ML20212K363

Seacoast Anti-Pollution League Interrogatories & Requests for Documents to Applicants on Rev 2 to State of Nh Radiological Emergency Response Planning.* W/Certificate of Svc.Related Correspondence

ML20212K363
Person / Time
Site:	Seabrook
Issue date:	03/05/1987
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#187-2717 OL, NUDOCS 8703090285
Download: ML20212K363 (9)

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Filed: March 5 1987 -

$4CNETED USNRC

+ . UNITED STATES OF AMERICA _

NUCLEAR REGULATORY CX)hWIISSION -lg7 llgg .g pj,$g BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD OFFlCE CF SEcp((Apy BSCHETlHG & SEMVICT' BftAliCH In the mat ter .of:

PUBLIC SERVICE COMPANY OF Docket No. 50-443 OL NEW HAMPSHIRE,.ET AL Jo-I./te/04

-('Seabrook Statlon, Units 1)

SEACOAST. ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE APPLICANTS ON NHRERP REV. 2 INSTRUCTIONS FOR USE

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The . Seacoast Anti-Pollution League hereby requests that the Applicants,. pursuant to 10 C.F.R. 42.740(b) and 92.741, answer separately and fully,.In weiting under oath or affirmatlon, the following ' interrogatories and produce and permit inspect ion ~and copying-of the original or best copy of all documents identifled-in their response to interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents herein identified, the Applicants file supplemental responses and produce additional documents as required by 10 C.F.R. 62.740(e).

Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, report) and state the following informat ion as applicable for the particular document; name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person (s) having possession of the document.

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TheLterm " document [s]" as used herein shall mean any writ ten or l- graphic ma t t er o f communica t ion. however produced or reproduced, and is' intended to.be comprehensive and include without limitation any and all_ correspondence, letters, telegrams, agreements, notes, Y- peontracts,- 7 instructions, reports, demands, memoranda, data, schedules, not ices,.- wor k papers, r.e co r d i n g s , whether electronic or f

-by other . means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporation or intra-

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. of fice communicat ions , notebooks , diar ies , s ketches, diagrams , maps ,

b forms, manuals, brochures, lists, publications, drafts, telephone M minutes, minutes of meetings, statements, calendars, journals, orders,

' co,n f i rma t i o n s , and all other written or graphic materials of any nature whatsoever.

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GENERAL INTERROGATORIES A) For each and every one of the admitted SAPL' Content ions (#'s 31 7, 8, 8A, Redrafted 15, 16, 18, 25, 33, 34 and 37), provide the folllowing information:

a) What witnesses do the Applicants intend to have testify with respect to-this contention?

b) What. position does the Applicants intend to take on this J

contention and what is the basis of this position?

c) What documents will be usedtin support of the Applicant's position on this contention?

B) For each and every witness identified in answer to subpart a above, provide the following information:

a) Name b) Address c) Present professional or employment affiliation

-d) Curriculum vita

i.I. N APPLICANTS SPECIFIC INTERROGATORIES

1. Provide a d'etailed 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 t o . KLD? When were the photographs taken (provide specific date(s) and time (s) of day)? (Answers should be provided both-for the aerial films from which the 300 cars in the beach area were counted (see Vol. 6, p. 10-16) and the aerial photographs referenced at 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 e above.

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 numbers 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?

7. Describe in detail how the State of.New Hampshire is going to staf f the Tra f fic Control Pos ts - (TCP) and Access Cont rol Pos ts (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 organizat ion ' or agency f r om wh i ch traffic coatrol personnel will be drawn. Describe how many of the personnel can reasonably be expected to be on duty at any given time.

8. Describe the basis of the assumption that traffic management and control measures are.in effect at the time the evacuation is ordered. How much time does KLD assume it will take to put these measures into effect?

9. Describe in detail the assumptions employed in the sensitivity study that yielded the result that an immediate General Emergency would only extend ETE's 20-30 minutes.

10. How was the 25% spontaneous evacuation rate arrived at?

11. Provide a map detailing every parking space in the " beach area."

- 12 . . Why did KLD not account for roadway capacity reductions result ing from disabled vehicles?

13. State the bases for the assumption that incoming emergency response vehicles will be able to travel from 40 to 50 MPH.

14. Explain why the KLD Report does not employ the capacity reduction for snow cited in the 1985 Highway Capacity Manual.

15. Explain why the KLD Report fails to take into account choke points at bridges.

16. Who performed the telephone survey of the bus companies ref erenced in Vol. 6 at p.11-18. ? Provide copies of the survey instrument employed, the raw data from the responses and the compilation of the responses.

, 17. Provide the raw data collected in the telephone survey and i describe in detail how it was dealt with to arrive at the 2.5%

l estimate of transit dependent persons for the resident l population.

18. What are the es t imat ed percen tages of t rans i t-dependent per sons j in the seasonal and transient populations? Detail how these estimated percentages were arrived at.

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19. Describe in detail the basis for the assumption that elderly l 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

-4 classifications that roadway has.been assigned.

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.

22. Provide documentation of discussions with campground operators which f ormed the basis of the 75% estimate of unoccupied campground sites during the day in Vol. 6 of the NHRERP at p. 2-20..

23. Where are the barricades and cones to be employed at Traffic Cont rol Pos ts (TCP) and Access Cont rol Pos ts ( 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 traf fic 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 transpor ted?). Provide an estimate of the amount of time it-will take to have all of this equipment in [

place. Descr ibe how snow removal respons ibilit ies would af f ect the ability of personnel to deploy the traffic management devices.

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? I f 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 intersect ion showing all inputs, outputs, and queues.

26. Provide full loading results at one major loading point.

27. Describe in detail how light traf fic 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 will be 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 time under conditions of heavy snow fall is 150 minutes.

30. What, if any, binding contracts have the State of New Hampshire and/or Applicants entered into for provision of personnel, services, vehicles or equipment for a radiological emergency response. Provide copies of any and all contracts identified.

, 3 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.

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).

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.

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.

35. When minors are found to be contaminated, is permission of parents required to be sought prior to their decontamination?

36. Under the Revision 2 plans, what provisions are to be made for isolating contaminated water (from showering and car washing) from the environment?

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.

38. For each of the 4 host community reception centers, state how many CDV-700 survey meters will be available. Has this number of survey meters yet been provided to the host communities?

39. For each of the 17 local communities within the EPZ in New Hampshire, state the number of individuals necessary to carry out an adequate emergency response. For each of the communities that did not participate in the Feb. 26, 19 86 g r a ded FEMA d r i l l , '

detail where replacement personnel would come f rom 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.

40. For each of the 17 local communities within the New Hampshire EPZ, state which local liaison is designated to work in that community. Provide an estimated time for the local liaison to travel from home to that community.

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, , 141. . Have .the . individual members. of : Teams ters Local-No. 633 been informed of _ the driving duties they may be asked to. assume under

- NHRERP Rev. 2? Have -the individual members of Teamsters Local No. 633_in any _way: indicated their, willingness to perform these duties? If.so, how?f 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

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for' contacting the - teamsters-union drivers in the event of a radiological-emergency at Seabrook.

4 2.- From what speci fic state' agencies will _the state draw personnel to fill in for lack of adequate perso'nnel 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 speci fic l emergency

< arrangements, f acili t ies, and _needs of these local communit ies?

L4 3. 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 Rev. .2 plans.

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How many sher i f f s -'deput les are to be relled upon to perform dutiesunder-the Revision 2 plans? State how.these deputies.

'are to be deployed (i.e. how many are to be at each staging area).

45. What assurances .does tIl e State 'of New Hampshire have that Pease-AFB will make its rudway or hospital facilities available in the event of a radiological emergency? Provide.any documentation

.that might establish that such assurances have been made.. Has

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Pease AFB raised any concerns about its role in the NHRERP Rev.

.2 ? If.so,-prov_ide a detailed description of those concerns.

46. Why has the agreement with Portsmouth Naval Shipyard ~ been eliminated from the plans?

47. Why is there no lei.ter of agreement in the plans with Rockingham County Dispatch?

d8. Why is there no letter.of agreement in the plans with the New England Telephone Company?

49.( Why,are there no letters of agreement with mass care f acilities

. designated in the host community plans?

50. Has the State of New Hampshire yet secured the missing agreements with the host care f acilities for-special f acilities in the EPZ?

51. Has the. State of New Hampshire made any effort to find a replacement staging area for the OWNE Mall? If so, has a replacement staging area been found? If yes, identify it by name and locatlon.

-52. .Has the'Sta'te 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. .

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 ~ o f Vol . 4 (444 buses).

54. Explain in detail the basis for the reduction in non-auto owning persons from 8,659 to 2,106.

55. Where does.the State of New Hampshire plan that Category I and Category IV, pat i en t s . f rom Exeter llospital will be treated following their evacuation?

56. Upon what legal basis does the State of New Hampshire found the provision in the Exeter Hospital Radiological Emergency Response Plan for differenttal consideration of the evacuation option for those patients aged 55 or over?

57. Identify any survey (s) that have been conducted of employees g within the New Hampshire Department of Health and Wel f are.

Provide a copy of each survey instrument employed and provide the survey results.

Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By its attorney, BACKUS, MEYER & SOLOMON

'Ro6ert Af Backus P. O. Box 516 116 Lowell Street Manchester, N.H. 03105 Tel: (603) 668-7272

'DATE: March 5, 1987 I hereby certify that a copy of the within Interrogatories and Requests for

. Documents to Applicants on NHRERP Rev. 2 has been sent this date, first class, postage prepaid, to those listed on the attached service list, and Federal Expressed to those names which are indicated with an asterisk.

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4tobe r t A. Backus

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. CERTIFICATE OF SERVICE AND SERVICE LIST-

~Jose Fed. Emerg.ph Flynn gmt. Asst.Gn.Cnsl.~ Helen Hoyt. Chm.L -* Thomas-Dignan,.Esq.*'

Ropes &: Gray Agcy. Admn. Judge' .

500 C.St. So. West Atomic Safety &.Lic Brd.- 225 Franklin St.

Washington, DC .20472 USNRC= - Boston,.MA 02110 Washington, DC- 20555 Office 1of. Selectmen D.~. Jerry Harbour ^* Docketing & Serv. Sec.

• Torn of.Hampton Falls

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Admin. Judge Office of the Secretary

-Hampton Falls, NH 03844 - Atomic Safety & Lic Brd. USNRC USNRC Washington, DC 20555 Washington, DC 20555

'Sherwin E. Turk, Esq. *t-Office of Exec. Legl. Dr* Dr. Gustave A. Linenberger

• Jane Dough 4y Admin Judge SAPL. .

USNRC Atomic Safety.& Lic. Brd.

'Wahsington, DC 20555 5 Market Street USNRC Portsmouth,_NH 03801 d

Washington, DC 20555 Phillip Ahrens, Esq. Paul McEachern,' Esq.- George Dana Bisbee,' Esq.

, Anst. Atty. General Matthew Brock, Esq. Attorney General's_OFF.

State House, Sta. #6 25 Maplewood Ave. ~ State'of New Hampshire

~ Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 e Portsnouth, NH 03801 Carol Sneider, Esq. , Asst. AG Diane Curran, Esq.- William S. Lord -

Ono Ashburton Place, - Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.

Boston, MA 02108 - Washington, DC 20009 Amesbury, MA 01913 Richard ~A. Hanpe, Esq. Maynard Young, Gairunn Sandra Gavutis New Hanpshire Civil Defense Board of Selectmen Town of Kingston

' Agency __

10 Central Road Box 1154 Hanpe & McNicholas %e, NH 03870 East Kensington, NH 03827 bnco [ NH b3301 Judith H..Mizner, Esq. Edward 'Ihomas Mr. Robert Harrison e 'Silverglate, Gertner, FBIA Pres. & Gief Exec. Officer Baker, Fine, Good & Mizner 442 J.W. McCormack (POW) PS00

, 98 Broad Street Boston, MA 02109 P.O. Box 330

Bo ton, MA 02110 Manchester, NH 03105 Roberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, NH 03844 8-3

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