ML20207T623

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State of Nh Responses to New England Coalition on Nuclear Pollution First Set of Interrogatories & Request for Production of Documents to State of Nh on Rev 2 to New Hampshire....* Related Correspondence
ML20207T623
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 03/18/1987
From: Bisbee G, Huntington G, Strome R
NEW HAMPSHIRE, STATE OF
To:
NEW ENGLAND COALITION ON NUCLEAR POLLUTION
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ML20207T535 List:
References
OL, NUDOCS 8703240187
Download: ML20207T623 (40)


Text

_ ._.

  • . O ptEl.AIED CORRESP0ho$c)

March 1gg(;g{ g7 USNRC 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 17 MNt 20 P2:24 ~

Before the Nuclear Regulatory Commission OFFICE OF MRtIARY 00CKElmGA Kavici.

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 RESP'NSES O 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 ANSWERS TO INTERROGATORIES Interrogatory No. 1 l

In accordance with 10 C.F.R. 52.740(e), please supplement your answers to NECNP's First Set of Interrogatories and Requests for the Production of Documents to the State of New Hampshire on New Hampshire Radiological Emergency Response Plans, filed April 30, 1986.

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Response

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Please see the State of New Hampshire's Supplemental Answers to NECNP's Interrogatorios propounded on April 30, 1986, which have been filed herewith.

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. t Interrogatory No. 2 What is the State of New Hampshire's position on each of the contentions that have been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan? What is the basis for your position?

Responso Contention Kensington 2 The State of New Hampshire believes that existing plans and procedures provide adequate opportunity for the licensee to provide timely notification of an emergency to state and local emergency response personnel. Adequate equipment has been or will be provided to undertake the notifications cited in the NHRERP.

Contention Kensington 4 The Kensington Elementary School can provide a sheltering dose reduction factor (DRF) of .9 or better. This fact is based on an inspection of the school by Wayne Roswell in May 1986.

Contention Kensington 6 The State believes that it has the necessary letters of agreement with support organizations. Copies of letters of agreements are included in Volume 5 of the NHRERP. As additioni letters are solicited and obtained they are kept on file at NHCDA.

Contention Kensington 10 The Applicant and the State have provided, or have available for installation, adequate communication equipment, including telephone lines, for placement in the Kensington EOC.

s _s Contention Hampton III.

It is the_ State's position that the ETE prepared by KLD, and incorporated as Volume 15 of the NHRERP, is adequate for emergency planning needs in New Hampshire. Further, the State believes that the ETE meets the general requirements of NUREG 0654/ FEMA REP 1.,

Rey, 1, Appendix 4.

Contention Hampton IV The State's position is that the available resources provided in support of the NHRERP, both personnel and equipment, provide a reasonable basis to implement the range of protective actions which would be required to protect the lives and property of inhabitants of the Emergency Planning Zone. The planning documents outline the means of providing the necessary resources as well as contingencies for supplementing those resources, should that ever become necessary.

Contention Hampton VI The NHRERP demonstrates that there are adequate resources available to protect the residents and visitors in Hampton. 'Where local resources fall short they may be augmented by state resources.

Also see the State's response above on Contention Hampton IV.

Contention Hampton VIII The State of New Hampshire has specifically identified the resources required to provide for timely implementation of a range of suitable protective actions for the residents and staff of the

.s

i Seacoast Health Center. The State has worked with officials of the Seacoast Health Center in developing a plan to identify and provide n

the resources necessary to implement the various contingencies in the plan and to provide' avenues through which additional resouices, whether from local sources or from t e State, can be requested.

Contention NECNP-RERP-8 ,

See State's response to Attoraef General Shannon i s Interrogatory No. 75, filed on this date.

Contention NECUP-NHLP-6 The State believes that there are adequate means.for relocating and/or sheltering those New Hampshire citizens with special needs.

The resources available to accomplish these tasks are outlined in the special facility plans, and local plan elements of the NHRERP.

Contention SAPL 31 See State's response to Attorney General Shannon's Interrogatory No. 32-35 filed on this date. Furthermore, KLC 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 trie ,

Applicants). The State, therefore, defers to the Applicants on these ,

interrogatories.

/

Contention SAPL 7 '

As to decontamination aupervisory personnel, Appendix A, Page A-2, Vol. 4A, will be modified in the next revision to assure adequate personnel to nect the needs identified in Appendix F of Vol. ,

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i, u '4 A. The number of personnel has been increased from eight to thirty-the e. This pool is sufficient to staff two centers in each

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ofthe'four hbst-nommunities for more than two full 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts.

ro. .

Each fact.lity' hf 3 allequate capabilities to permit execution of the procedur$sr \given in Appendix B to the Host Community Plans.

The stalfing given in for " Exterior-Reg. Area Monitoring" for both the primary and secondary faellities in those Appendicies and in Appendix

,7 F, Vol. 4A, are adequate to meet the 20% figure provided by FEMA as l

the planning basis for meeting the NHREG 0654 requirement. A December 24, 1985! FEMA guidance memo on this subject is available for i

inspection.

As to the adequacy of procedures of contaminated waste handling, see the Sate's response to SAPL interrogatories 2(k) and 3(f), at pp.

o. ,

14-5, pg. 19.

l ,. . Contention SAPL 8 and 8A There are or will be adequate personal and communications e

equipJent to support a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day emergency response l

capability. This capability. includes the resources to complete notificationofemerheincyresponsepersonnelatanytimeofdayor L night.

I Contention SAPL 15 New Hampshiro's position is that adequate and appropriate lettnra of agreement are cit'e'd in the NHRERP to demonstrate and

[ ' support reasonable assurance.that adequate personnel and equipment I

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resources are available to implement the range of protective responses which may be needed to protect the inhabitants of the Emergency Planning Zone.

Contention SAPL~16 l See State's response on NECNP Contention RERP-8.

Contention SAPL 18 The State's position is that NHRERP Rev. 2 contains reasonable estimates of the numbers of non auto-owning population in the Seabrook plume exposure EPZ. Adequate resources for evacuating thisl segment of the population exist.

Contention SAPL 25 The State has arranged for the resources necessary to protect those persons whose mobility may be impaired. Adequate numbers of' properly equippe'd vehicles and drivers are available should evacuation become necessary. .

Contention SAPL 33

'See position state with regard to Contention SAPL 7, above.

t 1 Contention SAPL 34 The State feels that it has adequate data describing the population distribution in the Seabrook EPZ. NHRERP, Vol. 6.

Contention SAPL 37 The State has provided or an adequate number of emergency A

vehicles. The vehicles will not.be precluded entry to the EPZ by evacuating traffic.

4

I Interrogatory No. 3 ,

I On or before March 19,-1987, please produce at the office of Harmon & Weiss all documents on which you relay or intend to rely during this proceeding to support your position on each of the contentions that have been admitted in this proceeding with respect 4 to Revision 2 of the New Hampshire Radiological Emergency Response f Plan. This includes but is not limited to all documents used in cnswers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings.

Response

See Motion For Protective Order, infra.  ;

Interrogatory No. 4 Please identify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to reply for your position on each of the contentions that have been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emerg3ncy Response Plan.

Response

The following individual share responsibility for compiling

-responses to interrogatories.

1. Richard H. Strome, Director New Hampshire Civil Defense Agency 1
  1. 2. Dr. William A. Wallace, M.D., M.P.H.

s-l Director, Division cf Public Health Services l

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. v-Response to Interrogatory No. 4 (Continued) 3.. Michael M. Nawoj Chief, Technological Hazards Division New Hampshire Civil Defense Agency

4. John D. Bonds Assistant Director, Division of Public Health Services
5. Scott McCandless, H.M.M. Associates Interrogatory No. 5 Please. identify all persons you may call as witnesses on each of the contentions that have been admitted in this proceeding with

- respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan. Please describe the substance of their testimony; and identify and' describe any documents and the portions thereof that they may rely on for their testimony.

Response

The State presently intends to call no witnesses.

Interrogatory No. 6 On or before March 19, 1987, please produce in the office of Harmon & Weiss all documents in the State of New Hampshire's

. possession which analyze or evaluate in any way the adequacy of the New Hampshire RERP or New Hampshire's state of preparedness in the event of a radiological emergency.

Response

The only such documents are the FEMA and RAC reviews, copies of which have been provided to NECNP. See Motion For Protective Order, infra.

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Interrogatory No. 7 Please identify all persons who participated in the. development

-cr_ drafting of. Revision 2 to the New Hampshire RERP.

Response

The following is a-list of the State employees that participated oignificantly in the preparation of NHRERP, Rev. 2. Additional cupport was provided by the Applicant and its consultants.

1. Richard strome
2. David Carney
3. Michael Nawoj
4. David Deans
5. Robert Pariseau
6. Robert Jeffries
7. Michael Porier
8. Deena Perlman
9. Nancy Wurtz
10. Grace Walker
11. Joanne Beaudoin
12. Nicholas Pishon
13. Howard Gaskill
14. Helen Wilson
15. Ronald Francouer
16. Eugene Ritzo
17. John Bonds
18. William Wallace

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19.- Diane Teft

20. John Stanton
21. Richard DePentima-
22. Wayne Johnson-
23. Belva Mohle
24. William Colburn
25. Michael Coltin

' Interrogatorv No. 8 Please identify all persons who are responsible.for training of-emergency response personnel for implementation of Revision 2 to the -

New Hampshire RERP.

Response

The-following persons have responsibilities for training emergency response personnel for implementing the NHRERP:

1.- Michael Nawoj-(As Emergency Planning Co-ordinator)

2. Harold Adams
3. David Deans
4. Robert Jeffries
5. David Morrison
6. Robert Patterson
7. William Thorpe

'8.

Mario Viglani

9. . Kathy Vanwald
10. Gerald Coogan n-e-- - , , , - -

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Interrogatory No. 9 Please describe the State's program for training emergency response personnel under Revision 2 of the RERP. Identify all individuals who are responsible for that program.

Response

See NHRERP, Volume 1, Section 3.2. See also the State's response to Interrogatory #8, supra.

Interrogatory No. 10 Please produce all documents supporting your calculations regarding the dose reduction effectiveness of certain institutions in the Seabrook EPZ, as described at Vol. 4, Appendix F of the RERP.

Response

All calculations regarding dose reduction effectiveness were completed by the Applicant in August, 1986. This information is provided as Table 2.6-3 in Section 2.6.5 of Volume 1, NHRERP.

Interrogatory No. 11 Please explain your reasons and criteria for choosing to evaluate the dose reduction effectiveness of these particular institutions.

Response

The reasons and criteria for identification of specific institutions with regard to the dose reduction effectiveness of these institutions are described in Section 2.6.5 of Volume 1, NHRERP.

Simply stated, the dose reduction effectiveness of these institutions was evaluated in order that a recommendation of sheltering may be made when the population of these institutions will not be exposed to

e" 9 levels of radiation which meet or exceed.the protective action guidelines set forth in Section 2.6.5 of Volume 1, NHRERP, so long as they remain inside the structures. If these guidelines are met or exceeded, evacuation will be the recommended action.

Interrogatory No. 12 Did considerations of.the time in which these facilities could be evacuated influence your decision to assess the doses reduction effectiveness of these structures? If so, what part did they play, what estimates of evacuation times have you made for these facilities, and what are your conclusions about the feasibility of safely evacuating them?

I

Response

Evacuation time played no part in deciding to carry out a dose reduction effectiveness assessment. The NHRERP, in Volume _6, page 11-21, states that a " reasonable estimate of the elapsed time from the order to evacuate to the~ time a bus servicing a special facility is loaded, is approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />", which is within the evacuation time estimates for any scenario. The state considers that safe evacuation of these facilities is feasible.

Interrogatory No. 13 Has the State performed dose reduction effectiveness calculations for any specific institutional structures in the EPZ, such as schools, other than those listed in the RERP? If so, please provide them. If not, what were your reasons and criteria for refraining from doing so?

Response

Dose reduction factors have been calculated for Philips Exeter Academy, Kensington Elementary School and the Greenland Elementary School. The study of Philips Exeter Academy was conducted at the request of the school and the Kensington Elementary School survey was done in response to a limitation placed by the Board to a contention raised by the Town of Kensington. The Town of Greenland asked to have its school surveyed. The surveys were completed by NHCDA and the Applicant and are available for inspection at the offices of NHCDA, Concord, NH. These surveys will not be used in the decision making process related to protective action recommendations. The reason for refraining from conducting dose reduction effectiveness calculations for other locations is because the State has adopted the

" shelter-in-place" concept, described in Section 2.6.5, Volume 1, NHRERP.

Interrogatory No. 14 Did considerations of the time in which these other facilities could be evacuated influence your decision not to assess the-dose reduction effectiveness of these structures? If so, what part did they play, what estimates of evacuation times have you made for these facilities, and what are your conclusions about the feasibility of cafely evacuating them?

Response

See answer to Interrogatory Numbers 12 and 13 above.

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Interrogatiory No. 15.

. .'For each Emergency Operations Center, how many separate ~

. telephone lines are: allocated to receiving calls'from: members of the.

public seeking transportation assistance? Are these commercial lines

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or dedicated lines?-

Response

See State's May 6, 1986 response to.SAPL Interrogatory No.

. 7(a). The-table indicating the number of telephone lines has not been. updated since that response was provided.

Interrogatory No. 16 For each-telephone line identified above,.has an operator been assigned to the line? If so,-identify the individual and describe-his or her expertise and experience in transportation, and each person's knowledge of the area. Will that person have any other responsibilities at the EOC? If so, describe those other

- responsibilities?

Response

The responsibilities for handling incoming calls for transportation assistance are described on a town by town basis in

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' the volumes of the NHRERP.that deal with local plans. In most cases the Transportation Coordinator is-responsible for receiving and re'sponding to incoming calls.for transportation (See, for example NHRERP Vol. 16 Section IV-F Step #6).

The responsibilities of the persons handling.the incoming calls are also described in the local plan volumes (See, for example, NHRERP Vol. 16 Section III-F and Section IV-F)

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Interrogatory No. 17 For each telephone line identified above, how many households have been told to call that line to request assistance? How many acalls does theemergency?-

radiological. State expect-to receive on each of these lines during

Response

The numbers of. expected incoming calls vary-according to both the town and the time. At present, the list of people that has pre-registered for. help includes 2386 people at 1305 different locations.

The town with the smallest list of people requiring transportation assistance is Kensington with six people at four locations. The Town of Hampton has the largest list with a total of 722 people from 208 locations. The other fifteen towns have request

-lists that fit within this range.

It should be noted that these confidential lists are subject to change at any time. Anyone calling in requesting transportation essistance may be added to these lists. It should also be noted that many of these people may share rides with friends or neighbors in the event of an actual emergency.

Interrogatory No. 18 For each telephone line identified above, does the State intend to use the-line for any function other than the receipt of calls requesting transportation assistance? If so, what other uses are planned?

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Response

The State has~provided the telephone lines for general emergency response use. No limitation to the use of the phone lines has been placed upon the towns. This means that the phone lines could be'used by members of the local emergency response organizations for conducting business other than receiving incoming requests for assistance.

Interrogatory No. 19 Does the State plan to use the same telephone lines identified above to coordinate the activities of vehicles assigned to pick up people with special transportation.needs? If not, what other means of communication will be used? Please identify the number.and type of communication equipment that will be used for this purpose at each EOC, and the number and identify of individuals that are assigned to that task.

Response

Yes, _ telephone lines at EOCs will be used to coordinate the pickup of the special needs population. Additional communication equipment is available, as described in NHRERP, Vol. 1, Section 2.2.

Communications equipment available for use by local-emergency response organizations is described in the set of local plan volumes at Section II.C.

The communications responsibilities of various members of the local emergency response organization are described in Section III and IV of the local plan volumes. The communication duties of State personnel are described in their separate procedures. These procedures comprise Volume 4, 4A and 4B of the NHRERP.

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Int'errogatory No. 20 ,

i Wh'at' advice will be given to people without transportation who call the EOClif the location of.the buses is unknown? What-is the-basis for this advice?

? Response "The Transportation Coordinator procedures (or the procedures of the personnel handling these functions in towns without a Transportation Coordinator) are included in Section IV of each local ~

plan volume. Each of these sets of procedures includes Attachment

2. This page is reviewed with those calling in for transportation assistance.

Interrogatory-No. 21 How will time estimates be made for the arrival at any point on

-the bus route?

Response

The procedures do'not require the Transportation Coordinator or the person filling this role, to make such a time estimate.

Interrogatory No. 22 By what means and how often will those arrival times be communicated to those people in need of transportation? Will the arrival times be verified? If so, by what means and how often?

Response

l. The NHRERP procedures do not provide for such estimates to be made.

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Interrogatory No. 23 Describe the system by which the person taking calls at the EOC will keep-track of who has requested help whether they have received it-yet.

Response

See response to Interrogatory No. 20, supra.

Interrogatory No. 24 For each person who indicates on a reply card that they will need transportation assistance, when will they be contacted with instructions? Who contacts them? Identify these' individuals.

Response

The answers-to these questions are included in the Transportation Coordinator procedures. These are included in Section IV of each local plan volume. The names of the Transportation l Coordinators are included in Appendix A of each local plan volume.

Where there are no transportation coordinators another member of the local emergency response organization has this responsibility and corresonding procedures.

Interrogatory No. 25 Please produce copies of all planned itineraries and routes of vehicles that will provide transportation for people with special transportation needs, including location of bus stops.

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Response

Each local: plan-includes. bus routes.- Maps for eachi designated.

route will be available-at local EOCs and the State-EOC.

Interrogatory No. 26 Please--identify each; individual in the EPZ who is unable by virtue of age or handicap to go to a. bus stop and requires pickup.at home during an evacuation.

Response

The identity-of'special needs persons, and'their responses to the_special needs survey, are confidential. Only those members of-the State'and local emergency response organizations with a responsibility.for assisting these people are normally allowed access to this listing. 'A total of-2386 persons _in the Seabrook EPZ have requested some. form of assistance.

Interrogatory No.-27 For each individual identified in response to'the preceding interrogatory, please identify the location from which that person will be contacted to inform him or her of transportation

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arrangements;~the specific telephone line or other means of communication that will be used; and.the number and identify of individuals that are assigned to'the task.

Response

.Special needs individuals will be contacted form the local EOC in the town in which they reside. In most cases these contacts will be made by the local Transportation Coordinator or his designees.

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Such.designess, if'needed,.will likely be drawn from the pool of emergency workers reporting to the EOC. The Transportation Coordinators and their designees will use the telephone resources available at the EOCs. Also see the State's response to Interrogatory No. 15 above.

In the event that the local emergency response organization does not assume these duties, for whatever reason, NHCDA staff Will assume this responsibility. See NHRERP Vol. 4, NHCDA Procedures Section

13. The NHCDA Local Liaison Staff will undertake any such assignments from the State IFO using the telephone equipment designated for their use. (See State's Response to Interrogatory No.

15,. supra.)

Interrogatory No. 28 Please identify each vehicle that the State of New Hampshire intends to reply on for transportation of school children, handicapped people, institutionalized people, and other people without transportation. Please identify the owner of the vehicle, the driver (s) of the vehicle, the location where it is stored, and its daily route (s) and itinerary under ordinary circumstances. In

. addition, please provide copies of the routes and itineraries of each of the buses over the past-two years.

Response

The numbers of vehicles, their owners, locations, and numbers of personnel available are identified in LOA's in NHRERP, Volume 5.

SONH does not know the daily routes and itineraries under ordinary circumstances and for the past two years, nor does it need to know this information for the purposes of the NHRERP.

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~ Interrogatory No. 29 For each vehicle described in answer to the preceding question, what is the vehicle's capacity? What equipment does the vehicle have-for transporting handicapped people?

Response

Vehicle types and capacities are described in the letters of agreement. See NHRERP, Vol. 5.

Interrogatory No. 30 Please provide copies of the breakdown and maintenance records for each vehicle identified above.

Response

The State does not have this information.

Interrogatory No. 31 Please identify which of these vehicles have radios on board.

For those vehicles which have radios, identify the individuals or organizations that.will communicate with these radios. Identify the equipment that will be necessary to communicate with the vehicles, and where it is located.

Response

The State does not have this information. Note, however, that State plans do not require communication with vehicles in transit.

Interrogatory No. 32 Please identify each bus driver who will be relied on in a radiological emergency, the employer (s) of that individual, and the specific vehicle that the individual will drive. If the driver has not been assigned to a specific vehicle, please explain whether the driver has been assigned to a particular bus company or other vehicle provider; and when the driver will be assigned to a specific vehicle.

l

Response

The State does not have this information..

Interrogatory No. 33 For each driver identified in response to,the preceding interrogatory,. state whether that person is ordinarily employed as a driver and if so by whom. Is the employment part-time or full-time?

Response

Drivers assigned to vehicles will be those who normally operate those vehicles or a qualified, trained substitute.

Interrogatory No. 34 For each driver identified in response to the preceding interrogatory, state whether the driver is experienced in driving a bus for the handicapped or loading students into a bus for the handicapped, and describe the nature and duration of that experience.

Response

See State's response to Hampton Interrogatory No. 2(1), filed on this date.

Interrogatory No. 35 For each driver identified above, state whether that individual has agreed to be available during a radiological emergency. If so, identify the' parties to the agreement, provide the date of the agreement, and indicate whether it was written or oral. If the agreement was in writing, please provide a copy.

Response

Drivers available for assignment are taking state training

-courses. Attendance at these training sessions implies agreement to

. emergency response assignment, however, the State has not and does not intend _to pursue formal agreements with individual drivers or other individual members of the emargency response organization.

Interrogatory No. 36 Provide copies of the regular employment contracts between drivers and the bus companies that have agreed to provide transportation service during a radiological emergency.

Response

The State does not have copies of these contracts.

Interrogatory No. 37 For each driver identified above, describe the means by which they will be contacted; the individual (s) who are assigned to contact them; and the location, number, and type of each piece of communication equipment that will be used to contact them to request their assistance during a radiological emergency.

Response

Bus companies will use telephones to contact drivers, as they do during an emergency school closing. Procedures will contain provisions for using broadcast outlets to alert bus drivers of companies under agreement to contact their garages at the Alert level. This will facilitate an early determination of the number of buses and drivers immediately available.

t Interrogatory No. 38

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For each driver identified above, describe all steps.that the State has taken to assure that drivers can be contacted on a.24-hour

' basis.

-Response See State's response to Interrogatory No. 37, supra.

Interrogatory No. 39 For each driver identified above, describe all steps that the State has taken to assure that the bus driver will be immediately available to respond to a radiological emergency.

Response

See State's response to Interrogatory No. 37, supra.

Interrogatory No. 40 Provide any information on estimates you have made concerning how long it will take each of these drivers to get to the bus that they will drive. Discuss the basis for your estimates and provide copies of any supporting documents.

Response

KLD has made estimates of bus mobilization times in its ETE.

These estimates are included in the NHRERP, Vol. 6.

Interrogatory No. 41 Have estimates been made of how long it will take to mobilize

! willing drivers at any time of the day? Discuss the basis for your i estimates and provide copies of any supporting documents.

Response

See State's response to Interrogatory No. 40, supra.

Interrogatory No. 42 For those drivers who reside within the Seabrook EPZ and have small children or other family members who require transportation out of the EPZ during an evacuation, please describe all arrangements that have been made for the evacuation of those family members?

Response

These people will be dealt with as part of the overall transportation dependent population. Drivers from within the EPZ who desire to take immediate family members with them have been told they may do so. This is made clear in training.

Interrogatory No. 43 With respect to the evacuation of school children, by whom and by what criteria will the decision be made as to whether to send buses to the staging areas or directly to the schools?

Response

The intent is to use buses garaged within the EPZ to provide immediate response to schools on a priority basis. A procedure has been developed to have the priorities determined by the State Education Department in consultation with State EOC_ officials and School Superintendents; based on those schools deemed most immediately volnerable. Buses garaged outside the EPZ will be mobilized at State Transportation Staging Areas for dispatch as needed to complete student evacuations.

Interrogatory No. 44

. Identify all individuals responsible for monitoring the adequacy of transportation for schools and institutions and individuals requiring special transportation, and directing the provision of transportation for these people. Is the responsibility divided between several people? If so, how? What other responsibilities are assigned to those individuals?

Response

. Local Transportation Coordinators determine the estimated transportation requirements of each town and report said to the IFO Local Liaisons. The IFO Resources Coordinator collects the data on' town needs and transmits it to the.EOC Resources Coordinator who mobilizes the required vehicles for dispatch-to the State Transportation Staging Areas.

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l When an evacuation is recommended, the IFO Resources Coordinator and the Transportation Staging Area Supervisor coordinate the dispatch of the appropriate vehicles to each town. The process continus until all identified needs are met and the evacuation completed. See Local RERPs Vol. 16-32, Transportation Coordinator, Resource Coordination Procedures, Volume 4, and Appendix I, Volume 4.

Interrogatory No. 45 Please identify all organizations and individuals that the State will contact in order to arrange for the transportation of school children and other people with special transportation needs during a radiological emergency.

Interrogatory No. 46 Please identify and describe the location from which those contacts will be made; the type and number of separate pieces of communication equipment that will be used; and the number and identitity of individuals who are assigned to make those contacts.

Response to Interrogatories Nos. 45-46 Contacts requesting transportation resources, other than those resources directly at the disposal of the towns, will be requested from the State EOC. The process for requesting those resources is described in the NHCDA Resource Coordinator Procedures included in the NHRERP, Vol. 4. Most requests will be made from State EOC telephones. Other communications equipment available for use from the EOC is described in Vol. 1 Section 2.2.

Also see procedures for the procedures for pupil transportation safety and EMS. Both are contained in NHRERP, Vol. 48.

'e- .e

. Interrogatory No.-47 Is the. communication equipment described in answer to the preceding interrogatory devoted exclusively to communications requesting transportation assistance? If not, to what other uses is it assigned?

Response

The telephones and communications equipment cited in the previous response are available for general emergency response use, and are not limited exclusively to communications requesting transportation assistance.

Interrogatory No.-48 Identify all bus and driver pairs that regularly carry children to and from schools, and can be expected to be available in a radiological emergency. Provide the basis for your answer to this question.'

Response

The State does not have this information. Numbers of bus drivers and alternate drivers are contained in NHRERP Resource

. Coordinator Procedure, Volume 4, Appendix I and letters of agreement, Volume 5.

Interrogatory No. 49 How long will it take to' mobilize all the necessary buses in case of an evacuation? What is the basis for your estimate?

Response

'The KLD ETE provides a mobilization time range from four minutes to three hours. See NHRERP, Vol. 6.

Interrogatory No. 50 Identify each-driver who has been trained for implementation of the NHRERP. Describe the means by which those individuals were trained, the dates on which they were trained, the identify of individuals who trained them, and the content of the training program. Please provide copies of any written materials that were used.

Response

An independent file of personnel is maintained by date, training class, and modules received. All bus driver personnel have received training in modules 01, 02, and 19. These files are maintained in the NHCDA office by class date. The individuals who trained the personnel are listed in number 8 above, course materials are available upon request.

Interrogatory No. 51 Describe any direct communications between Public Service or the State of New Hampshire and the drivers in the Teamster's Union.

Response

The State of New Hampshire has communicated only with the leadership of the Teamster's Union. See the related letter of agreement contained in the NHRERP at Volume 5.

The State has no knowledge of communications between representatives of PSNH and any member of the Teamster's Union.

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Interrogatory No. 52 Describe any communications or agreements between the Teamster's Union and its own drivers regarding the NHRERP.

Response

The State has no knowledge of communications or agreements .

between the leadership of the Teamster's Union and its members.

Interrogatory No. 53 Provide any agreements between drivers for the Teamsters Union and Union Officials, Applicants, or the State of New Hampshire.

Response

See State's Response Interrogatory Nos. 51 and 52 above.

Interrogatory No. 54 Provide copies of regular employment contracts of drivers in the Teamsters Union who will be relied on during a radiological emergency.

Response

See State's Response to Interrogatory No. 52 above.

Interrogatory No. 55 Provide all agreements or correspondence between the Teamsters Union or Union officials, Applicants, or the State of New Hampshire, regarding the possible provision of transportation services by Teamsters members during a radiological emergency.

Response

See State's Response to Interrogatory No. 51, supra.

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Interrogatory No. 56 Describe all arrangements that the State has made for the provision of backup buses in the-event that insufficient buses are available-.during~a radiological emergency.

Response

The State EOC Resources Coordinator and' Pupil Transportation-Safety Representative share responsibility for identifying and mobilizing additional resources as required-(see Volume 4 and 48).

Interrogatory No. 57 Identify all bus and driver teams that are allocated for the transportation of transients during the summer months.

Response

See response to Interrogatory No. 48, supra. Also note.that bus and driver arrangements are not seasonal.

Interrogatory No. 58.

Are those individuals committed exclusively to assist in the emergency response for the Town of Hampton? If not, describe their other responsibilities.

Response

No. Available vehicles and personnel may be sent to various locations at which their services are needed. See Rockingham County Procedures in NHRERP, Vol. 4B. These include procedures for dispatching emergency vehicles and drivers as necessary.

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Int'e rrogatory - No. 59 '

NUREG-0654-states that."the overall objective of e'ergency

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response plans is to provide does savings-(and in some, cases '"

immediate-life savings for a' spebtruir of accidents that ~ could produce

-offsite doses in excess of Protectivo' Action Guidelines (PAGs)." In - '

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this-vein, NUREG-0654 requires plann,ers to. consider, inter alia, the.

timing and consequences of potentia 14re_16ases.

What spectrum of >

accidents did the State consider in developing Revision 2Lto the ' '

NHRERP, and what are the characteristics of those accidents?- What , .

quantitative dose saving result from implementation of theLprotective measures proposed?in. Revision"2, given each type of accident that was considered? Please provide all- data. that supports your conclusion. t Interrogatory No.-60 Assuming that does reductions are achieved, describe the health effects associated with each of the accidents that you considered in developing Revision 2 to the RERP.

Interrogatory No. 59-61 Identify and provide access to any and all of your calculations of potential-dose consequences to the public in the event of a radiological emergency at Seabrook, and the bases for those calculations.

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Response

. y The. State objects to these interrogatories on the grounds of relevance. NUREG-0654 neither states nor implies tha't' State planning chould consider the-timing and consequences of a~ range of potential accident scenarios. Rather, the federal agencies have considered a range of accident scenarios in compiling the planning guidelines.

Notwithstanding its objection, and without wai\ ring it, the Stath responds as follows:

The. State of New Hampshire, in developing the RERP unad the i

planning standards described in NUREG-0654. The State of New '

Hampshire understands that those standards were developed to assure

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. j. q appropriate. responses to'a range of accident sequences and scenarios

( and therefore no spectrum o5 accidents was considered independently by the State. There is, th'erefore, no data available which' addresses inequantitativedose-sav[ngthatmaybeexpectedtoresultfrom iriplementation of Revision 2 protective measures.

No separate postulation of accident scenarios requirement was ever intended, nor has such a postulation been attempted by the State.

Interrogatory No? 62 Has the -State completely ruled out sheltering of the beach a population if'an. accid 9nt occurs during the summer? Under what fsircumstances might sheltering be ordered? Describe the criteria for-

, making such a decision./

Response

No, sheltering of beach population has not been " completely ruled out." The State's concept for shellering are described in

, NHRERP Vol. 1 Section 2.6.5. Criteria for selecting protective

,1 s actions, including sheltering, are addressed in Section 2.6.7. Also

  1. see State's May 14, 1986 responses to NECNP Interrogatories 5(a) -

2 5(p).

Interrogatory No. 63 Describe and identify the date and parties to all oral agreements for the provision of host facilities and staff for evacuees from the Seabrook EPZ.

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Response

LThere have/been.no " oral agreements" per se.

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Each of the host community-governments has agreed to provide host community services.

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\ between NHCDA and' municipal officials. '

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%' Please identify and.' produce a'll written agreements for the ' '

f -provision of host facilities and staff for evacuees from the Seabrook L

EPZ.

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No such written agreements have been solicited and, therefore, none exists.

7 U Interrogatory No 65 Please identify all individuals who Vill be relied on to staff

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.I host facilities during a radiological emergency, and their functions.

Response

The New Hampshire Division of Human ~ Services (DHS) will -lu3 j

responsible for providing sufficient staff and resources.for v

operating Host Community Reception Centers. Each Host Community will 1 be served by a DHS Primary ~and Support Emat' enc ' Services Unit staffed by district office personnel frty sa :ed State offices.

Human Services personnel will provide evacuee registration, a message

.np exchange and locating service, information/ recreation, mass care q referral, a volunteer service, and will coordinate student pick-up.

See Vol. Set 1.3, DHS Procedures, Volume 48.

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Mass care Shelters will be operated by the American Red Cross.

A Host Community's American Red Cross Chapter will provide the initial staffing of that community's shelters. Additional support will be provided by other Red Cross Chapters within the Southern and Northern New England American Red Cross Territories and outside these Territories if needed. Red Cross personnel primarily provide sleeping accomodations, food services, emergency medical stations, recreation, and registration for evacuees in their shelters. Once primary responsibilities are fulfilled, Red Cross will assist other agencies in the Host Community operation. See Red Cross LOA Vol. 5, Red Cross-Procedures, Vol. 4B.

Primary and Secondary Decontamination Centers will be staffed by Host Community firefighters and their mutual aid fire departments under direction of personnel from the Division of Public Health Services. Firefighters will provide radiological monitoring of evacuees and their vehicles and will assist with decontamination if needed. Division of Public Health personnel provide the on-site decision making and interface with Public Health Officials at the State EOC when necessary. See Vols. 33, 35, 36, 38 Host Plans Appendix A and B. See Vol. 4A, DPHS Procedures Decon.

Host Community Emergency Operations Centers will be staffed by members of their emergency response organizations.

Interrogatory No. 66 Please describe all measures that will be taken at host facilities to prevent contaminated individuals from contaminating uncontaminated or less contaminated individuals.

Response

Appendix B of host facility communities Volumes 33, 35, 36, 38 and Appendix F of Volume 4A of the N.H. RERP provides for segregation of contaminated from non-contaminated of uncontaminated individuals, and the areas used for decontamination are of sufficient size to segregate individuals with different levels of contamination, should that be necessary.

Interrogatory No. 67 Please describe all equipment and procedures for storing and disposing of waste water.from the washing of evacuees and their vehicles.

Response

Under Revision 2 of NHRERP there are no provisions made for isolating contaminated water from showering or car washing.

Monitoring of discharge water will be conducted in accordance with procedures described in Appendix F of Volume 4A of the NHRERP. If the water exceeds the limit specified in the New Hampshire Rules for control of Radiation He-P 2020 and He-P 2023, it will be diluted by addition of water until the discharge is within state standards.

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MOTION FOR PROTECTIVE ORDER Because the' State of New Hampshire filed no contentions on the:

NHRERP and intends ~to offer no testimony on any contentions that were filed, the/ State isEnot obligated to respond to any interrogatories on'the NHRERP. See this Board's Memorandum and Order (March 1, 1983) atJ3-4, 7 (Interrogatories which are sponsored by the interrogee and which will not be the subject of direct testimony proffered by the

.interrogee need not be answered.) Recognizing, however, that New' Hampshire state personnel involved in developing the NHRERP can and will provide valuable input in this proceeding on New Hampshire emergency planning issues, the State has voluntarily responded to I

this set of interrogatories and request for production of documents.

The State-of.New Hampshire hereby moves the Board for a protective

' order that the documents that NECNP requests to be produced may be produced at.the offices of the New Hampshire Civil Defense Agency in Concord,-New Hampshire. The majority of-the requested documents are already in the possession of the NECNP (e.g., NHRERP; RAC Reviews),

and the remainder of the documents constitutes a large number of pages. To provide copies of these documents by mail to NECNP would 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 work hours at the Civil Defense Agency headquarters, 107 Pleasant Street, Concord, New Hampshire, 03301.

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I ;c - a Purthermore, the State of New Hampshire requests thatLthis Board enter a protective order that, for the reasons given, the following interrogatories need not be answered further.

Interrogatory Nos. 59-61 In these interrogatories, NECNP inquires as to whether and how

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the State has considered a. spectrum of accidents in developing the NHRERP. Insofar as NECNP suggests that NRC planning regulations require state planners to analyze independently a spectrum of accidents, it-inquires into matters not required by NRC regulations and guidelines. Rather, NUREG-0654 itself, which considers a spectrum of accidents, establishes emergency planning guidelines.

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SIGNATURES

'As to Answers to Interrogatories 6-58, 63-64:

Richard H. Strome As to Answers to Interrogatories 1-5, 59-62,'65:

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, based 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:

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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.

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Richard H. Strome Director, Civil Defense Agency Sworn to before me this jr/( day of rc , 1 S7:

W HvLud Publiu' My Commission Expires: 9/f/f'

'l As to Obiections and Motion for Protective Order:

0 4$W Date 4

George Dana Bisbk.g i Senior Assistant Attorney General Environmental Protection Bureau Office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3679 slwin Date

%($ it Geoffrey M.

Attorney 1 I untingt'on

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

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