ML20214W657
| ML20214W657 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/04/1987 |
| From: | George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | HAMPTON, NH, MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION LEAGUE |
| References | |
| CON-#287-3738 OL, NUDOCS 8706160123 | |
| Download: ML20214W657 (200) | |
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[ June;n
"': y i Dated:
4, 1987 UNITED STATES OF AMERICA
'87 JW111 A9 54 NUCLEAR REGULATORY COMMISSION g.g 00CP!inu t ifavtr.f.
5P:.HGH before the s
ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos.
50-443-OL NEW HAMPSHIRE, et al.
)
50-444-OL
)
(Seabrook Station, Units 1 and 2)
)
(Offsite Emergency Planning-
)
Issues)
)
APPLICANTS' SUPPLEMENTAL RESPONSES TO FIRST SET OF INTERVENOR INTERROGATORIES Pursuant to 10 CFR 52.740(e), Applicants hereby supplement their responses filed March 18, 1987 to the first sets of interrogatories propounded to them by other parties.
This supplementation includes information derived from studies which have been completed since the original answers were filed.
If any in process or future studies reveal information requiring supplementation under 10 CFR $2.740(e),
further supplementation will be made.
8706160123 B70604 PM ADOCK 05000443 L/265CC.1 0
TOWN OF HAMPTON APPLICANTS' INTERROGATORIES 1.
.With respect to each contention and subpart thereof filed by the Town of Hampton and admitted by the Licensing Board's order of February 18, 1987.
Please provide the following information:
a.
What is the Applicant's positioning with respect to each contention and its subparts? Describe in detail the reasons for your posi-tion.
b.
Identify and provide access to all documents and the Data Base on which you rely to support your position on each of these conten-tions. This includes the Data Base used, or to be used, in your answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings.
c.
Identify all persons on whose factual knowledge, opinions or tech-nical expertise you rely for your position on each contention and subpart thereof.
d.
Identify all persons you may call as witnesses on each of these contentions during these proceedingst describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.
RESPONSE
SUPPLEMENTATION:
d.
Pursuant to 10 C.F.R. 92.740 (e). Applicants supplement their answers to Interrogatory 1(d) as follows:
Applicants object to this interrogatory insofar as it calls for the iden-tification of non-expert witnesses. Applicants incorporate-by reference their response to NASS. A.G. Interrogatory 5 (set 2).
Insofar as this interrogatory calls for the identification of expert 1
witnesses. Applicants answer as follows:
1 The Applicant's response is based on their present intention which is subject to change.
L/266LK.1
a.
As regards TOH Revised Contention III, Applicants at this time Intend to offer a panel of expert witnesses which will include Edward B. Lieberman and Dennis S. Mileti. The substance of the i
testimony of the panel at this time as regards TOH Revised Contention III is provided in Applicants' Motion for Summary Disposition on Town of Hampton Contention No. III (March 25, 1987).
b.
As regards TOH Revised Contention No. IV, Applicants at this time intend to offer panels of witnesses which will include:
Richard H. Strome, Anthony M. Callendrello and Paul Frechette. The substance of the testimony of the panels a this time as regards TON Revised Contention IV is provided in Applicants' Motion for Summary Disposition on Town of Hampton Revised Contention IV (March 25, 1987).
c.
As regards TOH Revised Contention VI, Applicants at this time offer panels of expert witnesses which will include: Anthony M.
Callendrello and Paul Frechette. The substance of the testimony of the panels at this time as regards TOH Revised Contention VI is provided in Applicants' Motion for Summary Disposition (TOH VI)
(March 25, 1987),
d.
As regards TOR Revised Contention VIII. Applicants at this time i
intend to offer a panel of witnesses which will include: Richard H. Strome, William T. Wallace, Anthony M. Callendrello, James A.
MacDonald, and Paul Frechette. The substance of the testimony of the panel at this time as regards TOH Revised Contention VII is i
provided in Applicants' Notion for Summary Disposition of NECNP Contention RERP-8. SAPL Contention No. 16 and Town of Hampton Contention VIII (March 25, 1987) i i
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MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 24.
Identify and produce each document, not identified in response to prior interrogatories, that evaluates or discusses the adequacy, reliability, or the sensitivity of KLD's ETE study or any aspect or subpart of this study.
RESPONSE
To the best of Applicants' knowledge, KLD Associates. Inc. has conducted the 9
following sensitivity analyses subsequent to publication of NHRERP. Rev. 2:
1.
Sensitivity analysis of the effects of major road blockages on ETE.
2.
Sensitivity analysis of the effects of non-compliance of evacuees with evacuation route instructions.
3.
Sensitivity analysis of the effects of different levels of spontaneous evacuation on ETE.
4.
Applicants incorporate by reference the response to Interrogatory 82 for production of documents.
SUPPLEMENTATION:
5.
Sensitivity analysis to determine the effect on ETE of sheltering Portsmouth residents who reside outside the 10-mile EPZ region.
6.
Sensitivity analysis which extended the trip generation times by one hour.
7.
Sensitivity studies to determine the effect on ETE of changes in the estimate of highway capacity.
8.
Sensitivity study to determine the effect on ETE of routing eva-cuees from northbound Rt. 85 to westbound Rt. 87 in Newfields.
1 l
L/065LS.24
MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 33.
Do you contend that the estimates of vehicle demand displayed in Figures 2-4, 2-5, and 2-8 of Volume 6 of Revision 2 of NHRERP, based on numbers estimated for the NRC by M. Kaltman in 1981, are reliable?
a.
If you answer in the affirmative, state your reasons and identify any experts, other persons, studies, or other documents upon which your reasons are based.
b.
Identify any other_ experts, persons, studies, or other documents which contain information about vehicle demand which differs in any way from that contained in Figures 2-4, 2-5, and 2-8 of Volume 6 of NHRERP.
RESPONSE
Yes.
a.
See discussion on pages 2-14, and 2-20 of NHRERP Volume 6.
SUPPLEMENTATION:
b.
On-going activities are being undertaken to update data covered throughout the NHRERP, to include Vol. 6, pp. 2-14 thcough 2-27.
See NASS AG Supplementary Interrogatory Number 48.
L/065LS.33
MASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 46.
Do you agree that Basis 8 to SAPL's Revised Contention No. 31 contains an accurate statement of the number of traffic guides needed in New Hampshire for Traffic Control Posts and Access Control Points? If not, state what you contend the accurate numbers are, and identify the source or sources of your information.
RESPONSE
Yes.
SUPPLEMENTATION:
The Traffic Management Manual calls for 120 persons to perform traffic control functions and 26 persons to perform access control functions for a total of 146 personnel.
L/065LS.46
NASS ATTORNEY GENERAL APPLICANTS' INTERROGATORIES (continued) 151.
Please produce all the source materials relied upon to produce Tables 5-1 and 5-2 of Volume 6 and describe the methodology employed and all assump-tions used for projecting 1986 employment data in Table 5-1.
RESPONSE
The technique for projecting 1986 employment data was to take the annual growth rate based on the data provided for 1980 3nd 1984 and extrapolate the 1984 data forward two years. As explained in response to Interrogatory No. 142, source material was usually discarded after the information was transferred to a permanent storage medium.
SUPPLEMENTATION:
Also, refer to Item 15. Appendix E, pager E-11 and E-12.
L/065LS.151
NEW ENGLAND COALITION ON NUCLEAR POLLUTION APPLICANTS' INTERROGATORIES (continued) 8.
Please identify all persons who are responsible for training of emergency response personnel for implementation of Revision 2 to the New Hampshire RERP.
RESPONSE
Personnel involved With Training Agency / Company Adams, Pip - Fireman Manchester Fire Department, Manchester, NH Coogan, Gerald - Consultant Consultant to NHCDA, 107 S. Pleasant St.,
Concord, NH Deans, David - Sr. Field Rep.
NHCDA, 107 S. Pleasant St., Concord, NH Jeffries, Robert - Field Rep.
NHCDA, 107 S. Pleasant St., Concord, NH Morrison, David - Consultant Schneider/EC Planning & Management Patterson, Robert - Consultant Schneider/EC Planning & Management Rizzo, Salvi - Radiological NHCDA, 107 S. Pleasant St., Concord, NH Instrument Technician Thorpe, William - Consultant Schneider/EC Planning & Management Vigliani, Mario - Consultant HMM Associates Von Wald, Katherine - Consultant Schneider/EC Planning & Management SUPPLEMENTATION:
Gifford, John - Field Rep.
NHCDA, 107 S. Pleasant St., Concord, NH Jollimore, Ken -Exercise Controller NHCDA, 107 S. Pleasant St., Concord, NH Poirier, Michael - Radiation NHCDA, 107 S. Pleasant St., Concord, NH Protection Officer L/072LS.8
SEACOAST ANTI POLLUTION LEAGUE APPLICANTS' INTERROGATORIES SAPL GENERAL INTERROGATORY:
A.
For each and every one of the admitted SAPL Contentions (31, 7, 8, 8A, Redrafted 5, 16, 18, 25, 33, 34, 37), provide the following infor-mation:
a.
What witnesses do the Applicants intend to have testify with respect to this contention?
b.
What position does the Applicants intend to take on this conten-tion and what is the basis of this position?
c.
What documents will be used in support of the Applicants position on this contention?
RESPONSE
SUPPLEMENTATION:
Pursuant to 10 C.F.R. 52.740 (e), Applicants supplement their answer to SAPL General Interrogatory A(a) as follows:
Applicants object to this interrogatory insofar as it calls for iden-tification of non-expert witnesses. Applicants incorporate by reference their response to Mass. A.G. Interrogatory 5 (set 2).
Insofar as this interrogatory calls for the identification of expert wit-nesses. Applicante answer as followeit a.
As regards SAPL Revised Contention 31, Applicants this time intend to offer the testimony of a panel of witnesses which will include:
Edward B. Lieberman and Dennis S. Mileti. The substance of testi-many of the panel at this time as regards SAPL Revised Contention 31 is provided in ADDlicants' Notion for Summary Disposition on Seacoast Anti-Pollution League Contention No. 31 (March 25, 1987) b.
As regards SAPL Contention 7, Applicants at this time intend to offer the testimony of a panel of witnesses which will include:
Richard H. Strome William T. Wallace William A. Colburn, Anthony M. Callendrello, James A. MacDonald and Paul Frechette. The substance of the testimony of the panel at this time as regards SAPL Contention 7 is provided in ADDlicants Motion for Summary Disposition on Seacoast Anti-Pollution League Contentions No. 7 and 33 March 25, 1987.
2 The Applicants response is base on their present intention which is subject to change.
L/266LK.3
c.
As regards SAPL Reasserted Contention 8, Applicants at this time intend to offer the testimony of a panel of witnesses which will include: Richard H. Strome, Anthony M. Callendrello and Paul Frechette. The substance of the testimony of the panel at this time as regards SAPL Reasserted Contention 8 is provided in Applicants Notion for Summary Disposition SAPL Reasserted Contention No. 8 March 25, 1987.
d.
As regards SAPL Reasserted Contention 8a, Applicants at this time intend to offer a panel of witnesses which will include: Richard H. Strose, Anthony M. Callendrello and Paul Frechette. The substance of the testimony of the panel at this time as regards SAPL Reasserted Contention 8 is provided in Applicants' Motion for Summary Disposition SAPL Reasserted Contention 8A (March 25, 1987) e.
As regards SAPL Redrafted Contention 15, Applicants at this time intend to offer the testimony of a panel of witnesses which will include: Richard H. Strome Anthony M. Callendrello and Paul Frechette. The Substance of the testimony of the panel at this time as regards SAPL Redrafted Contention 15 is provided in Anolicants' Notion for Suasary Disposition in Seacoast Anti-Pollution League Redrafted Contention No. 15 (March 25, 1987).
f.
As regards SAPL Contention 18 Applicants this time intend to offer a panel of witnesses which will include: Richard H. Strose, i
William T. Wallace, Anthony M. Callendrello, James A. NacDonald i
and Paul Frechette. The substance of the testimony of the panel at this time as regards SAPL Contention 18 is provided in Applicants' Notion for Summary Disposition of NHCNP Contention l
RERP-8. SAPL Contention No. 18 and Town of Hampton Contention VIII l
(March 25, 1987).
g.
As regards SAPL Contention 18, Applicants at this time intend to offer a panel of witnesses which will include: Richard H.
Strome, Anthony M. Callendrello and Paul Frechette.,The substance of the testimony of the panel at this time as regards SAPL t
Contention 18 is provided in Applicants' Motion for Summary l
Disposition of Seacoast Anti-Pollution League Contention No. 18 (March 25, 1987).
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h.
As regards SAPL Contention No. 25 Applicants at this time intend to offer a panel of witnesses which will include: Richard H.
Strome Anthony M. Callendrello and Paul Frechette.
the substance of the testimony of the panel at this time as regards SAPL Contention 25 is provided in Applicants' Motion for Suasary Disposition of Seacoast Anti-Pollution League Contention No. 25 (March 25, 1987),
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1.
As regards SAPL Contention 33, Applicants at this time intend to offer a panel of witnesses which will include: Richard H. Strose, William T. Wallace William A. Colburn, Anthony M. Callendrello, James A. MacDonald and Paul Frechette. The substance of the testimony of the panel at this time as regards SAPL Contention 33 is provided in Applicants' Motion for Summary Disposition on Seacoast Anti-Pollution League Contentions Nos. 7 and 33 (March 25, 1987).
J.
As regards SAPL Contention 34, Applicants at this time intend to offer a panel of witnesses which will include:
Edward E.
Lieberman and Dennis Milet1. The substance of the testimony of the panel at this time is provided in Applicants' Motion for Summary [Dispositioni on Seacoast Anti-Pollution League (Contention No. 34) (March 25, 1987) k.
As regards SAPL Contention 37, Applicants at this time intend to offer a panel of witnesses which will include:
Edward E.
Lieberman and Dennis S. Mileti. The substance of the testimony of the panel at this time as regards SAPL Contention 37 is provided in ADollCants' Motion for Summary Disposition Motion on Seacoast Anti-Pollution League Contention No. 37 (March 25, 1987) 1 b
L/266LK.5
SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued) 21.
Since KLD prepared the evacuation time study at Vol. 6 of the NHRERP, has any other information come to light that would in any manner alter the results and conclusions of the report? If so, specify the nature of the infor-nation and provide any and all relevant documentation.
RESPONSE
To the best of Applicants' knowledge, KLD Associates, Inc. has conducted the following sensitivity analyses subsequent to publication of NHRERP, Rev. 2:
1.
Sensitivity analysis of the effects of major road blockages on ETE.
2.
Sensitivity analysis of the effects of non-compliance of evacuees with evacuation route instructions.
3.
Sensitivity analysis of the effects of different levels of spontaneous evacuation on ETE.
4.
Applicants incorporate by reference the response to Interrogatory #2 for production of documents.
SUPPLEMENTATION:
Refer to Applicants' responses to Mass AG Interrogatory No. 24.
4 L/071LS.21
SEACOAST ANTI-POLLUTION LEAGUE APPLICANTS' INTERROGATORIES (continued) 39.
For each of the 17 local communities within the EPZ in New Hampshire, state the number of individuals necessary to carry out an adequate emergency
' response.
For each of the communities that did not participate in the Feb. 26, 1986 graded FEMA drill, detail where replacement personnel would come from to carry out the emergency response. Provide whatever evidence the State of New Hampshire has to establish that there are sufficient personnel to carry out an emergency response in all of these communities simultaneously.
RESPONSE
NHRERP, Volumes 16-32, Appendix A, identifies the number of persons necessary to carry out an adequate emergency response. NHRERP, Volume 2, Appendix G, delineates those organizations, identified by procedure, that would provide assistance to local communities which are unable to respond fully or at
'all to a radiological emergency. The procedures identified in NHRERP, Volume 2.
Appendix 0, are found in Volumes 4 and 4B of the NHRERP. These procedures establish that there are personnel that will be available to assist local com-munities with an emergency response.
SUPPLEMENTATION:
/
Personnel needs and availabilities are displayed in the personnel resource assessment summary served on the parties April 15, 1987.
L/071LS.39
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i SEACOAST ANTI-POLLUTION LEAGUE r
APPLICANTS' INTERROGATORIES (continued) a
r 50.
Has the State;of New Hampshire yet secured the missing agreements with U-the. host care facilities for,specici facilities in the EPZ?
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RESPONSE
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As to Answers:
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George S. 4homas Vice President, Nuclear Production New Hampshire Yankee Division of Public Service Company of New Hampshire June 4, 1987 State of New Hampshire Rockingham County, es.
Then appeared before me the above subscribed George S. Thomas and made oath that he is the Vice President, Nuclear Production of New Hampshire Yankee Division, authorized to execute the foregoing supple-mental responses to first set of intervenor interrogatories on behalf of the Applicants, that he made inquiry and believes that the fore-going answers accurately set forth such information as is available to the Applicants.
Before me, bdb vua W My Commissi% Expires 3. (,-qo 3/6/90 L/265CC.2 y
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I CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr.,
one of the attorneys for the Applicants herein, hereby certify that on June 4, 1987, I made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):
Administrativ,e Judge Helen Hoyt, Robert Carrigg, Chairman Chairperson, Atomic Safety and Board of Selectmen Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Judge Gustave A. Linenberger Diane Curran, Esquire Atomic Safety and Licensing Andrea C.
Ferster, Esquire Board Panel Harmon & Weiss U.S. Nuclear Regulatory Suite 430 Commission 2001 S Street, N.W.
East West Towers Building Washington, DC 20009 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nucles: Regulatory Assistant Attorney General Commissit a Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bothesda, MD 20814
- Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814
- Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel 116 Lowell Street U.S. Nuclear Regulatory P.O.
Box 516 Commission Manchester, NH 03105 Washington, DC 20555
Philip Ahrens, Esquire Mr.
J.
P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S.
Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey Mr. Angie Machiros U.S.
Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn:
Tom Burack)
Town of Newbury Newbury, MA 01950
- Senator Gordon J. Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F.
Powers, III Mr. William S.
Lord' Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 50C C Street, S.W.
Washington, DC 20472 l
Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 l i
Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region I Silverglate, Gertner, Baker, 442 John W. McCormack Post Fine, Good & Mizner Office and Court House 88 Broad Street Post Office Square Boston, MA 02110 Boston, MA 02109 Charles P. Graham, Esquire McKay, Murphy and Graham 100 Main Street Amesbury, MA 01913
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Thomas G.
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(*= Ordinary U.S. First Class Mail.)
Dated:
June 4, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
)
50-444-OL
)
Off-site Emergency (Seabrook' Station, Units 1 and 2) )
Planning Issues
)
)
APPLICANTS' RESPONSE TO INTERROGATORIES RE:
NHRERP REV. 2
' PROPOUNDED TO THEM BY OTHER PARTIES (SET 2)
I f
TOWN OF HAMPTON INTERROGATORIES TO THE APPLICANTS S-1 Please identify, describe and fully answer all interrogatories pre-vlously served by the TOWN OF HAMPTON upon the Applicant as if fully set forth and requested herein. Please note the errata as referenced in TOWN OF HAMPTON CORRECTIONS TO TOWN OF HAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANT ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS.
RESPONSE
Applicants object to identifying and describing TOH's interrogatories.
Those interrogatories were fully answered when answered. Applicants object to setting forth those answers again. See " Applicants' Supplemental Answers to First Set of Intervenor Interrogatories" filed herewith.
L/256CC.1
TOWN OF HAMPTON INTERROGATORIES TO THE APPLICANTS S-2 With respect to the PERSONNEL RESOURCE ASSESSMENT
SUMMARY
, April 1987, previously filed by Applicant with the Licensing Board, please identify all persons, including persons employed by or having knowledge of the Town of Hampton, referenced at page 2-2 which provides "survuys were conducted with per-sons knowledgeable about the specific Town to verify and adjust the numbers of required and available personnel resources." With respect to each such person so identified, please state the dates of any such surveys, discussions, correspondence, or any communications whatsoever, the persons conducting or involved in each such surveys or communication, the subject matter of each, the information obtained therefrom, and whether this information is relied upon or incorporated into the personnel resource assessment summary, April, 1987.
RESPONSE
Meetings with respect to the surveys were conducted with Town of Hampton personnel to determine the number of persons available to perform emergency response functions. Meetings held with town officials were:
L/256CC.2
RESPONSE
(continued)
Date Place Topic Interviewer Contact 11/19/86 Hampton Town Resource Survey Judy Rainey Phil Richards Hall (Consultant)
(Town Manager /CD Director) 12/10/86 Hampton Town Resource Survey Judy Rainey Phil Richards Hall (Consultant)
(Town Manager /CD Director)
Tony Kuncho (Fire Chief)
Bob Mark (Police Chief) 12/17/86 Hampton Resource / Planning Dave Deans Bob Mark (Police Chief)
Police Dept.
Meeting NHCDA Dave Pelletier (Hampton Keith Ashley Police Department)
(Consultant) Dave Kalway (NH State Police) 3/26/87 Public Works Resource Verifi-Ed Hartnett John Hangan (Public Department cation (Consultant) Works Director) 5/6/87 Hampton Resource Meeting Dave Deans Bob Mark (Hampton Police Folice Dept.
Personnel Utili-(NHCDA)
Chief) zation George Sgt. Barnard (Hampton Willant Police Department)
(Consultant)
D. Pellitier (Hampton Police Department)
Information obtained pertaining to personnel a railabilities was relied upon in the development of, and contained in, the personrel resource assessment summary in addition to available documentation.
L/2500c.2.1 l
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TOWN OF HAMPTON INTERROGATORIES TO THE APPLICANTS
.S-3 With reference to the personnel resource assessment summary, April -
1 1987, identify and describe what steps were taken "to insure that each plan reflected all of the required planning responsibilities," what steps were taken "to identify all of the tasks required to be performed in fulfilling the con-templated emergency response functions," and what steps were taken "to identify
. personnel resources available to fill the emergency response positions for each municipality identified in the procedural walk throughs."
In responding to this question, please identify and describe all documents relied upon-in support of the personnel resource assessment summary and in support of this answer.
RESPONSE
i-As stated in the personnel resource assessment summary (Page 2-1, 2), "The first step in this process was to ensure that each plan reflected all of the required planning responsibi1~ities. This was done by a review of each plan and its-associated procedures against present federal guidance and against other RERPs that make up the entire offsite response effort for Seabrook Station."
Furthermore, "[b]uild'ing upon the review of each plar., a walk-through of each
[
implementing procedure was then conducted to identify, by position and functional responsibility, all of the tasks required to be performed in fulfilling the
' contemplated emergency response functions. This process led to the determination of specific numbers of personnel required to implement each plan and the identi-j_
fication of those positionc requiring staffing for 24-hour operations. The L
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RESPONSE
Town of Hampton/S-3/ Continued resulting identified personnel needs are displayed in the form of emergency-response organization charts for each of the six towns currently not par-ticipating in emergency planning efforts. An Organization Chart for each-town is included within the respective town section of this report." Steps taken to identify personnel resources available to fill the emergency response positions included analysis of available documentation and the surveying of persons knowledgeable about the specific town as outlined in the personnel resource assessment summary at 2-2.
Documents relied upon are listed in tables provided at the end of each town, county or state summary and have been previously pro-vided through the discovery. process.
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L/256CC.3.1
TOWN OF HAMPTON INTERROGATORIES TO THE APPLICANTS S-4 With respect to the Town of Hampton, please identify and describe each document reviewed, considered, or relied upon, to support the personnel resour-ces contained in the personnel resource assessment summary.
RESPONSE
Plesse refer to supporting documentation as listed in the personnel resource assessment summary and that has been previously available through the discovery process.
L/256CC.4 1
TOWN OF HAMPTON INTERROGATORIES TO THE APPLICANTS S-5 Please identify and describe all documents supporting your calcula-tions regarding the dose reduction effectiveness of certain institutions in the Seabrook EPZ, as described in Volume 4, Appendix F of the NHRERP.
RESPONSE
The documents supporting calculations regarding dose reduction effectiveness of institutions as described,,in NHRERP, Volume 4, Appendix F are identified in Table 2.6-3 of NHRERP, Volume 1, Section 2.6.
These documents are " Structure Shielding from Cloud and Fallout Gamma Ray Sources for Assessing the Consequences of Reactor Accidents" EG&G Inc., Las Vegas, Nevada, which provides guidance on external shielding factors of various construction materials, and "Public Pro-tection Strategies in the Event of a Nuclear Reactor Accident...Multicompart-mental Ventilation Model for Shelters." SAND-77-1555, which provides guidance on inhalation sheltering factors as a function of air exchange rates.
L/256CC.5 i
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TOWN OF HAMPTON INTERROGATORIES TO THE APPLICANTS S-6 Please identify and describe the basis for your belief that the
' Teamsters Union will provide the drivers referenced in its letter agreement with the Applicant. Please state how many of such Teamsters you have contacted, directly or indirectly, the dates thereof, and the information obtained. State whether any survey, vote of the Teamsters, or other verification was undertaken to confirm the letter agreement, and the results thereof. Please identify and' describe all documents upon which you rely in support of your answer.
RESPONSE
The basis relied on for the belief that the Teamster's Union will provide drivers is the Letter of Agreement with Teamster's Local No. 633 contained in NHRERP, Volume 5.
Applicants have not contacted any individual Teamsters.
Applicants have no knowledge of any survey or vote of the Teamsters or other verification to confirm the letter of agreement L/256CC.6
TOWN OF HAMPTON INTERROGATORIES TO THE APPLICANTS S-7 With reference to Anthony M. Callendrello's Affidavit submitted in support of Applicants' Motion for Summary Disposition on Town of Hampton VI, identify and describe:
a.
"The information available during the preparation of Revision 2" upon which Mr. Callendrello relies to compute the full time, spe-cial, or part time police officers for the Town of Hampton, and any additional information presently relied upon for these computations.
b.
How Mr. Callendrello computed that up to 70 persons are required for Town of Hampton Emergency Response Organization.
c.
By name and employment position, the 127 persons available to Town of Hampton to serve in an emergency response capacity, and the specific capacity for each.
d.
How Mr. Callendrello determined that Town of Hampton will provide 2 police personnel to support traffic control functions in an emergency. Describe any conversations, correspondence, or com-munications with Town of Hampton officials, directly or indirectly, concerning this issue, the dates, parties involved, and substance'of each.
e.
How Mr. Callendrello computed that 6 Town of Hampton police could be made available by the Town for municipal security, f.
All conversations, correspondence, communications, or surveys, referenced at paragraph 15 of Mr. Callendrello's Affidavit, including those, directly or indirectly, with Town of Hampton officials, the dates thereof and substance of same, i
L/256CC.7
RESPONSE
a.
The figures presented for the Town of Hampton Police Department resources as depicted in Rev. 2 are based upon an open dialogue with the Town prior to its withdrawal from the planning process.
Information provided in the personnel resource assessment summary is based on information gathered during the interviews described in the response to interrogatory S-2 and from available documen-
- tation, b.
As stated in the personnel resource assessment summary "... a walk-through of each implementing procedure was then conducted to identify, by position and functional responsibility, all of the tasks required to be performed in fulfilling the contemplated emergency response functions. This process led to the deter-mination of specific numbers of personnel required to implement each plan..."
(summary at 2-1) c.
Objection. The level of detail requested is beyond that required by NUREG-0654 or other pertinent regulations, d.
Numbers of police personnel that could be made available during an emergency response if the Town were participating in emergency planning efforts resulted from meetings held with local personnel.
See also response to interrogatory S-2.
e.
See response to (d) above, f.
See response to Town of Hampton Interrogatory S-2.
L/256CC.7.1
1 l
TOWN OF HAMPTON INTERROGATORIES TO THE APPLICANTS S-8 Identify and produce for inspection and copying at the offices of Shaines & McEachern, P.A., 25 Maplewood Avenue Portsmouth, New Hampshire 03801 all documents upon which you rely to support your answers to interrogatories S-1 to S-7.
RESPONSE
1 Applicants object to producing documents at the offices of Shaines and McEachern for the reasons set forth in Applicants' notion for protective order filed herewith. Those documents which have not already been served on the parties price to issuance of Town of Hampton's supplemental interrogatories or specifically included in response to an interrogatory will be made available for inspection and copying at the Seabrook Station. Please contact Mr. William J. Daley at (603) 474-9521, extension 2057, to arrange for document inspection.
9 L/256CC.8
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 conten-tions.
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 infor-mation concerns.
RESPONSE
Documents which Applicants may choose to use to support their position and which have not been previously identified and produced are:
a.
The three aerial photographs of Hampton Beach taken on July 4, 1983 (see response to Supplementary Interrogatory 21).
These photographs may be used to support Applicants' position on contentions related to beach population density. Specifically these contentions include:
Town of Hampton III, Basis A SAPL-31, Basis Item 20 (11/26/86)
SAPL-34 b.
As part of the normal planning process, a number of Letters of Agreement have been added and deleted. These may in the aggregate be used by Applicants to support their position on all conten-tions.
The above documents are available for inspection and copying at the Seabrook Station. Please contact Mr. William J. Daley at (603)474-9521, Extension 2057 to arrange for document inspection.
L/255CC.2
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 and identify any documents that discuss or describe the study, calcu-lation or analysis; b.
Identify the persons who performed the study, calculation or analysis; c.
State when and where the study, calculation or analysis was per-formed; 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
Documents in the form of studies, calculations, or analyses which the Applicant-at this time intends to rely on to support its position on contentions l
I have been identified and made available to the parties.
In addition, there are a number of other activities which may be reported in the form of a study, l
l l
survey or analysis which are, or will be, in progress and which Applicants may, upon completion, decide to use to support its position on the contention.
These include:
r l
L/253CC.3 I
RESPONSE
(continued) o
" Windshield Survey" - the purpose of this survey is to assess the residential land use characteristics of the beach areas.
o A revision and/or supplementation to the report entitled "A Study to Identify Potential Shelters In The Beach Areas Near Seabrook Station" (Performed for New Hampshire Yankee, prepared by Stone &
Webster Engineering Corporation, March 1986),
o Continued work on the ongoing personnel resource assessment program.
0-Additional ETE sensitivity analysis identifed in response to Mass AG Supplemental Interrogatory $24.
L/253CC.3.1
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 specific 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 publi-cation, and, if so, identify the book or publication.
l L/253CC.4 l
l
RESPONSE
LApplicants object insofar as this interrogatory requires information beyond the scope of 10 CFR $2.740(e).
In' accord with 10 CFR 92.740(e),' Applicants answer as follows 1 a.
As regards TOH Revised Contention III, Applicants at this time intend to offer a panel of expert witnesses which will include:
Edward B. Lieberman and Dennis S. Mileti. The substance of the testimony of.the panel at this time as regards TOH Revised Contention III is provided_in Applicants' Motion for Summary Disposition on Town of Hampton Contention No. III (March 25, 1987).
b.
As regards TOH Revised Contention VI, Applicants at this time intend to offer panels of expert witnesses which will include:
Richard H. Strome, Anthony M. Callendrello and Paul Frechette.
The substance of the testimony of the panels at this time as regards TOH Revised Contention VI is provided in Applicants' Motion for Summary DisDosition (TOH VI) (March 25, 1987).
c.
As regards TOH Revised Contention VIII, Applicants at this time intend to offer a panel of witnesses which will include:
Richard H. Strome, William T. Wallace, Anthony M. Callendrello, James A. MacDonald and Paul Frechette. The substance of the testimony of the panel at this time as regards TOH Revised Contention VIII is provided in Applicants' Motion for Summary Disposition of NECNP Contention RERP-8 SAPL' Contention No. 16 and Town of Hampton Contention VIII (March 25, 1987).
d.
As regards NECNP Contention RERP-8 see answer 4(c) above.
+
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The Applicants' response is based on its present intention which is subject to change.
'f L/253CC.4.1
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RESPONSE
(continued) e.
As.regards SAPL Revised Contention 31, Applicants at this time intend to offer the testimony of a panel of witnesses which will include: Edward B. Lieberman and Dennis S. Mileti. The substance of the testimony of the panel at this time as regards SAPL Revised Contention 31 is provided in ADDllCants' Motion for Summary Disposition on Seacoast Anti-Pollution League Contention No. 31 (March 25, 1987).
4 i
f.
As regards SAPL Reasserted Contention 8, Applicants at this time intend to offer.the testimony of a panel of witnesses which will include: Richard-H. Strome, Anthony M. Callendrello and Paul J
Frechette. The substance of the testimony of the panel at this time as regards SAPL Reasserted Contention 8 is provided in Applicants' Motion for Summary Disposition SAPL Reasserted j -
Contention No. 8 (March 25, 1987).
1 g.
As regards SAPL Reasserted Contention 8a, Applicants at this time i
intend to offer a panel of witnesses which will include:
Richard H. Strome, Anthony M. Callendrello and Paul Frechette. The
-substance of the testimony of the panel at this time as regards SAPL Reasserted Contention 8a is-provided in ADDllCants' Notion for Summary Disposition on SAPL Reasserted Contention 8A (March' 25, 1987).
h.
As regards SAPL Contention 16, see answer 4(c) above.
i 1.
As regards SAPL Contention 33, Applicants at this time intend to offer a panel of witnesses which will include: Richard H. Strome,-
William T. Wallace, William A. Colburn, Anthony M. Callendrello, i
James A. MacDonald and Paul Frechette. The substance'of the testimony of the panel at this time as regards SAPL Contention 33 is provided in Applicants' Motion for Summary Disposition on Seacoast Anti-Pollution League Contentions Nos. 7 and 31 (March 25, 1987).
- j. As regards'SAPL Contention 34, Applicants at this time intend to offer a panel of witnesses which will include:
Edward B.
Lieberman and Dennis S. Mileti. The substance of the testimony of the panel at this time is provided in Applicants' Motion for Summary IDispositionl on Seacoast Anti-Pollution League (Contention No. 34) (March 25, 1987).
i.
I Professional qualifications of the above-named persons are attached.
i L/253CC.4.2
CURRICULUM VI'TAE - 1987 L
.NAME:
William T. Wallace, Jr.,
M.D., M.P.H. NH License *5537 I
ADDRESS:
RFD 2, Box 270, Contoocook, NH 03229 TEL. NO.
(603) 746-3831 NATIONALITY:
United States Citizen
.DATE OF. BIRTH:
May 17, 1935 MARITAL STATUS: Married with three children, ages 20, 23, 26 EDUCATION:
Qualification Date School High School 1953 Littleton High School Littleton, NH A.B.
1957 Boston Univ. College of Liberal Arts Boston, MA M.D.
1961 Univ. of Vermont College of Medicine Burlington, VT D.T.M. & H.
1965 London Univ.
School of Tropical Medicine London England M.P.H.
1969 Johns Hopkins Univ.
School of Public Health and Hygiene Baltimore, MD EXPERIENCE Internship 1961-1962 Methodist Hospital of Indiana Indianapolis, IN Military 1962-1964 U.S.P.H.S. Div. of Indian Health Hastings Hospital Tehlequah, OK Missionary Medicine 1965-1968 General Medicine &
Public Health Ganta United Methodist Hosp.
Ganta, Liberia L/270LK.1 1
Missionary Medicine 1969-1972 Medical Director Ganta United i
Methodist, Hosp.
Ganta, Liberia Public Health 1969-1972.
. County Public Health.
Officer - Ministry of Health, Republic of p
Liberia 1972-1973 Centers for Disease Control Atlanta, GA (informal study) 1973-1976 (seconded to)
Ministry of Health &
Social Welfare Monrovia, Liberia Position: Director of Medical Services July 1976-Director Bureau January 1978 of Crippled Children's Services Div. of Public Health I
Concord, NH January 1978-Deputy Health Officer February 1981-Div.* of Public Health Services-Dept. of Health and Welfare-Concord, NH
~
February 1981-Acting Director July 1981-Div. of Public Health Services-Dept. of Health and Welfare Concord NH August 1981-Director of Public Present Health Services Dept. of Health &
Welfare Concord, NH 1
L/270LK.2
PROFESSIONAL ASSOCIATIONS:
American College of Preventive Medicine - 1973 Election as Fellow American Public Health Association Liberian Medical Association NH Medical Society National Council for International Health New England Public Health Association - Officer OTHER ASSOCIATIONS: - 1984 Board of Directors-NH Lung Association Manchester, NH Board of Directors-Concord Regional Visiting Nurse As.
Concord, NH Professional Adivsory Easter Seals, Rehabilitation' Center Committee Manchester, NH Governor's Commission New Hampshire for the Handicapped Acid Rain Coordinating New Hampshire Committee ACADEMIC APPOINTMENTS Adjunct Associate Professor Health Administration and Planning School of Health Studies University of New Hampshire Adjunct Professor Community & Family Medicine Dartmouth Medical School L/270LK.3
SHORT BIOGRAPHY RICHARD H. STROME CURRENT:
Director of the New Hampshire Civil Defense Agency since January, 1983 PAST:
Senior Administrative Assistant to the President of the New Hampshire Senate in charge of operations.
Science Advisor to the New Hampshire Senate.
Retired Military Officer (USAF) with broad experience while on active duty in command responsibilities, research and development, aircraft and missile operations, as well as maintenance staff functions. Member of Disaster Practice Evaluation team at Pease Air Force Base and graduate =of the Air Force Nuclear, Biological, and Chemical Hazard School.
EDUCATION:
Bachelor of Science, Cum Laude, U.N.H. with majors in che-mistry and biological sciences. Graduate studies in phy-siology, anatomy, histology, as well as graduate studies in industrial management.
PUBLICATIONS:
Classified operations manuals and.research plans.
AWARDS & CITATIONS: Distinguished Flying Cross, Meritorious Service Medal, Air Medal (7), etc.
SECURITY:
Top Secret, cryptographic.
AVOCATIONS:
Fish and wildlife management.
l L/270LK.4
'}>
il Resume of Work Experience and Educational Background William N. Colburn 200 Boyce-Road Canterbury, NH 03224--
5 Work Experience P
.6/22/84-present Coordinator of Emergency,Sarvices New Hampshire Division of Human Services (DHS) 3
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I Department of Health and Human Services (DHHS) s Develop / maintain plans for several emergency services functions ass'igned to the DHHS; train volunteer staff to carry out spedific tasks related-to these services; m'anage staff during' exercises and implementation of these programs.
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5/12/75-6/22/84 Staff Development /Trair.ing Spec' alist I
i New Hampshire Division of Human' Services /QHHS,s
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programs \\ Tor agency staff.
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the Stpte public assistance' programs.
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NOTE: Other work experience includes:
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y Vocational Rehabilitation Counselor
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William N. Colburn Page 2 Educational Backaround Northeastern University Graduated 6/58 Boston, Massachusetts School of Liberal Arts (Sociology major; 5
Psychology minor)
Northeastern University Graduate School of Education Boston,~ Massachusetts 12 Sem. Hours - 1958-1959 Boston University Graduate School of Education Boston, Maat chusetts 9 Sem. Hours - 1960-1963 University of.New Hampshire
" Individual Testing" 4 Sem. Hours - 1962-1963 Durham, New Hampshire ilortheastern University Graduate School of Education soston, Massachusetts
" Group Development" - 3 Sem. Hours - 1964-1965 Special Seminars:
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" Individual / Family Grant Workshops" - 1984 and 1987 National Emergency Training Center Emmitsbury, Maryland NOTE: Numerous other work-related seminars and courses not listed here.
C/8K1617.1
DETAILED EXPERIENCE RECORD CALLENDRELLO. ANTUONY M.
NEW RAMPSHfRE YANKEE DfVISf0N.
PUBLIC SERVICE OF NEW HAMPSNIRE (Jan. 1984 - Present)
Appointments:
Emergency Planning Manager - 1986 Emergency Preparedness Supervisor - September 1985 Senior Emergency Planner - January 1984 Mr. Callendrello is currently supervising the offsite emergency prepared-ness efforts for Seabrook Station. He has direct responsibility for the direction of Massachusetts, New Hampshire and Maine state and local planning and training.
Prior, he was responsible for the development of onsite emergency response procedures and prompt
- notification system procurement and installation ind scenario preparation.
STONE & WEBSTER ENGTNEERING CORPORATTON. NEW YORK. VY (Apr. 1980 to Dec. 1983)
Shorehas Nuclear Power Station. Lone Island Limhtina Comoany (Mar.
1983 to Dec. 1983)
Mr. Callendrello supervised a group of planners providing technical support for offsite radiological emergency planning.
Principally this involved the i
preparation of an energency response plan and implementing procedures for j
the first utility implemented offsite plan developed in the country.
His
. responsibilities also include the support of the ASLB licensing hearings through the preparation of discovery responses and written testimony Oyster Creek Nuclear Generating Station. General Public Utilities (Oct. 1980 to Jur.s 1983)
Mr. Callendrello supervised the development of Radiological Emergency Plans.
(REPS) for the county and municipalities within the Emergency Planning Zone of the Oyster Creek Nuclear Generating Station. This involved the following principal efforts: the preparation of individual REPS for the county and twenty municipalities: the preparation of implementing and stan-dard operating procedures; the preparation of the scenario for the FEMA witnessed exercise: the training of offsite emergency response personnel in the specifics of radiological duties: and the direct support of FEMA exer-i cise activities through the provision of field radiological data and field l
team referees / evaluators.
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AMC This planning process involved extensive interviews and meetings with various officials of the State county, and municipalities. utility manage-ment and site operating personnel, the FEMA regional representative. and local news meota.
4 James A. Fit 2 Patrick Nuclear Power Plant. Power Authertty of the State of New York (Mar. 1982 to July 1982)
Mr. Callendrello supervised the onsite radiological energency planning effort for the J.A. Fitzpatrick Nuclear Power Plant. This effort involves
.the modification of the emergency plan. implementing procedures. and Emergency Action Levels (EALs) in accordance with the latest Federal guidance. The preparation of these documents was in support of the 1982 NRC/ FEMA graded exercise and the NRC appraisal.
t Indian Point Nuclear Power Station - Unit 3. Power Authority of the Statt of New York (Jan. 1982 to Mar. 1982)
Mr. Callendrallo supervised the support of offsite radiologicel emergency response planning for the four counties within the Emergency Planning Zone of Indian Point Unit O.
This support involved the training of county exe-cutives and agency heads in their role in a radiological emergency response, and the training of personnel responsible for decontaminatica center operation, dose assessment, field monitoring, reception center operations, and emergency operations center activation and operations.
In addition. support material for this effort was prepared including ae
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emergency worker's training manual-: standard operating procedures'for field monitoring and dose assessment personnel: and materials and suggested layouts for emergency operations centers.
Finally, he supervised the support of the successful 1982 FEMA witnessed exercise.
This included the preparation of the offsite scenario: the prv-vision of observers / evaluators at offsite locations; and the collection, evaluation, and provision of evaluator critique comments.
Sales Generatina Station. Public Service Electric and Gas Comorny (Aug. 1980 to May 1981)
Mr. Ca11endrello' directed the development of Radiological Emergency Plans (REPS) for the State of New Jersey and the counties and municipalities in the Emergency Planning Zone of the Salen Generating Station.
This work included the preparation of REPS for the State, two counties, and six munt-cipalities; the development of implementing and standard operating proce-dures: the development of training materials; and support in the staging of the 1982 FEMA observed exercise.
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AMC Wo. H. Zimmer Nuclear Power Station. Cincinnati Gas and Electric Comoany (May 1960 to Aug. 1980)
Mr. Callendrello was responsible for the coordination and technical review of efforts to. design an integrated prompt public warning system for the area near the Zinest Station to support radiological emergency plar.ning.
During this period. he participated in the preparation of evacuation time estimates for the area near the Zimmer Station in response to NRC require-He has assisted in the preparation of the Radiological' Emergency ments.
Plans for the Commonwealth or Ktatucky and the counties within the Emergency Planning zone. Also, he has assisted in the preparation of writ-ten testimony for the Atomic Safety Licensing Board licensing hearings.
CONLEY. MILLER & NOWIKAS. INCORPORATED (1976 to 1980)
He was responsible for industrial and environmental noise control projects.
Industrial projects rtquired compliance with OSHA noise standards for many industries including power generating stations, papermaking. food pro-cessing, and metal fabricating.
Environmental projects dealt with the control of noise from large rotating equipment in order to comply with State and local codes.
LEWIS S. G000 FRIEND & ASSOCIATES (1973 to 1976)
Mr. Callendrello directed projects involving industrial noise control and the prediction, assessment, and control of environmental noise.
Typical in-plant equipment analyzed including fans pumps crushing and mixing mills, and power station equipment.
Environmental projects on which he worked dealt with a variety of power station equipment, highways, and com-i I
munity annoyance studies.
In particular, he assessed the environmental icpact of the noise from four 1000 MW nuclear generaticg plants on a single site for the New York State Atomic and Space Development Authority.
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JAMES A. MacDONALD RADIOLOGICAL ASSESSMENT MANAGER Mr. MacDonald received his Associate in Nuclear Engineering from Wentworth Institute in 1965, his Bachelor of Science in Nuclear Engineering from Lowell Technological Institute in 1968, and his Master of Science in Radiological Health from Harvard University in 1970.
In the summer of 1969 he completed tne Health Physics Training Program sponsored by Brookhaven National Laboratory and the USAEC.
While completing the last three years of his undergraduate studies, Mr.
MacDonald worked for Sanders Nuclear Corporation in Nashua, New Hampshire as an Engineering Assistant.
His time was devoted to performing analytical design of various systems employing radioisotopes as heat sources.
This work included the feasibility evaluation of the application of radioisotopes for these systems and devices Oy analytically designing and optimizing fuel capsules, energy conversion systems, and shielding.
In addition, Mr. MacDonald worked on establishing and implementing a facility radiation safety program. This included work on the design and licensing of a remote-handling hot cell and a radiochemistry laboratory.
Mr. MacDonald joined Yankee-Westboro in May of 1970 as an engineer within the Radiation Protection Section.
In this capacity, Mr. MacDonald assisted in obtaining plant operating licenses in the areas of radioactivity source term analysis and dose evaluations, environmental radiological monitoring, emergency planning, and in-plant radiation protection programs.
In September of 1972, Mr. MacDonald transferred to the Safety Analysis Section where he worked in the source term and dose evaluation areas. These evaluations were performed for radioactivity releases associated with normal plant operation and for releases associated with accident conditions.
In October of 1973, Mr. MacDonald was appointed to the position of Manager of the Radiation Protection Group.
In this capacity, Mr. MacDonald directed the l
activities of the group which include both licensing assistance in the radiation i
protection area for plants under design and construction and operational health j
physics assistaqce for operating plants.
l-Mr. MacDonald joined Public Service Company of New Hampshire in August of 1983 as Radiological Assessment Manager with the responsibility for implementation of the Seabrook Station Radiological Emergency Plan, i
Mr. MacDonald is a national and New England chapter member of the Health Physics Society and is certified in the field of health physics by the American Board of Health Physics.
-e e
PAUL R. FRECHETTE, JR.
29601: Green Bay Rd.
Lake Bluff, IL 60044 Telephone: Home (312) 295-7120 Business (312) 940-2084 EDUCATION University of New Hampshire Graduate courses in Biology - 1975 8.A. Biology University of New Hampshire PROFESSIONAL EXPERIENCE 03/1980 - Present EDS NUCLEAR /IMPELL CORPORATION OT/1985 - Present Supervisor, Emergency Planning, Mid-West Region.
Project Manager for the offsite Emergency Planning Programs at seven nuclear facilities in Illinois.
i Supervisor of a twenty-three (23) person planning team contracted by Commonwealth Edison for LaSalle, Braidwood,
- Dresden, Zion, Byron and Quad Cities to develop the Illinois Plan for Radiological Accidents (IPRA); as well 3
as, contracted by Illinois Power Company for development of the IPRA plan for the Clinton Power Station.
Responsi-bilities include overseeing all normal day to day activities of the planning team members, budget and schedule management, interface with upper level management on marketing prospects and contractual commitments.
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07/1984 - 01/1985 Project Engineer, Clinton Power Station, offsite emergency plan, procedure and training development.
l Manager of a six (6) person Planning Team contracted to develop the Illinois plan for Radiological' Accidents (IPRA) for the Clinton site.
This project includes development of Standard Operating Procedures.
Offsite l
Agency Training Programs, drills and exercise programs, and offsite scenario development.
Responsibilities in-l cluded budget and schedule management.
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2 02/1984 - 07/1984 Project Engineer, F'ermi II - Detrolt Edison, ensite health physics support Provided consultant services to Detroit Edison Corporate Health Physics Department in preparation for Fermex 84 (Annual Exercise).
Responsibilities included scenario development, training, review and update of plans and pro-cedures.
05/1983 - 02/1984 Project Engineer for all offsite Emergency Preparedness Activities at the Dresden and LaSalle Nuclear Power Stations.
Prepared scenarios for all participating State, County and Municipal agencies in conjunction with the Utili ty scenario.
Provided pre-exercise -training to State, County and Municipal agencies in preparation for the FEMA annual emergency preparedness exercise.
Prepared Controller /
Evaluator instructions, and trained controllers..Respon-sible as lead controller for coordinating all offsite response activities.
Responsible for current annual update of the State of Illinois Emergency Plans for the Dresden and LaSalle Nuclear Power Stations.
02/1983 - 05/1983 Lead Senior Engineer for the Byron Nuclear Power Station offsite emergency planning effort.
Developed Standard Operating Procedures for Traffic and Access Control and Evacuation of General Population.
Provided training to all offsite agencies in the areas of notification, traffic and access control and evacuation.
Developed all
- State, County and Municipal scenarios, scenario messages, free play items and controller messages for the initial annual Emergency Preparedness Exercise.
l Developed exercise notebooks and provided training to all controller / evaluators involved in the exercise.
Developed testimony for presentation at the ASLB hearings relative to licensing issues for the Byron Station.
l 09//1982 - 02/1983 Onsite Emergency Planning Engineer - Georgia Power.
Revised Station EPIP's in response to both an internal
(
Q.A. audit and N.R.C. appraisal open items from tha ore-l vious annual exercise.
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3 Provided training to all control room operators, and internal and external survey teams with regards to the recent procedure revisions.
Lead controller for all offsite monitoring activities dur-ing the 1982 N.R.C. appraisal.
04/1982 - 09/1982 Project Engineer for the Station of Florida Radiological Emergency Management Plan for Nuclear Power Plants revisions project.
Responsible for the complete revision of the State and County plans for the Turkey Point, Crystal River, St.
Lucie and Farley Nuclear Stations.
This work was in response to NUREG-0654, and FEMA comments arising from exercises conducted at these plants.
01/1982 - 04/1982 Senior Engineer for the Florida Power and Light Emergency Preparedness Project.
Developed offsite monitoring offsite field teams.
procedures and trained Assisted in the development of offsite dose calculation procedures and training; schematics for the classification of emergencies based on radiological parameters, and the associated Protective Action Recommendations.
Developed several radiological scenarios involving plant specific parameters and new THI required instrumentation to be used in preparation for the annual exercise.
06/1981 - 01/1982 Principal Engineer for the Baltimore Gas and Electric Training Project.
Assisted in the development of lesson plan's, and visual aids used to train Health Physics, Radiation, and Chem-istry Technicians.
02/1981 - 06/1981 Provided onsite assistance to Georgia Power to accomplish system seismic analysis.
(79-14) 03/1980 - 02/1981 Principal Engineer on Equipment Qualifications Projects.
(79-01B)
Responsible for calculation of doses to equipment from re-circulating fluids after a LOCA.
Use of QAD-P5A and ORIGEN programs to perform integrated exposure calcula-tions for seven stations.
Provided training in all regional offices with regards to the application and use of computer codes in the calcula-tion of integrated exposure to equipment.
1 4
09/1978 - 03/1980 Saint Thomas Aquinas High School Dover, New Hampshireg i
Instructor of college preparatory courses in Biology, Chemistry and Introductory Physics.
Responsible for development of new curriculum.
Basketball coach.
09/1977 - 09/1978 Stone and Webster Engineering Corporation Boston, Massachusetts Assisted in the design of plant radiation shielding and maintaining occupational radiation exposure ALARA.
Pro-i vide assistance in marketing engineering services with regards to mini-computer applications in the areas of effluent dose assessment, health physics exposure manage-
- ment, and waste management.
Traveled with PDP-11/03 system to demonstrate capabilities in these areas.
01/1975 - 09/1977 CIS Radiopharmaceuticals Incorporated Bedford, Massachusetts Production Manager responsible for production of diag-nostic radioisotopes, scheduling of employees and evaluation of employee performance.
Promoted to Research and Development Department.
Respon-sible for developing and refining radioimmune assay test-ing techniques.
08/1967 - 01/1971 United States Navy Completed Polaris Electronics "A" School (26 weeks), and Missile Technician "C" School (37 weeks).
Served as a Missile Technician on board a Nuclear Submarine.
Respon-sibilities included:
Operations, testing and repair of missile guidance computer systems, and related environ-mental systems.
REGISTRATIONS State of New Hampshire certification to instruct Secondary Sciences.
1 S
\\
PROFESSIONAL QUALIFICATIONS EDWARD B.
LIEBERMAN Vics President KLD ASSOCIATES, INC.
My name is Edward B.
Lieberman and my business address is KLD Associates, Inc..,
300 Broadway, Huntington Station, New York 11745.
I am presently Vice President of KLD Associates, Inc.
I received the Bachelor of Science degree in Civil Engineering in 1951 from Polytechnic Institute of Brooklyn.
I was awarded the Master of Science degree in Civil Engineering in 1954 from Columbia University and in Aeronautical Engineering in 1967 from Polytechnic Institute of Brooklyn.
I am currently working on a Doctorate degree in Transportation Planning at the Polytechnic University.
I am a member of the Chi Epsilon Honorary Fraternity.
With almost 30 years of professional experience, I have managed a number of major projects.
I pioneered the l
development and application of traffic simulation models, making major state-of-the-art innovations in the traffic engineering profession.
I have also been responsible for many engineering studies involving data collection and analysis and design of traffic control, systems to expedite traffic flow and relieve congestion.
l I have developed simulation models to study traffic performance on urban networks, freeways, freeway corridors
and two-lane, two-way rural roads.
These programs include consideration of pedestrians, interaction with vehicular traffic, truck and bus operations, special turning lanes, and vehicle fuel consumption and emissions; both pratimed and actuated traffic signal controls are represented.
I was the Principal Investigator for the development of traffic signal control strategies for congested conditions in mid-Manhattan.
These strategies were implemented and evaluated in the field.
Field tests indicated substantial reductions in. delay combined with increased vehicle throughput.
I was the Principal Investigator in the development of an interactive computer graphics (ICG) software system for displaying traffic simulation results generated by the NETSIM model.
I designed the overall structure of the software for implementation on PC AT computers and, subsequently, on larger ICG work stations.
This work was sponsored by FHWA.
l I was responsible to a large extent for the theoretical development of DYNEV, a Dynamic Network Evacuation model.
The DYNEV model consists of two major components:
an equilibrium traffic assignment model and a macroscopic dynamic traffic simulation model designed for all types of roadway facilities (urban streets, freeways, rural roads).
DYNEV is designed to be used as a tool to develop and organized evacuation plans needed as part of general 2-j h-c-
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disaster preparedness planning.
DYNEV was used to analyze an existing evacuation scenario at the con Edison Indian Point Nuclear Power Station and is currently being used to develop an extensive evacuation plan for the LILCO Shoreham Nuclear Power Station on Long Island, New York.
In developing this evacuation plan for the Seabrook t
Nucl'ar Power Station, my activities include definition of e
evacuation scenarios, definition of the evacuation network, development of traffic control treatments and of traffic routing patterns, analysis of trip tables, analysis of simulation results, optimization of evacuation strategies and the preparation of formal documentation.
I was responsible for the development of the I-DYNEV model, an interactive. version and. enhancement of the DYNEV model, under contract with the Federal Emergency Management Agency (FEMA).
I-DYNEV, in turn, was integrated into the Integrated Emergency Management Information System (IEMIS),
developed by FEMA.
I-DYNEV was applied to estimate the evacuation times for the Emergency Planning Zones (EPZ) for eight nuclear power stations.
I developed course material and conducted training for emergency planning personnel at the National Emergency Training Center (NECTC) in Emmittsburgh, Maryland.
I was also responsible for the designs of the NESIM microscopic urban traffic simulation model (formerly UTCS-1) and of the SCOT freeway traffic simulation model.
The
NETSIM microscopic traffic simulation model developed for the Federal Highway Administration, enables agencies to evaluate traffic operations in urban environments.
The SCOT model was developed for the Transportation Systems Center of the Department of Transportation.
This program includes a dynamic traffic assignment algorithm which routes traffic over a network in response to changing traffic flow characteristics to satisfy a specified origin-destination table.
In addition, I have developed advanced traffic control policies for urban traffic for the FHWA-sponsored UTSC Project, as well as a bus preemption policy to enhance the performance of mass transit operations within urban environs.-
I designed and programmed the advanced " Third' generation" area-wide, cycle-free control policies for moderate and congested traffic flow for computer-monitored real-time systems.
I also developed a cycle-based, off-line computational procedure named SIGOP-II, to optimize traffic signal timind patterna to minimize system "disutility."
I led a group of traffic engineers and systems analysts in developing a system of macroscopic traffic simulation models designed to evaluate Transportation Systems Management (TSM) strategies.
This software system, named TRAFLO, also includes an equilibrium traffic assignment model.
This model has been distributed to other agencies including FEMA..
e
-I designed an " Integrated Traffic Simulation System,"
named TRAF, which will eventually incorporate all the best traffic simulation models available.
Using structured programming techniques, TRAF integrates:
NETSIM, TRAFLO, and ROADSIM, a microscopic rural-road simulation model.
I served as Principal Investigator on NCERP Project 3-20 entitled, " Traffic Signal Warrants."
This project involved both field data collection and the application of the NETSIM model to study intersection delay as a function of traffic volume, a type of control and geometrics.
In turn, I developed and documented new signal warrants, some of which will be incorporated in the next version of ths Manual on Uniform Traffic Control Devices (MUTCD).
Under NHTSA sponsorship, I directed a research. study to evaluate a Driver Vehicle Evaluation Model named DTRVEM.
1 This model simulates the response of motorists to hazardous events.
This effort included analysis of the model formulation and software and sensitivity testing.
A i
i workship was designed, organized, scheduled and conducted by myself and other KLD professionals; experts from all over I
the U.S. were invited to recommend specific NHTSA research activities for the further development of the model.
A recommended research program constituted the major output of
.the contract.
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Over the years I have been involved in a number of other studies to evaluate traffic operations on large-scale road networks, using one or more of the models described above.
Prior to 1960 I applied my skills to the areas of stress analysis, vibrations, fluid dynamics and numerical analysis of differential equations.
These analyses were programmed for the IBM 7090 and System 360, CDC 6600 and 7600, G.E. 625 and UNIVAC IIOB digital computers in assembly languate, FORTRAN and PLI.
I also designed the logic and real-time programming for a sonar simulator built for the Department of Navy and monitored by a PDP-8 progess-control digital computer.
I am a member of the American Society of Civil Engineers, the Institute of Transportation Engineers, the Association of Computing Machinery and the Transportation Research Board (TRB).
I am also a member of the Traffic Flow Theory and Characteristics Committee of the TRB.
I am 4
a licensed Professional Engineer in New York, Maryland, and Florida.
The following list comprises selected publications of my j
studies and findings:
"DYNET - A Dynamic Network Simulation of Urban Traffic' Flow," Proceedings, Third Annual Simulation Symposium, 1970.
( - - - -
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" Simulation of Traffic Flow at Signalized Intersections:
the SURF System," Proceedings, 1970 Summer Computer Simulation Conference, 1970.
" Dynamic Analysis of Freeway Corridor Traffic," SME paper, Trans. 70-42.
" Simulation of Corridor Traffic:
The SCOT Model," " Highway Research Record No. 409, 1972.
" Logical Design and Demonstration of UTCS-1 Network Simulation Model,"
Highway Research Record No. 409, 1972 with R. D. Worrall and J. M.
Bruggerman).
" Variable Cycle Signal Timing Program:
Volumes 1-4," Final Report of Contract DOT-FH-11-7924, June, 1974.
" Traffic Signal Warrants," KLD TR-51, Final Report on NCHRP Project 3-20/1, December 1976 (with G. F. King and R.
Goldblatt).
" Rapid Signal Transition Algorithm," Transportation Research Record No. 509 1974 (with D. Wicks).
"Subnetwork Structuring and Interfacing for UTCS Project-Program of Simulation Studies," KLD TR-5, January, 1972.
" Development of a Bus Signal Preemption Policy and a System Analysis of Bus operations," KLD TR-11, April, 1973.
"SIGOP-II - Program to Calculate Optimal, Cycle-Based Traffic Signal Timing Patters, Volumes 1 and 2,"
Final Report, Contract DOT-FH-11-7924, KLD TR-29 and TR-30, December, 1974.
Summary report inTransportation Research Record 596, 1976 (with J.
Woo).
" Developing a Predictor for Highly Responsive System-Based Contro,"
Transportation Research Record 596, 1976 (with W. McShane and R. Goldblatt).
"A New Approach for Specifying Delay-Based Traffic Signal Warrants,"
Transportation Research Special Report 153 - Better Use ofExisting Transportation Facilities, 1976.
" Network Flow Simulation for Urban Traffic Control Systems," Vols.
1-5, PB230-760, PB230-761, PB230-762, PB230-763, PB230-764, 1974 (with R.
Worrall), Vols. 2-4 updated 1977, KLD TR-60, TR-61, TR-62 (with D. Wicks and J. Woo).
" Extension of the UTCS-1 Traffic Simulation Program to Incorporate Computation of Vehicular Fuel Consumption and Emissions," KLD TR-63, 1976 (with N. Rosenfield).
" Analysis and Comparison of the UTCS Second-and Third-Generation Predictor Models," KLD TR-35, 1975.
" Urban Traffic Control System (UTCS)
Third Generation Control (3-GC) Policy,"
Vol. 1, 1976 (with A.
Liff).
" Design of TRAFIC Operating System (TCG), KLD TR-57, 1977.
" Revisions to the UTCS-1 Traffic Simulation Model to Enhance Operational Efficiency," KLD TR-59, 1977 (with A.
Wu).
"The Role of Capacity in Computer Traffic Control," in Research Directions in Computer Control of Urban Traffic Systems, ASCE, 1979.
" Traffic Simulation:
Past, Present and Potential," in Hamburger, W.S.
and
- Steinman, L.,
eds., Proceedings of the International Symposium of Traffic Control Systems, University of California, Berkeley, 1979.
"TRAFLO:
A New Tool to Evaluate Transportation System Management Strategies," presented at the 59th nw-ww-----,e--,r.,7wym.,_
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Annual Meeting of the Transportation Research Board, 1980 (with B. Andrews).
" Determination of the Lateral Deployment of Traffic on an Approach to an Intersection," presented at the 59th Annual Meeting of the Transportation Research Board, 1980.
" Service Rates of Mixed Traffic on the Left-Most Lane of an Approach,"
presented at the 59th Annual Meeting of the Transportation Research Board, 1980 (with W. R. McShane).
" Development of a TRANSYT-Based Traffic Simulation Model," presented at the 59th Annual Meeting of the T*ansportation Research Board, 1980 (with M. Yedlin).
-" Hybrid Macroscopic-Microscopic Traffic Simulation Model," presented at the 59th Annual Meeting of the Transportation Research Board, 1980 (with M. C.
Davila).
"A Model for Calculating Safe Passing Distance on Two Lane Rural Road,"
presented at the 60th Annual Meeting of the Transportation Research Board, 1981.
"The TRAF System - Anayltic Formulation and Logical Design of the Roadsim Model," KLD TR-129, June, 1983.
l "PREDYN User's Guide," KLD TR-131, June, 1983.
"The TRAF System - Technical Report,"
KLD TR-136, August, 1983 (with M.
Yedlin, B. Andrew and K. Sheridan).
" Application of the I-DYNEV System to Compute Estimates of Evacuation Travel Time at Nuclear Power Stations -- Four Demonstration Case Studies," KLD TR-142, December, 1983.
" Users Manual for the Interactive Dynamic Network Evacuation Model:
I-DYNEV,"KLD TR-144, February, 1984.
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" Formulations of the DYNEV and I-DYNEV Traffic Simulation Models Used in EESF,"
KLD TR-154, March, 1984.
"PREDYN/IDYNEV Training Guide," KLD TR-155, April, 1984 (with R. Goldblatt).
" Specifications of Recommended Interactive Graphics Hardware' Configuration and Graphics Support Software for the Netsim Graphics Display Package," KLD TM-93, July, 1985.
" Metering of High-Density Sectors Comparison of Traffic Operations Along Fifth Avenue in Mid-Manhattan:
Metering control vs. Existing Control," KLD TM-94, July, 1985.
" Description of an Integrated Traffic Assignment and Distribution Model (TRAD) for the IDYNEV System," KLD TR-187, April, 1986.
" Evacuation Plan Update (Robert G. Ginna Nuclear Power Station)," KLD TR-189, May, 1986 (with R. Coldblatt).
" Evacuation Plan Update (Davis Besse),"
KLD TR-190, July, 1986 (with R.
Goldblatt).
"Seabrook Station Evacuation Time Estimates and Traffic Management Plan Update," KLD TR-174, August, 1986.
" Reducing Traffic Congestion at Herald Square," ITE Journal, September, 1986, pp. 27-31 (with A. K. Rathi).
" Congestion Based Traffic Control Scheme for High Traffic ~ Density Sectors,"
Transportation Research Record No. 1057, TRS, National Research Council,
' Washington, D.C.,
1986, pp. 49-57 (with A. K. Rathi and G.
F. King).
" Overview of the Evacuation Plan and of the Evacuation Time Estimtaes for the Seabrook Nuclear Power Station," KLD 1
TM-98, October, 1986.
" Overview of the Evacuation Plan and of the Evacuation Time Estimates of the Ginna Nuclear Power Station," KLD TM-99, November, 1986 (with R. Goldblatt).
" Overview of the coastal Region within the Pilgrim Station Emergency Planning Zone," KLD TM-100, November, 1986.
" Enhanced Freflo Program:
Simulation of Congested Environments," paper submitted for presentation at Transportation Research Board's 66th Annual Meeting, January, 1987 (with A. K. Rathi and M.
Yedlin).
"The Netsim Graphics System," paper submitted for presentation at Transportation Research Board's 66th Annual Meeting, January, 1987 (with B.
Andrews and A. Santiago).
l" l
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11 -
i 1
PROFESSIONAL QU ALIFICATIONS DENNIS 5. MILET!
Professor Department of Sociology and Director -
Hazardous Aan====mt Laboratory t
COLORADO STATE UNIVERSITY I
My name is Dennis 5. Mileti and my business address is Department of Sociology.
Colorado State University Fort Collins, Colorado 80523. I am presently a tenured Pro-fessor of Sociology at Colorado State University. From 1978 to 1985 I was a tenured As-sociate Professor specializing in those. areas of study dealing with complex organiza-tions, hazards, policy and methods.
I also serve as Director of the Hazards Assessment Laboratory at Colorado State University, which was organized in 1984. The laboratory is an interdisciplinary setting 1
l In which geological, climatological and technological hazards and emergencies are ad-dressed in terms of rists or hazard mitigation and management, preparedness, and emer-l 1
l gency response.
I Prior to these appointments from 1974 to 1978. I held the position of Assistant Professor. I was alsa tn Instructor for one year in the Department of Sociology at the University of Colorado, Boulder, from 1971 to 1972. I have taught numerous undergrad-uate courses, including Introduction to Sociology. Complex Organizations. Sociology of Disasters, Research Methods. Demographic Processes, and Social Change. In addition. I have taught courses at the graduate level such as Advanced Quantitative Analysis. Re-search Methods I and !!. Demography and Population and Complex Organizations.
l
Dennis S. Mileti Page 2 I received my Sachelor of Arts degree in Sociology in 1966 from the University l
of California. I.os Angeles. In 1971 ! was awarded a Master of Arts degree in Sociology from California State University. I.os Angeles. ! completed my doctorate degree in So-clology in 1974 at the University of Colorado, Boulder.
In 1975 I was appointed Visiting Assistant Professor at the University of Southern
)'
California Graduate School of Public Administration. During this year I offered an in-tensive Seminar Pttgram sponsored by the University. From 1978 to 1979 I was an In-vited Instructor for the Chautauqua Short Course Program sponsored by the American i
Associadon for the Advancement of Science. In 1981 I was appointed Policy Analyst for the Seismic Safety Commission by the State of California. During the year I served on this appointment I was on leave from my university duties.
1 I am a member of the American Sociological Associationt the International Sociological Association, the Pacific Sociological Association, the Midwest Sociological Society, the Earthquake Engineering Research Institute, and the American Association for the Advancement of Science, and the U.S. Civil Defense Council. In addition I have been a member of several committees since 1976, including:
COMMITTEE MEMBERSHIPS 1984-date National Academy of Science. National Research C'ouncil, Commission on Engineering and Technical Systems, Commit-tee on Natural Disasters.
1984-date National Academy of Sciences. National Research Council.
Commission on Physical Sciences. Mathematics, and Re-sources. Board on Earth Sciences, Subcommittee on Earth-quake Research.
1985-1986 National Academy of Sciences National Institute of Medi-eine. Committee on the Effects of Nuclear War.
i l
Dennis S. Milett Page 3 1984-date National Institute of Mental Health. Public Health Service.
Center for Mental Health Studies of Emergencies Advisory.
1983-year National Science Foundation. U.S. Delegate on Earthquake Prediction Research to Japan. International Scientific Ex-change Section.
1983-date Frent Range Consortium on Natural Hazards Studies. Col-orado State University of Colorado. University of Denver.
1983-date International Sociological Association. Research Committee on Disasters.
1982-1983 Pacific Sociological Association. Nominations Committee for the Standing Committees for 1983.
1982-date Earthquake Engineering Research Institute. Chair Commit-tee on Social Science Research, Berkeley.
1981-1983 U.S. Department of the Interior. Geological Survey Advisory Panel on the Earthquake Studies Program.
1981-1982 Pacific Sociological Association. Program Committee for the 1982 Annual Meetings in San Diego.
1981-1982 Governors Eme' e. y Tasic Force on Earthquakes. Threat and Reconstrue.r Committees. State of California. Sacra-mento.
1980-1981 Governors Science and Technology Advisory Council. Com-mittee on the Relocation of Uranium Mill Tailings. State of Colorado.
1979 year American Association for the Advancement of Science.
Committee on Intergovernmental Research and Develop-ment on Fire Safety and Disaster Preparedness. Washington, D.C.
1976-1978 National Academy of Sciences. National Research Council.
Commission on Sociatechnical Systems. Committee on Earthquake Prediction. Washington, D.C.
A PPOINTMENTS 1974'date Faculty. Depattment of Sociology Colorado State Universt-ty. Fort Collins (1985-date. Professor: L978-L985. Associate Professor: 1974-L978. Assistant Professor).
9 in,mm.
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Osnnis S. Milsti Page 4
('
1984-date Director Hazards Assessment, Colorado State University, Fort Collins.
1981-year Polley Analyst, Seismic Safety Commission, State of California, Sacramento (on leave from university).
1978-1979 Invited Instructor, American Association for the Advance-ment of Science, Chautauqua Short Course Program.
1975 year V! siting Assistant Professor, University of Southern California, GradLate School of Putnic Administration, Inten-sive Seminar Program.
1971-1972 Instructor, Department of Sociology, University of Colorado, Boulder.
AWARDS 1983-1984 Alumni Honor Faculty Award, Colorado State University Alumni Association for excellence in teaching, research and service 1981 year Cited in Outstanding Young Men of America 1978-1977 Cited for excellence in teaching, research and service by the Dean, College of Arts, Humanities and Social Sciences MEMBERSHIPS American Sociological Association, International Sociological Association.
Pacific Sociological Association Midwest Sociological Society, American Associ-ation for the Advancement of Science, Earthquake Engineering Research Insti-tute, Western Social Science Association, National Coordinating Council on Emergency Management Sigma XI.
RESEARCH GRANTS AND CONTRACTS 1985-1987 Co principal Investigator, " State of the Art Assessment:
Public Warning Systems," Subcontract from Oak Ridge Na-tional Laboratory for the Federal Emergency Management Agency.
1984-1985 PrincipalInvas:Igator," Assessment of Human Stress Impacts from the Livingston Train Derail;nent and Chemical Emer-gency." contract for !!!!ncis Central Culf Railroad.
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Dannis S. Milet1 Page 5 1984-date Associate Investigator, " State-of-the-Art Assessment: Evac-uation," subcontract from Oak Ridge National Laboratory for the Federal Emergency Management Agency.
1984-date Associate Investigator, " International Study of Disaster Im-pact on Domestic Assets," subcontract from the University of Georgia for the National Science Foundation.
1983-1984 Principal Investigator, " Intended and Forgotten Audiences for Emergency Warnings," quick-response grant from the Natural Hazards Research Applications and Information Center.
1982-1983 Associate Investigator, " Organizational Interface for Nucle-ar Reactor Emergency Preparedness," subcontract from Oak Ridge National Laboratories for the Nuclear Regulatory Commission.
1981 year Principal Investigator, " Nuclear Hazard Warnings and Emer-
' gency Evacuation Preparedness," contract for Pacific Gas and Electric Company.
1980-1983 Principal Investigator. " Local Land Use Policy Decisions."
Colcrado State University Experiment Station.
1979-1982 Principal Investigator, " Behavioral Aspects of the Three Mile Island incident and Re-start " contract for General Pub-
!!c Utilities via Shaw, Pittman, Potts and Trowbridge.
1977-1980 PrincipalInvestigator " Migration impacts of Non-Metropolitan Areas in the West," Colorado State Uni-l versity Experiment Station.
1977-1979 Principal Investigator, " Adoption and Organizational Imple-mentation of Policy for Land Use Regulations " grant from the National Science Foundation.
1975-1977 Co principal Investigator. Socioeconomic, Organizational and Politican Consequences of Earthquake Prediction." grant from the National Science Foundation.
1974 Research Sociologist. " Assessment of Research on Natural Hazards." grant from the National Science Foundation.
PUBLICATIONS [1985 and 1986 Updates aie apoended to this listing]
Books and Monograohs (refereed) e
Dennis S. Mileti Page 6 Mileti. Dennis S.
The Order of Chaos in Disasters (in progress).
Mileti Dennis S., John Schneider and D. Stanley Eltzen Graduate Research Methods in the Social Sciences (in progress)
Gillespie David F., and Dennis S. Mileti 1979 Technostructures and interorranizational Relations.
Lexington, Mas-sachusetts: Lexington Books.
Gillespie David F., Dennis S. Milett and Ronald Perry 1978 Orranizational Resoonse to Chanrint Community Systems Kent Ohio: Kent State University Press.
Chanters (invited and refereed)
Mileti, Dennis S.
1986 "Research methods and disaster research." In Russell T. Dynes and Carlo Polanda (Eds.). Sociolory of Disasters: Contributions of Sociotory to Disaster Research. Italy: Franco Angelo (forthcoming).
Mileti, Dennis S., and John H. Sorensen 1985 "Why people take precautions against natural hazards." In Neil Weinstein (Ed.). Encourarint Self-Sehavior (forthcoming).
Sorensen, John H. and Dennis S. Mileti 1985 " Protective actions for natural hazards: a review of programs to stimulate public adoption." In Neil Weinstein (Ed.). Encourarine Self-Protection Behavior (forthcoming).
Martsough, Donald M., and Dennis S. Mlleti 1985 "The Media in Disasters." Pp. 282-294 in J. Laube and S. Murphy (Eds.).
Persoectives in Disaster Recovery. Norwalk, Connecticut:
Appleton-Century-Crofts.
Mutton, Janice, Dennis S. Mileti and John Sorensen 1984 " Factors affecting earthquake warning system effectiveness." Pp. 947-956 in K Oshida (Ed ) Earthouake Prediction Tokyo: Terra Scientific Publishers for UNESCO.
Milett. Dennis S., Janice Hutton and John Sorensen 1984 " Social factors affecting the response of groups to earthquake prediction."
Pp. 649-658 in K. Oshida (Ed.). Earthouake Paediction. Tokyo: Terra Sc entific Publishers for UNESCO.
Sorensen, John. Janice Hutton and Dennis :. Mileti 1984 " Institutional management of risk information following earthquake predte-tions." Pp. 913-924 in K. Oshida (Ed.). Earthouake Prediction. Tokyo: Terra Scientific Puh!!shers for UNESCO.
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Dennis'S. Milett Page 7 Hutton, Janice, John Sorensen and Dennis S. Mileti 1981 " Earthquake prediction and public reaction." Pp. 129-166 in T. Rikitake (Ed.). Current Research in Earthauake Prediction. Boston: Reidel Publishing Tokyo: Center for Academic Puolications.
Milett, Dennis S.
l 1981 " Planning initiatives for seismic hazard mitigation." Pp. 44-53 in J. Isenberg l
(Ed.). Social and Economic imoact of Earthauakes on Utility Lifelines. New York: American Society of Civil Engineers.
Monorraohs and Chanters (quasi-refereed)
Milett, Dennis S., and Joanne Nigg 1988 " Social science earthquake investigations." In Roger Scholl (Ed.). L_gggLng
- f. earned from Recent Earthquakes. Berkeley: Earthquake Engineering Reseach Institute.
Review Panel of the National Earthquake Hazards Reduction Plan 1984 National Earth-cuake Hazards Reduction Prorram: Five Year Prorram Plan. Washington, D.C.:
Federal Emergency Management Agency.
Sorensen, J., E. Copenhaver, D. Milett and M. Adler 1984 Orranizational Interface in Reactor Emergencyll_annint_ and Resoonse.
Washington, D.C.: U.S. Nuclear Regulatory Commission, NUREG No. CR-3524.
Milett, Dennis S.
1982 "A bibliography for graduate research methods.
Pp. 249-255 in Russel Schutt, Alan Orenstein and Theodore C.
Wagenaar (Eds.). Research Methods Courses:
Syllabi. Assignments and Projects.
Washington, D.C.:
American Sociological Association.
Milett, Dennis S., Janice Hutton and John Sorensen 1981 Earthauake Prediction Response and Ootions for Public Policy. Boulder:
Institute of Behavioral Science, Monograph 28.
Santopolo, Frank, and Dennis S. Mileti 1980 imoacts of Poculation Growth in Articultural Colorado Committees. Fort Collins: Colorado State University Experiment Station Bulletin.
Committee on Fire Safety and Disaster Preparedness 1979 Fire Safety and Disaster Precaredness. Washington, D.C.: American Asso-clation for the Advancement of Science.
Committee on Socioeconomic Effects of Earthquake Prediction 1978 A Program of Studies on the Socioeconomte Effects of Earthauake Pracic-tion. Washington, D.C: National Academy of Sciences-National Research Ccun-cil.
i 1
Dennis S. Mllett Page 8 Mileti, Dennis. D., Thomas E. Drabek and J. Eugene Haas 1973 Human Systems in Extreme Environments:
A Sociotorical Perspective.
Boulder: Institute of Behavioral Science, Monograph 21.
Mlleti, Dennis S.
1975 Natural Hazard Warning Systems in the United States. Boulder: Institute of Behavioral Science, Monograph 12.
Portions reprinted in Joseph Perry and Meredith Pugh, Collective Behavior: Ramaanse to Stress.1978.
i Erickson, Neil, John Sorensen and Dennis S. Mileti 1975 Lar*Ma Hamds in the United States: A Research A55mmmment. Boulder:
Institute of Behavtotal Science.
Mileti, Dennis S.
1973 Di~ter Relief and Reh=Miltation in the United States. Boulder: Institute of Behavioral Science.
Ayre, Robert Dennis S. Milett and Patricia Trainer 1975 Earthouake and Tsunami Hamds in the United States: A Research A*=5-glgg. Soulder: Institute of Behavioral Science.
Journal Articles: Discioline Focus (refereed)
Milett, Dennis S., and David F. Gillespie i,
1985 "The effects of legitimacy on goal change and formalization in organiza-tions," Journal of Contemocrary Socioloey 22 (1,2):33-33.
Mileti, Dennis S.
4 1985 "The human equation in earthquake prediction and warning," Policy Studies Egydgw 4 (4):725-733.
Mileti, Dennis S., Donald Hartsough, Patti Madson and Rick Hufnaget 1984 "The Three Mlle Island incident: a study of behavtoral indicators of human stress. Mass Emerrencies and DI=ters 2(1):89-114.
Mileti, Dennis S.
l 1983 " Societal comparisons of organizational response to earthquake prediction:
Japan vs the United States." Mass Emergencies and Disasters 1(3):399-414.
Gillespie. David F., and Denni.s S. Mileti 1982 " Differentiation in organizations," Social Forces 60(4):1172-1175.
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}
1982 " Structure and process in the implementation of public policy, Politiest Science Review 21(1):1-34.
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Dennis S. Milett Page 9 Milett, Dennis S.
1982 "A review of research on pubile poucy adoption " Public Administration Re-view (accepted and forthcoming).
Milett. Dennis 5., Doug Timmer and David F. Gillespie 1982 " Intra and interorganizational determinants of decentralization," Pacific Sociolocical Review 2S(2):163-183.
Mileti, Dennis 5., David F. Gillespie and Stan Eltzen 1981 "The multidimensionality of organizational size." Sociolory and Social Re-ggage 65(4):400-414.
Gillespie, David F., and Dennis S. Mileti 1981 " Heterogeneous samples in organizational research," Sociolorical Methods and Research 9(3):327-388.
M11sti Dennis S.
1980 " Human adjustment to the risk of environmental extremes." Sociotory and Social Research 64(3):327-347.
Gillespie David F., and Dennis S. Mileti 1980 " Determinants of planning in organizations," Administrative Science Re-yjgw 10(3):21-32.
Mlleti, Dennis 5., and David F. Gillespie 1980 " Organizational and technological interdependencies." Journal of Contem-oorarv Sociolorv L7(3-4):132-158.
Gillespie, David F., Ronald Perry and Dennis S. Milet1 1980 " Stress and transformation." Journal of Social Research 21(2):139-147.
Milett, Dennis S., David F. Gillespie and Stan Eitzen 1979 " Structure and decision making in corporate organizations," Sociotory and Social Research 63(4):723-744.
Gillespie, David F., and Dennis S. Milett 1979 " action and contingency postulates in organization-environment relations."
l Human Relations 32(3):261-271.
Milett. Dennis 5., David F. Gillespie and Elizabeth Morrissey L978 " Technology and organizations: methodological deficiences and lucunae."
l Technotory and Culture 19(1):83-92.
i Gillesple. David F., and Dennis S. Mileti l
1978 " Organizational technology and environment adaptation-manipula tion."
i Scottish Journal of Sociology 2(2):21.5-219.
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Dennis S. Milett Page 10 Mileti, Dennis 5., David F. Gillespie and J. Eugene Haas 1977 " Size and structure in complex organizations." Social Forces 56(1):208-217.
Gillespie. David F., and Dennis S. Mileti 1977 " Technology and the study of organizations: an overview and appraisal."
Academy of Manarement Review 2(1):6-19. Reprinted in Readines on How Man-amers Manate. Englewood C11f ts, New Jersey: Prentice Hall.1982.
Mileti, Dennis 5., and David F. Gillespia 1974 "An integrated formallaation or organization-environment interdependencies," Human Relations 29(1):80-100.
Gillespie, David F., and Dennis 5. Mllet1 1974 " Organizational adaptations to changing cultural contingencies,"
l Sociolonical inauiry 46(2):135-141.
Gillespie David F., Roy 1.otz, Dennis S. Mileti and Ronal Perry 1978 " Historical and paradigmatic differences in the use of the goal concept "
International Review of History and Political Science 8(30):1-14.
Gillespie, David F., and Dennis S. Milett l
1976 "A refined model of differentiation in organizations," Sociolorv and Social i
Research 60(3):263-278.
Perry, Ronald. David F. Gillespie. Roy Lotz and Dennis S. Milett 1976 " Attitudinal variables as estimates of t:ehavior." Eurocean Journal of Social i
Psychotory 6(1):74-90.
Milett, Dennis 5., Ronald Perry and David F. Gillespie 1975 "The analytical use of case study materials in the study of organizations."
Sociotoricalinouiry 45(4):72-50.
M11ett Dennis S., and Elwood M. Beck 1975 " Explaining evacuation symbolically: communication in crisis."
Communication Research 2(1):24-49.
Gillesple David F., Ronald Perry. Dennis S. Mllett and Roy 1.otz 1975 " Organizational tensions and decentralization: the interactive of f act on member commitment. International Journal of Group Tensions 5(2):26-37.
Perry, Ronald. David F. Gillespie and Dennis S. Milett l
1974 " Collective stress and community transformation." Human Relations 27(8):767-788.
Milett Dennis S.
l 1974 " Change ratios in age-specttic percent contradictions to fertility: a new i
method with applications to the (Jnited States." Pactf tc Soctotcetcal Revtew j
17(a):3-26.
First Petze, student paper competttton. Pactile 50c:otegicat l
Association.1974.
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I Dennis S. Mileti Page 11 Milett. Dennis 5.. and David F. Gillespie 1974 "An integrative approach to the study of organizational technology, struc-ture and behavior," Current Sociotory 23(1):189-200.
Gillespie. David F., and Dennis 5. Mileti 1974 " System stress and the persistence of emergency organizations."
SocioloricalInouiry 44(2):111-119.
Milett. Dennis 5..'and Larry Barnett 1972 "Nine demographic factors and their relationship toward abortion legaliza-cloo." Social Biolony 19(2):43-50.
Journal ArriaW* Anetted Focus (refereed)
M11sti. Dennis 5.
1984 " Role conflict and abandonment in emergency workers." Emerrency Man-asement Review 2(1):20-22.
Mlleti Dennis.
1984 " Earthquakes and human behavior." Earthouakes Spectra 1(1):89-106.
Mlleti. Dennis 5.
1983 "Public perceptions of seismic hazards and critical f acilities." Buttetin of the Wa=okwical Societv of America 72(8)13-18.
i 2
Milett. Dennis 5.. and Patricia Harvey 1978 " Correcting for the human f actor in tornado warnings." Disaster Precared-g 2(February):5-9.
Maas J. Eugene, and Dennis 5. M11sti 1977 " Socioeconomic and political consequences of earthquake prediction."
Journal of the Physical Earth 25(4):283-293.
Hass. J. Eugene, and Dennis 5. Mileti I
1977 " Earthquake prediction and its consequences." California Geology 30 4
(7):147-157, 1977. Revised and reprinted in San Francisco 20(4):60-68,1978.
Hass J. Eugene, and Dennis 5. Milett 1976 " Earthquake prediction and other adjustments to earthquakes." Bulletin of l
the New Zasland Society for Earthcuake Enttneerint 9(4):183-194.
i Book Reviews (invited and refereed)
Mileti Dennis S.
l 1984 "A review of Social and Economte Aspects Earthquakes by Barclay G. Jones and Miha Tomaaevic (Eds.). !!!aca: Program in Urcan and Regtonal Studies.
1983." Mass Emerrencies and Dtsasters.
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Dennis S. Mileti Page 12 Milett. Dennis 5.
1982 "A review of Unequal Care: Interorganizational Relations in Health Care by 4
M. Milner, Jr. New York: Columbia University Press.1980." Social Forces 60(3):943-944.
l Milett. Dennis 5.
1982 "A review of Whistle Blowing: Loyalty and Dissent in the Corporation by Alan Westin (Ed.). New York: McGraw-Hul. 1981." Sociotory: A Review of New Bochs 7(2).
1 M11sti. Dennis 5.
1940 "A review of Af termath: Communities Af ter Natural Disasters by H. Paul i
Friesema et al. Severly Hius: Sage Publications 1979 and Af ter the Clean-up:
Long Range Effects of Natural Disasters by James Wright and Peter Rossi et al.
Beverly Hills: Sage Publications.1979." Journal of the American Plannint Asso-clation (October): 444-485.
I Mlleti. Dennis 5.
l 1976 "A review of A Sociology of Organizations by J. Eldridge and A. Crombie.
New York: International Pue!! cations.1975." Contemocrary Sociology 5(6):784.
Technical Reoorts (not refereed)
Milett. Dennis 5.
1945 Stress Imoacts of a Technotorical Emerrency: An Unobtrusive Indicators Study of Livineston Train Derattment. New Orleans: Lemie. Kellener.
Mileti. Dennis 5.
i 1983 Human Resoonse Scenarios: Law Erforcement Anotications and Media tm-l clications. Sacramento: California Division of Mines and Geology.
Mlleti. Dennis 5.
1982 Orranizational Behavior and Interorrinizational Relations: tmotications for Nuclear Power Plant Emerrencies and Precaredness.
Oak ' Ridge. Tennessee:
Oak Ridge National Laboratortes.
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Milett. Dennis 5.. Donald M. Hartsough and Patti Madson i
1982 The Three Mile Island incident: A Study of Behavioral Indicators of Hum 3n I
Sit 33. Wasnington. D.C.: Shaw. Pittman. Potts, and Troweridge.
Mileti. Dennis S. and Arthur Sevenson 1981 Earthcuake Prediction-Warntnr Resoonse for Emergency Organizations 'o the Prediction Terminology. Van Nuys: Dutnern California Earthquake Pre-i paredness Project.
Mutton. Janice, and Dennis S. Mitett 1979 Analysts of Adoceton and Imotementatton of Community (.and Use Regula-tions for Floodolatns. San francLsco: Woocward-Clyde.
Dennis S. Milett Page 13 Hass, J. Eugene, and Dennis S. Mileti 1976 Sociceconomic Imoact of Earthcuake Prediction on Government. Business and Community. Boulder: Institute of Behavioral Science.
Milett, Dennis, S., and David F. Gillespie 1976 Interorranizational Relations and Community Service Delivery Systems.
Boulder: Center for Action Research.
Publications in PiccMnzs (not referred)
M11sti. Dennis S.
1980 " Human response to earthquake prediction." Pp. 35-38 in Walter Hays (Ed.).
Pm::$nes of the Conferences on Earthouakes Prediction Information. Menlo Park: U.S. Geological Survey. Paper presented at the January 1980 Conference on Earthquake Prediction Information. Los Angeles.
Mileti, Dennis S., and Janice Hutton 1978 " Social aspects of earthquakes." Pp. 179-192 in PrccMnes of the Second International Conference on Microtonation. San Francisco: National Science Foundation. Paper presented at the Novemt:er L978 Conference on the State Hazards Reduction, San Francisco.
Milett, Dennis S.
1978 " Socioeconomic effects of earthquake prediction stage policy."
Prcceennes of the National Conference on Earthauake Related Hazards.
Lexington, Kentucky: Council of State Governments. Speech presented at the November,1977 Conference on State Policy for Earthquake Prediction Technolo-gy, Soulder, j
Other Published Comments (invited or referred)
Milett, Dennis S.
1984 "The character of traffic in an emergency," Bulletin 6(1):4-5.
Mileti, Dennis S.
1983 "Disasterous warnings," Omni (March):24,25,152.
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Milett. Dennis S.
1982 " Hazards reduction work:
the next era." National Hazards Ot: server 6(4):L-2. Reprinted in Eartncuake Information Bulletin 14(2h60, L982.
Milett, Dennis S.1982 " Sociological aspects of earthquake prediction." Earthcuake In-i formation Bulletin it(3):102-L05.
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Hass, J. Eugene, and Dennis S. Milett 1917 " Earthquake prediction respo ue." Time (January 24):83.
Dennis 5. Mileti Page 14 Mileti. Dennis 5.
1977 " Earthquake prediction: is it better not to know?" Mggg 8(2):8-14.
Milett. Dennis 5.
1977 "Sociat hazards of earthquakes prediction." Science News 111(2):20-21.
Naas, J. Eugene. Thomas Drabek and Dennis 5. Musti 1978 " Individual and organizational response to threat." Mass Emereencies
'1(4):247 Mueti. Dennis 5.
1978 " Social scientists and applied research." The American Sociolorist 11(4):220-221.
Milett. Dennis 5.
1974 " Response to research and national needs."Igggggg 2(October):6.
PROFESSONAL PAPERS AND PRESENTATIONS Conference Pacers Mileti. Dennis 5. and R. Gary Williams 1983 "A sociological perspective on the siting of hasardous waste faculties."
paper presented to the Social and Economic Effects of Puhuc N.sptions ses-ston of the Symposium on Waste Management. Tucson: March.
Milett. Dennis 5.. Rick Hufnaget and David Gillespie 1984 " Regulation of the firm: toward a theory of consequences." paper pres-l ented to the Complex Organizations Session of the American Sociological Asso-l clation. San Antonio: August.
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Mileti. Dennis 5.
1984 " Stress from risk uncertainties." invited paper presented to the Social As-pects of Risk Uncertainties Session of the Society for Risk Analysis. Knoxville:
l October.
Mileti. Dennis 5.
1984 " Social and political obstacles to the use nonstructural flood loss mitigation measures." paper presented to tne American Society ot Civil Engineers. San Francisco: Octocer.
l Milett. Dennis 5.
1984 "Why people take precauttons against natural hazards." paper presented to the Conference on Encouragtng Self Protection Benavtor. Rutgers Universtty:
l July.
Dennis 5. Milett Page 15 Mileti, Dennis 5.
1984 " Sociology in litigation: app!! cations of disaster research," paper presented to the Soetology of Disasters Session of the Pacific Sociological Association.
i Seettie: April.
Milett, Dennis 5.
1983 " Social impact and use of earthquake prediction-warnings," paper presented to the US-Japan Seminar on Practical Approaches to Earthquake Prediction and Warning Tokyo: November.
Frey, R. 5cott, Thomas Dietz. Dennis 5. M11ett, and Debra Cornellus 1983 " Structural determinants of community adoption of the National Flood In-l surance Program," paper presented to the Rural Sociological society, Lexington:
July.
Mllett, Dennis 5., Donald M. Hartsough, Patti Madeon and Rick Hufnaget 1983 "The Three Mile Island incident: a study of unobtrusive indicators of human stress," paper presented to the Disasters and Hazards Research Session of the Midwest Sociological Society, Kansas City: April.
Hufnagel, Rick, and Dennis 5. M11ett l
1943 " Organizational and environmental catastrophe: factors affecting organi-i i
zational response to a predicted earthquake," paper presented to the Disasters and Hazards Research Sec.::i::n of the. Western Social Science Association.
l Albuquerque: A pril.
M11ett, Dennis 5.
1982 "garthquake prediction response: cultural comparisons between Japan and the United States," paper presented to the Disaster Research Session of the In-tornational Sociological Association. Mexico City: August.
Milett Dennis 5.
1982 "!nfluencing corporate decisions on the use of microzonation information "
I paper presented to the Third Internation! Conference on Microtonation, Seattle:
June.
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i Milett, Dennis 5.
1982 "garthquake prediction and warnings: the human equation," paper pres-ented to the Conference on Hazards Research, Po!!cy Development, and Impte-l mentation incentives: Focus on Urean Earthquakes, Policy Research Center at the University of Redlands, Redlancs: June.
i Milett, Dennis 5.
1982 "Public perception of setsmic Pazards " paper presented to the Seismolottcal Society of Amertca. Ananetm: A prti.
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Dennis 5. M110t1 Page 16 Winiams, Gary, Frank Santopolo and Dennis 5. Mueti 1940 " Perception of growth impacts in energy impacted communities." paper presented to the Rur:15cciological Soetety, Ithaea: August.
M11sti Dennis 5.
1980 " Planning initiatives for seismic hazard mitigation," paper presented to the Conference on Social and Economic Impacts of Earthquakes on Critical Lif elines of the American Seelety of Civu Engineers, San Francisco: May.
Timmer, Doug, and Dennis 5. Mueti 1980 "!nterorganizational and struetural determinants of decision making," paper presented to the Seeston on Comptes Orgartzations of the Midwest Sociological Society, Muwaukee, Wiluams, Gary, Dennis 5. Milett 1940 " Community growth and impacts," paper presented to the Western Social Solence Assoaistion. Albuquerque: Apru.
Muett, Dennis 5.
1940 " Human response to earthquake prediction," paper presented to the Status of Knowledge Session of the Conference on Earthquake Prodietion Information.
Los /.ngeles: January.
Williams, Gary, and Dennis 5. Mllett 1979 " Perceptions of growth impacts in non-metropolitan Colorado," paper pres-ented to the impacts Seeston of the Conference on Regional Migration Trends.
St. Louis: October.
Milett, Dennis 5., and Gary Wlutams 1979 " Resident perceptions in growth impacted western argricultural communi-ties " paper presented to the Rural Sociologica150elety, Vermont: August.
Gillespie David F., Dennis S. Muati and 5 tan Eltzen 1979 "The opthenominauty of organizational size," paper presented to the Session on Complex Organizations of the Midwest Sociological Society, Milwaukee:
- April, Mileti, Dennis 5., Janice R. Mutton and John Sorensen 1979 "50elal factors and response to earthquake prediction." paper presented to the Internationa15ymposium on Eartnquake Prediction, UNESCO. Parts: Apeti.
Mutton. Janice R., Dennis 5. Mllett, and John Sorensen 1979 " Factors affecting earthquake warning system effectiveness," paper pres-ented to the International Sympostum on Eartnquake Prediction, UNESCO, Paris:
April.
Dennis S. Milett Page 17 Sorensen, John. Janice R. Mutton and Dennis 5. Mileti 1979 " institutional management of risk information following earthquake predle-tions." paper presented to the International Sympostum on Earthquake Predic-tion. UNESCO. Paris: April.
Milett. Dennis 5.. and Janice Hutton 1978 " Social aspects of earthquakes.* paper presented to the State of the Art Session of the Second international Conference on Microzonation. San Francisco:
November.
Mueti. Dennis 5.. and David F. Gillespia 1978 " Organizational size, complexity and decision making." paper presented to the Organizations Session of the American Sociological Association. San Francisco: September.
Gillespie. David F., and Dennis 3. Mllett 1978 " Corporate size as work." paper presented to the Organization of Work Ses-ston of the American Sociological Association. San Francisco: September.
Milett. Dennis 5.. and David F. Gillespie 1978 " Action postulates in organization-environment relations." paper presented to the Organizations-Environment Session of the Midwest Sociological Society.
Omaha April.
Gillespie. David F., and Dennis 5. Milett 1978 " Size and orfanizational differentiation." paper presented to the Formal and Complex Organizations Session of the Pacific Sociological Association.
Spokane: April.
Mileti. Dennis 5.. and Patricia Harvey 1977 " Correcting for the human factor in tornado warnings." paper presented to the Conference on Severe !.ocal Storms of the American Meteorological Society.
Omaha: October.
Mileti. Dennis 5.. and David F. Olllespie 1977 " Organization and environment adaptation manipulation." paper presented to the Organizational Relations Session of the American Sociological Assocta-tion. Chicago: September.
Hutton, Janice R., and Dennis 5. Mllett 1977 "The uses and abuses of scenartos in policy research." paper presented to the Social Policy Session of the American Sociologtcal Association. Chicago:
September.
Gillespie. David F., and Dennis S. Milett 1977 " Organizational growth and mal agertal ef ficiency." paper presented to tne Social Organization / Format / Complex Session of tne Pacific Sociolcgtcal Assocta-tion. Sacramento: April.
Dennis 5. Milett Page 18 Milett, Dennis 5., and David F. Gillespie 1977 " Organizational manipulation and adaptation to complex environments."
paper presented to the Complex Organizations Session of the Midwest Sociologieal Society, Minneapo!!s: April.
Gillesple. David F., Dennis 5. Milett and J. gugene Haas 1976 "$1:e and structure in complex organizations," paper presented to the Orga-
-nizational Change Session of the American Sociological Association, New York City: August.
M11ett, Dennis 5.
1976 "!. earning theory and disaster warning response," paper presented to the ts-suas in gnvironmental Analysis Session to the American Sociological Association, New York City: August.
Haas, J. gugene, and Dennis 5. Mllett 1976 " Consequences of earthquake prediction on other adjustments to earth-4 quakes," paper presented to the Australian Academy of Science, cancern: tay.
Milett, Dennis 5., and J. gugene Haas 1974 "A methodology for future collective events." paper presented to the Col-tective Behavior Session of the Midwest Sociological Society, St. Louis: Apr!!.
Gillespie, David F., and Dennis 5. Mileti 1974 " Operations technology and organizational structure," paper presented to the Formal Organizations session of the Midwest Sociological society, St. Louls:
April.
Haas, J. gugene, and Dennis 5. Mlleti 1976 " Assessing the consequences of earthquake prediction " paper presented to the Social Risk Session of the American Association for the Advancement of Sci-ence, Bostons February.
Mlleti, Dennis 5., and David F, G111espie 1975 " Technological uncertainty in organization environment relations." paper presented to the Formal Organizations Session of the American Sociological As-sociation, San Francisco: August.
Mllett, Dennis 5., and David F. Gillespie 1975 "A resolution of inconsistencies t:etween size. complexity and the admints-j trative component in organizations." paper presented to the Format Organiza-tions Session of the Midwest Sectological Society, Chicago: April.
I Milett. Dennis 5., and David F. Gillespie 1975 " Technology and the study of organizations." paper presented to the Formal Organizations Session of the Pact!tt Sociologtcal Association. Vletorta: Aprti, i
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Dennt.s S. Milett Page 19 Milett. Dennis 5.. and David F. Gillespie 1975 "An interaction model for organization environment relations." paper pres-ented to the Interorganizational Relations Session of the Midwest Sociological Society. Omana: A ptt!.
M11ett Dennis 5.. and David F. Gillespie 1974 "A formalization of organization-environment dependencies." paper pres-ented to the Format Organizations Session of the Pacific Sociological Associa-tion. San Jone: Marsh.
Farhar. Barbara, and Dennis 3. Mileti 1974 "Value and role lasues for the involved social scientist." paper presented to the Applied Session of the Pacific Sociological Association. San Jose: March.
Mllett Dennis 5.
1973 "Drowingt a commun!"ations disease." paper presented to the Mass Com-munications and Pubite Opinion Session of the American Sociological Assocla-tion. New York City: August.
Milett. Dennis 5. and $1gmund Krane 1973 " Response to impending system stress." paper presented to the What Do We Know Session on Human Behavtor in Disaster of the American Sociological Asso-clation. New York City: August.
Milett. Dennis 5.
1973 "A paradigm and sociology of knowledge for theories of natural law." paper presented to the Theory Session of the paper presented to the Theory Sesston of the Midwest Sociological society. Milwaukee: April.
Milett. Dennis 5.
1972 " Response to hazards warnings." paper presented to the Organizational and Community Response to Disaster Seminar at the Disaster Research Center of the Ohio State University. Columbus July.
SPEECHE3 AND GyEST LICTURERS
" Social aspects of risk." Risk Analysis Seminar. Department of Industrial Engineering.
Stanford University: February,1985.
" Communicating engineering informatton to pucile of f tetals." Social App!! cations Ses-ston, Earthquake Engineering Research Institute. Seattle: Feeruary 1985.
" Social and political ocatacles to the use of nonstructural flood loss mtttgation mea-sures." American Society for Civil Engineers. San Franetsco: Octocer. L984.
Dennis 5. Milett Page 20
" Warnings: applying research in the private sector," Plenary Session on Hazards Re-search and Management: Assessments of a Field, Natural Hazards Research Ap-puestions workshop. Boulder: July,1984
" Human response to emergencies." Emergency Preparedness Executive Seminar for County Commissioners of the Commonwealth of Pennsylvania GPU Nuclear Corporation. Harrisburg: March,1984.
"The uses of earthquake prediction-warnings," Colloqium on Earthquake Prediction Re-search in the US, Earthquake Research Institute, University of Tokyo:
November,1983.
"Numan response in disasters," American Red Cross, Mlle High Chapter, Boulder Re-glos. Boulder: July,1983.
" Integrated emergency management cha!!enges and opportunities." Plenary Session of the Natural Masards Research Applications Workshop. Boulder: July,1943.
"Putue response to flood disasters " Conference on the Need to Teamwork in Managing Flood Hazards. Association of State Floodplain Manager Sacramento: A pril, 1943.
" Natural hazards, disasters and public policy " Environmental Management Institute, University of Southern California, Los Angeles: April,1982.
Myths of disaster response" Earthquake Planning Conference for Business and Indus-try, Los Angeles: May,1982.
Communicating lessons learned f rom social science research on earthquakes." Workshop of Identifyng and Disseminating Lessons Learned from Recent Earthquakes,"
Earthquakes gngineering Research Institutes. Los Altos: December,1982.
" Social causes of earthquake prediction-warning response: imp!! cations for the design of California's warning system and Southern California Earthquake Preparedness Pro }ect, Van Nuys: Octocer,1981.
" Assessment of resesreh on natural hazards: what have we learned and what prottems demand further attention " Natural Hazards Research Applications Workshop.
Sculder: July,t981.
" Disaster reconstruction patterns to guide planning," Covernors Task Force for Earth-quake Emergency Preparedness.
Committee on Long Range Reconstruction, Sacramento: May,1981.
"Socio-cultural dimensions of earthquare risk." Covernors Emergency Task Force on Earthquakes General Assemcty. Sacramento: May,1981.
Dennis 5. Mileti Page 2L
"!nterorganizational relations and service delivery systems." Health Scioness Center, University of Colorado. Denver: October,1980.
" Social response to earthquake prediction: local po!!cy issues." Southern California Emergency Services Asseetation. Montebello February.1980.
" Human response te weather-torne hazards warnings." Department of Atmospherte Sciences. Colorade State University: Octoeer.1979.
l
" Natural hasseds, disasters and :oeial resseren." Department of Sociology. University of Denver: Decomeer. 1980,1979.
" Measuring implementation of public pouey for floodplain land use controls." Natural Haasse Research Appliestions workshop. Boulder: August,1978.
"Seeloseonomie effees of earthquake prediction and state policy." Conference on State Pouey for Earthquake Prediction Technology. Boulder: November 1977.
I
" Population, resources and polley for socisi change." College of Natural Resources.
Colorado State University: September l977t February,1978t February.1980.
"The behavior of ernment and corporate organizations in an earthquake prediction."
American iety for Putile Administation. Colorado Chapter. Denver: A pril, 1978.
"The social and economie aspects of scientifically credihte earthquake predictions."
Caufornia State Seminar on Emergency Preparedness and Earthquake Prediction.
Palm Springs: June.1976.
" Preparing to.make use of earthquake predictions." Emergency Preparedness Commis-sion for the County and C!ttes of !.os Angeles. Monteceuo: February,1976.
"The social organlaation of hazard warning systems." En'gineering Foundation Confer-enee on Decision Making for Natural Nazards. Pacific Grove: March l976.
"8riefing on the likely social and economic impacts of earthquake prediction." Cover-nor's Conference Room. Sacramento: May.1975t Mayor's Conference Room, t.os Angeles: October.1975.
" Social economie and legal aspects of earthquake prediction." General Assembly of the t
International Union of Geodesy and Coophystes. Granocle: September,1975.
" Earthquake prediction and its implicationt.; for e.norgency preparedness." Center for Community Studies. Tokyo: Septemcer. l975.
" Social impacts of earthquake predtetto i: implications for pottcy." Californta water and Power Earthquake Engineering Forum. San Francisco: April, l975.
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0:nnts 5. Mllett Page 22 i
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OTHRR PROFES$10NAL SERVICE o,
ia.r a.,r Session on nuclear power. Third International Congress on Emergencies. Washington, D.C.:
May, 1988: Session on Appued Seelology. Pseille Soetological Association.
Seetties Apru, t$44: Session on Theoretical Aasemammes. Western Social Science Asco-l clation. San Diege: Apru.1984: Session on Methodological Approaches in the Study of i
Health Care Douvery Systems. Western Social Selence Association. San Diego: April.
1984: Session on Earthquake Hazard Reduction: Is the National Earthquake Hazard Re-duction Program Meeting its Congressional Mandate. Seventh Annual Workshop on Nat-4 j
ural Hasards Research Appuestions. Boulder: July,194St Session on Disasters and Cat-I aclysms: Can Sociology Help. Pacif te Soetological Assoaistion. San Diego: April,1982:
j Session on Couestive Behavior. American Soetological Association. New York: August.
1984t Session on Comptes Organization. Psefie Sociological Assoaistion. San Francisco:
Apru.1944t Session on Complex Organizations. Western Social Setence Association, i
Tempo 1974.
I Dh I
l Session on Theoretical Assessments. Western Social Scionee Association. San Diego:
l Apru.1984: Session on Societal Response to Hazards. American Sociological Assocta-I tion. San Antonio: August,1984: Session on Put!!c Response to Earth Science Informa-i j
tion. Natural Hazards Research Appucations Workshop, Boulder: July 1980: Session on 1
Warning Systems. National Conference on Natural Hazards Boulder: June,1974: Ses-ston on Warning Systems. National Conference on Natural Hazards. Boulder: July,1975:
4 Session on Disaster Relief and Warning Systems. National Conference on Natural Haz-i j
ards. Estes Park: June,1973.
l 1
Partisinant i
l Panel on Disaster Research its Funding and Future. American Sociological Association.
San Antonio: August,1984: Review Panet. Corresponding Member. Task Group on So-cial and Economic Aspects of Earthquakes National Academy of Sciences. National Re-l search Councu. Commission on Sociotechnical Systems. Washington, D.C.: 1982: Work-i shop on Disseminating Lessons Learned from Recent Earthquakes. Earthquake l
Engineering Research Institute. Los Altos: December.1982: Tennessee Valley Authority i
Flood Plain Evaluation Panel. Boulder: Novemeer.1982: Earthquake Prediction Warning j
Task Force Workshop. Southern California Earthquake Preparedness Project. Astlomar:
j December 1981: Sympostum on Earthquake Prediction. Preparedness and Human Re-i sponse. San Fernando: June,1976: Seminar on Disaster Research, Colorado State Unt-
)
versity. Fort Collins: Feeruary. L975: Symposium on Complex Organizations: Researen j
and Applications. Western Soctst 5ctance Association. El Paso: April. L974.
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0:nnis S. Milett Page 23 Is A R E W W Corresponding Editor, o wanintions and occusations Newsletter of the American Sociologiest Association. Western Region,1984-present: Associate Editor for social set-enee. Earthquake Snactra. Journal of the Earthquake Engineering Research Institute.
1984-1987: Corresponding Editor on Hazards and Disaster. Environmental Socioloey, Newsletter of the seetton on Environmental Sociology of the Amortean Sociologtcal As-sociation,1981-datet Guest editor, spoeial issue on Environmental Stress. Threat and Social System Response. Mass Emerzeneles 1(4):247-344. 1974.
l l
Testimony Nuclear Regulatory Commission in the matter of emerigney planning at the Shoreham Nuclear Reestor. Suffolk: December 1983 through.une,1984: Nuclear Regulatory Commission in the matter of emergency planning at the Wolf Creek generating station.
Burlington, Kansas: January,1984: Nuclear Regulatory Commission in the matter of preemergency puette education and information for emergency planning at the Wa-terford Three Nuolear Rosetor, New Orleans February,1983: Suffolk County Legista-l ture. State of New York, in the matter of emergency planning at the shoreham Nuclear Reactor, Suffolk: January. 1983: Nuclest Regulatory Commission in the matter of emergency planning at the Diablo Canyon Nuclear Reactor. San Luis 00tsco: January, 1982: Senate Subcommittee on Science. Technology and Space in the matter of the Na-t tional Earthquake Hazards Reduction Act Washington, D.C. April,1980: Nuclear Regu-latory Commlaston in the matter of the impact of floating nuetear plants on tourist be-havior, Bethesda: May,1977 and July,1978.
Larialative argi Pronram Reviews Earthquake Hazards Reduction Program. U.S. Congressional Panel. Federal Emergency Management Agency. 1983-82: Earthquake Hazards Reduction Program of the U.S. Geo-l logical Survey,1982: Final Regulations for Floodplain Management and Protection of Wetlands. Federal Emergency Management Agency, Federal Register 178(45):59520 59534, 1980: App!!ad Research Program Evaluation. National Science Foundation. 1978-79.
l Propanal ReviaWE i
t Societal Response Program of Civil and Environmental Engineering. National Science Foundation. 1985-81: Divtston of Policy Research and Analysts. National Sctence Foun-dation.1983: Sociology Program. National Scterce Foundation. 1982 91: Design Re-i search Program. National $ctence Foundation,1982: Diviston of Proctem Focused Re-search. National Selence Foundation.1990: Otytston of international Programs National l
Science Foundation. L978: Olvtston of A 'vanced Environmental Research and Technolo-l gy. National Setence Foundatton. 1973-76.
i i
i
Dennis 5. Mllett Page 24 Artsein Revenws Human Relations. 1948-83. 1978-77: Soeloloeical Persoectives (Pacifle Socioloalcal Re-
_vjgg).1984: Soetal Forces. 1940-79: Socioloav and Soeial tanearen. 1943-81, 1979-78 1974: The Social Science Journal, 1943, 1941-77: TM Soeialaatcal cuarterly.1975:
Journal of the Amartean Plannine Aaaaalation 1940: Deviant Behavior.1983: M An@.1943: The Environ-ntal Prof --" anal. 1943 42 b_inatin of the 5eismoloatcal (celety of Amartes.1942: jegigiggcal Focus 1940: Mass Emegencies. 1978. 1976-75:
Paitav Analvata, 1974 Current h'en in Eartha"** Prediction. 1944 M33l t=;.
.wiss and D*-tart.1948.
4 Other Reviews I
L. Lave and D. Eppie. " Future Scenarios." Chapter 21 in R. W. Mates (Ed.). Climate Imaaat A
- mtr 5td== of the Interaction of Climate mad Soeistv. Geneva, for the International Counett of Setentille Union's Setentif te Committee on Probleans of the En-vitenment.1982: Study on Earthat ska Hanneds 'nformation D"-taationt Charleston.
South Carolin4. Reston for the U. i. Geological:lutvey,1942.
l Denartment and University Service College Scholarship Committee. 1945-84: Department Executive Committee. 1994 42, i
1980-77: Department Graduate Aff airs Committee. 1988-84, 1977 74: Department Five Year Review Committee.1982: Department Comprehensive Examination Commit-tee.1984-75: Department ad hoe Committee on Research Space 1983: Department Evaluation of Independent Study Courses.1978 Department Faculty Search Committee.
1988-84: University Committee for Department Chair. 1945 84: University Committee on Ethnie Studies. 1974-74: University Committee on Latin American Studies. 1973-74.
TEACHING l
Courses Taumht (urppantraduate)
Introduetion to Sociology Complex Organizatons i
Demographic Processes and Social Change HLatortca15cotological Theory l
Research Methods Sociology of Hazards and DLsasters I
i i
Courses Taucht (traduate)
(
Advanced Quantitative Analysts l
Multiple Regrenston and Path Analysts e
L
I
. Dennts S. Milett Page 25 Research Methods !
Rescarch Methods U Demography and Population Complex Organizations 1
Grattate Theses and Dissertations Chair. Ph.D. Dissertation Committee,6 Member. Ph.D. Committees.12-Chair. M.A. Thesis Committees. 4 Member M.A. Committees.12 Student Evahastions Ranked as exce!! ant by most students in most coursest evaluation summaries are avatt-acte upon request.
Teachina Awere Alumni Honor Faculty Award. Colorado State University. Alumni Association, for Aca-demic Year 1983 94: Cited for excellence by the Dean. College of Arts. Humanttles and Social selences for Academic Year 1977 1978.
VITA ADDITIONS (1988)
Sorensen. J., J. Mutton and D. Milett 1984 " Institutional management of risk informa-tion following earthquake predictions."
Pp.
913 924 in F. Evtson (Ed.)
tartha"*= Prediction. Parts: United Nations Educational. $ctentif te and Cultur-al organization.
Milett. D.. J. Sorensen and J. Hutton 1984 " Social factors affecting the response of groups to earthquake prodletton: Imp!! cations for public policy." Pp. 649-638 in F. Evison (Ed.) tarthauake Predictton. Parts: United Nations Educational. Scien-(1f te and Cultur 10rganization.
Milett. Dennis 5.. D. Hartsougn. P. Madson. R. Huf nagel 1984 "The Three Mlle Island In-cident: A Study of BehavtoralIndicators of Human Stress" Mass Emerrenctes anc Q1gantu 2 (1): SS-113.
Hutton. J., D. Milett and J. Sorensen 1984 " Factors af fecting the ef fectiveness of eartn-quakes warning ctssemination systems." Pp.
313 924 in F. Evtson (Ed.!
Earthouake Prediction. Parts: U.itted Nations Educational. $ctentific and Cultur-at organization.
I
=
Dennis 5. Milett Page 26 Narwou. Christine C. (Ed.) 1948 "Espertences and extrapolations from Hirosalma and Nagasaki."
Pg. 427-447 in M.A. Harwou and T.C.
Nufchinson (EdsJ gg-r---tal u ---- - ; of NC - War Vala-- G: to-L-deal and Aartcut-tural Eftests. 6 ew Yorma John Wiey and Se.6.
Muod. Dennis. J. Sorensen. W.
1944 Ev-tw rw.w v.i,Ma Process and Oak Ridge, ennessees Oak R Age National Lacoratory: No.
Federal Emergency Management Agency 1984 Na"---' wae '- Hamda Reduction Five Years Plan. Washington D.C.: Federa, Emergency Management gency.
f Pephia Rey D. MMed. B. Farhar - Pugrim and J. Sheiner 1943 un =at Ne of Di--
uer ha**= la esa unt*='8 Ste Fort Cotuns. Colorades (aaards Assessment
.aterseery at ceerede State J niversity.
Muod. Dennis 1948 " Emergency (42): 0-10.rene performance in disaster res
,,v, Mueti Dennis S., with D. Hartsough. J. Mutton. P. Madsen S. Pratt. C. Simile i
1933 St: - - t=aaats of a T;.t--L-deal e
- _ ra An Ur.c.utrualve Indicators i
I Studv al rha Livinenton Train Derent= ant. Fort Coluns. Colorsoot Hazards As-sessment Lateratory at Colorado State University.
Mueti. Dennis and Gary Wuuams 1988 "A seelelegteal perspective on the siting of hasardous waste f act!!tted.
Paper presented at the Annual Conference on Waste Management. Session on 50-etal and Economie Effects of Puttle Peroeption: Tueson: March.
Coehrane. Nat and Dennis Muett l
i 1988 "Vulneratuities of medieauhealth care systems to the effect of nuclear war." Paper ted at the Symposium on the MedieelImpiteations of Nuclear War. Na Academy of Selenees. Institute of Medietne. Seeston on Medical Resouree Needs and Avauettuty. Washington, D.C.: September.
Partielpant. Conference for Researehers on the Use of Cr'Jia Response Concluston Retrieval System. University of Pitts0urg Center for Scotal and Urean Researen.
j Pittsburgt Doeoster.1948.
l l
Appointed (by invitation) to $lgma Xt The $ctentitle Research Soetety 1985.
l l
"Soetal aspects of risk." speeen presented to Risk Analysts Seminar. Department cl 'n-l dustrial Engineering. Stanford University. Standford Feoruary 1983.
" Human response to emergencies." 1peech presented to Emergency Preparedness Exec-
{
uttve Seminar. General Public Utiltttes Nuclear Corporatton, Mtcctetown.
Pennsylvania May.1945.
l t
i
Dennis S. M110tt Page 27
" Social aspeets of the Parkttold. California earthquake predetton." speseh presented to the Annual Meeting of the Amortean Geophystes! Union. Session on Parkfield Earthquake Studies. San Franetsco: December,1945.
"Communleating engtnoering information to public offloials.* speseh presented to the Annual Meeting of the Earthquake Engineering Renesteh Institute. Session on So-etal Appliestion. Seatties February 1945.
"How well de trentional warning system strategies deal with today's natural and tech-noingleal hasards?", spesen presented to the pienary sendon of the Tenth Annual Invitational Workshop on Hazards Research and Appliestion. Boulder
- July, 1948.
"Sosial tapees and lesens from the Parkfleid earthquake predletion." speech pres-ented to the Earthquake Predetton Warning and Response System Workshop.
Governor's offlee of Emergency Servlees. Astlemar. California: July.
Correspondag Eeter. C - de*Haa-'- and Oee"aariana newsletter for the Western Re-glen of the Amerteen Soolologteal Assostation.
Organiser and Presider. Sessions !. O and !!! on Nuclear Power. Emergency 48. Third In-tornational Conference Emergency Management. Washington, D.C.: May,1968.
Correspondag Edtor. Column on Natural Harards and Disasters. Environmental Soetal-Newsletter of the Section on Environmental Soolology of the American legtes! Assostation. 4L (Spring. 1945): 10-18t 42 (Summer L945): 5 0.
Ennert Witnam Testimmar Nuclear Regulatory Commission in the matter of emergeney planning at the Sheaton-Harris Nuclear Power Plant. Ra:eigh: June and Novemeer.1985.
Prensual Reviews National Setenee Foundation. Soetetal Response Program January 1985.
National Selenee Foundation Olvision of Fundamental Research in Emerging and Crttia cal Engineering System. April,1983.
Renart Reviews Earthquakes Engineering Research Institute Committee Report on Research Opportunities from the L90$ Memo City Earthquake. Septemoer.1985.
Dennis 5. M11eti i
Page 28 4
a 1
Nadonal Academy of Scionees. National Research Council. Commission on Engineering and Technleal Systems. Report on Impressions of the Guerrero-Michoacan.
Mesion Earthquake. Octotor.1945.
Advisortes Seednar presentation on emergency putnie information needs for chemical and hazard-3 ous materials sooidents to Offlee of the Governor of Colorado. State Police, and Colorado Division of Emergeney Seivices. Denver: July,1945.
laterviews Gwem Interviews given with reporters from The New York Times. National Pubtle Radio.
M. Colorado State University media. I133, and for other local media.
VITA ADDfTIONS(1988 i
Article review for the International Journal of Mass Emergenotes and Disaster 1986.
Speech. " Social and Economie Impacts of Earthquake Predictions." !.os Angeles City Earthquake Prediction Workshop. As11omar. California! Octnoer 12. 1986.
Speech. " Earthquake Prediction: A Genera 10verview." Emergency Preparedness Com-
]
mission for the Cities and County of Los Angeles Carson, California: Aprt! 24.
l 1944.
Milett. Dennis S., and James Goltz " Social Response to the Parkiteld Prediction." paper l
presented to the Parkfield Prediction Esperiment Session of the American Asso-eistion for the Advancement of Selence. Philadelphia, May, itse.
Proposal Review. Earthquake Systems Integration Division of Pundamental Research i
for Emerging and Critical Engineering Systems. National Science Foundation.
1944.
l Speech. "Novemoor 1944 Colomena Nevada del Ruta Voteanic Eruption: Emergency Pre-i paredness and Mitigation Measures." Committee on Naturat Dtaaster Commtsston on Engineering and Technical Systems. National Research Counctl. National l
Academy of Setences. Wasnington. D.C.: Cetocer 27.1984.
Milett. Dennis S., Randai C. Updike. Patricia A Bolton and Caertet Fernandey. 1986.
Recommendations for tmorovtre the Extstina Warning System for Posstete NevW m Ruiz Volcanic Eruction. ColomDra. South America. Wasnin(ton. D.C.:
j National Academy nt $ctence. L 586.
i i
3 Dennis 5. Milett Page 29 Sposen. "!ndustrial Crisis Response," Fluid Mechanics and Wind Engineering Program, Couage of Engineering, Colorado State University, Fort Couins: November 5.
1984.
Member. National Academy of Sciences. National Research Council. Commission on En-gineering and Technica15ystems, Committee on Natural Disasters.
Member, National Academy of Sciences National Research Coucil Commission on Physical Sciences Mathematics and Resources, Board on Earth Sciences, Suty committee on Earthquake Research.
Cochrane Hal, and Dennis Mueti. 1984. "The Consequenees of Nuclear War: An Eco-nomic and Social Perspective." Pp. 341-409 In F. Soloma and R.Q. Martson (eds.)
The Medleal f=aHa*Haa of Nuclear War. Washington, D.C.:
National Acade-my Press.
Milett. Dennis 3. and John H. Sorensen " Determinants of Organizational Effectiveness in Responding to Low Procability Catastrophic Events," paper presented to the Crisis Analysis Models Session. Internation1 Conference on Industrial Crists Man-agement New Yorts University, Graduate School of Business Administration.
New Yorts City: September 6.1986.
Organizer and Presider Sessions on the Sociology of Disaster. Annual Meeting of the American Socivicgical Association New York City: August,1946.
Article review. Human Relations,1984.
Speech, "Armero, Columbia What are the f.essons for Hazards Management in the United States," Plenary Session, Hazards Research and Applications Workshop.
Boulder, Colorado: July,1944.
Speech. "Public Response glements for Flood Warning Emergency Preparedness." Plena-ry Session Conference on What Have We Learned Since the sig Thompson Flood.
Boulder, Colorado: July, itse.
Williams. Gary, and Dennis 3. Mueti. L986. " Inclusion of Social Variables in Models of Risk Assessment." Pp. 375-379 in Geotechnical and Ceohydrolonical Asoects of i
Waste Manasement. Boston: Rotterdam.
Article review. Earthauake Soectra. L986.
l Speech. " Social Aspects of Risk Communication." Conference on Communications in Emergencies. Wyoming Disaster and Civil Defense Divtston, Cheyenne: A pril.
i 1986.
Proposal review External Research Otytston, U.S. Geological Survey.1986.
I l
I
Dennis S. Mileti Page 30 i
Speech. "What We Know About Human Behavior and Earthquakes." Annual Meeting of the Earthquake Engineering Research Institute, San Francisco: February.1986.
Elected Member, Sigma Xi the Scientific Research Society,1985-present.
4 Sorensen John H. Dennis S. M11ett and Emily Copenhaver.
1985. " Inter and In-traorganizational Cohesion in Emergencies." Mass Emerrencias and Disaster.
3(3): 27-52.
Report Review. National Academy of Sciences National Research Council,1986.
M11sti. Dennis.1946. " Disaster Survival." Alumnus Quarterly 62 (1): 6-7,20.
Article review, Journal of the American Plannint Association 1946.
i j
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'k i
.--.--._-_.ne-_,-_____---,,--
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,-_,_.~.n.,,_,,,,,_,,
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NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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:
a.
Identify each non-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 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
Applicants object to the interrogatory as stated as inquiring into the work product and legal theory of counsel. There is no provision in the Rules of Practice for requiring the listing of " fact" witnesses. However, without waiving its objection. Applicants advise that non-expert hearing witnesses have not yet been designated.
But further in this regard Applicants call attention to:
their answers in response to the Town of Hampton Interrogatory 1 as to TOH III. IV, VI and VIII; NECNP's interrogatories 2, 3, 4 and 7 (Schedule 7.1 and.1 as supplemented (4/8/87)), Applicants' Supplemental Responses to Mass AG Interrogatories 2 and 3 with schedules and attachments (4/24/87); and Applicants' notions for summary disposition of intervenor contentions, affiant's affidavits and curriculum vitae all of which have been served on Mass AG.
L/253CC.5
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 testimony, 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; 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; g.
State whether the opinion of any expert 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 is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.
L/253CC.6
.=-
A
RESPONSE
To the extent this interrogatory seeks inforaation regarding experts who are expected to testify, see ariswer to Interrogatory 4.
Beyond that Applicants object to this interrogatory as it inquires into the work product and legal theory of counsel.
L/253CC.6.1
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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
Steps that may be taken are included in the current draft of State of New Hampshire responses to the RAC comments on Revision 2 of the NHRERP.
L/253CC.7
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 8.
In accordance with 10 CFR 92.740(e), please supplement your answers to Massachusetts Attorney General's Interrogatories and Request for Prnduction of Documents, filed March 5, 1987.
RESPONSE
See " Applicants' Supplemental Respon*:3 to First Set of Intervenor Interrogatories" filed herewith.
L/253CC.8
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 contingen-cies 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, provide 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.
i L/253CC.9
RESPONSE
9.
a.
Letters of agreement with each towing company are located in NHRERP Volume 5. Additional Letters of Agreement not contained in Volume 5 are attached.
b.
The name of each provider, including the number of vehicles available and vehicle locations, is provided in the letter of agreement.
c.
Each letter of agreement commits drivers / crews for identified tow trucks.
No contingencies are expressed in the Letters of Agree-
- ment, d.
See response to item b, above.
e.
Objection. This question seeks a level of detail not required by the regulations or NUREG-0654.
f.
Compensation arrangements are described in each Letter of Agreement.
g.
Applicants have no such documents.
h.
Applicants have no other than those identified in subpart a. above.
L/253CC.9.1
/
STATE OF NEW MAARP5 HIRE
- O amenweseneneur see.seemseen as esses a,
s museone put ame I N Hemuu s muuss Comment seen sammensess e Janu n sismesse 6
0**"er asosamme n stacass o m rer i
Jaases A. sassierss oscury Omree Al's Automotive Service Center of Exeter, N.H. recognizes the critical role of keeping highways clear of W== sits in the event of either natural or technological emergencies such as flooding, fires, accidents at industrial facilities, including the Vermont Yankee and Seabrook Nuclaer Pbuer Plants, and other emergencies. For this reason, Al's Automotive agrees to assist the State Emergency respones effort, in particular the New Homoshire Civil Defense Agency, try providing it's services as detailed under the terms of this agreement or as regJosted try the New Hampshire Civil Defense Agency, and for such compensation as is deemed fair and agaitable by preper authority.
The number and capacity of tow trucks avellable for clearing road and treffic impediments during an emergency is:
3 (Out of total of: 1-2 Car Rasp,)
(; : : r,-
3-1 Ton
)
These vehicles are located at: $ Franklin St., Exeter
.i These vehicles have the following radio communicatione capability:
FREQ. - 462.625 and 467.625 Orivers/ Crews for these tow vehicles are available for response during an emergency.
In the event of an amorp and in coordination with the State, Al's Automotive will make all ofrorts to deploy its toe trucks to staging areas specified by the Nee Hampshire Civil Defense Agarty to provide assistance to stalled vehicles and to claer reeds of ispediments as they occur. Staging areas to which Al's Autenstive ed@t be deployed in anticipation of an evacuation of the Seetseek Statlan Ese Planning Zone are listed in W1ues 5 of the Medialspisel Emergarty Plan and PM 12-5. At the time of meh111astian, The Nee Hampshire Civil Defense Agency will specify the specific staging ares for deployment. The Noe Hespehire Civil Defense Agency will provide training as necessary' to facilitate implementation of this Agreement.
New Hospshire Civil Defense Al's Automotive Service Center
&I gy
/
/
e ey a
Minneel M. g i cnier Its Agent Ur RepreseWtatlyi Technological Hazares Division M
Executad This Oey J /
M4UN Executed This Day A#
r 308/M assegamey seemsommme ser pese nameusee
STATE OF NEW HAA4PNMS ER80LMWW epaafneest I
9 us. nessen. a s es as e Sams,e met asse ser naamm amuse caused,me. nummen su se l
Je088 DL essom o
mOlam M. Steams i
a-Jaanes a.sao ooores Ous., eh,we, LITTER 7 AGEDENT Sargents $srvice Centar, Inc. of Rye, New Hampshire recognizes the critical role of keep natural or technotaa!*q= emergencies such as flooding, fires, accidents industrial facilitise, including the Vermont Yarttee and Seabrook Nuclear Power _
Plants, and other emergencies. For this reason, Sargents Service Center, Inc.
agrees to assist the State Emergency response effort, in particular the New Hampshire Civil Defense Agency, by providing it's services as detailed unoer the terms of this a0ressent or as regJested by the New Hampshire Civil Defense Agency, and for sucn' compensation as is deemed fair and agaitaDie by proper authority.
Tne number and capacity of tow trucks availatde for clearing road and traffic f=parii==rits during an emergency is: 1 - 1 ton wrecker l
These venicles are located at: 255 Central Road, Rye, New Hampshire l
These venicles have the following radio communications capability:
l C8 Radio & Scanner i
Orivers/ Crews for these tow vehicles are available for response curirg a,
[
emergency.
In the event of an emergency and in coordination with the State, Sargents Service Center, Inc. will sehe all offorts to deploy its tow trucks to staging areas specified by the New Heepshire Civil Defense Agency to provide t
assistance to stalled vehicles and to clear roede of ispediments as they occur. Staging areas to unich Sargents Service Center, Inc. might be cooloyec in anticipation of an evacuation of the Senercok Statlan Eastgency Planning Zone are listed in Volume 5 of the Mediological Emergency Response Plan and PAE 12-S. At the ties of =andiration, The New Hespehize Civil Defense Agency will speelfy the specific staging ares for deployment. The New Haapanize Civil Otenes Agency will provide trainin0 as necessary to facilitate implems1tation of 'this Agressant.
I e
New Hasp Civi Defense 4-,
'er, By MA Sy ~.
Micnael N. Neuoj{ Chief I Its Apnt Dr phpfteentative Technalaaiaal Headtds Division Executed Tnis Day
((
Executed This Day F T
ff salSe/jse
- ==s==r
===s===m fw New Mongdho aa
3 MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 eva-cuation 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 implementation of confirmation of evacuation may employ the method recommended in NHRERP, Volume 6, Section 13.
b.
This is a matter of State of New Hampshire policy; consequently, Applicants defer to response by the State of New Hampshire.
L/253CC.10
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 personnel; (b) exactly how many of said personnel will be needed for this task; fe) how (siren, bullhorn, voice?) the beach population will be notified of a beach closing; (d) exactly what beach-goers 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 state 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; (1) 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?
L/253CC.11
C
RESPONSE
The plans do not call for the beaches to be automatically closed at the Alert Emergency Classification Level. A thorough description of each of the actions queried by this interrogatory (except Items h, i. and j) is contained in NHRERP, Volume 1. Section 2.1 and Section 2.6-5 and and in Volumes 4 and 4A, Appendices F and U respectively. EBS messages and public announcements are con-tained in Volume 4, Appendix G.
The specific public address message is attached. Procedures for organizations having specific responsibilities for beach closing are contained in Volume 48, Department of Resources and Economic Development and New Hampshire State Police Procedures, and Volumes 16 and 18,Section IV, and Appendix G.
These procedures are supplemented by the New Hampshire Traffic Management Manual which have been served on the parties to this proceeding.
With respect to item h.,
it has already been established that there is ample ride sharing capacity available for beach goers who may not have access to their own transportation. As to item 1., Applicants do not understand what the interrogatory means by " beach-going vehicles" As to item j., this is a matter of State of New Hampshire policy; consequently, Applicants defer to the State of New Hampshire for this response.
L/253CC.11.1
ATTACIBIENT 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.
L/253CC.11.2
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MASS ATTORNEY GENERAL SUPPLEIENTAL INTERROGATORIES TO TNE APPLICANTS 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
i Yes.
In chapter 4 of Volume 6 of the NHRERP KLD presents estimated distri-butions describing the responses of evacuees associated with the various prepa-ratory activities preceeding the actual evacuation trip. For people on the beaches KLD presents Distribution IB on page 4-9 which describes the estimated time for notification of persons on the beach. On page 4-11 and 4-12 KLD offers I
i an estimated distribution of the amount of time it takes for people on the. beach i
to complete their preparation tasks. The ETE values can be culled from detailed output provided by the model. KLD believes the interrogatory focuses on the i
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summer scenarios numbers 1-4.
KLD will therefore provide that information for review at the Seabrook Station in response to this interrogatory. Specifically l
l this information will be provided for Hampton Beach and Seabrook Beach.
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0 MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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.
RESPONSE
The procedures and organizations employed to close the beach areas in
[
Hampton and Seabrook are contained in Volume 4. Appendix F.
In addition, proce-dures for organizations having primary and secondary assigned responsibilities are contained in Volume 48.
Resources include Department of Resources and Economic Development (DRED) (up to 39 personnel), New Hampshire State Police (as needed), and as outlined in Section IV and Appendix G of Volumes 16 and 18.
These procedures are supplemented by the New Hampshire Traffic Management Manual which has been served on the parties. Training required for identified person-nel 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).
L/253CC.13
MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 14.
At a Site Area Energency the plans call for an evacuation of the beach i
area along Ocean Boulevard, from Little Boars Head on the north to Route 286 in j
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 evac-untion; whether the sirens will be utilized in the siren or voice mode or both; whether EBS messages will be broadcast at this 1
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 the Site Area Emergency and beach area evac-untion and, if so, describe how this population will be informed and state what information it will be provided, i
RESPONSE
a.
The northern boundary is in actuality Great Boar's Head rather than Little Boar's Head. This is consistent with traffic control strategy and siren activation for the beach area. The procedures will be adjusted accordingly. The southern boundary is Route 286 as it intersects with Route 1A.
The east-west boundaries of the area in question extend from the Atlantic Ocean to the east, to the end of the barrier island to the west, i.e. it is that area that is serviced by Route 1A for north and south ingress and egress.
b.
The information requested is contained in NHRERP, Volume 1 Section 2.1 and Volumes 4 and 4A, Appendices F and U respectively.
See response to Interrogatory 11 for the specific public address i
- message, i
I L/253CC.14
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MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 response package was not sub-mitted 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 volun-tarily 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 formal response package will be submitted.
RESPONSE
Objection. Why particular things were or were not submitted at a time cer-tain is irrelevant to any contention before this Board, is not likely to lead to the discovery of admissible evidence and therefore not within the scope of discovery under the NRC rules of procedure. Commitment as to future willingness to waive the rules is also not the proper subject of interrogatories.
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L/253CC.15
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 16.
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; 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 IA, 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 pro-vided (a) by KLD to Merrimac Engineering Services, Inc. prior to the counts and (b) to the counting crews themselves by Merrimac Engineering Services; 1.
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).
L/253CC.16
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RESPONSE
a.
The weather is recorded on the audio tapes which have been pro-vided to Mass AG.
Copies of these tapes are available at Seabrook
- Station, b.
Approximately 20 minutes.
c.
There was one person in each. crew. Occupants of cars were observed and recorded onto audio tape. The tapes provide details regarding buses and vans. Vehicle types and license plate numbers and state were also recorded to the extent time permitted, d.
One.
e.
See response to c, above.
f, g.
Refer to tapes for this information.
h.
Applicant will provide any and all written documents retained, for inspection at Seabrook Station.
1.
Reporting consisted of audio tapes.
J.
The person who took the counts traveled by car.
L/253CC.16.1
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 NKRERP), state who conducted these counts and respond accordingly to each subpart of the immediately preceeding interrogatory.
RESPONSE
KLD conducted the counts.
a.
July 4, 1986 was mostly sunny, often quite warm, with some clouds.
July 5 started out partly cloudy and as the day wore on became increasingly so to the extent that the sun was blocked roughly at noon and there was some rain during the afternoon.
For that reason the counts were limited to the morning.
b.
The-counts extended over roughly two hours in each case.
c.
There were two people; one per crew. Each recorded data at different sites over the same time frame.
d.
Two.
i e.
The technique used was to stand by the curb close to the line of cars and look directly into the vehicles as they passed. The observations of car occupancy were recorded on audio tape. All inbound, near lane vehicles (including vans and buses) which passed were counted.
On Ashworth Avenue and on Route 1A which are two lane throughfares, the vehicles in the near lane were counted unless there was a gap in traffic which enabled the observer to j
clearly see the occupants of the vehicle in the far lane.
f.
The Ashworth Avenue site was taken south of Island Path. The Highland Avenue site was taken on its approach to Ocean Boulevard.
l The Route 51 site was taken at its approach to Brown Avenue. The l
Route 1A site was in Salisbury and was taken in front of the main l
parking lot just west of where 1A turns North, while the site on Route 286 was on its approach to Route 1A near the State boundary.
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L/253CC.17
BESPONSE (continued)
The Ashworth Avenue site was on the west side of the street.
Highland Avenue was on the Southwest corner with Ocean Boulevard.
Route 51, likewise, was on the Southwest corner of its intersec-tion with Brown Avenue. Route 1A was on the South side of Route 1A and the Route 286 site was on the Southwest corner of its intersection with Route 1A.
g.
Only inbound traffic was counted.
h.
Does not apply.
1.
Does not apply.
j j
The method of traveling between counting sites was by car, i
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NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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
Please refer to the previous response to the original NASS AG Interrogatory
- 143.
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C MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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.
RESPONSE
Please refer to Applicants' response to the MASS AG Interrogatory #151.
L/253CC.19
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 20.
Describe in detail how the information obtained from state labor agencies (see preceeding interrogatory) was utilized to update the demand esti-nation of employees who work in the EPZ as described on pages 1-3 of Volume 6 of the NHRERP-Rev. 2.
RESPONSE
Refer to the detailed description of the methodology in Section 5 NHRERP Volume'6.
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L/253CC.20
o NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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
Applicants assume the interrogatory refers to the July 4, 1983 aerial pho-tographs. The three aerial photographs are available for review at Seabrook Station. Applicants will aske reprints of these photographs, if possible, at Nass AG's cost.
L/253CC.21
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 22.
Richard Strome, the Director of NHCDA, stated on page 2 of his affida-vit dated March 25, 1987, in support of Applicants' notion for summary disposi-tion 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, popu-lation data (permanent, seasonal, transient), transient dependent population, special needs facilities, schools, employment data, trip generation times, motels / hotels / campgrounds, number of tran-sients per vehicles, and parking capacity of the beach areas? If not, exactly how will 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 Kaltaan 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?
L/253CC.22
RESPONSg 22.
a.
As stated within the cited affidavit by Richard strome, the period of review of the NHRERP is found at Volume 1, p. 3.3-3.
b.
NHCDA.
c/d. NUREG-0654, Appendix 4, page 4-1 states that "the evacuation time estimates should be updated as local conditions change (e.g.,
change in type or effectiveness of public notification system)."
The dynamic nature of emergency response planning is doggedly reiterated in response to this interrogatory. Contact with special facilities, schools, local officials, etc., are ongoing elements of the RERP; information obtained through such contacts as well as the general knowledge of state and local emergency response planners will assist in the identification of changes to local conditions having potential impact to the ETE. The ETE may j
or may not be recomputed, depending upon local conditions.
e.
The ETE was developed in 1985; as such, the data used from the 1981 Kaltaan report was five years old at the time of use. The information contained in the Kaltman report was the most up-to-date information for the specific areas in question available to KLD at the time the ETE was prepared.
Page 2-27 of Volume 6 pro-l vides a general description of the history of the statistics used by KLD. As indicated above, contact with local contacts and
{
facility representatives is an ongoing activity which provides an I
ever-constant refinement of information. This information will be used during the NHRERP review process to determine the impact, if any, to the planning process and required revisions.
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v NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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.
RESPONSE
a.
There is no current plan to file the "next revision."
b.
See subpart (a).
c.
See subpart (a).
d.
See objection to Mass AG Supplemental Interrogatory #15 and subpart (a).
i L/253CC.23
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 current set of EBS messages contained in NHRERP, Rev. 2 were written by planning consultants retained by New Hampshire Yankee who have been identified previously in response to interrogatories submitted by NECNP. The messages were reviewed, critiqued, and put into final form by staff of the New Hampshire Civil Defense Agency.
Dennis S. Mileti played no role in the writing of these messages.
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L/253CC.24 i
- NASS ATTORNEY GENERAL SUPPLEIENTAL INTERROGATORIES TO THE APPLICANTS 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
Not applicable.
t
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L/253CC.1
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NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 Kaltaan report, etc).
RESPONSE
v See Attachment A.
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L/253CC.25
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ATTACHMENT A KLD is now in the process of compiling the statistics which formed the basis for assigning transient vehicles to the various centroids. When completed KLD will send this information to Seabrook Station where it can be reviewed.
At this time the following data have been compiled for these centroids representing the beach areas for Scenarios 1 and 2:
Community Centroid Permanent + Transient Total Capacity
=
Newbury 2082 100 944 2104 7
372 1423 Newburyport 2081 208 944 1152 315 2260 2575 2830 Salisbury 2093 81 3519 2094 192 3792 2095 192 288 465 7599 8064 8060 Hampton 2105 230 6070 2106 115 1313 2107 115 173 2108 236 882 696 8438 9134 9070 North Hampton 2054 82 158 2109 140 180 222 338 560 600 Rye 2036 240 8
2110 244 80 2111 244 1195 2112 244 580 972 1863 2835 2260 253CC.25.1
a ATTACEMENT A (cont)
All of the centroid loadings were based on:
o Estimated parking capacities at the beaches o
Estimates of permanent residents in the " beach area".
The last column is taken from Volume 6. NHRERP, page E-5.
Differences between the last two columns represent:
Plum Island: We felt that, upon review the 2830 estimate was overstated. See first paragraph on p. E-5.
Salisbury Round-off.
Hampton/
Small allocation differences. The suas are 9694 vs.
N. Hampton 9670.
Rye A significant percentage of permanent residents live near, but not on, the " beach area" and these centroids are loaded with both " beach area" vehicles plus "near beach area" vehicles.
All other transient loading reflects the Kaltaan data, somewhat modified:
See Section 6.
Since the Kaltaan data was shown in sector cells (i.e. In the form of " roses") this data had to be assigned to " nearby" centroids which accessed elements of the evacuation network. KLD is currently drawing up a table relating these sector data and their associated centroid loadings l
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NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 26.
For each centroid noted above for which the number of transient vehicles came from the beach area vehicle count, defined precisely the geographic area for which, using aerial photos or slides, vehicles were counted and allocated to that centroid.
RESPONSE
See Attachment A.
t L/253CC.26
u MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 ETEs which KLD has calculated for Seabrook's EPZ.
RESPONSE
Mass. AG previously requested copies of the computer tapes of all the sen-sitivity and ETE runs conducted by KLD. Applicants made the copies. When Applicants informed Mass. AG the copies were ready, he insisted that in view of his decision to go to KLD's office and use the originals, he did not want all the copies. Applicants stand ready to deliver whatever copies Mass. AG unequi-vocally orders.
L/253CC.27
4 MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 28.
KLD computed the Seabrook ETEs on a stand-alone version of the IDYNEV.
computer model, which was developed by KLD under a contract with FEMA. The ver-sion 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 office 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 ETEs contained in Volume 6 of the NHRERP-Rev. 2.
RESPONSE
Applicants object and repeat what Mass. AG has been told before:
Applicants and KLD Associates do not own the model and cannot reproduce and disseminate it on demand.
L/253CC.28
4 NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 29.
Volume 6, pp. 3-9, of NHRERP-Rev. 2, lists the 2-way and 1-way capa-city estimates for_the four road type categories (low design, medium design, high design, and limited access) used in the evacuation model. Appendix N pre-sents 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 evac-untion network is limited by road capacity or intersection capacity.
Please produce a list that indicates the road type category for each link in the evac-uation network and classifies each link as being roadway-capacity limited or downstream-capacity limited.
RESPONSE
KLD has provided access to the model which includes the output generated by IDYNEV. This output identifies, for each link, the value of mean headway.
This value of mean headway can then be compared with the values of " equivalent head-way" associated with each road type as documented on page 3-9 Volume 6.
The influence of intersection capacity on link capacity is indicated by the effec-tive green / cycle time ratios which are also specified as part of the input stream. Those links for which this ratio is unity, or for which no control is indicated, have capacities which are defined by its road capacity. On the other hand, if a ratio other than unity is specified, then the effective capacity is the roadway capacity multiplied by the ratio.
L/253CC.29
- o NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 30.
With respect to the agreement by Teamsters Local No. 633 of New Hampshire to provide emergency workers and drivers in the event of a radiologi-cal 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 otherwise obtain the Union's Letter of Agreement.
b.
State what compensation, if any, individual teamsters were pro-mised they 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?
c.
Produce copies of all other correspondence you have received or sent to the Teamsters Local No. 633 in 1986 and 1987.
RESPONSE
a.
Applicants have no knowledge of such letters or documents, b.
Applicants are not aware of the compensation arrangements between Teamsters Local 633 and the State of New Hampshire.
c.
Applicants have not corresponded with the Teamsters Local No. 633.
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NASS ATTORNEY GENERAL SUPPr.mntwTAL INTERROGATORIES TO THE APPLICANTS 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 referenced 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.
RESPONSE
a.
The First Market Research survey.
b.
See response to Interrogatory number 43 of Mass AG.
c.
None d.
Not applicable.
L/253CC.31
o NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 32.
Nhen 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
No.
1 L/253CC.32
C NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO TNE APPLICANTS 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.
', RESPONSE Yes.
L/253CC.33
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C MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 34.
Assuming a rapidly developing accident with release of offsite radiation and meteorology 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 evac-uation 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, n.
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 ETE is a decision-making tool to be used in determining the most effec-tive public protective measure and as such does not consider doses to the public.
L/253CC.34
l NASS ATTORNEY GENERAL SUPPLEIENTAL INTERROGATORIES TO TNE APPLICANTS 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 thun-derstorm 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.
RESPONSE
No.
L/253CC.35
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MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 36.
Is it your position that In the event of a rapidly developing acci-dent 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
Yes.
L/253CC.36
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u NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 NHRERP provides for the protective action option of sheltering for all segments of the population within the EPZ as a function of accident conditions.
Time of year does not preclude selection of the protective action option of sheltering.
L/253CC.37
C MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 potential radiation doses would not be below the whole body or thyroid protective action guide?
Please explain.
RESPONSE
Applicants agree with the State of New Hampshire response to TOH Interrogatory 7 because it reflects what the NHRERP, Revision 2 provides.
The State of New Hampshire response did not assume that potential radiation doses would not be below the whole body or thyroid protective action guide; therefore Applicants cannot say what their response would be because such an assumption would necessarily have to consider all the factors explicated in NHRERP, Volume 1, Section 2.6-7 and Volumes 4 and 4A, Appendices F and U respectively.
L/253CC.38
MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 39.
Is it your position that in the event of a beyond design bases acci-dent, 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
Applicants object to this interrogatory. The NRC's Severe Accident Policy Statement " explicitly removes plant-specific reviews of severe accident vulner-abilities as a necessary or routine part of an Operating License review,"
Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2),
ALAB-819, 22 NRC 681, 095, 697 (1985), Aff'd, CLI-86-5, 23 NRC 125 (1986);
Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants, 50 Fed. Reg. 3218 (August 8, 1985).
Further, this interrogatory is irrelevant since the planning basis is inde-pendent of specific accident sequences. The Applicants refer the Massachusetts Attorney General to the ASLB's rejection of its contention in the April 29, 1986 ASLB Memorandum and Order which further detail the basis for the Applicant's objection, i
L/253CC.39 l
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 40.
Please provide the basis for your response to the previous interroga-tory and all documents on which you rely to support that response.
RESPONSE
See response to Interrogatory 39.
I L/253CC.40
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS l
s.
41.
With respect to the on-foot survey identified by Applicants in response, dated Narch 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:
l c.
provide the date(s) and time (s) of day that such survey was performed; 1
d.
provide all documentation, notations, writings, and recordings of, or relating to, such survey.
i
RESPONSE
a.
Mr. Ed Lieberman, KLD Associates, performed the survey.
b.
The survey was performed in sets of samples in different loca-tions.
Each sample size was at least 30 homes, and was generally larger.
The locations included residential areas in Hampton and Seabrook beach areas, c.
This survey was conducted in late August of 1985. The times of day were late morning and afternoon, d.
The documentation was taken by pencil on note paper and then the average value was documented in NHRERP, Volume 6.
The original note paper was not retained.
L/253CC.41
1 MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 42.
In response, dated March 18, 1987, to SAPL Interrogatory No. 5, Applicants state "the estimate for Item d, namely transients, was obthined by assuming that the available parking capacities in the beach area was completely filled 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.
RESPONSE
Please refer to our previous response to NASS AG Interrogatory #137. The working sheets used in the original data take off have not been retained.
L/253CC.42
NASS ATTORNEY GENERAL SUPPLE 8 ENTAL INTERROGATORIES TO THE APPLICANTS 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 EPZ7
RESPONSE
Yes.
l L/253CC.43
. _ _ _ _ _.. _ ~,. _ _
_ _ _ _ _ _ _. _ _ _. ~. - _ _., - - _ _ _ _ _ _ _ _
NASS ATTORNEY GENERAL SUPPLDENTAL INTERROGATORIg8 TO TWE APPLICANTS 44.
If the entire transient summer beach population is directed to shelter at a time when beaches are at or near capacity, please stater 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 populations 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.
RESPONSE
n.
No time estimate for implementation of sheltering has been done because such an estimate is not required by regulations and planning guidance.
It is normally assumed that sheltering can be implemented faster than evacuation.
b.
General sheltering instructions are contained in NHRERP, Volume 4 Appendix 0.
In accordance with Appendix 0, these instruction may be modified to provide specific instructions to any segment of the population, c.
Instruction to shelter would be given to the beach population via EBS.
i L/253CC.44
NASS ATTORNEY GENERAL SUPPLEIENTAL INTERROGATORIES TO TNE APPLICANTS 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 sheltering capacity for the transient population in each New Hampshire beach area in the Seabrook Station plume exposure EPZ (with shelters having a minteel shielding factor of.8 for cloud shielding and.4 for ground shielding) is 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.
This study has been served on the parties to this proceeding.
I e
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4 I
L/253CC.45
NASS ATTORNEY 05 NEPAL SUPPLEIENTAL INTERR0GATORIES TO TWE APPLICANTS 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 provides a.
where the campers will be instructed to shelters b.
how they will be instructed to shelters c.
the instructions that will be given to campers:
d.
where in NHRERP. Rev. 2. such provisions for campgrounds can be founds and e.
Whether there are any plans to supplement or revise the NHRERP in any manner with respect to provisions for sheltering persons at campgrounds.
RESPONSE
The NHRERP. Revision 2. Volume 1. Section 2.6.5 provides for persons in campgrounds to be instructed to leave the area in the vehicles in which they arrived in the event any protective actions are recommended.
L/253CC.46
NASS ATTORNEY GENERAL SUPPLEMNTAL INTERROGATORIES TO TNE APPLICANTS 47.
Are you familiar with the methodology utilized by N. Kaltaan 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.
RESPONSE
Yes. The Applicants' understanding of the methodology used by Kaltman is that which is described in the "Kaltman" report. The Applicants have no other source of information regarding the methodology used.
1 L/253CC.47
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO TNE APPLICANTS 48.
What do you currently believe to be the current number of:
a.
Hotel rooms in the New Hampshire portion of the EPZ?
b.
Notel 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.
MESPONSE Applicants have no " current belief" as called for in the interrogatory as to the number of hotel and motel rooms beyond that set forth in Volume 6 of the NHRERP. With respect to campgrounds, the number of spaces is 1889. The source of this information is a preliminary survey entitled " Campground Maximum Capacities".
l L/253CC 48 l
i
MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 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 person (s) 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 con-sulted with, state for which shelters the owners were, or were not, consulted withs 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.
RESPONSE
a.
The study was performed by Donald W. Bell, Senior Nuclear Technology Engineer, Carolyn Burns, Nuclear Technology Scientist, Wu-Hung Peng, Nuclear Technology Engineer and Certified Health Physicist, and Nader Sarivar-Sadri, Senior Nuclear Technology Scientist, of the Stone & Webster Engineering Corporation, b.
The study at page 3 says that each building was visually inspected. At page 4 the study says "Each potential shelter listed was visited by a health physicist who estimated structure-specific cloud and ground shielding factors".
L/253CC.49
RESPONSE
(continued) f
- g c.
Owners of potential shelters were not consulted.
e d.
It was not the purpose of the study to obtain agreements from owners of structures that were evaluated; therefore, none were
- obtained, i,
~
e.
As noted in the study, shelter capacity was determined by deriving available floor space from tax assessment cards and from visual J-inspection of the structures.
f.
Page 4 of the study notes that the health physicist estimated the shielding factors using reference 3 as a guide. Reference 3 is identified on page 8 of the study, a
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L/253CC.49.1
__ 4 NASS ATTORNEY GENERAL
\\s sSUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 Evaluationj, it is stated that the use of a voice
\\
,;?
message for notification is inappropriate in the beach areas.
Please describe:
t (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.
\\
RESPONSE
s The statement attributed to IRT-030 is taken out of context. The referenced iten goes on to recommend the use of a signal tied to posted signs with instruc-
,tions.
NHRERP, Volume 1, Section 2.1 at page 2.1-14 addresses this recommen-dation by providing for a CD alert signal to be sounded over the siren system.
NHRER,Vofume1,Section2.3providesforsignstobepostedinrecreational areas providing instructions on what to do when the alert signal is sounded.
The voice message would be used to provide additional instructions, and is not inappropriate for th'is purpose.
V 7
w, L/253CC.50
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NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATGRIES TO THE APPLICANTS 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
The IRT-030 notes no deficiencies.
Section 2.7 of the report notes recom-mendations for off-site emergency planning, all of which have been considered in development of NHRERP Revision 2.
l 4
L/253CC.51
MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 52.
With respect to summer residents who inhabit unwinterized accom-modations 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 in the 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.
RESPONSE
a.
Provisions for sheltering residents of unwinterized accommodations 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 N'tSERP, Volume 4, Appendix G.
c.
If such persons are advised to shelter, they will be advised to shelter in place.
L/253CC.52
NASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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 instruc-tions? What percentage of the evacuees do you expect will comply?
RESPONSE
The NHRERP does not provide for instructing the general public to report to reception centers. The affected population would be advised of the location of reception centers, of directions to them, and of the services available to them.
The NHRERP conforms to the guidance of FEMA memorandum from Richard W. Krima to FEMA Regional Offices and Natural and Technological Hazards (NTH) Division Chiefs, dated December 24, 1985, entitled " Guidance on NUREG-0654/ FEMA-REP-1 Evaluation Criteria J-12".
L/253CC.53
MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 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.
L i
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s L/253CC.54 i
... _ -,. _ _,. _ - - _ _ _ _ -. -,., ~, _ _...
MASS ATTORNEY GENERAL SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 55.
In the event of an accident with a wide-spread offsite release of radiation, if all persons instructed to report to reception centers for moni-toring do so report, could a bottleneck be created at the entrance to such reception 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.
RESPONSE
See response to Interrogatory 53.
Sensitivity studies of impact of potential bottlenecks at reception centers on ETE have not been performed, nor are they required by regulation or planning guidance.
L/253CC.55
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 1.
In accordance with 10 CFR 2.740(e), please supplement your answers to NECNP's previous sets of interrogatories, filed April 30, 1986, and March 5, 1987.
RESPONSE
See " Applicants' Supplemental Responses to First Set of Intervenor Interrogatories" filed herewith.
L/254CC.1
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 2.
Please identify and produce all documents on which you rely or intend to rely during this proceeding to support your position on each of the conten-tions that have been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan. This includes but is not limited to all documents used in answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings.
RESPONSE
See " Applicants' Supplemental Responses to Intervenor Interrogatories" filed April 24, 1987, at 1-4 and " Applicants' Supplemental Responses to First Set of Intervenor Interrogatories" filed herewith.
1 f
L/254CC.2
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 3.
Please identify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to rely for your position on each of the contentions that have been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan.
RESPONSE
See Applicants' response to NECNP's original Interrogatory 4.
L/254CC.3
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 4.
Please identify all persons you may call as witnesses on each of the contentions that have been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan.
Please describe the substance of their testimony and identify and describe any documents and the portions thereof that they may rely on for their testimony.
RESPONSE
Applicants object to this interrogatory insofar as it calls for the iden-tification of non-expert witnesses. Applicants incorporate by reference their response to Mass. A.G.
Interrogatory 5 (set 2).
Applicants further object to so much of the NECNP's Interrogatory 4 as requests Applicants to state their position in regard to other Intervenors' contentions.
Insofar as this interrogatory calls for the identification of expert wit-nesses, as regards the following contentions, Applicants incorporate by reference their answer to Mass. A.G.
Interrogatory 4 (set 2):
l TOH Revised Contention III l
TOH Revised Contention VI l
TOH Revised Contention VIII l
NECNP Contention RERP-8 l
L/254CC.4 l
t
RESPONSE
(continued)
As tegards the remainder of NECNP's contentions, in accord with 10 CFR
$2.740(e), Applicants' answer as follows:2 (a) As regards NECNP Contention No.
NHLP-6, Applicants at this time intend to offer a panel of witnesses which will include: Richard H. Strome and Anthony M. Callendrello.
The substance of the testimony of the panel at this time as regards NECNP Contention No. NHLP-6 is provided in Applicants' Motion for Summary Disposition of NECNP Contention NHLP-6 (March 25, 1987),
b.
As regards TOH Revised Contention No. IV. Applicants at this time intend to offer panels of witnesses which will include:
Richard H. Strome and Anthony M. Callendrello. The substance of the testimony of the panels at this time as regards TOH Revised Contention IV is provided in Applicants' Motion for Summary Disposition on Town of Hampton Revised Contention IV (March 25, 1987),
2 The Applicants' response is based on its present intention which is subject to change.
L/254CC.4.1
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 5.
In your response to Massachusetts' first set of interrogatories, Interrogatory 141, you stated that the estimate of 2.4 persons / vehicle for beach area traffic was developed from onsite surveys.
Please identify, describe, and provide access to those surveys, and state the date(s) that these surveys were performed.
RESPONSE
On page 4-8 of Volume 6 of the NHRERP we describe the data taken on the July 4th weekend in 1986 and indicate that " based on this data we will adopt an esti-mate of 2.4 persons per vehicle...".
See also the botton 6 lines in Table 4-1 on page 4-7.
L/254CC.5
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 6.
In your response to Massachusetts' first set of interrogatories.
Interrogatory 141, you stated that estimates of 1.16 persons / car for employees is based upon census data.
Please identify, describe, and provide access to that data.
RESPONSE
See the next to the last column on page H-2 in Appendix H of Volume 6 to the NHRERP.
l l
L/254CC.6 i
i
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NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 7.
In your response to Massachusetts' first set of interrogatories, Interrogatory 138, you stated that the basis for population figures in the New Hampshire RERP include " telephone requests to NH Labor Services and Employment Bureau, U.S. Census Bureau." Please describe the date of these contacts, the individuals and offices contacted, and the specific information obtained through the contacts.
In addition, please identify and describe all documents that were generated by these contacts.
RESPONSE
These contacts were made during Autumn. 1985.
Information is in Volume 6 of the NHRERP. No notes were retained, and further, no answer is possible to the remainder of the interrogatory.
L/254CC.7
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 8.
Please describe the dates on which Applicants' consultants prepared the " Personnel Resources Assessment Summary Developed in Support of Motions for Summary Disposition" (hereafter " Personnel Summary").
RESPONSE
April 1-10, 1987.
L/254CC.8
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 9.
Please identify all individuals who participated in the preparation of the Personnel Summary.
RESPONSE
The following individuals working for or under the direction of the Applicants participated in the preparation of the Personnel Summary.
Public Service of New Hampshire Anthony M. Callendrello, Manager of New Hampshire Yankee Division Emergency Planning Seabrook Station Education Center P.O. Box 300 Seabrook, NH 03874 Aldikoff Associates John Baer, Technical Consultant 107 Barry Lane William Renz, Technical Consultant Syosset, New York 11719 Mike Sinclair, Technical Consultant Schneider/EC Planning & Management William Dunlap, Sr. Consultant 2101 No. Front Street Joseph Enoch, Emergency Planner Riverside Office #3 Chester Lloyd, Emergency Planner Harrisburg, Pennsylvania 11710 John Spead, Emergency Planner Trainer 1 Kathy VonWald, Emergency Planner Impell Corporation Craig Starkman, Lead Senior Engineer 225 Broad Hollow Road Melville, New York 11747 Ebasco George Willant, Principal Plantier 160 Chubb Avenue Lesley Tilston, Assc. Environmental Planner Lyndhurst, New Jersey 07071 L/254CC.9
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 10.
Please identify and provide access to all documents generated by or relied upon during the Applicants' personnel review.
RESPONSE
Listings of documents relied upon in the development of personnel resource assessment summary served on the parties are provided within the summary. These documents have previously been made available for inspection.
L/254CC.10
i NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 11.
For each town studied, please identify all positions for which the reviewers determined that 24-hour staffing was required, as discussed at page 2-1 of the Personnel Summary.
Please provide access to all supporting documents.
RESPONSE
All emergency response positions determined to require 24-hour staffing are shown on the organization chart provided in the Personnel Summary for each town studied.
24-hour positions are marked with an asterisk. The supporting docu-ments consist of the NHRERP itself and the procedures incorporated therein.
L/254CC.11
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 1
12.
For each town studied, please identify all positions for which the
- reviewers determined that 24-hour staffing was not required, as discussed at page 2-1 of the Personnel Summary.
Please provide access to all supporting documents.
RESPONSE
Emergency response positions not requiring 24-hour staffing are shown on the organization chart provided in the Personnel Summary for each town studied.
Positions requiring 24-hour staffing are marked with an asterisk. Positions not requiring 24-hour staffing are unmarked. The supporting documents consist of the NHRERP itself and the procedures incorporated therein.
L/254CC.12
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 13.
Please identify and describe all personnel surpluses in the overall offsite emergency response organization, as discussed on page 2-3 of the Personnel Summary.
RESPONSE
Personnel surp'.uses are identified in the matrices included in the Personnel Summary providing proposed assignments of personnel for the towns studied.
l L/254CC.13
. _ _ ~ - - -, _.
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 14.
Please identify and describe all personnel surpluses in the specific emergency response organizations, as discussed on page 2-3 of the Personnel Summary.
RESPONSE
Personnel surpluses are identified in the matrices included in the Personnel Summary providing proposed assignments of personnel for the towns studied.
l 4
L/254CC.14
=. - - _.
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 15.
Please describe any plans for a recruiting program, as discussed on page 2-3 of the Personnel Summary.
RESPONSE
1 It is Applicants' position that, based upon the Personnel Summary, adequate personnel resources are available to implement the local RERP. Therefore, at this point in time, no plans to implement a recruiting program exist.
I L/254CC.15 i
NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEIENTAL INTERROGATORIES TO THE APPLICANTS 16.
Please identify all plans for continuing work on the " program," as discussed at page 2-3 of the Personnel Summary. Have these plans been implemen-ted? If so, how and when.
Please identify and provide access to all documents that reflect continued work or plans for continued work on the " program."
RESPONSE
It is Applicants' intention to continue to provide support to the State of New Hampshire with respect to the personnel resource assessment program in order to ensure the availability of personnel resources within the various state agencies and supporting organizations and within the local municipalities. This includes maintaining an open dialogue with key persons from various organiza-tions so that any pertinent information on personnel availabilities may be incorporated as it is made available.
i L/254CC.16
r NEW ENGLAND COALITION ON NUCLEAR POLLUTION SUPPLEMENTAL INTERROGATORIES TO THE APPLICANTS 17.
Please provide the names, titles, and work and home addresses of all personnel who are listed as "Available" in Table 3.1-3, entitled " Overview of Personnel Requirements for State Agencies Required to Assist Municipalities Unable to Respond to an Emergency," Section 3 of the Personnel Summary, page 1 of 3.
For each individual identified above, please provide the following information:
a.
Has that person been assigned to a specific local emergency response function? If so, what are his or her responsibilities?
b.
Has that individual been informed of his or her responsibilities during a radiological response at Seabrook? If so, how was he or she informed?
c.
Has that individual consented to carry out his or her respon-sibilities?
If so, how was the consent obtained?
d.
Please identify those individuals who have been trained for an emergency response, and state when that training took place and by whom the training was conducted. Was the training focused on the individual's specific responsibilities?
RESPONSE
Objection. This question seeks a level of detail not required by the regu-lations or NUREG-0654. The pools which will be drawn upon are listed in the NHRERP Volume 2 Appendix G.
No more is required.
L/254CC.17
SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLICANTS GENERAL INTERROGATORIES C.
For each witness identified in response to the prior-flied 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 witnesses were identified in response to prior filed general interroga-tories. See also " Applicants' Supplemental Responses to First Set of Intervenors' Interrogatories" filed herewith, i
L/255CC.C
7-SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLICANTS GENERAL INTERROGATORIES 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 served on the parties to this proceeding.
RESPONSE
No changes are being made to Revision 2 at this time.
Commitments to revise the plan will be based upon RAC acceptance of the State of New Hampshire's responses to the RAC comments as well as any commitments resulting from the hearing process. Service upon the parties will depend upon the status of the proceedings at the time the changes are made.
L/255CC.D
SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLICANTS SPECIFIC INTERROGATORIES 58.
Describe the area surveyed in the on-foot survey, how many surveyors conducted the survey and time of day of the survey referenced in answer a to SAPL Interrogatory 83.
How many dwellings total were included in the survey?
RESPONSE
See Applicants' answer to Mass AG Supplemental Interrogatory #41.
A minimum of 120 total dwellings were included in the survey.
1 i
L/255CC.58
. SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLI(MNTS SPECIFIC INTERROGATORIES 59.
In conducting its " empirical observation of the number of vehicles which can physically be accommodated within the beach area," what area did KLD include as in the " beach area"? Was Wallis Sands State Park included? Was Odiorne Point State Park included? Was Jenness Beach included? Was North Hampton Beach State Park included?
RESPONSE
The entire length of the coastal region extending from Plum Island, Mass, on the south to the town of Rye, NH on the north. The beaches and parks cited were all included.
t I
L/255CC.59
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'i SEACOAST ANTI-POLLUTION LEAGUE
.c, INTERROGATORIES TO THE APPLICANTS SPECIFIC INTERROGATORIES
+
,4 60.
State the location for each of the 17 New Ilampshire municipalities where traffic control devices will be stored. Also state the locations of 1 Department of Transportation garages near or within the EPZ as per Applicants' response to SAPL Interrogatory #23.
RESPONSE
Applicants defer to the response of the State of New Hampshire to SAPL
(* ~
Interrogatory No. 57.
5 1-l L/255CC.60
SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLICANTS SPECIFIC INTERROGATORIES 61.
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 liaison to travel from home to the IFO.
RESPONSE
The assignment of local liaison personnel for each of the 17 local com-munities may be dependent on plume movement, arrival time of the liaisons at the IFO and other factors and will be made at the time of an emergency response.
The arrival time of local liaison to the Incident Field Office is estimated to be approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
L/255CC.61 m i e-r--
+
SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLICANTS SPECIFIC INTERROGATORIES 62.
Which two host care facility letters of agreement for special facili-ties are still missing (see SAPL Interrogatory #50)?
RESPONSE
There are no host health care facility letters missing. All such letters which are required have been obtained.
L/255CC.62
SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLICANTS SPECIFIC INTERROGATORIES 63.
State the names and qualifications and training of those individuals who performed the dose reduction effectiveness calculations for special facili-ties in the EPZ.
Detail the methodology they employed in performing their calculations,
RESPONSE
The persons who performed the dose reduction effectiveness calculations for special facilities cited in Table 2.6-3 of NHRERP, Volume 1, Section 2.6 are John F. Long and Mario Vigliani, both of whom were retained as consultants by New Hampshire Yankee during preparation of NHRERP, Revision 2.
The qualifica-tions of Mssrs. Long and Vig11ani are attached. The methodology employed in performing calculations is contained in the document " Structure Shielding from Cloud and Fallout Gamma Ray Sources for Assessing the Consequences of Reactor Accidents," EG&G, Inc., Las Vegas which has been made available in discovery.
The forms used for collection of data for each facility have also been made available in discovery.
L/255CC.63
Mm SCHNEIDER Resume current 07-09-56 EC Pfanning and Afanagement Services JOHN F. LONG, JR.
Education 1976 8.S., Biological Health (with Honors)
The Pennsylvania State University University Park, Pennsylvania Experience 4/82 to Present Schneider/EC Planning & Management Services Harrisburg, Pennsylvania Project Manager.
Responsible for providing supervision and direct technical assistance to project staff.
Assigned program responsibility for emergency manage-ment planning, procedure preparation, personnel train-ing, drill and exercise preparation, ifcensing support and scheduling project work consistent with client objectives.
Recent project assignments have included:
- managing project staff charged with development of local and state radiological emergency response plans and procedures for five towns and one city within the Seabrook Station plume EPZ and surrounding support and mutual aid areas and organizations for the Massachusetts Civil Defense Agency.
Activities included extensive interface between MCDA and Seabrook Station emergency preparedness staff;
- managing the offsite radiological emergency prepared-ness program for the Peach Bottom (Pennsylvania)
Atomic Power Station including revision / development of radiological emergency response plans for counties, municipalities, school districts and health care facilities located within the plume exposura pathway emergency planning zone, the design and presentation of training and orientation programs for emergency response personnel and emergency management officials inChester,LancasterandYorkCounties(Pennsylvania) and Cecil and Harford Counties (Maryland), exercise preparations and post-exercise critique; "ItoWr* t$tmt S' " '
NemsDurg, PA til10 (7171236 0031 4 Meneer of ame $cmessor Group of Cwwenes
..~...
J:hn F. Long, Jr.
Page 2
- support to the offsite radiological emergency pre-paredness program for the Limerick (Pennsylvania)
Generating Station including lead planning assignments for development of radiological emergency response plans for health care facilities (three hospitals and seven nursing homes) located within the plume exposure pathway emergency planning
- zone, development of emergency response training programs for health care faci'ity staff and administration, development of the Berks County (Pennsylvania) radiological emergency response plan, development of standard operating procedures and functional implementing procedures, and presentation of radiological emergency training and orientation programs for county EOC personnel and emergency workers;
- support to a study of the one y management systems of member casuunities for the tre Reg <on Council of Governments (Centre County, Pennsylvania).
Responsi-bilities included site visits to member municipalities to determine the status of existing emergency manage-ment programs, survey development and interviews of involved parties, preparation of a status report on the existing emergency management system within the region, and assistance in the development of a final project document outlining a regional approach to local emergency management including a prototype regional all-hazards emergency plan; and
- support to the Monroe County (Michigan) radiological emergency preparedness effort including the develop-ment of the school services annex and school services implementing procedures to the Monroe County radio-logical emergency response plan the development of radiological emergency response, plans for public school districts located within the plume exposure wthuey emergency planning zone of the Fermi-2 Atomic Power Station and the properation of responses to contentions concerning the adequacy of the Monroe County radiological emergency response plan.
5/78 to 4/82 SEDA - Council of Governments Lewisburg, Pennsylvania Program Manager. Responsibilities included the develop-ment and management of human service programs for the Appalachian Regional Consission in a rural eleven-county district; proposal preparation and grants management for public health, environmental health, primary health care, emergency medical services, child development and education projects; development, proposal preparation
John F. Long, Jr.
Page 3 and staff support to a project assessing health impacts of energy development within Central Pennsylvania; and assistance in management of a regional public safety t
communications pro;ect including the development of emermacy communications centers in several counties lack'ng centralized emergency management functions.
7/67 to 5/78 Minersv111e Area Medical Center Minersville, Pennsylvania Administrator / Project Director.
Responsibilities included overall project management for a rural primary health care center.
Activities included the devel-opment, construction oversight, funding, staffing and actual management of the center.
Continuing Education Personnel Management. Capitol Campus, The Pennsylvania State University, 1975 Accounting Schuylkill Campus, The Pennsylvania State University, 1977 Health Center Management, U.S. Public Health Service, Leesburg, Virginia, 1977 Basic Emergency Management, Federal Emergency Management Agency, 1982 i
j Radiolo Agency,gical Monitoring, Federal Emergency Management 1983 Radiological Monitoring / Decontamination Monitoring, i
Pennsylvania Emergency Management Agency, 1984 Instructer's
- Course, Radiological Monitoring /Decon-tamination Monitoring, Pennsylvania Emergency Management Agency, 1984 Instructional Systems Design Certification Program,1984 l
Fundamentals Course for Radiological Response Teams, 1
Pennsylvania Emergency Management Agency, 1985 Related Activities Conducted disaster preparedness seminar and field
- exercise, Susquehanna Valley ENT Association, 1983
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J::hn F. Long, Jr.
Page 4 Guest lecturer, Harrisburg Area Comunnity College, program in Emergency Medical Services Administration, 1984 Certifications Emergency Medical Technician, Pennsylvania Department of Health, 1978-1981 Radiological Monitor, Pennsylvania Emergency Management Agency, 1984 Radiological
Response
- Team, Pennsylvania Emergency Management Agency, 1985 Radiological
Response
Team Instructor, Pennsylvania Emergency Management Agency,1985.
F 7
MARIO A. VIGLIANI Ecucation Raciological Health Physics, University of Lowell, 8.S.
1983.
M.S.
Raciological Sciences anc Protection, University of Lowell, in arcgress.
i Summary of Expe rience Mr. Vigliani specializes in Health Physics / Radiation Protection.
Since joining HMM, ne nas oeen involvec in a variety of emergency planning activities inclucing the oevelopment of emergency plan implementing procecures for an onsite emergency resoonse organization and the covelopment of plans anc proceoures for state ano local governments, as well as for other of f site response agencies.
He has also been a participant in ene cavalopment of evacuation time estimates.
[ 7f essional Experience 1983 -
HMM Associates, Principal Engineer and Health
- Present Physicist.
j c
For Puolic Service Company of New Hamosnire, ceveicoec lesson plans related to local clan anc oracecure training fer seventeen local governments witnin the Seacrock EPZ; anc particioated in the coveicoment cf a secarate set of seven 1esson plans for training State emergency workers in ene uses of tne New Hampsnire State Emergency Response Plan and Checklist Procedures.
{
Also fCr Public 5ervice Company of New o
Hampshire, precarea incivioual City / Town i
Raciological Emergency Resconse Plans for j
seventeen ccemunities in the Seabrook EPZ, as well as Nest Alans for six other municipalities.nien are assignated as host communities in ene event of an evacuation l
of the Seacrcok EPZ.
For New Hampsnire Civil Defense Agency, o
performeo a sneltering/snielcing analysis of ten nealth care facilities located within ene Seacrook Emergency Planning Zone to cetermine each facility's raciological sneltering effectiveness.
This study will ce useo curing emergencies anc provides the Il 1
1 r
MARIO A. VIGLIANI 7
Page 2 l.-
State with the necessary criteria for deciding, on a case-by-case easis, whetrer sneltering or evacuaticn will ce the sopropriate Protective Action for each cf enese facilities.
4 For Puolic Service Indiana's Marele Hill o
Nuclear Generating S tation, preparec emergency plan isolementing procedures pertaining to:
offsite/onsite sampling, i
monitoring, cecontamination, protective action guicelines, emergency exposure guicelines and related areas.
He nas also i
participates in offsite planning relateo te EPZ eoucation in Indiana.
j For Clevelano Electric Illuminating Com-o cany's Perry Power plant, consumer Power Company's sig Rock Point Power Plant ano Philacolonia Electric Company's Limerick Generating Station, participated in the develcoment of evacuation time estimates.
1982 University of Lowell, Lowell, M A.
Health Pnysics Tecnnician.
At the University of Lowell 1MW researen reactor f acility, performed radiation and contamination surveys, instrument calibrations low level waste 2
cackaging and volume rec,uction, and cata cocumentation in accoroance with NRC requirements for nuclear facilities.
Assisteo in student training certaining to raciation protection.
Professional Affiliations Health Physics Society American Nuclear Society i
i N 11/44 l
lb i
SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLICANTS SPECIFIC INTERROGATORIES 64.
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 allotted within the community.
RESPONSE
Applicants defer to the State of New Hampshire's response to their supple-mental interrogatory SAPL No. 60.
L/255CC.64
SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLICANTS SPECIFIC INTERROGATORIES 65.
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
Applicants defer to the State of New Hampshire's response to their supple-mental interrogatory SAPL No. 61.
L/255CC 65
SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO TNE APPLICANTS 1
SPECIFIC INTERROGATORIES 66.
For each of the six towns dealt with in the " Personnel Resource Assessment Summary Developed in Support of Motions for Summary Disposition,"
list the names of the " persons knowledgeable about the specific town" referenced at p. 2-2 with whom surveys were conducted to verify and adjust the numbers of required and available personnel resources.
RESPONSE
For each of the six towns dealt with in the Personnel Resource Assessment Summary, the New Hampshire Civil Defense Field Representatives from whom inform-ation was obtained are:
o Town of Hampton Falls - Mr. David Deans o
Town of Rye - Mr. Michael Poirier o
Town of Kensington - Mr. Robert Pariseau o
Town of South Hampton - Mr. Robert Pariseau o
Town of Hampton - Mr. David Deans o
Town of North Hampton - Mr. David Deans Information regarding personnel resources of the towns gathered during the performance of the Field Representatives' normal job duties was used in addition to available documentation in formulating availabilities of town personnel. The position of Civil Defense Field Representative includes becoming knowledgable about assigned local municipalities as part of its responsibilities.
L/255CC.66
RESPONSE
(continued)
For the towns of South Hampton, Hampton and North Hampton, verification and adjustment of the numbers was based on the public documentation cited in the summary interviews with the above NHCDA Field Representatives, the represen-tatives from local towns and other organizations, as listed below:
o Town of South Hampton Mr. M. Santosousso, Selectman and Civil Defense Director o
Town of Hampton Mr. A. Kuncho, Fire Chief Mr. R. Mark, Police Chief Mr. D. Pelletier, Police Department Mr. P. Richards, Civil Defense Director Sgt. Barnard, Police Department Mr. J. Hangan, Public Works Mr. D. Kalway, New Hampshire State Police o
Town of North Hampton Mr. B. Golden, Police Chief Mr. Goodwin, Fire Chief Mr. R. Strout. Highway Agent Mr. R. Wells, Highway Department Det. Blanchard, Police Department For the towns of Hampton Falls, Rye and Kensington verification and adjust-ment was based on information provided by NHCDA Field Representatives and the public documentation cited in the summary.
L/255CC.66.1
SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLICANTS SPECIFIC INTERROGATORIES 67.
Are identification checks to be done at Access Control Points for determining whether vehicles will be allowed into the EPZ in the event an evac-untion is in progress? Nhat is the estimated time per vehicle for performance of such an identification check?
RESPONSE
Access back into the EPZ will be controlled as described in NHRERP, Volume
- 1. Section 2.6, p. 2.6-16.
Applicants have no such time estimates.
I L/255CC.67
SEACOAST ANTI-POLLUTION LEAGUE INTERROGATORIES TO THE APPLICANTS SPECIFIC INTERROGATORIES 68.
Since it cannot be determined from Appendix N what all of the roadway capacities assigned are, as claimed in answer to SAPL Interrogatory #20, list each roadway section in the EPZ and state to which of the 4 classifications that roadway has been assigned.
RESPONSE
Objection.
The premise of the question is demonstrably false. One can determine from Appendix N the roadway capacities assigned. The Appendix con-tains a third column which gives this information explicitly for each link.
As to the matter of roadway classifications, see our response to Mass AG Supplemental Interrogatory #29.
L/255CC 68
As to Answers:
-*yc b George 6. Thomas Vice President, Nuclear Production New Hampshire Yankee Division of Public Service Company of New Hampshire June 4, 1987 State of New Hampshire Rockingham County, ss.
Then appeared before me the above subscribed George S.
Thomas and made oath that he'is the Vice President, Nuclear Production of New Hampshire Yankee Division, authorized to execute the foregoing responses to interrogatories on behalf of the Applicants, that he made inquiry and believes that the foregoing answers accurately set forth such information as is available to the Applicants.
Before me, EdAtkhs JA<t>ur My Commidsion ' Expires
. ?f; :f:,, j 'myPub5c As to objections:
23 th2 w_
Thomhs G.
Dignan, Jr.
George H. Lewald Kathryn A.
Selleck Deborah S.
Steenland Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 Counsel for Applicants
D Ei W
CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attorneys fob 7th&U ll A9 54 Applicants herein, hereby certify that on June 4, 1987, I made service of the within document by depositing copjgs.
thereof with Federal Express, prepaid, for delivery tm)t(or
. Tomi where indicated, by depositing in the United States mail, BEANL" first class postage paid, addressed to):
Administrative Judge Helen Hoyt, Robert Carrigg, Chairman Chairperson, Atomic Safety and Board of Selectmen Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Judge Gustave A.
Linenberger Diane Curran, Esquire Atomic Safety and Licensing Andrea C.
Eerster, Esquire Board Panel Harmon & Weiss U.S. Nuclear Regulatory Suite 430 Commission 2001 S Street, N.W.
East West Towers Building Washington, DC 20009 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S.
Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814
- Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S.
Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel 116 Lowell Street U.S. Nuclear Regulatory P.O.
Box 516 Commission Manchester, NH 03105 Washington, DC 20555
4 Philip Ahrens, Esquire Mr.
J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S.
Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General.
Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th-Floor P.O. Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RED 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey Mr. Angie Machiros U.S.
Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn: -Tom Burack)
Town of Newbury Newbury, MA 01950
- Senator Gordon J. Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S.
Lord Town Manager Board of. Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen i
Office of General Counsel RFD Dalton Road l
Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301-I
, 4 i
i i
Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region I Silverglate, Gertner, Baker, 442 John W. McCormack Post Fine, Good & Mizner Office and Court House 88 Broad Street Post Office Square.
Boston, MA 02110 Boston, MA 02109 Charles P. Graham, Esquire McKay, Murphy and Graham 100 Main Street Amesbury, MA 01913
/
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id7 Dig' W//
Thomas G.
Jr.
(*= Ordinary U.S.
First Class Mail.)
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