ML20212P331
| ML20212P331 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/05/1987 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | NEW HAMPSHIRE, STATE OF |
| Shared Package | |
| ML20212P218 | List: |
| References | |
| OL, NUDOCS 8703160071 | |
| Download: ML20212P331 (15) | |
Text
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March 5, 1987 UNITED STATES NUCLEAR REGULATCEY COf1MISSICN BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
Public Service Company of )
New Han.pshire, et al. ) Docket 'Hos. 5 0-443 OL
) 50-444 OL (Seabrook Station, Units 1 & 2) ) OFFSITE EMERGENCY
) PLANNING ISSUES
)
NEW ENGLAND COALITICN ON NCCLEAR FOLLUTIO!!'S FIRST SET OF INTEPPOCATCRIES A!!D PECUEST FCP THE PPODUCTIOtl OF- DOCUMENTS TO STATE OF NEW HAMPSHIRE Ot! PEVISIGN 2 TC THE tiEW HAMPSHIFE FADIOLCGICAL Et!EFCENCY FESPONSE PLAN II;STFUCTICNS FCP USE The following interrogatories are to be answereo in writing ano under oath by an employee, representative or agent of the State of ??ew Hampshire with personal knowledge of the facts or information requested in each interrogatory. We remind you of your obligation to supplement answers to interrogatories, under 10 C.F.'F. S 2.740(e).
The following definitions shall apply to these inter-rogatories:
- 1) " Document" shall mean any written or graphic matter of commu nica tion, however produced or reproduced, and is intended to be conprehensive and include without limitation any and all cor-respondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other F.703160071 870305 PDR ADOCK 05000443 9 PDR
means, computer data, computer printouts, photographs, microfilm, microfiche,' charts, analyses, intra-corporate or intra-office commu nica tions , notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, draf ts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.
- 2) " Identify" with respect to any document shall mean to state the following: the document's title, its date, the author o f the document, the person to whom to document was sent, all
[,ersons wno received or reviewed the document, the substance and nature of the cocument, and the present custodian of tne document and of any and all copies of the document.
- 3) " Identify" with respect to any action or conduct shall rean state the following regarding any such action or conduct:
tne 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; and any document recording or documenting such action.
- 4) " Identify" with respect to an individual shall mean state the individual's name, address, employer, occupation, and title.
- 5) " Describe" with respect to any action or matter shall mean state the following regarding such action or matter: the
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3-substance or nature of such action or matter; the persons partic-ipating in or having knowledge of such action or matter; the cur-rent and past business positions and addresses of such persons; and the existence and location of any and all documents relating to such action or matter.
GENERAL-INTERRCGATGRIES
- 1) In accordance with 10 C.F.R. S 2. 74 0(e) , please supple-ment your answers to NECNP's First Set of Interrogatories and Requests for the Production of Documents to the State of-New Hampshire on New Hampshire Radiological Emergency Pesponse Plans, filed April 30, 1986.
- 2) What is the State of New Hampshire's position on each of the contentions that have been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Pesponse Plan? What is the basis for your position?
- 3) On or before March 19, 1987, please produce at the office of Harmon & Weiss all documents on which you rely or intend to rely during this proceeding to support your position on each of the contentions that have been admitted in this proceed-ing with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan. This includes but is not limited to all documents used in answers to these interrogatories, summary dis-position motions, testimony, and cross-examination of witnesses during hearings.
- 4) Please identify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to rely for
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4-your position on each of the contentions that have been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan.
.5) Please identify all persons you may call as witnesses on each of the contentions that have been admitted in this pro-ceeding with respect to Revision 2 of the New Harpshire Radiological Emergency Fesponse Plan. Please describe the sub-stance of their testimony; and identify and describe any docu-ments and the portions thereof that they nay. rely on for their testimony.
- 6) On or before March 19, 1967, please proauce in the of fice of Harmon & Weiss all docwnents in the State of New Hampshire's possession which analyze or evaluate in any way the adequacy of the New Hampshire RERP or New Hampshire's state of preparedness in the event of a radiological emergency.
- 7) Please identify all persons who participated in the development or draf ting of Revision 2 to the New Hampshire RERP.
- 8) Please identify all persons who are responsible for training of emergency response personnel for implementation of Revision 2 to the New Hampshire RERP.
- 9) Please describe the State's program for training emer-gency response personnel under Revision 2 of the RERP. Identify all individuals who are responsible for that program.
INTERROGATORIES REGARDING SPECIFIC CONTENTIONS NECNP RERP-8 )
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- 10) Please produce all docut.1ents supporting your calcula-tions regarding the dose reduction efffectiveness of certain institutions in the Seabrook EPZ, as described at Vol. 4, Appen-dix F of the RERP.
- 11) Please explain your reasons and criteria for choosing to evaluate the dose reduction effectivness of these particular institutions.
- 12) Cid considerations of the time in which these facilities could be evacuated influence your decision to assess the dose reduction effectiveness of these structures? If so, what part did they play,'what estimates of evacuation times have you race'for these facilities, and what are your conclusions about the feasibility of safely evacuating them?-
- 13) Has the State performed dose reduction effectivness calculations for any specific institutional structures in the EPZ, such as schools, other than those listed in the RERP? If so, please provide them. If not, what were your reasons and criteria for refraining f rom doing so?
- 14) Did considerations of the time in which these other facilities could be evacuated influence your decision not to assess the dose reduction effectiveness of these structures? If so, what part did they play, what estimates of evacuation times have you made for these facilities, and what are your conclusions about the feasibility of safely evacuating them?
NHLP-6 and HAMPTON REVISED CONTENTICN IV TO PEVISION 2
- 15) For Each Emergency Operations Center, how many separate telephone lines are~ allocated to receiving calls from members of
.the public seeking transportation assistance? Are these commer-cial lines or dedicated lines?
- 16) For each telephone line identified above, has.an opera-tor been assigned to the line? If so, identify the individual and describe his or her expertise and experience in transporta-tion, and each person's knowledge of the area. Will that person have any other responsibilities at the ECC? If so, describe those other responsibilities.
17 ) , For eacn telephone line identified above, how many households have been told-to call that line to request assistance? How many calls does the State expect to receive on each of these lines during a radiological emergency?
- 18) For each telephone line identified above, does the State intend to use the line for any function other than the receipt of calls requesting transportation assistance? If so, what other uses are-planned?
- 19) Does the State plan to use the same telephone lines identified above to coordinate the activities of vehicles assigned to pick up people with special transportation needs? If not, what other means of communication will be used? Please identify the number and type of communication equipment that will be used for this purpose at each EOC, and the number and identity of individuals that are assigned to that task.
- 20) What advice will be given to people without transporta-tion who call the EOC if the location of the buses is unknown?
What is the basis for this advice?
- 21) How will time estimates be made for the arrival at any point on the bus route?
- 22) By what means and how often will those arrival tires be communicated to those people in need of transportation? Will the-arrival times be verified? If so, by what means and how of ten?
- 23) Describe the system by which the person taking calls at the ECC will keep track of who has requested help and whether they have received it yet.
- 24) For each person who indicates on a reply card that they will need transportation assistance, when will they be contacted with instructions? Who contacts them? Identify these individu-als.
- 25) Please produce copies of all planned itineraries and routes of vehicles that will provide transportation for people with special transportation needs, including location of bus stops.
- 26) Please identify each individual in the EPZ who is unable by virtue of age or handicap ~to go to a bus stop and requires pickup at home during an evacuation.
- 27) For each individual identified in response to the preceding interrogatory, please identify the location from which that person will be contacted to inform him or her of transporta-
tion arrangements; the specific telephone line or other means of communication _that will be used; and the number and identitity of individuals that are assigned to the task.
- 28) Please identify each vehicle that the State of New Hampshire intends to rely on for transportation of school chil-dren, handicapped people, institutionalized people, and other people without their own transportation. Please identify the owner of the vehicle, the driver (s) o f the vehicle, the location where it is stored, and its daily rou te( s ) and itinerary under ordinary circumstances. In addition, please provide copies of the routes and itineraries of each of the buses over the past two years. ,
- 29) For each venicle described in answer to the preceding question, what is the vehicle's capacity? What eq uipm ent does the vehicle have for transporting handicapped people?
- 30) Please provide copies of .the breakdown and maintenance records for each vehicle identified above.
- 31) Please identify which of these vehicles have radios on board. For those vehicles which have radios, identify the indi-viduals or organizations that will communicate with these radios.
Identify the equipment that will be necessary to communicate with the vehicles, and where it is located.
- 32) Please identify each bus driver who will be relied on in a radiological emergency, the employer (s) of that individual, and the specific vehicle that the individual will drive. If the
9-driver has not been assigned to a specific vehicle, please explain whether the driver has been assigned to a particular bus company- or other vehicle provider; and when the driver will be assigned to a specific vehicle.
- 33) For each driver identified in response to the preced-ing interrogatory, state whether that person is ordinarily
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employed as a criver and- if so by whom. Is the employment part-time or f ull-time?
- 34) For each driver identified in response to the preced-ing interrogatory, state whether the* driver is experienced in criving a bus for the hancicapped or loading students into a bus for the handicapped, and describe the nature and duration of that experience.
- 35) For each driver identified above, state whether that individual has agreed to be available during a radiological emer-gency. If so, identify the parties to the agreement, provide the date of the agreement, and indicate whether it was written or oral. If the agreement was in writing, please provide a copy.
- 36) Provide copies of the regular employment contracts between drivers and the bus companies that have agreed to provide transportation service during a radiological emergency.
- 37) For each driver identified above, describe the means by which they will be contacted; the individual (s) who are assigned to contact them; and the location, num ber , and type of each piece of communication equipment that will be used to contact them to request their assistance during a radiological emergency.
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- 38) For each driver identified above, describe all steps -
that the State has taken to assure that drivers can be contacted on a 24-hour basis.
- 39) For each driver identified above, describe all steps that the State has taken to to assure that the bus driver will be immediately available to respond to a radiological emergency.
- 40) Provide any information on estimates you have made con-cerning how long it will take each of these drivers to get to the bus that they will drive. Ciscuss the basis for your estimates and provide copies of any supporting documents.
- 41) Have estimates bees. made of how long it will take to r.obilize willing drivers at any time of the day? Discuss the casis for your estimates and provide copies of any supporting d o c um e n ts .
- 42) For those drives who reside within the Seabrook EPZ and have small children or other family members who require trans-portation out of the EPZ during an evacuation, please describe all arrangements that have been made for the evacuation of those family members.
- 43) With respect to the evacuation of school children, by whom and by what criteria will the decision be made as to whether to send buses to the staging areas or directly to the schools?
- 44) Identify all individuals responsible for monitorin~g the adequacy of transportation for schools and institutions and indi-viduals requiring special transportation, and directing the pro-e
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vision of. transportation for these people. Is the responsibility divided between several people? If so, how? What other responsibilities are assigned to those individuals?
- 45) Please identify all organizations and individuals that the State will contact in order to arrange for the transportation of school children and other people with special transportation needs during a radiological emergency.
- 46) Please identify and describe the location from which those contacts will be made; the type and number of separate pieces of communication equipment that will be used; and the num-her and identitity of individuals who are assigned to make those contacts.
,47) Is the communication equipment described in answer to the preceoing interrogatory devoted exclusively to communications requesting transportation assistance? If not, to what other uses is it assigned?
- 48) Identify all bus and driver pairs that regularly carry children to and from schools, and can be expected to be available in a radiological emergency. Provide the basis fot your answer to this question.
- 49) How long will it take to mobilize all the necessary buses in case of an evacuation? What is the basis for your estimate?
- 50) Identify each driver who has been trained for implemen-tation of the NHRERP. Describe the means by which those individ-
uals were trained, the dates on which they were trained, the identity of inoividuals who trained them, and the content of the training program. Please provide copies of any written materials that were used.
- 51) Describe any direct communications between Public Set-vice or the State of New Harpshire and the drivers in the Team-ster's Union.
- 52) Describe any communications or agreements between the Teams ter's Union and its own drivers regarding the NHPEPP.
- 53) Provide any agreements between drivers for the Team-sters Union and Union officials, Applicants, or the State of New Hampshire.
- 54) Provide copies of regular employment contracts of drivers in the Teamsters Union who will be relied on during a radiological emergency.
- 55) Provide all agreements or correspondence between the Teamsters Union or Union of ficials, Applicants, or the State of New Hampshire, regarding the possible provision of transportation services by Teamsters members during a radiological emergency.
- 56) Describe all arrangements that the State has made for the provision of backup buses in the event that insufficient buses are available during a radiological emergency.
- 57) Identify all bus and driver teams that are allocated for the transportation of transients during the summer months.
response functions in the event that the Town of Hampton is l 1
unable or unwilling to perform them, and the roles that those individuals will take. l
- 58) Are those individuals ' committed exclusively to assist in the emergency response for the Town of Hampton? If not, i
describe their other responsibilities. l HAMPTON REVISED CONTENTION VIII TO REVISION 2
- 59) NUREG-0654 states that "the overall objective of emer-gency response plans is to provide dose savings (and in sorce cases immediate life savings for a spectrum of accidents that could produce offsite doses in excess of Protective Action Gu ioelines ( PAGs ) ." In this vein, NUP EG- 0 6 54 requires planners to consider, inter alia, the timing and consequences of potential releases. What spectrum of accidents did the State consider in developing Revision 2 to the NHRERP, and what are the character-istics of those accidents? What quantitative dose savings result f rom implementation .of the protective measures proposed in Revi-sion 2, given each type of accident that was considered? Please provide all data that supports your conclusion.
- 60) Assuming that dose reductions are achieved, describe the health effects associated with each of the accidents that you considered in developing Revision 2 to the RERP.
- 61) Identify and provide access to any and all of your cal-culations of potential dose consequences to the public in the event of a radiological emergency at Seabrook, and the bases for those calculations. ,
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- 62) Has the State completely ruled out sheltering of the beach population if an accident occurs during the summer? Under what circumstances might sheltering be ordered? Describe the criteria for making such a decision.
SAPL CONTENTION 7
- 63) Describe and identify the date and parties to all oral agreements for the provision of host facilities and staff for evacuees from the Seabrook EPZ .
- 64) Please identify and produce all_ written agreements for the provision of host facilities and staff for evacuees from the Seabrook EPZ .
- 65) Please identify all individuals who will be relied on to staff host facilities during a radiological emergency, and their functions.
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- 66) Please describe all measures that will be taken at host facilities to prevent contaminated individuals from contaminating uncontaminated or less contaminated individuals.
- 67) Please describe all equipment and procedures for stor-ing and disposing of waste water from the washing of evacuees and their vehicles.
pectfully submitted, ane Curran HARMON & WEISS 2001 "S" Street N.W. Suite 430 l Washington, D.C. 20009 (202) 328-3500 March 5,1987
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I. certify that on March 5,1907, copies of the foregoing interrogatories were served by Federal Express or by hand on the
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NRC' Staff, . the Executive Director for. Operations, the Licensing Board, the State of New Hampshire, FEMA, and Applicants; and by first-class mail on all other parti s listed on the attached ser-vice list.
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5 Market Street AssistantAttorneyGeneral Calvin A. Canner Portssouth. NH 03801 State House, Station f 6 City Manager Augusta. ME 04333 CityHall Carol S. Sneider. Esquire 126DanielStreet Assistant Attorney General' ssihosasG.Dignan,Esq. Portssouth, NH 03801 1AshburtonPlace,19thFloor R.I. Gad II, Esq. .
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