ML20235M893
| ML20235M893 | |
| Person / Time | |
|---|---|
| Site: | Seabrook |
| Issue date: | 02/21/1989 |
| From: | Lonergan A MASSACHUSETTS, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20235K640 | List: |
| References | |
| OL, NUDOCS 8902280482 | |
| Download: ML20235M893 (19) | |
Text
6:
A UNITED. STATES 0F AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before'the Administrative Judges:
Ivan W.
Smith, Chairman Dr. Richard F.
Cole Kenneth A. McCollom
)
In the Matter of
)
Docket Nos. 50-443-OL
)
50-444-OL PUBLIC SERVICE COMPANY
)
(Off-Site.EP)
OF NEW HAMPSHIRE, EI AL.
)
)
(Seabrook Station,-Units 1 and 2)
)
February 21, 1989
)
TESTIMONY OF ARTHUR LONERGAN ON BEHALF OF THE ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS REGARDING J1 54 i
l B9022BO4B2 890221 1
PDR ADOCK 05000443 T
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l TESTIMONY.OF ARTHUR LONERGAN ON BEHALF OF THE ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS REGARDING J1 54
SUMMARY
OF TESTIMONY This testimony concerns a telephone survey I conducted on February 6 through February 10, 1989. -The purpose of this 1
survey was to find out how certain space, which has been designated for Congregate Care Center usage in various industrial facilities, is used in the normal. course of business and how that space could be made ready for use by evacuees in.
the event that there was an emergency at Seabrook.
I also asked each-contact person to tell me who would be available to provide the manpower to make the particular space ready for use as a Congregate Care Center.
The above question was asked with respect to business and non-business hours.
Additionally, I asked whether there was a plan which had been drawn up regarding the clearing of such space.
.i The results of the survey can be summarized as follows:
out of the twenty-five facilities I called, only nine said they i
had plans or procedures to address the matter of clearing the.
space.
Of these nine, five would rely on a plan given them by i
"Seabrook".
The other four had some sort of in-house plan but
]
only two of those were reported to be in written form.
Three 1
others stated they had no plans regarding this matter and two were "not sure" if such a plan was in existence.
The general i
manager of one facility said he had no idea the facility had been designated for use as a Congregate Care Center.
One individual indicated that clearing and making the space usuable
_ _ - _ _ _._ _ _ _ ___ _ N
I for evacuees would entail reliance on a " directive".
Two are relying on."Seabrook" or " Red Cross" to. deal with space l
conversion or clearance.
Six would not answer my questions and one facility was no longer open.
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When I asked the contact' people about_the staffing for a movement-to clear or rearrange space, two said that they would J
rely on Red Cross or Seabrook, ten said they had a " call list",
four said they had employees at the site around the clock, one.
]
" assumed" the facility would use its own personnel, six would not answer.my questions,.one had no. idea the facility had been designated for such use and.one-is no longer open.
The names of contact people were made available through two documents, copies of.which aro attached to this. testimony.
The following statements are numbered according to the numbers on the June 21, 1988 status lists which are attached hereto as Attachment A.
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TESTIMONY i
1 1.
Statement concerning Mans Electric in North Andover,
?
Massachusetts, at 1101 Turnpike Road, obtained from David Kennedy.
On February 7, 1989 I spoke with Mr. David Kennedy.
He informed me that during the normal course of business, the space which has been designated for use by evacuees in the event of an emergency at Seabrook is used for garage office space, parking lots and vehicle repair.
He said that the space would have to be cleared prior to use by evacuees as a Congregate Care Center.
If the emergency occurred during business hours, the space would be cleared by available employees of Mass Electric, "Seabrook" people and Red Cross people.
If the emergency occurred during non-business hours, the space would be cleared by "Seabrook" and Red Cross.
2.
Statement concerning Mass Electric at 170 Medford Street in Malden, Massachusetts, obtained by Mr. Peter Flynn.
I spoke with Mr. Peter Flynn on February 7, 1989.
He would not answer my questions.
3.
Statement concerning Mass Electric at 44 River Street in Beverly, Massachusetts, obtained by Mr. Don McHale.
On February 6, 1989, I spoke with Mr. Don McHale.
He informed me that some of the space designated for use as a Congregate Care Center is ordinarily used as office space.
He told me that if an emergency occurred during business hours he would look towards "Seabrook" or the Red Cross to clear that l l
c that portion-of the space which needed to be cleared.
- However, l
he was not absolutely clearnas to who would be responsible.
If l
an emergency occurred during non-business hours, Mr. McHale said he was not sure who would supply manpower for clearing the space.
4.
Statement concerning New England power / Mass Electric at 25 Reservoir Road in Westborough, Massachusetts, obtained from Mr. Ronalt David.
On February 8, 1989 I spoke with Mr. David.
He informed me that'the space designated for use as a Congregate Care' Center was used in the normal course of business as office space or auditorium space.
He said there would-be some need to clear the designated ares, depending on which floor was being used.
During business hours Mr. David said he had an on site staff of 25 people who could be responsible for clearing the area.
If-an emergency occurred during non-business hours, Mr. David said he would contact his people.
As an example of his people who would be available to perform tasks for clearing the space, he indicated that he had construction crews and maintenance people.
Mr. David said he has a written plan for clearing the space which was proposed by Mike Lewis from Seabrook.
On February 10, 1989, I spoke to Philip Wilkowski concerning obtaining a copy of the plan mentioned by Mr. David.
In order to obtain a copy of this plan, I was informed by Attorney Kirk
)
Ramsauer, on February 14, 1989, to contact Mr. Thomas Dignan or John Ritcher at the law firm of Ropes & Gray. i I
K
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ =. - _ _ _ _ _
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5.
Statement concerning pSNH at 1000. Elm Street in Manchester, New Hampshire,.obtained from Mr. Mike Wojdyla.
On February 8, 1989 I spoke with Mr. Mike Wojdyla.
He informed me that the space designated for use as a Congregate Care Center is ordinarily'used as. conference rooms and an auditorium.
He. told me that tables and chairs would have to be broken down and moved in order to convert the space for use by evacuees.
If an emergency occurred during business hours, Mr.
Wojdyla said he had his own people, plus~a list of people he could call to provide the manpower needed.
If an emergency occurred during non-business hours, a " call-list" would be'used-to provide any necessary manpower.
Mr. Wojdyla was not sure whether there was.a plan in existence regarding converting the space as a' Congregate Care Center.
6.
Statement concerning PSNH at New Hampshire, obtained from Charles Morton.
On February 8, 1989, I spoke to Mr. Charles Morton.
He would not answer my questions and referred me to Mr. David Shields.
I have been awaiting return call fron David Shields.
7.
Statement concerning pSNH at 333 March Avenue, Manchester, New Hamp3 hire, obtained from Jack Burke.
On February 8, 1989, I spoke with Mr. Jack Burke.
He informed me that during the normal course of business, the space which has been designated for use by evacuees in the event of an emergency at Seabrook'is used for vehicle storage, conference rooms, and garage area.
He said that the space would have to be cleared of materials and vehicles in order to i
a I
be used as.a Congregate Care Center.
If an emergency occurred during. business hours, Mr. Burke said that the warehouse crew would clear the space.
If the emergency occurred during non-business hours, Mr. Burke said-that standby people obtained-through a " call-out" procedure would be used to clear the space.
When asked if there was a written plan pertaining to converting the space for use as a congregate care center, he said he would have to check on this.
He then told me to call Don Tracy, who is the facilities manager.
Mr. Tracy said that I would have to make my request to Ropes and Gray regarding the written plan for clearing the space.
It was never indicated to me one way or the other whether in fact this facility had a written plan.
8.
Statement concerning PSNH at 60-80 West Pennacook Street in Manchester, New Hampshire, obtained from Don Tracy.
On February 8, 1989, I spoke with Mr. Don Tracy.
He informed me that during the normal course of business, the space which has been designated for use by evacuees in the event of an emergency at Seabrook is used as office space and q
for the repair and maintenance of trucks.
He said that in I
order to convert and use the space as a congregate care center,
(
l vehicles would have to be removed.
If this emergency occurred during business hours, and the space had to be converted for use by evacuees, Mr. Tracy initially said that Red Cross would be used.
Then he changed his mind and said that he would use I
in-house people to clear the area.
If the emergency occurred during non-business hours, and the space had to be converted,
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r for use, Mr. Tracy said that standby people available through
" call out" procecure would be used.
He said that these are essentially in house people.
When asked if there was a plan:in existence regarding clearing.the space for use as a Congregate Care Center, Mr. Tracy said that there would be a directive to clear the space.
9.
Statement concerning General Electric at Western Avenue in-Lynn, Massachusetts, obtained from James Callahan.
On February 8, 1989, I spoke with Mr. James Callahan.
He told me that the usual business carried on in this facility is jet engine manufacturing.
He informed me that during the normal course of business the space which has been designated for use by evacuees in the event of an emergency at Seabrook is used as auditorium space, warehouse space, and conference room space.
He said that some rearrangement would be necessary in order to use the space for a Congregate Care Center, but he said that this would not disrupt the evacuees to the point of being a problem.
If an emergency occurred during business hours and the space had to be converted, Mr. Callahan said that employees of GE would provide the manpower.
Similarly, if the emergency occurred during non-business hours, Mr. Callahan said that employees of GE would provide the manpower.
Apparently there are three full-time shifts at all times working at this i
facility.
When asked whether there were any written plans for clearing the space, Mr. Callahan indicated that these type of plans were within their normal contingency plans.,
_-m____.__.____________.___
4
- 10. Statement concerning Sheraton-Wayfarer Inn at'U.S. Route 3 L
in Bedford, New Hampshire, obtained from Marcel Gerard, general manager..
On February-8, 1989, I spoke with Mr. Gerard.
He informed me that during the normal course of business, the space which l.
had been designated for use by evacuees in the event of an 1
emergency at Seabrook is used for meeting rooms, guest rooms, F'
convention centers, and conference centers.
When asked if this space had to be cleaned out or rearranged in order to be used by evacuees, Mr. Gerard indicated that there would be a day-to-day set up; that sometimes there is nothing in any of the rooms, but sometimes modifications would be needed to clear and set up.
He said it was hard to predict because things change on an ongoing basis.
Whether an emergency were to occur in business or non-business hours, hotel staff would be relied on to provide the manpower.
Mr. Gerard indicated that there was a plan from an independent team who may have been representing Seabrook.
When asked for a written copy of this plan, Mr. Gerard advised me to call the legal department at Flatley Headquarters in Braintree.
- 11. Statement concerning the Sheraton Tara Hotel at Tara Boulevard in Nashua, New Hampshire, obtained from Bob Lehman, general manager.
When I called Mr. Lehman, the general manager of the Sheraton Tara, and asked him questions about the space that had been designated for congregate care use, he did not know what I was talking about.
He was unaware that this facility had been designated as such.
He asked me to mail him the q_ostions and.
4' then he would speak to superiors at-Sheraton.
Mr. Lehman indicated that he has been general manager at this particular hotel for two months.
- 13. Statement concerning Raytheon at 141 Spring Street in Lexington, Massachusetts, obtained from Len McCarrick.
On' February 8, 1989,.I spoke with Mr. Len McCarrick.
He informed me that during the normal course of business the space which has been designated for use by evacuees in the event of an emergency.at Seabrook is used for cafeteria space, n.edical department space, main entrance space, and large corridor space.
When I asked him if this space would have to be cleared out or rearranged in order to be used as a congregate care center, he-said that furniture would have to'be moved.
If the emergency occurred during business hours, Mr. McCarrick said that Raytheon maintenance people would provide the manpower.
If the emergency occurred during non-business hours, Mr.
McCarrick said the security force who are there at the facility 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and the janitors would provide necessary manpower.
Mr. McCarrick said there was no plan in writing regarding the clearing of the space.
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- 14. Statement concerning Raytheon at 430 Boston post Road in Wayland, Massachusetts, obtained from Steven Fugarazzo.
On February 8, 1989, I spoke with Mr. Fugarazzo.
He informed me that during the normal course of business, the space which has been designated for use by evacuees in the event of an emergency at Seabrook Station is used as cafeteria _ _ _ _ _ _ _ -
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. space, conference room' space, and first. aid facilities.
M.r.
Fugarazzo informed me that furniture would have to be moved in order to use the space as a congregate care. center.
If the
~
emergency were to occur during business hours, maintenance personnel of approximately 45 people would provide the manpower.
If the emergency occurred during non-business hours,-
Mr. Fugarazzo said that a call in on an overtime basis would be initiated.
He said that Seabrook would call and that Seabrook would' initiate that call.
He said.that he does have a congregate care. plan from Seabrook which he got last June or July.
When I called back on February 10, 1909 to request a copy of this plan, Mr. Fugarazzo was not at the facility.
I left a message and have been awaiting his return call.
- 15. Statement concerning Raytheon facility at 528 Boston post Road in Sudbury, Massachusetts, obtained from representative of Raytheon.
On February 8, 1989, I spoke a representative of the Raytheon facility.
I did not record his name.
He gave me the following information.
He said that in the normal course of business the space designated for use as a congregate care center is cafeteria space, conference room space, and first aid facility space.
He indicated that this space would have to be rearranged or cleared out to be used as a congregate care center and this would entail moving tables and chairs.
If an emergency occurred during business hours, maintenance people would provide the manpower.
If an emergency occurred during non-business hours, "Seabrook" would notify Mr. Steve Fugarazzo, i
I L
and he would then' notify his people on a call-in basis.
There is a plan pertaining to use as a Congregate Care Center which was l
given to.the facility by Seabrook some time last-June or July.
16.' Statement concerning Raytheon facility at Harwell Road,.
Hanscom Field Complex in Bedford, Massachusetts, obtained 3
from Anthony.Mangini.
On February 8, 1989, I spoke with Anthony Mangini.
He told l
me that in the normal course of business the space designed for use by evacuees is ordinarily used as an aircraft hangar.
He said this space would have to be cleared out in order to be used as a congregate care center and that clearing out this space would entail removal of the aircraft.
If an emergency occurred during business hours, Mr. Mangini said that Raytheon flight operations people and maintenance people would provide t.he manpower.
If an emergency occurred during non-business i
hours, second and third shift maintenance and security guards would provide the manpower.
Mr. Mangini indicated that there is a plan.
Mr. Mangini said this facility has a plan which covers removal of the aircraft.
In addition, he has a booklet of approximately 16 pages which he described as congregate care center type of a plan.
When I asked for a copy of that plan, he advised me to contact an attorney named Mr. Carl Barton at Raytheon legal department in Lexington, Massachusetts. -
o
- 18. Statement concerning Raytheon facility at 2 Wayside Road in Burlington, Massachusetts, obtained from Arthur King.
On February 9, 1989, I spoke with Mr. Arthur King.
He informed me that in the normal course of business, the space which has been designated for use by evacuees is ordinarily used for cafeteria space, dining room space, and conference room space.
Mr. King said that this space would have to be cleared out or rearranged in order to be used by evacuees.
This would entail removal of furniture.
If the emergency occurred during business hours and the space had to be converted to use, personnel from plant engineering would provide the manpower.
If an emergency occurred during non-business hours, personnel from plant engineering and security by way of a " call in" procedure would provide assistance.
Mr. King told me there was no written plan to clear the space which had been designated as a congregate care center.
- 19. Statement concerning Raytheon facility at Wobu n Street in Lowell, Massachusetts.
On February 9, 1989, I spoke with a representative of Raytheon.
He indicated that this facility manufactures missile systems.
In the ordinary course of business, the space designated for use by evacuees would be used for a conference room, cafeteria, function room, or main aisles.
The contact I
person said the space would have to be cleared out in order to l
l be used by evacuees and this would entail the removal of
)
furniture.
If the emergency occurred during business hours, i
i maintenance and tradesmen would provide the manpower.
If the L_____.._____._.____.__....________
a
emergency occurred during non-business hours, management would put into effect an emergency call in system.
This person told me there are some written plans regarding converting this space and this has been put together by Raytheon.
When I called back on February 10, 1989, I left a message for Mr. Louis Chandounet requesting a copy of the written p1Ln regarding the congregate care center.
To this day I have not heard back from him.
- 20. Statement concerning Raytheon facility at 676 Island Pond Road, Manchester, New Hampshire, obtained from Winnie Blaise, Industrial Relations person.
When I called this facility on February 9, 1989, I asked to speak to Mr. Kevin Paquin or Mr. Robert L'Homme.
Mr. Paquin is no longer there.
The woman I spoke to, Winnie Blaise, took my questions and informed me she would get back to me.
Ms. Blaise returned my call later this afternoon and told me that she was referring my questions to Mr. Carl Barton at the Raytheon Headquarters in Lexington.
I received no answers to my questions from Ms. Blaise.
- 21. Statement concerning Raytheon facility at 350 Lowell in West Andover, Massachusetts, obtained from Mr. Manning.
On February 9, 1989, I called Mr. Manning.
He informed me that the usual business carried on in this facility is the manufacture of ground to air missile systems.
In the normal course of business the space designated for use by evacuees is a main cafeteria, a small cafeteria, and a medical facility.
This space would have to be cleared out or rearranged to be I
used by evacuees.
This would entail the moving and rearranging of tables and chairs and the moving of other furniture.
If an 1
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1 emergency occurred during business hours, and the space had to be converted for use by evacuees, maintenance and tradespeople would provide the manpower.
If.the emergency occurred during non-business hours, there would be a. call-in' procedure 1
implemented. 14r. Manning said that a. call-in procedure is j
available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week.
He also said that' key members of management would be located by this. emergency call-in procedure.
Mr. Manning said there is'no written plan for conversion for use as a congregate care center, but they would rely on general corporate procedure.
- 22. Statement concerning Raytheon facility at 7 Redmond Street in Nashua, New Hampshire, obtained from Mr. Manning.
On February 9, 1989, I spoke again with Mr. Manning.
He-told me thatLthis Raytheon facility is used as a warehouse.. Mr. Manning-said that.certain areas within the warehouse are designated office; areas and some space is open and common.
This space would be used for evacuees in the event of an emergency.
Clearing up this space for use as a congregate care center would entail moving furniture.
.If this emergency occurred during business hours, storekeepers, materials handlers, shippers and tradespeople would provide the manpower.
If the emergency occurred during non-business hours, security people would provide the manpower.
In addition, there is an emergency phone procedure that would be available.
When asked whether there were any written plans regarding use of the space, Mr. Manning indicated there are no written plans but he would rely on corporate procedure. _ - _ - - _
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- 23. Statement regarding Raytheon facility known as the Bunker
)
Hill Pavilion at Water Street in Charlestown, Massachusetts, f
On February 8, 1989, I called this facility, and was informed that it is closed.
As a result, I could not get any information as to what the space is being used for presently, how the space would be rearranged or cleared out, who would provide the manpower, or whether there were any plans in fact I
to convert the space to a congregate care center.
- 24. Statement concerning Yankee Atomic Electric Company at 1661 Worcester Road, Framingham, Massachusetts.
On February 9, 1989, I placed a call to this facility, and left a message for Mr. John DeVicentis, Vice President, to call me back.
Mr. DeVicentis called me back that day and asked me to address any questie's to Attorney Thomas Dignan at Ropes and Gray.
- 26. Statement concerning Perini Corporation at 73 Mount Wayte Avenue in Framingham, Massachusetts.
On February 9, 1989, I called Mr. Richard Varney, plant manager.
He informed me that this facility is the headquarters i
for Perini Corporation.
In the normal course of business, J
space designated for use by evacuees would include conference 1
rooms, unfurnished office space, a handball court, corridors, and lobby space.
Mr. Varney said that some of this space would
)
have to be cleared out to be used by evacuees.
If an emergency occurred during business hours, maintenance personnel could provide the manpower.
If an emergency occurred during non-business hours, Mr. Varney assumed that personnel from l L_ __ _ __ _ ________ - - - - - ~
f Perini would clear the space.
Mr. Varney indicated that there are no' written plans in place regarding the use of this space as a congregate care center.
- 27. Statement concerning Perini Corporation at Johnson Road in Bow, New Hampshire, obtained from Gary Webb and Robert Walker.
On February 10, 1989, I spoke' with!Mr. Gary Webb, shop office manager.
Mr, Webb informed me that the usual business carried on in this facility is heavy construction and repair entailing the use of' heavy equipment.
He declined to answer.
any other question and said that Mr. Walker would call me back.
On February 14, 1989, Mr. Walker of Perini Corporation called me back and told me to call Mr. George Graham regarding any questions I had.
When I called the number given to me.for Mr. Graham, I realized that Mr. Graham worked for.Seabrook Station in the emergency planning area.
As such, I did not speak with him.
- 28. Statement concerning Holy Cross College at One College Hill in Worcester, Massachusetts, obtained from Mr. Zimmerman.
On February 10, 1989, I called this facility and spoke with Mr. Zimmerman who indicated that he would get back to me.
On February 14, 1989, I spoke again with Mr. Zimmerman.
He told me.at that time that all questions regarding congregate care centers should be addressed to Attorney Thomas Dignan of Ropes and Gray. i
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