ML20214G628

Atty General Jm Shannon Offsite Emergency Planning Interrogatories & Request for Production of Documents to Applicant (Set 2).* Related Correspondence

ML20214G628
Person / Time
Site:	Seabrook
Issue date:	05/19/1987
From:	MASSACHUSETTS, COMMONWEALTH OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20214G630	List: ML20214G628 ML20214G641 ML20214G673 ML20214G707 ML20214G732 ML20214G741 ML20214G768 ML20214G792
References
CON-#287-3503 OL, NUDOCS 8705270127
Download: ML20214G628 (28)

Text

,8 3 503 6 WETATED CORRESMJNDth,%1 DCCH E lli' US'IRC UNITED STATES OF AMERICA '87 MAY 20 P5 :50 NUCLEAR REGULATORY COMMISSION " - '"

0FFM.'-

00Cnt% ^ M'Ml Before Administrative Judges: ORANC" Helen F. Hoyt, Chairperson Gustave A. Linenberger, Jr.

Dr. Jerry Harbour

)

In the Matter of )

)

PUBLIC SERVICE COMPANY OF NEW ) Docket Nos.

FIAMPSHIRE, ET AL. ) 50-443/444-OL (Seabrook Station, Units 1 and 2) ) (Off-Site EP)

) May 19, 1987

)

ATTORNEY GENERAL JAMES M. SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR TilF. PRODUCTION OF DOCUMENTS TO THE APPLICANTS (SET t10. 2)

Pursuant to 10 C.F.R. S2.740 and 2.740b, Attorney General James M. Shannon hereby propounds the following interrogatories to the Applicants. These interrogatories are to be answered in writing on or before June 5, 1987 and under oath by an employee, representative, or agent with personal knowledge of the facts or information requested in each interrogatory.

Definitionn As 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 direct testimony relating to, to cross-examine on, to offer proposed findings or rulings regarding,.or to' urge 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" i

i means those contentions admitted in this proceeding by the Orders of the Licensing Board, 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 Sa; Reasserted SAPL Contention 16; SAPL contention 33; and SAPL Contention 34.

3. " Document" 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, j photographs, microfilm, microfiche, charts, analyses, l intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manunio, brochures, lists, publications, drafts, telephone minutes, minut2s of meetings,

O statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

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 actions the purpose or proposed effect of such action; and 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; and 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 person; n

a (b) The profession or occupation and field of claimed

-expertise of the person; (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, (i) the title and subject matter, (ii) the name and address of the publisher, 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 mett (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 basist e

(h) The name and address of every person, or every corporation or other institut' ion, that has employed _the person within the last ten years of employment; (i) All periods of claimed self-employment, including a description of all duties.and responsibilities thereof;

~(j) All previous experience in the field of claimed expertise which involved problems, analyses or studies similar to those concerning which the person is expected to testify in this 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'given; and (1) Any_other experience in the field of claimed expertise.

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

(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

y (f) All litigation in which the person has testified on any matter in which you have had an interest, including the 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 plural 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. S 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 June 5, 1987,at 10:00 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.

DL e.

' INTERROGATORIES

1. To the extent not previously described in response to the Attorney. General's interrogatories, describe in detail your current position with respect to each gontention to be litigated by the Attorney General and each subpartoof each such 4

contention.- Describe in detail the reasons for your position.

2. Identify and produce all documents not yet produced 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 not previously-identified-in response to the Attorney General's interrogatories to

support your position on each of these contentions. If so, p~..

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;

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f.. Explain how such' study,. calculation, or analysis provides support for your position-on each of these contentions.

4. Assuming summary disposition'is not granted on any contention currently-admitted in this proceeding, do you intend to offer the testimony of any expert witness with respect to any contention to be. litigated by the 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:

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c, a'.,LIdent'ifysNachenon-expertLwitnesswho_youintend_to;

.present<with respect.to-each subpart of each:such 3

contention;l .

-State the substance'of:the facts to which each-

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fnon-expert' witness isfexpectedito testify; and

c. . State whether the lf acts L:listedfin . response _ to - the 5 foregoing;are1 contained in any. document, and' produce  :

the.same.-

6. :For eachi-contention to be litigated by'the' Attorney;

- General,Lidentify,-as defined'in Paragraph 7, all experts'and 7 other persons you have retained-to' prepare any testimony.that may have aEbea' ring on any of these contentions and all experts  :

and other, persons with whom you have consulted in preparation.

of_any-testimony.that may have_a_ bearing on these contentions,

.whether or not you have decided to introduce such testimony, and 1 for;each-such person, please:

.a. cIdentify the contention or subpart of the contention on which;he'was consulted,.or on which he has or-is preparing testimony; _.

b._ State the substance.of the facts to which each expert may testify;. -

Ec State:the substan'ce"of the' opinion or opinions to which ,

each' expert'may testify;.

d.

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Provide-a summary of the. grounds for each opinion to which eachfexpert may 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 is-based in whole'or:inLpart on any: scientific rule or principle,

- and', if so, set forth such rule or principle;- _

g. State whether the opinion of any expert is based in j whole or'in partoon any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereoftrelied upon; and

h. State whether the opinion of any expert is based in wholeaor in part upon any scientific or engineering

-book or other publication, asnd, if so, identify the book or publication.

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7. Identify and produce all documents'not previously-identified in which you1or 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.

8. -In accordance with 10 C.F.R. S 2.740(e), please supplement your answers to Massachusetts Attorney General's Interrogatories and Request for Production of Documents, filed March ~5, 1987

9. For each provider of towing services upon whom the

-State of New Hampshire intends to rely in the' event of a radiological emergency at Seabrook Station, provide the following information:

-(a) . Produce a' copy of the Letter of Agreement with each company;

'(b) List the name, address, and telephone number of each provider and how many tow trucks each has agreed to provide and any contingencies that may apply to this agreement; (c) List how many drivers each provider has agreed to provide and any contingencies that may apply to this agreement; (d) List where each of these tow trucks is normally based; (e) List the name, home address, and phone number of each driver;

-(.f)' Stat'e what arrangement for compensation has been made,fif any, with each provider and each driver for services

' rendered during a radiological emergency; (g) Provide copies of all documents in your possession whichLApplicants or the State of New Hampshire, or their agents, provided to each tow services provider, including those

- used to obtain its commitment to provide services;

- which describe the services sought from providers during a radiological emergency; (h) Provide copies of all documents in your possession which the Applicants or the State of New Hampshire, or their agents, have received from each provider.

10. What specific steps will be taken:

(a) To-monitor whether all persons in areas ordered evacuated have in fact left the area and have not stayed at home-or at work?

(b) Upon finding persons who refuse to evacuate areas in which evacuation has been ordered, will these persons be allowed to remain, ordered out, forcibly removed or will some other action be taken?

11. The plans call for the beaches to be closed as a precautionary action at the alert classification level. Assume a hot summer day with crowded beaches when an alert occurs and the beaches need to be closed. Please describe: (a) exactly how how this closing will be accomplished, and by what I.

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personnel; (b). exactly how manyLof said personnel'will be

-needed for this task; (c) how (siren, bu11 horn, voice?) the beach population will be notified of a beach closing; (d) exactly what beachgoers will be told (provide a copy of the message.or. messages); (e) whether the. sirens will be utilized

.in either the siren or the voice mode or both in order to close

.the beaches; (f) whether EBS messages will be broadcast at this stage and, if.so, which ones (please identify by book /page-of the'NHRERP-Rev. 2); (g) whether'the remainder of the population in the EPZ will be notified of the alert and beach closing and, if so, how; (h) what will be done,:if anything, for beach-goers who have been dropped off at beaches and who have no ride away from the beach; (i) whether beach-going vehicles will be utilized in the beach closing process and, if so, how many; (j) what will be done regarding those beach-goers who refuse to leave the beaches promptly; (k) whether any special traffic control measures will be taken and, if so, what they are; (1) and whether extra personnel (other than those working at the beaches and parking lots) will be brought in to aid in the beach closing process?

12. Do Applicants, KLD Associates, or the State of New Hampshire have any studies, estimates or calculations of how long it will take from the time an " alert" occurs until all beach-goers can be cleared from the beaches and beach parking lots? If so, state what these studies, estimates or calculations are, who made them, how the estimates or a

(

' b calculations'were made, and whether any documentary (written or

. computerized) record exists of these.calcuations. Please

. produce a copy of these records.

' 13 . Describe in detail for each beach in the New Hampshire portion of the EPZ the type and number of personnel resources which'will be needed to close each beach and clear.the beach parking. lots on a hot, summer day when the beaches are crowded. Describe any special training these personnel will receive. Produce copies of all training materials, instructions, or procedures pertaining to personnel involved in beach closings.

14. At a site area emergency the plans call for an evacuation of the beach area along Ocean Boulevard, from Little

. Boars Head on.the north.to Route 286 in the south.

(a) Describe exactly the boundaries of this evacuation

~ area, describing as precisely as possible.how far west of Ocean Boulevard, if any, this evacuation area includes; (b) Describe how persons in this area will be notified

.of the evacuation; whether the sirens will be utilized in the siren or the voice mode or both; whether EBS messages will be broadcast at this stage and, if so, which ones (please identify

, .ing book /page of NHRERP-Rev. 2); whether, apart from EBS measures, additional information will be provided to persons in this area and, if so, state exactly what this information is and.how it will be transmitted; whether the remainder of the population of the EPZ will be notified of the site area

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emergencyJand beach' area evacuation and, iftso, describeLhow this1 population will:be: informed and state.what_.information-it (willEbe provided.:

15. Please;-produce;the most:recent' draft, or final version-

.if1it!has been.' submit'ted to FEMA,.of the State'of New Hampshire'sl response to the most1recent RAC-review-'(December.

.1986). State why.this formal 1 response package.was'not~

, submitted toFEMAL(a) in April.1987 as you previously: indicated it would be,-or (b) prior to'the closeLof this discovery period. State ~whether your will: voluntarily answer

' interrogator'ies from the'intervenors regarding'any changes to NHRERP-Rev. :2, Lor'other corrective actions, contained;in this formal response. package, whenever it is filed. State.when this formal; response ~ package will be submitted.

With respect to'the counts of. vehicle occupancy-which

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were. conducted for KLD on August 28 and Septemberf.1, 1985, by Merrimac Eng'inee' ring Se'rvices, .-Inc. (as_ reported in Table 4-1 and' item 18 of Appendix E of~ Volume.6 of the NHRERP-Rev. 2):-

(a) State the condition of the weather at the time

counts were being taken on each day;

'(b) State how long counts were taken at each site on each day;

.(c) State how many people were in each counting. crew at each site and describe what each crew member did; (d). State how many counting crews were working on each day;

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'-i (e). Describe with particularity the counting methodology used, noting, among other things, whether occupants for each passing vehicle were counted or whether occupants of only some fraction (e.g., every third-vehicle) of passing vehicles were counted. Describe whether occupants from buses and vans were counted and, if so, how this was done; (f) State the precise location where each person counting occupants stood for each site on each day (e.g., on the west side of Route 1A, 125 yards north of its intersection with Route 101E);

(g) For each day at each location described above, state which line(s) of traffic were involved in the counting process (e.g., traffic heading south only, or traffic in both directions);

. (h) Produce any written instructions, procedures, or work orders provided (a) by KLD to Merrimac Engineering Services,-Inc. prior to the counts and (b) to the counting crews themselves by Merrimac Engineering Services; (i) Produce all written reports from Merrimac Engineering Services, Inc. regarding these counts; (j) Describe the method by which counting crews travelled between counting sites (e.g., by car).

17. With respect to the counts of vehicle occupancy (and license plates) which were conducted on the July 4th weekend in 1986 (as reported on pages 4-8 of the NHRERP), state who conducted these counts and respond accordingly to each subpart of the immediately preceeding interrogatory.

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18. Produce a copy of all the demographic data that KLD-obtained-from the State Planning. offices', as described on pages

, 1-2 of Volume 6 of the NHRERP-Rev. 2.

19. List or produce a copy of all the information KLD obtained from state labor _ agencies, as described on pages 1-3 of Volume 6 of the NHRERP-Rev. 2.

20. ' Describe in detail how the information obtained from state-labor agencies (see preceeding interrogatory) was utilized to update the demand estimation of_ employees who work in the EPZ, as described on pages 1-3 of Volume 6 of the NHRERP-Rev. 2.

~21.

Produce-a reprint of each of the.three (3) aerial photographs of Hampton Beach, taken on July 14, 1983,. described at. item 8 of-Appendix E of Volume 6 of the NHRERP-Rev. 2.

22. Richard Strome,:the Director of NHCDA, stated on page 2 of his affidavit dated March 25, 1987, in support of Applicants' motion for summary disposition of SAPL 31, that Volume 6 of the NHRERP (the ETE study) "will be subject to the similar scrutiny to which the entire New Hampshire RERP will be

, subjected during periodic reviews, and will be revised as required."

l-(a) Will these periodic reviews of the ETE study occur at least once every twelve months? If not, state how frequent L this review will occur?

(b) Who will undertake these periodic reviews? Will it be KLD or NHCDA, or someone else?

(c) What steps will be taken to review the ETE study l

at.each periodic review? Will empirical data be gathered afresh each year for all critical input elements, including roadway characteristics, population data (permanent, seasonal, transient), transient dependent population, special needs

. facilities, schools, employment data, trip generation times, motels / hotels / campgrounds, number of transients per vehicles, and parking' capacity of the beach areas? If not, exactly how will the ETEs be kept up-to-date?

-(d) Will ETEs actually be re-computed as part of the periodic review?

(e) Many of the input data elements (e.g., those items utilized from the February 1981 Kaltman report) are already more than a few-years old. Given the commitment to periodically review and update the ETE study, how can use of these data elements be justified? When will empirical data be gathered to update these six-year old data elements?

23. .In its Supplemental' Answers to SAPL's interrogatories, the State of New Hampshire referred to certain changes in the plans that "will be reflected in the next revision of the NHRERP".

(a) When will this "next revision" of the RERP be filed?

(b) Please produce the most up-to-date draft of this "next revision" of the NHRERP.

(c) For each contention to be litigated by the Attorney General, list all changes to the offsite evacuation

plans that will~.be reflected in the next revision of-the RERP and address an element of the-plans alleged in that contention to be inadequate or deficient.

.(d) State whether you will voluntarily answer interrogatories from the.intervenors regarding any changes or additions to NHRERP-Rev. 2 contained in the next revision, whenever it is filed.

24. State who wrote the current set of EBS messages in the-NHRERP-Rev.-2. Describe the role played by Dennis S. Mileti with respect to the writing of these EBS messages.

25. Using-the list of centroids contained on pages M-1 through M-5 of Volume 6 of the NHRERP-Rev. 2, note for each centroid how the number for " transient" vehicles was obtained (e.g., from the beach area vehicle count, from the NRC's Kaltman report, etc.).

26. For each centroid noted above for which the number of.

transient vehicles came from'the beach area vehicle count, define precisely the geographic area for which, using aerial photos or slides, vehicles were counted and allocated to that centroid.

27. Although we have previously requested copies of the computer tapes of all the sensitivity runs conducted by KLD, and Applicants agreed to provide these tapes, we have yet to receive them. Please provide computer readable copies of all sensitivity runs conducted to date on the ETE's which KLD has calculated for Seabrook's EPZ.

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28. KLD. computed the Seabrook ETE's on a stand-alone

. version'of the IDYNEV computer'model, which was developed by KLD under a contract with FEMA.. The version of IDYNEV which FEMA now has, however, is not identical to the version KLD used; so we have'been unable to thoroughly test KLD's work on FEMA's model. While Applicants have permitted us to have access to KLD's model, directly at KLD's offices in Huntington Station, New York, and also by phone modem,' KLD is charging

$100/ hour for each c.p.u. hour and is monitoring all our computer runs. . This arrangement has proven to be both unreasonably expensive and unreasonably intrusive. Please produce a separate copy of the computer model which KLD used in computing the ETE's contained in Volume 6 of the NHRERP-Rev. 2

29. Vol. 6, pp. 3-9, of NHRERP-Rev. 2, lists the 2-way and 1-way capacity estimates for the four road type categories (low.

design, medium design, high design, and limited ~ access) used in the evacuation model. Appendix N presents the link capacities for the evacuation network, but does not indicate the road type category for each link. Therefore, it is not possible to verify the road capacities, nor is it possible to determine if a given section of the evacuation network is limited by road capacity or intersection capacity. Please produce a list that-indicates the road type category for each link in the evacuation network and classifies each link as being roadway-capacity limited or downstream-capacity limited.

30. With respect to the agreement by Teasmsters Local No.

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633'ofLNew Hampshire.'to provide emergency workers-and drivers-in thefevsntLof a. radiological emergency at Seabrook Station:

(a) Produce cop'ies of all letters or other documents provided to the Union by e'ither. Applicants or.the State of~New Hampshire to explain the services being requested or otherwise obtain the union's Letteroof Agreement.

(c) State what. compensation, if any, individual teamsters.were promised thsy would receive for-their services

-if:they assisted during a radiological emergency. How much.

-would they be paid per' hour?- Who would pay this compensation?

(d) Produce copiesoof all'otherLcorrespondence.you have received or sent to the Teamsters Local No. 633 in 1986 and 1987.

'31. Item-16 on page 1-4'of Volume 6 of the NHRERP-Rev. 2 states: "These estimates were based on the survey data base...."

(a)-Is the referencsd' survey the one conducted by First Market Research or the special needs survey conducted by NHCDA?

.(b) What was the response rate of this survey?

(c) Since Volume 6 was published, what steps, if any have been taken to verify or check the estimates of demand for transit services ?-

(d). Produce all documents in your possession, or in the' possession of KLD, which describe the method and results of any verification or check of the estimate of demand for transit services..

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32. When First Market Research conducted the survey utilized by KLD in preparing the ETE study (Volume 6 of the NHRERP-Rev. 2) were any validation efforts taken to ensure that the respondents were representative of the_ target population?

-If so, please describe these validation efforts and identify' who conducted them. Produce all documentation of these validation efforts.

33. Do you admit that in conducting its' telephone survey First Market Research engaged in no re-calls, that is, when a number dialed went unanswered, no attempts were made to call the number back at another time of day? If your answer-is anything but a simple yes, state what the exact survey methodology was.

34. Assuming a rapidly developing accident with. release of offsite radiation and meterology such that any plume would be expected to travel in the direction of the New Hampshire beaches occurring at 2:00 p.m., on a peak summer weekend day, when beaches are at or near capacity, do you contend that the evacuation times identified in NHRERP Volume 6, would be short enough to prevent all fatalities among members of the beach population under all accident sequences? If not, (a) under what accident sequences would ETEs not be short enough, and (b) provide a range of the numbers of early fatalities that could occur.

35. Would your response to the previous interrogatory be any different iflyou were to assume that, thirty minutes after plume release, thereLwas a thunderstorm along the beach area?

Please state how this additional assumption could affect your response to the previous interrogatory.and provide the range of early' fatalities that could occur under this. assumption.

36. Is it your position that, in the event of a rapidly developing accident occurring at 2:00 p.m. on a peak summer weekend day, sheltering may be relied upon as a protective action for the entire transient beach population?

37. Do you contend that Rev. 2 of the NHRERP provides, or plans, for the sheltering of the entire transient beach population in the event of an accident occurring on a sunny day between May 15 and September 15 at a time when beaches are at or near capacity?

38. Do you agree with the following response of the State of New Hampshire to ToH Interrogatory 7:

Response

During the period from May 15 through September 15, if the potential radiation dose is below the whole body or thyroid protective action guide, and other conditions warrant (see Section 2.6.5, Volume 2 NHRERP), the resident population would-be requested to shelter where they are when the recommendation is made. Transient populations who have temporary residences or are in locations where they may remain would also be asked to shelter-in-place. Transient populations in state forests, parks, campgrounds and other recreational areas who are not in a location where they may remain or who do not have temporary residences readily available will be directed to leave the EPZ.

If not, please state with precisely what part of the response you do not agree, and precisely why you do not agree. Would

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your response be any different'if the above statement were changed so as to assume that potential radiation doses would not'be below-the whole body or thyroid protective action guide? Please explain.

39. Is it your position that in the event of a beyond design bases accident, that the transient beach population can in all cases be evacuated in time to avoid the incurrence of radiation exposure in excess of 200' rem by that entire population?.

40. Please provide the basis for your response to the previous interrogatory and all documents on which you rel'1 to support that~ response.

41. With respect to the on-foot survey identified by Applicants in response, dated-March 18, 1987, to SAPL Interrogatory No.'3a.:

a. identify the person (s) who performed such survey;

b. state the number of houses that were surveyed and, where available, the locations of such houses;

c. provide the date(s) and time (s) of day that such survey was performed; i

d. provide all documentation, notations, writings, and recordings of, or relating to, such survey.

42. In response, dated March 18, 1987, to SAPL Interrogatory No. 5, Applicants state "the estimate for Item d, namely transients, was obtained by assuming that the available l

L parking capacities in the beach areas was completely filled l

l l

r. l i

with cars." For each of the 57 aerial slides used by KLD Associates in determining parking spaces (produced in response to Massachusetts Attorney General's Interrogatory 137), please provide the numbers of parking spaces that were counted for each slide, and to the extent possible, identify the spaces that were counted.

43. .Do you contend that, at 2:00 p.m., on a peak summer weekend day when beaches are at or near capacity, that sheltering of the entire transient summer beach population can be effectuated at all beaches within the Seabrook Station plume exposure EPZ?

44. If the entire transient summer beach population is directed to shelter at a time when beaches are at or near capacity, please state:

a. How long it would take to accomplish sheltering of the entire transient population;

b. What, if any, instructions would be given to the transient beach population;

c. In what manner and by what instrumentation, (e.g., by sirens in voice mode, bullhorns, etc.) would instructions to shelter be given to the beach population.

45. Please provide separately for each beach area in the Seabrook Station plume exposure EPZ, the sheltering capacity in the beach area for the transient population.

46. What, if any, provisions have been made to shelter persons at campgrounds in the EPZ? If provisions have been made to shelter persons at campgrounds, please provide:

(a) where the campers will be instructed to shelter;

.(b) how theyrwill be instructed to shelter; (c) the instructions that will.be given to campers; (d) where in:NHRERP,'Rev. 2, such provisions for campgrounds can be found; and

(.):_'whether e there_are any plans to supplement or revise the NHRERP in any manner with respect to provisions for sheltering

. persons at campgrounds.--

47. Are you familiar with the methodology utilized by M.

Kaltman when, in gathering data for what-is commonly called the Kaltman report (see reference on p. E-10 of Volume 6 of the NHRERP-Rev. 2),-overnight ~ accommodations (hotels, motels, and campgrounds) were surveyed? If so, describe your understanding of that methodology.

48. What do you currently believe to be the current number of:

(a) Hotel rooms in-the New Hampshire portion of the EPZ?

(b) Motel-rooms in the New Hampshire portion of the EPZ?

(c) Campground spaces in the New Hampshire portion of the EPZ?

(d) Produce all documents and identify all studies upon which you rely for your answers'to this interrogatory.

49. With respe'ct to the Stone & Webster Engineering Corp.

study, dated March, 1986, and entitled "A Study to Identify Potential Shelters in the Beach Areas Near Seabrook Station,"

please:

(a) identify the person (s) who performed such study; (b) state whether the person (s) who performed such study visited every shelter identified in the study; (c) state whether the persons who performed the study consulted-with all, or some, of the owners of the identified potential shelters, or with their agents,

'e e and if only some of the~ owners were consulted with, state for which shelters the owners were, or were-not,

' consulted with; (d)-' state whether the owners.'of all'the potential shelters identified in the study all. agreed to provide the space indicated in the study for the sheltering of transients, and if they did not all so agree, please indicate:_

(1) how many. owners did agree; (2) identify the shelters for which those owners did agree;-

(e) state, as precisely as possible, the manner in which the sheltering-capacity of each identified shelter was determined-(e.g., by viewing the exterior of the building, by viewing the interior of the building, by talking with the owner, etc.);

(f) state,_as precisely as possible, the manner and procedure employed to determine the dose reduction factor of each identified shelter.-

50. At Page 13 of the document entitled "New Hampshire Yankee ~Seabrook Station Independent Review Team' Emergency Planning Evaluation," IRT-030, dated January, 1986 [hereafter IRT Evaluation], it is stated that the use of a voice message for notification is inappropriate in the beach areas. Please describe: (a) what, if any, corrective actions have been, or will be, taken with respect to this item regarding notification' of the beach population; and (b) the means by which the beach population will be notified and instructed in the event of an emergency.

51. For every deficiency noted by the Independent Review Team Evaluation, please state: (a) the deficiency noted, (b) the corrective action taken or intended to be taken; and (c) the date the corrective action was taken or is intended to be taken.

c ._

'o

~ 52. With respect to summer residents who inhabit unwinterized accommodations at or near the beach, please identify and describe, with appropriate reference to NHRERP, Rev. 2:

(a) -what provisions, if any, have been, or will be, made for sheltering these residents;

~(b) _ the instructions that will be given to these residents in1the event beaches are to be closed and the permanent population is instructed to shelter; (c) if such persons are instructed to shelter, where they will be instructed to shelter.

53. Is it your position that the vast majroity of evacuating persons who, in the event.of an accident with an offsite release-or radiation, are instructed to report to reception centers for monitoring will comply with those

, instructions? What percentage of the evacuees do you expect will comply?

54. In the event of an accident with an offsite release of radiation, what percentage of the EPZ population would you expect to be instructed to report to reception centers for monitoring? What is the largest number of persons that might be instructed to report for monitoring?- What is the smallest number of persons that might be instructed to report for monitoring?

55. In the event of an accident with a wide-spread off-site release of radiation, if all persons instructed to report to reception centers for monitoring do so report, could a bottleneck be created at the entrance to such reception f

s centers? Have any sensitivity studies been performed to determine the impact such bottleneck (s) would have on ETEs?

Please explain your responses and provide any such studies.

JAMES M. SHANNON ATTORNEY GENERAL Donald S. Bronstein Carol S. Sneider Allan R. Fierce Assistant Attorneys General Environmental Protection Division One Ashburton Place, Room 1902 Boston, Massachusetts 02108 (617) 727-2265 Date: May 19, 1987