ML20247A592

Applicant Voluntary Responses to Commonwealth of Ma Atty General Requests for Documents & Info on Exercise.* W/ Certificate of Svc.Related Correspondence

ML20247A592
Person / Time
Site:	Seabrook
Issue date:	03/24/1989
From:	Cook G, George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	MASSACHUSETTS, COMMONWEALTH OF
References
CON-#189-8358 OL, NUDOCS 8903290151
Download: ML20247A592 (16)

Text

_ _ _ _ _ _ _ _ _ _

,js5fL -

)

);.

uECATED CORRE.SPO.npW95 ,,-

M, k5l,i&V

j i

L l March 2'49 *Mt7 ' P3 ;56 OffH: - .p l

UNITED STATES OF AMERICA Nik,[" j l #

l NUCLEAR REGULATORY COMMISSION i l l i

L 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' VOLUNTARY RESPONSES TO MASS AG'S REQUESTS FOR DOCUMENTS AND INFORMATION ON THE EXERCISE Applicants respond herein to the letter request of the Attorney General for the Commonwealth of Massachusetts (" Mass AG"), dated March 10, 1989,1 for documents and information regarding the FEMA graded exercise held on June 28-29, 1988

(" Exercise"). Applicants will produce the documents requested at Seabrook Station during business hours upon reasonable notice to undersigned counsel on the same conditions to which the parties have agreed in the past.

1 Mass AG's telecopied letter was not sent until after 5:00 p.m. on Friday, March 10, 1989.

8903290151 890324

$DR ADDCK 05000443]" gb PDR '

c

/

t Reauest No. 1 Please list or produce a copy of the schedule of all

. drills.and exercises conducted since July 1, 1988, for those of ORO's service providers and support organizations who provide (A) manned vehicles to evacuate special facilities, and (B) ambulances to transport contaminated / injured individuals.

1 Apolicants' Response There were no further drills and exercises conducted since July 1, 1988 for the service providers and support l organizations identified in (A) and (B) above.

Reauest No. 2 Please list or produce a copy of the schedule of all drills and exercises conducted since July 1, 1988, for (A) all SS-ERO members involved in formulating offsite protective action recommendations and (B) all NHY-ORO members involved in formulating offsite protective action recommendations.

Applicants' Response Applicants object to this Interrogatory, which seeks information not pertaining to the performance during the June I 28-29, 1988 FEMA Graded Exercise, of the onsite and offsite emergency response organizations, on the ground that it is  ;

not relevant to the admitted exercise contentions. Without waiving the foragoing objection, Applicants respond as follows:

The ORO Command and Control Drill conducted on March 22, 1989 provided: (A) SS-ERO members the opportunity to be

1 l

involved in the formulation of offsite protective action recommendations, and (B) NHY-ORO members the opportunity to-be involved in the formulation of offsite protective action recommendations.

Reauest No. 3 :l Please' produce the Quality Assurance Audit Report No. '

88-A02-01, " Emergency Preparedness Plan" for Seabrook Station, dated March 9, 1988, and the corresponding audit checklist, both of which are described in NRC Inspection Report No. 50-443/89-02.

Applicants' ResDonse Applicants object to this Interrogatory on the ground that the information it seeks, an internal audit of Seabrook Station made before the June 28-29, 1988 FEMA Graded Exercise, is not relevant to the admitted exercise contentions.

Reauest No. 4 Please produce the most current version of the Public Notification Coordinator's Position Packet.

Applicants' Response The most current revision of the Public Notification Coordinator's Position Packet will be produced. It consists of:

- Implementation Procedure 2.13; "Public Alert and Notification System Inc]uding EBS Activation."

Implementing Procedure 3.1; "NHY Offsite Response EOC Activation and Operation."

1,. . l Appendix H; "New Hampshire Yankee Offsite Response-Communications Directory."

Reauest No. 5 Please produce, if they are not all contained i- the Position Packet referred to above (#4), a copy of each of the most current pre-written EBS messages.

Aeolicants' Resconse A' copy of the most current revisions of pre-written EBS .

messages, as of December 12, 1988, Will be produced. l Reauest No. 6 Please produce a list of all1 training sessions, drills and exercises conducted since July 1, 1988, for the ORO's Public Notification Coordinators.

Aeolicants' Resoonse ,

DRILLS AND EXERCISES: The Public Notification Coordinator participated in the ORO Command and Control Drill conducted on March 22, 1989.

TRAINING: The Public Notification Coordinators received the following training on the following dates since July 1, 1988, l

Trainina Module Dates Module 1 - Emergency Planning Overview 10/3/88 1/23/89 2/21/89 j i

Module 2 - Emergency Management '9/27/88 l 9/29/88 l 10/20/88 1/23/89 2/21/89 I

< f, x ,#

/ - '"---

,..;,,b"

([, -!,

);] 3 -M l' .

v. 7 f,):

as o Module 3 - PANS Activation 10/27/88 g ;' ' 2/8/89

> nj 3/16/89

, Module 8 .EOC Operations' 10/20/88 1/31/89 3/8/89:

9/27/88.

~

Module 12 - Transportation

9/29/88 4

>10/20/88 1/31/89 2/8/89~

Module 16 - Tabletop 10/27/88 2/8/89 3/16/89 4

E Recuest No. 7 Please produce the'most recent version of theJfollowing SPMC training modules (including all trainer and trainee materials):

A. . Emergency Management B. Public Alert and Notification System C. . Dose / Accident Assessment

.D. .Public Information E. Medical Emergency F.. Bus Driver-G. Radiological Surveys and Analysis

i. H. Communications Acolicants' Resoonse Applicants object to part "B" of this Interrogatory on the grounds that the information it seeks is not relevant to the admitted exercise contentions and that the subject is not within the jurisdiction of the off-site Board. With the exception of B, the most recent version of the requested SPMC i

I

L 1 L,.

I 4

1 training modules (including all trainer and trainee  !

materials) will be produced.

Reauest No. 8 Please produce the most recent version of the SS-ERO's training materials (for both trainers and trainees) which address the subjects of:

a. making protective action recommendations for offsite officials, and/or

b. use of the METPAC model in recommending protective actions to appropriate offsite officials. 1 Apolicants' ResDonse Applicants object to this Interrogatory, which seeks ,

information not pertaining to the performance during the June i

28-29, 1988 FEMA Graded Exercise, of the onsite and offsite j 1

emergency response organizations, on the ground that it is

)

not relevant to the admitted exercise contentions. Without j waiving the foregoing objection, Applicants respond as follows:

The most recent version of the SS-ERO's training materials (for both trainers and trainees) which address items a. and b. above will be produced.

Reauest No. 9 Please list each protective action recommendation made by the SS-ERO to appropriate offsite officials during day 1 of the Exercise (June 28, 1988), and for each one state or list:

A. The exact time it was made;

4 B. The name of person or persons involved in making it and their titles / positions;.

C. The scenario developments which prompted' ]

decisionmakers-to consider making a protective-action recommendation e.t that time; D. Any reservations or concerns any of.the decisionmakers had about making that PAR at'that time.

E. The exact manner is which the PAR was' communicated-to offsite authorities (Please produce a copy of tne communication if it has been reduced to writing);

~

F. All follow-up questions or concerns received from .

the offsite authorities about the PAR, and all responses given to these questions and concerns.  !

1 ADolicants' Response Applicants object to part "D" of this Interrogatory on  ;

the ground that is too vague and poorly defined. Without.

waiving the foregoing objection, Applicants respond as follows:

The SS-ERO made the following protective action recommendations to appropriate offsite officials during Day 1 of the Exercise (June 28, 2988):

1. Close Parker River National Wildlife Refuge, Plum Island Beach, and Salisbury Beach.

A. 1150 B. Ceorge S. Thomas, Response Manager C. Declaration of SITE AREA EMERGENCY at 1146 D. The recommendation was made to be consistent with actions previously taken for beaches in 1 the State of New Hampshire by NH authorities. '

1 J

l i

1

h1

.=

~

E. Tha PAR was communicated to offsite authorities by the Corporate Support-Manager via the NAS links'in the NH'EOC and the ORO EOC and by delivery of the, State' Notification Fact Sheet to offsite-authorities in.the ORO EOC and the NH IFO. The State Notification Fact Sheet is attached.-

F.; None indicated by exercise records.

2. Evacuate Seabrook, Hampton Falls, Hampton, Kensington, South Hampton, North-Hampton in~New Hampshire and Amesbury, Salisbury in Massachusetts.

Shelter remaining EPZ communities in New Hampshire and Massachusetts.

i A. 1336 B.. George S. Thomas, Response Manager (

i C. Declaration of GENERAL EMERGENCY and in- l containment Post LOCA monitor reading. greater i than 10,000 R/hr. ]

D. None indicated by exercise records.

E. Via NAS' links in the NH EOC and the ORO EOC and by delivery of_the' State Notification Fact Sheet to offsite authorities in the ORO EOC and the NH IFO. The State Notification Fact- .

Sheet is attached.

F. Exercise records show:

1 I (1) The 'JRO EP Advisor called the ERO EOF  ;

! Coordinator to confirm that the PAR had not changed because of the release at 1346.

i (2) State of New Hampshire and ORO authorities requested information on and status of forecasted wind shift. Answer .

was no immediate change based on most recent forecast.

(3) Questions were asked about status of the wide range gas monitor sample and field monitoring team results. Answer was that results were not available at the time.

~ ~ - - -

gy I ';'^ .

.r

^

Li liN!u gp - .

c,-O N < > >

h;' l D, < 1 6 > l

, , '3. In; addition to' previous ~ PAR, evacuate Brentwood,tEastL i

-Kingston, Exeter, Kingston and Newton in New Hampshire '

.and Merrimac, Newbury, Newburyport and West Newbury'in Massachusetts. Continued shelter in remaining EPZ.

communities.

,Q A. 1540

B. George lS.. Thomas, Response Manager' C. Forecasted wind shift 1that would potentially.

cause. plume to affect additional communities to'the south and the' west showed indication of occurring.

D. None. indicated by exercise records..

Via- NAS links in the NH EOC and~the ORO EOC E.'

and by. delivery of the StateLNotification Fact Sheet to offsite authorities'in the ORO EOC,__

and the.NH'IFO. The State-Notification Fact 1 i Sheet'is' attached.

F. 'None indicated by exercise records.

Recuest No. 10 Why did.the SS-ERO-not issue.a PAR to evacuate

~

.Portsmouth on Day 1 of the exercise?. l Applicants' Resoonse

< 'The SS-ERO did not issue a PAR to evacuate Portsmouth'on 1 Day 1 of the Exercise because on Day 1 of the' Exercise 1

.Portsmouth was not within 5 to 10 miles of the plant in a i downwind' direction. Should information on meteorological conditions show that a different downwind portion of areas subject to a PAR was going to be affected, an additional or expanded PAR would be issued and explained by the SS-ERO.

_g_

-_a_____1___________________ ___

l 1

1 This condition was not indicated.for Portsmouth on. Day 1 of x the Exercise.

Recuest No. 11 j Please describe what set of ETEs were used in the METPAC l model during the Exercise and why that set was used. j 1

l Anolicants' Resoonse Attachment.1, Table 5.2.2 of the YAEC Report 1618, dated }

October 1986 defines the set of ETEs used in the current METPAC model. The ETE values listed on Table 5.2.2.were  !

i derived from a-1983 ETE study which was litigated as part of ,

'the onsite proceedings. The METPAC program will be updated  !

based on the results of the ASLB litigation on the current h ETE study,and the revised-evacuation times will be l

incorporated into the program data base.

Reauest No. 12 Please describe how the SS-ERO's Procedures for selecting and issuing offsite PARS take into account (A) weather data and weather forecasts ~(including forecasts for changes in wind direction and speed), and (B) extant circumstances that will likely cause the ETEs to be shorter or longer than the " baseline" ETEs in the METPAC model (e.g.,

the emergency occurs at a time of day in the summertime when the beach population is know to be substantially smaller that it~would be at 1-3 p.m.).

Anolicants' Response Applicants object to this Interrogatory, which seeks ,

information not pertaining to the performance during the June 28-29, 1988 FEMA Graded Exercise, of the onsite and offsite energency response organizations, on the ground that it is i

l I

l

.: 'l not relevant to the admitted exercise contentions. Without waj.vinq the foregoing objection, Applicants respond as follows:

(A) A PAR selected by the SS-ERO incorporates  !

I meteorological conditions that are current as of the time the PAR is made to offsite authorities. One of the actions of the SS-ERO operating at the EOF is to monitor regional meteorological data and be alert to forecasts for changes in meteorological conditions (particularly wind direction) that-could affect a PAR being considered or previously made.  !

i Should this information show that a different downwind  !

1

. portion of areas subject to a PAR was going to be affected, an additional or expanded PAR wceld be issued and explained  !

by the SS-ERO.

(B) The role played by ETEs in the selection of a PAR 1

by the SS-ERO would most likely be limited. The SS-ERO selects a PAR based mainly on the station accident conditions and prognosis. The SS-ERO thereby arrives at a PAR prior to  !

or independently of an accidental release of radioactive material that is of a magnitude that would require shelter vs. evacuation dose comparisons, and for which ETEs would be  !

q a factor. The condition postulated in the question would be l discussed with the offsite authorities when the PAR was issued by the SS-ERO.

i l

l 1

Where a-particular ETE value.is'a' determining factor in 1

'the PAR decision, an ETE value for a scenario appropriate to 1

the extant circumstances could be selected from the. range of

-1 scenarios considered in the METPAC model.

i t

l l

I l

4

)

)

i

(

- - _ - - - _ _ -- - _ _ - _ - _ _ _ _ - _ _ ___ ___ _ n

, v.; , '

pit i il

.:. As to Answers:-

maec/ lh d' George S. Tho' mas

,~

Vice. President - Nuclear Production New Hampshire Yankee Division of Public Service Company of New Hampshire ,.

1 March 24, 1989 STATE OF NEW HAMPSHIRE

-i Rockingham, ss. ']

Then appeared before me the above subscribed George S. Thomas and made oath' that he is the Vice President --Nuclear Production, New Hampshire Yankee-Division of Public Service. Company of New Hampshire, authorized to execute the =

foregoing responses to interrogatories on behalf of the Applicants, and that he made inquiry and. believes that the foregoing answers accurately set forth'infor-mation as is available to the Applicants.

Before me, b 5u A b C t D hA%u_(

My CommissWn Expires: Marc) 6, 1990 l

As to objections and responses to request for. production of documents:

/ J' '"

Thomas G. gna ,' J r . )

George H. ew d l Kathryn A. S 11eck l Jeffrey P. Trout l Jay Bradford Smith l Geoffrey C. Cook Ropes & Gray One International Place Boston, MA 02110 l (617) 951-7000 r Counsel for Applicants  ;

l i

_ = _ __ _ . _ _ _ _ _ b

1 L J.L s i! "

' Met CERTIFICATE OF SERVICE ,

1 I, Geoffrey C. Cook,oneoftheattorneysf39thE28ph1d(( hts ]

herein, hereby certify that on March-24, 1989, I made service of 1 the within document by depositing copies thereo$jwith Federal-  !

Express, prepcid, for delivery to (or, where indspated,5by 1. r depositing in the United States mail, first class postase paid, addressed to): ,

Administrative Judge Ivan W. Smith Administrative Judge Peter B.

Chairman, Atomic Safety and Bloch, Chairman, Atomic Licensing Board Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway l Bethesda, MD 20814 Bethesda, MD 20814 l Administrative Judge Richard F. Cole Dr. Jerry Harbour Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board East West Towers Building U.S. Nuclear Regulatory 4350 East West Highway Commission Bethesda, MD 20814 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Kenneth A. Administrative Judge Emmeth A.

McCollom Luebke 1107 West Knapp Street 4515 Willard Avenue Stillwater, OK 74075 Chevy Chase, MD 20815 James H. Carpenter, Alternate Robert R. Pierce, Esquire Technical Member Atomic Safety and Licensing Atomic Safety and Licensing Board s Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory l U.S. Nuclear Regulatory Commission Commission East West Towers Building One White Flint North, 15th Fl. J L 4350 East West Highway 11555 Rockville Pike

! Bethesda, MD 20814 Rockville, MD 20852 l

t  !

J p

• Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board 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 04as3 Paul McEachern, Esquir,4 John Traficonte, Esquire Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue Department of the Attorney P.O. Box 360 General Portsmouth, NH 03801 One Ashburton Place, 19th Fl.

Boston, MA 02108 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 R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton &

Washington, DC 20510 Rotondi (Attn: Tom Burack) 79 State Street 01950 Newburyport, MA

• Senator Gordon J. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 507 Kopelman & Paige, P.C.

Concord, NH 03301 77 Franklin Street (Attn: Herb Boynton) Boston, MA 02110 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 Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.

Washington, DC 20472

y -m 1 4 7

[ , ,

J.

t ,

90 Gary W. Holmes, Esquire' D Richard A. Hampe, Esquire q Holmes &' Ells . .

Hampe and McNicholas.+

c47 Winnacunnet Road 35 Pleasant Street o Hampton, INH 03842 ' Concord, NH 03301- j

" Judith H. Mizner, Esquire

.Mr. Richard R. Donovan

' Federal Emergency Management. 79 State Street,.2nd Floor 1 Adency Newburyport',.MA 01950

l

.. s Federal' Regional Center ..

130 228th' Street, S.W.

.Bothell, Washington 98021-9796 q

-Ashod N. Amirian, Esquire ' Robert Carrigg, Chairman. y

'145 South ~ Main Street . Board of Selectmen

'P.O. Box 38' Town Office, Atlantic'Avnnue ,

Br,adford, MA 01835; North Hampton, NH 03862'  :)

Diane' Curran, Esquire 'JohnLP." Arnold, Esquire i Andrea C..Ferster, Esquire' Attorney General ij Harmon, Curran.& Tousley George Dana Bisbee, Esquire- i Suite 430 Assistant Attorney General ~  ;

t 2001 S.. Street, N.W. Office of the Attorney General

c. Washington, DC .20009 25 Capitol Street l Concord, NH 03301-6397 I

., /.  ; i Y./ Q / _,

s'

~

l GeoffreyyC.p6ok  ;

J

(*= Ordinary U~S. First. Class Mail) q r

1 I

$ )

^

-___ ___ _ ___ A l