ML20065T955
| ML20065T955 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/10/1990 |
| From: | Trout J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | MASSACHUSETTS, COMMONWEALTH OF |
| References | |
| CON-#490-11181 OL, NUDOCS 9012310243 | |
| Download: ML20065T955 (29) | |
Text
.. _ _ - _ -
- " H/f/
RR ED 00ssesiG;0EWOf Filed DecemberC % @b90 i
[
UNITED STATES OF AMERICA 90 DEC 11 P6 30 l
NUCLEAR REGULATORY COMMISSION
- n
.3 o r y j.
before tho ATOMIC SAFETY AND LICENSING BOARD I
L
)
In the Matter of
)
)
PUBLIC SERVICE COMPAN'i 0F
)
Doakot Hon. 50-443-OL NEW IIAMPSilIRE, et al.
)
50-444-OL
)
Off-sito Emorgency
.(Seabrook Station,. Units 1 and 2)
)
Planning Issuco
=)
)
l LICENSEES' FIRST DET OF INTERH00ATORIES AND= FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO T!!E MASS AG REGARDING REMANDED MASSACl!USETTS TEACHER ISSUES Pursuant - to 10 C. F. R. - 6 6 2. */4 0b and 2. 741, Licensees I
hereby request that the Attorney conoral for The Commonwealth Jof Massachusotto respond to the following interrogatorios'and produco-for inopoction and copying tho. documents requestod.
h
'below.
The production'of the documents requestod horoin shall take place at-the officos of Ropos & Gray,-One l
International Place, Bot. on, Massachusetts at 10 a.m. on Friday, January 11, 1991.
l; DEFINITIONS AND INSTRUCTIONS 11.
The term " document" is defined to be synonymous in meaning and equal in scope to the usage of tho torm
" documents and tangible things" in Fodoral Rulo-of Civil 9012310D43 901210 A
PDR ADOCK 05000443 h()())
G YDR J
Proceduro 34(a), and therefore chall includo, without limitation, any written or otherwise recorded in f o rmation.
2.
To " identify" a document means to stato its author, dato, title, addressee (s), and subject matter.
3.
To " identify" a porcon other than an export witness means to stato the porcon's full name, title, businoso address, affiliation, and professional qualifications (if any).
To " identify" an export witness means to stato, in addition to the forogoing:
the protossion or occupation and field (s) of a.
expertico of the person;
- b. the educational and cpocialized training hictory of the person, including dato and granting institution of all degroes carned; a lict of publications by the porcon in the aron (o) c.
of expertico; and
- d. the age of the person and the amount of timo the person has worked in the field of exportico.
4.
If any of the interrogatories or document production requests contained herein are claimed to be objectionable, then please identify the portion (c) to which objection ic mado and the portion (s) to which answer or production is mado.
1 5.
If it is claimed that any document responsivo to any request is privileged, then pleauo describo in dotail the nature of and basis for the assented privilogo, and j
identify each allegedly privileged document.
6.
If any document required to be identified or produced in those answers has boon destroyed, please identify the document, stato the date of its destruction, identify the person responsible for ordoring destruction, stato tho' purpose of destruction, and (if applicable) produco any document rotontion policy that governed or should have governed the rotontion or doctruction of the 2
document.
7.
For the purposes of those intorJogatories and roquestst "SPMC" means the most curront version of the Scabrook a.
i Plan for Massachusetts Communities, and all appendicos and attachments thoroto;
- b. "NHY-OR0" means the flow Hampshiro Yankoo Of f-sito Responso Organization; "Massachusotts EPZ" refers to that portion of the c.
Emergoney Planning Znno for Scabrook Station which lies within the Commonwealth of Massachusetts;
- d. " Holy Cross Ops Plan" means the Holy Cross Host Facility Activation and Operation plan, dated 12/26/89, Attachment C to the October 19, 1990 Affidavit of Anthony M. Callendrollot i
l.
e.
" School Host racility Plan" means the Massachucetto School Host racility Plan, College of the Holy Cross, Worcester, Mascachusetts, dated 10/2/89, Attachment D to tho October 19, 1990 Affidavit of Anthony M.
Callendrello;
- f. "Maco AG" refore to the Attorney General for The Commonwealth of Massachusotto, all assistanto to and employeco and agents thereof, all witnceses efforod or to be offered thereby in these proceedings, and all individuals and entitics with respect to which the Attornoy General for The Commonwealth of Mac.achucoto claims an attorney-client privilogo with respect to litigation of the incues remanded in ALAD-937;
- g. " Teachers" means all public school perconnel, privato school porconnel, and day care providorc;
- h. " Schools" means all public schools, private schools, and day cere facilitics;
- i. "The Commonwealth" means the commonwealth of Massachusetta and all officials, agencios, employcos, agents, and political cubdivisions thorcof; and
- j. " SARA" means the Emergency Planning and Community Right to Know Act of 1986, 42 U.S.C.
SS 11001 91 gig., and all federal, state, and local regulations, orders, and guidelines promulgated pursuant thereto.
4
l INTERROGATORIES %ND DOCUMENT REQUESTD 1.
Please identify the person (s) an
'dng or substantially contributing to the answer of each of the following interrogatorios, and produce a copy of each person's most recent resumo.
Z.
Please identify all analysos, surveys, studios and reports known or believed by Mass AG to exist (including, but not limitou to, all rossesbed by The Commonwealth) as to how Teachers employed in the Massachusotta EPZ would respond in the ovent of a radiological amorgency at Seabrook station, and produce all such documents within the possession or control of Mass AG.
3.
Please identify all analysos, surveys, studios and reports known or believed by Mass AG to exist (including, but not limited to, all possessed by The Commonwealth) as to how Teachers employed in the Massachusetts EPZ would respond to an emergency requiring ovacuation of their School, and produce all such documents within the possession or control of Mass AG other than those produced in response to the foregoing request.
4.
Please identify all analyses, surveys, studios and reports known or believed by Mass AG to exist i
.~
(including, but not limited to, all possossed by The Commonwealth) as to how Massachusetts Teachers would respond to a radiological emergency, and produce all s
such documents within the possession or control of Mass i
AG other than those produced in response to the foregoing requests.
5.
Please identify all analyson, surveys, studios and reports known or believed by Mass AG to exist (including, but not limited to, all possessed by The Commonwoalth) as to how Massachuse*,ts Teachers would respond to an emergency requiring evacuation of their School, and produce all such documents within the possession or control of Mass AG other than those produced in response to the forogoing requests.
6.
Pleaso identify all analyses, su rveys, studios and reports known or believed by. Mass AG to exist (including, but not limited to, all possessed by The Commonwealth) as to how Teachers have rosponded to radiological omergencias, and produce all such documents within the possession or control of Mass AG other than those produced in response to the foregoing requests.
7.
Pleano identify all analyses, surveys, studios and reports known or believed by Mass AG to exist (including, but not limited to, all possessed by The Commonwealth) as to how Teachers would respond to a l
l' i
l,
t radiological emergency, and produco all such documents within the possession or control of Mass AG other than those produced in response to the forogoing requests.
8.
Please identify all analysos, surveys studios and reports possessed known or believed by Mass AG to exist (including, but not limited to, all by The Commonwealth) as to how Teachers have responded to omer'joncies requiring ovacuation of their School, and produco all such documents within the possession or control of Mass AG other than those produced in response to the forogoing requests.
9.
Please identify all analycos, su rvoys, studios and reports possessed known or balloved by Mass AG to exist (including, but not limited to, all by The Commonwealth) as to how Teachers would recpond to an omorgency requiring ovacuation of their School, and produce all such documents within the possession or control of Mata AG other than those produced in response to the forogoing requests.
10.
Pleano identify and produco the most recent SARA plans for Amesbury, Morrimac, Newbury, Newburyport, Salisbury, and West Howbury, 11.
Does the Mass AG contend that any municipality located in the Massachusotts EPZ is not in complianco with the requirements of SARA as they relato to omorgency., -
w ls 4
planning--for: Schools.and school children?
If your answer.is~anything other thant.antunqualified negative,.
d L
1 then please identify each such municipality which Mass LAG-centends is not or may not'be=in compliance,-andi_
(a)-
_ State each fact on which your answer is based.
(b)
Identify and produce each-document which you
!l contend reflects or supports your answer.
(c)
Provide the. technical qualifications (education,
-employment history, licenses'and certificates, experience, or_other information that Mass AG-contends establishes the qualifications of the-1 person) of any person on whose expertise-Mass AG-relies:for the answer, or-state that Mass AG t
does not rely.upon the expertise of any person' fct the answer.
- 12. -Does:the Mass AG contend that any School located in the Massachusetts.EPZ is not in compliance with the
-responsibilities assigned toEit by_ local SARA plans?f
~I f I
your'answercis'anythir) other.than an; unqualified y
- egative,Lthen pleast identify each:such-School-which Mass AG contends is notoor.may notobe in1 compliance,
'a nd ::
'(a):
Sta'te each fact on which your answer is based.
(b):
Identify and produce each document which-you1 contend reflects or supports your answer..,, _
~
i (c)
Provide the technical qualifications (education, employment history, licenses and certificates, experience,-or other information that Mass AG contends establishes the qualifications of the person) of any person on whose expertise Mass AG relies for the answer, or state that Mass AG does not rely upon the expertise of any person for tne answer.
13.
Does the Mass AG contend that any School located in the Massachusetts EPZ would not, in the event of an emergency requiring evacuation of the School, comply with the responsibilities assigned to it and its personnel by local SARA plans?
If your answer is anything other than an unqualified negative, then please identify each such Sci.ool which Mass AG contends would not or may not comply, and:
(a)
State each fact on which your answer is based.
(b)
Identify and' produce each document which you contend reflects or supports your answer.
(c)
Provide the technical qualifications-(education, employment history, licenses and certificates,.
experience, or other information that Mass AG contendo establishes the qualifications of the person) of any person on whose expertise Mass AG relies for the answer, or state that Mass AG
-9
.' k s
'does not rely'upon the expertise of any person for-the: answer.-
14.. :Please identify:and: produce all smergency plans for-Massachusetts EPZ-Schools.
i 15.
Please identifyf_and produco-all regulations,- executive ordersjfpolicy statements, guidelines, and other 4
.svandards established by-The Commonwealth which reflect ~
1 s
I or relate to the responsibilities of Teachers in the I
event-ofiafradiol'ogical emergency.
16.. JPlease" identify' all regulatic ns, executive orders, i
policy statements, guidelines, and other' standards-3 established-by The Commonwealth which reflect;or relato to the,responsibil'ities of Toachers in-the-event of an-3 emergency atitheirischool,cand produce all such i
-documents other than those produced in response-to the Lf oregoing : roquest. >
17.
Does the' Mass AG contend that any. day care facilityf
- within
- the Massachusetts-EPZ would not, in<the eventvof
-i JaLradiological emergency at Seabrookistation,; comply 7
with '.the ' requirements: of 102 ~CMR15 7.06(29) (b) ? -If -your a
answer is anything other.than an. unqualified negative, i
-then please, identify each such facilityLwhich Mass-AG contends would not'or may not comply,'and:
(a)
I' state each' fact on which your answer is based.-
(b)
Identify ano produce each document which you l
-contend reflects or supports your answer.
I I
(c)
Provide the technical qualifications (education, employment history, licenses and cortificatos, experience, or other information that Mass AG contends establishes the qualifications of the person) of any person on whose exportino Mass AG relics for the answer, or stato that Mass AG does not rely upon the expertise of any person for the answer.
18.
Does the Mass AG contend that any day caro facility within the Massachusetts EPZ is not in compliance with the requirements of 102 CMR S 7. 07 (16) (d) ?
If your answer is a.
..or than an unqualified negativo, then please identify each such facility which Mass AG contends is not or may not be in compliance, and:
(a)
Stato each fact on which your answer is based.
(b)
Identify and produce each document which you contend reflects or supports your answer.
(c)
Provide the technical qualifications (education, employment history, licenscs and cortificates, experience, or other information that Mass AG contends establishes the qualifications of the person) of any person on whose exportico Mass AG relies for the answer, or stato that Mass AG l.
_ _ _, _ _ _. _ _ _ - - - - - - - - - - ^ - - - - - - - - - - ' ^ - - - - - - - - - - - ' - - - - - - - - - - - - - - - ' - - - - - - - ' ' ' '
does not rely upon the expertise of any person for the answer.
19.
Does the Mass AG contend that any day care facility within the Masstchusetts EPZ is not in compliance with the requirements of 102 CMR S 7.11(8)?
If your answer is anything other than an unqualified negative, then please identify each such facility which Mass AG contends is not or may not be in compliance, and:
(a)
State each fact on which your answer is based.
(b)
Identify and produce each document which you contend reflects or supports your answer.
(c)
Provide the technical qualifications (education, employment history, licenses and certificates, experience, or other information that Mass AG contends establishes the qualifications of the person) of any person on whose expertise Mass AG relles for the answer, or state that Mass AG does not rely upon the expertise of any person for the answer.
20.
Does the Mass AG-contend that any day care facility within he Massachusetts EPZ is not in compliance with the requirements of 102 CMR S 8.08(21)?
If your answer is anything other than an unqualified negative, then please identify each such facility which Mass AG contends is not or may not be in compliance, and: -. -.
(a)
State each fact on which your answer is based.
(b)
Identify and produce each document which you contend reflects or supports your answer.
(c)
Provide the technical qualifications (education, employment history, licences and certificates, experience, or other information that Mass AG contends establishes the qualifications of the person) of any person on whose expertiso Mass AG relies for the answer, or state that Mass AG does not rely upon the expertise of any person
.for the answer.
21.
Does the Mass AG contend that any day care facility within the Massachusetts EPZ would not, in the event of a radiological emergency at Seabrook Station, comply With the requirements of 102 CMR S 8.10?
If your answer is anything other than an unqualified negative, then please identify each such facility which Mass AG contends would not or.may not comply, and:
(a)
State each fact on which your answer is based.
(b)-
Identify and produce each document which you contend reflects or supports your answer.
(c)
Provide the technical qualifications (education, employment history, licenses and certificates, experience, or other information that Mass AG contends establishes the qualifications of the l
..2 person)--of any-person on Lwhose expertise Mass AG rel1es--for_!the answer,;or-state that Mass AG
~
.i
'does.notJrely upon the expertiselof any person for the answer.
22.
Does the Mass AG-contend that any day ~ care facility within the Massachusetts-EPZ istnot in compliance with the requirements of 102 CMR S.7,07 (18) (1) ?
If your
]
answer is anything other.than an: unqualified negative, 4
thenTplease-identify each such facility which Mass AG Econtends is not orLmay not be in compliance, and:
.(a)
State each fact on_whichfyour-answer is based.-
(b)
Identify and. produce each document which you contend reflects.cnn supports your' answer.
- (c)
. Provide tholtechnicalnqualifications~(educationi employment history,. licenses and certificates, experience, or other.information that Mass AG contends. establishes'the qualifications of the person)'lof any. person:on?whose~ expertise. Mass AG reli~cs 1for' the s answer, ; orrstate' that Mass-- AG.
1does not: rely upon the expertise of~any person-n' for the! answer.
-23.
Does MassLAG agree that it-is the policyJor positionLof.
=!
^
the Massachusetts; civil Defense Agency land/or the -
i a
- Massachusetts l Executive'Officetof:Publicf Safety,-with
' respect to: radiological emergencies, that "(i]n-the c
, ri e m, -.- i
i event ofian avacuation,:it is the responsibility of teachers', other school personnel,1and-day-care-providors
-to_ decompany -children.to-rocoption conters, until they:
~- 1
-can;be. discharged to_their parents-or guardians"?
I f-
_your answer to-anything other than-an: unqualified affirmative, then please describo in-detail what-Mass AG
-contends the policy or position of the Massachusetts Civil 10efense Agency and the Massachusetts Executive Office of Public' Safety to be with'rospect1to the-responsibilitioslof. Teachers in-the event-of a radiological emergency, and:
-i 1
- (a )-
' Stato'each fact _on-which-your~ answer is' based.
(b)
Identify and produce each documentLwhich you.
. contend' reflects or:cupports your_ answer-.
(c).
Provido tho' technical qualifications.'(education, q
-employmentihistory, licenses andicortificates, i
t Li-
- experienco,forLothor-information that Mass AG i
o
- contends establishes tho qualifications of the person)-of any person on-whoseLexpertise Mass AG' o
rel'ies for the answer, or state that' Mass-AG 4
idoes notfrely upon the expertise:of'any porson'
[
-for thet answer.-
4
'24.--Does-Mass AG--contend that, in--the event of-a
, _ ~
.radiologicalDemerger.cy at Seabrook. Station,' Teachers employed _in the Massachusetts EPZ would not meet thei'r
-I a
~.
w "rosponsibility.
to accompany children to reception contors, until they can be discharged to their parents or guardians"?
If your answer is anything other than an unqualified negative, then pleaso:
(a)
Describo in detail each reason for your answer.
(b)
State what percentage of Teachers Mass AG contends would thus fail to moet their state-imposed responsibility to accompany the children.
(c)
Stato each fact upon which your answers to sub-parts (a) and (b) above are based.
(d)
Identify and produce cach document which you contend supports your answers to sub parts (a) through (c) above.
(e)
Provide the technical qualifications (education, employment history, licensos and cortificatos, experience, or other information that Mass AG contends establishes the qualifications of the person) of any person on whose exportise Mass AG rollos for the answers, or state that Mass AG does not rely upon the exportise of any person for the answers.
25.
Does Mass AG agree that the Memorandum of Charlos V.
Barry to Robert J.
Boulay, April 24, 1989, Attacnment B to the October 19, 1990 Affidavit of Anthony M..
--c-4
_Callendrello, correctly states the.present policy or
+
position =of-the' Massachusetts Civil Defense Agency and
.the Massachusetts Exccutive office of Public Safety?. If
-your; answer is anything other'than an unqualified affirmative',:then please describe'in detail what Mass-AG contends the policy or position of the Massachusetts Civil Defense Agency and the Massachusetts Executive office of Public. Safety to be-with_ respect to orders from the Governor to Teachers in the-event of a radiologicallemergency, and:
-(a)
-State cachJfact upon which.your answer is based.-
i
.(b)
Identify and: produce each document which you
-cu.dond.sepports your answer.
(c);
_ Provide the technical 1 qualifications (education, b
employment history, licenses and certificates, a
experience, or other information that Mass:AG-contends; establishes'the_ qualifications of the person) of.any. person on whose experticeLMassLAG J
relics.for the. answer, ortstate-thatiMass AG-does not: rely.:upon the: expertise of any person l[
'for the answer.
L 2 6. -.DoescMass AG -contend - that, in lthe event of: a radiologica1Eemergency at Seabrook Station,_ Teachers-h employed;in theLMassachusetts'EPZ would disobey an order from-the~Governortor his delegatee that.they accompany L p 1^
,.,. n
+
F
+
i the children to' reception conters-until relieved?
If t
your answer isVanything otherLthan-an unqualified ~
negative,J hen please:
t
.(a);
-Describe in detail each reason for your answer.
.(b);
State what percentage of' Teachers MassJ AG contends would thus disobey the Governor's emergency order.
I (c).
State--3ach fact upon which your answers to sub-parts'(a) andL(b) above are based.
- (d).
- Identify and produce each document which you
(
T contend supports your answers to sub parts (a) through;(c) above.
.(e)?
-Provide the technical qualifications (education, t
~
~
employment history, 1icenses and certificates,-
experience,-or other information that Mass AG i
contends establishes the1 qualifications of the
- person). of any person on whoseLexpertise Mass AG
' relies for the answers,.or' state that Mass-AG L
.does not rely upon the expertise of--any1 person;
.forfthe; answers.
?27.-
PleaseLdescribe.Hin detail,1and--identi'fy and produce all 3
L fdocuments; thaticonstitute,- reflect--or refer to, all w
~
- communications,;concerning theLresponse of Teachers y
A employed.in the! Massachusetts EPZ in the event of a o
s I.. i
- i 4
- radiological emergency at1Seabrock Station,- between the Mass.-AG (as-defined) and:
-(a) the office for Children; (b)-
.other Massachusetts governmental officials and entities, including, but not limited to city, town and school district officials; l
(c)
Teachers; 4
(d)~
Schools-and administrators.thereof;-
(e):
Teachers' unions and officials thereof; and (f) all-~other-persons and entities.;
2 8.-
Please' describe in detail, and identify and produce all y
documents-that. constitute, reflect or refer to, all communications,_concerning School emergency planning in connection 1With1Seabrook Station, between Massachusettu i
- governmental
- offic'lais1and-entities.(including, but not 1
limited to; the Mass AG"as defined)-and:
(a) the office for children:
- ( b) -
other Massachusetts governmental. of ficials1and
--J i
entities, including,-but not l'imited tofcity, town 1and? school district officials; y
-(c)
Teachers;'
(d).
Schools _-and' administrators-thereof; (e)
Teachers' unions and officials:thereof;-and j
(f) all other-persons-and entities.
. 19_
-e' m.
Ih}
L 29.
Please describeLin detc.il, and_ identify =and produce all-documents that: constitute, re'flect or refer to,=all communications, concerning the response of Teachers employed. in the: Massachusetts L EPZ 1: the. event of a
-radiological emergency at Seabrook Station, between EMassachusetts governmental officials and entities other a
than the. Mass AG (as defined) and:
~
gg (a)-
the: Office for Children; (b) other Massachusetts governmental officials:-and entities,fincluding, but not limited-toicity, 1
town-andEschool' district officials; D(c)-
Teachers; r
.:( d )
Schools and administrators thereof; 1
(e)
Teachers' unions'and officials--thereof; and
^ '
-(f).
all other persons and entities,
- 30.
Does: Mass AG contend.that?there is not " reasonable assurance that, in thoievent ofla. radiological. emergency-
?
a atilseabrook# necessitating an evacuation of-children in--
y school's?andiday-care centers within therMassachusetts
=EPZ, a sufficient number of--teachers;-and day-care center.
- personnelcwilliescort the children'to the_ School;Hosti 4
't;}
FacilitylatLHcly Cross CollegeLand. remain with those-
- [
Jehildren-untillrelieved'of thatDassignment"? -If your-answerDis,anything other than;an unqualified negative, then please:
1
'I f i.;
y
,y y
w v
o
.m.,
e
1 v,
'( a )-
State eachifact on which your answer is based.
(b)
- Identify and-produce each document (including, but limited-to, each analysis, survey, study and.
]
report) which you contend supports your answer.
k
'(c)-
Provide the technical qualifications (education, q
employment history, licenses and certificates, t
experience, or-other information=that Mass AG contends establishes the qualifications of the t
person) of any person on whose expertise Mass AG relies for the answer, or state that Mass AG.
i
~does-not rely.upon the expertisc of-any person 1
-for the-answer.
1
'(d)
Identify each witness whom' Mass AG intends to L
- 1 call to testify in support of Mass'AG's-1 position.
- 31.
-Does-Mass AG contend that' Licensees have not'"mado satisfactory alternative arrangements for the care and
= supervision offthe-children botheon the bus trip to-Worcester and=during their! stay.at the School Host Facility"?
IfLyour answer;is anything other than an I
unqualified negative, then please:
_a (a).
State each fact on which your answer 1s-based.
o l(b)'
Identify and produce each document (including, i
but'11m'ited to, each analysis,. -- survey, study and report) w'hich you contend supports your answer.
2
.t E
i i
i
- (c)
Provide the_ technical qualifications (education,;
I employment history, licenses-and certificates, experience,'oriother'information that Mass AG contends establishes the qualifications of-the person) of any person on whose expertise Mass AG a
relics for the answer, or state that Mass AG does not rely upon the. expertise 1of any-person.
I
-forL the answer.-
(d)-
-Iden*ifyieach' witness whom Mass AGTintends to callito testify in support of Mass AG's position.
u 3 2-. -
Please describe in detail-each action which-Mass AG contends:must be-taken in_ order =to provide " reasonable i
assurance _that,-inLtheLevent;of a_ radiological emergency-at-Seabrook necessitating an. evacuation of/ children in i
schoolsiand day-care 6 enters within the Massachusetts:
EPZ, a sufficient _ number of teachers _and day-care conter personnel:will' escort the children to the School Host' Facility at Holy Cross. College:and romain with those1 i
children until* relieved of.that assignment"?
Please a
also:
(a)
- State each fact.on which your answer-is based.
(b)'
Identify and produce-each document whichlyou ccontend supports your answer.
r.,
4 (c)
Provide the technical qualifications (education, 1
employment history, licenses and certificates, experience, or other information that Mass AG contends establishes the qualifications of the person) of any person on whose expertiso Mass AG relies for the answer, or state that Mass'AG does not rely upon the expertise of any person for the answer.
33.
Please describe in detail each action which Mass AG contends must be taken in order that Licensees will have "made satisfactory' alternative arrangements for the care and supervision of the children both on the bus trip to Worcester and during their stay at the School Host Facility"?
If Mass AG contends that changes would be required to the SPMC, the Holy Cross Ops Plan, and/or the School Host Facility Plan, please describe -in detail each_such change.
Please also:
(a)
State each fact on which your answer is based.
(b)
Identify and produce each document which you contend supports your answer.
(c)
Provide the technical qualifications (education, employment history, licenses and certificates, experience, or other information that Mass AG contends establishes the qualifications of the person) of any person on whose expertise Mass AG
.4 e
i relics-for-the answer, Lor stato-that Mass AG-does noti rely upon tho. exportise.of L any. person 1 i
for the"answor.
3 4. --- Does Mass-.AG contend;that Teachers-are not generally relied;upon to accompany evacuating' children (1).from c
'the-emergency planning zones around1other_ nuclear power.
t plants, (ii)1from the' areas around-facilities.-containing hazardous materials, and (iii).in other. situations where
- )
lt ovacuation.of, Schools is requirod?- If your answer is anything.other;than an unqualified negativo,;thon
~
1 pleaso:
i (al
-Stato.:oach fact on which your answer-is based.
1(b)
Identify _and produco_cach-document (including, but limited to, 'oach analysis, ' survey, study; and report) -which 'you contend supporta your answer.-
- (c).
Provido.the technical qualifications-(oducation, I
employment ~~ history, licensos and certificates, il experience,.or_othor;information that Mass AG.
contends establishes-the qualifications of the person) of.any)porson on'whose exportico Mass AG relios,forethe answer, or stato that Mass 1AG 2
does not:rolyJupon_the exportise of any person 3
for-thofanswer.
W
' 3 5. -.Does: Mass AG: contend that the reliance on Teachers to -
accompanysovacuatingnchildren (i) _f rom 'the omorgency.
- 4 h
'i,
,.m,-
,,,_L._
n
. planning zones:around,other nuclear; power plants, (ii) y from the nreasiaround facilities'containing' hazardous materials, and^(iii) in.other situations where evacuation of SchoolsLis required,-does not' provide-
" reasonable assurance that adequate protective measures can and will-be taken"'for the supervision of the evacuating children?
If your answer _is anything other-
'than an' unqualified. negative, then please:
(a)_
State:each fact on which your answer is based.
- (b)
- Identify.and-producoleach document (including,
'but limited to, each. analysis, survey, study and 3
. report)Jwhich-you-contend supports your= answer.
4 (c)
Provido the_ technical qualificati'ons (education, employment history, licenses-and certificates, experience, or other information that Mass AG contends establishes 1the-qualifications of the person) of any person on whose1 expertise = Mass AG-relies.for-the answer, or-state.that: Mass-AG does not rely upon the expertise of any person <
for the answer.
36.
Does Mass AG. contend that reliance upon Teachers to
. accompany evacuating children does provide:" reasonable assurance that adequate protective measures can and will' i
tua -taken" for the supervision of the evacuating children -
(i): from-the, emergency planning zones. around 'other.
z.-
i 9
~ nuclear power plants, (ii) -f rom-the areas around facilities containing hazardous materials, including and
-(iii)s in'other: situations whero evacuation ~of Schools ~is
. 4 required, but'such_ reliance does not provide " reasonable assurance" with respect to the Massachusetts EPZ?
Please state each~ reason for your answer, and, separately for each reason, please'also:
I.
'(a)
State each fact on which your answer is based.
(b)
Identify and produco each document _(including, but' limited:to, each analysis, survey', study and.
report) which.you contend-supports your answer.
(c)?
Provido-the technical qualifications (education, 1
(
employment history, licensos and cortificates, experience, or.other information that Mass AG
~
contends establishes.the qualifications of the person) of any person on whose exportiso Mass-AG relles for the answer, or:stato that Mass AG-does not rely'uponithe exportise-of any-person _
l for the-answer.
- Dy their. attorneys, f
/7 Thom'as G.
Dignan, Jr.
George.H.'Lewald:
Kathryn sellock shea
-Jeffrey P.cTrout Ropes & Gray One International Place Boston, MA 02110-2624 (617) 951-7000,
-a
RELATED CORRESPONDBCE Ari;iD UWC CERTIFICATE OF SERVICE I, Jeffrey P. Trout, one of the attorneys for thd 'Lic~ ens ~echW"f herein, hereby certify that on December 10, 1990, I mAdli idrYi'ce I of the within document by depositing copies thereof with Federal Express, prepaid, for delivery-to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):
A'iministrative Judge Ivan W.
Smith Adjudicatory File Chairman, Atomic Safety and Atomic Safety and Licensing Lilensing Board Board Panel Docket (2 copies)
I'. J Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commiosion East West Towers Building East dest Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Administrative Judge Richard F.
Cole Robert R.
Pierce, Esquire Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board East West Towers Building
't.S.
Nuclear Regulatory 4350 East West Highway Commission Bethesda, MD 20814 East West ToWors Building 4350 East West Highway Bethesda, MD 20014 Administrative Judge Kenneth A.
Mit:1 A.
Young, Esquire McCollom Edwin J.
Reis, Esquire 1107 West Knapp Street Office of the General Counsel Stillwater, OK 74075 U.S.
Nuclear Regulatory Commission One White-Flint North,'15th F1.
11555 Rockville' Pike Rockville, MD 20852 John P. Arnold, Attorney General Diano Curran, Esquire George-Dana Bisbee, Associate Andrea C.
Forster, Esquire Attorney General Harmon, Curran & Tousley Office of the Attorney General Suite 430 25 Capitol Street 2001 S Street, N.W.
Concord,.NH 03301-6397 Washington, DC 20009
- Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Panel 116 Lowell Street U.S.
Nuclear Regulatory P. O.-Box 516 Commission Manchester, NH 03105 Mail Stop EWW-529 Washington, DC 20555
Philip Ahrens, Esquire Suzanne P.
Egan, City Solicitor Assistant Attorney General Lagoulis, Hill-Whilton &
Department of the Attorney Rotondi General 79 State Street Augusta, ME 04333 Newburyport, MA 01950 Paul McEachern, Esquire Stephen A. Jonas, Esquire Shaines & McEachern Leslie Greer, Esquire 25 Maplewood Avenue Matthew Brock, Esquire P.O.
Box 360 Massachusetts Attorney General Portsmouth, NH 03801 One Ashburton Place Boston, MA 02108
- Senator Gordon J.
Humphrey R.
Scott Hill-Whilton, Esquire U.S.
Sanate Lagoulis, Hill-Whilton &
Washington, DC 20510 Rotondi (Attn:
Tom Burack) 79 State Street Newburyport, MA 01950
- Senator Gordon J.
Humphrey Barbara J.
Saint Andre, Esquire one Eagle Square, Suite 507 Kopelman and Paige, P.C.
Concord, NH 03301 101 Arch Street (Attn:
Herb Boynton)
Boston, MA 02110 H. Joseph P2fnn, Esquire Judith H. Mizner, Esquire Office of General Counsel 79 State Street, 2nd Floor Federal Emergency Management Newburyport, MA 01950 Agency 500 C Street, S.W.
Washington, DC 20472 Gary W.
Holmes, Esquire Ashod N.
Amirian, Esquire Holmes & Ells 145 South Main Street 47 Winnacunnet Road P.O.
Box 36 Hampton, NH 03842 Bradford, MA 01835 Mr. Richard R.
Donovan Mr. Jack Dolan Federal Emergency Management Federal Emergency Management Agency Agency - Region I Federal Regional Center J.W.
McCormack Post Office &
130 228th Street, S.W.
Courthouse Building, Room 442 Bothell, Washington 98021-9796 Boston, MA 02109 2-
George Iverson, Director N.H. Office of Emergency Management State House Office Park South 107 Pleasant Street Concord, NH 03301 3
/WM
'Jeffrey P.
Trout
~
(*= Ordinary U.S.
First Class Mail) l l
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