ML20235N182
| ML20235N182 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/21/1989 |
| From: | Flynn H Federal Emergency Management Agency |
| To: | HAMPTON, NH |
| Shared Package | |
| ML20235N172 | List: |
| References | |
| OL, NUDOCS 8903010085 | |
| Download: ML20235N182 (25) | |
Text
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February 21, 1989
'89 FE9 23 P 6 :28 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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EEFORE THE ATOMIC SAFETY AND LICENSING"B'OARD JUDGE IVAN W. EMITH, CHAIRMAN JUDGE RICHARD F. COLE JUDGE JERRY R. KLINE
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In the Matter of )
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Public Service Co. of New Hampshire, ) Docket No. 50-443-OL et al. ) 50-444-OL
) Offsite Emergency (Seabrook Station, Units 1 & 2) ) Planning Issues
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i FEDERAL EMERGENCY MANAGEMENT AGENCY'S RESPONSES TO TOWN OF HAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE FEDERAL EMERGENCY MANAGEMENT AGENCY ON THE JUNE 28-29, 1988 EXERCISE (" EXERCISE") f IJJTERROGATORY NO. 1:
Identify all teachers who performed or participated in protective actions for richool children during the Exercise. For each, state:
(a) The nature and extent of the participation or function performed; (b) The purpose of the performance or participation; (c) The school (s) for which each teacher performed or participated; (d) The section(s) of the NHRERP or SPMC tested or exercised; (e) Whether in PEMA's opinion the performance or participation was adequate, and the basis for that opinion; (f) Whether a log, record, or other documentation concerning the Exereire participation was prepared by or on behalf of each teacher; (g) Identify and produce all documents upon which you rely to answer this interrogatory.
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RESPONSE NO. 1:
The Federal Emergency Management Agency (FEMA) did not observe or evaluate the participation of school teachers in the exercise of offsite emergency response plans for-Seahrook Station held on June 28 and 29, 1988.
It was not the purpose of the exercise to evaluate their performance, FEMA considers schools and day care centers to be part of the general population who were not required to take part in the exercise. The extent of play for this exercise was agreed upon in advance by the States of New Hampshire and Maine, New Hampshire Yankee Offsite Response Organization (NHY ORO), FEMA, and the Nuclear Regulatory Commission (NRC) and was intended, in part, to demonstrate that the State of New Hampshire and the NHY ORO had the capability to notify schools of the existence of an emergency, to communicate protective action recommendations or decisions, to ascertain whether the schools or day care centers required assistance in the form of buses for their children, and to deliver that assistance when requested. The extent of play did not call for school children to be sheltered, boarded on buses or evacuated. Neither i l
did it call on school personnel to respond to exercise messages. The exercise {
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was designed, in part, to test the State's compensatory actions in the event l of noncooperation by schools.
l INTERROGATORY NO. 2:
- Identify all administrators and school personnel other than teachers who performed or participated in protective actions for school children during the Exercise. For each, state
(a) The nature and extent of the participation or function performed (b) The purpose of the performance or participation:
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FEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the June 1933 Exercise, Page 2.
(c) The school (s) for which each administrator and school personnel performed or participated; l
(d) The section(s) of the NHRERP or SPMC tested or exercised:
1 (e) Whether in FEMA's opinion the performance or participation was adequate, and the basis for that opinion; I (f) Whether a log, record, or other documentation concerning the Exercise participation was prepared by or on behalf of each teacher; (g) Identify and produce all documents upon which you rely to answer this interrogatory.
RESPONSE NO. 2:
For the reasons explained in Response No. 1, FEMA did not observe or evaluate the performance of school administrators or other school personnel in carrying out protective actions for school children.
INTERROGATORY NO. 3:
Identify all employees, agents, representatives, and contractors of the State of New ilampshire who, during the Exercise, performed or participated in protectr/e actions involving school children. For each, state:
(a) The nature and extent of the participation or function performed; (b) The purpose of the performance or participation; (c) The school (s) for which each administrator and school personnel performed or participated; (d) The section(s) of the NHRERP or SPMC tested or exercised; (e) Whether in FEMA's opinion the performance or participation was adequate, and the basis for that opinion; (f) Whether a log, record, or other documentation concerning the Exercise participation was prepared by or on behalf of each employee, agent, representative or contractor of the State of New Ilampshire.
(g) Identify and produce all documents upon which you rely to answer this interrogatory, i
FEMA's Response to Toll's First Set of Interrogatories and Request for Prodcution on the June 1983 E::ercise, Page 3.
a RESPONSE NO. 3:
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As noted in the Exercise Report, the extent of play of the exercise involved various officials of the State of New Hampshire performing or participating in protective actions regarding school children. These protective actions included the notification of school officials of instructions for effecting the sheltering and evacuation of school children and the mobilization and deployment of transportation resources to assist the I
evacuation of schools. As stated in the Exercise Report, pp. 172-82, among l l
these officials were the Governor, the Board of Education, Department of Education officials, Portsmouth officials, Brentwood officials, IFO Local i
Liaisons, Local Liaison Officers, the State Transportation Coordinator, and !
the Stage Staging Areas.
(a) As noted in the Exercise Report, the Governor decided not to recommend early dismissal of schools, and instead determined at Site Area Eme gency to hold children in school until 1700, as a precautionary PA. The Board of Education notified all appropriate school districts of this precautionary PA. As further noted in the Exercise Report, p.173, Portsmouth officials recommended early dismissal with the instruction to hold latch-key
, children at the schools until their parents could pick them up. Brentwood l
l officials directed the Swasey school to allow normal dismissal of school children. In towns not evacuating, Board of Education officials notified EPZ schools and potential host schools of the decision to extend late dismissal l
from 1700 to 1900 or until parents picked up their children. j In regard to transportation to effect the evacuation of school children, as stated in the Exercise Report at p. 173: j
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FEMA's Response to TCH's First Set of Interrogatories and Request for Prodcution i- on the June 1988 Exercise, Page 4.
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t h j The IFO Local Liaisons coordinated transportation resources to assist the evacuation of schools. For participating towns, the transportation requirements for m the schools were obtained from the Local Liaison Officers in each of the towns. For the non-participating towns, the transportation resource requirements for the schools were'obtained by the Local Liaison Officers in the IFO by direct contacts with the school themselves.
Transportation requirements were summarized and transmitted to the State (Transportation Coordinator).
Follow-up was done by obtaining information from the State-Staging Areas indicating when vehicles'were dispatched and !
when vehicle.s arrived at destinations, and when they departed. No significant delays or problems were observed in obtaining or dispatching resources.
b) The purpose of such performance or participation was to notify school
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i officials of the instructions for effecting the sheltering and evacuation of the school children in the various communities within the EPZ, and to mobilize (
l and deploy l transportation resources for the evacuation of the school children. '
(c) FEMA has no knowledge of the specific schools notified in the !
exercise, beyond that contained in the Exercise Report, pp. 172-182.
(d) The sections of NHRERP or SPMC tested or exercised are not I specifically referenced in the Exercise Report.
(e) In FEMA's opinion, the performance and participation of the New Hampshire officials was adequate, for the reasons stated in the discussion of Objective #19 in the Exercise Report, pp. 172-182.
(f) FEMA did not maintain a discrete log, record, or other documentation j concerning the Exercise participation with respect to each employee, agent, l representative or contractor of the State of New Hampshire.
l l (g) The document relied upon to answer this interrogatory is the Exercise Report.
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l FEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the June 1933 Exercise. Page 5.
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4 INTERROGATORY NO. 4:
Identify all employees, agents, representatives, and contractors of the Applicants, and all personnel not previously identified in answer to these interrogatories, who performed or participated in protective actions for school children during the Exercise. For each, state:
(a) The nature and extent of the participation or function performed; (b) The purpose of the performance or participation; (c) The school (s) for which each such employee, agent, representative or contractor of Applicants, and all personnel not previously identified in answer to these interrogatories performed or participated; (d) The section(s) of the NHRERP or SPMC tested or exercised; (e) Whether in FEMA's opinion the performance or participation was j adequace, and the basis for that opinion; (i) Whether a log, record, , other documentation concerning the Exercise participation was prepared by or on behalf of each employee, agent, representative or contractor of Applicants, and all personnel not previously identified in answer to these interrogatories; i (g) Identify and produce all documents upon which you rely to answer this interrogatory.
RESPONSE NO. 4:
For the reasons explained in Response No. 1, the extent of play for this exercise did not call upon NHY ORO to perform or participate in executing any 1
protective actions involving school children in the sense of sheltering or l evacuating them.
INTERROGATORY NO. 5:
For each school in the New Hampshire EPZ, identify all communications during the Exercise between teachers or other school personnel and the State of New llampshire, its agents or contractors, concerning protective actions for school children. With respect to each communication:
(a) Identify the person making the communication; FEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the June 1938 Exercice, Page 6.
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-(b) The method of communication; (c) Time; (d). Purpose; (e) Recipient; (f) Response; (g) Any actions taken as a result of the communications; and .
1 (h) Identify and produce all documents upon which you rely to answer this interrogatory.
RESPONSE NO. 5:
At various times during the exercise, FEMA observed that persons at the State Emergency Operations Center (EOC), Incident Field Office (IFO), and participating local government EOCs telephoned 49 schools and more than 100 l
day care centers and delivered exercise messages concerning the nature of the '
emergency and the recommended protective actions. Details of these telephone i
calls were not maintained as part of FEMT's official record. I INTERROGATORY NO. 6:
For each school in the New Hampshire EPZ, identify all communications during the Exercise between teachers or other school personnel and Applicants, its agents and contractors, and all personnel participating in the Exercise, and not previously identified in answer to these interrogatories. With ;
respect to each communication: '
(a) Identify the person making the communication; (b) The method of communication; (c) Time; (d) Purpose; (e) Recipient; l
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! FEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution j on the June 1953 Exercise, Page 7
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(f) Response; j (g) Any actions taken as a result of the communication; and (h) Identify and produce all documents upon which you rely to answer this interrogatory.
RESPONSE NO. 6:
At various times during the exercise, FEMA observed that School Liaisons at the NHY ORO Staging Area telephoned the ORO control cell, which played the role of nonparticipating schools and day care centers located in the Massachusetts portion of the Seabrook EPZ, and delivered exercise messages concerning the nature of the emergency and the recommended protective actions. Details of these telephone calls were not maintained as part of FEMA's official record.
INTERROGATORY NO. 7:
In FEMA's Exercise Report dated September 1, 1988, FEMA determined that the State of New Hampshire demonstrated the ability and resources necessary to implement protective actions for school children. With regard to this opinion:
(a) Identify each person who FEMA claims demonstrated the ability to implement appropriate protective actions for school children within the plume EPZ and the basis for that opinion; and (b) Identify and produce all documents upon which FEMA relies to answer this interrogatory.
REf90NSE NO. 7:
(a) The persons who FEMA claims demonstrated the ability to implement l appropriate protective actions for school children within the plume EPZ are i
those referred to in Response No. 3 above, and the transportation providers, local population, and Staging Area personnel referred to in the Exercise Report, pp. 173-81. '
FEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the' June 1988 Exercise, Page S.
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In the Exercise Report of September 1988, on page 256, FEMA did state the conclusion that the State of New Hampshire had demonstrated exercise objective 19, which was to " demonstrate the ability and resources necessary to implement appropriate Protective Actions for school children within the plume EPZ."
Objective 19 corresponds to evaluation criteria J.9. and J.10.g. of NUREG-0654/ FEMA-REP-1, Rev. 1.
The conclusion that these exercise objectives had been demonstrated was based, in turn, on the judgment that the State of New Hanipshire had demonstrated the capability to notify schools of the existence of an emergency, to communicate protective action recommendations or decisions, to ascertain whether the schools or day care centers required assistance in the form of buses for their children, and to deliver that assistance when 4 1
requested. See Verification of Corrective Actions, Exercise Report, App. B.,
B-10.
(b) The document which supports FEMA's conclusion is the Exercise Report which has already been served on the parties.
UlTERROGATORY NO. 8:
Identify and produce a current set of FEMA Guidance Memoranda presently used by FEMA to evaluate radiological emergency plans, and exercises testing those plans.
RESPONSE NO. 8:
A current set of FSMA's guidance memoranda has already been supplied to the Seabreak service list. !
FEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the June 1988 Exercise, Page 3.
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INTERROGATORY NO. 9:
State whether FEMA regulations, Guidance Memoranda, or other criteria used by FEMA for the evaluation of an exercise of a radiological emergency response plan have changed in form, substance, or practice, from that used by FEMA to evaluate the February, 1986 exercise of Seabrook Station and that used by FEMA to evaluate the June, 1998 emergency exercise. If yes, identify each change, the purpose of the change, and the effect on FEMA's review and-evaluation of an exercise.
RESPONSE NO. 9:
Guidance Memorandum EX-3 is a revision, written since February 1986, of earlier. guidance on the conducting of exercises. The substance of the revision is to reflect operational experience gained over a number of years of j evaluating exercises. Guidance Memorandum IN-1, on the subject of ingestion pathway exercises, is new since February 1986. Both of these memoranda have already been provided to counsel for the Town of Hampton.
INTERROGATORY NO. 10:
For any :equested document or part of a document that was at one time, but is no longer in your possession, custody or control, or which is no longer in existence, or which cannot be located or produced, identify the document, state where and how it passed out of existence or why it can no longer be located and the reasons therefor, and identify each person having knowledge concerning such disposition or loss and d.he contents of the document, and identify each document evidencing its prior existence and/or any fact concerning its nonexistence or loss.
RESPONSE NO. 10:
The documents requested by the Town of Hampton in this request would include exercise evaluator forms, logs, and narrative reports which were completed by exercise evaluation teams and turned in to the RAC Chairman at the close of the e:<ercise. The circumstances of the discarding of the original documents have been explained by Richard Donovan at a deposition FEMA's Response to TCH's First Set of p Interrogatories and Request for Prodcution on the June 1988 Exercise. Page 10.
taken by the Office of the' Attorney General of Massachusetts. FEMA presumes that a copy of the transcript is available to the Town of Hampton. The explanation offered by Mr. Donovan has also been summarized by counsel for FEMA, on'the record of conferences in this litigation, on at least two occasions when counsel for the Town of Hampton participated.
INTERROGATORY NO. 11:
In its exercise report dated September 1, 1988, FEMA determined that the State of New Hampshire demonstrated the ability and resources to implement appropriate protective actions for impacted permanent and transient plume EPZ population (including transit dependent persons, special needs populations, [
handicapped persons and institutionalized persons). With regard to this '
opinion state:
(a) The number of buses and drivers necessary to implement the NHRERP for these populations in an actual emergency at Seabrook Station; (b) The number of buses and drivers for these populations who participated in the June, 1988 Exercise:
(c) The number of bus companies that FEMA believes will make transportation resources available in an actual emergency at Seabrook Station, and the number of buses that FEMA believes will be made available from each company; (d) The identity and number of bus companies who actually provided buses for use in the June, 1988 Exercise, and the number of buses actually f provided by each company; f
[ (e) The number of ambulances and drivers who FEMA believes are necessary to implement the NHRERP in an actual emergency at Seabrook Station; (f) The identity and number of ambulances and drivers who actually j participated in the June, 1988 Exercise:
(g) The number of special needs buses and drivers that FEMA i believes is necessary to implement the NHRERP in an actual emergency at Seabrook Station; (h) The identity and number of special needs buses and drivers who actually participated in the June, 1988 Exercire on the NHRERp.
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l FEMA's Response to TOH's First Set of l Interrogatories and Request for Prodcution on the June 1988 Exercise, Page 11.
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y' RESPONSE NO. 11:
(a) The number of buses and drivers necessary to implement the NHRERP (New Hampshire Radiological Emergency Response Plan) is the number stated in the plan itself.
i (b) During the 1988 exercise, 20 buses, 1 ambulance, and 1 wheel chair van, with drivers, were supplied by companies with whom the State of New' Hampshire has letters of agreement. The identities of the particular companies responding at the time of the exercise were not reported to FEMA.
In the case of one of the buses participating in the exercise, at two separate [
special facilities, the bus was converted to a special needs bus by the i
installation of a conversion kit which had been stored at the special facility and which was later removed when the demonstration was completed. The ;
identity of the particular bus company involved was not reported to FEMA. In ,
addition, 23 drivers from the State's supplemental pool'of drivers drove their private vehicles to simulate the running of bus routes. It should be noted that the extent of play did not call for all of the buses or drivers l identified in the plan to be mobilized. A sample was selected. I (c) FEMA believes that the number of bus companies which will make transportation resources available in an actual emergency is that which is reflected in the NHRERP. FEMA believes that the number of buses that those companies will make available in the event of an actual emergency is that which is stated in the NHRERP.
(d) FEMA did not maintain a record of the identities of the particular I
companies responding at the time of the exercise.
FEMA's Response to TOH'c First Set of Interrogatories and Request for Prodcution on the June 1988 Exercise, Page 12.
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I (e) The number of am.'y21ances and drivers necessary to implement the NHRERP is the number statec in the plan itself. ;
(f) During the 1988 exercise, 20 buses, 1 ambulance, and 1, wheel chair van, with drivers, were supplied by companies with whom the State of New Hampshire has letters of agreement. FEMA did not maintain a record of the ,
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identities of the particular companies responding at the time of the '
exercise. In addition, 23 drivers from the State's supplemental pool of drivers drove their private vehicles to simulate the running of bus routes. j l
It should be noted that the extent of play did not call for all of the buses or drivers identified in the plan to be mobilized. A sample was selected.
(g) The number of special needs buses and drivers necessary to implement the NHRERP is the number stated in the plan itself.
(h) In the case of one of the buses participating in the exercise, at !
two separate special facilities, the bus was converted to a special needs bus by the installation of a conversion kit which had been stored at the special facility and which was later removed when the demonstration was completed.
The identity of the particular bus company involved was not reported to FEMA.
l INTERROGATORY NO. 12:
In its exercise report dated September 1, 1988, FEMA states that "the State identified vehicles through its suppliers that were sufficient to evacuate the special population in the plume EPZ." p. 165. Concerning that opinion:
(a) Identify the process by which the State " identified vehicles" sufficient to evacuate the special population; (b) Identify each vehicle driver actually contactod by the State of New Hampshire, its agents or contractors, during the Exercie,e for the purpose of identifying vehicles sufficient to evacuate special needs populations:
PEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the June 1988 Exercise, Page 13.
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.(c) For each vehicle driver identified in the preceding answer, l identify:
(i) .The person making the communication to the vehicle driver; (ii) The method of communication; (iii) Time; (iv) Purpose; (v) Recipient; ;
(vi) Response; (vii) Any actions taken as a result of the communication; and (viii) Identify and produce all documents upon which you rely to answer this interrogatory.
(d) Identify all other actions undertaken by the State, not already provided in the answer to this interrogatory, that FEMA claims support its opinion that the State identified sufficient vehicles to evacuate special needs populations.
RESPONSE NO. 12: I (a) The process of identifying the number of buses sufficient to. i evacuate special populations in the EPZ has two principal parts. The first involves identifying the magnitude of the need. This involves comparing the-NHRERP and the record of special populations (including transit-dependent i
individuals) with the scope of the protective action decision to evacuate.
1 This identifies the number and location of people requiring transportation. ]
i The second part of the process involves identifying the number of buses and 1
drivers available at the time of the (simulated) evacuation. The State of New I Hampshire did this by contacting companies with which it has letters of agreement and ascertaining how many buses and drivers were available at the j time of the call. These calls were made at several different times during the I
exercise.
- EMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the June 1988 Exercise, Page 14.
4 8 (b) The State of New Hampshire contacted companies, not their individual drivers. The identities of the particular companies responding at the time of the exercise were not reported to FEMA. In addition, it contacted 23 drivers from its supplemental driver pool. The identities of individual drivers were- I not reported to FEMA.
l (c) The information requested in Interrogatory 12(c) is not available to- j l
FEMA since the identities of individual drivers were not reported to FEMA. J However, FEMA did observe that numerous telephone calls to transportation suppliers were made from the New Hampshire EOC and IFO at various times which I are reflected in the Significant Events Log in the Exercise Report.
(d) The information on which FEMA relied to support its opinion that the l
State of New Hampshire identified sufficient vehicles to evacuate special needs populations is reflected in its Exercise Report.
INTERROGATORY NO. 13:
In FEMA's exercise report dated September 1, 1988, FEMA states:
Number required Number available (at 1420) (at 1424) i Buses 304 750 Vans 14 95 I Ambulances 33 34 W/C Vans 21 32 '
Special Needs 17 *
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Coach buses 5 55
- would come from bus category using conversion kits With respect to this information, for each category of transportation l referenced above, identify how FEMA determined the number of vehicles l required, as of 1420, and how FEMA determined the number available vehicles at l 1424.
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FEMA's Response to TOH's First Set of .
Interrogatories and Request for Prodcution i on the June 1983 Exercise, Page 15.
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RESPONSE NO. 13:
See Response No. 12(a).
INTERROGATORY NO. 14:
With respect to traffic control in the New Hampshire EPZ, identify:
(a) The total number of traffic control guides necessary to implement the NHRERP in an actual emergency at Seabrook Station; (b) The number of traffic control guides who participated in the June, 1988 Exercise and the function each performed; (c) The total number of access control guides necessary to implement the NHRERP in an actual emergency at Seabrook Station; 'I (d) The number of access control guides who participated in the June, 1988 Exercise and the function each performed. l l
RESPONSE NO. 14:
(a) The number of traffic control guides necessary to implement the !
NHRERP is the number stated in the plan itself.
(b) The State of New Hampshire deployed guides and other necessary personnel to 2 traffic control 'po'ints and 2 access control points.
Participating local governments deployed guides and other necessary personnel to 13 traffic control points. The guides did not perform functions such as directing traffic since that would inconvenience the public. Furthermore, the extent of play required only that a sample number of guides go to the appropriate locations and that other personnel deliver to those locations the equipment necessary to establish the traffic or access control points.
(c) The number of access control guides necessary to implement the NHRERP is the number stated in the plan itself.
(d) See Response 14(b).
PEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the June 1938 Exercise, Page 16.
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. ;l INTERROGATORY NO. 15:
In its exercise report dated September 1, 1988, FEMA determined that the State of New Hampshire demonstrated the organizational ability and resources necessary to control evacuation traffic flow and control access to evacuated and sheltered areas. With respect to this opinion, identify:
(a) The procedures employed by the State Police liaison to arrange for 25 officers, at 1037, to handle beach closing:
'(b) The meaning of the phrase " handle beach closing";
(c) The number of officers actually contacted and participating in such beach closing; (d) What procedures FEMA employed to demonstrate or confirm the accuracy of this assertion; (e) The procedures employed by FEMA to demonstrate or confirm that, as of 1530, all traffic control points required to implement FM PA #3, requiring a total of 89 troopers, were staffed; (f) The meaning of "NH PA #3".
RESPONSE NO 15:
(a) The New Hampshire EOC communicated the decisic.n to close the New i Hampshire beaches to the IFO, which in turn communicated with State Police Troop A. Troop A identified 25 Troopers and vehicle numbers and gave their ,
estimated times of arrival at access control points. Troop A then contacted !
those Troopers by radio and gave them an exercise message that they would be dispatched to specific access control points.
(b) The phrase " handle beach closing" in this context means a demonstration of the State's capability to deliver notice of the beach closing decision to State Troopers and direct them to travel to their assigned access control points and, once there, to direct traffic away from the beaches. This was done by delivering exercise messages to the number of State Troopers called for by the exercise scenario and the extent of play. The extent of play did not require Troopers actually to travel to access control points.
FEMA's Response to TCH's First Set of Interrogatories and Request for Prodcution on the June 1988 Exercise, Page 17.
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- j. (c) See Response 15(a).
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(d) FEMA observed roll call and delivery of the exercise message to State Troopers by Troop A.
(e) The State of New Hampshire produced and furnished to Troop A a roster of State Troopers and vehicle numbers from other troops who were available for backup, together with estimates of their arrival times. When Eni PA 43 was adopted, the IFO requested additional TCPs. The State Trooper at-the IFO passed this request on to Troop A who contacted the required number of Troopers, by radio, and delivered an exercise message that they would be directed to go to specific traffic control points.
(f) "NH PA #3" refers to New Hampshire Protective Action Dec e 9a No. 3, t
which was to evacuate ERPAs A, C, and D and to shelter persons located from 5 to 10 miles from the plant.
INTERROGATORY NO. 16: I With respect to each contention and basis admitted by the Licensing Board regarding the Exercise, please provide the following information:
-(a) What is FEMA's position with respect to each contention and basis? For each, identify the reasons for your position; (b) If FEMA has not yet taken a position on any contention or basis, identify the information which must be provided, and/or the conditions or contingencies which must be satisfied, before FEMA may take a position; (c) Identify all persons you may call as witnesses; the particular contention or basis on which each will testify; the subject matter on which each witness will testify; the substance of each witnesses' testimony; the grounds for each opinion or testimony; and identify and produce any documents, indicating the relevant portion and citation, that each witness will rely upon to support his testimony, and any documents PEMA will offer into evidence through each witness; FEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the June 1968 Exercise, Page 13.
(d) Identify all persons on whose factual knowledge, opinion, or technical expertise you rely for your position on each contention and basis. )
For each person, state the. substance of the knowledge, opinions, or technical j expertise that FEMA relies on. I RESPONSE NO. 16:
(a) FEMA has not taken a position on each and every contention and basis for the reasons explained below in Response No. 16(b). To the extent that FEMA has developed a position, it is stated in the Review and Evaluation of ,l the Seabrook Plan for Massachusetts Communities, transmitted to the Nuclear Regulatory Commission (NRC) on December 14, 1988, and the Seabrook Exercise i
Report, transmitted to the NRC on September 2, 1988.
(b) FEMA has not taken positions on some of the contentions, although it .
is not for lack of information. Under the Memorandum of Understanding between )
FEMA and NRC, FEMA's role in the licensing process is to communicate its findings on offsite emergency plan reviews and exercise evaluations to NRC Staff and to defend those findings in the hearings, if necessary. In some l l
cases, FEMA has not taken a position on contentions because they raise matters not within the scope of FEMA's evaluation process. In other cases, FEMA has not taken a position because the contentions raise legal issues such as the !
I legal authority of the MN ORO or the validity of the " realism assumptions" '
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FEMA does not anticipate taking a position on those matters.
(c) FEMA intends to call Richard W. Donovan as its only witness. In summar), his testimony will be to the effect that the reports referred to in i
Response No. 16(a) reflect official FEMA positions arrived at in the regular course of FEMA activities and that the conclusions stated therein are well founded.
FEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the June 1988 Exercise, Page 19.
l (d) To the extent that FEMA has taken positions on contentions and bases, it has relied on the factual knowledge, opinion, or technical expertise of Richard W. Donovan, Joseph H. Keller of Idaho National Engineering Laboratory, Edward A. Tanzman of Argonne National Laboratory. In each case, their expertise is in the area of evaluation of offsite emergency. response plans and exercises thereof. FEMA also relied on the factual observations of approximately 150 exercise evaluators who are identified in the Exercise Report. Their observations are sunmarized in the Significant Event Log which appears in the Exercise Report as Table 3, beginning at page 38.
INTERROGATORY NO 17:
Please identify and produce all documents that FEMA, or its agents or contractors, has authored or compiled, and that discuss the Exercise, or any of the contentions or bases admitted for litigation by the Licensing Board on the Exercise.
RESPONSE NO. 17:
Neither FEMA nor its agents or contractors produced any documents addressing the exercise, the exercise contentions, or their bases, other than the Exercise Report transmitted to NRC on September 2,1988, FEMA'S Consolidated Findings transmitted to NRC on December 14, 1988, or pleadings.
which are already part of the record of this case.
INTERROGATORY NO 18:
Identify and produce all documents (1) on which you rely to answer these interrogatories or (2) which you intend to offer as exhibits in this proceeding for any purpose.
FEMA's Response to TOH's First Set of Interrogatories and Request for Prodcution on the June 1988 Exercise, Page 20.
RESPONSE NO. 18:
In answering the Town of Hampton's Interrogatories and Requests for Production, FEMA relied on the September 1988 Exercise Report, which will be offered as part of its prefiled testimony or as an exhibit, and on NUREG-0654/ FEMA-REP-1, Rev. 1. and which will not be offered as an exhibit.
Both of these documents are already available to the Town of Hampton.
The information provided in the foregoing responses was verified or [-
supplied in the first instance by Richard W. Donovan, the FEMA official with the most direct knowledge of the matters contained therein. The undersigned represents that the information is true to his knowledge.
Respectfully submitted,
/ /
H.(,70SEpf FLYNN[
Assistant General Counsel ,,
Federal Emergency Management Agency ,
500 C Street, S.W.
Washington, D.C. 20472 , f Telephone (703) 646-4102 -
i
? - s A
r tf s i
FEMA's Response to TOH'c First Set of Interrogatories and Request for Prodcution on the June 1988 Exercice, Page 21. .
3, 1 - e. .
E i l l 00EKEiED i UsNEC l'
February 21, 1989
'R) FEB 23 P6 :28 UNITED STATES OF AMERICA f,h gt , , q p , : ,t NUCLEAR REGULATORY COMMISSION UF ^?iO4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD JUDGE IVAN W. SMITH, CHAIRMAN JUDGE JERRY HARBOUR JUDGE GUSTAVE A. LINENBERGER, JR.
)
In the Matter of )
)
Public Service Co. of New IIampshire, ) Docket No. 50-443-OL et al. ) 50-444-OL
) Offsite Emergency (Seabrook Station, Units 1 & 2) ) Planning Issues
)
)
CERTIFICATE OF SERVICE I hereby certify that I served copies of the foregoing RESPONSE OF THE FEDERAL EMERGDJCY MANAGEMENT AGENCY (FEMA) TO THE SEACOAST ANTI-POLLUTION LEAGUE'S REQUEST FOR ADMISSION TO FEMA REGARDING GRADED EXERCISE ISSUES and FEDERAL EMERGENCY MANAGEMENT AGENCY'S RESPONSES TO TOWN OF HAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE FEDERAL EMERGENCY MANAGEMENT AGENCY ON THE JUNE 28-29, 1988 EXERCISE (" EXERCISE") on the persons listed below by depositing said documents with the U.S. Postal !
Service on this 21st day of February, 1989.
Ivan W. Smith, Esq., Chairman Atomic Safety and Licensing Board Nuclear Regulatory Commission Bethesda, Maryland 20555 Dr. Jerry Harbour Administrative Judge Atomic Safety and Licensing Board Nuclear Regulatory Commission Bethesda, Maryland 20555
9 Gustave A. Linenberger, Jr.
Administrative Judge
.. Atomic Safety and Licensing Board 3 Nuclear Regulatory Commission Bethesda, Maryland 20555 Robert R. Pierce, Esq.
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ]
Docketing and Service Section Office of the Secretary Nuclear Regulatory Commission Bethesda, Maryland 20555-Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l
Thomas G. Dignan, Jr., Esq. j Ropes & Gray i 225 Franklin Street Boston, MA 02110 Carol S. Snieder Assistar.t Attorney General Office of the Attorney General {
One Ashburton Place, 19th Floor Boston, MA 02108 Dianne Curran, Esq.
Harmon, Curran & Tousley i
2001 S Street, N.W.
Suite 430 I Washington, D.C. 20009 Robert A. Backus, Esq.
Backus, Meyer & Solomon 116 Lowell Street Manchester, NH 03106 Matthew T. Brock, Esq.
Shaines & McCachern Post Office Box 360 Portsmouth, Nil 03801 m_%._m.m__--_ __..__m -_ _ _ _ _ _ _ _ . _ _ _ _ _
l
+ i m
Barbara St. Andre,- Esq. !
Kopelman & Paige. l 77 Franklin Street !
Boston, MA'02110.
R. Scott Hill-Whilton, Esq.
Lagoulis, Clark,' Hill-Whilton
& McGuire >
.79 State Street. '
Newburyport, MA 01950 Ashod N. Amirian, Esq. j
-Town Counsel for Merrimac 376 Main Street ;
Haverhil, MA 08130 l
Gary W. Holmes, Esq. l Holmes & Ellis 47 Winnacunnet Road Hampton, NH 03842 ,
.J.P. Nadeau, Esq.
Selectmen's Representative Board of Selectmen 10 Central Road Rye, NH03870 Charles P. Graham, Esq.
Murphy and Graham 33 Low Street Newburyport, MA 01950 j Richard A. Hampe, Esq.
Hampe and McNichols '
35 Pleasant Street Concord, NH 03301
. Philip Ahrens Assistant Attorney General Office of the Attorney General State House Station, #6 Augusta, ME 04333 Geoffrey Huntington Assistant Attorney General 25 Capitol Street Concord NH 03301-6397 Sherwin E. Turk, Esq.
Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
h
'p..,.-
tt 191l h i
! 5 Jane Doughty l' Seacoast Anti-Pollution League 5 Market Street Portsmouth, NH 03801 William S. Lord Board of Selectmen Town Hall - Friend Street Amesbury, MA 01913 Sandra Gavutis, Chairman
. Board of Selectmen RFD 1, Box 1154 Route 107 Kensington, NH'03827 Allen Lampert Civil Defense Director Town of Brentwood 20 Franklin Street Exeter, NH 03833 Angie Machiros, Chairman Board of Selectmen 25 High Road Newbury, MA 01950 Jerard A. Croteau, Constable 82 Beach Road P.O. Box 5501 l Salisbury, MA 01950 I Michael Santosuosso, Chairman Board of Selectmen South Hampton, NH 01913 Calvin A. Canney, City Manager o City Hall 126 Daniel Street Portsmouth, NH 03801 Mr. Robert Carrigg, Chairman Board of Selectmen Town Office Atlantic Avenue North Hampton, Nil 03862 William Armstrong Civil Defense Director Town of Exeter 10 Front Street Exeter, Nil 03833 l
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