ML20212K348

Atty General Jm Shannon Offsite Emergency Planning Interrogatories & Request for Production of Documents to State of Nh (Set 1).* Interrogatories Should Be Answered in Writing on or Before 870319.Related Correspondence

ML20212K348
Person / Time
Site:	Seabrook
Issue date:	03/05/1987
From:	Bronstein D MASSACHUSETTS, COMMONWEALTH OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20212K324	List: ML20212K320 ML20212K348 ML20212K370
References
OL, NUDOCS 8703090281
Download: ML20212K348 (40)

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-WTED CORRE 00CKETED lF USNRC UNITED STATES OF AMERICA 4 32-NUCLEAR REGULATORY COMMISSION OfflCE 0r" $ECkMET Before Administrative Judges: 60tKETmG & SESVICI.

Helen F. Hoyt, Chairperson ERANCN Gustave A. Linenberger, Jr.

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' Jerry Harbour d *

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)In the Matter of . )

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PUBLIC SERVICE; COMPANY OF NEW ) Docket Nos.

50-443/444-OL

. HAMPSHIRE, ET AL. )

,(Seabrook Station, Units 1 and 2) ) (Off-Site EP)

, ) March 5, 1987

)

ATTORNEY GENERAL JAMES M. SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF 1

DOCUMENTS TO THE STATE OF NEW HAMPSHIRE (SET NO. 1)'

Pursuant to 10 C.F.R. S2.740 and 2.740b, Attorney General James M.,Shannon hereby propounds the following interrogatories

< to the State of New Hampshire. These interrogatories are to be t answered in writing on or before March 19, 1987 and under oath by an employee; representative, or agent with personal knowledge of the facts or information requested in each interrogatory.

Definitions Ac used in these interrogatories, the following terms have

(- the following meanings:

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1. " Litigate" with regard to a topic or contention means

to offer d rect testimony relating to, to cross-examine on, to y lE' N E !A . . pd P

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_r offer proposed findings or rulings regarding, or tofurge the denial (or allowance subject to conditions) of the pending application on the basis of the topic or contention.

~ 2. " Contention to be litigated by the Attorney General" means those contentions admitted in this proceeding by the Order of the Licensing Board, dated February 18, 1987 and specified in " Attorney General James M. Shannon's Notice of Intention To Participate On Newly Admitted Contentions," dated

-March!2, 1987. Specifically, those contentions are ToH Revised Contention III; ToH Revised Contention VI; ToH Revised Contention VIII; NECNP Contention RERP-8; SAPL Revised Contention 31;-Reasserted SAPL Contention-8; SAPL Contention 8a; Reasserted SAPL Contention 16; SAPL Contention 33; and SAPL Contention 34.

3. "Do;ument" means any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

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4. " Identify" with respect to any document means to state the following respecting the document: its title, its date, the author of-the document, the person to whom the document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.

5. " Identify" with respect to any action or conduct means

.to state the following regarding any such action or conduct:

the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; any document recording or documenting such action.

6. " Describe" with respect to any action or matter means

~to state the following regarding such action or matter: the substance or nature of such action or matter; the persons participating in or having knowledge of such action or matter; the current and past business positions and addresses of such persons; the existence and location of any and all documents relating to such action or matter.

7. " Identify" with respect to an expert witness means to state:

(a) The name, mailing address, age and present professional or employment affiliation of the persons (b) The profession or occupation and field of claimed expertise of the person;

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-(c).The history of formal education or training of the

person, including, but not limited to, (i) the name and address of.each school.where the person received special education or training,-(ii) the date those schools were attended, and (iii) a description of each degree earned, including the date and granting institution; (d) The history of specialized training in the area of claimed expertise, including, but not limited to, (i) the type of training received, (ii) the name and address of the institution providing this training, and (iii) the dates of-such training;

-(e) A list of publications of any kind by the person'in the area of claimed expertise, including, but not limited to, (1) the title and subject matter, (ii) the name and address of the puolisher, and (iii) the date of publication;

-(f) A list of any and all licenses in the area of claimed expertise, including, but not limited to, (i) the designation of the authority by which the license was issued, (ii) the date(s) of the licensing, (iii) the requirements for obtaining each license, and (iv) the manner by which these requirements were met; (g) The amount of time the person has worked in the

field of claimed expertise, stating periods where work was other than on a full-time basis; (h) The name and address of every person, or every corporation or other institution, that has employed the person --

! within the last ten years of employment;

5-y (i) All' periods of-claimed self-employment,. including a.

-description of all duties and responsibilities thereof; (j) _All previous experiencegin'the' field of claimed

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expertise:which_ involved problems, analyses or studies similar to those concerning which the person is-expected to. testify in.

Ethis proceeding;

_(k) All other litigation in which the person has.been consulted, specifying~those matters in which the person has

-testified, including the name of the case or matter and the court'or other forum in which testimony was givent-and (1) Any other experience.in the field of claimed expertise.

8. " Identify" with respect to a non-expert witness means to state:

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(a) The name, mailing address, age and present professional or employment affiliation of the witness; (b) The profession or occupation of the witness; (c) The name of the supervisor and department of the witness;-

(d) The current employment or professional relationship, if.any, between.the witness and you; (e) The past employment or professional relationship between the witness and you, including the dates of that relationship; and (f) All' litigation in which the person has testified on any matter in which you have had an interest, including the f

d name of the case or matter and the court.or other forum in which testimony was given.

Wherever appearing in these interrogatories, the masculine form is defined to include the feminine and/or the neuter and the: singular form is defined to include the plura1'wherever

-necessary to apply the-context to any factual situation that may exist or to render the interrogatory more inclusive in scope.

Notice Regarding Supplementation Your attention is called to the provisions of 10 C.F.R.

S 2.740(e) regarding your obligation to supplement interrogatories and requests for the production of documents.

Request for the Production of Documents

Pursuant to'10 C.F.R. 5 2.741, you are hereby requested to' produce, for inspection and copying, each document identified in response to these interrogatories and each document required to be identified in response to these interrogatories, at the offices of Attorney General James M. Shannon, Room 1902, one.

Ashburton Place, Boston, MA 02108 on March 19, 1987 at 10:00 o' clock a.m. Each document produced in response to this request should be labeled to indicate the interrogatory or interrogatories in response to which it is produced.

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l I INTERROGATORIES

'l. . Describe in detail ~your; position with respect to each-contention to be litigated by the Attorney. General and each

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, subpart offeach such contention. DescribeLin detail the reasons _for your position.

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 information concerns.

3. State whether you have relied, do rely, or will rely on any study,_ calculation, or analysis to' support your position on each of these contentions. If so, please:

a. - Describe ~the nature of the study, calculation or analysis and identify any_ documents that discuss or describe the study, calculation 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.

4. Do you intend to offer the testimony of any expert witness with respect to any contention to be litigated by the

r Attorney General? If so, please:

a. Identify each 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 expert witness is expected to testify;

c. ' State the substance of the opinion or opinions to which each expert witness is expected to testify;

d. Provide a summary of the grounds for each opinion to which each expert witness is expected to testify;

e. State whether the facts and opinions listed in response to the foregoing are contained in any document;

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 witness is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.

-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, 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.

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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 current local plans.

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?

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

9. Is population density greater for the areas within two miles, five miles, and ten miles of the Seabrook plant than the average population densities for areas within two miles, five

, miles and ten miles of all other nuclear reactors in this country?

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 and ten miles of the plants than does the Seabrook reactor.

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'll. Is there a larger summer transient population within two miles, five miles or ten miles of the Seabrook plant than

~ there is within two miles, five miles, or ten miles of all

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; evacdation 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 sheltering capacity exists to shelter the entire transient population; and if sufficient capacity does not exist to enable the sheltering of the entire population, state for what percentage of the population sufficient sheltering capacity exists.

13. Will emergency planning for the area within ten miles of the Seabrook plant effectuate less " dose reduction" than the average dose reduction for all other nuclear plants in this country, assuming coraparable radiological releases in the event of an accident?

14. Comp &re 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.

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

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.

17. Compare the average dose reduction factor of homes within the Seabrook ten-mile EPZ beach area to average dose reduction factors of homes around other reactors.

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

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.

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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 'het amounts, to whom, and the reasons for these payments. Identify and produce all documents, including contracts, which relate to these payments.

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 purporting to act on behalf of KLD Associates.

-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 corporate or internal record;

d. identify each person who participated 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.

23. Identify and pr,oduce 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 12 -

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any way to terms and conditions of payment to Mr. Lieberman or i

KLD Associates for conducting an ETE study; instructions, I

guidance, criticisms, or suggestions to Mr. Lieberman or KLD I 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.

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.

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 experta, other persons, and documents upon which you rely.

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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 measures 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.

.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. 550.47(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 (i) 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.

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.

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 factor in determining whether there is " reasonable assurance that adequate protective 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 fatalities beyond which you would agree that an evacuation plan does not offer such " reasonable assurance," state that limit.

30. On what basis does KLD estimate (Vol. 6, p. 2-27) or assume (Vol. 6. p. 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.

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 model was programmed to assume.

32. Identify the aerial films mentioned on p. 10-16 of Volume 6 of NHRERP-Revision 2 by stating when they were taken, J

by whom, and who has this film. Produce this film.

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.

i Kaltman in 1981, are reliable?

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a. If you answer in the affirmative, state your reasons 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.

34. Identify and produce all documents which indicate or project the population of the following groups inside the EPZ:

(a) in the period 1985-86, (b) in the summer 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 pollution

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 NHRERP may become unreliable.

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 function; (2) describe for each such person which traffic control post or other function each said person.has been assigned; and (3) list 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.

37. In calculating that an Immediate General Emergency would extend the ETE's by 20-30 minutes (see p. 10-16 of Volume 6), how soon after the evacuation order le 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.

38. What is the basis for the assumption, noted on p. 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 making this assumption.

39. In calculating ETE's with the "25 percent" assumption noted above in Interrogatory 25, 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 basia for this assump* ion'and identify any surveys, studies, and oxperts upon which you rely for this assumption.

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% spontaneous evacuation assumption?

If so, identify any such studies or surveys.

41. Did the KLD study contained in Volume 6'of Revision 2 of the NHRERP assume or take into account in any manner that some portion of the population beyond the EPZ would also spontaneously evacuate, taking up some roadway capacity 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.

42. In Volume 6 of the NHRERP-Revision 2, Appendices F and G are not entirely legible. Produce a legible copy of each.

43. Describe in detail the methodology for the telephone survey described in Appendices F and G of Volume 6 of Revision 2 of NHRERP, including, inter alia, 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 obtained. Also identify who has the actual

survey data cheets. Produce all 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 them, all computer print-outs, all documents assessing, reviewing, validating, or critiqueing the results, and all correspondence regarding this telephone survey, identifying each correspondent.

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

45. In conducting the ETE study, did KLD assume that all community 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.

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 1

Access Control P? If not, state what you contend the accurate numbers are, and identify the source or sources of your information.

47. List the names and home addresses, employment

addresses, and traffic control assignments of each of the New Hampshire traffic control personnel.

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

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 NHRERP? 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.

50. Have any surveys or other studies been conducted to

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assess the impact of role conflict on those traffic control personnel, bus and tow truck drivers, law enforcement and other emergency workers who have families residing within the EPZ?

If so, identify and produce said studies.

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 EPZ? If so, identify and produce said study.

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

a. Produce a copy of the survey methodology and the survey instrument or forms

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

-c.- Describe when this survey occurred and who conducted its

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.

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.

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 metholodogy used to calculate this number, (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.

55. Produce each of the records, studies, photos, slides, reports, and other documents referenced in Appendix E of 4

Volume 6 of the NHRERP-Revision 2.

5 6.- 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).

57. List and describe each and every change that you have '

made to Volume 6 of-the NHRERP-Revision 2 since it was-

published.

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.

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 i sheets, computer print-outs, and tabulations of results.

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 referenced on p. 1-10 of Volume 6 of the NHRERP-Revision 2.

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update or refine the highway characteristics documented in the field survey described in the previous interrogatory.

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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 NHRERP-Revision 2.

63. Do you admit that the NHRERP contains no contingencies which permit the redirection of evacuating vehicles in response to a change in plume direction? If your answer is negative, explain in detail what these contingencies are and how they i would be implemented. Identify any person, expert, and 6 document upon which you rely for your answer.

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

< a. When evacuating drivers seek to go in a direction I described on the intersection sketches as " movement 4

discouraged";

b. when evacuating drivers stop, thereby blocking a line t

of vehicles, to speak to the traffic guide for any

! reason (complain, ask directions, seek assistance, ,

j etc.);

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c. when evacuating drivers stop to obey traffic lights ,

and stop signs;

d. when evacuating drivers seek to dinobey traffic lights  ;

and stop signs; -

e. when an accident or a breakdown occurs which blocks or impedes traffic through an intersection.

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65. Will traffic control guides be stopping drivers to question and direct them to appropriate evacuation routes and  !

host communities?

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66. Identify and produce each and every document, including correspondence, which pertains, directly or indirectly, to any contention to be litigated by the Attorney Geneal and was exchanged between you and FEMA since your receipt of the FEMA /RAC Review of the NHRERP-Revision 2.

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.

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

69. Produce paper copies of the IDYNEV outputs produced in the runs specified in the previous interrogatory.

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.

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, text of the questions 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 produced.

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 position, the personnel designated to set out such cones, signs and barricades.

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

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?

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 transient summer beach population.

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 summer beach population.

77. Please identify all documents you intend to rely upon to support your position that sheltering will or will not be used as a protective response for the transient summer beach population.

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

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.

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 Seacrook plant.

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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.

82. If the transient summer beach population, or any portion thereof, is instructed to evacuate, how, by whom and on f

what basis will that decision to evacuate the beach population be made? Please provide any documents on which you intend to rely in making that decision.

83. Please describe your methods for estimating radiation +

i releases.

84. Please describe, and provide all documents pertaining ,

to, all meteorological models to be used for projecting doses off-site. <

85. Please describe any provisions in the plans, or means available, to monitor during an emergency the public's a

compliance with the State's protective 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. ,

86. Is it your position that sheltering should never he relied upon as a protective response action foe the transient ,

summer beach population located within ten miles of the Seabrook plant, or for any portion of that population?

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87. JUnless your answer to interrogatory 86 is an unqualified yes, describe under what circumstances, and for r

what portion of the population, sheltering ~should be used as a f- protective responce for the tiaostent summer beach population.

88. Please' provide the basis for'your determination that sheltering should or#should,not ever be used as a protective response option for13L1, or any portion of, the transient J'.i # ?( summer beach population.

89, Please provide any documents you have reviewed that are in- any way relevant to t'te conclunion(s) set forth in 1 ,.

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response'c.'o interrogatory 86.

. 90. Please, identify all docuronts you intend to rely upon

, to support your posicion that sheltering should or should not J,  :' .

ever be'ubed as a protective response option for each portion of the trahaiwnt aummer beach population located within ten miles of the Seabrook plant.

91. Is it your position that sheltering of the transient summer beach population is a saible at all osach areas located wtthin. ten-miles of the plant?

92. Please identify those beach areas within ten miles of the Seabrook plant for which hheitering of the transient o' ,

population would not be a fenetble response.

, 93. Please provide t'he basis for your' determination that shcirering of tiv. transient beach population , or a particular portion thorer:1, is or is not taasible.

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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

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response to Interrogatory 90.

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< 95..

Please' identify all documents.you intend to rely upon

-to' support your position'that. sheltering of the transient

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,10 summer beach populationg or any portion thereof, located within

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[ ten miles of the Seabrook plant is or is not feasible.

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96. Is it your position that adequate physical facilities e exist in all beach areas located within Seabrook's ten-mile EPZ to shelter the ent' ire peak transient summer beach population?

s 9 7. . Please provide the basis for your response to interrogatory 95 that adequate physical facilities do orEdo not

, exist.U

93. Please p: ovide any documents you have reviewed that are in'any way relevant to the conclusion (s) set forth in response to interrogatory 95.

., 99. Please identify all documents you intend to rely upon to support your position that adequate physical facilities do o

or do not exist to shelter the entire peak transient summer beach population.

100. Please identify all facilities that could be used to shelter the transient summer beach population and provide the dose reduction factor for each, identifying for each the basis t

for your determination of the dose reduction factor 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.

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

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 miles of the Seabrook plant.

103. Please provide any documents you have reviewed that are in any way relevant to the conclusions ~ set forth in response to interrogaties 101 and 102.

104. please identify all documents you intend to rely upon to support your position that sheltering of the transient summer beach population could or could not ever be an adequate protective response option for that population.

i 105. Is it your position with regard to the transient summer beach population, or for any portion of that population, that the protective response of sheltering could never achieve

-the same level of dose reduction as the protective response of evacuation?

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106. Please provide the basis for your response to interrogatory-105.

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

108. Please identify all documents you intend to rely upon to support your position set forth in response to interrogatory 105.  :

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?

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?

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 112. Please provide the bases for your responses to interrogatories 109 and 110, including all documents you rely upon in support of those responses.

112a. If your answer to either interrogatory 109 or 110 is anything but an unqualified yes, please identify and describe i

6 those situations for which the protective 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?

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?

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-result from an accident at Seabrook, and, if not, how many early fatalities might result in your view of a worst-case scenario?

115. Please define " worst-case scenario" as used by you to respond to interrogatory 114.

116. Please provide all data, charts, and statistics you have indicating types of accident sequences and scenarios (under varying meteorological conditions) that might result in fatalities to the off-site population within ten miles of the i

Seabrook plant, and the numbers of such possible fatalities.

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 f

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- 3 fata'lities or incidents of serious

radiation illness ~that.might i

,  ; result-from the accident' sequences and scenarios identified in

': response-to interrogatory.116.

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 m ,

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 scenarios, and meteorological conditions, the protective response of sheltering will be prescribed.

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 evacuation for the transient summer beach population, result in lower radiation exposure to that population.

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?

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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.

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.t 122. If the protective response of_ sheltering is ever to be used for any portion of the transient summer beach population, please describe, and provide any materials not included in the NHRERP relevant to, how that population will be instructed to take shelter, the precise wording of any instructions, and how, by whom, and where they will be directed to go?

123. If the protective response of sheltering were to be employed for the transient summer beach population, please provide any data you have, or otherwise your opinion, on how rapidly such sheltering could be effectuated?

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 I

beaches have not already been closed?

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?

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.

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 protective response actions will the following populations be instructed to take: (a) the transient summer beach population; (b) the non-transient beach o

population, including overnight visitors; and (c) the general population.

r 128. In the event of an anticipated small-scale short release of radiation on a peak summer weekend day, what respective protective response actions will the tansient 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; and (c) within two hours of notification of off-site authorities.

129. Is it your position that the transient beach population can in all cases be evacuated in time to avoid any radiation exposure to that population?

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

131. Is it your position that the transient beach l

population can in all cases be evacuated in time to avoid the

! incurrence of radiation exposures in excess of 200 rem by the entire evacuating population?

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132. Please provide the basis for your response to interrogatory 131 and all documents you' rely on to support'that response.

133. Is it your position that in the event of a large-scale early release of radiation that for the transient summer beach population the protective response of evacuation will be an adequate protective response action?

134. Please provide the basis for your response to interrogatory 133 and all documents you rely on to support that response.

135. In the event the transient summer beach population, or any portion therof, 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 evacutions, 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 I:

~that transportation will be obtained; (c) any provisions for l

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 l possibility that the population could upon exit from the shelters be exposed to radiation, from ground deposition or an

! overhead plume, after exit from the shelters.

4 136. Please identify and provide copies of all photographs, including aerial photographs, of the beach area

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within ten miles'of the Seabrook plant that~are in your possession or that have been provided by you 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.

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 cr counted in determining the peak numbers of vehicles, or other figures relevant to the number of persons, in the EPZ beach areas.

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 i of, any population figure provided in the NHRERP, including Volume 6.

t l 139. With respect to any surveys identified in l

interrogatory 138 please. provide: all data generated by such l

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 F.re in any l

way relevant to such surveys; and please identify: all

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4 methodologies _ employed; assumptions _used; all persons or entities: involved-in performing or devising such surveys; and

' the names,~ addresses and phone numbers of all persons surveyed..

1140.: 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 summer beach area population, and identify for each such document provided the population figure to which.it relates and

, the manner in which it relates to that population. figure. '

141. -Please identify and provide all documents, notes, p:

calculations, methodology,.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 NHRERP, and~ identify for each document so provided the figure or

- statistic to which it relates and the manner in which it

~ relates'to=th'at statistic.

[. 142. Please produce all records of the on-site interviews l

with emergency planning personnel noted on page 1-2 of Volume 6 h of the NHRERP-Revision 2 and state whether these are the same ,

i on-site interviews described on page 1-11 of this volume. If not, _please produce records for these-interviews as well.

143. Please produce the demographic data obtained from the State Planning Office noted on page 1-2 of Volume 6 of the NHRERP-Revision 2.

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144. Please produce the survey instruments, methodology, data collected, and a21 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.

145. In the last full paragraph at the bottom of page 1-11 of-Volume 6, it is noted that "[d]emographic data was obtained from several sources." Flease list these sources and produce the date obtained from each.

146. On Exhibit 2-1 on page 2-5 of Volume 6 of the NHRERP-Revision 2, where did tne 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.

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.

148.- Explain why, as stated on page 2-24 of Volume 6, "it is not reasonable to assume that all lots servicing retail establishments are filled to capacity on a day when the weather attracts people to the beach area." Identify any data, assumptions, experts, or other sources on which you rely.

149. Assuming that Seabrook Unit 1 is licensed and becomes operational: (a) how many employees will work there and (b) how many tourists, including school children, are expected to visit the plant on an average weekday during the school year?

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150. In the " Note" at the bottom of pages 4-9 of volume 6, describe what is meant by the' term " normalized" and explain how the " don't know" responses were distributed?

151. Please produce all the source materials relied upon to produce Tables 5-1 and 5-2 of Volume 6 and describe the methodology employed and all assumptions used for projecting 1986 employment data-in Table 5-1.

152. Describe the basis for making the three assumptions about weekend employment made on the bottom half of page 5-6 of Volume 6.

JAMES M. SHANNON ATTORNEY GENERAL

('A v s a 7.; n. L , ( '

T DonaJd S. Bronstein Carol S. Sneider Assistant-Attorneys General Environmental Protection Division One Ashburton Place, Rm. 1902 Boston, Massachusetts 02108 617-727-2265 Date: March 5, 1987

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