ML20214T236
| ML20214T236 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/04/1987 |
| From: | Bisbee G, Strome R NEW HAMPSHIRE, STATE OF |
| To: | Shannon J MASSACHUSETTS, COMMONWEALTH OF |
| Shared Package | |
| ML20214T239 | List: |
| References | |
| CON-#287-3676 OL, NUDOCS 8706100172 | |
| Download: ML20214T236 (26) | |
Text
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RELATED C0 6
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Jun0 4, 1987 36 76 UNITED STATES OF AMERICA 0%[,h~EU NUCLEAR REGULATORY COMMISSION Before the Nuclear Regulatory CommisgjonJW -5 P2 37
)
I p.,,
In the Matter of
)
Docket Nos. 50-443-OL
)
and PUBLIC SERVICE COMPANY OF
)
50-444-OL NEW HAMPSHIRE
)
(Off-Site Emergency (Seabrook Station, Units 1 and 2
)
Planning Issues)
__ _ )
THE STATE OF NEW HAMPSHIRE'S RESPONSES TO ATTORNEY GENERAL JAMES M.
SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE STATE OF NEW HAMPSHIRE (SET NO. 2)
ANSWERS TO INTERROGATORIES Interrogatory No. 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 contention to be litigated by the Attorney General and each subpart of each such contention.
Describe in detail the reasons for your position.
Response
The State of New Hampshire's position on the contentions has not changed since it responded to the Massachusetts Attorney General's last set of interrogatories.
Interrogatory No. 2 Identify and produce all documents not yet produceo 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.
Response
All oocuments identified in these responses are available for inspection at the Civil Defense Agency headquarters in Concord, New Hampshire, on reasonable notice, between the hours of 8:30 am, and 4:00 p.m.,
Monday through Friday.
0706100
((b0 43 PDH AD POR 4
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)
Interrogatory No. 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, please:
a.
Describe the nature of the study, calculation or analysis i
and identify and 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.
Response
No, as to such documentation on which the State does or did rely.
As to such documents upon which the State may in the future rely, they will be referenced in any necessary supplemental responses.
Interrogatory No. 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 witess 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 witnessis expected to testify; c.
State the substance of the pinion or opinions to which each expert witness is expected to testify; d.
provide a summary of the ground 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 documents 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 sudirule or principle;
1 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.
Response
No.
Interrogatory No. 5 Do you intend to offer the testimony of any non-expert witness with respecb to any contention to be litigated by the Attorney General?
If so, please:
a.
Identify each non-expert witness whanyou 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.
Response
No.
Interrogatory No. 6 For each contention to be litigated by the Attorney General, identify, as defined in Paragraph 7, all experts and other persons you have retained to prepare any testimony that may have a bearing 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 tesdmony, and for each such person, please:
a.
Identify 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; c.
State the substance of the opinion or opinions to which each expert may testify; d.
Provide a summary of the grounds for each opinion to which each expert may testify;
o,
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 in part on any scientific rule or principle, and, if so, set forth such rule or principle; l
g.
State whether the opinion of any expert is based in whole or in part on any code or regulation, governmental or l
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 is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.
Response
See the State's response to Interrogatories 4 and 5 above.
Interrogatory No. 7 Identify and produce all documents not previously identified 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.
Response
The State has compiled no new documents assessing the adequacy of the NHRERP.
Steps that may be taken to address the RAC review will be included in the State of New Hampshire response to the RAC comments on Revision 2 of the NHRERP.
That document is being-compiled at this time and exists only in draft form.
Interrogatory No. 8 In accordance with 10 C.F.R.
S2.740(e), please supplement your answers to Massachusetts Attorney General's Interrogatories and Request for Production of Documents, filed March 5, 1987.
Response
This will be done as necessary.
a
D -
Interrogatory No. 9 For each provider of towing services upon whom the State of New Hampshire intends to relyingthe 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.
State what arrangement for compensation has been made, if any, with each provider and each driver for services rendered during a radiological emergency; g.
Provide copies of all documents in your possession which applicants 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.
Response
a.
Copies of the letters of agreement with towing companies are in NHRERP, Volume 5.
Letters of Agreement obtained since the publication of Rev. 2 are available for inspection at the NHCDA offices.
b.
The name of each provider, the number of vehicles available and vehicle locations, are included in each letter of agreement.
c.
Each letter of agreement commits drivers / crews for identified tow trucks.
No contingencies are expressed in
~
the Letters of Agreement.
d.
This information is contained in the Letters of Agreement.
?,
e.
.The State has not compiled this information..
f.
Compensation arrangements are described in each Letter of Agreement.
~
g.
The State has no such documents.
h.
The only documents other than those identified in Item a.
above consist of routine transmittal letters to towing companies.
Interrogatory No. 10 Uhat 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?
Response
a.
Procedures for confirmation of evacuation will be developed and published in the next plan revision.
b.
The State will provide explicit instruction for the appropriate population groups to evacuate.
The State believes that the general public will follow the instructions given by properly constituted authorities, and, therefore, does not anticipate the need to do anything further to initiate an evacuation.
Interrogatory No. 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 this closing will be accomplished, and by what personnels b.
exactly how many of said personnel will be nee'ded for this task; c.
how (siren, bullhorn, voice?) the beach population will be notified of a beach closing;
-7 d.
exactly what beachgoers will be told (provide a copy of tne 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);
9 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 specialtraffic control measures will be taken and, if so, what they are; 1.
and whether extra personnel (other than those working at L
the beaches and parking lots) will be brought in to aid in the beach closing process?
Response
The NHRERP calls for consideration of the closing of beaches at the Alert classification level.
Once a decision to close the beach areas has been made, (see Vol. 4 Appendix F), DRED personnel will be informed (see DRBD Procedures Vol. 4B) to implement beach closing.
Selected sirens (those along the beach) will sound an alert tone and then in the voice mode will be employed to notify persons on the beach that the beach has been closed.
The message given to beach-goers is set forth below.
The EBS system is placed on stand-by at the alert level.EBS messages, however, are not broadcast.
Public service announcements will be prepared and distributed to radio stations for broadcast.
Beach-goers will be restricted from use of the beach proper and the State maintained parking areas (these are the areas which have been closed).
It is expected that ' beach-goers' will either move away from the beach area to facilities.near the beach (i.e., restaurants, shops, arcades, etc.) or will leave the area in the vehicles in which they arrived.
The State does not anticipate that beach-goers will refuse to leave the beach area.
Traffic control will be implemented in order to facilitate the egress of beach-goers (See Troop A procedures, Vol. 4B)
Access control will also be implemented in order to discourage additional persons from going to the beach area once it has been closed.
Additional personnel can be brought in, if necessary, to assist in the closing of the beaches.
The State objects to Interrogatory 11(i) Decause of 4
the vagueness of the term " beach-going vehicles."
I i
s
-g_
EARLY BEACH PROTECTIVE ACTION MESSAGE Attention... Attention...
Because of a problem at Seabrook Station, the beach is now closed.
Please leave the beach immediately.
Listen to a local radio station for more information.
Interrogatory No. 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 calculations were made, and whether any documentary (written or computerized) record exists of these calculations.
Please produce a copy of these records.
Response
The State has done no study of this timing issue.
Interrogatory No. 13 Describe in detafl for each beach in the New Hampshire portion of the EPZ the type and number of personnel resources which will be needed to clone 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.
Response
The procedures and organizations employed to close the beach areas in Hampton and Seabrook are contained in Volume 4, Appendix F.
In addition, procedures for organizations having primary and secondary assigned responsibilities are contained in Volume 4B.
Personnel and resources are provided by agencies which include Department of Resources and Economic Development (DRED) (up to approximately 39 personnel), New Hampshire State Police (as needed).
Procedures for these agencies are outlined in NHRERP Vol. 4B.
These procedures are supplemented by the New Hampshire Traffic Management Manual.
Training provided for identified personnel includes:
Module 14, Implementation of Beach closing (DRED personnel and State and affected local police departments) and Module 13, Traffic Management (State Police and affected local police departments).
Interrogatory No. 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 by 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 1,
the site area emergency and beach area evacuation and, if so, describe how this population will be informed and state what information it will be provided.
Response
The NHRERP Vol. 4 Appendix F calls for consideration of Evacuation of a part of the beach area in the event a Site Area Emergency is declared.
The intent of considering this precautionary action is to provide consideration for the barrier beach area in Hampton and Seabrook.
Notification at Site Area Emergency will be by siren for the entire EPZ.
EBS messages will also be broadcast throughout the EPZ describing the appropriate protective action to be taken.
Examples of EBS messages which might be used are found in Appendix G of Vol.
4.
The EBS by its nature does not discriminate in the dissemination of messages from one group to another.
The EBS is accessible to all who have a commercial radio receiver.
Interrogatory No. 15 Please produce the most recent draft, or final version if it has been submitted to FEMA, of the State of New Hampshire's response to the most recent RAC review (December 1986).
State why this formal respone package was not submitted to FEMA (a) in April 1987 as you previously indicated it would be, or (b) prior to the close of this discovery period.
State whether you will voluntarily answer interrogatories from the intervenors regarding any changes to NHRERP-Rev.
2, or other corrective actions, contained in this formal response package, whenever it is filed.
State when this fornal response package will be submitted.
Response
As stated in response to Interrogatory 7 above, the State has not yet completed its comments to the most recent RAC review of the NHRERP.
. The State' objects to the request to produce a copy of any draft comments to the RAC review, on the grounds that such drafts-constitute privileged, deliberative process materials.
In re Franklin National Bank Securities Litigation, 478 F.
Supp. 577 (S.D.N.Y.
1977).
The State also objects to the request for the State to give its reasons for not' submitting comments to the RAC review, on the grounds of relevance.
The State will not commit to. respond to any interrogatories beyond those required by NRC regulations and by the Licensing Board.
Interrogatory No. 16
<g
, With respect to the counts of vehicle occupancy which were conducted for KLD on August 28 and September 1, 1985, by Merrimac Engineering Services, 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; s
e.
Describe with particularity the counting methodology used, 4
noting, among other things, whether occupants for each passing vehicle were counted or whether occupants of only
~
.some fract. ion (e.g., every third vehicle) of passing vehicleu~were counted.
Describe whether occapants from buses and vans were counted and, if so, how this was done; J>
i n; 4 f.c, State the precise location where each person counting i
a occupants stood for each site on each day (e.g., on the
(
went side of Route lA, 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 (0
directions);
f 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;
,s j.
Describe the nethod by which counting crews traveled between counting sites (e.g., by car).
.e,,
-a __ -.,..-_______.-;._
-g
- Response As the terms of this interrogatory indicate, the State did not conduct the vehicle counts in question.
Interrogatory No. 17 With respect to the counts of vehicle occupany (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 preceding interrogatory.
Response
See the State's response to Interrogatory 16 above.
Interrogatory No. 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.
Response
The State has no separate records of the data cited.
Interrogatory No. 19 List or produce a copy of all the information KLD obtained from state labor agencies, as described on page 1-3 of Volume 6 of the NHRERP-Rev.
2.
Response
The State has no listing of this information.
Interrogatory No. 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.
i
Response
A detailed description of methodology is included in Section 5 i
Volume 6 of the NHRERP.
l L
Interrogatory No. 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.
Response
The State has no copies of these aerial photographs.
Interrogatory No. 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."
a.
Will these periodic reviews of the ETE study occur at least once every twelve months?
If not, state how frequent 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 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?
Response
a.
The commitment for an annual plan review for the NHRERP is found at Volume 1, p.
3.3-3.
b.
NHCDA will supervise annual plans reviews, which will be done by NHCDA personnel or consultants, as determined by NHCDA.
L
s E c-e. The State has established no specific criteria for its annual review of the ETE.
It is likely, however, that the State will subjectively consider changes in population or availability of populatio_n data, changes in the evacuation roadway network, or changes in emergency response resources I
when determining whether new unalytical work is warranted.
New empiracal data will likely not be gathered each year.
Interrogatory No. 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.
t 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.
Response to a-d Updating of he NHRERP is a continuous process.
Members of the State and local emergency response organizations may suggest revisions to the NHRERP at any time.
Likewise the State may entertain proposals for plan revisions from other knowledgeable and interested parties including affected nuclear power plant operators and their consultants.
The process for proposing, reviewing and adopting revisions to the NHRERP is described in the procedure entitled Instructions to Person Proposing Revisions to the New Hampshire Radiological Emergency Response Plan.
This procedure augments the general guidance on plan revision described in the NHRERP, Vol.
1, Section 3.3.3.
A copy of these Instructions is available for inspection at the Civil Defense Agency offices in Concord, New Hampshire.
To date only a few proposed changes to Rev. 2 have been submitted to or considered by NHCDA for review and approval.
No changes have been finalized.
It is not now known when the next publication of a NHRERP revision will occur.
The State objects to the request to produce draft versions of the NHRERP on the grounds that such documents are privileged, deliberative process material.
In re Franklin National Bank Securities Litigation, 478 F. Supp. 577 (S.D.N.Y. 1977).
5
. =
Interrogatory No. 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.
Response
.The EBS messages contained in NHRERP, Vol.
4, NHCDA Procedures, Appendix G_were drafted by New Hampshire Yankee and its consultants.
The messages were reviewed and edited by staff of the New Hampshire Civil Defense Agency.
To the State's knowledge, Dennis S.
Mileti played no role in the writing of these messages.
Interrogatory No. 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.).
Response
The State did not undertake the vehicle count in question.
Interrogatory No. 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.
Response
l The State did not conduct the vehicle count in question.
Interrogatory No. 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 readablecopies of all sensitivity runs conducted to date on the ETE's which KLD has calculated for Seabrook's EPZ.
Response
The State has no copies of the requested computer tapes.
Interrogatory No. 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 PEMA.
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 L.
l
3 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.
Response
The State does not have a copy of the computer model requested by this interrogatory.
Interrogatory No. 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.
Response
The State has no such list.
Interrogatory No. 30 With respect to the agreement by Teamsters Local No. 633 of New Hamshire to provide emergency workers and drivers in the event of a radiological emergency at Seabrook Station:
a.
Produce copies of all letters or other documents provided to the Union by either Applicants or the State of New Hampshire to explain the services being requested or l
otherwise obtain the union's Letter of Agreement.
l b.
State what compensation, if any, individual teamsters were promo ed they would receive for their services if they I
assisted during a radiological emergency.
How much would they be paid per hour?
Who would pay this compensation?
l c.
Produce copies of all other correspondence you have l
received or sent to the Teamsters Local No. 633 in 1986 and l
1987.
l
\\
m
Response
The request for assistance from Teamsters Local No. 633 was a.
-discussed with' Union Officials.
A Letter of Agreement was developed along the lines'of Letters of Agreement with other organizations and submitted to Union officials.for execution.
(See Volume 5 NHRERP LOA with Teamsters Local 633).
No other documents were provided to the union.
b.
Compensation for union members as a group or individually is not discussed in the LOA.
c.
. Copies of all correspondence with Teamsters Local 633 have been previously provided (See LOA Vol. 5 and Letter from Teamsters Local 633 to Nicholas Pishon, NHCDA).
Interrogatory No. 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...."
Is the referenced survey the one conducted by First Market a.
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.
Response
The State did not conduct this survey.
Interrogatory No. 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.
Response
The State is aware of no such validation efforts.
4
l
~
6 '
. Interrogatory No. 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 hade 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.
Response
The State did not conduct this survey.
Interrogatory No. 34 Assuming a rapidly developing accident with release of offsite radiation and meteorologysuch 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 sequ'.acesi 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.
Response
The State of New Hampshire objects to this interrogatory on the grounds of vagueness and overbreadth.
Without waiving this objection, the State quotes the response provided on March 18, 1987 to Interrogatories 27-28 of Attorney General Shannon's off-site interrogatories:
"The State of New Hampshire has no data on fatalities that might result among any populations after an accident at Seabrook Station.
The State cannot state whether the KLD's ETE study demonstrates, or does not demonstrate, the l
evacuation times are short enough to prevent any fatality l
under any accident sequence."
(Emphasis in original.)
Interrogatory No. 35 Would your response to the previous interrogatory be any different if you were to assume that, thirty minutes after plume release, there was a thunderstorm along the beach area?
Please state how this additional assumption could affect your response to the i
previous interrogatory and provide the range of early fatalities that l
could occur under this assumption.
Response
See the State's response to Interr,ogatory 34 above.
l
.- Interrogatory No. 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?
Response
The State of New Hampshire objects to this interrogatory on the grounds of vagueness and overbreadth.
Without waiving its objection, the State responds as follows:
The " shelter in place" concept, as described in NHRERP, Vol. 1, Section 2.6.5, can be implemented at any time for that segment of the population that requires it.
Because the State of New Hampshire relies on early beach closings and sheltering-in-place, persons without residences, temporary or permanent, will be asked to leave the EPZ.
The State's position with regard to sheltering the transient beach population, at anytime of day, day of week, or week of year, is provided in the State's response to Interrogatory 75 of Attorney. General Shannon's off-site interrogatories provided on March 18, 1987.
Interrogatory No. 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?
-Response The State objects to this interrogatory on the grounds ~of vagueness and overbreadth.
Without waiving this objection, the State responds as follows:
The NHRERP Rev. 2 provides reasonable assurance that in the event of a wide range of potential accidents the means are in place to implement a range of protective actions in order to effect a dose savings to the general public.
This includes provisions for prompt notification of the general public along with a direction to implement appropriate protective actions based upon the specific circumstances at the time.
Protective actions for specific parts of the EPZ could include sheltering in place, leaving the area or to taking no action.
f.
- - Interrogatory No. 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 your response be any different if the above statement were changed so as to assume that poential radiation doses would not be below the whole body or thyroid protective action guide?
Please explain.
Response
The interrogatory is nonsensical.
The response in question is the State's response.
Interrogatory No. 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?
Response
The State objects to this interrogatory on the grounds of vagueness and overbreadth.
Without waiving this objection, the State responds as follows:
The State has undertaken no analysis of the issue raised.
Interrogatory No. 40 Please provide the basis for your response to the previous interrogatory and all documents on which you rely to support that response.
Response
See the State's response to Interrogatoy 39 drve.
p 4-t-Interrogatory No. 41 With respect to the Un-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; d.
provide all documentation, notations, writings, and recordings of, or relating to, such survey.
Response
The State did not conduct the referenced survey.
Interrogatory No. 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 parking capacities in the beach areas was completely filled with cars."
For each of the 57 aerial slides used 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 counced.
Response
The State does not have this information.
Interrogatory No. 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?
Response
See the State's response to Interrogatories 36 and 37 above.
Interrogatory No. 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;
7 a
4 5 b.~
What, if any,_ instructions'would be given to the' transient beach population; In what manner and by what instrumentation, (e.g., by c.
sirens in voice mode, bullhorns, etc.) would instructions to~ shelter be given to the beach population.
Response
The State has undertaken no estimate of the time required a.
to accomplish sheltering, b.
Instructions for transients are describe under the shelter in place concept included in NHRERP Vol. 1, Section 2.6.5.
The EBS shelter message is included in Vol. 4, NHCDA c.
procedures, Appendix G.
The State may elect to have this or a similar message bre-dcast, in the voice transmission mode, from beach area sirens as well.
Interrogatory No. 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.
Response
The State has conducted no studies of transient shelter capacities.
It has, however, reviewed the estimates provided in "A Study to Identify Potential Shelter in the Beach Areas near Seabrook
' Station" performed for New Hampshire Yankee by Stone & Webster Engineering Corporation in March 1986.
The State believes that the numbers included in that report are reasonable estimates.
Interrogatory No. 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:
where the campers will be instructed to shelter; a.
b.
how they will be instructed to shelter; the instructions that will be given to campers; c.
d.
where in NHRERP, Rev.
2, such provisions-for campgrounds can be found; and whether there are any plans to supplemed:or revise the e.
NHRERP in any manner with respect to provisions for sheltering persons at campgrounds.
. 4
, Response.
The NHRERP, Revision 2, Volume 1, Section 2.6.5 provides that
' persons in campgrounds will be instructed to leave the area in the 2
vehicles in which they arrived in the event any protective actions
-are recommended.
Interrogatory No. 47 Are you familiar with the methodology utilized by M. Kaltman when, in gathering data for what is commonly called the Kaltman report (see refernece 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.
Response
No.
Interrogatory No. 48 s
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.
Response
The State' believes that the best available data on hotel _and motel rooms and campgrounds spaces in the Seabrook EPZ is the set of t
data provided in Volume 6 of the NHRERP.
Interrogatory No. 49 With respect to the Stone & Webster Engineering Corp. study, dated March, 1986, and entitled "A Study to Identify Potential Shelters in the Beach Areas Near Seabrook Sation," please:
i 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, and if only some of the owners were consulted with, state for which shelters j
the owners were, or were not, consulted with; i
I
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d.
state whether the owners of all the potential shelters identifiedin 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.
Response
The study cited was done by the Applicants.
Interrogatory No. 50 At Page 13 of th 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.
Interrogatory No. 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.
Response to Interrogatories 50 and 51
- The State has not determined any particular course of action regarding issues raised in the cited IRT documents.
Interrogatory No. 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 j
sheltering these residents; l
_.g.
- b.
the instructions that will be given to these residents in the event beaches are to be closed and the permanent population is instructed _to shelter; if such persons are instructed to shelter, where they will c.
be instructed to shelter.
Response
a.
Provisions for sheltering residents of unwinterized accomodations at or near the beach are explained in NHRERP, Volume 1, Section 2.6.5.
b.
The instructions to be given to these residents are contained in NHRERP, Volume 4, Appendix'G.
If such persons are advised to shelter, they will be c.
advised to shelter in place.
Interrogatory No. 53 Is it your position that the vast majority 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?
Response
The design of operations for the Decontamination Centers, as described-in NHRERP Volumes 33, 35, 36 and 38 (the Host community plans), and Volume 4A, (DPHS~ Procedures) is based on a FEMA memo from Richard W.
Krimm, Assistant Associate Director, State and Local Programs and Support, to NTH Division Chiefs and FEMA Regional Offices, dated December 24, 1985, providing guidance on "NUREG-0654/ FEMA-REP-1 Evaluation Criterion J.12."
That document states that radiological emergency response plans "...should include provisions at relocation center (s) in the form of trained personnel and equipment to monitor a minimum of 20% of the estimated population to be evacuated."
For additional information, see the State's response to Interrogatory 32, Seacoast Anti-Pollution League's Interrogatories and Requests for Documents to the State of New Hampshire on NHRERP REV 2, dated March 17, 1987.
The public would be advised of the location of reception centers, of directions to them, and of the services available at them.
The State has made no estimate of the fraction of the population that may avail itself of monitoring at the reception center.
It has provided for handling 20% of the population within the EPZ within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pursuant to FEMA guidance.
o e
% Interrogatory No. 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?
Response
See response to Interrogatory 53.
The State has no estimate of the smallest number of persons that might be instructed.
Interrogatory No. 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 centers?
ifave 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.
Response
The State envisions no bottlenecks that would preclude meeting its planning basis of maintaining a capability for monitoring at least 20% of the population in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
No such sensitivity studies have been undertaken by the State.
MOTION FOR PROTECTIVE ORDER Because the State of New Hampshire filed no contentions on the NHRERP and intends to offer no testimony on any contentions that were filed, the State is not obligated to respond to any interrogatories on the NHRERP.
See this Board's Memorandum and Order (March 1, 1983) at 3-4, 7 (Interrogatories which are sponsored by the interrogee and which will not be the subject of direct testimony proffered by the interrogee need not be answered.)
Recognizing, however, that New Hampshire state personnel involved in developing the NHRERP can and will provide valuable input in this proceeding on New Hampshire emergency planning issues, the State has voluntarily responded to this set of idstrogatories and request for product of documents.
The State of New Hampshire, however, moves the Board for a
. protective order that the documents that Attorney General Shannon requests to be produced may be produced at the offices of the New Hampshire Civil Defense Agency in Concord, New Hampshire.
The
& majority of the requested documents are already in the possession of Attorney General Shannon (e.g., NHRERP; RAC Reviews), and the remainder of the documents constitutes a large. number of pages.
To provide copies of the documents by' mail to Attorney General-Shannon would be an undue burden and expense.
Rather, the State of New Hampshire requests that the Board require only that the requested documents be made available for inspection, upon reasonable notice, between the hours of 8:30 a.m. ana 4:00 p.m.,
Monday through Friday, the Civil Defense Agency headquarters, 107 Pleasant Street, at Concord, New Hampshire, 03301.
In addition,.the State of New Hampshire moves the Board for a protective order that, for the reasons given with respect to each interrogatory, the following interrogatories need not be answered further:
Interrogatory ll(i)
Interrogatory 15 2
Interrogatory 23 Interrogatories 34 - 37 Interrogatories 39 - 40 4
4 4
~
m,.,-.
,. O J SIGNATURE
- I, Richard H. Strome that the foregoing answers, are true, exceptbeing first duly sworn, do depose and insofar as they are based on information that is available to the State but not within my personal knowledge, as to which I, based on such information, believe them to be true.
Richard H.
Strome Director, Civil Defense Agency Sworn to before me this 4th day of June, 1987:
Ettgr/.f. h Y Notary,Public
\\(.MyC'ommissihnExpires:[-/[/9
't, c,!
~
As to Objections and Motion for Protectior Order:
e f
duS, @O
/
George Daha Bisbee Senior Assistant Attorney General Environmental Protection Bureau Office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3679 e
-