ML20080M811

Interrogatories & Requests for Documents Re Emergency Planning for State of Nh.Certificate of Svc Encl

ML20080M811
Person / Time
Site:	Seabrook
Issue date:	09/29/1983
From:	Bellotti F MASSACHUSETTS, COMMONWEALTH OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20080M740	List: ML20080M735 ML20080M756 ML20080M791 ML20080M811
References
ISSUANCES-OL, NUDOCS 8310040277
Download: ML20080M811 (11)

Text

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UNITED STATES OF AMEFICA NUCLEAR REGULATCRY CC" MISSION ._

ATOMIC SAFETY A"D LICENSING BOARD $3 gJ 3 g g BEFORE ADMINISTPATIVE JUDGES: hhh(I NG &

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Helen F. Hoyt, Chairman Dr. Emmeth A. Luebke Dr. Jerry Harbour ,

In the Matter of ) Docket Nos.

) 50-443-OL PUBLIC SERVICE COMPANY CF ) 50-444-OL NEW HAMPSHIRE, et al. )

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

)

)

ATTORNEY GENERAL BELLOTTI'S INTEFFOGATORIES AND REQUESTS FOR DOCUMENTS TO APPLICANTS ON EMEPGENCY PLANNING FOP THE STATE OF NEW HAMPSHIPE INSTPUCTIONS FOP USE Attorney General Francis X. Bellotti hereby requests that the Applicants, pursuant to 10 C.F.R. SS2.740(b) and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories snd produce and permit inspection and copying of the original or best copy of all documents identified in the responses to interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents therein identified, the Applicants file supplemental responses and produce additional documents as required by 10 C.F.R. S2.740 (e) .

0310040277 830929 PDR ADOCK 05000443 0 PDR

Where identification of a document is recuested, briefly describe the document ' (e.g. , book, letter, memorandum, report) and state the following information as applicable for the 4

particular document: name, title, number, author, date of  ;

publication and publisher, addressee, date written or approved, s

and the name and address of the person (s) having possession of the document.

I 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,.1'etters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, i

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.

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_3 INTERROGATOFIES

1. Please identify and produce all documents within the Applicants' possession,-custody, or control 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

[ 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,

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distribution, or use of radioprotective drugs, or plans f r ,

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 Applicants' possession, custody, or control which refer to the emergency response needs or resources of the State of New Hampshire or means f or satisfying the State's resource requirements, or upon which the Applicants rely in support of the State's capability to satisfy its resource requirements, in any of the following areas:

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

[ b. emergency medical transportation;

c. medical treatment for contaminated injured individuals; i 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.

J- 3. In the opinion of the Applicants, does the State of New

Hampshire currently have adequate resources within the State in each of the areas identified in subparagraphs 2a - 21. above to implement its emergency plan? State the bases for your answer including your bases for determining what in detail,

constitutes an adequate quantity or level of each such i,

resource, and identify and produce all documents upon which you i

rely.in support of your answers.

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

regsras any areas of emergency response capability, is it the l

Applicants' position that the necessary additional ~ resources a

can be procured on a timely basis from outside the State? If so, identify- the types, 'guantities and sources of all such

[ additional resources and specify the time within which they will be available to the State following its request therefor.

e Identify and produce all dccuments upon which you rely in support of your. answers.

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5. In the opinion of the Applicants, what i s the greatest; number of " contaminated injured individuals" who could be,in

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- need of medical 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

- levels of contamination for which your estimate. accounts, and the type of medical treatment which would be recuired for each such injury or level of contamination. . Include in your estimate all contaminated injured individuals who could be helped in any way by medical treatment. Identify and produce

< all' documents upon which you rely for any portion of your answer.

6. In the opinion of the Applicants, can the health care facilities identified in the PERP provide to the number of contaminated injured individuals specified in your answer to i

interrogatory 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 documents upon which you rely. List all redical facilities other than those identified in the RERP which might be recuired to provide care to assure that the full number of persons specified in'your answer to interrogatory 5 receive all treatment which could be of he'p to them.

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7. In the opinion of the Applicants, what percentage of the emergency response officials and personnel identified in tre 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 th a t their f amilies 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 the Applicants, will there be the adequate personnel available on a timely basis to replace local emergency workers removed from the emergency zone if workers are removed due tc releases of radionuclides other than I-131 in amounts requiring protection? [See RERP, at 2.7-3]

State the bases f or 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 the Applicants, has the State of New Hampshire established an emergency action level scheme censistent 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 the Applicants, has the State of New Ear.pshire established procedures for notification of all erergency personnel by each of the state emergency response organizations? If so, describe those procedures in detail.

Identify and produce all documents within the Applicants' refer to such possession, custody, or control which contain or of your answers.

procedures or upon which you rely in support

11. In the opinion of the Applicants, has the State of New Harpshire 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 the Applicants' including any possession, custody, or control relating thereto, documents relating in any way to a siren or other audible alert system for the Seabrook vicinity.

12. In the opinion of the Applicants, how will local emergency response organizations i-n 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 possession, custody, or control of the Applicants which refer or relate in any way to evacuation routing or traf fic Seabrook.

management in the event of a radiological emergency at

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14. Identify and produce all documents within the Applicants' possession, custody, or centrol which relate in any way to the capacity or building 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. In Applicants' opinion, can sheltering be relied upon as a protective option for the transient beach populations in the coastal New Hampshire communities? for the seasonal population in those communities? State the bases for your answer in detail and identify and produce any documents upon which you rely.

16. Identify each person whom Applicants expect to call as a witness on any of the admitted contentions relative to the REEP , state his or her qualifications, and describe the subject matter on which he or she is expected to testify.

CERTIFICATE OF SERVICE 00gMJED I, Jo Ann Shotwell, Esquire, counsel for Massachusett g" t m 3 General Francis X. Bellotti, hereby certify that on September 9,yy p3 :19E3,5 I

made se'Ivice of Attorney General Bellotti's Interrogatories and Requests For Docunents To Applicants On Francis Emergency t 4 R$st Hampshire, Attorney General X. Planning For TheGBellotti's Notice b N}D h$f 56n'-Of Witnesses On Emergency Planning For State of New Hampshire, Attorney General Francis X. Bellotti's Interrogatcries And Requests For Documents To The State Of New Hampshire On Emergency Planning For The State Of New Hampshire , and Attorney General Francis X. Bellotti's Interrogatories And Pequests For Documents To The Federal Emergency Managem'ent Agency On Energency Planning For The State of New Hampshire, by mailing copies thereof, postage prepaid, to the parties named below:

Helen Hoyt, Chairperson

• Rep. Beverly Hollingworth Atocic Safety and Licensing Coastal Chamber of Commerce Board Panel 209 Winnacunnet Road U.S. Nuclear Regulatory Commission Hampton, NH 03842 Washington, DC 20555 Dr. Enme th A. Luebke* William S. Jordan, III, Esquire Atomic Safety and Licensing Diane Curran Board Panel Harmon & Weiss U.S. Nuclear Regulatory Commission 1725 I Street, N.W.

Washington, DC 20555 Suite 506 Washington, DC 20006 Dr. Jerry Harbour

• Edward L. Crost, Jr., Esquire Atonic Safety and Licensing Assistant Attorney General Board Panel Dana Bisbee, Esquire U.S. Nuclear Regulatory Commission Assistant Attorney General l Washington, DC 20555 Office of the Attorney Geheral 208 State House Annex Concord, NH 03301 Atonic Safety and Licensing Appeal Roy P. Lessy, Jr., Esquire

• l Board Panel David A. Repka, Esquire

• l U.S. Nuclear Regulatory Commission Robert G. Perlis, Esquire

• l Washington, D C 20555 Office of the Executive Legal ,

l Director l U.S. Nuclear Regulatory Commission l Washington, DC 20555

• By Express Mail l

l

l Atomic Safety and Licensing Robert A. Backus, Esquire i Board Panel

• 116 Lowell Street U.S. Nuclear Regulatory Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Dr. Mauray Tye Assistant Attorney General Sun Valley Association Department of the Attorney 209 Summer Street General Haverhill, MA 01830 Augusta, ME 04333 David R. Lewis

• Thomas G. Dignan, Jr., Esquire **

Atocic Safety and Licensing Robert K. Gad, III, Esquire **

Board Panel Ropes & Gray U.S. Nuclear Regulatory Commission 225 Franklin Street En. E/W-439 Boston, MA 02110 Washington, DC 20555 Charles Cross, Esquire Ms. Olive L. Tash Shaines, Madrigan, & McEachern Designated Representative of 25 Kaplewood Avenue the Town of Brentwood P.O. Box 366 R.F.D. 1, Dalton Road Portsnouth, NH 03801 Brentwood, NH 03833 Roberta C. Pevear Edward F. Meany Designated Representative of Designated Representative of the Town of Hampton Falls the Town of Rye Drinkwater Road 155 Washington Road Hampton Falls, NH 03844 Rye, NH 03870 Mrs. Sandra Gavutis Calvin A. Canney Designated Representative of City Manager '

the Town of Kensington City Hall RFD 1 126 Daniel Street East Eingston, NH 03827 Portsmouth, NH 03801 Patrick J. McKeon Jane Doughty l Selectmen's Office Field Director 10 Central Road- Seacoast Anti-Pollution League Rye, NH 03870 E Market Street Portsmouth, NH 03801 Richard E. Sullivan, Mayor Docketing and Service Section Town Eall Office of the Secretary ' .

Newburyport, MA 01950 U.S. Nuclear Regulatory Commission Washington, DC 20555

• By Express Mail

• • By Eand Delivery on 9/30/83

• i Brian P. Cassidy Representative Nicholas J. Costello Regional Counsel 1st Essex District FEMA Fecion 1 Whitehall Road Amesbury, MA 01913 John W. McCormack Post Office

& Courthouse Eoston,.MA 02109 Mr. Angie Machiros, Chairman Diana P. Randall Newbury Board of Selectmen 70 Collins Street Town of Newbury, MA 01950 Seabrook, NH 03874 Anne Verge, Chairperson Patrick J. McKeon Chairnac of SelectIcen, Rye, Board of Selectmen New Bacpshire Town Hall South Hampton, NH 03842 10 Certral Road Pye, NH 03870 Donald E. Chick Maynard B. Pearson Town Manager Board of Selectmen Town of Exeter 40 Monroe Street Amesbury, MA 01913 10 Fren: Street New Hampshire 03833 Selectmen of North Hampton Mr. Daniel Girard Tcwn of North Hampton Civil Defense Director New Hampshire 03862 25 Washington Street Salisbury, MA 01930 Senator Gordon J. Humphrey Senator Gordon J. Humphrey 1 Pillsbury Street U.S. Senate Concord, NH 03302 Washington, D.C. 20510 Herb Boynton) (Attn: Tom Burack)

(Attn:

Signed under the pains and penalties of perjury, this 29th day of September , 19 83.

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g jo Ann Shotwerl Wssistant Attorney General Environmental Protection Division Public Protection Bureau One Ashburton Place Boston, MA 02108