ML20247A572

Applicant Voluntary Responses to Commonwealth of Ma Atty General Interrogatories & Request for Production of Documents That Pertain to Exercise Areas Requiring Corrective....* W/Certificate of Svc.Related Correspondence

ML20247A572
Person / Time
Site:	Seabrook
Issue date:	03/24/1989
From:	Cook G, Fiegenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	MASSACHUSETTS, COMMONWEALTH OF
References
CON-#189-8357 OL, NUDOCS 8903290145
Download: ML20247A572 (18)

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$E1ATED CORHESPONDEACS  !

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'89 MAR 27 P3 :55 March 24, 1989 ,

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. UNITED STATES DF hAMERICA

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, NUCLEAR REGULATORY COMMISSION  ;

before the ATOMIC SAFETY AND LICENSING BOARD d

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In the Matter of. )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL

'NEW HAMPSHIRE, et al. ) 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues j

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l APPLICANTS' VOLUNTARY RESPONSES TO "MA ATTORNEY GENERAL'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS 1 THAT PERTAIN TO EXERCISE ARCA'S."

Applicants voluntarily respond herein to the, informal discovery request of the Attorney General for the Commonwealth of Mass &chusetts (" Mass AG") dated March 10, k 1989. Applicants will produce the documents requested at Seabrook Station during business hours upon reasonable notice to undersigned counsel on the same conditions to which the I

parties have agreed in the past.

Interrogatory No. 1 Please state the name, title / position and business address of the person answering these interrogatories.

8903290145 890324 3 DR ADOCK 0500 pi

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,7 l-x, Aeolicants' Response Applicants' incorporate herein their response to Interrogatory'No. 9. .] !

Interrogatory No. 2

-l Please state any and all steps that have been taken to i date to correct, modify, enhance, or otherwise effect the .i areas requiring corrective action (ARCA'S) noted on pages 207, 226, and 231 of the Exercise Report of the Seabrook Nuclear Power Station prepared by the Federal Emergency Management Agency (FEMA) dated Sept. 1, 1988 ("the Exercise Report").

Aeolicants' Response

1. As to the ARCA noted on page 207:

a. SPMC, IP 2.8, was revised in. Amendment 6 to include instructions to repeat directives to field workers approximately every 30 minutes. SPMC, IP 1.4 was not revised because the Communications Coordinator to whom this procedure pertains monitors radio traffic in the ORO EOC only (unless an equipment problem occurs at the staging area). IP 2.8 contains the directions for those individuals in the Staging Area, the EOC, or the field who are in radio contact with field workers.

b. The EMS radio at the staging area has been repaired. ,

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c.. .The ranges ~of the 800 mHz'and EMS radio networks are adequate to perform activities in: support of the SPMC from the designated ORO staging area.

2. As to'the-ARCA noted on page 226:

a. Issue #1: The ARCA;concerning instructions for' Bus Drivers and. Route Guides has'been noted in the annual update training module for Route. Guides, EM  !

1054.

b. IssueJ#2: As indicated on page 282 of the same report, NH Yankee committed that the FEMA-identifiediconcerns for incomplete instructions or ,

details on mapa for day care centers and' nurseries.

will be addressed by June, 1989. .These maps are.in-the process of being enhanced to provide clearer and more detailed directions and instructions.for' use by the drivers of the vehicles that would be'

'l assigned to these facilities. The location of each' '

of the day care centers and nurseries is being field-verified to ensure accuracy and the maps on which they appear are being redrawn with improved I

legibility techniques and with features that will assist the driver. This work and the enhanced version of the maps will complete by the June, 1989 commitment.

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3. As to-the ARCA noted on page 231, no actions have currently been:taken.

Interrogatory No. 3 Please state any and all steps that have beeniplanned;  ;

and/or will be taken in the future to correct, modify, j

- enhance,.or.otherwise effect [ sic]'the.ARCA'S'noted on pages 4 207, 226, and 231 of the Exercisa Report. I r

Aeolicants Response-Applicants object to this Interrogatory insofar as it- i seeks information concerning any and all steps that.will be taken in the future that would affect the'ARCAs identified. I

The question is. overly broad'in that Applicants may undertake some' action in the' future that they have not yet considered or planned for but which may affect the areas'that received' l ARCAs. Without waiving the foregoing objection, Applicants i respond.as follows concerning. steps that Applicants have planned or that Applicants currently believe will-be taken in the future

1. As to the ARCA noted on Page 207:

a. A revision will be made to~ Annual Update Training Modules, including EM 1020, EM 1038, EM 1039, EM 1043, EM 1045, EM 1054, and EM 1055 to include a discussion of this ARCA and problems that may be encountered by heavy radio traffic. I

b. Radio systems of new ambulance support companies I

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R will be reviewed to ensure compatibility with the staging area. radio.

2. As to the ARCA noted on page 226: i

a. . Language for inclusion in SPMC, IP 2.10,. indicating l

that Route Guides and Bus Drivers are to follow l l '

designated routes, has been approved and the procedure will be' revised. 1

b. See response 2.b to Interrogatory No. 2.

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3. As to the ARCA noted on page 231:

Training for MS-1 hospital. staffs is scheduled.

Interrogatory No. 4 3

i For any and all steps identified in response to Interrogatories l'and/or 2 (sic] [should be 2 and/or 3]

please-state-the dates (s) on which those steps were taken or are expected to be taken.

Anolicants' Resoonse

1. As the to ARCA noted on page 207:

a. The revision to SPMC, IP 2.8 was approved on July 7, 1988 and issued in Amendment 6 of the SPMC. l

b. The EMS radio was repaired and in service on September 23, 1988.  !

c. Revisions to Lesson Plans EM 1038, EM 1039, EM l 1043, EM 1045, EM 1053, and EM 1054 will be completed on March 31, 1989.

2. As to the ARCA noted on page 226:

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a. The proposed revision'to SPMC,.IP 2.10.was' approved on August 18, 1988 and will be issued in the next amendment to the SPMC.. .

b.\ . Lesson Plan EM 1054 was; revised-and approved for.

use'on January 25, 1989.

.c. SeeLresponse 2.b to Interrogatory No. 2.

3. As>to the:ARCA noted on page 231:

Training;is scheduled for>MS-1 hospital staffs on June 9, 1989..

Interroaatorv No. 5

-For any and all steps. identified in response.to Interrogatories 1 and/or 2 [ sic] [should be 2 and/or 3]

please stateLthe name(s),and title / position of the persons (s) who' decided to take those steps and the name(s) and-title / position'ofLthe person (s) who has" implemented-or is expected to implement those steps.

ADolicants' ResDonse As to. Interrogatory'No. 2, step:

1. a. was' implemented by P. Capone, emergency planning consultant,-approved by M. Hawkins, Manager of

-i' Emergency Planning, and reviewed and approved by the Change Control Team (CCT) which consists of the Director of Emergency Preparedness, Manager of  !

l Performances Services, Manager of Response and.  !

Implementation, Manager of Resources and Facilities,' Manager of Community Relations, i

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I Specialty: Training Manager, and Manager of Emergency Planning.

1. b. was implemented by G. Catapano,' communications consultant,'and approved by P. Prugnarola, Manager of Computer Services of NHY.

2. a. was implemented by R. Thompson, Emergency Preparedness Training Supervisor, and approved by T. Grew, Specialty Training Manager.

2. b. The commitment and actions outlined in response to ,

, i Interrogatory No. 2 were recommended by management members of the NH Yankee Emergency Preparedness and the Community Relations Subdivision to its l Executive Director, G.R. Gram, who approved the commitment and the corrective actions. The I

corrective actions are being implemented by a team of NH Yankee and contracted personnel coordinated by J.A. Mcdonald. j As to Interrogatory No. 3, step: j

1. a. will be implemented by R. Thompson, Emergency Preparedness Training Supervisor, and approved by T. Grew, Specialty Training Manager.

1. b. will be implemented by G. Catapano, communications consultant, and approved by P. Prugnarola, Manager l i

of Computer Services, NHY. )

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2. a. was' implemented'hy D..Bovino, Supervisor of' Plans and Procedures, approved by M. Hawkins,-Manager of Emergency Planning, and reviewed,and' approved by l n  !

the CCT.: .

2. b.- See' response 2.b to Interrogatory _No. 2 above.

'3. willLbe implemented by R.: Thompson, Emergency Preparedness Training Supervisor, and approved by.

T. Grew, Specialty Training Manager, and S.J.1 H

'Ellis, Response and Implementation Manager.

Interrogatory No. 6 For'any and'all steps identified in response to Interrogatories 11and/or 2 [ sic] [should be 2'and/or 3],

please describe in detail the manner in which:those steps have been implemented or will.be implemented.

ADolicants' ResDonse As to Interrogatory No. 2, step:

1. 'a. The procedure revision was originated by an emergency planner and approved by the Manager of Emergency Planning and reviewed and approved by the CCT for incorporation into.the SPMC. The revision was incorporated into Amendment 6 of.the SPMC.

l The EMS radio unit was delivered to Edward L.

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Thompson & Son, Inc., Chelmsford, Massachusetts, on August 4, 1988 for repair, and returned to the staging area and placed into service on September 23, 1988.

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2. a. LThe implementation of the revisions to the training.

. materials'were done'in accordance with established- .l processes)for: training materials revisions. An assigned instructor in. conjunction with the Emergency Preparedness Training Supervisor produced new materials or revised previously' existing materials to reflect the needed changes as noted in.

Interrogatory 2. . The materials then were sent to

~ designated subject matter experts for review.

After comments from the subject matter experts were

' resolved, the Emergency Preparedness Training Supervisor and the Specialty Training Manager  !

reviewed and approved the materials. The revisions were completed prior to training in 1989. The' materials will be used during the 1989 training cycle. This assures that all responders have been trained on the revised materials. l Revision to the training materials for lesson plan '

EM 1020 will reflect emphasis in limiting radio use i I

to essential emergency communications. The j l

materials will be revised in a similar fashion to j the process described above.

2. b. See response 2.b to Interrogatory No. 2.

As to the Interrogatory No 3, steps; l

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1. . a. See response 2.a above.

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1. b. The radio frequencies' utilized by'new ambulance support companies-have been requested and will be reviewed by the NHY communications consultant, ,

G. Catapano, to determine compatibility with the existing system. j

2. a.- The procedure ~ revision'was originated by the-Supervisor of Plans and Procedures, approved by1the .

Manager'of Emergency Planning, and reviewed and approved by the CCT for incorporation in the next amendment of the SPMC.

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2. b. See response to 2.b toj Interrogatory.No. 2.

3. The training sessions for the MS-1 hospitals-are conducted periodically. The specific requirements for the issues stated in the ARCA of page 231 were compared with the content of previous programs.

The content of-the training was. observed to cover the necessary topics. In addition, the training group will provide input to the program to. explain to the participants that training on the biological effects of radiation and the terminology associated l l

with radiation has been identified as an area requiring corrective action.

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l Interroaatorv No. 7 For each and every ARCA noted by FEMA on pages 207, 226 y and 231 on the Exercise RepoIL, please state whether or not the Applicants acknowledges that the ARCA'S reflect inadequacies of performanac in the June, 1988 exercise of the Seabrook Plan for Massachuset.ts Communities.(SPMC).

h2plicants' Resoonse The FEMA Final Exercise Report of the Seabrook Nuclear Power Station, dated September 1, 1988, Appendix A, at page A-3, defines ARCAs as." Demonstrated and observed inadequacies of performance and although their correction is required, they are not considered, by themselves, to adversely impact public health and safety."

Interrocatorv No. 8 For each and every ARCA noted by FEMA on pages 207, 226 and 231 of the Exercise Report, if the Applicants maintain that the ARCA does not adversely impact public~hetith and safety, please state in detail the reasons,for and basis of that belief.

Acolicants' Resoonse Applicants incorporate herein their response to Interrogatory No. 7.

Interrogatory No. 9 Please identify by name(s), title / position and business address any and all individuals who were consulted in, or who otherwise contributed to, the answering to the above interrogatories.

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i Anolicants' Resoonsq

1. .D. Tailleart, Manager of Emergency Planning, New Hampshire Yankee - Seabrook Station.-

2. D.' Bovino, Supervisor of Plans and. Procedures, New.

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' Hampshire Yankee - Seabrook Station.

4. T.. Grew, Specialty Training Manager, New Hampshire i Yankee - Seabrook Station.

5. R. Thompson, Emergency Preparedness Training Supervisor, New Hampshire Yankee - Seabrook Station.

6. P. Prugnarola, Manager of Computer Services, New Hampshire Yankee - Seabrook Station.

7. J.A. MacDonald, Radiological Assessment Manager, New Hampshire Yankee - Seabrook Station.

8. G. Catapano, communications consultant, New Hampshire Yankee - Seabrook Station.

9. J. Baer, emergency planning consultant, New Hampshire Yankee - Seabrook Station.

Interrogatory No. 10 Please identify any and all documents that were consulted, referred to, or otherwise referenced in answering the above interrogatories by stating the author, date, title, addressee (s) and s.lbject matter of the document.

ADolicants' Resoonse

1. FEMA Exercise Report of the Seabrook Nuclear Power Station dated 9/1/88.

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L 2. Lesson Plan EM 1054, " Annual Update for Group 17"-(Route Guides), written by Ronald Thompson, Emergency Preparedness Training Supervisor. This lesson was developed for an audience of Route Guides only. The subject matter reviews the folloeing material with particular emphasis as it relates to Route Guides: FEMA ARCAs, Amendment 6 changes to plans and procedures, pending changes to plans and procedures, and the expected response of ORO members prior to a full power operating license.

3. CCT Package #293: Author: P. Capone Date: 7/8/89

Title:

N/A Addresses: N/A

Subject:

Directives to emergency workers.

4. CCT Package #316: Author: D. Bovino 1

Date: 8/18/89

Title:

N/A Addresses: N/A

Subject:

Instructions not to deviate from routes by Route Guides and Bus Drivers.

5. IP 2.8, SPMC, Amendment 6.

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Egeuest No. 1 Please produce any and all' documents that were identified in answer to Interrogatory #10.  !

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'ADolicants' ResDonse <

Applicants will produce the cocuments-identified.in Interrogatory No. 10 that hase'not already,been made f available to the parties.

Recuest No. 2 Please produce any and all documents that reflect, pertain to, or otherwise'were generated or received in connection with any stepr. identified in response to Interrogatories 1 and 2 [ sic] [should be 2 and 3].

ADolicants' ResDonse Applicants will produce the documents. identified in response to interrogatories Nos. 2 and 3 that have not already been made available to the parties.

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. MAR'24.89-15t08

. . . . . . .THY.E-PLAN

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F As to Answers

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Ted C. Feis p baum Vice-President - Engineering,-Quality ~

Programs and Licensing.

New Hampshire Yankee ~ Diviolon of ,.

Public Service Company of New Hampshire j _'

March 24, 1989 STATE OF NEW HAMP5 HIRE Rcchingham, ss.

Then appeared before me the above subscribed Ted C. Feigenbaum and made

. cath that he is the Vice-President - Engineering Quality P H:w Hampshire Yankee Division of Public service Company of New Hampshirerogr cuthorized to execute the foregoing responses to interrogatories on behalf of ,

the~ Applicants, and that he made inquiry and believes that ng the foregoi answers accurately set forth information as is available to the Applicants. .

Before me, JP>b b tu4 My CommisWion Expires Mac4h 6, 1990 i

1 As to objections and responses to request for production of documents:

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W/W ._ E/E r/ t' b Thomas G. Di George H. Lt. afd Xathryr. A. 8elleck -

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Jeffrey P. Trout Jay Bradford 9mith 6ecffrey C. Oook Ropes fr Gray one International Place ,

Boston, MA 02110 (617) 951-7000 Counsel for Applicants

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' M-CERTIFICATE OF SERVICE I, Geoffrey C. Cook, one of the attorneys for the *@ppppc}ptP 3 :55 l herein, hereby certify that on March 24, 1989, I made servLce of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or, where indicatedjyby.

f depositing in the United States mail, first class postade paid,. "

addressed to):

Administrative Judge Ivan W. Smith Administrative Judg6 Peter B.

Chairman, Atomic Safety and Bloch, Chairman, Atomic Licensing Board Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Administrative Judge Richard F. Cole Dr. Jerry Harbour Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board East West Towers Building U.S. Nuclear Regulatory 4350 East West Highway Commission Bethesda, MD 20814 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Kenneth A. Administrative Judge Emmoth A.

McCollom Luebke 1107 West Knapp Street 4515 Willard Avenue Stillwater, OK 74075 Chevy Chase, MD 20815 James H. Carpenter, Alternate Robert R. Pierce, Esquire Technical Member Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towerr Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20$14 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Offico of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Comnission 2ast West Towers Building One White Flint North, 15th F1.

4350 East West Highway 11555 Rockville Pike Betheuda, MD 20814 Rockville, MD 20852

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• Atomic' Safety'and Licensing. Robert A. Backus,' Esquire Appeal Board 116 Lowell Street U.S.' Nuclear Regulatory P. O. Box 516'

, Commission. Manchester, }nr '03105 Washington, DC 20555 Philip Ahrens, Esquire Mr. J. P. Nadeau  !

Assistant' Attorney General Selectmen's Office j Department,of the Attorney 10 Central Road j General Rye, NH .03870 l Augusta, ME 04333 Paul McEachern, Esquire John Traficonte, Esquire Shaines & McEachern Assistant' Attorney General

- 25 Maplewood Avenue Department of the Attorney. .

P.O. Box 360 General Portsmouth, NH 03801 One Ashburton Place, 19th Fl.

Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman,: Board of Selectmen City Manager  !

RFD 1.- Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

• Senator'Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton &

Washington, DC 20510 Rotondi (Attn: Tom Burack) 79 State Street Newburyport, MA 01950

• Senator Gordon J. Humphrey Leonard Kopelman, Esquire

. One Eagle Square, Suite 507 Kopelman & Paige, P.C.

Concord, NH 03301 77 Franklin Street (Attn: Herb Boynton) Boston, MA 02110 Mr. Thomas F. Powers e III Mr. William S. Lord  ;

Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.

Washington, DC 20472

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' Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH -03842 . Concord, NH 03301 Mr. Richard R. Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street, 2nd Floor Agency Newburyport, MA 01950 Federal Regional Center 130 228th Street,.S.W.

.Bothell, Washington 98021-9796 i

Ashod N. Amirian, Esquire Robert Carrigg, Chairman ,

145 South Main: Street Board of Selectmen P.O. Box 38 Town Office, Atlantic Avenue Bradford, MA 01835 North Hampton, NH 03862 Diane Curran, Esquire John P. Arnold, Esquire Andrea C. Ferster, Esquire Attorney General Harmon, Curran & Tousley George Dana Bisbee, Esquire Suite 430 Assistant Attorney General 2001 S Street, N.W. Office of the Attorney General Washington, DC 20009 25 Capitol Street Concord, NH 03301-6397 r- ,/ .

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(*= Ordinary U.S. First Class Mail) i

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