ML20080M735

Interrogatories & Requests for Documents Re Emergency Planning for State of Nh

ML20080M735
Person / Time
Site:	Seabrook
Issue date:	09/29/1983
From:	Bellotti F MASSACHUSETTS, COMMONWEALTH OF
To:	Federal Emergency Management Agency
Shared Package
ML20080M740	List: ML20080M735 ML20080M756 ML20080M791 ML20080M811
References
ISSUANCES-OL, NUDOCS 8310040256
Download: ML20080M735 (12)

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00CNETED USNRC

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UNITED STATES OF AMERICA '~ "

NUCLEAR REGULATORY COMMISSION )3. OCT -3 P3:35 ATOMIC SAFETY AND LICENSING BOARD CFFICE OF SECRETARY 00CKETING & SEPviff BEFORE ADMINISTPATIVE JUDGES: NAO Helen F. Hoyt, Chairman Dr. Emmeth A. Luebke Dr. Jerry Harbour In the Matter of ) Docket Nos.

) 50-443-OL PUBLIC SERVICE COMPANY OF ) 50-444-OL NEW HAMPSHIRE, et al. 1 (Seabrook Station, Units 1 and 2) -) September 29,-1983

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ATTORNEY GENERAL BELLOTTI'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE FEDERAL EMEFGENCY MANAGEMENT AGENCY ON EMEPGF"CY PLANNING FCB THE STATE OF NEW HAMPSHIFE INSTRUCTIONS FOP USE _

i Attorney' General Francis X. Bellotti hereby requests that the' Federal Emergency Management Agency *, pursuant to 10 C.F.R.  !

SS2.740(b) and 2.741, answer separately and fully, in writing under oath orLaffirmation, the following interrogatories and produce and permit incpection and copying of the original or best copy of all documents identified in the responses to

• These interrogatories and document requests have been directed to FE!!A following dsicussions with FEMA counsel on the question of whether FEMA is a party to this proceeding for discovery purposes. If it is later determined that FEMA personnel are, instead, witnesses of the NRC Staff, this pleading will be conformed to the procedures applicable to discovery of the NFC Staf f.

8310040256 830929 )

PDR ADDCK 05000443 O PDR

interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents therein identified, FEMA file supplemental responses and produce additional documents as required by 10 C.F.R. 52.740 (e) .

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

The term " document [s]" as used herein shall mean any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data,' computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, maps, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

_ INTERROGATORIES

.l. .Please identify and produce all documents within the possession, custody, or control of the Federal Emergency

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Management Agency [hereirafter, " FEMA"] which contain or refer to any actual or potential revisions or additions to the draft New Hampshire Radiological Emergency Response Plan submitted to FEMA Region 1 on or_about May 12, 1983 [hereiaafter, "the RERP"), including but not limited to any documents relating or referring to evacuation routes, traffic access or control points, traffic management plans, reception centers, radiological monitoring locations, plans for evacuation of people in the beach areas dependent on public transportation, plans for. decontamination of persons or vehicles exposed to radiation, provisions for.the storage, distribution, or use of radioprotective drugs,- cr plans for sheltering the summer beach populations or those seasonal residents whose homes provide insufficient shielding from radiation.

2. Please identify and produce all documents within FEMA's

) poscession, custody, or control whi-b refer to the emergency response needs or resources of the State of New Hampshire

[hereinaf ter, "the State"] or means for satisfying the State's

-resource requirements, or upon which FEMA relies in support of the State's capability to satisfy its resource requirements, in i any of the following areas:

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a. . emergency transportation for people in the beach areas without private transportation;

b. emergency medical transportation;-

c. medical treatment for. contaminated injured individuals; radiological monitoring and assessment equipment;

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e. -dosimeters and respiratory equipment for emergency workers;

f. manpower for traffic management and acce'ss control;

g. manpower for emergency transportation and security operations; h- manpower for emergency maintenance for evacuation routes and response to abandoned vehicles, traffic accidents, and other obstructions to evacuating traffic flow;

i. manpower for staffing of emergency response facilities.

3. In the opinion of FEMA, does the State currently have adequate resources within the State in each of the areas identified in subparagraphs 2a' - 23. above to imple :.ent its emergency plan? State the bases for your answer--in detail, including your bases for determining what constitutes an adequate quantity or level of each such resource, and identify and produce all documents upon which you rely in support of your rnswers.

4. If your answer to question 3 was in the negative as regards any areas of emergency response capability, is it FEMA's position that the necessary additional resources can be i procured on a timely basis from outside the State? If so, identify the types, quantities and sources of all such-additional resources and specify the time within which they will be available to the State following its request therefor.

Identify and produce all documents upon which you rely in support of your answers, i

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5. In the opinion' of FEMA, what is the greatest number of

" contaminated injured ' individuals" who could lx3 in need of medical treatment in the event of.a radiological emergency at

. Seabrook Station? State the bases for your answcr in detail, describing the types of injuries and sources or levels of contamination for which your estimate accounts, and the type of medical treatment which would be-required for each such injury or level of contamination. Include in your estimate all-contaminated injured individuals who could be helped in any way t by medical treatment. Identify and produce all documents upon r

which you rely for any portion of your' answer.

6. In the opinion of FEMA, can the health care facilities-identified in the RERP provide to the number of contaminated injured individuals.specified in your answer to_ interrogatory 5 all medical treatment which could be of help to them? If not, can such treatment txt provided by other health care facilities in New Hampshire and/or Massachusetts? State-the' bases for your answers in detail and identify and produce any documents upon which you rely. List all medical facilities other than those identified in the-BERP which might be required to provide care to assure tnat the full number of persons specified in i

your answer to interrogatory 5 re.ceive all treatment which l

! could be of help to them.

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7. In the opinion of FEMA, what percentage of the emergency response officials and personnel identified in the RERP will, in fact, report to their emergency posts and fulfill their designated' responsibilities in the event of a radiological emergency at Seabrook Station? What percentage of such emergency response officials.and personnel will'first ensure that their families are being taken care of before reporting to duty and what will be the length of the delay in assumption of emergency-responsiblities resulting therefrom?.

State the bases for your answers in detail and identify and produce any documents upon which you rely.

8. 'In the opinion of FEMA, will there be adequate personnel available on a timely basis to replace the local emergency workers removed from the emergency zone if workers

-are removed due to releases of radionuclides other than I-131 in amounts requiring protection? [See RERP, at 2.7-3] State.

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the bases for your answer in detail, identifying the source and-numbers of replacement workers and specifying the bases for assurance they will be available in a timely fashion. Identify and produce all documents upon.which you rely in support of your_ answers.

9. In the opinion of FEMA, has the State established an emergency action level scheme consistent with that established by the Applicants? State the bases for your response in detail and identify and produce any documents upon which you rely in support of your answer.

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10. In the opinion of FEMA, has the State established procedures for notification of all emergency personnel by each of the State emergency response organizations? If so, describe those procedures in detail. Identify and produce all documents within the State's possession, custody, or control which contain or refer to such procedures or upon which you rely in support of your answers.

11. In the opinion of FEMA, has the State developed the means to provide early notification and clear instruction to the public in the event of an emergency at Seabrook Station?

If so, describe those means in detail and identify and produce all documents within FEMA's possession, custody, or control relating th e re to , including any documents relating in any way to a siren or other audible alert sys' tem for the Seabrook vicinity.

12. In the opinion of FEMA, how will local emergency response organizations in New Hampshire be notified of an emergency at the Seabrook Station? State the bases for your answer in detail and identify and produce any documents upon which you rely.

13. Identify u. oduce any documents within FEMA's possession, custody, or con- which refer or relate in any way to evacuation routing or traft1. 'qement in the event of a radiological emergency at Seabrook.

14. Identify and. produce all. documents within FEMA's possession, custody, or control which relate in any way to the capacity orfbuilding material of buildings in the coastal'New Hampshire. communities within ten miles of the Seabrook site, the number.of such buildings which are insulated, the number of such buildings which have basements, the level or degree of protection afforded by such buildings against radionuclides, or the feasibility of sheltering the summer beach and seasonal populations within those communities in such buildings.

15. l[n the opinion of FEMA, do the provisions in the RERP for sequential notification by New-Hampshire Civil Defense of all State response organizations following verification by DPH, and the provisions allowing a 15-minute lapse between an emergency classification by the licensee and notification of Civil Defense and requiring that notification of the State response organizations be completed before Civil Defense will activate the public alerting system ensure sufficiently prompt notification of response organizations and the public? State the bases for your answer in detail and identify and produce any-documents upon whien you rely.

16. In the opinion of. FEMA, is the RERP adequate and capable of being implemented as required by 10 C.F.R.

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S50.47 (a) (2) ? Does it provide reasonable' assurance that

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. a'dequate protective' measures can and.will be raken in.the event of a radiological' emergency at Seabrook Station as required by 10 C.F.B. S 5 0 '. 4 7 (a) (1) ? Does it satisfy all of the planning standards set,forth at 10 C.F.R. S50. 47 (b) (1) - (16), as addressed by the criteria of NUREG-0654, Rev. l? If your ,

answer to any of these questions is anything other than an unqualified affirmative response, state in detail all respects in which the REBP fails to satisfy the stated requirement and describe the revisions or additions thereto which are necessary, in the opinion of FEMA,.to achieve compliance. Identify and 4

produce all-documents upon which you rely for any of your answers.

17. In'the opinion of FEMA, can the' transient beach populations in the'New Hampshire coastal communities within ten P miles of the Seabrook site be protected from all adverse health I

effects potentially associated with radiation exposure.by means-of evacuation in the event of a radiological emergency at Seabrook Station? If your answer is in the negative, indicate what adverse health ef fects could be experienced by the beach population ~and the numbers of such persons who may potentially experience each such'effect. Whether your answer is in the affirmative or negative, state the bases-for it in detail and identify and produce all documents upon which you rely.

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.' 18. In the opinion of FFMA, can-the seasonal residents in

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the beach areas-within ten miles of the Seabrook site be protected from all adverse healthieffects potentially associated with' radiation exposure'by means of in-place sheltering? -If your answer is in the negative, indicate what adverse health effects could be experienced'by the seasonal population and the-numbers of such persons who may potentially experience each such effect. Whether your answer is in the affirmative or negative, state the bases for it in-detail and identify and produce all documents upon which you rely.

19. In the opinion of FEMA, what is the most efficient evacuation routing scheme for the~ seasonal and transient beach i populations in the coastal New Hampshire communities within ten miles of the Seabrook site? State the bases for your answer in detail and identify and produce all documents upon which you rely. Do the routes which you.have specified conform in all.

respects to those assumed by the Applicants in their evacuation time estimates as set forth in Appendix C to the FSAR? to i

those assumed by Costello, Lomasney &-deNapoli/C.E Maguire in the ir " Final Draf t .cWE . Appendix E Emergency Planning Zone Evacuation Time Study"? If the answer in both cases is no, 1 t

will FEMA require revised evacuation-time estimates based on the most efficient routing scheme? When will such estimates be 1

required to be completed?

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20. In_the opinion of FEMA, what traffic management plans or traffic controls will-lead to the most efficient evacuation

.of the seasonal' and _ transient beach populations jin the coastal New Hampshire communities within ten miles of the site? State the bases for your answer in detail and' identify and produce any documents upon which you rely. Have .these traffic controls and management plans been reflected in the evacuation time estimates prepared by~the Applicants? those prepared by C._E.

Maguire? If the ~ answer in both cases is no, will FEMA require revised evacuation time estimates based on such plans and controls? When will such estimates be required.to be completed?

21. _ In the opinion of FEMA, what.will the effect be on evacuation times for the seasonal and beach populations._in the coastal New Hampshire communities of directing vehicles to access control points for decontamination?: What will-be the health effects associated with_ allowing persons to evacuate to other than reception centers so that they (and the family members or f riends with whom they stay) will continue to be expcsed to contaminated vehicles?

22. What health effects will result from evacuation on a hot summer day with closed windowc and ventilation systems?

State the bases for your answer in detail and identify and produce any documents upon which you rely?

23. What assurance does the State have that it can obtain a sufficient quantity of radioprotective drugs early enough to use them for protection of omergency workers? [See REPP, at 1.3 - 10]

24. Identify each person whom FEMA expects to sponsor as a witness on any of the admitted contentions relative to the RERP, state his or her qualifications, and describe the subject matter on which he or she is expected to testify.