ML20205D695

Commonwealth of Ma Atty General Second Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Related Correspondence

ML20205D695
Person / Time
Site:	Seabrook
Issue date:	10/19/1988
From:	Fierce A MASSACHUSETTS, COMMONWEALTH OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20205D699	List: ML20205D695 ML20205D777 ML20205D810
References
CON-#488-7329 OL, NUDOCS 8810270184
Download: ML20205D695 (29)

Text

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- (@ 000KEiC0 09HC UNITED STATES OF AMERICA  !

i NUCLEAR REGULATORY COMMISSION

'88 (CT 21 P3 :43 li ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judges:

Ivan W. Smith, Chairman h[QFru W:[  !

e Gustave A. Linenberger, Jr.

Dr. Jerry Harbour i i

)  !

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

' 50-444-OL

)

PUBLIC SERVICE COMPANY ) (Off-Site EP)  ;

OF NEW HAMPSHIRE, EI AL. )

) October 19, 1988 Seabrook Station, Units 1 and 2) )

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$ L MASSACHUSETTS ATTORNEY GENERAL *S SECOND SET  !

OF INTERROGATORIES TO APPLICANTS ON T'IE l j SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES (

1 Pursuant to 10 C.F.R. $ 2.740b, James M. Shannon, the j i

Attorney General for the Commonwealth of Massachusetts ("Mass.  !

A.G.") hereby requests that the Applicants respond to the following interrogatories within fourteen (14) days. l

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) DEFINITIONS AN W SIRUCTIONS f f

A. As used herein, the term "NHY" shall mean the Public f

j Service Company of New Hampshire's New Hampchire Yankee Division, any of its res.resentatives, officers, employees, agents, servants, affiliates, or subsidiaries. The term "0RO" shall mean NHY's Offsite Response Organization for i Massachusetts. The "SPMC" means the Seabrook Plan for 1

i 8810270104 001019 PDR ADOCK 05000443 PDR 0 G

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Massachusetts Communities, and all appendices, amendments, and l attachments thereto. The "Massachusetts EpZ" means the j Massachusetts portion of the Emergency planning Zone for (

Seabrook Station.

B. Ts used herein, the term "person" shall mean any natural person, corporation, partnership, firm, trust, group, association or other organization and, where appropriate, the use of the singular includes the plural and the use of the plural includes the singu?,ar.

C. As used herein, the term "document" shall mean the original, and any and all copies which differ in any way from the original, of any notes, correspondence, memoranda __

(including written memoranda of telephone conversations, other __

communications, discussions, agreements and any other acts, transactions or activities), time sheets, contracts, agreements, pamphlets, receipts, order forms, records, bonds, requisitions, bills, plans, blueprints, layouts, drawings, specifications, sound recordings, minutes, diaries, by-laws, notebooks, logs, bulletins, circulars, brochures, forms, statements, journals, letters, telegrams, notices, interoffice and intraoffice communications, photostats, microfilms, computer re. -is, studies, reports, analyses, messages, comparisons, ,

.phs, charts, summaries, films, photographs, tapes, transcripts, advertisements and any other written matter of any kind including, but without limitation, any marginal comments appearing on any documents or any other writing.

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. A 4 D. As used herein, the term "communication" shall mean any oral, writt'en or electronic transmittal of information, or request for information, made from one person to another person, whether made in person, by telephone or by any other ,

means and includes any documents made only for the purpose of recording a communication, idea, statement, opinion or belief. ,

E. Wherever appropriate, the masculine form of a word shall be interpreted as feminine, and vice versa, so as to i

bring within the scope of these interrogatories any information j

that might otherwiso be construed to be outside their scope.

The words "and" and "or" and the phrase "and/or" should not be

, read as to restrict the scope of the insterrogatory. __ i F. For any docuraent or part of a document that was at one _

time, but is no longer, in Applicants' possession, custody or control, or which is no longer in existence, or which cannot be  !

! r 1, __

located, identify the do:ument, state where and how it passed out of existence or why it can no longer be located and reasons 1 therefor, and identify each person having knowledge concerning l j such disposition or loss and the contents of the document, and i

identify each document evidencing its prior existence and/or  :

any fact concerning its nonexistence or loss.

l G. "Concerns," "concerning" or any other derivative  !

thereof, includes referring to, responding to, relating to, i i

l pertaining to, in connection with, comprising, memorializing, i

5 commenting on, regarding, discussing, showing, describing, l 3

reflecting, analyzing, supporting, contradicting, and  !

constituting.

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I H. "School" includes all forms of schools, public or private, day care centers and day care homes, and nursery schools.

111IERRQGATORIES_TQ_AEELICAHIS

1. Please describe in detail the purpose of the "generic" plans listed in Appendix F of the SpMC and how you and/or the ORO intend to use them. For each such "generic" plan, please list the name and address of each and every individual, company, or organination to which these "generic" plans have been provided, the dates the plans were provided, and the substance of any response received. --

2. Do you contend that any schools have site-specific --

radiological emergency response plans (RERps)? If so, identify  ;

each school and state for each whether you have a copy of said plan.

3. For any of the schools which have no institution-specific RERps, do you contend that local governments or school officials have engaged in some planning for protecting the health and safety of their students from a radiological l emergency? If so, state which local governments and/or schoolt have done no and, for each, describe the type and extent of planning undertaken and identify any and all documents which Gescribe this planning.

4. Identify each school which has agreed to cooperate with the ORO during a radiological emergency and will allow its i students to board ORO's buses and be transported by them.

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5. The SPMC at Plan s 3.4-4 and I.P. 2.5, S 5.2, p. 7 state that ORO will consider recommending the precautionary action of "early evacuation of schools." No mention is made of other possible precautionary actions, i.e., (1) early dismissal of schools and (2) early evacuation of some schools combined with early dismissal of others. Have these two precautionary actions been excluded from consideration in the SPMC? If so, state the reason (s) for this exclusion. If not, identify those i sections of the SPMC which indicate how (what criteria ate ,

applied), when, and by whom such precautionary actions will be considered and implemented.

6. Identify the person (s) in NHY's ORO who is most __

knowledgeable about the SPMC's plans and procedures for schoolsL_

and day care centers in the Massachusetts EPZ.

7. The SPMC at Plan S 3.4-4 and I.P. 2.5, 5 5.2, p. 7 generally describes the factors to be considered when ORO is considering whether to recommend early evacuation of the schools. With respect to these factors:

(a) What combination of plant conditions (stable vs.

unstable), wind direction or projected wind shifts, and degree of readiness of available resources to support early evacuation of schools would prompt ORO to recommend eatly I

i evacuation of schools, and explain your reasons.  !

t (b) What combination of these factors will prompt ORO to recommend against an early evacuation of the schools, and explain your reasons. <

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8. Do you contend that if a school in the Massachusetts EPZ has no institution-specific RERP and has engaged in no prior planning for a radiological emergency the implementation of the SPMC by flHY's ORO fully compensates for the lack of prior planning at the school and provides reasonable assurance that adequate protective measures can and will be taken for the children in school there? If noT, what prior planning is necessary by the schools to enaire that adequate protective j

measures can and will be taken?

9. For schools in the Massachusetts EPZ which have engaged in no prior planning for a radiological emergency, does the SPMC depend or rely upon the administrators and teachers at__

these schools to behave and respond in certain ways to __

l implement the SPMC for the children in their schools in the event of a radiological emergency at Seabrook Station? If so, describe specifically the administrator and teacher behavior (s) and/or response (s) the SPMC depends or relies upon for each of the precautionary and protective actions which may be i

recommended for schools under the SPMC. 1

10. For schools in the Massachusetts EPZ which have engaged in no prior planning for a radiological emergency, does the SPMC depend or rely upon the regular school bus drivers for i l

these schools to behave and respond in certain ways to  ;

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implement the SPMC in the event of a radiological emergency at Seabrook Station? If so, describe specifically the bus driver behavior and/or responses the SPMC depends or relies upon for

each of the precautionary and protective actions which may be reccmmended for schools under the SpMC.

11. Have estimates been made of how long it will take ORO's buses to get to schools in the Massachusetts EpZ after a decision is made to evacuate the schools? If so, state what these estimates are and how they were derived. Identify any and all documents which pertain to these estimates.

12. Do you admit that each School Liaison will share a commercial telephone at the Staging Area with either a Special population Liaison or a Local EOC Liaison? If the answer is no, please reconcile your answer with the arrangement for telephones depicted on the Staging Area Operational Layout, --

I.p. 3.2, Attachment 5. --

13. Please list the name and address of each of the ,

companies currently being relied upon by ORO to supply buses and/or vans in the event of a radiological emergency at Seabrook Station, and for each company identify the number of buses and vans which:

(a) will always be immediately available (with drivers) upon notification by ORO, even if buses have other scheduled assignments; (b) will be available (with drivers) only after [

completing a tranport job which the compar/ has a prior I commitment to drive.

(c) will be available (with drivers) under certain t l

other conditions (please identify).

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14. For each bus or van company listed in the prior interrogatory, list the names, addresses, and phone numbers of each driver who has agreed to drive a bus or van into the EPZ in the event of a radiological emergency at Seabrook. For each such driver, list the ORO training courses each has taken whether the driver passed the courses, and the dates these courJes were taken.

15. Please identify the person in NHY's ORO who is most familiar with the current arrangments, conttactual and otherwise, with the bus and van companies being relied upon by the SPMC.

16. Describe the method by which the bus transportation __

needs in Appendix M were determined for each of the schools in --

the Massachusetts EPZ?

1 1 17. Please list the names, bddresses, and business phone

__ numbers for (a) Each of ORO's current School Coordinators; (b) Each of ORO's current School Liaisons.

18. Explain the "code" numbers assigned to each of the J

schools and day care centers in Appendix M and what these code numbers are used for.

19. Please explain the system of priorities, if any, which School Liaisons will use in making their calls to schools and day care centers (i.e., in what order the callt will be made),

i 20. Wnat efforts, if any, will ORO make during a radiological emergency to notify schools which the School

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i Liaisons are unable to reach because the talephone(s) at the  !

schools are continuously busy? j

21. please identify any studies or other documents which f assess, analyze, estimate, critique, or otherwise concern the suitability of using the schools in the Massachusetts EpZ as

• protective shelters during a radiological emergency at Seabrook j i Station. I

22. As described in the original MAG 47(M), it is not  !

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clear whether School Liaisons will "verify" a school's [

l transportation requirements by obtaining (a) the total number {

j of buses which would be needed to transport all the students in f' i

the school or (b) the number of buses'which, in addition to __

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those available to the school, are needed to ensure that all __ j i students can be transported. please describe what number the Liaisons are seeking and state whether Liaisons are to f

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encourage schools to use their own buses or not? (i

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23. After a School Liaison reads the School Protective i

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f Action Message set forth as Attachment 1 to I.p. 2.7 and  !

) informs a school that ORO "will have the vehicles you identify l dispatched to your school to support your immediate f evacuation," if the school administrator asks, "How soon can j you get those buses here?" what will the School Liaison say in response? J

24. Do you contend that the Commonwealth of Massachusetts i i

and/or the six Massachusetts EpZ communities, acting in a l 1

Mode 1 response without ORO involvement, can implement the i

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. t SpMC's plans and procedures for school children in a timely i fashion? If your answer is yes, please describe how this can be done and, in doing so, address each of these potentiol I obstacles to a timely implementation:

(1) the fact that all SpMC procedures for school  !

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coordinators and school liaisons are written for ORO l t

l personnel who in carrying out their tasks after calling the [

' i schools interface only with other ORO personnel (e.g.,  ;

1 ORO's Bus Company Liason);

l (2) the fact that no state or local officials have the f h N names or phone numbers of any of the bus companies being  !

! relied upon under the SpMC; __ [

i (3) the likelihood that state and local officials will;_ l i

j not have copies of the SpMC's plans and procedures for I

schools when the emergtncy begins; i __

(4) the fact that the Letters of Agreement with the f

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bus companies run between the companies and the Seabrook  !

]I Joint Owners and not between the companies and the state or i

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I the local governments. I I

'5. The SpMC is silent on the issue of who will supervise i 1

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the boarding of school children onto the ORO buses. Will ORO i; t

personnel do this? If not, describe in detail who will. [

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) 26. Please identify the current host school facility or i

i facilities. For each facility provide the name, address, ,

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capabilities, contact person and phone number, j i

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27. Were a first shift School Liaison ever to fail to show up for duty, would the ORO seek to bring in a back-up Liaison, divide the work of all School Liaisons up among the Liaisons who did report for duty, or take some other compensatory action (please describe).

28. In the event of a real radiological emergency, in what period of time does NHY's ORO expect to be able to complete the process of relaying a message from the School Coord'rator to the School Liaisons and then to all of the schools (including day care / nursery schools) listed in Appendix M. Please describe how this time expectation was calculated or estimated.

29. Identify the person (s) in NHY's ORO who is most __

knowledgeable about the SpMC's plans and procedures for __

protecting those in the hospitals, nursing homes, and other special facilities (not including schools).

30. List the current host hospitals expected to accept hospital and/or nursing home patients from the Massachusetts portion of the EpZ. For each hospital listed, provide the number of patients in each medical classification which the hospital is prepered to accept and state the time duration over which the hospital is prepared to keep the patients.

31. List the current hospitals which are prepared to and have agreed to recept contaminated, contaminated-injured, and/or excessivel) exposed general porulation evacuees.

32. For each hospital listed in esponse to the last interrogatory, list how many of each of the following types of 11 -

l ritients can be treated per hour:

(a) contaminated patients; (b) contaminated-injured patients; (c) excessively exposed patients.

I 33. For each of the host hospitals, describe in detail the 1

l facilities and equipment available for monitoring and l decontaminating evacuees in each of the hose hospitals and the [

l arrangements inade for receiving, evaluating, and treating ,

I contaminated injured individuals.

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34. Identify which of the hospitals is the primary (MS-1) i f

hospital for the eva$uation and emergency treatment of j "contaminated injured" members of the general public. --

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35. List the names and addresses of the current companies -- .

l i relied upon by the SpMC to provide ambulances or other vehicles for medical transport during a radiological emergency. For each company also provide the total number of drivers and the total number of other ambulance personnel who have agreed to travel into the Seabrook EpZ during an emergency response.

Indicate for each company whether the drivers and accompanying i l

personnel have signed letters of agreetaent indicating a willingness to provide such services. If no such agreements  !

exist, what assurances do you have that the driver and other personnel will respond in a radiological emergency.

36, please identify the current host special facility or facilities. For each facility provide the name, address, capabilities, contact person and phone number. ,

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37. Do you contend that Amesbury Hospital, Anna Jaques Hospital, or any of the nursing homes ot other special facilities in the Massachusetts EpZ have institution-specific ,

radilogical emergency response plans? If yes, identify the hospital (s), nursing home(s) or other special facilities having such plans and state whether you have a copy of each such plan.

38. pursuant to the SpMC, who will care for those in the Massachusetts EPZ hospitals and other special facilities who can not be evacuated?

39. Identify the person (s) in NHY's ORO who is most knowledgeable about the SpMC's plans and procedures for those persons in the Massachusetts EpZ who may have special __

notification, evacuation or other needs. __

40. Explain the meaning of the priority codes assigned to each special needs individual listed in Appendix M, and explain how thesu codes will be used.

41. When was the last special needs survey conducted and when do you expect that the next one will be cc ducted? How  ;

frequently will such surveys be conducted? i

42. Regarding the last special needs survey, identify the persons or organization (s) that conducted the survey, and state how many survey were mailed out and how many completqd surveys ,

were returned?

43. Do you have any information concerning whether upon receipt of the Special Needs Survey there were special needs individuals who refused to complete the survey, completed it I

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with factually incorrect information and returned it, and/or turned in their surveys to advocacy groups. If so, please describe this information and identify any and all documents which concern such events and/or indicate that such things may have happened.

44. Section 3.7.2(F) of the SpMC (p. 3.7-3) indicates that a Special Needs poster was distributed in the fall of 1987 to various advocacy groups in the six Massachusetts EPZ municipalities as well as agencies surrounding the Ep2. Please identify these advocacy groups and agencies by name and address.

45. Appendix II, p. M-17 (Amendment 6), indicates the number of mobility-impaired people wi'th special transportation __

needs: (a) for each town; and (b) the total number of such __

people in all six towns. The sum of the numbers set forth for each town, however, is substantially less than the number given

_, as the total. please account for this descrepancy and state the correct numbers for each town and the total.

46. Appendix M, p. M-17 (Amendment 6), Note C indicates that the sources for the data on the mobility-impaired population were a special needs surisy by International Survey Research Company, "by personal knowledge and references," and through a special needs hotline. Regarding these sources:

(a) Where is International Survey Research Company located, and who was the person there who was principally responsible for condacting the survey; 1

(b) State how many mobility-impaired persons were identified through each of these three sources; (c) Describe what efforts were taken, if any, to verify the information about those with mobility impairments obtained from these three sources.

47. Identify all the sources used to obtain the names, addresses, and other information about persons in the Massachusetts EpZ with sensory impairmer.ts and persons with mental / emotional impairments and state how many persons were identified through each of these sources. For each such sources, also describe what efforts were taken, if any, to I

verify the information acquired about those with sensory-impairments obtained from that source.

l 48. Do you have any intention to change the methods used l

to identify persons in the Massachusetts EpZ with special needs? If so, please describe these changes.

49. How many unredacted copies of the special needs population listings contained in Appendix M exist, who has them, and what steps have been taken to assure the security of this information?

50. Are the original Special Needs Surveys that were returned still being maintained? If so, who has them, where are they located, and what steps have been taken to assure the security of this information?

51. From the time the Sepcial Needs Surveys were returned, for each step in the process of collecting the completed

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surveys, analyzing them, compiling the data, and producing the special population listings contained in Appendix M, state:

(a) How many people had access to the acquired information; (b) Whether copies were made of the surveys or the information acquired; and (c) What steps were taken to assure the security of the acquired information. I c

52. What data gathering efforts, if any, have you or your .

agents undertaken to identify individuals willing and capable of assisting handicapped persons in the Massachusetts EpZ in  !

the ov+1nt of a radiological emergency at Seabrook Station? __

53. Describe any and all steps, if any, your or your __

agents have taken to have persons with handicaps, their families, and/or agencies serving or advocating for the handicapped review the SpMC's plans and procedures for

__ protecting persons with handicaps. Describe the result of this l

review process and identify any and all communications and i

other documents you and your agents have which concern this i

review process. i l

! 54. Has the NHY ORO found an alternate location for the staging area apart from the one at 145 Water Street in Haverhill, MA? If so, identify the location selected.

55. Do you contend that in the event of a radiological  !

1 emergency at Seabrook Station, 145 Water Street in Haverhill, Mass., will be made available to NHY's ORO for u7e as a staging l r

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area. If so, please describe who will have the legal authority to authorize use of this property as a staging area and cite the legal basis to support the conclusion that this person can j

lawfully authorize this use in that circumstance.

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56. Identify ther person in NHY's ORO who is most knowledgeable about the SpMC's plans and procedures for monitoring and decontaminating evacuees at the Reception t J Centers. t 57 Where are the ORO's two(2) dedicated monitoring  ;

trailers for general public evacuees to be stored when they are  !

not in use during a radiological emergency? i 4

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58. What routes are the monitoring trailers to traverse to__  !

get to their respective reception center locations (provide __ !

maps or describe in detail)?

59. Have problem location along the routes traversed by j the monitoring trailers been identified (e.g. difficult to negotiate corners)? If so, identify the locations, describe the problems, and describe what plan have been made to provide ,

traffic control or other assistaace at thosv locations?

60. What vehicles are to move the monitoring trailers, and t

where are these vehicles stored? If they are to be supplied by ,

I a contracted provider, name this company (or companies) and  ;

state its address, contact person, and phone number.

61. Have the drivers who will be depended upo.1 to move the {

l trailers during a radiological emergency had training in

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, driving the anticipated routes with the trailers in tow? If k

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so, please describe. Have they driven practice runs over the l f

t entire routes with the monitering trailers in tow? If so, on what day of the week and time of day were these practice runs l

conducted, and how long did each run take? Have alternate l f

drivers teen trained?

62. What are the outer dimensions of the monitoring trailers? How much square footage of floor space does each  !

l provide inside? >

63. Describe in detail how NHY's ORO proposes to monitor r 8,300 evacuees within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> at each of these trailers. What )

is the assumed monitoring time per individual? How does this [

compare to the actual time experienced during drills and __

f exercises? __

64. How many people does NHY ORO assume could be decontaminated within a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period at each trailer? What  !

t is the assumed average time per decontamination Shower? Is any l accounting made in this assumption of some people needing to be i t

showered a second or third time?

65. How many monitoring and decontamination personnel are to work inside each trailer? How many square feet is each of those individuals assumed to occupy? Describe (or provide a diagram) of the routing scheme for evacuees through the trailer that keeps the contaminated individuals aduquately separated ,

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l from those who are found to be uncontaminated. [

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66. Where are nursing home residents, hospital patients,  ;

I day care center children, jail inmates, those witn j t

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mental / emotional impairments, and persons in other special facilities to be monitored and decontaminated? Describe in detail which personnel are to be responsible for handling each of these types of special facility evacuees and the facilities I that will be employed in the task of monitoring and, if necessary, decontaminating them?

67. What is the total number of emergency workers that could potentially require monitoring and decontamination at the Emergency Worker Facility (EWF) (a) if NHY's ORO is authorized )

to implement the Plan and no State or local emergency l responders are involved, (b) if the State and local responders are involved, but ORO personnel are nht, and (c) if both ORO _

personnel and State and local responders are involved in the _ j emergency reponse (e.g., as when state troopers arrive in the  !

middle of the emergency and replace OKO traffic guides).

68. Where is the EWF trailer to be stored when it is not  ;

in use during a radiological emergency? j

69. Along what route is the EWF trailer to be transported to the staging area (provide a map or describe in detail)! Have  !

I problem locations along this route been identified (e.g.

l difficult to negotiate corners) and have plans been made to provide traffic control or other assistance at those locations?

70. What vehicle is to be used to transport the EWF l

trailer? Where is it stored when not in use during a ,

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radiological emergency? If it is to be supplied by a contracted provider, name the company and state its address, j

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I contact person, and phone number.

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t 71. Has the driver who will be depended upon to move the i

l EWF trailer during a radiological emergency had traling in l driving the tow vehi:le with the trailer? Has a practice run I or runs been driven over the entire route with the trailer in j tow? Have any alternate drivers been trained?

72. Has an alternate location for the EWF been loctted in ,

the event that the staging area in the City of Haverhill is not l f

available? l

73. How many emergency workers (EWs) does NHY's ORO assume l

l can be monitored at this EWF during a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period? What is I the assumed monitoring time per EW7 How does this compare to the actual monitoring times experienced during drills and _

L exercises? ,,_ l t

j 74. What provisions have been made for monitoring and decontaminating the special needs individuals who are to be given special evacuation assistance from their homes? Describe the facilities and personnel for these functions in detail.  ;

l t l 75. Describe in detail the type and number of survey l

meters available at the monitoring trailers and the EWF j l

trailers. Describe the detection capabilities and ranges of each of these tspes of instruments.  !

16. At each of these facilities, how are intractable contamination problems (e.g., internal contamination) to be dealt with? Who at each facility is to decide upon the appropriate course of treatment,7 What radiological health j experts at to be consulted in arriving at appropriate treatment f I

choices under Mode 1. Mode 2 and "mixed mode' scenarios?

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77. Describe in detail the provisions for appropriately l

l packaging and storing contaiminated articles at the monitoring l

trailers. How is one individual to guard the articles i

( belonging, potentially, to thousands of evacuees? How are l these articles to be disposed of ultimately? What contracts f are currently in effect with waste disposal companies (identify  ;

I the companies.)

t l 78. What plans does the ORO have for either pumping out or l replacing the storage tanks for waste water at each of the i monitoring trailers and the EWF7 Where is the water in the l tanks ultimately to be disposed? What person or entity will  !

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bear the ultimate responsibility for disposal of this waste .,_.

l l vater? _

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! 79. Have the estimated times for traversing each of the -

l bus routes in the six (6) Massachusetts communities been L

i i calculated? If so, please list these estimates (or provide documents which contain them.)

l 80. Has any effort been made to calculate the additional  !

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radiation dosages that would likely be received by those

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l transit-dependent individuals who would have to stand outside }

l along bus routes awaiting transport over the dose absorbed by l the rest of the population? If so, how has this information f been factored into protective action decisien-making?

81. During inclement weather conditions such as severe l winter storms, is there an alternate plan for assisting the f l

transit-dependent population? l i

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82. How are transit-dependent evacuees to be located along the roadways if the evacuation takes place during the night?

l 83. What consideration, if any, has been given to the l hardship older citizens would have to endute in waiting outdoors in inclement weather and the potential adverse impact on their health in so doing?

84, provide a matched listing of each special facility in l

the Massachusetts portion of the EpZ (and its population) with I

its host facility showing the capacity of the host facility to I

accept each category of evacuees.

85. Detail which specific personnel are to be relied upon for loading nursing home residents and hospital patients onto -

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emergency vehicles. _

l 86. What specific plans exist for the integration and i

l deployment of federel monitoring and assessment personnel?

87. please identify by name and position those ORO

_, personnel whose responsibility it is to request federal monitoring and assessment assistance.

(a) Identify what procedures, if any, these personnel would consult or refer to in making such request (s).

(b) please describe the relation:thip that presently l

l exists betwean ORO and the Department of Energy ("DOE") and l

\ l between ORO and the NRC with regard to such federal 1

assistance, i (c) Please identify and describe the substance of any

! communications running between ORO, the DOE and the NRC from September 1, 1987 to the present concerning such l

federal assistance.

88. Please identify the specific locations, if any, within the Massachusetts EpZ which have been identified as possible or probable monitoring locations.

89. With reference to the following document Guidance.on O f I m il e_Imr tg ency_Ra di a t i o n Me a nu temenLSyslama Ph a ne_. L-AiIborne_ Release, FEMA REP-2, Rev. 1 July 1987 please provide the following information:

(a) What provisioris exist for the deployment of trainad emergency monitoring personnel at relocation centers in host areas for monitoring all arriving evacuees __

known to have been exposed to high levels of radiation as __

described at S 6.427 (b) Does ORO have adequate monitoring resources to maintain doployed survey terms in the plume Ep2 for a minimum of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> as set forth in S 6.57 If the SpMC is relying on either federal or state assistancJ to be available before that time please indicate:

(1) whether the assistance relied upon is federal and/or state; (2) from what physical locations the governmental assistance is expected to originate from; (3) the response time from notification to arrival for such governmental assistance; and (4) the bases for the answers to (1) -

(3) above.

i l

l .

(c) Does the manpower for the ORO survey teams come from within a radius of approximately 20 miles from the reactor site as recommended in S 6.57 Are onsite reactor facility staff relied upon for such manpower? If not, why not?

l-(d) Please identify and describe survey team deployment plans as described in S 6.6 created for the Massachusetts EPZ. Please indicate the constraints identified in S 6.6 which were recognized in creating these plans.

(e) Please describe what procedures exist to insure that field monitoring will be con'centrated at the edges of -

l evacuated areas to ensure that the evacuated area is large -

enough as described in S 6.6. What etfort has been made to l

I identify possible monitoring locations at the edges of those areas in the Massachusetts EPZ which the ORO would or I

could recommend be evacuated in accordance with the SPM0?

l (f) Has any pianning been done to accomplish 1

simultaneous monitoring at preselected monitoring points as described in S 6.6.7 (g) Please identify and describe any logistics plans as described in S 6.8 created for the Massachusetts EPZ.

(h) Does the ORO have sufficient monitoring equipment defined as the amount required to provide the needed i measurements for any set of release and meteorology variations? What amount of monitoring is sufficient in l light of the geography and meteorology of the Seabrook site?

90. Please identify for each of the following types of equipment: (1) the number available, (2) the present location, i (3) the maintenance performed during the last 12 monthe and (4) the current calibration if applicable:

(a) portable radiation monitoring instruments; (b) air samplers; (c) dose rate meters; (d) beta / gamma rurvey meters; and (e) dual channel analyzers.

l i 91. Describe the circumstances that would or could l

occasion the shift to real-time radiological monitoring for purposes of genetating protective action recommendations. ._

l Please identify by name and position the ORO official who wouldi_

l l make this decision. What procedures, if ony, would this l

official censult or refer to in making this decision.

92. How many field nonitoring teams are available under

_. the control of:

i (a) the state of New Hampshire; I

(b) the ORO; and (c) the licensee pursuant to the Seabrook Station l

Radiological Response Plan'.'

93. How will the activities of the various field l monitoring teams identified in the immediately preceding interrogatory be coordinated? Who is responsible for such coordination?

94. What factors led to the determination to provide 2 field monitoring teams in the SPMC7 l - 2s -

l

95. Are the field monitoring teams described in the SPMC mobile? If the answer is yes, please identify what vehicles f

I are available for use by these teams and where these vehicles

[

are stored.

l.

) 96. Have any estimates been made as to the time needed l

l from the decision to deploy the field monitoring teams to the l

[ communication of actual field-data to the appropriate personnel? If yea, what are those estimates?

97. Please describe and provide the dates of all drills conducted with ORO field monitoring ceams.

(a) Please indicate which of these drills, if any, l

j involved hands-on practice with monitoring equipment. --

{ (b) Please indicate which of these drills, if any, --

! involvad physical deployment of these teams. Where were l

l the teams sent?

98. Please identify the locations of work and residence for those ORO personnel identified as field monitoring teams.

Have any estimates been made concern!ng the time needed for these personnel to be mobilized in the event of an emergency?

l l What are those estimates?

99. Please describe the primary means of communication linking the ORO field-monitoring teams with:

1 1 (a) each other; i

I (b) monitoring teams from the State of New Hampshire:

(c) federal monitoring teams; (d) monitoring teams provided by the Commonwealth; and (e) the ORO EOC.

i l 100. What plcnning has been dene to ensure that federal or l

state monitoring assistance teams are able to communicibe data l

to the ORO EOC?

101. Has any time study for implementing a sheltering PAR (

l been done:

l l (a) for any sector or sectors of the Massachusetts EpZ; or 1

(b) for any portion or portions of the Massachusetts

! EpZ population?

l h 102. Has any study been conducted te determine the shelter protection factor of dwellings outside the beach areas of the l

Massachusetts EpZ? --

l 103. On what basis was a 0.9 dose reduction factor assumed --

in determining the relative benefits to be assigned to a sheltering protective action recommendation?

l 104. In calculating projseted dose to the population as a result of evacuation in comparison with sheltering or any other alternative protective action what portion of the pr0jecte3 dose was the result of groundshine, including radioactive material on the skin of those evacuating as well as in the automobiles in which they are evacuating?

105, please identify and describe all studies or analyses l

the purpose of which was to compare the projected dose to the population in the event of an accident at Seabrook Station assaming different protective action recommendations Nere made and followed.

106. Please identify and describe any studies or analyses conducted since September 1987 the purpose of which was to estimate the air exchange rate for dwetlings in the Massachusetts EpZ. What air exchange rate has been assumed for the dwellings in the Massachusetts EpZ?

107. Please identify and describs any efforts made for the Massachusetts Ep2 to identify those specific areas in which the sheltering protection afforded by the existing housing stock is higher than .9.

108. please describe the consideration, if any, given to a l protective action that combines sheltering with rapid identification after plume passage of "hot spots" and --

relocation as described in NUREG-1210. --

(a) If this strategy has not been adopted for the Massachusetts EpZ please explain the basis for this decision.

(b) please identify and describe any studies or analyses referred to or consulted in answering (a) above.

(c) If this strategy has not been rejected and/or is considered a viable available option open to ORO to recommend for portions of the Massachusetts Ep:, please describe what procedures and what equipment and personnel exist for its implementation.

109. Please identify the sources of neteorological information on which ORO intends to reiy during a radiological erergency at Seabrook.

110. For each source of information identified in the immediately preceding interrogatory please describe the communication link between ORO and that source.

111. Please identify and describe any studies and analyses concerning Seabrook site meteorology.

112. What assumptions have been made concerning the frequency of wind-shifts within 2 miles of the Seabrook plant?

Within 5 miles? What is the basis for these assump' ions?

Respectfully submitted, JAMES M. SHANNON ATTORNEY. GENERAL COMMONWEALTH OF MASSACH'.lSETTS By'

/h Allan R. Fierce' John Traficonte Ausistant Attorneys General ,

Nuclear Safety Unit

__ one Ashburton Place

- Boston, MA 02108 (617) 727-2200 DATED: October 19, 1988 6

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