ML20151G577

Applicants Second Set of Interrogatories Re Massachusetts Atty General Amended Contention on Notification Sys.W/ Certificate of Svc.Related Correspondence

ML20151G577
Person / Time
Site:	Seabrook
Issue date:	07/15/1988
From:	Selleck K PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	MASSACHUSETTS, COMMONWEALTH OF
References
CON-#388-6777 OL-1, NUDOCS 8807290021
Download: ML20151G577 (10)

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• DOCKETEC USNRC RELATED CORRESPONDE"C1  % Jul. 22 P 2 :16 Gr r tE July 15, 19 88L I. i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-443-OL-1 PUBLIC SERVICE COMPANY OF ) 50-444-OL-1 NEW MAMPSHIRE, et.al. ) On-site Emergency

) Planning Issues (Seabrook Station, Units 1 and 2) )

)

APPLICANTS' SECOND SET OF INTERROGATORIES REGARDING THE MASSACHUSETTS ATTORNEY GENERAL'S AMENDED CONTENTION ON NOTIFICATION SYSTEM Pursuant to 10 C.F.R. 55 2.740b and 2.741, Applicants hereby request that the Attorney General of the Commonwealth of Massachusetts ("Mass AG") respond to the following interrogatories.

General Definitions and Instructions

1. The word "document" as used herein shall ucan any written matter, whether produced, reproduced or stored on paper, cards, tapes, disks, belts, charts, films, computer storage devices or any other medium and shall include, without limitation, matter in the form of books, reports, studies, statements, speeches, notebooks, agreements, appointment calendars, working papers, manuals, memoranda, notes, 8807290021 880715 PDR ADOCK 05000443 G PDR [

records, correspondence, diaries, plans, diagrams, drawings, periodicals, lists, telephone logs, minutes, photographs, and any published materials and shall also include, without limitation, originals, copies (with or without notes or changes thczeon) and drafts.

2. The word "communications" shall mean correspondence, contact, discussion, or any other kind of written or oral exchange between two or more persons or entities including, but not limited to, all telephone conversations, face-to-face meetings or conversations, visits, conferences, internal and external discussions, and exchange of a document or documents.

3. In the event that it is claimed that any document responsive to any request is privileged, each privileged document should be fully identified in writing, signed by counsel, except that the substance thereof need not be described to the extent said substance itself is claimed to be privileged. To "identify" a document claimed to be privileged means to r, tate:

(a) the date on which the document was prepared; (b) the author or authors of the document; (c) the addressee (s) and recipient (s) of the document, if any; (d) the title of the document; (e) the number of pages in the document; and 4

(f) the substance of the document to the extent it is not privileged.

4. Please include, with the answer to each of the interrogatories that follow, the name, institutional affiliation and professional qualifications, if any, of the person who is answering.

5. "Amended Contention on Notification System" shall mean the Mass AG's contention and bases admitted to this proceeding by the On-Site Licensing Reard by Mamorandum and Order dated June 2, 1988. ,

6. If any document required to be identified in these answers has been destroyed and no copy exists within the Mass AG's or the Commonwealth's possession, custody or control, identify the documents, state che date of its destruction, identify the person responsible for ordering destruction, state the purpose of destruction, and (if applicable) identify any document reteltion policy that governed the retention or destruction of the document. To "identify" a document, for all purposes in these requests other than those covered by Instruction #3 above, means to state:

(a) the date on which the document was prepared; (b) the author or authors of the document; (c) the addressee (s) and recipient (s) of the document, if any;-

(d) the title of the document; 1

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(e) the number of pages in the document; and (f) the substance of the document.

7. "Mass AG Response" shall mean the document, entitled "Massachusetts Attorney General's Response to First Set of Interrogatories Regarding the Massachusetts Attorney General's Amended Contention on Notification System", filed on July 12, 1988.

INTERROGATORIES

1. Please define exactly what is meant by "acceptable levels" of sound outputs in Mass AG Response No. 8, citing specific decibel levels, and state in detail all the facts underlying that definition.

2. Please state whether the Mass AG, or any entity or individual contracted to or cooperating with the Mass AG, has performed or intends to perform any calculation (s) to assess the existence or size of "uncovered areas" as that term is used in Mass AG Response No. 8. If so, please state:

(a) who performed the calculation (s), giving the name, institutional affiliation, business address, and professional qualifications, if any, of all individuals involved; (b) the method or manner in which the calculation (s) was performed, including but not limited to any scientific texts or practices relied upon in setting up the calculation (s);

l (c) all data used in the calculation (s);

(d) all results generated by the calculation (s),

indicating which set of data produced which result.

3. Please state in detail what the Mass AG contends are the appropriate technical design specifications for a mobile siron alert system such as Applicants' VANS system, for each of the following variables:

(a) weight of equipment carried; (b) amount of equipment carried; (c) nature of equipment carried; (d) weight distribution of fully extended siren; (e) stress capacity of lifting mechanism; (f) weight of siren; (g) lift capacity and reliability of telescopic crane.

4. please define exactly what is meant by "time required to pack the vehicle" in Mass AG Response No. 18(c), and state in detail all the facts underlying that definition.

5. Please define exactly what is meant by "extreme weather conditions" in Mass AG Response No. 22, and state how frequently such conditions occur in the Massachusetts portion of the EPZ for Seabrook Station.

6. Please state in detail all the facts underlying the Mass AG's assertion that such "extreme weather conditions", as referred to in Mass AG Response No. 22, will cause "snow and ice (to] gather . . . in the sections of the crane through

which its extension takes place and in the mechanism designed to rotate and oscillate the siren," indicating how much snow and ice allegedly would gather under each level of "extreme weather", and how much snow and ice would need to gather before the extension of the crane would be materially impeded.

7. Please state exsctly where in the Design Report the Mass AG asserts that a requirement exists for use of the message mode along public beaches in Massachusetts.

8. Please define, by percentage, exactly what is meant by "a substantial failure rate" in Mass AG Response No. 32, and state in detail all the facts underlying that definition.

9. Please state how frequently each of the "debilitating" weather conditions described in Mass AG Response No. 37 occurs in the Massachusetts portion of the EPZ for Seabrook Station, and state in detail all the facts underlying that answer.

10. Please define exactly what is meant by "virtually impractical", "will rarely fly", "make flight impractical",

and "severe visibility problems" in Mass AG Response No. 37, and state in detail all the facts underlying those definitions,

11. Please state in detail all the facts underlying the Mass AG's assertion that "(a) pilot will never fly in freezing rain because of the ice build-up that occurs on control surfaces", including but not-limited to all facts concerning the amount of ice build-up that occurs under each amount and duration of freezing rain.

12. Please identify all documents upon which the Mass AG has relied, does rely or intends to rely to support his position on the Amended Contention on Notification System. Identify the information in each document on which the Mass AG has relied, does rely or intends to rely and the specific basis and sub-basis of the contention which that information Concerns.

13. If you have not already done so in accordance with Instruction No. 4, please state, for each of the foregoing interrogatories, the name, institutional affiliation, and professional qualifications, if any, of the person (s) answering.

By their attorneys, br- a

~

Thom4s G. Dignan, Jr.

Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith Ropes & Gray 225 Franklin Street Boston, MA 02110 (617)423-6100 DOCKETED s UdNRC CERTIFICATE OF SERVICE I, Kathryn A. Selleck, one of the attorneys for Yae W- Ji 22 P2:16 Applicants herein, hereby certify that on July 15, 1968, I made service of the within document by depositing cop {ei W !wr At-thereof with Federal Express, prepaid, for delivery tP(hjdC '

where indicated, by depositing in the United States mail, first class postage paid, addressed to) the individuals listed below with one exception, namely, Carol S. Sneider, Esquire, Assistant Attorney General, who is being served in hand this date.

Administrative Judge Sheldon J. Robert Carrigg, Chairman Wolfe, Esq., Chairman, Atomic Board of Selectmen Safety and Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Emmeth A. Diane Curran, Esquire Luebke Andrea C, Forster, Esquire 4515 Willard Avenue Harmon & Weiss Chevy Chase, MD 20815 Suite 430 2001 S Street, N.W.

Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney Gnneral Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North, 15th F1.

East West Towers Building 11555 Rockville Pike 4350 East West Highway Rockville, MD 20852 Bethesda, MD 20814

• Atomic Safety and Licensing Robert A. Backus, Esquire l Appeal Board Panel Backus, Meyer & Solomon l U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105

0-Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road l General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Drock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

• Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Clark, Hill-Whilton &

Washington, DC 20510 McQuire (Attn: Tom Burack) 79 State Street Newburyport, MA 01950

• Senator Gordon J. Humphrey Mr. Peter J. Matthews one Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 I

H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301

Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region I 79 State Street, 2nd Floor 442 John W. McCormack Post Newburyport, MA 01950 office and Court House Post Office Square Boston, MA 02109 Charles P. Graham, Esquire Murphy and Graham 33 Low Street Newburyport, MA 01950 (Li ptW6 a

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