ML20070T247

First Set of Interrogatories & Requests for Documents Re Contentions III.1,III.2,III.3,III.12 & III.13.Related Correspondence

ML20070T247
Person / Time
Site:	Seabrook
Issue date:	02/04/1983
From:	Bishop L, Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
ISSUANCES-OL, NUDOCS 8302080264
Download: ML20070T247 (18)

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'83 FR -7 N1 :03 UNITED STATES OF AFERICA NUCLEAR REGULATORY COPMISSION ATONIC SAFETY AND LICENSING BOARD BEFORE ADPINISTRATIVE Helen JUDGES:

F. Hoyt, Chairman Dr. Emmeth A. Luebke Dr. Jerry Harbour In the Patter of

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} Docket Nos.

PUBLICr SERVICE COPPANY OF l

NEW !!APPSHIRE, e t al. ) 50-443-OL

) 50-444-OL (Seabrcok Station, Units 1 and 2) )

) February 04, 1983

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NECNP FIRST SET OF INTERROGATORIES AND REQUESTS FOR DOCUEENTS TO APPLICANTS ON CONTENTIONS III. 1, III. 2, III. 3, III. 12, and III. 13 ~~ '

INSTRUCTIONS FOR USE The New England Coalition on Nuclear Pollution (NECNP) request tha t the Applicants, pursuant to 10 C.F.R .

SS2.740(b) and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce and permit inspection and copying of the original or best copy .

of all documents identified in the responses to interrogato i r es below, and that subsequent to filing answers to these interrogatories and producing documents therein identifi ed, the Applicants file supplemental responses and produc e additional 02080264 830204 bD DR ADDCK 05000443 PDR - - - - - - - - - -

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documents as requirsd by 10 C.F.R. 52.740(e).

Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, report) and state the following information as applicable for the particular document: name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person (s) having possession of the document.

The term " document (s]" as used herein shall mean any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

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I INTERROGATORIES

1. Please identify and produce all documents which contain or refer to any assumptions, methodology or input used in the " preliminary evacuation analyses" set forth in Appendix C to the Seabrook Station Radiological Emergency Plan (hereinafter, " Appendix C"], or the results of those analyses, including but not limited to any maps or aerial photographs of the model traffic network or traffic queue locations, any descriptions of the characteristics of the links in that traffic network, and any sensitivity analyses performed.

2. Please identify and produce all documents within the possession, custody, or control of the Applicants which contain or refer to other evacuation analyses for the Seabrook vicinity, whether conducted before or after that set forth in Appendix C, or to any assumptions, methodology, input, or results of such analyses.

3. Identify by name, title, profession, and affiliation all individuals who participated in the preparation of Appendix C, or in the conduct of the underlying analyses.

4. Have the Applicants undertaken or contracted for any further evacuation analyses for the Seabrook vicinity over and above that set forth in Appendix C? If so, identify the contractor (s) and/or employees (s) who have/are/will be participating in the conduct of said analyses and the actual or

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anticipated completion date(s) therefor.

5. Identify all experts whom the Applicants intend to call as witnesses relative to evacuation of the Seabrook vicinity and state their qualifications.

6. E.% plain in detail the basis for the use in Appendix C of a 30% reduction in the capacity of the road network to reflect adverse weather conditions. Identify all documents upon which the Applicants relied in choosing that percentage.

Did Applicants assume, in calculating evacuation times for the adverse weather case, that the adverse weather affected travel speed? If so, what effect was assumed? If not, explain in detail the reasons why Applicants believe that effect need not be accounted for.

7. Identify the streets which were included in the transportation network for the evacuation analysis set forth in Appendix C. Did the EVAC model, as used for purposes of that analysis, account in any way for travel time from place of origin to a so-called " collector street," including travel time on local roads, or for waiting time in driveways or on local roads? If so, explain in detail the manner in which that model did account for these factors. Identify for each of the beaches within the plume exposure pathway EPZ as crawn in Applicants' FSAR [ hereinafter, "the EPZ"] the nearest street thereto which has been included in the evacuation traffic network for the analysis in Appendix C.

8. NUREG-0654, FEMA-rep-1, Rev. 1 [ hereinafter, NUREG-0654], App. 4 provides (at p. 4-2) that, in preparing evacuation time estimates, "[t]he number of permanent residents shall be estimated using the U.S. Census data or other reliable data, adjusted as necessary, for growth." [ Emphasis supplied]

In the opinion of the Applicants, what is the appropriate target date for adjusting population figures for the'Seabrook vicinity for growth? Explain your answer in detail, identifying any documents upon which you rely.

9. Explain why, in Appendix C, the population distribution for the area between 5 and 10 miles of the Seabrook site was not determined by year-round electric meters.

10. Please produce the 1978-79 electric meter use data and the 1978 weekday-veekend occupancy survey referenced in '

Appendix C, at page 8.

11. Describe in detail the manner in which on-street parking was estimated and transient automobile figures derived therefrom in Appendix C. (See App. C, at 9)

12. Explain in detail your reasons for excluding from the calculation of off-season daily transient automobile demand in Appendix C persons in the area by reason of employment with other than " major manufacturers" and your reasons for excluding from summer weekend transient automobile demand non-resident employees. Please identify all documents upon which you have

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relied in making thes' exclusions, list by name and address the

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" major manufacturers" whose employees were included, and identify any documents within your possession, custody, or control which contain or refer to numbers of non-resident employees who are within the EPZ either during weekdays or on weekends. (See Appendix C, at 10)

13. What free-flow speed was assumed for purposes of the evacuation analysis set forth in Appendix C? Explain in detail the bases for that assumption, identifying any documents upon which you relied.

14. Please produce the document Traffic Flow Theory, Transportation Research Board Special Report 165, National Research Council, Washington, D.C., 1975, and the Highway Research Board's Highway Capacity Manual referenced at page A-2 of Appendix C.

15. Is it not true that the EVAC model provides unrealistically low evacuation time estimates by attributing to evacuees knowledge which they will not have with respect to traffic speeds or downstream links? (See App. C, at p.A-2) If l

your answer is in the negative, explain the reasons for your answer in detail, identifying any documents upon which you rely.

16. Produce all documents in the Applicants' possession, custody or control which discuss the EVAC model or any other computer model for estimating evacuation times.

17. Explain in detail the manner in which roadway capacities were determined for the evacuation analysis et I

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forth in Appendix C.

18. In the opinion of the Applicants, what actions could be taken to improve significantly evacuation times within the EPZ? How much would it cost to implement each such action?

(See NUREG-0654, at 4-10)

19. Identify those state and local emergency response officials who have reviewed Appendix C. produce any written comments prepared by such officials.

20 In the opinion of the Applicants what are the bounds of error associated with tb ,vacuation time estimates contained in Table 4 of Appendix C? Explain the bases for your answer in detail, identifying any documents upon which you rely.

21. In Applicants' opinion, if an accident occurs at Seabrook Station on a weekday during working hours what percentage of the permanent population within the EPZ will be working outside that area, leaving other family members at home without automobiles? Explain the bases for your answer in detail, disclosing any assumptions made and identirying any documents upon which you rely.

22. In Applicants' opinion, how many people within the EPZ are likely to be dependent on public transportation as their means for evacuation in the event of an accident at Seabrook Station? How many of those people are non-ambulatory? Explain the bases for your answers in detail, disclosing any assumptions made and identifying any documents upon which you rely.

23. In Applicants' opinion, what is the appropriate method for accounting for ambulatory and non-ambulatory public transportation-dependent populations in arriving at evacuation time estimates? How much time wi:1 be required to evacuate the public transportation-dependent population within each of the sectors for which evacaation time estimates have been provided in Appendix C for each of the evacuation scenarios analyzed there? Explain the bases for your answers in detail, disclosing any assumptions made and identifying any documents upon which you rely.

24. please produce all documents within the Applicants' possession, custody, or control relating to the behavior which might be expected of drivers during the course of an evacuation, including an evacuation due to an accident at a nuclear reactor and, in particular, when within sight of the plume.

25. In the opinion of the Applicants, how many persons outside the EpZ might spontaneously evacuate in the event of an accident at Seabrook Station? From what areas would those people evacuate and what would be the effect of such spontaneous evacuation on the evacuation time estimates set forth in Appendix C? Explain your answers in detail, disclosing any assumptions made and identifying any documents upon which you rely.

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26. What, if any, analyses or studies have been conducted by or for the Applicants of past traffic jams within the EPZ?

Describe in detail the methodology, findings, and conclusions of any such analysis or study and produce any documents within Applicants' possession, custody, or control related thereto.

27. In the opinion of the Applicants, what is the proper way to account for each of the following possibilities in prepari.g evacuation time estimates:

a. vehicles breaking down or running out of fuel during the evacuation;

b. abandoned vehicles;

c. vehicles having insufficient fuel at the commencement of the evacuation, to the knowledge of their owners;

d. disregard of traffic control devices;

e. evacuees using inbound traffic lanes for outbound travel; and

f. blocking of cross-streets at intersections.

What would be the effect on the evacuation time estimates contained in Appendix C of so accounting for each of these possibilities? How many vehicles will experience the problems listed in a., b., and c. above in each of the evacuation sectors in Appendix C for each of the evacuation scenarios analyzed therein? Explain the bases for your answers in detail disclosing any assumptions made and identifying any documents upon which you rely.

28. NUREG-0654 provides (at p. 4-6) that in calculating evacuation time estimates in the case of "...a northern site

with a high summer tourist population (the applicant] should consider rain, flooding, or fog as the adverse { weather]

condition as well as snow with winter population estimates."

In Applicants' opinion, what is the appropriate summer adverse weather condition which should be used in estimating evacuation times at Seabrook? What it the estimated evacuation time, assuming that condition, for each of the evacuation sectors analyzed in Appendix C? Explain your answers in detail, disclosing any assumptions made and identifying any documents upon which you rely.

29. How much time will be required to evacuate simultaneously on a summer weekend all persons on the coastal beaches within the EPZ? the persons on Hampton Beach and Seabrook Beach? the persons on Hampton Beach and Salisbury State Beach? all persons within the EPZ? (See NUREG-0654, App.

4, at 4-4] Explain the bases for your answers in detail, disclosing any assumptions made and identifying any documents upon which you rely.

30. How much time should be added to the evacuation time estimates set forth in Appendix C to account for notification time? Does your answer vary depending on whether notification is staggered? If so, provide figures for both simultaneous and staggered notification. Explain the bases for your answers in detail, disclosing any assumptions made and identifying any documents upon which you rely.

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31. How much time should be added to the evacuation time estimates set forth in Appendix C to account for preparation / mobilization and confirmation times? Explain the bases for your answers in detail, disclosing any assumptions made and identifying any documents upon which you rely.

32. How much time should be added to the evacuation time estimates set forth in Appendix C to account for work-to-home travel within the evacuation network? Explain the bases for your answer in detail, disclosing any assumptions made and identifying any documents upon which you rely.

33. Under the Applicants' Emergency Classification System, as set forth in Chapter 5 of the Seabrook Station Radiological Emergency Plan (" RAP"], will an " Alert" be declared only when there is an actual " substantial degradation of station safety margins..." (at 5-1) or also when there is the potential for such, in accordance with the guidance of NUREG-0654 (at 1-8)?

l Will the Applicants declare a " Site Area Emergency" or " General

! Emergency" if expected releases are any greater than "small fractions of the EUA Protective Action Guideline exposure levels"? If your answers deviate in either of these respects from the guidance set forth in NUREG-0654, explain the bases for those deviations in detail, identifying any documents upon which you rely.

34. Under the Applicants' Emergency Classification System as set forth in Chapter 5 of the RAP, will a " General

Emergency" be declared any time expected releases exceed EPA Protective Action Guideline Exposure levels offsite for more than the immediate site area, in accordance with the guidance of NUREG-0654 (at 1 1-16)? Will a General Emergency be declared whenever events are in process or have occurred which involve imminent, as well as actual, substantial degradation or melting with potential for loss of containment integrity, in accordance with the guidance of NUREG-0654 (at 1-16)? If your answers deviate in either respect from the guidance set forth in NUREG-0654, explain the bases for those deviations in detail, identifying any documents upon which you rely.

35. List any example initiating conditions set forth in NUREG-0654, Appendix 1 and any postulated accidents in the Seabrook Station FSAR which have not been included in the initiating conditions set forth in Tables A.1, A.2, A.3, and A.4 of the RAP. (See NUREG-0654, at 42). Explain in detail the bases for each such ommission, identifying any documents upon which you rely. In particular, explain in detail the bases for the following apparent deviations from the guidance of NUREG-0654:

a. The designation of only certain radiological

! effluents the exceeding of technical specifications for which will teruit in declaration of an Unusual Event. (Compare NUREG-0654, at 1-5, No. 2 and RAP, Table A.1, Nos. 1 and 2)

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b. The limitation.of the initiating condition in

' the RAP, Table A.1, No. 5 to the exceeding of the specified limit "due to steam generator tube

failure" (compare to NUREG-0654, at 1-5, No. 5) and the conditions in Table A.1, Nos. 5 and 6 to certain operational modes (compare to NUREG-0654, at 1-5, No. 5).

c. The omission from Table A.1 in the RAP of a loss of offsite power or of onsite AC power capability.which does not require a plant mode reduction in accordance with technical specifications (compare NUREG-0654, at 1-5, No. 7).

d. Modification of example initiating condition no. 10 in NUREG-0654, at 1-5, from " Fire within the plant lasting more than 10 minutes" to " Fire that threatens but does not defeat a plant safety

train or function." (See RAP, Table A.1, No. 8)

e. The omission from Table A.1 in the RAP of plant conditions which " involve other than normal controlled shutdown (e.g., cooldown rate exceeding technical specification limits, pipe cracking found during operation)". (See NUREG-0654, at 1-6, No. 15)

f. The omission from Table A.1 in the RAP of

"[rlapid depressurization of PWR secondary side."

(See NUREG-0654, at 1-6, No. 17.)

9 Characterization of the initiation of the ECCS and discharge to the reactor vessel as an initiating condition for an Alert, rather than an Unusual Event. (Compare NUREG-0654, at 1-5, No.

1 and RAP, Table A. 2, No. 1)

h. The omission from Table A.2 in the RAP of example initiating condition No. 6 as set forth in NUREG-0654, at 1-9.

i. The limitation of initiating conditions 7, 8 and 10 as set forth in Table A.2 of the RAP to

" operational modes 1 through 4." (Compare NUREG-0654, at 1-9, Nos. 7, 8 and 10)

j. The modification of the initiating condition No. 13 as set forth in NUREG-0654, at 1-9, from

"[f] ire potentially affecting safety systems" to

"[f] ire defeating any safety system train or function" (see RAP, Table A.2, No. 13).

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k. The omission from Table A.3 in the RAP of initiating condition no. 1 as set forth in NUREG-0654, at 1-13.

1. The modification of initiating condition no. 5 as set forth in NUREG-0654, at 1-13 from

" steam line break with greater than 50 gpm primary to secondary leakage..." to " steam line break with significant primary secondary steam generator tube break..." (See RAP, Table A.3, No. 3).

m. The omission from Table A.3 in the RAP of the initiating conditions contained in NUREG-0654, at 1-13, Nos. 13, 15, 16(a), 16(b), and 17.

n. The omission from Table A.4 in the RAP of the initiating conditions contained in NUREG-0654, at 1-17, No, l.a..

36. What events or conditions are covered by each of the phrases "[s]evere natural phenomenon incidents," " abnormal occurrences near site or onsite" and "significant loss of assessment or communications capability" contained in Table A.1 of the RAP, No. 137

37. What events or conditions are covered by Item No. 19 in Table A.2 of the RAP? Are all events specifically set forth e 1

in NUREG-0654, at 1-10, Nos. 17-19 covered?

38. Explain in detail the bases for your inclusion of condition No. 16 in Table A.2 of the RAP, identifying any documents upon which you rely.

39. Does the word "promptly" in Table A.3, No. 6.d. of the RAP mean within 15 minutes? If not, what does it mean?

40. In Applicants' opinion, is the initiating condition of

" failure of a safety or relief valve in a safety related sys.en

to close following reduction of applicable pressure" properly characterized as an Unusual Event, rather than a Site Area or General Emergency, even given that such was in part the cause of the accident at Three Mile Island Unit 27 State the bases for your answer in detail, identifying any documents upon which you rely.

41. In the Applicants' opinion, is it necessary that the Seabrook Station Radiological Emergency Plan demonstrate the Applicants' ability to respond to failures at both units, or a failure at one unit which affects the other's capacity to opertte safely? If your answer is in the negative, explain in detail the bases therefor, identifying any documents upon which you rely. If your answer is in the affirmative, is it the opinion of the Applicants that the RAP demonstrates such an ability? Explain the bases for your answer in detail, identifying any provisions of the RAF or other documents upon l which you rely.

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42. Will independent emergency response teams provide independent response capability for each Seabrook unit? If not, explain in detail your justification for not having such independent response capability, identifying any documents upon which you rely. If so, describe in detail the means for l

l coordination of response between the two teams and identify the l

l personnel who will comprise the second team.

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43. In Applicants' opinion, how should the Emergency Classification System reflect the possibility of simultaneous failure of both units, or a failure at one unit which affects the other's capacity to operate safely? Explain your answer in detail, identifying any documents upon which you rely.

44. Are the emergency facilities and equipment described in Chapter 6 of the RAP designed.to respond simultaneously to accident conditions at both plants? If not, what changes / additions would be necessary to provide that capability? Explain your answers in detai.1, identifying any-documents upon which you rely.

45. Will each unit of the reactor be equipped with all of the radiation protection equipment described in Section 10.4.4 of the RAP? If not, explain in detail your justification for not providing sufficient protection equipment for all personnel at both units, identifying any documents upon which you rely.

46. In Applicants' opinion, what alterations should be made to the boundaries of the plume exposure pathway and ingestion pathway emergency planning zones for Seabrook Station i

as set forth in the FSAR to account for the possible consequences of an accident at both units? Explain the bases j

for your answer in detail, disclosing any assumptions made and

! identifying any documents upon which you rely.

47. Please provide, for each individual whom the Applicants intend to use as an expert witness on the subjects

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of evacuation or evacuation times, a list of all proceedings of any kind before any tribunal in which said individual has testified and the subject matter of his/her testimony on such occasion. Please produce any documents within the Applicants' possession, custodyr or control containing any such testimony.

48. Please identify, for each individual whom the Applicants intend to call as an expert witness on the subects of evacuation or evacuation times, all reports, studies, papers, articles, and books, whether published or not, and whether a draft or final, relating in any way to said subjects and prepared, in whole or in part, by said individual or by a corporation, partnership, agency, or other organization of which said individual is (or was at the time of preparation) an employee, officer, director, partner, or agent.

49. Identify any officer, director, employee or representative of any of the Applicants who dissents from any finding, conclusion, or statement contained in Appendix C or to any portion of the answer to any of the foregoing interrogatories. Describe in detail the nature of any such dissent.

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Respectfully submitted ,

Diane Curran

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Lee L. Bishop HARION & WEISS 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006 (202) 833-9070 DATED: February 4, 1983 I

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