ML20212K692

Seacoast Anti-Pollution League Interrogatories & Requests for Documents to State of Nh on State of Nh Radiological Emergency Response Plans,Rev 2.* W/Certificate of Svc. Related Correspondence

ML20212K692
Person / Time
Site:	Seabrook
Issue date:	03/05/1987
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	NEW HAMPSHIRE, STATE OF
References
CON-#187-2718 OL, NUDOCS 8703090390
Download: ML20212K692 (8)

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MarcigCgTED987 UNITED STATES OF AMERICA g  : NUCLEAR REGULATORY COMMISSION. g i.P157 BEFORE THE ATOMIC SAFETY AND LICENSING BOASD.g F SECHiTW h0CXLTlHG A SE!tV!Cf;

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.In the matter of:

PUBLIC SERVICE COMPANY OF - Docket No. 5 0 -44 3 Ol NEW HAMPSHIRE,.ET-AL p /yqf g[

(Seabrook Station, Units 1)

SEACOAST ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO-THE STATE OF NEW HAMPSHIRE ON NHRERP REV.-2 INSTRUCTIONS FOR USE The Seacoast Anti-Pollution League hereby reques ts that the State of N_ew Hampshire, pursuant to 10 C.F.R. 62.740(b) and 92.741, answer separately and .f ully, in writing under oath or affirmation, the following- interrogatories and produce and permit inspection and copying of the original or best copy of all documents identified in their response to interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents herein identified, the State file supplemental responses and produce additional documents..as required by 10 C.F.R. 02.740(e).

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

(' having possession of the document.

The term " document [s]" as used herein shall mean any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any

, and all correspondence, letters, telegrams, agreements, notes,

! contracts, instructions, reports, demands, memoranda, data, L_ schedules, notices, work papers, recordings, whether electronic or 4 by other means, computer data, computer printouts, photographs, microfilm, microfiche, char ts, analyses, intra-corporation or intra-4 of f i ce commun ica t ions , no t ebooks , di a r i es , s ke t ches , d iagrams , maps ,

forms, manuals, brochures, lists, publications, drafts, telephone l--

minut es , minutes of meet ings , s ta t emen t s , calendars , journals , order s ,

confirmations, and all other written or graphic materials of any l

l' nature whatsoever, g

' 8703090390 870305

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GENERAL INTERROGATORIES L

A) For each and every one of the admit ted SAPL Contentions (#'s 31, 7, 8, 8A, Redrafted 15, 16, 18, 25, 33,-34 and 37), provide the folllowing information:

.a) What witnesses does the.. State of New Hampshire intend to.

have testify.with cespect to this contention?

_ b) What position does the-State of New Hampshire intend to take on this contention and what is the basis of-this position?

c) What documents will be used in support of the State of New-Hampshire's position on this contention?

B) For each and every witness identified in answer to subpart a above, provide the following information:

a) Name b) Address c). Present professional or employment affiliation d) Curriculum vita

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STATE OF NEW HAMPSHIRE SPECIFIC INTERROGATORIES

-1. Provide a' detailed explanation as to how the number of "through"

vehicles in_the EPZ highway network at the time of the order

~to evacuate was' calculated. Was this 3,000 estimate included in'the calculations which resulted in ne time estimates?

2. . Provide copies of all of the aerial photographs KLD looke'd at of the Seabrook EPZ. By whom were the aerial photographs used in the KLD Report taken? Who provided the aerial photographs to KLD? When were the photographs taken (provide specific date(s) and time (s)'of day)? (Answers should be provided both for the aerial films from which the 300 cars in the' beach area were counted (see Vol. 6, p. 10-16)'and the aerial photographs referenced at Vol. 6, p. 2-10).

3. Provide any and all sources of information and documents relied upon to generate the KLD estimates of:

a) vehicles per dwelling at seasonal housing units b) counts of overnight accommodation units e) numbers'of vehicles at campgrounds Provide page ref erences to documents cited in response to parts a, b, and c above.

4. Describe in detail the method by which the estimate of the peak summer weekend population of the Town of Hampton was reduced Efrom 110,000 to 36,635.

5. Provide any and all documents upon which KLD relied for population estimates for the following groups:

a) permanent residents b) seasonal housing residents c) patrons of overnight accommodations d) transients (i.e. daytrippers) e) transit dependent persons Provide a succinct description of how the estimates of these groups and any other groups KLD used were combined to estimate the total population within the 10-mile EPZ. Provide the peak population estimate numbers for the 10 mile EPZ. Provide the peak population estimate for what KLD describes as the " beach area."

6. Provide any and all documents KLD may have relied upon to project resident and employee growth in the EPZ over the next 10 years.

How,-if at all, was growth accounted for in the KLD estimates?

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Describe in?detallhow the State of 'ew Hampshire-is going to

? 17. N s taf f the Traf fic Control -Pos ts (TCP) and Access Control Pos ts' (ACP). For each of the TCP and ACP designated in the KLD Report,

state the name and address of the person who will man the post and'the organization or agency from which that person will be

-drawn.. Provide rosters of.the personnel for-each and every organizat ion or agency f rom :which . t raf f ie control. personnel-will be drawn. Describe how many of .the personnel can reasonably.

be expected'to be on duty at any given time.

8. ' Describe the. basis of the assurapt ion that traffic management and control measures are in effect at the time the evacuation

'is ordered. How much time does-KLD assume it will take to put.

-these measures into effect?.

J9. Describe in detail the assumptions employed in the sensit iv'ity study that yielded the result that an immediate General ~ Emergency would only extend ETE's 20-30 minutes. -

10. /How was=the.25% spontaneous evacuation rate arrived-at?

11. Provide a map detailing every parking space in the " beach area.'"

12. Why did KLD not account for roadway capacity reductions resulting

.from disabled vehicles?

13. State the bases for the assumption that incoming emergency response' vehicles will be able to travel from 40 to 50 MPH.

14. Explain why the KLD Report does not employ the capacity reduction for snow cited in the 1985 Highway Capacity Manual.

15. Explain why the KLD Report fails to take into account choke points at ~ bridges.

16. Who performed the telephone survey of the bus companies ref erenced in Vol. 6 at p.11-18.? Provide copies of the survey instrument employed, the raw data from the responses and the compilation of the responses.

17. Provide the raw data collected in the telephone survey and describe in detail how it was dealt with to arrive at the 2.5%  ;

estimate of transit dependent persons for the resident populatlon.

18.. What are the estimated percentages of transit-dependent persons in the seasonal and transient populations? Detail how these estimated percentages were arrived at.

19. Describe in detail the basis for the assumption that elderly or disabled persons can board a bus in a 15 second mean highway.

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20. Provide -the detailed data collected on roadway geometries, lis t every road studied in the Seabrook EPZ and' state to which of the 4-classifications that roadway has been assigned.

21. Since KLD prepared the evacuation time study at Vol. 6 of the NHRERP, has any other information come to light that would-in any manner alter the results and conclusions of the report? If so, specify the nature of the information and provide any and all' relevant documentation.

22. Provide documentation of discussions with campground operators which formed the basis of the 75% estimate of unoccupied campground sites during the day in Vol. 6 of the NHRERP at p. 2-20.

23. Where are the barricades and cones to be employed at Traffic Control Posts (TCP) and Access Control Posts (ACP) to be stored?

How many cones are available for use and how many barricades are available for use? Detail the means by which these traf fic management devices are to be deployed to the locations at which they are to be used (i.e. who is to deploy them and by what means are they to be transported?). Provide an est imate of the amount of time it will take to have all of this equipment in place. Describe how snow removal responsibilit ies would af f ect the ability of personnel to deploy the traffic management devices.

24. Provide a proper calculation of the number of persons needing transit because of out of service vehicles. Has KLD r ecalcula ted ETE's using a correct calculational method? I f so, what impact did this correction have on ETE? If not, why not?

25. Provide a sample derivation of link capacities for one simple and one more complex link, along with a sample of actual flow at a crowded intersect ion showing all inputs, outputs, and queues.

26. Prov.ide full loading results at one major loading point.

27. Describe in detail how light traf fic patterns have been treated in the simulation model.

28. Provide an estimate of the number of boats in the Seabrook Station EPZ and the average number of people per craft. How does KLD assume that these individuals will be evacuated and what is the estimate of time required for a complete evacuation of the boating populace?

29. Provide a description of the empirical basis upon which KLD rests its assumption that the maximum trip generation time under conditions of heavy snow fall is 150 minutes.

30. What, if any, binding contracts have the State of New Hampshire and/or Applicants entered into for provision of personnel, services, vehicles or equipment for a radiological emergency response. Provide copies of any and all contracts identified.

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31. _ What.spee_ific instructions ~and training are-_given to traffie-

control ~ personnel in order _that they will.know how to direct

traf fic and how to respond to inquiries - by evacuees..

Provide-

!any-documents and/or. training materials'.

32. lWhat . number o f. individuals does the State of _ New Hampshire expect = would 2 repor t .to. recept ion centers - for - monitor ing and .

decontamination if a radiological emergency were-to occur at Seabrook?' Provide numbers separately for each of .the reception centers c(Salem, Manchester, Rochester, Dover).

. 33. What guarantees does the State have that Manchester:High School,

.Spaulding High School, Salem High School and Dover High School would be made available'in the event of a r'adiological emergency?

Name=the individual.or individuals who have authorized use of each 'of these facilities. Provide answers to these'- same questions f or. : each ' of the secondary facilities in the four communities.

34. What individual or individuals have authorized the use of local fire department personnel to perform decontamination services?

Provide answers for each of the 4 host communities. How many fire department : personnel are there in each of the 4 host communities? How many are full time personnel? Provide copies of the materials used in instruction and training of the fire department personnel ~ for decontamination duties.

35. When minors are found to _ be contaminated, is permission of parents required to be sought prior to.their decontamination _?-

36. Under the Revision 2 plans, what provisions are to be made for isolating contaminated water (from showering and car washing) from the environment?

37. How many DPHS Supervisors are there who could be assigned to duty at a host community. reception center? List the names and a'ddresses of these individuals.

38. For.each-of the 4 host community reception centers, state how many CDV-700 survey meters will be available. Has this numbar of survey meters yet been provided to the host communities?

39. - For each of the 17 local communities within the EPZ in New Hampshire, state the number of individuals necessary to carry out an adequate emergency response. For each of the communi t ies that did not participate in the Feb. 26, 1986 graded FEMA ~ dr ill, detail where replacement personnel would come f rom to carry out the emergency response. Provide whatever evidence the State of New Hampshire has to establish that there are sufficient personnel ~ to carry out an emergency response in all of these communities simultaneously.

40. For each of the 17 local communities within the New Hampshire

'EPZ, state which local liaison is designated to work in that community. Provide an estimated time for the local liaison to travel from home to that community.

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52. Ilas the State of New llampshire any data on the sheltering dose reduction factors for the schools and day care centers in the New Ilampshi re por t ion of the EPZ? If so, please provide the data.

53. Account for the discrepancy in the total number of buses shown in the Rev. 2 local plans (482 buses) and the number set out in the "Transpor tat ion resource Requirements" at p. I-8 of Vol. 4 (444 buses).

54. Explain in detail the basis for the reduction in non-atto owning persons from 8,659 to 2,106.

55. Where does the S ta te of New llampshire plan that Category I and Category IV patients from Exeter llospital will be treated following their evacuatlon?

56. Upon what legal basis does the State of New flampshire found the provision in the Exeter llospital Radiological Emergency Response Plan for differential consideration of the evacuation option for those patients aged 55 or over?

57. Identify any survey (s) that have been conducted of employees within the New llamp s h i r e Department of Ilealth and Wel f are.

Provide a copy of each survey instrument employed and provide ,V the survey results. \

Respectfully submitted, ,

SEACOAST ANTI-POLLUTION LEAGUE By its attorney, BACKUS, MEYER & SOLOMON

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IJ2%,/%A llobert A. Backus P. O. Box 516 116 Lowell Street Manchester, N . fl . 03105 Tel: (603) 668-7272 DATE: March 5, 1987 I hereby cer tif y that a copy of the within Interrogatories and lleguests for Documents to the State of New llampshire on NilRERP Rev. 2 has been sent this date, firs t class, pos tage prepaid, to those listed on the at tached service list, and Federal Expressed to those names which are indicated with an asterisk.

R6bert'A. Backus

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1 CERTIFICATE'OF-SERVICE AND' SERVICE LIST:

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~ Asst.Gn.Cnsl. Helen,Hoyt. Chm. .* Thomas Dignan, l Nsq. *

$ Jcs'eph F,I: d . E m Flynndgmt.

erg.- . Agcy. Admn. Judge Ropes & Gray-FJ J 500 C.St. . Sc. West Atomic Safety &~Lic Brd. 225 Franklin St.

f Washington,'DC- 20472 USNRC Boston,.MA 02110-

' Washington,-DC 20555 tOffice'of Selectmen Dr. Jerry Harbour ~* Docketing & Serv. _ Sec.

• Tc:n of = Hampton Falls Admin. Judge .

Office of' the Secretary Hampton Falls, NH 03844 Atomic Safety & Lic~Brd. USNRC USNRC Washington, DC 20555

- Washington, DC 20555 Sherwin E. Turk, Esq. V Office of Exec. Legl. Dr.

Dr. Gustave A. Linenberger.

• Jane Dough 4y

. Admin Judge. SAPL jUSNRC'  : Atomic Safety & Lic. Brd. 5 Market Street

Wahsington, DC 20555 ~

USNRC Portsmouth,.NH 03801

- Washington, DC 20555 L Phillip-.Ahrens, Esq. Paul McFachern, Esq. George Dana Bisbee, Esq.

Anat.' Atty. General. Matthew Brock, Esq. Attorney General's OFF.-

State House, Sta. #6 25 Maplewood Ave. State of'New Hampshire Augusta, ME 04333 '

P.O. Box 360 Concord, NH . 03301 Portsnouth, NH 03801

~ Carol Sneider, Esq. , Asst. AG Diane Curran, Esq. William S. Iord

One

Ashburton Place, Harmon, Weiss Board of Selectmen

19th Floor 20001 S Street NW Suite 430 lban Hall-Friend St.

Boston, MA 02108' ,

Washington, DC 20009 Amesbury, MA 01913 Richard A. Hanpe, Esq. Maynard Young, GairTan Sandra ~ Gavutis -

LNew Hangshire Civil Defense . Board of Selectmen Town of Kingston l~ ~--Agency 10 Central Road Box 1154 Harpe & McNicholas .

Rye, NH 03870 East Kensington, NH 03827 corh. b3301-t

, : Judith H.' Mizner, Esq. Edward Thomas Mr. Robert Harrison

~, Silverglate, Gortner, FEMA Pres. & Gief Exec. Officer-.

Baker, Fine, Good & Mizner 442 J.W. McCortnack (P001) PSCO I. t88. Broad Street Boston,,MA 02109 P.O. Box 330

[EBoston,'MA 02110 Manchester, NH 03105 r

Roberta Pevear I

State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, NH 03844 s

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