ML20207T534
| ML20207T534 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/18/1987 |
| From: | Huntington G, Strome R NEW HAMPSHIRE, STATE OF |
| To: | SEACOAST ANTI-POLLUTION LEAGUE |
| Shared Package | |
| ML20207T535 | List: |
| References | |
| CON-#187-2845 OL, NUDOCS 8703240108 | |
| Download: ML20207T534 (24) | |
Text
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- sttATT.D CORRESPONDENCI!
March 18, 1987 UNITED STATES OF AMERICA M t RC JS NUCLEAR REGULATORY COMMISSION Before the Nuclear Regulatory Commispo#R 20 P2:24 j-0 EC
)
000
[yc4 In the Matter of
)
Docket Nos. 50-443-OL
)
and PUBLIC SERVICE COMPANY OF
)
50-444-OL NEW HAMPSHIRE
)
(Off-Site Emergency (Seabrook Station, Units 1 and 2
)
Planning Issues)
)
THE STATE OF NEW HAMPSHIRE'S RESPONSES TO SEACOAST ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE STATE OF NEW HAMPSHIRE ON NHRERP REV. 2 AND MOTION FOR PROTECTIVE ORDER GENERAL INTERROGATORIES A)
For each and every one of the admitted SAPL Contentions (#'3 31, 7,
8, 8A, Redrafted 15, 16, 18, 33, 34 and 37), provide the following information:
a)
What witnesses does the State of New Hampshire intend to have hestify with respect to this contention?
b)
What position does the State of New Hampshire intend to take on this contention and what is the basis of this position?
c)
What documents will be used in support of the State of New Hampshire's position on this contention?
O Y O OffB PDk 0303
Q 4 B):
For'each and every witness identified in answer to a.subpart a above, provide the following information:
a)
Name b)
Address c)
Present professional or employment affiliation d)
Curriculum vita Response To General Interrogatories A And B:
See State's responses to NECNP Interrogatories Nos.
2-6, filed on this.date.
SPECIFIC INTERROGATORIES 1.
Provide a detailed explanation as to how the number of "through" vehicles in the'EPZ highway network at the time of the order to evacuate was calculated.
Was this 3,000 estimate included in the calculations which resulted in the time estimates?
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)?
(Answer should be provided both for the aerial films from which the 300 cars in the beach area were counted (see Vol.
6, p. 2-10).
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 Provide page references to documents cited in response to parts a, b, and c above.
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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.
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 for the 10 mile EPZ.
Provide the peak population estimate for what KLD describes as the " beach area."
6.
Provide any and all documents 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 estimates?
Response to Interrogatories Nos. 1-6 KLD Associates, Inc.'s services relative to Volume 6 of the NHRERP have been retained by the Applicants, not the State of New Hampshire.
It is the State's understanding that the Applicants will respond to these interrogatories (which were also propounded on the Applicants).
The State, therefore, defers to the Applicants on these interrogatories.
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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' person 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.
Response
The details of staffing Access Control Points (ACPs) and Traffic Control Points (TCPs) within the Seabrook EPZ are found in Volume 4B, (Troop A procedures), and the Traffic Management Manual.
The Traffic
. Management Manual extracts ACP and TCP information listed in the ETE and presents it in a listing by municipality on a priority basis, and in such a manner that any person or group of persons could implement the appropriate controls at a given point.
There is no specific individual designated to man specific access or traffic control points.
The primary responsibility for implementing access control rests with State Police Troop A.
Responsibility for traffic control within the EPZ is the primary responsibilit-J of municipal law enforcement agencies.
Additional support to local law enforcement for traffic control would be made available through Troop A.
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8 '.
- Describe--theibasistof_the assumption that: traffic management?and icontro14 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?
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.Describedin detail-the assumptions employed,inLthe sensitivity study that. yielded the' result that an immediate General
- Emergency'would-only. extend ETE's 2-30 minutes.
- 10. 'How was the 25%-spontaneous evacuation' rate arrived at?L ll.
Provide a map detailing every parking space in the beach area'."
~ 12.'
Why did-KLD not account for roadway capacity reductions resulting from disabled vehicles?
13.
State the bases for.the assumption tha't incoming emergency response vehicles will be able to travel.from 40 to 50 MPH.
1
-14.
" Explain:why the KLD report does not employ the capacity 1
reduction for snow cited in the 1985 Highway Capacity Manual.
4
. 15.
Explain why the KLD Report fails to take into account choke
-points at bridges.
16.
i
. 'Who performed the telephone survey of the bus companies referenced in Vo1~. 6 at p. 11-18?
Provide copies of the survey instrument employed,-the raw data from the responses and the compilation of the responses.
i 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.
m 4
18.- What are the estimated percentages of transit-dependent persons in the seasonal and transient populations?
Detail how these estimated percentages were arrived at.
19.
Describe in detail the basis for the assumption that elderly or disabled persons can board a bus in a 15 second mean highway.
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20.
Provide the. detailed data collected on roadway geometrics, list every road studied in the Seabrook EPZ and state to which of the 1
4 classifications that roadway has been assigned.
Response to Interrogatories Nos. 8-20 See State's response to Interrogatories nos. 1-6, supra.
- 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 information and provide any and all relevant documentation.
Response
None has come to the State's attention.
22.
Provide documentation of discussions with campground operators which formed the basis of the 75% estimate of unoccupied campground sites during the day in Vol. 6 of the NHRERP at p.
2-20.
Response
See State's response to Interrogatories nos.
1-6, supra.
23.
Where are the barricades and cones to be employed at Traffic Control Posts (TCP) 'and Access Control Posts (ACP) to be stored?
How many cones are available for use and how many barricades are available for use?
Detail the means by which these traffic management devices are to be deployed to the locations at which they are to be used (i.e. who is to deploy them and by what means are they to be transported?).
Provide an estimate of the amount of time it will take to have all of this equipment in place.
Describe how snow removal responsibilities would affect the ability of personnel to deploy the traffic management devices.
Response
The State hereby adopts and incorporates.herein by reference, the Applicant's response to SAPL Interrogatory Number 23 submitted on March 18, 1987.
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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 ETE?.If not, why not?
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.
26.
Provide full. loading results at one major loading point.
27.
Describe in detail how light traffic patterns have been treated in the simulation model.
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 willEbe evacuated and what is the estimate of time required for a complete evacuation of the boating populace?
29.
Provide a description of the empirical basis upon which KLD rests its assumption that the. maximum trip generation timer under conditions of heavy snow fall is 150 minutes.
Response to Interrogatories nos. 24-29 See State's response-to Interrogatories nos. 1-6, supra.
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~ 30.
What, if'any, binding contracts have the State of New Hampshrie and/or Applicants entered into for provision of personnel, s
services, vehicles or equipment ~for a radiological emergency response.-
Provide copies of any and'all contracts identified..
Response
The State of New Hampshire objects to this interrogatory insofar as it suggests " binding agreements" for emergency support are necessary, because no such " binding agreements" are required by.NRC regulation.
Without waiving such objection, the State responds as follows:
- See NHRERP, Volume 5.
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
The State hereby adopts and incorporates h'erein by reference, the Applicant's response to SAPL Interrogatory 31 submitted on March
~13, 1987.
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-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
The following total numbers of persons who would be expected to report to the reception centers is calculated at 20% of the population of the communities that would be directed to evacuate there.
The estimates were supplied by KLD for a summer Sunday and are the numbers used by the state in preparation of the NHRERP Revision 2 decontamination center procedures.
Salem 6284 Dover 7886 Rochester 6612 Manchester 8699 33.
What guarantees does the State have that Manchester High School, Spaulding High School, Salem High School and Dover High School would be made available 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
The State objects to this interrogatory insofar as it suggests
" guarantees" that named schools "would be available" are necessary, because no such guarantees are required by NRC regulation.
Without waiving such objection, the State responds as follows:
The State of New Hampshire is not aware of the requirement for a guarantee with respect to the use of any facilities in conjunction with an emergency response.
The State is assured that the facilities listed in the host plans supporting the NHRERP are adequate, and will be'available in the event of an emergency.
This assurance-is based upon the participation of local officials and key emergency response personnel in the development and testing of these plans.
With respect.to mass care facilities, the plans indicate a contact person who would provide access to the facility in the event it becomes necessary to use the facility.
Further, it is the State's understanding that the American Red Cross (see Letter of Agreement Vol. 5 NHRERP) has, or will, survey each mass care facility, and has or will obtain an agreement for their use.
34.
What individual or individuals have 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
Fire department personnel have, as part of the ongoing planning process, volunteered as participants who will provide decontamination services as well as other emergency response services.
The State has not requested and does not have rosters of fire department personnel in the four communities.
Training is provided at the request of the department and is scheduled by the department using the department's normal chain of command and approval process.
The training materials being used are available for inspection at the Civil Defense Headquarters, 107 Pleasant Street, Concord, New Hampshire.
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35.
When minors are found to be contaminated, is permission of parents required to be sought prior to their decontamination?
Response
In the event' o'f an actual emergency, unaccompanied minors (minors without parents or guardians) would be the responsibility of the State.
Since DPHS has the responsibility for decontamination of the general public and emergency workers (see Section 1.3.3, Vol. 1, NHRERP), decontamination of unaccompanied minors with a contamination level of 100 CPM above background will be conducted under supervision of DPHS.
Monitoring and decontamination of children who arrive at the center without parents will be conducted in accordance with Appendix F, Volume 4A, NHRERP.
36.
Under the Revision 2 plans, what provisions are to be made for isolating contaminated water (from showering and car washing) from the environment?
Response
Under Revision 2 of NHRERP there are no provisions made for isolating contaminated water from showering or car washing.
Monitoring of discharge water will be conducted in accordance with procedures described in Appendix F of Volume 4A of the NHRERP.
If the water exceeds the limit specified in the New Hampshire Rules for Control of Radiation He-P 2020 and He-P 2023, it will be diluted by addition of water until the discharge is within state standards.
- 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 individuals.
Response
There are'33 persons who have been identified by DPHS who'could be assigned to duty at host community reception centers.
The next revision of the NHRERP will provide the names of this supervisory pool, as page-A-2 of Appendix A.
Vol. 4A, NHRERP.
38.
For each of the 4 has 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
80 CDV-700 Survey Meters will be available for each host community.
These instruments have or will be distributed.
- 29. -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 response in all of these communities simultaneously.
Response
NHRERP, Vol. 16-32, Appendix A, identifies the number of persons necessary to carry out an emergency response.
NHRERP, Appendix C
delineates those organizations, identified by procedure, that would provide assistance to local communities that are_ unable to response o
fully or at all to a radiological emergency.
The procedures
. identified in NHRERP, Vol. :2, Appendix G, are found in Volumes 4 and 4B of the NHRERP.
These procedures establish the personnel that will be available to assist local communities with an emergency response.
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 2.
travel from home to that community.
Response
In the event that an emergency occurs which requires activation of the IFO in Newington, a team of local liaison personnel is dispatched to the IFO.
This team will consist of those personnel who are immediately available to respond from the NHCDA. Technological Hazards Division and other persons listed in the local liason roster.
See Agency Liaison Procedures Vol.
4, Appendix C.
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i 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 i
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 teamsters union drivers in the event of a radiological emergency at Seabrook.
Response
A Letter of. Agreement with Teamsters Local 633 dated June 2, 1986, is contained in Vol. 5 of the NHRERP.
The ability of the union leadership to contact and organize its membership is well demonstrated.
A procedure to link Local 633 Teamsters Union and the State EOC during an emergency is being reviewed by unior. officihls.
A listing of bus companies is contained in Vol. 2 Appendix I.
It is possible that a union member could be asked to drive a bus, van or other vehicle belonging to any of the listed companies or state agencies.
The State does not have information indicating how many union members reside within the geographic region of the listed bus companies.
. 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 State hereby adopts and incorporates herein by reference, the Applicant's response to SAPL Interrogatory Number 42 submitted on March 18, 1987~.
43.
For each of the 17 local communities in the New Hampshire EPZ, state the names of any school personnel, day care center operators and health care providers who are expected to assist in evacuation of students, young' children'or patients under the I
l Rev. 2 plans.
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Response
Local plans, Vol. 16-32, Appendix F, of the NHRERP list the special facilities which are located in the communities within the Seabrook EPZ.
These volumes also set forth the procedures which will be utilized to assist the evacuation of students, young children or patients under the Revision 2 plans.
The contact person for each facility is also listed.
Listings identifying the names of individual facility personnel are maintained separately by each facility.
4 4.-
How many sheriffs deputies are to be relied upon to perform duties under the Revision 2. plans?. State how these: deputies are to be deployed (i.e. how many are to be at each staging area).
Response
A description of the. deployment of staging area personnel is contained in Volume 4B, Staging Area Personnel procedures.
4'5.
What assurances does.the State of New Hampshire have that Pease-AFB will make its runway or hospital facilities available in.the event of a radiological emergency?
Provide any documentation that might establish that such assurances have been made.
Has Pease AFB raised any concerns about its role in the NHRERP Rev.2?
If so, provide a' detailed description of those concerns.
Response
The Federal Radiological Emergency Response Plan contained in Vol. 5 and described in Vol. 1, Section 1.4.2 of the NHRERP provides the mechanism for-obtaining assistance from federal facilities such as Pease Air Force Base.
The State has no knowledge of any concerns raised by the Air Force in providing emergency assistance to the State.
46.
Why has the agreement with Portsmouth Naval Shipyard been eliminated from the plans?
Response
Agreements with federal installations are coordinated through the Federal Radiological Emergency Response Plan (FRERP) which is contained in Vol. 5 of the NHRERP and decribed in detail in Vol.
1.4.2.
Because the Portsmouth Naval Shipyard is a federal installation, it is encompassed within the scope of the FRERP and therefore need not be specifically addressed in the NHRERP.
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.47..Why is there.no~1etter of. agreement in the plans with Rockingham County-Dispatch?
Response
Rockingham County Dispatch is part of the Rockingham County Sheriffs Department which is a governmental entity having statutory
. responsibility to: provide and support law enforcement emergency.
services to the residents of Rockingham County.
This statutory responsibility obviates the need for a letter of Agreement with the Rockingham County Dispatch.
However, a letter of agreement with Rockingham County Sheriff's Department, which includes Rockingham County Dispatch, is contained in NHRERP, Vol. S 48.
Why is there no letter of agreement in the plans with the New England Telephone Company?
Response
A letter of agreement with New England Telephone Company is not required.
They are not assigned specific responsibilities under the NHRERP.
49.
Why are there no letters of agreement with mass care facilities designated in the host community plans?
Response
It is the State's understanding that the American Red Cross (see Letter of Agreement Vo. 5) has, or will, survey mass care facilities and obtain appropriate agreements.
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L50.
Has the State of New Hampshire yet-secured the' missing..
agreements with the host. care facilities for special facilities:
in the EPZ?-
Response
Most but not all letters of agreement-have been.obtained.
51.
Has'the State ofTNew 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.
Re'sponse i
The State is currently not. seeking a replacement staging area for OMNE Mall.
52.
Has the State of New Hampshire any data on the sheltering dose reduction factors for the schools and day care centers.in the New Hampshire portion of the EPZ?
If so, please provide'the
- data, r
Response
Dose reduction factors have been calculated'for Philips Exeter Academy, Kensington Elementary School and Greenland Elementary School.
The study of Philips Exeter Academy and Greenland Elementary School were conducted at the request of those schools.
The
.Kensington Elementary School survey was done in response to a limitation placed by the Board to a contention' raised by the Town of Kensington.
The surveys were completed by NHCDA and are available for inspection at the offices of NHCDA, Concord, NH.
These surveys will not be used in the decision making process related to protective action recommendations.
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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.
I-8 of Vol. 4 (444 buses).
54.
Explain in detail the basis for the reduction in non-auto owning persons from 8,659 to 2,106.
Response to Interrogatories 53-54 The State hereby adopts and incorporates herein by reference, the Applicants's response to SAPL Interrogatory Nos. 53-54 submitted on March J8, 1987.
55.
Where does the State of New Hampshire plan that Category I and Category IV patents from Exeter Hospital will be treated following their evacuation?
Response
Categories I and IV are transportation categories.
These have been confused with a three class system for categorizing medical care.
Two letters from host facilities (Concord Hospital and Catholic Medical Center) indicate the ability to provide care for 60 patients in classes II and III of the medical care system.
The State believes that Hampstead Hospital (the third host hospital) will handle any other patients evacuated.
56.
Upon what legal basis does the State of New Hampshire found the provision in the Exeter Hospital Radiological Emergency Response Plan for differential consideration of the evacuation option for those patients aged 55 or over?
Response
There is no legal basis for differential consideration of the evacuation option for patients 55 and over.
The State has no intentions of leaving behind, in the event of evacuation from the facility, any individuals.
(See procedure steps L through S, pg. 18, Exeter Hospital RERP, Appendix F of the Exeter Plan, Vol. 26A).
The State regrets that this comment has resulted in confusion about the State's intent.
The next revision of the Plan will include revision of this statement to indicate that, at the Site Area Emergency classification level, authorities should determine which patients who, by virtue of age or medical condition, will require extraordinary assistance in evacuation.
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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 survey instrument employed and provide the survey results.
Response-
-William Colburn, Coordinator of Emergency Services for the Division of Human Services, surveyed the DHS field staff-in February 1987.
A copy of the survey form and tabulations of the returns to date are available for review at NHCDA offices.
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. MOTION FOR PROTECTIVE ORDER Because the State of New Hampshire filed no contentions on the NHRERP and intends to offer no testimony on any contentions that were filed, the State is not obligated to respond to any interrogatories on the NHRERP.
See this Board's Memorandum and Order (March 1, 1983) at 3-4, 7 (Interrogatories which are sponsored by the interrogee and which will not be the subject of direct testimony proffered by the interrogee need not be answered.)
Recognizing, however, that New Hampshire state personnel involved in developing the NHRERP can and will provide valuable input in this proceeding on New Hampshire emergency planning issues, the State has voluntarily responded to this set interrogatories and request for production of documents.
The State of New Hampshire, however, moves the Board for a protective order that the documents that the Seacoast Anti-Pollution League's requests to be produced may be produced at the offices of the New Hampshire Civil Defense Agency in Concord, New Hampshire.
The majority of the requested documents are already in the possession of SAPL (e.g., NHRERP; RAC Reviews), and the remainder of the documents constitutes a large number of pages.
To provide copies of the documents by mail to SAPL would be an undue burden and expense.
Rather, the State of New Hampshire requests that the Board order that the requested documents be made available for inspection during work hours at the Civil Defense Agency headquarters, 107 Pleasant Street, Concord, New Hampshire, 03301.
o
. In addition, the State of New Hampshire moves this Board for a protective order that, for the reasons given, the following interrogatories need not be answered further:
Interrogatory No. 30 The State of New Hampshire objected to this interrogatory as inquiring into matters not required by NRC regulations.
The State knows of no requirement that it seek or obtain " binding agreements" for emergency support in the event of a radiological emergency.
Interrogatory No. 33 The State of New Hampshire objected to this interrogatory as inquiring into matters not required by NRC regulations.
The State knows of no requirement that it seek or obtain " guarantees" that the named schools "would be made available in the event of a radiological emergency."
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SIGNATURES r
As to Answers to Interrogatories 1-31, 33-34, 39-51, 53-54, 57:
Richard-H. Strome i o As to Answers to Interrogatories 35-38, 52, 55-56:
I Dr. William T. Wallace, Jr.
l As to Answers to Interrogatories A-B,-32:
l Richard H. Strome and Dr. William T. Wallace, Jr.
l l
I, William T. Wallace, Jr.,
M.D.,HM.P.H.,
being first duly sworn, do depose and say that the foregoing'answerc are true, except i
insofar as they are based on information that is available to the State but not within my personal knowledge, as to which I, based on such information, believe them to be true, i
William T. Wallace, Jr.,
M.D.,
M.P.H.
Director, DPHS Division of Public Health Ser/ ices i
Sworn to~before me this day of March, 1987:
Notary Public My Commission Expires:
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f e I, Richard H. Strome, being first duly sworn, do depose and say that the foregoing answers are true, except insofar as they are based on information that is available to the State but not within my personal knowledge, as to which I, based on such information, believe them to be true.
[
b Richard H.
Strome Director, Civil Defense Agency Sworn to before me this
/J7/ day f Marc,,1987:
' ~~ ':.
/
HvEacy FabIier
'2C n My Commission Expires:
9/J/8/
ff As to Objections and Motion for Protective Order:
Date George Dana Bisbee Senior Assistant Attorney General Environmental Protection Bureau Office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3679 sla n LN#
l Date Geoffrey M.
H ntington
/f Attorney
/
Environmenta Protection Bureau Office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3679