ML20207T558
| ML20207T558 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/18/1987 |
| From: | Bisbee G, Huntington G, Strome R NEW HAMPSHIRE, STATE OF |
| To: | HAMPTON, NH |
| Shared Package | |
| ML20207T535 | List: |
| References | |
| OL, NUDOCS 8703240128 | |
| Download: ML20207T558 (14) | |
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. ;p TEt ATEn COM FSPONDENCE harkkEkk' l93 00 USNHC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION J
m g h P2:24 Before the Nuclear Regulatory Comdirston hFflCE cr Ruh Md /
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In the Matter of
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Docket Nos. 50-443-OL
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and PUBLIC SERVICE COMPANY OF
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50-444-OL NEU HAMPSHIRE
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(Off-Site Emergency (Seabrook Station, Units 1 and 2'
)
Planning Issues) i THE STATE OF NEW HAMPSHIRE'S RESPONSE TO THE TOWN OF HANPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OI!
DOCUMENTS TO THE STATE OF NEW HAMPSHIRf ON THE NEW HAMPSHIRE' RADIOLOGICAL EMERGENCY RESPONSE PLANS AND MOTION FOR PROTECTIVE OFDER 1.
With respect to each contention and subpart there of filed by the Town of Hampton and admitted by the Licensing I:oard's Orcer of February 18, 1987, please provide"the following informstion:
a.
What is State of New Hampshire's position with respect to each contention and its subparts?
Describe in deta'il the reasons for your position.
b.
Identify and provide access to all documents and the Date Base on which.you rely to support your position on each of these contentions.
This includes the Data Base used, or to be used, in your answers to these interrogatories, summary disposition motions, testimony, and cross-exam'ination of witnesses during hearings.
c.
Identify all persons on whose factual knowledge, opinions, or technical expertise you rely for'your position on each contention and subpart thereof.
d.
Identify all persons you may call as witnesces on each of these 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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,l Respo se to Interrogatories 1(a) - 1(d)
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See St' ate's responne to NECNP's Interrogatories 2-5, filed on y
this;date.
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Pldaet dxplain'and provide the Data Base for each of the tollowihg facts, statements, assumptions or conclusions in the
- NHRERP Revision 2, and identify and provide reasonable access to 41,1 documents on which you reply to support your answers to this idterrogatory
s That the number of persons comprising the Town of Hampton sa.
resident population is 13,234.
Please define " resident population: and fully explain and provide the Data Base for why this fp.gure differs from that used in prior drafts of the UHRERP and identify all persons included.within this populati~on figures.
thb number of persons comprising the Town of Hampton b.
That peak summer weekend population is 36,635.
Please define
" peak summer weekend population" and fully explain and x
provide'the Data Base for why this figure differs from that used in,ptior drafts of the NHRERP and identify all persons includsd within this population figures.
'That the number of persons comprising the Town of Hampton c.
peak summer midweek population is 34,337.
Please define s
- " 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 identif'y all persons included within_this population figures.
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d.
That there will be a vehicle occupancy rate of 2.4 persons during an evacuation.
e.
That ETE uill be reduced by twenty (20%) percent for rain.
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'Thac'ETE will be reduced by twenty-five (25%) percent for i snow.
g.
That all roads will remain passable during evacuation.
h.
-That recomme'nded traffic control tactics will be in effect during an eyacuation.
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c id That there will be three thousand.(3,000) "through" vehicles traveling through the EPZ'ap the~ time of p3 g;
.^!g f' evacuation.-
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f.q'.g That tweSty-five;(25%). percent of the EPZ population will spontaneously evacuate.
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That evacuees vill im fadt evacuate to their assigned host
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.,That the' bus drivers ide'ntified by. Letter Agreement,
- including the teamsters, have the tra'ining. experience to evacuate the disable, medically imphired, and student populations.
N Response to Interrogatories 2(a) - 2(k)
S \\ds KLD Associates, Inc.'s services relative to Volume 6 of the NHRERP ha've been retained by the Applicants, not the State of New Hampshire.
It is the State's understanding that the Applicants will respondtotbeseinter'rogatories (which were also propounded on the T.
t Applicantal.
The' State, therefore, will defer to the Applicants on y
these interrogatories'.
Response tc3 Interrogatory 2(1) s
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Drivers provided for bus transportation that are identified by
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i letters of agreement in Volume 5 of the NHRERP, routinely provide service 1to students and therefore may be expected to be familiar with this group of individuals.
In addition, drivers serving students with special needs, the disabled, or the medically impaired are expected to be capable of providing services to these individuals s
based upon previous training or related work experience, s
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. Normal route drivers, or members of the Teamsters Union, may not have direct training for handling disabled or medically impaired persons, but sufficier.t numbers of Emergency Medical Services (EMS) personnel will be available to assist the drivers.
The EMS personnel are trained to handle these people and provide these services on a day to day basis.
.3.
Provide the total number, and the Data Base used to compute the following:
a.
Town of Hampton peak beach population.
b.
Town of Hampton transit dependent population.
c.
Town of Hampton transient population.
d.
Town of Hampton 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(a) - (e), number and provide the Data Base for each such group in the entire EPZ.
Response to Interrogatories 3(a) - 3(g)
See State's response to Interrogatories 2(a)-2(k), supra.
4.
Identify, describe, and provide the Data Base to support any change in the population figures, for each group identified in Interrogatory #3, between the NHRERP Revision 2 and all prior drafts of the NHRERP.
Response to Interrogatory 4 See State's response to Interrogatories 2(a)-2(k), supra.
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. 5.
Please' identify and describe whether the NHRERP Revision 2 makes provision 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 IFO/ EOF accident assessors calculate atmospheric dispersion estimations based on meteorological data which is supplied by both the utility meteorological tower, and DPHS monitoring teams.
These calculations are made primarily on the METPAC System which receives new meteorological data and recalculates atmospheric dispersion estimations every 15 minutes.
The monitoring teams report current meteorological data as instructed to by the Monitoring Team Coordinator.
The IFO/ EOF Accident Assessor procedures indicate that the process is repeated as necessary for the duration of the emergency.
See Appendix F, Volume 4 and Appendix U, Volume 4A for
. protective action decision making and Section 5, Volume 4A procedures for IFO/ EOF accident assessment team and Section 2.5.2(e) and (h),
Volume 1 NHRERP for meteorological data acquisition, and the METPAC user manual.
This monitoring process enables reconsideration of protective action recommendations whenever there is a change in plant status or other pertinent factors such as wind direction and weather.
-G-6.
Please identify and describe whether the NHRERP Revision 2 addresses or otherwise makes provision for population growth within.the EPZ.
Identify relevant sections of the NHRERP and provide the 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, provides that the Director of the NHCDA will ensure that the plan will be reviewed at least annually and kept current.
Further, the Hampton RERP, at page III 8, assigns the responsibility for annual review of the plan to the Civil Defense Director.
7.
Please identify and describe whether sheltering may be used as a protective 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 criteria for licensing set forth in 10 C.F.R.
S 50.47 (a) (1).
Provide the Data Base to support your answer.
Response
During the period from May 15 through September 15, if the potential radiation dose is below the whole body or thyroid protective action guide, and other conditions warrant (see Section 2.6.5, Volume 2 NHRERP), the resident population would be requested to shelter where they are when the recommendation is made.
Transient populations who have temporary residences or are in locations where they may remain would also be asked to shelter-in-place.
Transient populations in state forests, parks, campgrounds and other recreational areas who are not in a location where they may remain or who do not have temporary residences readily available will be directed to leave the EPZ.
. 7 ' --
It.is intended ~that the beaches will be closed as.a
-precautionary' action at the alert emergency classification level,
.before protective actions for the general population'are' warrant'ed.
'At a-site area emergency classification. level, the beach area along 1;
Ocean Boulevard, from Little Boars Head.on the north to Route 286 in the south, will:be evacuated.
The state plan does not provide for
. the state to direct transients to a nearby.public building'in the
. event of a radiological emergency at'Seabrook Station.
See Sections D2.6.3'(for protective action guidelines) and 2.6.5 (for protective actions,. including sheltering), Volume-1, NHRERP.
In addition, see Appendix F,' Volume 4 and Appendix U, Volume 4A of the NHRERP for protective action decision criteria.and precautionary actions such as 4
early closure of beaches and evacuation of beach areas.
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J 8.:
With respect to the Compensatory Plan, please identify, describe, and provide the Data Base, for the following:
I a.
All personnel, identified by title and position; equipment; evacuation and emergency vehicles; and all'other' resources of whatever kind of description, which State of'New Hampshire believes are available to carry out the i-Compensatory Plan, in the event a municipality or municipalities are unable or unwilling to. implement the NHRERP.
-b.
The present location of each person, vehicle, item of equipment or resource identified in Answer #8 (a).
c.
The name, title, and position of every school teacher, administrator, or other school official who has volunteered
~j to carry out NHRERP duties, and identify, describe, and provide the complete Data Base in support of your answer.
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, d.-
The name, title, and position of any medical, special needs or health care facility staff, employees, or administrators, including any persons 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
The State has no compensatory plan. Instead compensatory actions are-described in various portions of the NHRERP.
Much of the compensatory capability is described in NHRERP, Vol.
4, NHCDA Local Liaison Procedures.
See also:
Vol.
2,. Appendix G, NHRERP.
a.
The State is prepared to use as many of its personnel and as much of its equipment as may be necessary to implement any required compensatory actions.
In addition the State is prepared to implement mutual aid agreements with neighboring States, to draw upon federal resources and to use the resources of private organizations with whom l
l-agreements exist.
These resources are listed throughout
(
the NHRERP.
The key personnel for each agency are listed in the State agency procedures.
These procedures comprise Volumes 4, 4A t
and 4B of the NHRERP..The key personal have access to the more detailed rosters of agency employees available for i
general support.
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Equipmentiis described in several locations..-Volume 1 has several sections that describe available equipment.- See, for example, 2.2 which-deals with equipment.
Equipment availability is also described in the State Agency procedures (Volumes 4, 4A and 4B) and in the letters of agreement in Volume 5.
b.
The State does not keep track of this precise information, beyond that contained in the NHRERP provisions cited above in 8(a).
c.
The State does not maintain a list of school department personnel.
Available special facility plans, however, describe the key. emergency response personnel in each school.
These are included as Appendix F of each local plan volume of the NHRERP.
d.
The State does not maintain a list of health care facility personnel.
Special facility plans, however, which describe the key emergency response personnel for each health care facility, are included in Appendix F of each local plan volume of the NHRERP.
9.
Identify and describe all corrective actions of whatever kind undertaken by, or on behalf of,. State of New Hampshire 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 State of New Hampshire believes still require corrective action and the nature of such corrective action, which State of New Hampshire intends to undertake.
Response
In its Final Exercise Assessment for the exercise of February 26, 1986 FEMA identified deficiencies it had noted during the exercise.
One of the two objectives of Revision 2 of the NHRERP wa's to resolve the deficiencies cited by FEMA in the Final Exercise Assessment.
The Rev. 2 submission to FEMA, in September 1986, included New Hampshire Response Actions to RAC Review of State and Local Radiological Emergency Response Plans August 1986 describing how and where the deficiencies cited by FEMA were addressed in Rev.
2.
A copy of that document has been provided to the Town of Hampton.
FEMA has subsequently issued its RAC review of Rev.
2.
This version of the RAC review was provided to the State in December 1986.
The document cites a substantially reduced list of deficiencies remaining to be resolved.
A copy of this RAC review has also been provided to the Town.
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_The State's' position is that the deficiencies cited in'the RAC
' review of December 1986' constitute the'only remaining unresolved.
' issues which may require corrective action. ~The State, with the assistance of the Applicant", is preparing responses to the most recent RAC review.
It.is likely that a formal response' package will be compiled for transmission to FEMA in April 1987.. This package will outline corrective actions New Hampshire plans to undertake.
10.. Identify and describe all corrective actions of whatever kind undertaken by, or on behalf of, State of-New Hampshire with respect to the RAC comments and recommendations n RAC REVIEW OF
'THE STATE OF NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN l
FOR SEABROOK.
Identify and describe any such RAC comments or
. recommendations, or comments or recommendations made by RAC at any time, which State of New Hampshire believes still require corrective action and the nature of the corrective action that
. State of New Hampshire intends to undertake.
Response
See the State's response to Interrogatory 9, supra.
11.
Identify and produce for inspection and copying at the offices of Shaines & ~ McEachern, P.A., 25 Maplewood Avenue, Portsmouth, New Hampshire 03891, all documents upon which you rely to support your answers to interrogatories 1 through 10.
Response
See Motion for Protective Order, infra.
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.. s 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 these interrogatories and request for production of documents.
The State of New Hampshire hereby moves the Board for a protective order that the' documents that the Town of Hampton requests to be produced may be so 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'the Town of Hampton (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 the Town 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 Defenso Agency headquarters, 107 Pleasant Street, Concord, New Hampshire, 03301.
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~ SIGNATURES t
- As to Answers to' Interrogatories 2-4, 6, and 8-10:
Richard H. Strome i
1 As to Answers to Interrogatory 5:
Dr. William'T. Wallace,-Jr.
As to Answers to Interrogatories 1 and 7:
Dr. William T. Wallace, Jr. and Richard H. Strome N
l I,. William T. Wallace, Jr.,
M.D.,
M.P.H., 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 l
' 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 Division of Public Health Services Sworn to before me this day of March, 1987:
4.
1 Notary Public My Commission Expires:
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- ,,.' 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.
~
1 Richard H.
Strome Director, Civil Defense Agency Sworn to before me this 24 da of 5
h 1987:
1M C Wuuacy euLiic My Commission Expires:
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As to Motion for Protective Order:
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pato coorge oang sisbee v
Senior Assistant Attorney General Environmental Protection Bureau Office of the Attorney General 25 Capitol Street Concord, Nil 03301-6397 Telephone (603) 271-3679 f
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A Date Geoffrey M.'
htingtoh
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Attorney Environmenta Protection Bureau Office of the Attorney General 25 Capitol Street Concord, N!!
03301-6397 Telephone (603) 271-3679
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