2-8 of NHRERP Volume 6 (Kaltaan Report referenced at E-10 of Volume 6).

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L/071LS.3 l L

r' SEACOAST ANTI-POLLUTION LEAGUE G

V APPLICANTS' INTERROGATORIES (continued)

I l

4. Describe in detail the method by which the estimate of the peak summer weekend population of the Town of Hampton was reduced from 110,000 to 36,635.

RESPONSE

Applicants did not employ any method of reduction; the method used to esti--

mate the peak summer weekend population of 36,635 is described in NHRERP Volume 6, Chapter 2.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

5. Provide any and all documents upon which KLD relied for population estimates for the following groups:

a. permanent residents

b. seasonal housing residents

c. patrons of overnight accommodations

d. transients (i.e. daytrippers)

e. transit dependent persons Provide a succinct description of how the estimates of these groups and any other groups KLD used were combined to estimate the total population within the 10-mile EPZ. Provide the peak population estimate numbers for the 10 mile. Provide the peak population estimate for what KLD describes as the " beach area."

RBSPONSB

a. The estimate of permanent residents was obtained from Town Clerks by telephone communication. See NHRERP Volume 6. Appendix E (p.

E-11, Item 50),

b. Seasonal housing residents were obtained from the Kaltman Report.

c. Item c was obtained from the same source as b.

d. The estimate for Item d, namely transients, was obtained by assuming that the available parking capacities in the beach areas was completely filled with cars. Based on field observations of vehicle occupancy, we were then able to estimate the total number of people visiting the beach. These people included not only transients, but all visitors to the beach including those wno are residents and who make use of the hotel / motel accommodations in the beach area. See NHRERP Volume 6 Appendix E (p. E-10).

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTEIUt0GATORIES (continued) .

RESPONSE

(continued)

e. Details of the calculation of transit dependent persons other than those in schools and in special facilities, are presented in con-siderable detail in NHRERP Volume 6. Section 11.

The arithmetic computations used to combine these individual esti-mates to form ,he t total within the EPZ are summarized in Appendix M. The peak population figures are provided in Section 10 of the Plan in the form of " roses." These roses can be found on pages 10-46 through 10-69 inclusive with further summaries given in Table 10-10a through d.

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L/071LS.5.1

SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

6. Provide any and all docuaents KLD may have relied upon to project resident and employee growth in the EPZ over the next 10 years. How, if at all, was growth accounted for in the KLD estiaates?

RESPONSE

KLD did not project resident and employee growth within the EPZ over the next ten years.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued) 1

7. Describe in detail how the State of New Hampshire is going to staff the Traffic Control Posts (TCP) and Access Control Posts (ACP). For each of the  !

TCP and ACP designated in the KLD Report, state the name and address of the per-son who will man the post and the organization or agency from which that person will be drawn. Provide rosters of the personnel for each and every organization or agency from which traffic control personnel will be drawn. Describe how many of the personnel can reasonably be expected to be on duty at any given time.

RESPOUSB A. NHRERP, Volume 1 Section 2.6.5, describes how the State of New Hampshire will staff access control points (ACP). This description is further supported by:

1. NHRERP, Volume 6, which identifies access control points for the EPZ;

2. NHRERP, Volume 2. Appendix E, which contains a map of access control points; l' 3. NHRERP, Volume 4B, State Police. Troop A Procedures and Appendix C to the procedures which contain access controleinstructions; and i

4. Traffic Management Manual of the State of New Hampshire, which j identifies and describes each ACP, contains asps and schematics of

the ACPs, contains instructions for implementing ACPs and provi-des the numbers of personnel available from the responsible agency for staffing ACPs.

! B. NHRERP, Volumes 16-32,Section II, describes how traffic control i

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i SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

RESPONSE

(continued) points (TCP) of the municipalities within the EPZ will be implemented and staffed. NHRERP, Volume 1, Section 1.3.3, NH State Police responsibilities, describes.the support function of the NH State Police for staffing TCPs. These 4

descriptions are further supported by:

i 1. NHRERP, Volume 6, which identifies traffic control points for the EPZ;

2. NHRERP, Volumes 16-32,Section IV, Chief of Police Procedures, which contain traffic control instructions for local police:

! 3. NHRERP, Volume 4B. State Police, Troop A Procedures and Appendix l

D to the procedures, which contain traffic control instructions l

for state police: and

4. Traffic Management Manual of the State of New Hampshire, which

identifies and describes each TCP, contains maps and schematics of the TCPs for each municipality, contains instructions for imple-menting TCPs, identifies the agencies responsible for staffing each TCP, and provides the numbers of personnel available from the responsible agencies for staffing TCPs.

l

C. The name and address of each person who would man each TCP and ACP is l

not presently known, nor is it required. As a planning basis, regulations l

require only that sufficient resources are available to carry out identified emergency response functions.

D. Rosters of personnel of each agency will be located at the headquar-ters of each of the responsible agencies, and will have to be inspected at those locations.

E. Applicants do not presently know how many of the personnel can reaso-nably be expected to be on duty at a given time.

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.. SEACOAST ANTI-POLLUTION LEAGUE O~

APPLICANTS' INTERROGATORIES (continued)

8. . Describe the basis of the assumption that traffic management and control measures are in effect at the time the evacuation is ordered. How much time does KLD assume it will take to put these measures into effect?

RESPONSE

The KLD studies are based upon the assumption that the vast majority of evacuating travelers will comply with the recommended routes. The role of the traffic guides, for the most part, is to facilitate these movements and to encourage this kind of compliance. There is only one location where there is a strong need to dispatch traffic guides for the purpose of maintaining highway capacity as used in the ETE calculations. This location is the Hampton Interchange which is identified as Traffic Control Post No. D-HA-02, shown on f

l page I-39, Vol. 6 of the NHRERP. At all other locations, the traffic guides do not take actions which increase highway capacity beyond that which is normally r

i available under peak heur conditions for the scenario in question.

The KLD estimates of capacity, which were based upon the procedures of the 1985 Highway capacity Manual, adopted a conservative posture to take into account any uncertainty in driver responses and the prospect that there would be i

some short-term disruptions associated with some cars running out of gas and

, having to be pushed onto the shoulder of the road.

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i L/071LS.8

SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

RESPONSE

(continued)

Consistent with the above approach, the only assumption that directly influences the ETE calculations is that the cited Traffic Control Post in Hampton would be in effect before congested traffic conditions arise at that location. It is estiaated that the elapsed time betwee,n the sounding of the Alert and the time that the highways become congested in that area during the summer peak period, is approximately 15 minutes (see Distribution E on page 4-16). To the extent that the other locations are manned somewhat later into the evacuation, one can expect a higher degree of non-cong11ance than if the Traffic Control Posts are manned at the Order to Evacuate. The effect of this non-compliance, however, has been found to be benign in the sense that the overall ETE is not affected. ,

Note: All citations are to NHRERP Volume 6.

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SEACOAST ANTI-POLLUTION LEAGUE

/

C APPLICANTS' INTEltit0GATORIES (continued)

9. Describe in detail the assumptions employed in the sensitivity study that yielded the result that an immediate General Emergency would only extend ETE's 20-30 minutes.

4 BESPONSE The sensitivity study to explore the effects of an immediate General Emergency is exactly the same as the computations performed under the planning basis, with the exception that the population in the beach areas do not get a head start. That is the sirens are activated throughout the areas to be evac-usted, including the beach areas, so that the entire population responds to this notification process at the same time. As a result, the zero time which is the 3

reference point for calculating the evacuation time estimate starts at the time l

when the entire population is alerted.

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SEACOAST ANTI-POLLUTION LEAGL1 n

v APPLICANTS' INTERROGATORIES (continued) l

10. How was the 255 spontaneous evacuation rate arrived at?

RESPONSE

The figure of 25 percent for spontaneous evacuation was obtained from Dr.

Mileti, a nationally-renowned expert on the subject of human behavior during emergencies.

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SEACOAST ANTI-POLLUTIOlt LEAGUE APPLICANTS' INTERit0GATORIES (continued)

11. Provide a aap detailing every parking space in the " beach area."

RESP 0llSB To the best of our knowledge, there is no such aap.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

12. Why did KLD not account for roadway capacity reductions resulting from disabled vehicles?

RESPONSE

KLD did account for short-term reductions in highway capacity due to vehicle disablements, by adopting conservative estimates of highway capacity.

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l SEACOAST ANTI-POLLUTION LEAGUE 10 V APPLICANTS' INTERROGATORIES (continued) a

13. State the bases for the assumption that incoming emergency response vehicles will be able to travel from 40 to 50 MPH.

RESPONSE

The discussion on pages 11-19 and 11-20 (NHRERP, Volume 6) provide the bases for the assumption that incoming emergency response vehicles will be able to travel at mean speeds of 40 to 50 mph. These estimates take into account the fact that speeds on the highways approaching the EPZ will be somewhat higher than these mean values (see Figure 2-14 in the Highway Capacity Manual), and th at speeds within the EPZ will be lower than these mean values. Thus, these O mean values reflect both the higher speeds outside the EPZ and the lower speeds within the EPZ.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES

'- (continued)

14. Explain why the KLD Report does not esploy the capacity reduction for snow cited in the 1985 Highway capacity Manual.

RESPONSE

The capacity reduction for snow that is incorporated within the KLD esti-antes is based upon work that has been done by two agencies, one of which has been cited in the Highway capacity Manual. The 25 percent reduction in highway capacity for snow is consistent with current knowledge.

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SRACOAST ANTI-POLLUTION LEAGUE D APPLICANTS' INTERROGATORIES (continued)

15. Explain why the KLD Report fails to take into account choke points at bridges.

RESPONSg The term choke point is not a commonly used traffic engineering term. A better term would be the term " bottle neck" which implies that for one reason or another a particular point on the highway exhibits lower capacity than the segments of the highway on either side. For a two-way two-lane highway, such lower capacity would be reflective of a condition where the directional split of the traffic flow is in balance or at least competitive. Where there is a domi-nant directional flow, as would be the case during an evacuation, there would be no effec'tive reduction in capacity since there would be little, if any, friction between vehicles traveling in opposite directions. While there are a few such narrow bridges within the EPZ on those roads which service high volumes of evac-unting traffic, the existence of a dominant outbound flow pattern and lack of substantive counter flow of traffic, would not, in my opinion, reduce the high-way capacity below those estimates provided in the ETE study.

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SEACOAST ANTI-POLLUTICII LEAGUE APPLICANTS' INTERROGATORIES (continued)

16. Who performed the telephone survey of the bus companies referenced in Vol. 6 at p. 11-18? Provide copies of the survey instrument employed, the raw data fron'the responses and the compilation of the responses.

RESPollSB The telephone survey of the bus companies was performed by a clerk at KLD.

The com'pilation of the responses is provided in NHRERP Volume 6.

To the best of the Applicants' knowledge, there is no survey instrument or raw data available to produce.

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l SEACOAST ANTI-POLLUTION LEAGUE s APPLICANTS' INTERROGATORIES l (continued)

17. Provide the raw data collected in the telephone survey and describe in detail how it was dealt with to arrive at the 2.5% estimate of transit dependent persons for the resident population.

RESPONSE

The raw data collected in the telephone survey is available for observation at the office of KLD Associates. The methodology for arriving at the estimate for transit dependent members of the population is detailed in NHRERP, Volume 6 Section 11.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTEIUt0GATORIES (continued) ,

18. What are the estimated percentages of transit-dependent persons in tne 4

seasonal and transient populations? Detail how these estimated percentages were arrived at.

RESPONSE

As a result of discussions with public officials along the coastal area, we have been informed that virtually all seasonal and transient visitors to the area have access to transportation. Most of them, of course, travel to this area by private vehicles a relatively small percentage arrive in transit

, vehicles which, of course, are available to them for any subsequent evacuation.

l Any hitchhiking that takes place is considered to be another form of transpor-tation using private vehicles.

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SgACOAST ANTI-POLLUTION LgAGUg APPLICANTS' INTgRROGATORIg8 (continued)

19. Describe in detail the basis for the assumption that elderly or disabled persons can board a bus in a 15 second mean highway.

RESPONSE

KLD was involved in a large scale data collection program of transit opera-tions in San Francisco some years ago. Part of that activity was to observe and time the boarding rates of people onto public transit buses. The ages of these people varied widely, of course, and included the elderly. It is our obser-vation that while the elderly may in fact take somewhat longer than a younger person to board a bus, any such difference is relatively small. A fifteen second average headway for boarding a bus represents a five fold increase rela-tive to the average boarding rates which have been observed and documented in the Highway Capacity Manual.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES V (continued)

20. Provide the detailed data collected on roadway geometrics, list every road studied in the Seabrook EPZ and state to which of the 4 classifications that roadway has been assigned.

RESPONSE

The data collected on roadway geometrics was initially stored on audio tape, then transcribed to paper and subsequently represented in the form of data on the input screens to the IDYNEV model. These data were used to assign the net-work links representing two-lane roadways to the four classifications defined on page 3-9. An examination of Appendix N will reveal the capacities assigned to each highway segment which is identified as a link and shown graphically on Figure 1-3. This information can then be correlated with the capacity estimates given in Section 3.

Note: All citations are to NHRERP Volume 6.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

21. Since KLD prepared the evacuation time study at Vol. 6 of the NHRERP, has any other information come to light that would in any manner alter the

< results and conclusions of the report? If so. specify the nature of the infor-nation and provide any and all relevant documentation.

RESPONSE

To the best of Applicants' knowledge, KLD Associates. Inc. has conducted the following sensitivity analyses subsequent to publication of NHRERP, Rev. 2:

1. Sensitivity analysis of the effects of major road blockages on ETE.

2. Sensitivity analysis of the effects of non-compliance of evacuees with evacuation route instructions.

4

3. Sensitivity analysis of the effects of different levels of spontaneous evacuation on ETE.

4. Applicants incorporate by reference the response to Interrogatory #2 for production of documents.

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-9 SEACOAST ANTI-POLLUTION LEAGUE. \l(x,

• t, .f.i, hP 1

APPLICANTS' INTERROGATORIES (continued) ]i '

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22. ' Provide documentation of discussions with campground opecators,which / ,

formed the basis of the 75% estimate of unoccupied campiground sites during the ,

q day in Vol. 6 of the NHRERP et p.^ 2-20.

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R58PONSE F

,_ - r No such documentation exists. ,

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FEACOAST ANTI-POLLUTION LEAGUE

/JPLICANTS' INTERROGATORIES (continued)

\

23. Where are the barri_ cades and cones to be employed at Traffic Control e.

Posts (TCP) and Access Contral Posts (ACP) to be stored? How many cones are

' available for use and how many barricades are available for use? Detail the 4 means by which these traffic management devices are to be deployed to the loca-

', pf,~ '

tions at which they ara,to be used (i.e. who'is to deploy them and by what means

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are they to be transported?). Provide an estimate of the amount of time it will atake to have all of this equipment in place. Describe how snow removal respon-o sibilities would affect the availability of pe sonnel to deploy the traffic 4 management devices.

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!' RESPONSE

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NHRERP Volumes 16-32,Section II describes how traffic control points in r the municipalities within the EPZ will be implemented and staffed. This

equipment will be stored and maintained in municipal facilities of each

'< community.

.N,HRERP Volume 1. Section 1.3.3, New Hampshire State Police respon-

' sibilities. describes the support functions of the New Hampshire State l

Police Iop staffing TCPs. Cones and barricades for the State's use during an' emergency will be stored at New Hampshire Department of Tranportat'lon (DOT) garages near or within the EPZ.

i b. There are 336 cones and 176 barricades available in the EPZ communities, j c. NHREW Volumes 16-32,Section II describes how traffic control points in I the municipalities within the EPZ will be implemented. This description is further supported by NHRERP Volume 48, New Hampshire Department of Transportation's (DOT) procedures which describe DOT's responsibilities for' supporting access and traffic control under the direction of New Hampshire State Police or New Hampshire Civil Defense. NHRERP, Volumes

' 16-32, Appendix C identifies the equipment and vehicles available to cach municipality to deploy equipment.

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, SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

RESPONSE

(continued)

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d. A' reasonable estimate of the time necessary to have allitraffic control equipment in place, depending on the size of the town, is 30'to 60 minutes.

1 e ., Applicants have no knowledge for describing how snow removal would affect personnel availability for deploying traffic management devices.

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SEACOAST ANTI-POLLUTION LEAGUE (m

N- /

h APPLICANTS' INTERROGATORIES (continued)

24. Provide a proper calculation of the number of persons needing transit because of out of service vehicles. Has KLD recalculated ETE's using a correct calculational method? If so, what impact did this correction have on ETE7 If not, why not?

RESPONSE

The NHRERP, Volume 6, Section 11 at p. 11-8 utilizes a deliberately selected conservative figure of 6 percent with which to estimate persons needing transit because of out of service vehicles. This figure assumes that on the average, every vehicle is out of service 3 weeks per year. This figure is higher than

((3,) available sources indicate which is 4 days per year, or 1.1 percent of the time.

Whether the 1.1 percent figure is applied to the percentage of EPZ popula-tion who own one vehicle or the 6 percent figure is applied to the estimated transit-dependent population, the result is the scar. (approximately 0.3 percent of the population would require transportation assistance because of out of scr-vice vehicles). The calculational method has no impact on ETE.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

25. Provide a' sample derivation of link capacities for one simple and one more complex link, along with a sample of actual flow at a crowded intersection showing all inputs, outputs. and queues.

RESPONSE

Simple Calculation For a freeway link of three lanes, the capacity during undersaturated flow conditions will be 3 x 1728 = 5184 vehicles per hour (vph) (see NHRERP, Volume 6 Section 3, pages 3-9, 10).

Under Level of Service F (r;or.gested) conditions. the capacity is reduced by applying a factor, R=0.85 to the above estimate, to yield 4406 vph. This factor is approximately the median of a range of 0-25 percent of observed reductions in capacity, when traffic is operating under congested conditions. (Refer to Ref.

30 of Chapter 6 of the 1985 HCM; more recent work has confirmed this " reduction effect".)

f Many atudies have shown that there is little or no reduction in capacity under congested conditions. On the other hand, congestion is a form of unstable flow and there is a prospect of cars running out of gas and causing short-term restrictions in capacity, during an evacuation. Thus, in consideration of all factors cited above, KLD took a prudent and realistic approach by applying a 15 percent reduction in capacity during congested conditions.

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SEACOAST ANTI-POLLUTION LEAGUE

' APPLICANTS' INTERROGATORIES (continued)

RESPONSE

(continued)

Complex Calculation A more complex situation arises when conflicting evacuating traffic stream approach an intersection. In this case, the nominal capacity must be multiplied by the effective Green: Cycle ratio and further identified to account for any interference between traffic streams. See references cited in footnote on page 3-3 (NHRERP, Volume 6).

The most complex calculation is the need to consider intersection spillback

) arising from the queuing reflecting congested conditions. This treatment is d handled with internal logic in IDYNEV. Essentially, this logic prevents vehicles from entering a congested link if, as a consequence, the entering vehicles would exceed the physical storare capacity of that link. Essentially, this is a dynamic metering policy which, in effect, reduces, as needed, the capacity of the feeder link.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES -

(continued)-

26. Provide full loading results at one major loading point.

RESPONSE

The data provided on pages N-21 through N-28 (NHRERP, Volume 6) provide a detailed breakdown of loading rates for each of the origin centroids for several scenarios. Each centroid is identified by number and the location of each centroid can be identified on Figure 1-3.

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l SEACOAST ANTI-POLLUTION LEAGUE lN V APPLICANTS' INTERROGATORIES (continued) l l

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27. Describe in detail how light traffic patterns have been treated in the simulation model.

RESPONSE

The light traffic patterns throughout the network which would be moving counterflow to the evacuating traffic are accounted for on the two-way, two-lane

~

highways, in the calculation of capacity. This is detailed below.

The definition of fd is that it is "an adjustment factor for directional distribution of traffic". This factor takes into account the effects on capa-city when the directional split of traffic flow departs from a 50/50 directional split.

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SEACOAST ANTI-POLLUTION LEAGUE gg O' APPLICANTS' INTERROGATORIES (continued)

28. Provide an estimate of the number of boats in the Seabrook Station EPZ-and the average number of people per craft. How does KLD assume that these individuals will be evacuated and what is the estimate of time required for a complete evacuation of the boating populace?

RESPONSE

The assumption made in the KLD estimate is that, associated with every boat, is a car that has brought the people to the dock. Since we have estimated the number of cars in the beach areas to be equal to the parking capacity, it then follows that these boat passengers, and their cars, are properly accounted for.

( -

Assuming that the boats are able to return to the dock within the span of the ETE it then follows that these people will join the evacuating traffic stream and will therefore, not extend the evacuation time. (Of course, persons in

, boats can choose to travel to docks outside the EPZ.)

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERRCGATORIES

-Q (continued)

29. Provide a description of the empirical basis upon which KLD rests its assumption that the maximum trip generation time under conditions of heavy snow fall is 150 minutes.

RESPONSE

As discussed on page 4-20 (NHRERP, Volume 6), the snow clearance time distribution is postulated based on undocumented informal discussions with those-who reside in the area. It is also based on the premise that individuals will clear their driveways using hand shovels or snow blowers. No additional person-nel are assigned to perform these activities other than the people who reside in O these dwellings, except possibly for private contractors who ordinarily provide such services.

Regarding snow clearance on roads, the personnel assigned those duties are identified by organization in NHRERP, Volume 16-32, Appendix C.

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SEACOAST ANTI-POLLUTION LEAGUE .

Q,- , APPLICANTS' INTERROGATORIES

-(cor. tinued ) 1 l

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. 3 0 .' What, if any, binding contracts have the State of New Hampshire and/or-  !

Applicants entered into for provision of personnel, services, vehicles or equip-ment-for a radiological er.ergency resporse. Provide copies of any and all contracts identified.

RESPONSE

The letters of agreement contained in the NHRERP, Volume 5, contain commit-ments to the State of New Hampshire for personnel, services, vehicles, and equipment.

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F SEACOAST ANTI-POLLUTION LEAGUE rx

( APPLICANTS' INTERROGATORIES (continued)- ,

31. What specific instructions and training are given to traffic control personnel in order that they will know how to direct traffic and how to respond to inquiries by evacuees. Provide any documents and/or training materials.

RESPONSE

A. Specific instructions for traffic control personnel are contained in the following:

1. NHRERP, Volume 4B, State Police Troop A Procedures and Appendix D to the procedures.

2. NHRERP, Volumes 16-32,Section IV, Police Chief Procedures.

3. Traffic Management Manual of the State of New Hampshire.

(

B. NHRERP, Volume 1. Section 3.2, describes training given to traffic control personnel.

C. The applicable training materials consist of the following:

Radiological Emergency Response Training New Hampshire Civil Defense Agency Module 1 Basic RERP Radiological Emergency Response Training New Hampshire Civil Defense Agency Module 2 Radiological Exposure Control i

Radiological Emergency Response Training New Hampshire Civil Defense Agency Module 13 Traffic Management O L/071LS.31 r

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SEACOAST ANTI-POLLUTION LEAGUE

. ~~

(j APPLICANTS' INTERROGATORIES (continued)

32. What number of individuals does the State of New Hampshire expect would report to reception centers for monitoring and decontamination if a radiological emergency were.to occur at Seabrook? Provide numbers separately for each of the reception centers (Salem, Manchester, Rochester. Dover).

RESPONSE

Based on a FEMA memorandum (Attachment 32-1)'providing interpretative guidance on NUREG-0654/ FEMA-REP-1 protective response evaluation criterion J.12, the State and local radiological emergency preparedness plans should include provisions at relocation center (s) in the form of trained personnel and equip-ment to monitor a minimum of 20 percent of the estimated population to be evac-uated.

The State of New Fanpshire, using this guidance, expects the following num-bers of individuals to arrive at Host Communities.

SALEM: Total 31,420, expect 20% or 6,284.

DOVER: Total 39,427, expect 20%,or 7,886.

ROCHESTER: Total 33,056, expect 20% of 6,612.

MANCHESTER: Total 43,493, expect 20% or 8,699.

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.- ATTACHMENT 32-1 J .~ .

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Qgg$ j. Federal Emergency washington, D.c. 20472 Managemen DEC 2 4 gg .

MEMORANDUM EOR: NDI Division Chiefs y 4, s**

Assistant Associate Director State and Incal Prograns ,

and Support  !

SUBJECI: Guidance on NUREG-4654/ FEMA-REP-1 Evaluation Crit.erion J.12 This menorandte provides interpretative guidance on NUREG-0654/PEMA-REP-1 protective response evaluation criterion J.12:

Each organization shall describe the means for registering and monitoring of evacuees at relocation centers in host i areas. The personnel and equipnent available should be capable of monitoring within about a 12-hour period all g residents and transients in the pitne exposuru EPZ arriving at relocation centers.

The question arises as to the percentage of the evacuees that could reason-ably be expected to arrive at a relocation center (s). Previous experience gathered on evacuation responses to a variety of natural and technological

. emergencies is not conclusive. Research into this matter, however, has revealed that anywhere fra 3 to 20 percent of the evacuses arrived at relocation centers or shelters. Por radiological emergencies, it is rea-sonable to assume that additional evacuees, to allay their concerns and fear over radiation, will go to relocation centers whether or not they i have been exposed to radiation. Thus, the percentage of potential evacu-ees for radiological emergencies may be closer to the upper end of the 3 to 20% range.

The congregata care issue is reviewed as a part of all Atmic Safety and Licensing Board hearings, although it has never been formally litigated at such a hearing. 1he congregate care facility capacity in the vicinity of '

nuclear power plants is usually cited as being between 5 and 15 percent of the estimated neber of evacuees. With these percentages in mind, it is l apparent that there is significant diversity in the frame of reference sur- l

! rounding this issue.

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1 Stewart M. Glass, Eso.

Page 2 .

O. JHK-57-85 October 4, 1985

-review of the LILCO plan, this issue effects position, should be,.known and clearly definedTherefo .

e NRC I thank issue. you for your help in obtaining a definitive position s on th Sincerely.

//W- .

J. H. Keller, Staff Scientist Special Programs cc: M. Lawless - FEMA R. Kowieski - FEMA s

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ATTACHMENTS 32-2

] g Westinghouse Idaho Nuclear Company. Inc.

Box 4000 .

Idaho Falls Idaho 83403

> JHK-57-85 October 4. 1985 ,

Stewart M. Glass, Esq.

Regional Counsel Federal Emergency Management Agency Region II 26 Federal Plaza New York, New York 10278

Subject:

Clarification of NUREG 0654 Element J.12

() I believe that clarification is reouired as to tne msaning of NUREG 0654

( element J.12. Since it is very likely tnat the FEMA witness panel again have to appear before tne ASLB on the Shorenam emergency will preparedness issues, I would like to see tne answers to the following questions:

1. Is there an NRC position on the numoer of evacuees who mignt arrive at a reception center (s) for monitoring and if so wnat % of the EPZ population shoulo be used in the planning process?

2. More importantly, what is the FEMA position on tne same cuestionst i raise this issue for two reasons. First, curing the Indian Point ASLB nearings I recall a NRC Commission Ruling which you supplied as packgrouna material, which stated that 100% of the EPZ population must be considerea when applying the 12 nour time frame of element J.12. Unfortunately I can not recall if this statement was in tne body of the Ruling or in one of the indivioual opinions appended to the Ruling. The location of the statement would have consideraole bearing on the issue. Second, while the RAC has founo the LILC0 plan inadequate with respect to element J.12, the reason for the inadecuacy is not the inanility to monitor arriving evacuees within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The ASLB. on page 10 of tne Concluding Partial Initial Decision on Emergency Planning, has found the LILCD plan to te defective because of the failure to aceouately plan for the monitoring anc registration of memeers of the general public arriving at tne reception -

center. The 20% of the EPZ population usea in planning for sneltering is apparently acceptable but the ASLB points out that the number seeming monitoring is not necessarily the same as that seeking shelter.

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'Ihe guidance prcvided below is based on the followirg factors: (i)Past experience with evacuations regardless of the nature of the energency, (2) inclusion of fear and uncertainty factors associated with radiological emergencies and (3) percentage of potential evacuees for congregate care facilities cited in ASLB hearings.

Guidance The State and local radiological emergency preparedness plans should include provisions at relocation center (s) in the form of trained personnel and equignent to monitor a minimLa of 20 percent of the estimated population to be evacuated.

Pbr highly inprobable radiological releases involving high ,

levels of radiation enom passing a relatively large area, it may be r=== mary to monitor a greater rasnber of evacuees beyond 20 percent of the population. In such a situation, State and local goverrments would be expected to develop and inplement ad hoc response measures, supplananted, if needed, by Federal and private sector resources. -

Any questions or concerns about this guidance should be directed to Mr. Bill tt at 646-2857. l I

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I SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

. 33. What guarantees does the State have that Manchester High School.

Sp sulding High School, Salem High. School and Dover High School would be made erallable in the event of a radiological emergency? Name the individual or individuals who have authorized use of each of these facilities. Provide answers to these same questions for each of the secondary facilities in the four communities.

RESPONSE

We are advised that the State stands assured that all public schools which function as reception centers, primary / secondary decontamination centers and mass care shelters will be made available in the event of a radiological

(

emergency. This has already been demonstrated by the amount of cooperation that all 4 host communities have provided the State relating to RERP. All host communities have participated in RERP information gathering and planning meetings as well as providing the State access to their public schools for the purposes of planning for reception, decontamination and mass care operations.

f The individual (s) who are responsible for making these facilities available and who have authorized use of the facilities are:

l SALEM: Board of Selectmen: Stephen Buco, Ronald Belanger, Howard Glynn (Chairman). David Tilton, Charles W. Coll DOVER: City Manager: Reynold Perry ROCHESTER: Mayor: Hon. Richard Green: Mayor Pro Tem: Charles F. Hervey MANCHESTER: Mayor: Robert F. Shaw O L/071LS.33 i

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fl SEACOAST ANTI-POLLUTION LEAGUE

() APPLICANTS' INTERROGATORIES (continued)

34. What individual or individuals h' ave authorized the use of local fire department personnel to perform decontamination services? Provide answers for each of the 4 host communities. How many fire department personnel are there in each of the 4 host communities? How many are full time personnel? Provide copies of the materials used in instruction and training of the fire department personnel for decontamination duties.

RESPONSE

a. For each of the 4 Host Communities, the person who governs the local emergency response organization, as identified in NHRERP, Volumes 33, 35, 36, and 38, has authorized the uGe of fire department personnel.

b. The number of fire department personnel in each Host Community is as follows:

SALEM: 55 full-time firefighters DOVER: 45 full-time firefighters ROCHESTER: 20 full-time and 54 call firefighters MANCHESTER: 160 full-time firefighters O

L/071LS.34

SEACOAST ANTI-POLLUTION. LEAGUE b(~'s APPLICANTS' INTERROGATORIES

.(continued)-

RESPONSE

(continued)

c. The applicable train'ing materials consists of the following:

Radiological Emergency Response Training New Hampshire Civil Defense Agency Module 1 Basic RERP Radiological Emergency Response Training.

New Hampshire Civil Defense Agency Module 2 Radiological Exposure Control Radiological Emergency Response Training i New Hampshire Civil Defense Agency- '

Module 11 New Hampshire Decontamination Center O

4 I

O L/071LS.34.1

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued) r t

35. When minors are found to be contaminated, is. permission of parents required to be sought prior to the decontamination?

l

RESPONSE

The interrogatory is objected to for the reason that it has no regulatory basis.

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I L/071LS.35

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SEACOAST ANTI-POLLUTION LEAGUE

( )

APPLICANTS' INTERROGATORIES (continued)

36. Under the Revision 2 plans, what provisions are to be made for iso-lating contaminated water (from showering and car washing) from the environment?

RESPONSE

There are no. provisions for containing ccet.ominated water. The State of New Hampshire will monitor water discharge to ensure that it is within the limits of the New Hampshire Rules for Control of Radiation, specifically rules He-P 2020 and He-P 2023. If a limit is exceeded, waste water discharge will be diluted with additional water until the discharge meets the state standards.

U O L/071LS.36

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

37. How many DPHS Supervisors are there who could be assigned to duty at a host community reception center? List the names and addresses of these indivi-duals.

RESPONSE

Names of persons assigned to these positions are contained in the NHRERP, Volume 4A, Appendix A.

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O L/071LS.37

SEACOAST ANTI-POLLUTION LEAGUE

~ ( ,/ APPLICANTS' INTERROGATORIES (continued)

38. For each of the 4 host community reception centers, state how many CDV-700 survey meters will be available. Has this number of survey meters yet been provided to the host communities?

RESPONSE

NHRERP, Volumes 33, 35, 36, and 38, Appendix B8, contain a table that i

provides for a supply of CDV-700 survey meters for each host community. A total of 80 CDV-700 survey meters will be made available to each host community. A partial inventory of survey meters are available now in host communities. .The balance will be provided by the State.

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i L/071LS.38 I

SEACOAST ANTI-POLLUTION LEAGUE

,q f 4

\m / ' APPLICANTS' INTERROGATORIES (continued)

39. For each of the 17 local communities within the EPZ in New Hampshire, state the number of individuals necessary to carry out an adequate emergency response. For each of the communities that did-not participate in the Feb. 26, 1986 graded FEMA drill, detail where replacement personnel would come from to carry out the emergency response. Provide whatever evidence the State of New Hampshire has to establish that there are sufficient personnel to carry out an emergency respoase - - 11' of these communities simultaneously.

RESPONSE

NHRERP, Volumes 16-32, Appendix A, identifies the number of persons

' () necessary to carry out an adequate emergency response. NHRERP, Volume 2. >

Appendix G. delineates those organizations, identified by procedure, that would provide assistance to local communities which are unable to respond fully or at j all to a radiological emergency. The procedures identified in NHRERP Volume 2.

Appendix G, are found in Volumes 4 and 4B of the NHRERP. These procedures establish that there are personnel that will be available to assist local com-3 munities with an emergency response.

i.

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A SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

40. For each of the 17 local communities within the New Hampshire EPZ, state which local liaison is designated to work in that community. Provide an estimated time for the local liaison to travel from home to that community.

RESPONSE

This interrogatory is a misreading of the NHRERP. Local liaison personnel will provide assistance to local communities from the NHCDA Incident Field Office in Newington, NH.

O 4

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I L/071LS.40

SEACOAST ANTI-POLLUTION LEAGUE

.(

I(,,/ APPLICANTS' INTERROGATORIES (continued) ,

l f

41. Have the individual members of Teamsters Local No. 633 been informed

- of the driving duties they may be asked to assume under NHRERP Rev. 27 Have the

-individual members of Teamsters Local No. 633 in any way' indicated their willingness to perform these duties? If so, how? Detail the specific locations of each of the bus companies that teamsters union members may be asked to drive for and state how many teamsters union members live within five miles of each of the bus-companies. Detail the arrangements for contacting the tenasters union drivers in the event of a radiological emergency at Seabrook.

\

RESPONSE

This interrogatory seeks information as to individual as opposed to institu-tional providers of service. The interrogatory is irrelevant to any issue before the Board and is objected to as such.

L/071LS.41

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued) l

42. From what specific state agencies will the state draw personnel to fill in for lack of adequate personnel in local communities? For each agency named, state the total number of personnel available to perform such functions.

How does the State plan to familiarize these personnel with the specific emergency arrangements, facilities, and needs of these local communities?

RESPONSE

The specific state agencies that would provide assistance to local com-munities are identified in NHRERP, Volume 2. Appendix G. The number of person-nel available to provide assistance are identified in the applicable agency

'- procedures in NHRERP, Volumes 4 and 4B. The Traffic Mana, sent Manual of the State of New Hampshire identifies numbers of law enforcement personnel available for assistance. The procedures referenced in Appendix G contain the information needed to familiarize these personnel with the specific arrangements, facili-ties, and needs of these local communities. Training on these procedures is provided by Radiological Emergency Response Training, New Hampshire Civil Defense Agency, Module 5, Procedure Check. list.

O L/071LS.42 I

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SEACOAST ANTI-POLLUTION ; LEAGUE [  !

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For each of the 17 local communities in the,Naw Hampshire EPZ, state .s /-

43. p 1 2 s

/9 the names of any school personnel, day care center operators o and health care s u . A-

. providers who are expected to assist in evacuati on of students, young )

children ?;:' (

) ; ry or patients under the Rev. 2 plans. -

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RESPONSE ,

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Key school personnel, day care' center personne'I. and hira'th care facility -

personnel, who itave a respons'ibility for implementation of plans to protect the y <

health and safety of persons under their care, are identified in spei;1al facil- l1>n ~

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ity plans in NHRERP, Volumes 16-32, Appendix F. I, /-

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/ ' (D, Ik / APPLICANTS' INTERROGATORIES (continued)

[

-44. How many sheriffs' deputies are to be relied upon to perform duties under the Revision plans? State.how these deputies are to be deployed (i.e.

~

how many are to be at each staging area).

\

RESPONSE

Five regular she' riff's deputies from Rockingham County are assigned to administrative positions at the two State Transportation Staging Areas (TSA).

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(# , There is a supervisu (chief deputy) at the Rockingham County Complex and a A tv s

- 7

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staging area manager and assistant manager at each of the two TSAs. Ten special deputies are assignedito the TSA at the Rockingham County Complex to serve as

d. local transportation coordinators in non-responding towns.

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c SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

.f. 45. . What assurances does the State of New Hampshire have that Pease AFB

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" willimake its runway or hospital facilities available in the event of a radiolo-gical emergency? Provide any documentation that might establish that such assurances have been made. Has Pease AFB raised any concerns about its role in

\

the NERERP Rev. 27 If so, provide a detailed description of those concerns.

/ RESPONSE The Federal agencies and support they may provide are identified in the Federal Radiological Emergency Response Plan (FRERP) which is described in the j

NHRERP. Volume 1, Section 1.4.2. The Department of Defense is identified as a O

b Federal support agency which will provide military assistance.;iC the form of manpower, technical support, and logistical support, including airlift services and telecommunications support, as requested by FEMA. Documentation of these services le provided by 50 Federal Regulation 46542 (November 8, 1985). The Applicants are not aware of any concerns raised by Pease AFB.

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f3 L/071LS.45

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES

./ (continued)

46. Why has the agreement with Portsmouth Naval Shipyard been eliminated

. from the' plans?

RESPONSE

The Portsmouth Naval Shipyard is a Department of Defense Facility. Refer to response to Interrogatory 45.

O O L/071LS.46

SEACOAST' ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

47. Why is there no letter of agreement in the plans with Rockingham

. County Dispatch?

RESPONSE

A letter of agreement with the Rockingham County Sheriff's Department, which includes Rockingham County Dispatch, is contained in NHRERP, Volume 5.

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O L/071LS.47

SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES

-(continued) d

48. Why is there no letter of agreement in the plans with the New England

' Telephone Company?

4

RESPONSE

A letter of agreement with New England Telephone is not required because it is not assigned a responsibility under the NHRERP.

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L/071LS.48 1

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r SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES

.Q' (continued)

49. Why are there no letters of agreement with mass care facilities designated in the host community plans?

RESPONSE

A Letter of Agreement between the State of New Hampshire and the American Red Cross is provided in NHRERP, Volume 5. It is Applicants' understanding that the American Red Cross has obtained or is in the process of obtaining Letters of Agreement with certain private facilities which would be utilized under the host coasunity plans.

1 l

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SEACOAST ANTI-POLLUTION LEAGUE

[ APPLICANTS' INTERROGATORIES (continued)

50. Has the State of New Hampshire yet secured the missing agreements with the host care facilities for special facilities in the EPZ7

RESPONSE

No. Two remain outstanding.

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SEACOAST ANTI-POLLUTION LEAGUE

- \/ APPLICANTS' INTERROGATORIES (continued) .

'51. Has the State of New Hampshire made any effort to find a replacement staging area for the OMNE Mall? If so, has a replacement staging area been found? If yes, identify it by name and location.

1

RESPONSE

No, and none is required.

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SEACOAST ANTI-POLLUTION LEAGUE  ;

l ,

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(_,)/ APPLICANTS' INTERROGATORIES (continued) \

i

52. Has the State of New Hampshire any data on the sheltering dose reduc-

. tion factors for the schools and day care centers in the New Hampshire portion of the EPZ? If so, please provide the data.

RESPONSE

To the Applicants' knowledge, the State of New Hampshire has performed dose reduction effectiveness calculations for two schools, Phillips Exeter Academy and Kensington Elementary School. Calculations for other institutional struc-tures were not performed for reasons and criteria explained in Section 2.6.5, Volume 1 of the NHRERP. The data should be obtained from the State of New Hampshire.

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SEACOAST ANTI-POLLUTION LEAGUE (j' ' APPLICANTS' INTERROGATORIES (continued)

53. Account for the discrepancy in the total number of buses shown in the Rev. 2 local plans (482 buses) and the number set out in the " Transportation Resource Requirements" at p. 1-8 of Vol. 4 (444 buses).

RESPONSE

4 The 482 buses from the local plans include school bus requirements as well as the special needs and coach bus-requirements. The 444 buses from NHRERP Volume 4, page I-8, are the school bus requirements only for the towns and for Rockingham County Nursing Home and Rockingham County Jail.

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SEACOAST ANTI-POLLUTION LEAGUE

>'~

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APPLICANTS' INTERROGATORIES (continued)

.I

54. Explain in detail the-basis for the reduction in non-auto owning per-

-sons.from 8,659 to 2,106.

RESPONSE

The figure 8,659 is a 1985 projection of non-auto-owning population within the 17 communities of the EPZ contained within the March 1984 Evacuation Time Study prepared by Costello, Lomasney & deNapoli Inc. (based on census data from the New Hampshire Office of State Planning). This figure is not a reflectiori of persons who may be in need of transportation assistance in an emergency. The figure 2,106 shown in the NHRERP reflects the number of persons who may need a 5- ride as identified by the NHCDA Special Needs Survey initiated in March, 1986.

The figure 2,106 does not presume to be the number of non-auto-owning population

[

in the EPZ communities.

1 4

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SEACOAST ANTI-POLLUTION LEAGUE

- APPLICANTS' INTERROGATORIES (continued)

55. Where does the State of New Hampshire plan that Category I and Category IV patients from Exeter Hospital will-be treated following their evac-uation?

RESPONSE

From Host Facility Letters of Agreement found in the Exeter Hospital RERP,

)

it can be seen that Concord Hospital and Catholic Medical Center may host up to 60 critical and intermediate care patients. The remainder of Exeter's census

' could be hosted at the Hampstead Hospital.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued) ,

56. Upon what legal basis does the State of New Hampshire found the provi-sion in the Exeter Hospital Radiological Emergency Response Plan for differen-tial consideration of the evacuation option for those patients aged 55 or over?

RESPONSE

The differential consideration for patients over age 55 in the event of evacuation has no legal basis. It was offered as a rational basis for physi-

' clans to decide whether evacuation is in the best interest of patients, balancing the risks from the move and from low level radiation.

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SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued)

57. Identify any survey (s) that have been conducted of employees within the New Hampshire Department of Health and Welfare. Provide a copy of each sur-vey instrument employed and provide the survey results.

RESPONSE

The Applicants have no knowledge of any such survey.

O O L/071LS.57

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N i

) .As to Answers' 4*ty d  %

George 8. Thomas Vice President, Nuclear Production New Hampshire Yankee Division of Public Service Company of New Hampshire March 18, 1987 State of New Hampshire Rockingham County, ss.

Then appeared before me the above subscribed George S. Thomas and made oath that he is the Vice President, Nuclear Production of New Hampshire Yankee Division, authorized to execute the foregoing responses to interrogatories on behalf of the Applicants, that he made inquiry and believes that the foregoing answers accurately set forth such information as is available to the Applicants.

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3 Before me, ,

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00:T3 J. E' TIA* !!' fWr/ PLthe t/y Co.. .1!u:::. _.<paa C;~cct20.1931 My Commission Expires As to objections:

Thomas G. Dignan, Jr.

R. K. Gad III Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 counsel for ADolicants O

L/099LK.2

()

DOLMETED CERTIFICATE OF SERVICE USNRC I, Th: mas G. Dignan, Jr., one of the attorgyn -Qg Applicants herein, _hereby certify that on MarcW'1 Egg'T,,j32 , N -

made service of the within document by depositing copies 4 . thereof with Federal Express, prepaid, for dektygtyrto.L(ogn

' where indicated, by depositing in the United fMWpfmailivlCf.

cRANCH first class postage paid, addressed to):

Administrative Judge Helen Hoyt, Robert Carrigg, Chairman '

Chairperson, Atomic Safety and Board of Selectmen Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building

-4350 East West Highway Bethesda, MD 20814 Judge Gustave A. Linenberger, Jr. Diane Curran, Esquire j 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 20009 4350 East West Highway 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 20814

• Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Tenth Floor i

7735 Old Georgetown Road Bethesda, MD 20814

• 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 l

i Washington, DC 20555

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t Philip Ahrens, Esquire Mr..J.P. Nadeau -i

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Assistant. Attorney General Selectmen'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 General 25 Maplewood Avenue One Ashburton' Place, 19th-Floor P.O.. Box 360 Boston, MA 02108 t Portsmouth, NH 03801 i

Mrs.--Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager ,

RED 1 - Box 1154 City Hall Route 107 126 Daniel Street

Kensington, NH 03827 Portsmouth, NH 03801 l

• Senator Gordon J. Humphrey Mr. Angie Machiros

[

i U.S. Senate Washington, DC 20510 Chairman of the Board'of Selectmen (Attn: Tom Burack) Town of Newbury

Newbury, MA 01950

• Senator Gordon J. Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor O Concord, NH 03301 (Attn: Herb Boynton)

City Hall Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen i Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 l

Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen i Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency '

500 C Street, S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire

Holmes & Ells . Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, lui 03841 Concord, NH 03301 l

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Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region I Silverglate, Gertner, Baker, O-. 442 John W. McCormack Post Fine, Good & Mizner Office and Court House 88 Broad Street Post Office Square Boston, MA 02110 Boston, MA 02109 Charles P. Graham, Esquire McKay, Murphy and Graham 100 Main Street Amesbury, MA. 01913

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Tff5inas Ggignan, Jr.

(*= Ordinary U.S. First. Class Mail.)

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