ML20207T635

State of Nh Responses to Atty General Jm Shannon Offsite Emergency Planning Interrogatories & Request for Documents to State of Nh.* W/Certificate of Svc.Related Correspondence

ML20207T635
Person / Time
Site:	Seabrook
Issue date:	03/18/1987
From:	Bisbee G, Huntington G, Strome R NEW HAMPSHIRE, STATE OF
To:	MASSACHUSETTS, COMMONWEALTH OF
Shared Package
ML20207T535	List: ML20207T534 ML20207T558 ML20207T567 ML20207T602 ML20207T623 ML20207T635
References
OL, NUDOCS 8703240198
Download: ML20207T635 (62)

Text

rr - x,,3 y VWRWSN!{& March 18, 1987 00CMETED

-UNITED' STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION __

Before the Nuclear Regulatory Commissio ttAR 20 P2 :25 0FFICE rr HCFt.TAHY 00CMETIMi 4 iEHyn BRANCH

)

In the Matter of ) Docket Nos. 50-443-OL

) and PUBLIC SERVICE COMPANY OF- ) 50-444-OL NEW HAMPSHIRE ) (Off-Site Emergency (Seabrook Station, Units 1 and 2 ) Planning Issues)

)

THE STATE OF NEW HAMPSHIRE'S RESPONSES TO ATTORNEY GENERAL JAMES M. SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR DOCUMENTS TO THE STATE OF NEW HAMPSHIRE INTERROGATORIES

1. Describe in detail your 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.

2. Identify and produce all documents on which you have relied, do rely, or will rely to support your position on each of these contentions. Identify the information in each document on which you have relied, do rely, or will rely and the specific subpart of each contention which that information concerns.

3. State whether you have relied, do rely, or will rely on any study, calculaton, or analysis to support your position on each of these contentions. If so, please:

a. Describe-the nature of the study, calculaton or analysis and identify any documents that discuss or describe the study, calculation or analysis;

b. Identify the persons who performed the study, calculation or analysis;

c. State when and where the study, calculation or analysis was performed;

d. Describe in detail the information or data that was studied, calculated or analyzed; ple'*MR 0

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e. Describe the<results of the study,~ calculation (H: analysis; f.- Explain how such study, calculation, or analysis provides support for your position on each.of these contentions.

-4. Do you-intend.to offer-the testimony.of any expert witness _with

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rGspect'to any contention to be 1itigated by the Attorney General?

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JIf 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 toswhich 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 scientific 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 publication, and, if so, identify the book or publication.

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5. Do you intend to offer the testimony of any non-expert witness with respect to any contention to be litigated by the At_torney 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 to Interrogatory Nos. 1-5 See State's response to NECNP's Interrogatories 2-6, filed on this date.

6. Identify and produce all documents in which you or any agent on your behalf have assessed the adequacy of state and local emergency plans with respect to any contention to be litigated by the Attorney General. Include in your response any documents concerning steps which have been taken or will be taken by the State of New Hampshire or the Applicants to address inadequacies in any past or current local plans.

Response

The State has commissioned no such document. See the State's response to the Town of Hampton's Interrogatories 9-10, filed on this date, relative to the RAC reviews.

7. Are peak summer day evacuation time estimates for the populations within two miles, five miles and ten miles of the Seabrook plant longer than the average two-mile, five-mile, and ten-mile EPZ evacuation time estimates for nuclear power plants in this country?

8. Please provide the names of all nuclear power plants that have longer evacuation time estimates for populations located within two miles, five miles and ten miles of those plants than does the Seabrook reactor. Include those respective time estimates for each plant.

9. Is population density greater for the areas within two miles, five miles, and ten miles of the Seabrook plant than the average population densities for areas within two miles, five m'les and ten miles of all other nuclear reactors in this country?

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10. Please provide the names of all nuclear power plants in this-country that have higher population densities in the areas within two miles, reactor.

five miles and ten miles of the plants than coes the Seabrook 11.

Is there a larger summer transient population within two miles, five miles or ten miles of the Seabrook plant than there is within two miles, five miles, or ten miles of all (NOTE: sentence appears to be terminated)

12. Please identify all nuclear power plants in this country that have a larger summer transient population than does the Seabrook plant for the areas located within two miles, five miles, or ten

. miles of the plant, and for each of those reactors indicate what provisions, if any, have been made to shelter the transient population; where such population is situated with respect to that reactor; the average dose reduction factor of shelters used for that population; evacuation time estimates for that population if it were to be evacuated; the location with respect to the transient population of any sheltering they will be expected to use; whether that population is predominantly a beach population; whether sufficient sheltering capacity exists to shelter the entire transient population; and if sufficient capacity does not exist to enable the sheltering of the entire population, state for what percentage of the population sufficient sheltering capacity exists.

13. Will emergency planning for the area within ten miles of the Seabrook plant effectuate less " dose reduction" than the average dose reduction for all other nuclear plants in this country, assuming comparable radiological releases in the event of an accident?

14. Compare the average dose reduction expected to be effectuated for the summer transient beach population within ten miles of the Seabrook plant to the average dose reduction expected to be effectuated, for persons within ten miles of all other reactors in this country, assuming comparable radiological releases in the event of an accident.

15 13-14Please and anyprovide the relevant documents basis for your response to interrogatories to your responses.

16 Do homes within the Seabrook ten-mile EPZ have on the average a lower dose reduction factor than do homes around all other nuclear reactors in this country.

17. Compare the average dose reduction factor of homes within the Seabrook ten-mile EPZ beach area to average dose reduction factors of homes around other reactors.

18. Please provide the basis for your responses to interrogatories 16-17 and any documents relevant to your response.

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-Response to Interrogatory Nos. 7-18

'The State of New Hampshire objects to these interrogatories on the grounds of relevance. Without waiving its objection, the State responds as follows:

The State of New Hampshire is aware of no explicit or implied requirement that emergency planning efforts at one' nuclear power plant site should be compared to those at other sites. The State hcs,~in any event, undertaken no such comparative analysis, nor is it cware of such an effort by any other party to the Seabrook licensing proceedings.

19. Describe in detail your relationship with KLD Associates and Edward B. Lieberman since January 1, 1985, detailing the amounts, if cny, you have paid to KLD Associates, to Mr. Lieberman, and others, to conduct the evacuaton time study contained in Volume 6 of the New Htmpshire Radiological Emergency Response Plan (NHRERP) Revision 2.

Produce all contracts and other documents which describe the relationship.

Response

The State of New Hampshire has no contractual relationship with KLD Associates or Edward B. Lieberman. The State has worked with Mr.

Lieberman, however, in the preparation of the KLD Evacuation Time Estimate report incorporated as Volume 6 of the NHRERP. It is our understanding that his efforts were contracted for by the Applicant.

Representatives of the State met with Mr. Lieberman before, during, and after his work on the ETE. Early meetings were briefings by Lieberman on the approach he was to take in compiling the study and to give him input he required from various State personnel.

Later meetings were arranged to hear briefings on the progress of his work. Still later briefings were given to present results and to respond to questions of drafts of his report.

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20. Did you-pay KLD Associates, or Edward Lieberman, or any employee of KLD Associates any money after January 1, 1985, for any reason other than as payment for conducting the ETE study? If so, detail the amounts, to whom, and the reasons for these payments. Identify and produce all documents, including contracts, which relate to these payments.

Response

No.

21. State whether any employee or agent of yours communicated orally during the period from January 1, 1985, through September 1, 1986, with Edward B. Lieberman or any other officer, agent, employee or person acting or purporting to act on behalf of KLD Associates.

Response

See State's response to Interrogatory No. 19, supra.

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22. If you answer the previous interrogatory affirmatively, as to each communication:

a. state whether made in person or by telephone;

b. state the date and place;

c. state the content of the communication as disclosed in any corporate or internal record;

d. identify each person who participated in the communication or who had knowledge thereof;

e. identify and produce each document referring or relating to the subject matter of subparagraph (c) hereof.

23. Identify and produce each document passing between any employee or agent of yours and Edward B. Lieberman or any other officer, agent, employee or other person acting or purporting to act on behalf of KLD Associates during the period from January 1, 1986, to September 1, 1986, referring or relating in any way to terms and conditions of payment to Mr. Lieberman or KLD Associates for conducting and ETE study; instructions, guidance, criticisms, or suggestions to Mr. Lieberman or KLD Associates in conducting an ETE study or in drafting Volume 6 of the NHRERP-Revision 2; data supplied to Mr. Lieberman or KLD Associates having anything to do with the ETE study; or inquiries or reports from Mr. Lieberman or KLD Associates regarding any aspect of the ETE study.

p c t Response to Interrogatory Nos. 22-23 As previously noted in the State's response to Interrogatory No.

19, supra, there have been a number of communications between Edward Lieberman and representatives of the State. Many of these communications were by telephone; others included interviews and meetings at State agency offices. Lieberman met with representatives of NHCDA, State DC^ and State Police on several occasions. No chronology of these ;nformal meetings has been kept.

Copies of the KLD progress reports have been provided to Attorney General Shannon. These progress reports were the basis for the ETE report. In addition to the progress reports, the following letters from KLD to New Hampshire Yankee or the Civil Defense Agency are on file and available for inspection:

1. May 30, 1986 letter fom Ed Lieberman to Mike Nawoj relating to the final reports

2. October 10, 1986 letter from Ed Lieberman to Seabrook Station relating to the overview of evacuation plan and time estimates;

3. August 15, 1986 letter from Ed Lieberman to Dick Strome relating to draft response to altered FEMA RAC comments;

4. August- 15, 1986 letter from Ed Lieberman to Dick Strome relating to directing how to respond to request from Town of Brentwood Selectmen;-

5 July 15, 1986 letter from Ed Lieberman to Seabrook Station relating to table specifying cumulative number of vehicles leaving EPZ; 6

July 14, 1986 letter from Ed Lieberman to Mike Nawoj relating to responses to FEMA RAC comments for Civil Defense review and approval;

7. May 30, 1986 letter from Ed Lieberman to Mike Nawoj relating to an update on KLD responses to FEMA comments;

8. May 30, 1986 letter from Ed Lieberman to Mike Nawoj relating to the outline of differences between the final and draft evacuation time and traffic report; and

9. November 4, 1985 letter from Ed Lieberman to Dick Strome relating to calculations on evacuation of EPZ.

The State has had no communication with Lieberman regarding any form of payment. Neither did the State provide him with any written instructions or comments on his work.

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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

See RAC review of the KLD ETE report, provided to the parties by FEMA on December 12, 1986.

25. Do you support the KLD finding that, at mid-day with good weather on a summer weekend in 1987 when the beach area population is at its highest expected levels, and assuming that the evacuation of the beaches begins 20 minutes before a general order to evacuate the entire EPZ is given, the entire population within the entire EPZ can in fact be evacuated within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 15 minutes after the general order to evacuate is given? If you do support this finding, state all reasons why you believe this finding is accurate, identifying all l experts, other persons, and documents upon which you rely. If you do l not agree with or support this KLD finding, state how long you contend such an evacuation would take, and identify all experts, otner persons, and documents upon which you rely.

Response

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The State of New Hampshire believes that the clear times cited in the KLD ETE for the various scenarios are conservative and has incorporated the KLD study into the NHRERP as Volume 6 The State l furthermore believes that the KLD ETE is a valid update of earlier Seabrook ETEs. It closely approximates the previously conducted ETEs sponsored by the Utility, NRC and FEMA. The State bases this position on the KLD study.

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26. How long would an estimated evacuation time for the entire EPZ, in the manner assumed in the previous interrogatory, have to be before you would agree that adequate protective measures cannot be taken to protect the public health and safety? State your reasons in detail for this answer, and identify all experts, other persons, studies and documents upon which you rely.

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Response

-lThe State of New Hampshire objects to this interrogatory on the grounds of relevance, inasmuch as there are no NRC guidelines on acceptable absolute evacuation times. Without waiving this ,

objection, the State responds as follows:

The. State has not devoted any time or resources to this question, and has, therefore, not developed a position on it. >

27. Do you contend that the NHRERP- Revision 2, as drafted and dated August 1986, without further revision, meets the standard contained in 10 C.F.R. 50.47(a) that emergency plans be adequate for the NRC.

to find "that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency"?

a. If your answer is "no", state what revisions in the plan are necessary to meet this standard and whether these revisions have been made,

b. State what responses you (i) have taken, and (ii) intend to take, prior to the off-site EP hearings to respond to the inadequacies identified in the FEMA /RAC Review of Revision 2 of the NHRERP.

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Response

Yes, it is the State's position that NHRERP Rev. 2, when implemented, meets the standards for a " reasonable assurance" finding.

The State is in the process of compiling responses to the RAC Review of Rev. 2. These responses, which will include commitments to continue the implementation of New Hampshire's emergency planning, will probably be assembled and submitted to FEMA in April 1987.

28 Assuming an accident when beaches are at or near capacity and assuming implementation of Revision 2 of NHRERP, do you contend that KLD's ETE study demonstrates that evacuation times are short enough to prevent all fatalities among members of the beach population under all accident sequences? If not, state how many early fatalities would occur, and specify under which accident sequences these fatalities would occur.

29. Do you contend that the number of early fatalities likely to be caused by a serious radiological emergency at the Seabrook plant is not a relevant factor in determing whether there is " reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency"? Explain your answer. If there is a limit to the number of likely early fatalities beyond which you would agree that an evacuation plan does not offer such

" reasonable assurance," state that limit.

Response to Interrogatory Nos. 28-29 The State of New Hampshire objects to these interrogatories on the grounds of vagueness and overbreadth. Without waiving this objection, the State responds as follows:

The State of New Hampshire has no data on fatalities that might result among any populations after an accident at Seabrook Station.

The State cannot state whether the KLD's ETE study demonstrates, or does not demonstrate, that evacuation times are short enough to prevent any fatality unoer any accident sequence.

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i As to whether any fatalities.that may result from a radiological emergency is a " relevant factor" in determining if the NHRERP i

l provides_ adequate protective measures, the State contends that a central. purpose of the NHRERP is to protect the population from

~ radiation exposure, including life-threatening exposure. In working to assure that'the NHRERP satisfies the guidelines of NUREG-0654, the State believes that that purpose is met.

13 0 . On what basis does KLD estimate (Vol. 6, p. 2-27) or assume (Vol. 6. p. 10-3) that there will be 3000 vehicles traveling through L the EPZ when an Alert is announced? Identify all experts, other l persons, and documents including aerial photos, upon which KLD relied l in making this estimate or assumption.

31.- In computing ETE's was the IDYNEV System programmed to assume that there were-3000 vehicles traveling through the EPZ at the time l of an Alert? If so, describe in detail the distribution of these i vehicles inside the EPZ which the model was programmed to assume.

32 Identify the aerial films mentioned on p. 10-16 of Volume 6 of NHRERP-Revision 2 by stating when they were taken, by whom, and who l has this film. Produce this film.

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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 I documents upon which your reasons are based,

b. Identify any other experts, persons, studies, or other doucments which contain information about vehicle demand which differs in any way from that contained in Figures, l 2-4, 2-5, and 2-8 of Volume 6 of NHRERP.

j 34. Identify and produce all documents which indicate or project the population of the following groups inside the EPZ: (a) in the period r

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1985-86, (b) in the summer of 1987, (c) in the next five (5) years, or (d) over the expected operating life of the Seabrook plant:

1. Permanent residents population

2. Employee population

3. Seasonal population

4. Transient tourist population

5. Peak beach going population

6. Transit dependent pollution 35 Identify and produce any documents which calculate or project when, as a result of population growth, the ETE's contained in Volume 6 of NHRERP may become unreliable.

Response to Interrogatory Nos. 30-35 KLD Associates, Inc.'s services relative to Volume 6 of the NHRERP have been retained by the Applicants, not the State of New Hampshire. It is the State's understanding that the Applicants will respond to these interrogatories (which were also propounded on the Applicants). The State, therefore, will defer to the Applicants on these interrogatories.

36. For each New Hampshire town which is not participating in evacuation planning, (1) state the name, city or town of residence, name of employer, job title or position, and location of usual work site for each traffic guide, bus driver, or other emergency worker the State of New Hampshire intends to mobilize to perform an emergency response functions (2) describe for each such person which traffic control post or other function each said person has been assigned; and (3) list for such person how long it is estimated it will take to travel to the assigned duty post: (a) from said person's home and (b) from said person's usual work site.

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Response

The New Hampshire RERP contains an emergency response plan for each municipality within the Seabrook Emergency Planning Zone. The NHRERP provides that in the event municipal officials, for whatever reason, are not able to carry out their duties, the State response organization will take measures to provide assistance or if necessary carry out instead of local officials, the actions which may be required to notify and protect the public. See Volumes 4, 4A and 4B which contain procedures and contact lists.

A Traffic Management Manual extracted from the ETE (which is included as Volume 6 NHRERP) provides the location of each access control or traffic control point in each municipality.

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-Transportation resources are listed in Volume 2 Appendix It names and addresses of bus drivers are maintained by the management of bus companies. It is estimated that it will take from a few minutes to approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to initially mobilize transportation resources. Traffic and access control personnel mobilization is based on a priority system that is described in the Traffic Control Manual. To implement the TCP's and ACP's would talk less than one hour.

The State does not have the specific information required in Interrogatory No. 36(1).

37 In calculating that an Immediate General Emergency would extend the ETE's by 20-30 minutes.(see p. 10-16 of Volume 6), how soon after the evacuation order is given did KLD assume that all traffic management and control measures would be in effect. State your basis l

for this anwer and identify any documents and experts upon which you rely for your answer.

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38. What is the basis for the assumption, noted on p. 10-3 of volume 6 of NHRERP, that 25 percent of the population within the EPZ, but outside the region ordered to evacuate, will spontaneously evacuate, contrary to instructions? Identify any surveys, studies or experts

! upon which you rely in making this assumption.

39. In calculating ETE's with the "25 percent" assumption noted above in. Interrogatory 25, vas it assumed that those who would spontaneously evacuate would be randomly distributed throughout that portion of the EPZ not ordered to evacuate? If not, what distribution was assumed? In either event, state the basis for this

! assumption and identify any surveys, studies, and experts upon which

you rely for this assumption.

Response to Interrogatory Nos. 37-39 See State's response to Interrogatory Nos. 30-35, supra, i

l l 40. Have any studies or surveys been conducted since the nuclear j reactor accident at Chernobyl to see what effect this event has had on KLD's 25% spontaneous evacuation assumption? If so, identify any such studies or surveys.

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Response

The State of New Hampshire knows of no such studies.

41. Did the KLD study contained in Volume 6 of Revision 2 of the NHRERP assume or take into account in any manner that some portion of the population beyond the EPZ would also spontaneously evacuate, taking up some roadway capacity beyond the EPZ and thereby impeding evacuation progress out of the EPZ? If so, describe how this was taken into account. Identify any studies or surveys, conducted both before and after Volume 6 was published, which you have gathered on this topic.

Response

See the State's response to Interrogatory Nos. 30-35, supra, i

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-42. In Volume 6 of the NHRERP-Revision 2, Appendices F and G are not entirely legible. Produce a legible copy of each.

Response

Legible copies of Appendices F and G to Volume 6 were provided to the parties in this proceeding with the State of New Hampshire's December 12, 1986 Status Report.

43. Describe in detail the methodology for the telephone survey I described in Apendices F and G of Volume 6 of Revision 2 of NHRERP,  ;

including, inter alia, who conducted it, what the instructions were to each telephone survey researcher, what was the sample strategy used to select the numbers called, how many calls were made altogether to produce the 1300 responses included in the tabulation (App. F), the schedule of actual phone calls attempted and phone calls completed by time of day and day of week, what methods were applied to ensure against having a non-response bias in the survey, and what validity and reliability tests were applied to assess the representativeness of the responses obtained. Also identify who has the actual survey data sheets. Produce all written descriptions of the survey, the survey methodology, all drafts of the survey instruments, instructions given to the survey researchers, all computer readable data sheets poduced by them, all computer print-outs, all documents assessing, reviewing, validating, or critiqueing the results, and all correspondence regarding this telephone survey, identifying each correspondent.

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Response

See State's response to Interrogatory Nos. 30-35, supra.

44. Have you, KLD, or anyone else conducted any other telephone or in-person survey research or poll to assess, or re-assess, trip generation time or any other aspect of the expected evacuation behavior of persons residing within the Seabrook EPZ? If so, please identify and produce all documentation relating to such surveys.

Response

Yes. See NHRERP, Volume 6, Section 4 and Appendix E. No reassessment has been conducted. But see also the State's response to Interrogatory Nos. 30-35, supra.

45. In conducting the ETE study, did KLD assume that all community workers would return home in their normal time frames? State the b0 sis for your answer and identify any studies, experts, and other information upon which you rely for your answer.

Response

See State's response to Interrogatory Nos. 30-35, supra.

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 P? .If not, state what you contend the accurate numbers are, and identify the source or sources of your information.

Response

Yes.

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47. List the names and home addresses, employment addresses, and traffic control assignments of each of the New Hampshire traffic control personnel.

Response

See State's response to Interrogatory No. 36, supra.

48. Identify and produce copies of all the instructional sheets, manuals, or guides which have been given to these New Hampshire traffic control personnel.

Response

Training Module 13, a one (1) hour session of the training program provides traffic control personnel with the necessary information required to utilize the Traffic Control Manual and to understand terms used in this segment of training. Assistance is provided to evacuees through knowledge of the contents of the Traffic Control Manual. The Traffic Control personnel are already proficient in the skills of traffic control and working under emergency situations since they are police officers, auxiliary police, Sheriff's Deputies, and other personnel with the same type of background.

The only instructional sheets to Traffic Control personnel are representative samples from the Traffic Control Manual. Such samples are available for review at NHCDA Offices.

49. Does Revision 2 of the NHRERP reflect the specific assignment of l

l the tow trucks recommended in Table 12-1 of Volume 6 of Revision 2 of the NHRERP? If your answer is yes, state where and how these I

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assignments are reflected, and list the name, home and business address, and specific location assigned for each tow truck driver.

Response

No. At the time of mobilization, NHCDA will specify the

. specific area for deployment. Information on private tow truck companies is included in the Letters of Agreement with them, NHRERP, Vol. 5.

50. Have any surveys or other studies been conducted to assess the impact or role conflict on those traffic control personnel, bus and tow truck drivers, law enforcement and other emergency workers who have families residing within the EPZ? If so, identify and produce said studies.

Response

The State of New Hampshire has not conducted such a study.

51. Have any studies or surveys been conducted to assess any aspect of the likely evacuaton behavior of the beach-going or other transient population inside the EPZ? If so, identify and produce said study.

Response

New Hampshire knows of no such study specific to the Seabrook EPZ.

52. At page 11-18 of Volume 6 of Revision 2 of the NHRERP it is noted that a " telephone survey" of organizations which own and operate buses was undertaken to obtain estimates of mobilization time.

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a. Produce a copy of the survey methodolgy and the survey instrument or form; l

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b. ,If~none exist, describe'themethodologyEndetail, specifying the questions asked; c.

Describewhnthissurveyoccurredandwhoconducted11b;

.d.

Produce-the survey dati collection sheets identifying for each.thenameandaddress'o{thecompanycalled; c

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If no survey data sheets exist, l'ist ea :h bus company 3 called, who.was spoken to,.the questions asked and the responses given; ,

f.

Describe _how, if at all, the results of-this telephone survey were checked for reliability; g.

Identi.fy and describe any follow-up studies that have been or wil1 be done to re-absess or- refine the estiniates of bus mobilization time utilized in Volur.3 6 of the NHRERP-Revision 2. '

Response .

SeeState'sresponsetoInterrogathryNos. 30-35, supra.

1 53 Produce copies of all instructions and instructional materials which will be or have been provided to bus drivers (a) prior to an accident and (b) at staging areas upon their, arrival during an evacuation.

Response

A.

The materials to be provided prior to an accident are:

Radiological Emergency Response Training.-New Nampshire Civil Defense Agency. . .

Module 1 ' '

Basic RERP .

Module 2 Radiological Exposure Control'

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Module 19 b' .

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s B. The material to be provided at staging areas are:

1. Emergency Worker Information to be issued with do[imetersandDosimetry-KIReportForm.

2. Map to local staging areas..

,[ ., 3. Maps to destinations.

/ 54. What is the number of transit dependent persons in the EPZ which you contend,should be utilized in calculating ETE's and the need for transit assistance vehicles. Describe in detail (a) the metholodogy used to calculate this number, (b) all assumptions made in conducting this calculation and the reasons, documentation, studies, and experts supporting these assumptions. Produce all documents and studies which you have relied on or have reviewed in calculating the number of transit dependent persons.

Response

The methodology and the number of transit dependent persons in the EPZ utilized in calculating ETE's is contained in NHRERP, Volume 6, Sectio'n.la The number of transit dependent persons in the EPZ utilized for c!alculating the need for assistance vehicles was determined by the llHCDA survey. A sample of the survey is available for inspection at the NHCDA offices.

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[ 55 .Produceleach of the records, studies, photos, slides,

[ reports, f.

and other, documents referenced in Appendix E of Volume 6 of the NHRERP-Revision 2. ,

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Response

y See State's response to Interrogatory Nos.'30-35, supra, a

56 r

Produce all correspondence and documents passing between you and FEMA since your receipt of the FEMA /RAC Review of Seabrook Station Evacuation Time Estimates and Traffic Management Plan Update contained in the State of New Hampshire Radiological Emergency Response Plan,(Rev. 2-8/86).

Response

i The State of New Hampshire objects to the breadth of this. i interrogatory as including requests for relevant and irrelevant

.aterial.

Without waiving its objection, the State responds as )

l follows: I The following documents are on file and are available for inspection:

A. Letters from FEMA l.

December 18, 1986 letter from FEMA to all Civil Defense Directors, Region 1, relating to guidance for protective actions for school children; a'

o .. .1 l

2.' December. 18, 1986 letter from FEMA.to all Civil Defense Directors,-Region'1,-relating to guidance memo MS-1 medical services;

3. JanuaryL20,.1987 letter from FEMA to all Civil Defense Directors, Region 1, relating to draft guidance memo In-2, the

-ingestion pathway; 4 January 30, 1987 letter from FEMA to all' Civil Defense

' Directors,' Region 1, relating to generic safety concerns regarding alert and notification system;

5. February _2, 1987 interoffice letter copied to New Hampshire, Vermont and Massachusetts about maintenance and testing program for public notification:

6 January 26, 1987 letter from FEMA Regional Director to Representative Bob Smith relating to FEMA responses to the 20 questions posed by Bob' Smith regarding evacuation:

7. December 19, 1986 letter from FEMA to Richard strome e'

requesting that New Hampshire change some of its answers to Bob Smith's 20 questions with suggested changes; ci

,5 e

.--e,,g-- , . - - - - ~ - -, ---,----,.-n.- ~ ~ ,--,,,,-,.-,--,,w-----4-- , .m e,,,.,. ,,,r-, ,, ,

.o .

8. January 22, 1987 letter from FEMA to Richard Strome relating to instructions to enter in "FIPS locator codes on annual submissions;

9. January 27, 1987 letter from FEMA to Richard Strome relating to amendment to letter of credit from FEMA to New Hampshire Civil Defense increasing budget allocation;

10. . January 14, 1987 letter from FEMA to Richard Strome requesting New Hampshire Civil Defense annual letter of certification;

11. January 6, 1987 letter from FEMA to all Civil Defense Directors, Region 1, relating to guidance on REP programs;

12. December 19, 1986 letter from FEMA to Mead Henrick, NHCDA, relating to instructions on how to destroy USCAT materials;

13. December 5, 1986 letter from FEMA to Richard Strome relating to New Hampshire's participation in civil rights compliance review; and

14. February 18, 1987 memorandum per telephone conference from Ed Thomas to Richard Strome.

, - -,-7 -- , . .

B. Letters from Civil Defense to FEMA

1. March 11, 1987 course evaluation forms from Keller to Henry.

.Vickers relating to course on Radiation Monitors.

2. March 9, 1987 letter from Richard Strome to Henry Vickers relating to National Emergency Response Structure.

3. March 3, 1987 letter from Hayden to Donovan relating to Donovan review on February 2, 1987 of New Hampshire Hazardous Mitigation Plan.

4. March 2, 1987 letter from David Hayden to Pisco relating to New Hampshire Disaster Preparedness Plan and Emergency Declaration Process.

5. January 27, 1987 First Quarter Reports for 1987 from Saggiotes to Henry Vickers.

6. January 29, 1987 letter from Keller to Howell relating to the ordering of 200 Radiological Protection Preparedness Manuals.

. . l

7. January 2, 1987 letter from Richard Strome to Henry Vickers relating to submitting copies of plans, statutes, etc.

8. January 10, 1987 letter from Michael Nawoj to Henry Vickers

,. relating to Bob. Smith's questions that the State has incorporated FEMA suggestions, i 1

57. List and describe each and evey change that you have made to Volume 6 of the NHRERP-Revision 2 since it was published.

Response

No changes have been made, l

58. List and describe each and every step you or KLD have taken to address the. issues raised in the FEMA /RAC Review of Volume 6 to the NHRERP-Revision 2.

Response

See State's response to Interrogatory Nos. 27, 30, and 35, supra.

59. Produce all documents relating to the survey of all residents of New Hampshire conducted in June 1986 by the New Hampshire Civil Defense Agency and referenced on page 11-9 of Volume 6 of the NHRERP-Revision 2. This production should include the survey instrument, methodology, sample strategy, measures of its validity and reliability, data collection sheets, computer print-outs, and tabulations of results.

Response

New Hampshire Civil Defense Agency, NHCDA, with the assistance of New Hampshire Yankee, NHY, mailed 35,495 special help needs survey letters to residents living within the ten (10) mile emergency

planning zone of the Seabrook Nuclear Power Station. Copies of the letter are available-for review at New Hampshire Civil Defense Agency Offices.

The first official report of receipts of the "Special Help Needs" survey card was compiled and completed by New Hampshire Civil Defense Agency on April 21, 1986. (The results are available for review at New Hampshire Civil Defense Agency Offices).

In accordance with established procedures, all receipts were duplicated and placed in town files. The originals were delivered to the local EPZ communities, by New Hampshire Civil Defense local liaisons. The New Hampshire Civil Defense Agency local liaison explained the procedures to be followed in verifying returns and offered the Agency's assistance in this process.

In July 1986, New Hampshire Civil Defense Agency conducted a telephone survey of responders requesting ambulance transportation.

Temporary adjustments were made for those responders indicating the need for transportation generally versus those specifically citing the need for an ambulance.

60. Produce the transcript of the audio cassettes made by KLD

_ personnel as they drove the entire highway system within the EPZ and poritons beyond, as referenced on p. 1-10 of Volume 6 of the NHRERP-Revision 2.

61. Produce all additional information and studies which update or refine the highway characteristics documented in the field survey described in the previous interrogatory. -

62. Please provide any other. documents, including aerial photos, you or KLD have reviewed regarding the size of the beach population which were not listed in Appendix E of Volume 6 of the NHRERP-Revision 2 Response to Interrogatory Nos. 60-62 See State's response to Interrogatory Nos. 30-35, supra.

63. Do you admit that the NHRERP contains no contingencies which permit the redirection of evacuating vehicles in response to a change in plume direction? If your anwer is negative, explain in detail what these contingencies are and how they would be implemented.

Identify any person, expert, and document upon which you rely for your answer.

Response

The protective action decision criteria used by the State are described in NHRERP Vol. 1, Section 2.6.7 The criteria provide for reconsideration of protective action recommendations based on several variables, including plume direction. As plume direction changes protective action recommendations may change. As noted in Section 2.6.4 of Volume 1 evacuation is implemented on a municipality-by-municipality basis. As plume direction changes new

' towns may be added to the list of municipalities advised to evacuate. In no circumstance, however, does the State foresee advising the evacuating population to change routing in the middle of an evacuation, as such instructions are likely to cause significant confusion. In all instances the State will attempt to expedite evacuation using the most accessible system of routes leaving the EPZ in a generally radial pattern.

_-_ _ . . _ _ . -_- , y _

64. Describe in detail what traffic guides have been instructed to

.do:

a. When evacuating drivers seek to go in a direction described on the intersection sketches as " movement discouraged";

b. When evacuating drivers stop, thereby blocking a line of vehicles, to speak to the_ traffic guide for any reason (complain, ask directions, seek assistance, etc.);

c. when evacuating drivers stop to obey traffic lights and stop signs;

d. when evacuating drivers seek to disobey traffic lights and stop signs;

e. when an accident or a breakdown occurs which blocks or impedes traffic through an intersection.

Response

Instructions to traffic guides are found in the Traffic Management manual.

a. It is anticipated that evacuating drivers will take directions from traffic control personnel who will prompt and encourage drivers in a direction that would provide the most expeditious evacuation routes.

Drivers who are not yet evacuating, that is those who may be returning home to pick up family, friends or relatives who may need a ride, will not be prohibited from executing traffic movements other than those being encouraged by traffic management personnel,

b. It is anticipated that the traffic guide as well as the vehicles behind the stopped vehicle will prompt the driver to find a quick resolution to his problem.

c. Rules of the Road (R.iA 265:9) dictate that the_ presence of a traffic officer supercedes fixed traffic signals at an intersection,

d. See a. , b. and c. , sur:ra,

e. Traffic guides have cormunications equipment, and can call for assistance. In addition occupants of vehicles behind the broken down vehicle would likely provide assistance in moving broken down vehicles out of the way.

Also, see the State's response to Interrogatory No. 48, supra.

65. Will traffic control guides be stopping drivers to question and direct them to appropriate evacuation routes and host communities?

Response

No.

66. Identify and produce each and every document, including correspondence, which pertains, directly or indirectly, to any contention to be litigated by the Attorney General and was exchanged between you and FEMA since your receipt of the FEMA /RAC Review of the NHRERP-Revision 2.

Response

See State's response to Interrogatory No. 56, supra.

67. Describe each change which has been or will be made to the NHRERP-Revision 2 since it was published and which pertains, directly or indirectly, to any contention to be litigated by the Attorney General. If said changes are noted in any documents, produce said documents.

Response

See State's response to Interrogatory No. 27, supra.

68. Produce computer-readable listing of all input files and data necessary to reproduce; (a) the IDYNEV runs documented in Volume 6 of the NHRERP-Revision 2; and (b) any subsequent runs, conducted in response to the FEMA /RAC review or Revision 2 or for any othr reason, relating to refining, correcting, supplementing, updating, testing, or revising the evacuation time estimates contained in Volume 6 of the NHRERP-Revision 2. Indicate whether the computer readable listings produced in response to (a) are identical to the data files currently stored at FEMA in Washington, D.C.

69. Produce paper copies of the IDYNEV outputs produced in the runs specifiad in the previous interrogatory.

70. Produce all empirical data, studies, or surveys used to support the snow clearance time estimates shown on page 4-20 of Volume 6 of the NHRERP-Revision 2. Indicate what personnel, by name, address, and employment position, will be used for snow clearance and if NHRERP-Revision 2 depends upon the same personnel to perform other emergency response tasks.

71. Describe in detail the telephone inquiries of hotel / motel managers referenced on page 6-1 of Volume 6 of the NHRERP-Revision 2, and produce copies of all related documents, including those which contain the dates calls were made, text of the questions asked, the tabulated responses, and the list of the hotels / motels called. If no documentation exists, state who was called, when calls were made, what questions were asked, and what response each call produced.

72. In computing evacuation time estimates, what, if any, data was included in the computation regarding estimates of the time required to set out cones, signs, and barricades? Indicate by name, address and employment position, the personnel _ designated to set out such cones, signs and barricades.

Response to Interrogatory Nos. 68-72 See State's response to Interrogatory Nos. 30-35, supra.

73. List the anticipated storage locations for cones, signs, and barricades.

Response

The State of New Hampshire hereby adopts and incorporates by reference herein the Applicants' response to Massachusetts Attorney General Interrogatory No. 73 filed on March 18, 1987

74. Is it your position that sheltering will never be relied upon as a protective action for the summer transient beach population located within ten miles of the Seabrook plant, or for any portion of that population?'

r

Response

It is not the position of the State of New Hampshire that sheltering will never be relied upon as a protective action for the summer transient beach population located within ten miles of the Seabrook plant, or for any portion of that population.

75 If sheltering is to be relied upon as a protective response option only for a portion of the summer beach population, please identify that portion of the population, and the basis for any determination that sheltering should be a response option for-that portion and not the remaining portion of the transient summer beach population.

Response

The RERP provides at Section 2.6.5 (at 2.6-6) that the transient population, which includes the transient beach population, should, when sheltering is recommended, leave the EPZ. Should a limited number of the transient population not have access to means to evacuate, they may, as stated in Section 2.6.5 (at 2.6-6) be requested to take shelter at the locations they are visiting that is to go indoors.

This is consistent with the preferred protective response of evacuation for the period between May 15 and September 15 for both the resident and transient population at Hampton Beach and Seabrook Beach from Ocean Boulevard and Little Boars Head to the north and

Ocean Boulevard and Route 286 to the south, even though the decision criteria might indicate that sheltering is a sufficient' protective response (see Appendix F, Vol. 4 and Appendix U, Vol. 4A, NHRERP).

When no such shelter is available to the transients not able to leave that beach area or any portion of the EPZ when sheltering is recommended the.RERP provides for an ad hoc decision to open public facilities for sheltering (see section 2.6.5 at 2.6-6).

The basis for the above provisions is not the result of any determination that sheltering should be a response option for part but not all of the transient summer beach population. It is, rather, a response option for~those who have no means of' leaving the area when sheltering is recommended and who also have no means of shelter.

76. Please provide any documents you have reviewed that are relevant to the conclusion (s), set forth in response to interrogatory 74 that sheltering will or will not ever be relied upon as a protective response for the transient summer beach population.

Response

The State of New Hampshire arrived at the conclusion set forth in response to Interrogatory No. 74 without reviewing any documents and, therefore, has no documents to provide.

77. Please identify all documents you intend to rely upon to support your position that sheltering will or will not be used as a protective response for the transient summer beach population.

Response

See State's response to Interrogatory No. 76, supra.

78. Unless your-answer to interrogatory 74 is an unqualified yes, describe when and under what circumstances, including types of accident-sequences and meteorological conditions, you anticipate that sheltering will be relied upon as a protective action for the summer transient beach population.

Response

The circumstances are described in response to Interrogatory No.

75. The state cannot speculate as to the " types of accident sequences and meteorological conditions" that could be associated with such circumstances.

79. Please provide any plans you have relative to sheltering the transient summer beach population, and indicate if, how, and when you intend to amend or add to those plans in any way.

Response

~

See State's response to Interrogatory No. 75, supra. The state has no intention, at this time,-to amend or add to those plans.

80. If no plans for sheltering the transient summer beach population currently exist, please indicate if, when and how you intend to develop any plans for sheltering the transient summer beach population located within ten miles of the Seabrook plant.

-Response See State's response.to Interrogatory No. 79, supra.

s 81. If the transient summer beach population, or any portion thereof, is instructed to shelter, how, by whom and on what basis will that decision to shelter the beach population be made? Please provide any documents on which you intend to rely in making that decision.

Response

Appendices F, Vol. 4, and U, Vol. 4A, of the NHRERP provide the decision criteria to be used by the Directors, NHCDA and DPHS in formulating recommendations. The decision process is described generally at Section 2.6.7, Vol. 1, NHRERP. Section 2.6.5, at 2.6-5 and -6. describe the notification process. See also State's response to Interrogatory No. 75, supra.

82. If the transient summer beach population, or any portion thereof, is instructed to evacuate, how, by whom and on what basis will that decision to evacuate, how, by whom and on what basis will that decision to evacuate the beach population be made? Please provide any documents on which you intend to rely in making that decision.

Response

See the response to Interrogatory No. 81 for the information requested in.this interrogatory.

83. Please describe your methods for estimating radiation releases.

Response

The state will rely on any of four methods for estimating radiation releases. Section 2.5, Vol. 1, NHRERP describes the accident assessment process.

84. Please describe, and provide all documents pertaining to, all meterological.models to be used for projecting doses off-site.

Response

The models used for projecting doses off site during.the accident assessment process, are provided as Appendices N, 0, P, and Q, Vol. 4A,-NHRERP.- This material has been provided, and the METPAC manual is available for inspections.

85. 'Please describe any provisions in the plans, or means available, to monitor during an emergency the public's compliance with the State's protective action instructions, including whether there is a capability and an intent to monitor during the course of an emergency in which the public is instructed to shelter the numbers of persons evacuating from the area.

Response

This monitoring is done largely by the NHCDA Local Liaison personnel. Their procedures are included in NHRERP Vol. 4. Also see IFO Controller procedures-and Resource Officer procedures that are contained in Vol. 4.

86. Is it your position that sheltering should never be relied upon as a protective response action for the transient summer beach population located within ten miles of the Seabrook plant, or for any portion of that population?

R3sponse See State's response to Interrogatory No. 81, supra.

87. 'Unless'your answer to interrogatory 86'is an unqualified yes, describe under what circumstances, and for what portion of the population, sheltering should be used as a protective response-for-the-transient summer beach population.

Response

See State's response to Interrogatory Nos. 75 and 81, supra.

8 8. - Please provide the basis for your determination.that sheltering should or should not ever be used as a protective response option for all, or any portion of, the transient summer beach population.

Response

See State's response to Interrogatory 75, supra.

89. Please provide the basis for your determination that sheltering.

should or should not ever be used as a protective response option tor all, or any portion of, the transient summer beach population.

Please provide any documents you have reviewed that are in any way relevant to the conclusion (s) set forth in response to interrogatory 86.

Response

See State's response to Interrogatory 75, supra.

There are no documents other than the NHRERP, that serve as the basis for this conclusion.

90. Please identify all documents you intend to rely upon to support your position that sheltering should or should not ever be used as a protective response option for each portion of the transient summer -

beach population located within ten miles of the Seabrook plant.

Response

See State's response to Interrogatory 89, supra.

7

91. Is it your position that sheltering of the transient sunser beach population is feasible at all beach areas locatea within ten-mile of the plant?

Response

It is the position of the State of New Hampshire that sheltering is feasible using public facilities for that portion of the transient summer beach population. unable to evacuate. Also see the State's response to Interrogatory 75, supra.

92. Please identify those beach areas within ten miles of the Seabrook plant for which sheltering of the transient population would not be a feasibl' response.

Response

The State has made no investigation of tnis issue.

93. Please provide the basis for your determination that sneltering of the transient beach population, or a particular portion tnereof, is or is not feasible.

Response

See the State's response to Interrogatory No. 75, supra.

94. Please provide any documents you have reviewed that are in any way relevant to the conclusion (s) set forth in response to interrogatory 90.

Response

Interrogatory 90 does not call for a conclusion. Tne state ot New Hampshire assumes the reference is to interrogatory 91. If tnis assumption is correct, the State of New Hampsnire nas reviewea no such documents. I 1

1 I

40 -

95. Please identify all documents you intend to rely upon'to support your position that sheltering of the transient summer beach population, or any portion thereof, located within ten miles or tne Seabrook plant is or_is.not feasible.

Response

The State does not presently intend to offer any evioence or rely on any documents in this licensing proceeding.

96. Is it your position that adequate. physical facilities exist in all beach areas located within Seabrook's ten-mile EPZ to shelter the entire peak transient summer beach population?

9 7._ Please provide the basis for your response to' interrogatory 95 that adequate physical facilities do or do not exist.

98. Please provide any documents you have reviewed that are in any-way relevant to the conclusion (s) set forth in response to interrogatory 95.

99. Please identify all documents you intend to rely upon to support your positon that adequate physical facilities do or do not exist to shelter the entire peak transient summer beach population.

Response to Interrogatories Nos. 96-99 The State has not determined whether adequate physical facilities exist to shelter the entire peak transient summer beach population.

l

100. Please identify all facilities that could be used-to snelter tne transient summer beach population and provide the dose reduction factor for each, identifying for each the basis for.your determination of the dose reduction factor and provioing all' computations, materials, photographs, notes ano other materials relied upon or reviewed in determining the dose reduction fctor of each building or facility.

Response

The State does not have the information requested regarding all potential facilities.

101. Is it your position that sheltering of the transient summer beach population located within ten miles of the Seabrook plant could never be an adequate protective response action for that population, or for any portion of that population, under any plausible accident scenario?

Response

No. See State's response to Interrogatory 75, supra.

102. Please provide the basis for your response to interrogatory 101, and unless your answer to that interrogatory is an unqualifiec yes, state under what circumstances, incluaing accident sequences and meteorological condtions, sheltering could provide an acequate protective response for the transient summer beach population, or any portion _thereof, locateo within ten miles of the SeabrooK plant.

Response

See State's response to Interrogatories 75 and 78, supra.

. s 42 -

103. Please provide any documents you have reviewed that are in any.

way relevant to the conclusions set forth in response to interrogatives 101 and 102.

Response

There are none.

104. Please identify all documents you intend to rely upon'to support your position that sheltering of the transient summer beach population could or could not ever be an adequate protective response option for that population.

Response

The State does not presently intend to offer any evidence or rely on any documents in this licensing proceeding.

105. Is it your position with regard to the transient summer oeach population, or for any portion of that population, that the protective response of sheltering could never achieve the same level of dose reduction as the protective response of evacuation?

Response

No.

106. Please provide the basis for your response to interrogatory 105.

Response

Many different scenarios can be postulated, and for at least some of them, the DRF associated with shelter will equal or exceed that for evacuation.

107, Please provide-any documents you have reviewed that are relevant to the conclusion (s) set forth in response to interrogatory 105.

Response

There are none.

108. Please identify all documents you intend to rely upon to support your position set forth in response to interrogatory.105.

Response

The State does not presently intend to offer any evidence or rely on any documents in this licensing proceeding.

109. Is it your position that with respect to the transient summer beach population the protective response of' evacuation will in all cases provide an adequate level of protection?

Response

It is the State's position that the protective response provisions in the NHRERP provide an adequate planning basis for protecting the public in the event of an accident at Seabrook Station. A determination of whether evacuation "will in all cases provide an adequate level of protection" requires the State to e

postulate "all cases". The State has not made any such postulation.

110. Is it your position that for the transient summer oeach population the protective response of evacuation will in all cases be an adequate protective measure?

111. Please define your use of the terms "acequate" and " adequate level of protection" with respect to your response to interrogatory 109 and define your use of the term " adequate protective measure" with respect to your response to interrogatory 1107

. .o 112. Please provide the. basis for your responses to interrogatories 109 and 110, including all documents you rely upon in support of those responses.

112a. If your answer to either interrogatory 109 and 110 is anything but an unqualified yes,.please identify and describe those situations for which the protective response of evacuation will not be " adequate" or achieve an " adequate level of protection" and the manner in which the respnse will not be adequate?

113. If your answers to interrogatories 109 and 110 are anything but an unqualified yes, please describe what, if any, other c.c additional actions will be taken to protect the population in those situations were the protective response of evacuation is not deemed by you to be an' adequate' protective measure or expected to achieve an adequate level of protection.

Response to Interrogatories Nos. 110-113 See State's response to Interrogatory 109, supra.

114. Is it your position that with respect to the off-site population no early fatalities, defined herein as death from radiation exposure within thirty to sixty days, could result from an accident at Seabrook, and, if not, how many early fatalities might result in your view of a worst-case scenario?

115. Please define " worst-case scenario" as used by you to respond to interrogatory 114.

116. Please provide all data, charts, and statistics you have indicating types of accident sequences and scenarios (under varying meteorological conditions) that might result in fatalities to the off-site population within ten miles of the Seabrook plant, and the numbers of such possible fatalities.

117. Please provide all documents you have reviewed indicating what effect, if any, the protective responses of sheltering and evacuation will have on the numbers of fatalities or incidents of serious radiation illness that might result from the accident sequences and scenarios identified in response to interrogatory 116.

Response to Interrogatories Nos, 114-117 The State of New Hampshire objects to these interrogatories on the grounds of vagueness and overbreadth. Without waiving this objection, the State responds as follows:

See the State's response to Interrogatory Nos. 28-29, supra.

118. Please describe separately for the general population witnin ten miles of the Seabrook plant, for the permanent population within tive miles of the plant, for the permanent population witnin two miles of the plant and for the transient summer beach population witnin ten, five, and two miles of the plant, under wnat circumstances, ana for what types of accident sequences and scenarios, and meteorological conditions, the protective response of sheltering will be prescribea.

Response

The protective response of sheltering is described in Section 2.6.5, Vol. 1, NHRERP. The decision process is given in Section 2.6.7 of that volume. The decision criteria are provided in Appendices F. Vol. 4 (NHCDA Procedures) and U, Vol. 4A (DPHS Procedures). Further information is provided in responses to previous interrogatories. The responses to interrogato' ries 74 ano 75 describe the State's position relative to transient summer beacn populations and beach populations in general.

119. Please describe when, including under what types of accident sequences and scenarios and meteorological conditions, the protective response of sheltering would, if used instead of just evacuation for the transient summer beach population, result in lower radiation exposure to that population.

Response

The State has not made the potentially infinite number of calculations implied by this interrogatory. Instead it has established rational procedures for selecting appropriate protective actions based upon specifics of a given accident. As noted previously this process is described in the NHRERP Vol. at Sections i 2.6.5 and 2.6.7. Also see Vol. 4, Appendix F.

1 l

l

a .

120. In determining whether to shelter or immediately evacuate

. persons in the beach. area, including the permanent population ano overnight visitors, what considerations, if any, will be given to meteorlogical conditions along the shore?

Response

Consideration of meteorological conditions along the shore will take place during the accident assessment process and during the protective action decision making process. Meteorological conditions are crucial to determining the dose consequence of an accident and a significant factor influencing the implementation of any decision to evacuate. The considerations given to meteorological conditions is described in Vol. 1 Section 2.6.5 and 2.6.7. Also see Vol. 4A Appendix J, which outlines the meteorological data obtained from the applicant, and Appendix N, the METPAC users manual used oy DPhS in its dose calculations.

121. Please describe and identify what equipment or other means you have for plume tracking and for monitoring weather anc wino conditions througout the EPZ and specifically along the shore.

Response

The State relies on two sources of meteorological cata for its plume dispersion calculations. The Applicant and DPHS monitoring team meteorological measurements are described in Section 2.5.3(e) and (h) in Volume 1 of the NHRERP. The contents of the DPHS monitoring team meteorological kit is listed in Appendix G of Volume l

l 1

y 3 4A of the NHRERP.-

In addition to data from the Applicant's local meteorological equipment, supplemental data from tne ConcordIFlight Service. Station NWS, NOAA, and Pease Air Force Base will be available for monitoring weather and~ wind conditions. Plume tracking will'be conducted by monitoring teams from the Applicant and from.DPHS.. DPHS monitoring teams will follow procedures described in Appendix C ot Volume 4A of the NHRERP.

122.

If the protective response of sheltering is ever to ce usea tor any portion describe, of provide and the transient summer beach any materials not population, please included in.tne NHRERP the precise wording of any instructions, relevant to, how that po and how, by whom, and where they will be directed to go?

Response

Appendix F~ outlines the strategy to be used to address the potential implementation of precautionary actions in tne Hampton Beach area. . Volume 1, Section 2.3 outlines the EPI. Volume 3 Appendix B contains EBS Messages.

Volume 4 contains Procedures for activating EBS and the Alert Notification System.

123.

the transient summer beach population, please provide have, be or otherwise your opinion, on how rapidly sucn sheltering coula effectuated?

Response

For those transients with access to accommodations at tne beacn, it is expected that their movement to shelter would be no longer than that of residents.

v _

~,

_(.

124.'Insituationswherethedeneralpopulationisdjrectedtotake shelter, precisely whatJinstructions _will be given t6 the transient summer beach populatio,n, assuming the beaches have not already Deen

~

closed? -

Response 3

/

Instructions to the " transient population" will be no cif fer' erst - ,

than those .given to generai population. See vol. 2 Appendix B.

v Note, however, that'the transient beach populatioa'will have been to I directed to leave the beaches before shelter directives are issued

~the general puglic.

125. In situations where the transient beach'populdtion, but not the' general population, is directed to evacuate, precisely what "

instructions,t if any, will be given to permanent residents and

~

overnight v.isitors in the beach areas?

Response ,

NewHampsh[redoesnotenvisionasituationwherethetransient

~

population would be given instructions which dif fer f rom 'tnose given.

.a to the general public.

126. Is it your opinion that the New Hampshire Radiological Emergency Response Plan (NHRERP) provides in any manner for the possibility of an accident resulting inIfanso, large-scyle early (within please identify those several hours) release of radiatign?

sections and pages of the plan which do so provide.

Response

+

Yes. x Volume 1, page i: Purpose.

Volume 1, Section 1.2: Concept of Operations.

t Volume 1, Section 2.1: Notification Network and Procedures, j s

See NUREG 0654,Section I(D), pp. 6-7.

i i

1

r:

s s

f e 127. In the eventsof an1 accident at the Seabrook plant that does result in a large-scale early release of radiation on a peak summer N weekend day, what protective response actions will the following

, populations be instructed to take: (a).the transient summer beacn population; (b) .the non-transient beach population, including overnight visit' ors; and (c) the general population.

128. In the event of an anticipated small-scale short. release of radiation on a peak summer weekend day, what respective protective response actions will the transient summer beach population, non-transient beach population and the general population be instructed to take assuming for each of these populations that the release will occur:

offbsite authorities;. (a) (b) within within thirty minutes one hour; of notification and (c) of within two hours of' notification of off-site authorities.

Response to Interrogatories Nos. 127-128 r

Protective' action recommendations will be determined in accordance with Volume 1 Section 2.6 of the NHRERP and will be based on the specifics of the release and the meteorological conditions.

Protective action recommendations will be uniform for all segments of ths population in an area where a pr'otective action is recommended. However, protection actions may be different for

'different areas of the EPZ based upon the parameters incorporateo into the. accident accessment process.

1

.129. Is it your position that the transient beach population can in all cases be evacuated in time to avoid any radiation exposure to that population?

Response

No.

130. Please provide ths basis for your response to interrogatory 129 and any doucuments relied upon to support that response.

N, s

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131. Is it your position that the transient beach population can in-

f. all cases be evacuated in time to avoid the incurrence of radiation I

[.

exposures in excess of 100 rem by the entire evacuating population.

r-

j. 132. Pleasetprovide the basis for your response to interrogatory'131 j and all documents you rely on to support that response.

l- Response to Interrogatories 130-132 L

V.

l' The NHRERP and emergency planning.in_ general'does not provice  :;

I an absolute assurance of protection, but rather provices reasonablet i

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assurance that'if an accident does occur that the resources. required J to respond adequately'to an emerge'cy n are or will be available.

See NUREG 0654,Section I(D), at 6-7.

1 133. Is it your position that in the event of a large-scale early release of radiation that for the transient summer beach population l the protective response of evacuation will be an adequate protective '

response. action?

( 134. Please provide the basis for your response to interrogatory 133 and all documentsJyou rely on to support that response.

f

Resoonse to Interrogatories Nos. 133-134 See State's response to Interrogatory Nos. 127-128, supra.

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. 135. In the event the transient summer beach population, or any portion-therof, is instructed to shelter, please descrice: (a) wnat j pr,ov'isions or plans, if any, have been made to evacuate such persons

! from those shelters, including'the timing of such evacuations, and if the evacuation is to be staggered, how such persons wili De instructed when to leave the shelters; (b) how the transient population will get to cars after sheltering, or specifically wnat other transportation might be provided to evacuate this population and from where that transportation'will be obtained; (c) any provision for washing off or otherwise decontaminating the transient population and their cars; and (d) any special provision or plans not already specified herein that take into account the possibility that the population could upon exit from the shelters be exposed to radiation, f rom ground deposition or an overhead plume, after exit from the shelters.

)

4

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Response

New Hampshire does not anticipate having to evacute people from shelters.

If, however, the unlikely circumstance arose the Emergency Broadcast System could be'used, perhaps in conjunctions with the alert and notification, system to provide instruction on what actions to take.

The sheltered population would likely be told to walk to-their vehicles.

Buses mobilized for evacuation are restaged at the staging areas from which they could be deployed if this were deemed appropriate.

Decontamination facilities ano personnel at Reception Center would be available if decontamination were necessary.

A decision to move people from shelters would weigh the exposure expected to be incurred while remaining in shelter versus-the exposured incurred in a move from shelter to evacuation.

136. Please identify and provide. copies of all photograpns, including aerial photographs, of the beach area witnin ten miles of the Seabrook plant that are in your possession or that nave been provided by you to, or used by, or are in the possession of any entity, agency, person, tirm, or business, including KLD Associates, that has at any time been retained, contracted with, or paia for by you to perform any activity relative to emergency planning.

137. Please identify, by indicating on maps or othetwise, each and every possible parking space in the beach area within ten miles of the Seabrook plant that KLD Associates identified or counteo in determining the peak numbers of vehicles, or other figures relevant to'the number of persons, in the EPZ beach areas.

138. Please identify and provide copies of all surveys performeo oy you or relied upon by your to identify, or calculate, or that is in any way relevant to a determination of, any population figure provided in the NHRERP, including Volume 6.

139. With respect to any survey identified in interrogatory 138 please provide: all data generated by such surveys; all drafts of such surveys, including drafts of all proposed questions whether used or not used;-and any notes, documents, data, memoranca, or correspondence that are in any way relevant to sucn surveys; and please identify: all methodologies employed; assumptions used; all persons or entities involved in performing or devising sucn surveys; and the names, addresses and phone numbers of all persons surveyeo.

Response to Interrogatories Nos. 136-139 See State's response to Interrogatories hos. 30-35, supra.

140. Please provide all documents, notes, calculations or otner material that have been used by you in determining, or that are in any way relevant to, any of the population figures provided in the NHRERP, including populaton figures for the summer beacn area population, and identify for each such document provided the population figure to which it relates and the manner in which it relates to that population figure.

Response

The basis for population estimates is provided in NHRERP, Vol. 6 Sections 2.4.5 and Appendices E and H.

141. Please identify and provide all documents, notes, calculations, methodology, or other material used, looked at, or listeneo to oy KLD Associates in determining any population figure or other population-related statistic, such as numbers of automobiles or buses, indicated in Volume 6 of the NHRERP, and identify for eacn document so provided the figure or statistic to which it relates and the manner in which it relates to that statistic.

l 142. Please produce all records of the on-site interviews witn emergency planning personnel noted on page 1-2 of. Volume o of tue NHRERP-Revision 2 and state whether these are the same on-site interviews described'on page 1-11 or this volume. If not, please produce records for these interviews as well.

143. Please produce the demographic date obtainea from the State Planning Office noted on page 1-2.of Volume 6 of the NMRERP-Revision 2.

144. Please produce the survey instruments, methodology, data collected, and all documentation pertaining to the field surveys at the beach areas described in the last paragraph of page 1-10 of Volume 6 of NHRERP-Revision 2.

145. Please produce the survey instruments, methodology, data collected, and all documentation pertaining to the field surveys at the beach areas described in the last paragraph of page 1-10 of Volume 6 of NHRERP-Revison 2.

146. On Exhibit 2-1 on page 2-5 of Volume 6 of the NHRERP-Revision 2, wher did the numbers 0.87, 0.98, 0.86, 0.78 come from and identify the assumptions, experts, studies, or other sources upon which they are based.

147. To clarify the " Note" to Table 2-1 on page 2-9 of volume 6, state whether the state data used was for the two years 1960 ano 1965 or the six years 1980 through 1985.

148. Explain why, as statea on page 2-24 of Volume 6, "it is not reasonable to assume that all lots servicing retail establisnments are filled to capacity on a day when the weather attracts people to the beach area." Identify any data, assumptions, experts, or other sources on which you rely.

Response to Interrogatories Nos. 141-148 See State's response to Interrogatories Nos. 30-35, supra.

149. Assuming that Seabrook Unit 1 is licensed and becomes operational: (a) how many employees will work there and (b) how many tourists, including school children, are expected to visit the. plant on an average weekday during the school year?

Response

The State has not made such estimates.

54 -

150. In the " Note" at the. bottom of pages 4-9 of Volume 6, describe what is meant by the term " normalized" and explain how the " don't know" responses were distributed?

151. Please produce all the source materials relied upon to procuce j

. Tables 5-1 and 5-2 of Volume 6 and describe the methodology employed and all- assumptions used for projecting 1986 employment cata in Table 5-1.

152. Describe the basis for making the three assumptions about weekend employment made on the botton half of page S-6 of Volume 6.

Response to Interrogatories Nos. 150-152 See State's response to Intrrogatories Nos. 30-35, supra.

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- [- MOTI N F R PROTECTIVE ORDER

.Because the. State.of New Hampshire. filed no contentions'on tne NHRERPJandLintends.to. offer no testimonyion'any' contentions that were filed,:the State-is not obligated-to: respond toL.any interrogatories

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- on1 the NHRERP.: -See this Board's Memorandum and Order (Maren 1, -1963) at 3-4,=7-(Interrogatories which are sponsored by the interrogee and which will not be the-subject of direct testimony proffered by tneL

^

interrogee.need not.be answered.)' 1 Recognizing, however, that New Hampshire state personnel involved 'in developing the NHRERP can and

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L vill' provide valuable input in this proceeding on New Hampshire f

emergency planning issues, the State has voluntarily.-responded to.

• i this: set of interrogatories and request for product'of documents.

. The State of New Hampshire, however,-moves the Board.for a 1 protective order that the documents-that Attorney General Snannon

~

h. requests to be produced may be produced at the offices of the New i

Hampshire Civil Defense Agency in Concord, New Hampshire. The majority of the. requested documents are already in the possession of r Attorney. General Shannon (e.g., NHRERP; RAC Reviews), and the remainder of the documents constitutes a large number of pages. To l~ provide copies of the documents by mail to the Town woula be an undue.

burden and expense. Rather, the State of New Hampshire requests that the Board order that the requested documents be made available for inspection during working hours at the Civil Defense Agency headquarters, 107 Pleasant Street, Concord, New Hampshire, 03301.

i

e .w 56 -

In addition, the State of New Hampshire moves the Boara for a-

-protective order that, for the reasons given, the following interrogatories need not be answered further:

Interrogatories Nos. 7-18 In these interrogatories, Attorney General _Shannon inquires into a comparison of Seabrook Station and all other nuclear power plants in the country with regard to certain protective action factors.

Because these inquiries relate to plants which may have'no resemblance to Seabrook, they are overbroad. Further, inasmuch as the NRC's emergency planning requirements do not call for such a comparative analysis, these interrogatories do not seek relevant information with respect to any matter in contention in this proceeding.

Interrogatory No. 26 Insofar as this interrogatory assumes that NRC regulations set forth absolute evacuation time requirements, it inquires into matters.

not germane to any issue in contention in this proceeding.

Interrogatory No. 28 In this interrogatory, Attorney General Shannon inquires into the prevention of "all fatalities" under "all accident scenarios."

Because it raises questions about an infinite number of possible accident scenarios and an infinite number of possible causes of a 4

y y. , , , , - - -

' ~ii; ; e o A

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, [ fatalities,:itiis too broadly: stated to allow a proper response.

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, It also inquires into matters not required ~by NRC-regulatio,ns to the textent it' suggests guarantees of absolute safety are' required.

r Inte r rogatory -~ No . 56

.This requestLseeks copies of all correspondence submitted by.

FEMA an'd'the-State of New Hampshire since_ December of 1986.

To the extent such. correspondence may deal in part with matters unrelated to I

' any issue-in contention'in this proceeding, it should not have to be

_ produced.

Interrogatories Nos. 29 and 114-117 The references in these interrogatories to " serious accident" or

" worst-case scenario" are too broad and vague to allow a proper response. Furthermore, toLthe extent that Attorney General Shannon

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means that-the radiological emergency plan must be based on a worst-case scenario, he is inquiring'into matters not required by NRC

- regulations.

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a v SIGNATURES As to Answers to Interrogatories 6-27, 30-73, 136-152 Richard H. Strome As to Answers to Interrogatories 1-5, 28-29,74-135 Richard H..Strome Dr. William T. Wallace, Jr.

I, William T. Wallace, Jr., M.D., M.P.H., being first duly sworn, do depose and say that the foregoing answers are true, except insofar as they are based on information that is available to the State but not within my personal knowledge, as to which I, baseo on such information, believe them to be true.

William T. Wallace, Jr., M.D., M.P.H.

Director, DPHS Division of Public Health Services Sworn to before me this day of March, 1987:

Notary Public My Commission Expires:

e .

I, Richard H. Strome, being first duly sworn, do depose and say that the foregoing answers are true, except insofar as they are based on information that is available to the State but not within my personal knowledge, as to which I, based on such information, believe them to be true, o

Richard H. Stromd' Director, Civil Defense Agency Sworn to before me this Ar4 day 1987:

/ /

e L HvJdcy F uL i f'u My Commission Expires: 7///f/

As to Obiections and Motion for Protective Order:

b y _ J "'  %

Date Georgs' Dana Bisbde/ (

Senior Assistant Attorney General Environmental Protection Bureau Office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3 79 5/n n 6, bum Date Geoffrey M. ntingfon /'

Attorney /

Environmenta Protection Bureau Office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3679

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.. bl ATEDCORRESPONDEg ~

CERTIFICATE OF SERVICE DOCXETED

, I, George Dana Bisbee, hereby certify that on this 18th day oh "O March, 1987, I made service of the within State of New Hampshire's Supplemental Answers to Seacoast Anti-Pollution League's InteqMbgggpggeP2 :25 and Requests for Documents to the State of New Hampshire on Emergency Planning for the State of New Hampshire Propounded on April 17 1986; State of New Hampshire's Supplemental Answers to New England } onhofeY Nuclear Pollution's Interrogatories and Requests for Document O{f{h{kyE" Vi State of New Hampshire on Emergency Planning for the State of New Hampshire Propounded on April 30, 1986; State of New Hampshire's Responses to the Town of Hampton's First Set of Interrogatories and Request for the Production of Documents to the State of New Hampshire on the New Hampshire Radiological Emergency Response Plans al.d Motion for Protective Order; State of New Hampshire's Responses To Massachusetts's Interrogatories and Request For Documents To The State Of New Hampshire On Rev. 2; State of New Hampshire's Responses to NECNP's First Set of Interrogatories and Request For Production of Documents To The State of New Hampshire On Revision 2 To The New Hampshire Radiological Emergency Response Plan and Motion for Protective Order; State of New Hampshire's Responses To Seacoast Anti-Pollution League's Interrogatories and Requests For Documents To The State Of New Hampshire On NHRERP Rev. 2 And Motion For Protective Order, by mailing copies thereof, postage prepaid, to:

• Administrative Judge Helen Hoyt

• Administrative Judge Sheldon J.

Chairperson Wolfe, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555

• Administrative Judge Gustave *Dr. Jerry Harbour A. Linenberger, Jr. Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. N.R.C Commission Washington, DC 20555 Washington, DC 20555 Philip Ahrens, Esquire

• Thomas G. Dignan, Jr., Esquire Deputy Attorney General R. K. Gad, III, Esquire Peter J. Brann, Esquire Ropes & Gray Assistant Attorney General 225 Franklin Street Department of the Attorney General Boston, MA 02110 State House Station 6 Augusta, ME 04333

• Served by express mail l

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OCarol S. Sneider, Esquire *Sherwin E. Turk, Esquire Assistant Attorney General Deputy Assistant Chief Department of the Attorney General Hearing Counsel

'One Ashburton Place, 19th Floor Office of the Executive Counsel 4 Boston, MA. 02108 Director U.S. Nuclear Regulatory Commission Ms. Diana P. Randall Washington, DC 20555

~70 Collins Street Seabrook, NH 03874

• Robert A. Backus, Esquire Backus, Meyer & Solomon oDiane Curran, Esquire 116 Lowell Street Harmon & Weiss P. O. Box 516 20001 S Street, N.W. Manchester, NH 03105

-Suite 430 Washington, DC 20009-1125 Chairperson Board of Selectmen Jane Doughty Town of South Hampton 5 Market Street East Kingston, NH 03827 Portsmouth, NH 03801 Judith H. Mizner, Esquire Charles P. Graham, Esquire Silverglate, Gertner, Baker, McKay, Murphy and Graham Fine, Good, and Mizner 100 Main Street 88 Broad Street Amesbury, MA 01913 Boston, MA 20110

• Paul McEachern, Esquire Matthew T. Brock, Esquire *J. P. Nadeau, Esquire Shaines & McEachern Selectmen's Office 25 Maplewood Avenue 10 Central Road P. O. Box 360 Rye, NH 03870 Portsmouth, NH 03801 Mr. Calvin A. Canney Ms. Roberta C. Pevear City Manager The Town of Hampton Falls City Hall Drinkwater Road 125 Daniel Street Hampton Falls, NH 03844 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Angie Machiros The Town of Kensington Chairman of the RFD 1, Box 1154 (Route 107) Board of Selectmen Kensington, NH 03827 Town of Newbury Newbury, MA 01950 Senator Gordon J. Humphrey Peter J. Matthews U.S. Senate Mayor Washington, DC 20510 City Hall (Attn: Tom Burack) Newburyport, MA 01950

• Scrved by express mail

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' Senator.Gordon J. Humphrey William S. Lord 1 Eagle Square Board of Selectmen Suite 507 Town Hall Concord, NH 03301 Friend Street Amesbury, MA 01913

.Mr. Thomas Powers Brentwood Board of Selectmen Town Manager RFD Dalton Road Town of'Exeter Brentwood, NH 03833 10' Front Street-Exeter, NH: 03833 Gary W. Holmes, Esquire Holmes & Ells

• H. Joseph Flynn 47 Winnacunnet Road Assistant-General Counsel .Hampton, NH 03841-Office of General Counsel Federal Emergency Management Richard A. Hampe, Esquire Agency. Hampe & McNicholas 500 C Street, S.W. 35 Pleasant Street Washington, DC 20472 Concord, NH 03301 OMr. Ed Thomas Mr. Robert Carrigg, Chairman FEMA, Region I Board of Selectmen John W. McCormack Post Office Town Office and Court House Atlantic Avenue Post Office Square North Hampton, NH 03862 Boston, MA 02109 i s

k-1 George Bana Bisbee

• Served by express mail

,