ML20214T328
| ML20214T328 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/04/1987 |
| From: | Bisbee G, Strome R NEW HAMPSHIRE, STATE OF |
| To: | SEACOAST ANTI-POLLUTION LEAGUE |
| Shared Package | |
| ML20214T239 | List: |
| References | |
| OL, NUDOCS 8706100208 | |
| Download: ML20214T328 (13) | |
Text
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June 4, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Nuclear Regulatory-Commission
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In the Matter of
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Docket Nos. 50-443-OL
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and PUBLIC-SERVICE COMPANY OF
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50-444-OL NEW HAMPSHIRE
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(Off-Site Emergency (Seabrook Station, Units 1 and 2
)
Planning Issues)
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THE STATE OF NEW HAMPSHIRE'S RESPONSES TO SAPL'S. INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE STATE OF NEW HAMPSHIRE NHRERP ANSWERS TO INTERROGATORIES Interrogatory No'.
C For each witness-identified in response to the prior-filed-general interrogatories referenced above, describe the substance of his or her testimony and identify any documents and the portions thereof that he or she'may rely on for basis of testimony.
Response
No witness was identified.
Interrogatory No. D Describe in detail all of the changes to the NHRERP that are being made to Revision 2 and state when the changes to the plans will be submitted to FEMA.
Response
Updating of the 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.
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. 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.
For this reason it is not presently possible to " Describe in detail all of the changes to the NHRERP that are being made to Revision 2..."
It is not now known when the next publication of a NHRERP revision will occur.
Interrogatory No. 57 State the location for each of the 17 New Hampshire municipalities where traffic control devices will be stored.
Also state the locations of Department of Transportation garages near or within the EPZ.
Response
The storage location of traffic control devices required to support the emergency response effort is at the discretion of each of the 17 EPZ communities.
Access Control Point equipment to be distributed by NH Department of Transportation personnel will be stored at DOT garages throughout the department's District 6 operations area.
These facilities include garages of the Highway Maintenance and Turnpike Bureau Maintenance Division located in Durham, Dover, Epping, Newfields, Rye, North Hampton, Kingson and South Kingston.
Interrogatory No. 58 For each of the 17 local communities within the New Hampshire EPZ, state which local liaison is to be the contact for that community from the NHCDA Incident Field Office in Newington, New Hampshire.
Provide the estimated time for each local liasion to travel from home to the IFO.
Response
Personnel assigned Local Liaisond duties are drawn from a list of personnel.
See RERP Vol.
4, Appendix C.
No specific individual is preassigned to a specific community.
Tnese assignments will be made by the IFO Controller.
The assignments are posted on the status board at the IFO as they are made or revised.
The IFO team may be staged at the UNUSUAL EVENT Classification level, and is automatically staged at the ALERT Classification level.
Some members of the IFO team live in or near the EPZ and could be expected to arrive there in a few minutes, others live at a greater distance.
During exercises, full staffing of the IFO was achieved from within 50 - 90 minutes which included re,sponse by team members from Concord to Newington, t
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.. Interrogatory No. 59 State the names and qualifications and training of those individuals who performed the dose reduction effectiveness calculations for special facilities in the EPZ.
Detail the methodology they employed in performing their calculations.
Response
The State did not perform these calculations.
Interrogatory No. 60 Provide an updated accounting of the evacuation assignments to be fulfilled by the 515 buses alleged to be sufficient for an evacuation of the Seabrook EPZ.
For each of the 17 local communities, provide a listing of the total number of buses needed for that community and then detail how that number of buses will be 4
allocated ~within the community.
~ Response Attached is the most recent accounting of the 17 local communities' bus requirements.
Interrogatory No. 61 i
For each of the two transportation staging areas, state how many buses will be staged from each of those locations.
Detail where the buses will go from each of those areas.
Provide copies of the strip maps to be.used to guide buses to the local staging areas.
Response
In Revision 2 of the NHRERP, the Rockingham County State Staging Area provides a total of approximately 231 buses to the local communities of Stratham, Newfields, Exeter, Brentwood, Kingston, Kensington, East Kingston, South Hampton and Newton, and to the Rockingham County Jail.
The OMNE Mall State Staging Area provides a total of approximately 284 buses to the local communities of Seabrook, Hampton Falls, Hampton, North Hampton, Rye, Portsmouth, New Castle and Greenland.
While this distribution provides for an efficient and timely dispatch of vehicles to the local towns, a
certain amount of judgment is allowed in order to adapt specific bus staging locations as a result of plant, meteorological or other i
pertinent factors.
A sample of the strip maps to be used to guide buses to a local staging areas is attached.
A complete set of strip maps is available for inspection at the Civil Defense Agency headquaters in concord, New Hampshire.
ATTACBENT TRANSPORTATION RESOURCE REQUIREMENTS Buses Special Needs Reclining Seat Towns Required Buses Required Coaches Reauired Seabrook 15 2
0 Hampton Falls 8
0 0
Hampton 75 4
2 North Hampton 12 0
0 Rye 14 2
1 Portsmouth 113 20 4
New Castle 4
0 0
Greenland 8
0 0
Strathan 15 1
0 Newfields 7
0 0
Exeter 101 12 6
Brentwood 7
1 0
Kingston 23 0
O Kensington 6
0 0
East Kingston 10 0
0 South Hampton 5
1 0
Newton 16 1
0 Rockingham County Nursing Home 3
11 2
Rockingham County Jail
_3 0
0 TOTALS 445 55 15 t
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Rockingham County Farn (State Staging Area) 6 v
q/f-To Brentwood. Fire Department (Local Staging Area)
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to Right out of County Fars onto North Rd. ~ Left onto Rt. 125 South.
Left onto Old Rt. 125 (Crowley Falls Rd.).
Fire Department is on lefc.
e101 bitate Staging
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Rte 1 5
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W giddle Bd Rte 125 Rte 111 A QLecalStaging Area
- 8. Brentwood Fire Dept
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i Interrogatory No. 62 t
I Has the American Red Cross obtained agreements with mass citre s
s facilities in the host communities?
List the facilities involved and l
their capacity for housing evacuees.
Response
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The American Yed Cross has obtained or is in the process'of i
obtaining Letter's of Agreertent.with mass care facilities which would 1
be utilized under the hc.
community plans.
Letters with the ~
following ma's_ care facilities have been obtained,(with respective s
t evacuee capaciples):
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Salem Goy's Club (Salem) 192 Salvation Army Building (Rocbester)i - lb0
, Interrogatory No.,6_3,3 i
Have '80' CDV-700. Survey Meters beeri provided to each of the hbst communities as' of this tiime?
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Response
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No.
cf Int 4thogatory No. 64
'- Detail the procedure to link Lo, cal 633 Teamsters Union and{ the
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9 State EOC as mentioned in the State',s response to SAPL Interrog'a'cory s
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Response
t The procedure, cdcrently 'in draft form and under review by Union official,s,,descriU end Teamsters Union (s the communications link between the State EO
-Local 633 as follows:
The EOC Resource c Coordinator at' th9 State EOC uses a commercial telephone to cont,act g
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,.the Teamsters Union Hall in Manchester.
"he hall is normally staffed
/ for 16ihours on each business day.
If no one is available at the hall,'the EOC Resource ' Coordinator will contact any one of four
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'g Teamstei officials whose home telephone numbers are at his disposal.
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. Interrogatory No. 65 Did the Portsmouth Naval Shipyard raise any concerns.in providing emergency assistance to the State during a radiological emergency at Seabrook?
Response
The State objects to the interrogatory on the grounds of relevance whether or not at some point in time the Portsmouth Naval Shipyard." raised concerns" about the NHRERP is of no bearing on the issue of the adequacy of the plan as it presently stands.
Without waiving this objection, the State responds as follows:
As a federal facility the Portsmouth Naval Shipyard has a role in the Federal Radiological. Emergency Response Plan.
As a Department of Defense facility its primaty responsibility is to provide support to the-defense effort of this country.
The State knows of no concerns this facility has in fulfilling its responsibilities under the Federal Radiological Emergency Rcsponse Plan.
Intyrrogatory No. 66
~What host care facility plans for special facilities in the EPZ are yet to be obtained?
Response
None.
Interrogatory No. 67 Are identification checks to be done at Access Control Points for.determing whether vehicles will be allowed into the EPZ in the event an evacuation is in progress?
What is the estimated time per vehicle for performance of such an identification check?
Response
Means for controlling access are described in the NHRERP, Vol.
1, Section 2.6.5, under the " Access Control" subheading.
Additional instructions for Access Control are provided in Vol. 4B, Troop A Procedures, Appendix C, Access Control Instructions.
The section describes the role of State Police in restricting entry to the plume exposure EPZ.
It notes that only personnel with proper identification will be allowed entry to the EPZ.
Identification checks will be a simple check of credentials, for emergency responders, and verification of residency (e.g. drivers license) of the public.
Each check should take, on the average, a matter of seconds.
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.. Interrogatory No. 68 What are the public buildings in the beach area in which transients without transportation may take shelter referred to in the -
" Affidavit of William T. Wallace on Sheltering" filed by the Applicants on March 25, 1987?
Has the permission of the building
-owners been obtained?
If yes, by whom?
Response
The NHRERP, Vol. 1, Section 2.6, states, at 2.6-6, that "[I]f necessary, transients without transportation may seek directions to a nearby public building from local emergency workers.
Public buildings may_be set up and opened as shelters for transients, on an ad hoc basis, if any unforeseen demand for shelter arises during an emergency."
Dr. Wallace, in the cited affidavit, was making
^
reference to buildings owned or managed by the municipalities or their governmental agencies, such as schools and municipal buildings.
The decision to place transients who find themselves unable to leave the EPZ in public buildings is a governmental decision, as is the determination of which public buildings will be used for that purpose.
There is no reason, therefore, for the State to secure permission of the buildings owners.
Interrogatory No. 69 Have campgrounds been equipped with tone alert radios as of this time?
Response
No campgrounds have received tone alert radios to date.
Interrogatory No. 70 Provide the names of the 15 Rockingham County Sheriff's deputies and detail to which transportation staging area each is to be assigned.
Response
Five regular sheriff's deputies from Rockingham County are assigned to administrative positions at the two State Transportation Staging Areas (TSA).
There is a supervisor (chief deputy) at the Rockingham County Complex and a staging area manager and assistant at each of the TSAs.
Ten special deputies are assigned to the TSA at the Rockingham County Complex to serve as local transportation coordinators for non-responding towns.
The names of all 108 Rockingham County Sheriff's Department personnel are listed on the New Hampshire Police Standards and Training Commission, a copy of which is available for inspection at the Civil Defense Agency here in Concord, New Hampshire.
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MOTION FOR PROTECTIVE ORD$R 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 interrogatories and request for product of documents.
-The State of New Hampshire, however, moves the Board for a protective order that the documents that SAPL 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 SAPL (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 SAPL 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. and 4:00 p.m.,
Monday through Friday, at the Civil Defense Agency headquarters, 107 Pleasant Street, 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 the interrogatory in question, Interrogatory 65 need not be answered' further.
. - SIGNATURE I, Richard H. Strome, being first duly sworn, do depose and say that the foregoing answers are true, except insofar as they are based on information that is available to the State out not within my personal knowledge, as to which I, based on such information, believe-them to be true, n
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l Richard H. Strome Director, Civil Defense Agency
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'Sworhto!beforemethis 4 t h 'd ay ~ o f.,J u n e, 1987:
LLb Notary Public My.Commiss' ion Expires: 7-/3'-[j2 s
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As to Objections and Motion for Protection Order:
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% W \\4W George Daya Bisbeg j
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Senior Assistant Attorney General Environmental Protection Bureau Office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3679 9
9 SELATED 00NWON00eG4 CERTIFICATE OF SERVICE I, George Dana Bisbee, hereby certify that on this 4th day of June, 1987, I made service of the within State of New Hampshire's Supplemental Rcsponse to New England Coalition on Nuclear Pollution's Third Set of Interrogatories and Request.for the Production of Documents to State of N;w Hampshire On Revision 2 to the New Hampshire Radiological Emergency Response Plan, the State of New Hampshire's Responses to Attorney General Jamcs M. Shannon's Off-Site EP Interrogatories and Request for Production of Documents to the State of New Hampshire, the State of New Hampshire's Responses to Hampton's Interrogatories and Request for Production of Documents to the State of New Hampshire on the New Hampshire Radiological Emergency Response Plan, and the State of New Hampshire's Responses to SAPL's Interrogatories and Request for Production of Documents to the State of New Hampshire NHRERP by mailing copies thereof, postage prepaid, to:
- Administrative Judge Helen Hoyt Administrative Judge Sheldon J.
Chairperson Wolfe, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel 8%
o*d U.S.
Nuclear Regulatory U.S. Nuclear Regulatory 97 Commission Commission a
Washington, DC 20555 Washington, DC 20555 Th
)]
- Administrative Judge Gustave
- Dr. Jerry Harbour A.
Linenberger, Jr.
Atomic Safety and Licensing
'3 Atomic Safety and Licensing Board Panel i
73 Board Panel U.S.
Nuclear Regulatory
$d
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U.S. N.R.C.
Commission Washington, DC 20555 Washington, DC 20555 Philip Ahrens, Esquire
- Thomas G.
Dignan, Jr.,
Esquire Deputy Attorney General R.
K. Gad, III, Esquire Peter J. Brann, Esquire Ropes & Gray Assistant Attorney General-225 Franklin Street Department of the Attorney General
- Boston, MA 02110 State House Station 6 Augusta, ME 04333
- Sherwin E.
Turk, Esquire Deputy Assistant Chief
- Carol S.
Sneider, Esquire Hearing Counsel Assistant Attorney General Office of the Executive Counsel Department of the Attorney General Director One Ashburton Place, 19th Floor U.S. Nuclear Regulatory Commission Boston, MA 02108 Washington, DC 20555 Ms. Diana P. Randall
- Robe rt A.
Backus, Esquire 70 Collins Street Backus, Meyer & Solomon 3874 116 Lowell Street 0
Seabrook, NH P.O. Box 516 Manchester, NH 03105
- Served by Express Mail Service.
2 0 Diane Curran, Esquire
. Harmon & Weiss 20001 S Street, N.W.
Chairperson Suite 430 Board of Selectmen Washington, DC 20009-1125 Town of South Hampton East Kingston, NH 03827 Jane Doughty _
5 Market Street
- Mr. Ed Thomas Portsmouth, NH 03801 FEMA, Region 1 John W. McCormack Post Office Brentwood Board of Selectmen and Court House RFD Dalton Road Post Office Square Brentwood, NH 03833 Boston, MA 02109 Judith H.
Mizner, Esquire Charles P. Graham, Esquire Silverglate, Gertner, Baker, McKay, Murphy and Graham Fine, Good, and Mizner 100 Main Street 88 Broad Street Amesbury, MA 01913 Boston, MA 20110
- Paul McEachern, Esquire J.
P.
Nadeau: Esquire Matthew T. Brock, Esquire Selectmen's Office Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P. O. Box 360 Portsmouth, NH 03801 Mr. Calvin A. Canney City Manager Ms. Roberta C.
Pevear City Hall The Town of Hampton Falls 125 Daniel Street Drinkwater Road Portsmouth, NH' 03801 Hampton Falls, NH 03844 Mr. Angie Machiros Mrs. Sandra Gavutis Chairman of the The Town of Kensington Board of Selectmen RFD 1, Box 1154 (Route 107)
Town of Newbury Kensington, NH 03827 Newbury, MA 01950 Senator Gordon J.
Humphrey Peter J. Matthews U.S.
Senate Mayor Washington, DC 20510 City Hall (Attn:
Tom Burack)
Newburyport, MA 01950 Senator Gordon J.
Humphrey William S.
Lord 1 Eagle Square Board of Selectmen Suite 507 Town Hall Concord, NH 03301 Friend Street Amesbury, MA 01913 O
o
Mr. Thomas Powers Gary P.
Holmes, Esquire Holmes & Ells Town Manager 47 Winnacunnet Road Town of Exeter 10~ Front Street Hampton, NH 03841 Exeter, NH 03833 Richard A. Hampe, Esquire
- H. Joseph Flynn Hampe & McNicholas Assistant General Counsel 35 Pleasant Street Office of General Counsel Concord, NH 03301 Federal Emergency Management Mr. Robert Carrigg, Chairman Agency 500 C Street, S.W.
Board of Selectmen Washington, DC 20472 Town Office Atlantic Avenue North Hampton, NH 03862 59 George Dhna Bisbee
,