ML20080M756

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

ML20080M756
Person / Time
Site:	Seabrook
Issue date:	09/29/1983
From:	Bellotti F MASSACHUSETTS, COMMONWEALTH OF
To:	NEW HAMPSHIRE, STATE OF
Shared Package
ML20080M740	List: ML20080M735 ML20080M756 ML20080M791 ML20080M811
References
ISSUANCES-OL, NUDOCS 8310040262
Download: ML20080M756 (12)

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DOCMETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .

ATOMIC SAFETY AND LICENSING BOARD .

OCT -3 P3:5

'BEFORE ADMINISTRATIVE JUDGES: CFrtctn:nc'h%'

CCCiqihigT Helen F. Hoyt, Chairman '"

E!G"Cri Dr. Emmeth A. Luebke-Dr. Jerry Harbour In the . Matter of ) Docket Nos.

) 50-443-OL 2C3LIC SEPVICE COMPANY OF ) 50-444-OL NEW EAMPSHIRE, et al. )

(Seabrook Station, Units 1 and 2) ) September 29, 1983

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ATTORNEY GENERAL BELLOTTI'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO TEE STATE OF NEW HAMPSHIRE ON EMERGENCY PLANNING FOR THE STATE OF NEW HAMPSHIRE

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INSTRUCTIONS FOR USE 4

Attorney General Francis-X. Bellotti hereby requests that the State of New Hampshire, pursuant to 10 C.F.R. S S_2. 74 0 ( 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 the responses to interrogatories l

t below, and that subsequent to filing answers to these I interrogatories and producing documents therein identified, the -

State file supplemental responses and produce additional 1

documents as required by 10 C.F.R. S2.740 (e) .

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Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, report) and state the fol. lowing 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 dccument.

The term " document [s]" as tsed 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, i

dera=ds, menoranda, 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 commcnications, notebooks, diaries, sketches, diagrams, maps, forms, manuals, brochures, lists, publications, drafts, telephone winutes, minutes of meetings, statements, calendars, journals, c_ _ers, confirmations and all other written or graphic materials of any nature whatsoever.

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INTERROGATORIES 1.

Please identify and produce all documents within the ,

possession, custody, or control of the State of New Hampshire cr .any officer or agency thereof [ hereinafter, "the State"]

which contain or refer to any actual or potential revisions or additions to the draf t New Hampshire Radiological Emergency Ferponse Plan submitted to FEMA Region 1 on or about May 12, 19E3 [ hereinafter, "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, or 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 the j

State's possession, custody, or control which refer to the cmergency response needs or resources of the State or means for .

satisfying the St' ate's resource requirements, or upon which the State relies in support of its capability to satisfy its

resource requirements, in 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;

d. radiological monitoring and assessment equipment;

e. dosimeters and respiratory equipment for emergency workers;

f. manpower for traffic management and access 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. - Does othe State currently have adequate resources within i

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the State in each of the areas identified in subparagraphs 2a -

21. above to implement-its emergency plan? State the bases for yo:r 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 answers.

4. .If your answer to question 3 was in the negative as

. regards any areas of emergency response capability, is it the

. State's position that. the necessary additional resources can be precured 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.

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5. In the opinion of the State, what is the greatest cumber of " contaminated injured individuals" who could be in

=eed cf redical treatment in the event of a radiological emergency at Seabrook Station? State the bases for your answer in detail, describing the types of injuries and sources or Le els of contarination for which your estimate accounts, and the type of redical treatment which would be ' required for each such injury or level of contamination. Include in your es-irate all contaminated injured individuals who could be helped in any way by medical treatment. Ident'ify and produce al'. dcccments upon which you rely for any portion of your answer.

6. In the cpinion of the State, can the health care facilities identified in the RERP provide to the number of cortaricated injured individuals specified in your answer to interrocatory 5 all medical treatment which could be of help to them? If not, can such treatment be 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 doccments opon which you rely. List all medical facilities other than those identified in the RERP which might be required l to provide care to assure that the full number of persons mpecified in your answer to interrogatory 5 receive all treatment which could be of help to them.

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7. In the opinion of the State, what percentage of the energency response officials and personnel identified in the P.23F- vill, 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 se:h emergency response officials and personnel will first enscre that their families are being taken care of before repcrting to duty and what will be the length of the delay in assemption of emergency responsiblities resulting therefrom?

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

B. In the opinion of the State, 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 ancunts requiring protection? [See RERP, lat 2.7-3] State the bases for your answer in detail, identifying the source and cunbers .of replacement workers and specifying the bases for assurance they will be available in a timely fashion. Identify anc produce all documents upon which you rely in support of ro:r answers.

9. Has the State established an emergency action level sciene consistent with that established by the Applicants?

State the bases for your response in detail and identify and

pred=ce any documents upon which you rely in support of your l answer.

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10. Has the State estahlished procedures for notification of all emergency personnel by each of the State elaergency rezponse organiza.tions? 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. 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

=eans in detail and identify and produce all d'cuments o within the State's possession, custody, or control relating thereto, including any documents relating in any way to a siren or other audible alert system for the Seabrook vicinity.

12. In the opinion of the State, 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 and produce any documents within the State's possession, custody, or control which refer or relate in any way to evacuation routing or traffic management in the event of a radiological emergency at Scabrook.

14. Identify and produce all documents within the State's possession, custody, or control which relate in any way to the capacity or building material of buildings in the coastal New Earpshire cormunities within ten miles of the Seabrook site, the number of such buildings which are-insulated, the number of su:h buildings which have basements, the level or degree of pr:tection efforded by such buildings against radionuclides, or

the feasibility of sheltering the summer beach and seasonal ,

l pe;ulations within those communities in such buildings.

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15. In the opinion of the State, do the provisions in the FI?? for segrential notification by New Hampshire Civil Defense cf all State response organizations following verification by C?E, -and the provisions allowing a 15-minute lapse between an emergency classification by the licensee and notification of l Civil Defense and reauiring that notification of the State rerponse 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 do=tments upon which you rely.

16. In the opinion of the State, is the RERP adequate and capable of being implemented as required by 10 C.F.R. 55C.47(a) (2) ? Does it provide reasonable assurance that i

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adequcte protective measures can and will be taken in the event of a radiological emergency at Seabrook Station as required by 10 C.F.R. S50.47 (a) (1) ? Does it satisfy all of the planning standards set forth at 10. C.F.R. 550.47 (b) (1) - (16), as addressed by the criteria of NUREG-0654, -Rev. 17. If your answer to any of these questions is anything other than an en calified af firmative response, state in detail all respects in which the RERP ~ fails to satisfy the . stated requirement, describe the revisions or additions thereto which are necessary to achieve compliance, and indicate what measures the State is ta'r.ing (or will take) to make such revisions or additions and the projected date for their completion. Identify and produce all documents upon which you rely for any of your answers.

17. In the opinion of the State, can the transient beach population in the New Hampshire coastal communities within ten ziles of the Seabrook site be protected from all adverse health effects potentially associated with radiation exposure by means cf evacuation in the event of a radiological emergency at Seabrook Station? If your answer is in the negative, indicate l vhat adverse health effects 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 the State, can the seasonal residents in the beach areas within ten miles of the Seabrook site be protected from all adverse h~ealth effects potentially asscciated 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 peptlation and the numbers of such persons who may potentially experience each such effect. Whether your answer is in the affirrative or negative, state the bases for it in detail and identify and produce all documents upon which you rely.

19. In the opinion of the State, what is the most efficient evacuation routing scheme for the seasonal and transient beach populations in the coastal New Hampshire concurities 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 those assumed by Costello, Lomasney

& deNapoli/C.E Maguire in their " Final Draf t of Appendix E l Emergency Planning Zone Evacuation Time Study"? . If the answer ,

in both cases is no, does the State intend to prepare revised

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evacuation time estimates based on the most efficient routing schere? When will such estiates be prepared?

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20. In the opinion of the State, what traffic management plans or traffic controls will lead to the most efficient evacuation of the. seasonal and transient beach populations in

.the ccastal New Hampshire communities within ten miles of the si:e? State the bases for your answer in detail and identify an' produce any documents upon which you re.'y. Have these traf fic controls and management plans been reflected in the evac =ation time estimates prepared by the Applicants? those prepared by C. E. Maguire? If the answer in both cases is no, does the State intend to prepare revised evacuation time esti=a:es based on such plans and controls? When will such es: ira:es he prepared?

21. How many emergency vehicles, and what type, can the State provide to local communities that request emergency transportaticn? [See RERP, at 2.6-9] How many drivers can the State supply?

22. What will the effect be on ovacuation times for the reascnal and beach populations in the coastal New Hampshire communities of directing vehicles to act:ess control points for decontacination? What will be the health effects associated with a_ lowing persons to evacuate to other than reception ,

{ cen:ers se that they (and the family members or friends with v5cr they stay) will continue to be exposed to contaminated vehicles?

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23. What health effects will result from evacuation on a ho scz=er day with closed windows and ventilation systems?

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

24. What assurance does the State have that it can obtain a sufficient quantity of radioprotective drugs early enough to cse then for protection of emergency workers? [See RERP, at 1.3 - 10]

25. Identify each person whom the State expects to call as a vitness on any of the admitted contentions relative to the FI.:P, state his or her qualifications, and describe the subject tatter on which he or she is expected to testify.

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