ML20078F913

Interrogatories & Requests for Documents on Emergency Planning for State of Nh.Related Correspondence

ML20078F913
Person / Time
Site:	Seabrook
Issue date:	10/05/1983
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
ISSUANCES-OL, NUDOCS 8310110227
Download: ML20078F913 (9)

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\ '[ -UlflTED STATES OF AMERICA

\\ c'!' ' e - y '" . NUCLEAR REGULATORY COMYll SSION '83 g g BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD bb tINSId$"

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PUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL NEW llAMPSilIRE, et al 50-444 OL (Seabrook Station, Units I and 2)

SEAOOAST ANTI-POLLUTION LEAGUE'S 1NTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE APPLICANT ON EMERGENCY PLANNING FOR Tile STATE OF NEW llAMPSilIRE INSTRUCTIONS FOR USE The Seacoast Anti-Pollution League hereby requests that the Applicant, pursuant to 10 C.F.R. 62.740(b) and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce and permit inspection and copying of the original or best copy of all documents identified in their responses to interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents therein identified, Applicant file supplemental responses and produce additional documents as required by 10 C.F.R. 02.740(e).

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

The term " document [s]" as used herein shall mean any written or graph i c ma t t er o f commun i ca t ion , however produced or reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-o f f i ce commun i ca t ions , no tebook s , dia r ies , s ke t ches , d i agrams , maps ,

forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmat ions and all other writ ten or graphic materials of any nature whatsoever.

8310110227 831005 PDR ADOCK 05000443 G PDR

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I NTEltitOGATOlt i 1:S

1. In the opinion of the Applicants, does New llampshire law provide clear authority for the Governor to order a protective response, including evacuation, in the event of a radiological emergency? If the answer is in the af firmative, state wi th par t iculari ty the legal analysis upon which that conclusion is based, includ!ng the steps and thought processes utilized in arriving at that conclusion.

Provide all applicable references to existing statutory and case ,

law, and cite any and all documents or other informational sources relied upon in your response.

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2. In the opinion of the Applicant, does t he NilitEllP p rovide f o r 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability to determine doses received by emergency personnel? Does, in the opinion of the Applicant, the NilRERP coinply wi t h 10 C. F.R. 450.47(b)(11)? Does, in the opinion of the Applicant, the NilRERP comply with the criteria under NUREG-0654 K.3.? If the responses to any and/or all of the above are in the affirmative, state in minute detail the facts upon which your conclusions are based, including detailed citations to all documents and/or other informational sourecs upon which you rely for your answer. If any .

9 of the answers are in the af firmat ive, ci te the provisions, including 1 page numbers, within the N!!RERP which provide for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability to determine doses received by emergency personnel, including citations to provisions in the N!!!tERP , including pages, which provide for the equipment necessary to provide that espability with respect to all emergency personnel within the 10 and 50 mile EPZ's, respectively, and provide in detail the basis upon which you conclude that such equipment wi11 be suf ficient to meet the criteria o f NUREG-0 654 K. 3. I f, any or all of the responses to interrogatories 1 or 2 are in the negative, similarly provide in detail the basis for that response, including detailed citations to any or all supporting documents or other informational sources relied upon in support of the answer.

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3. In the opinion of the Applicent, does the NilitEftP adequately provide for the radiological decontaminat ion of emergency personnel wounds, supplies, instruments and equipment, including showing that there exists a means for waste disposal? If the answer is in the af firmative, state in detail the f actual basis upon which the response rests, including detailed citations to supporting documents and/or in fo rma t iona l sources relied upon for the response.

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4. If the Applicant aware of any provision in the NIIIIEllP for any decontamination centers adequately staffed and equipped to perform the numbers of decontaminations that would be required of emergency personnel and supplies, ins t rument s and equipment? I f so, ci te wi th particularity the provisions and page numbers in the NilitEltP which make the above provision.

5. Doe s t h e NiillEllP , i n t h e o p i n i o n o f the Applicant make any analysis or reference to hospital treatment facilities and emergency workers which would provide decontamination of emergency personnel wounds?

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6. Does, in the opinion of the Applicant, the NilitERP provide sufficient means for waste disposal of low-level radioactive waste resulting from decontamination of emergency personnel wounds, supplies, instruments and equipment? If the answer is in the affirmative, state with particularity the provisions in the plan that provide for such disposal, as well as ci tations to page numbers.

Also state with particularity the individuals responsible for such waste disposal, their authority to engage in low-level radioactive waste disposal, and their professional qualifications to engage in .

that activity. Also state with particularity the cites identifled for location of low-level radioactive waste resulting from such decontamination referred to above, whether those sites be temporary or permanent.

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7. Does, in the opinion of the Applicant, the NilRERP cot.p ly wi th the requirements of 10 C.F.R. 650.47(b)(10) and NOREG-0654 J.11.?

If the answer is in the affirmative, cite the provisions in the NilRERP which support your response, including page numbers. In particular, state where the plans provide for (a) maps for recording survey and monitoring data, key land use data, dairies, food processing plants, v.a t e r sheds, water supply intake and treatment plants, and reservoirs, (b) identification of procedures for deteeting contaminatlon, for estimating the dose consequences of .

uncontrolled ingestion, and for impos ing pro tect ion procedures such as impoundment, decontamination, processing, decay, product diversicn, and preservat ion, (c) criteria for deciding whether dairy anima ls shou ld be pu t on s tored f eed, and (d) the protective measures to be used for the ingestion pathway, including the methods for protcet ing the public f rom consumpt ion of contaminated food stuf f s.

I f, in the event the Applicant is unable to ci te prov i s ior.s in the NilRERP which provide for the above mandated criteria, state with particularity why the Applicant concludes that the NilRERP is nevertheless adequate to protect the public from contamination through the inges t ion exposure pa thway no twi ths tanding i ts inabili ty to meet the applicable criteria under NUREG-0654 J.11. If in the event the Applicant is of the opinion that the NilRERP is inadequate in this regard, state wi th par t iculari ty how and when these eri terla wilI be met, and identify the specifle resources avaltable within the State of New !!ampshire to implement those crit 3ria.

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m Respeetfully submitted, Seacoast Anti-Pollution League fly its attorneys, BACKUS, SilEA & MEYER

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Itobe r t A. ITackus -

116 Lowell St., Box 516 Manchester, N.ll. 03105 l'e l : (603) 668-7272 October 5, 1983 9

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