ML20154B792

NRC Staff First Set of Interrogatories & First Request for Production of Documents to Towns of Amesbury,Newbury, Salisbury,West Newbury,Merrimac & City of Newburyport.* Certificate of Svc Encl.Related Correspondence

ML20154B792
Person / Time
Site:	Seabrook
Issue date:	09/06/1988
From:	Bergquist S NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	AMESBURY, MA, MERRIMAC, MA, NEWBURY, MA, SALISBURY, MA, WEST NEWBURY, MA
References
CON-#388-7047 OL-1, NUDOCS 8809140135
Download: ML20154B792 (18)

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Uwc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD * '

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In the Matter of PUBLIC SERVICE COMPANY OF Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al. 50-444-OL-1 Offsite Emergency (Seabrook Station, Units 1 and 2) Planning Issues NRC STAFF'S FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO THE TOWNS OF AMESBURY, NEWBURY SALISBURY, WEST NEWBURY, AND MERRIMAC, AND THE CITY OF NEWBURYPORT Pursuant to 10 C.F.R. Il 2.740b and 2.741, the NRC Staff hereby request that the towns of Amesbury, Newbury, Salisbury, West Newbury, and Merrimac, and the city of Newburyport ("Intervenor" or "Intervenors")

individually respond to the following interrogatories, and produce for inspection and copying the documents requested below.

Each interrogatory shall be answered separately and fully and shall include all pertinent infomation available to the above-noted parties, their officers, employees, directors, advisors, representatives, or counsel, based upon the personal knowledge of the person answering. The production of the documents requested herein shall take place at the Hearing Division. Office of the General Counsel, Nuclear Regulatory Comission,11555 Rockville Pike, Rockville, Maryland.

Instructions A. To the extent that Intervenors do not have specific, complete, and accurate infomation with which to answer any interrogatory, Inter.

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2-venors should so state, and the interrogatory should be answered to the extent infomation is available, identifying each person who is believed to have accurate information with respect thereto. Where exact infoma-i tion is not available, estimated infomation should be supplied; the answer should state that the information is an estimate and the basis 1

1 on which the estimate was made. Where appropriate, the upper and lower boundaries of the estimate should be given.

B. Each interrogatory shall be deemed to be continuing, and Intervenors are requested seasonably to supplement answers with additional facts, documents, infomation, and names of witnesses which become known, in accordance with i 2.740(e)(1) and (2) of the NRC's Rules of Practice.

C. The words "and" and "or" shall be construed either conjunctively l

or disjunctively so as to bring within the scope of these discovery requests any infomation that might otherwise be construed to be outside l their scope.

D. Wherever appropriate, the singular form of a word shall be interpreted in the plural, and vice versa, so as to bring within the scope of these discovery requests any information that might otherwise be construed to be outside their scope, i

E. Wherever appropriate, the masculine form of a word shall be interpreted as feminine, and vice versa, so as to bring within the scope l

of these discovery requests any infomation that might otherwise be

construed to be outside their scope.

i F. Please produce each document in the fem and condition in which it exists on the date of service of this request, including all coments,

i 3-notes, remarks, and other material that may have been added to the docu-ment af ter its initial preparation.

G. If Intervenors object to or claim a privilege (attorney client, work product, or other) with respect to any interrogatory or document request, in whole or in part, or seek to withhold documents or informa-i tion because of the alleged proprietary nature of the data, please set forth all reasons and the underlying factual basis for the objection or claim of privilege in sufficient detail to permit the Licensing Board to t l

determine the validity of the objection or claim of privilege, This l description by Intervenors should include with respect to any document:

(1) author, addressor, addressee, recipients of indicated and "blind" t copies together with their job titles; (2) date of preparation; (3) l subject matteri (4) purpose for which the document was prepared; (5) all persons to whom distributed, shown, or explained; (6) present custodian; (7) all persons believed to have a copy of the document; and (8) the nature of the privilege or objection asserted. l H. For any document or part of a document that was at one time. '

i but is no longer, in Intervenors' possession, custody, or control, or which is no longer in existence, or which cannot be located or produced, f identify the document, state where and how it passed out of existence or why it can no longer be located and the reasons therefor, and identify f each person having knowledge concerning such disposition or loss and the I contents of the document, and identify each document evidencing its prior i l

existence and/or any fact concerning its nonexistence or loss. -

l  !. When, in order to answer a question fully or accurately, it is necessary to distinguish between the responses of individual Intervenors [

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or to identify individual Intervenors, such distinctions or identifica-tions should be made in the answer.

Definitions and Guidelines to be Used in Responding to this Request

1. The word "document" as used herein shall mean any written matter, whether produced, reproduced or stored on paper, cards, tapes, disks, belts, charts, films, computer storage devices or any other medium and i shall include, without limitation, matter in the form of books, reports, studies, statements, speeches, notebooks, agreements, appointment 4

calendars, working papers, manuals, memoranda, notes, procedures, orders.

instructions, directions, training materials, records, correspondence, diaries, plans, diagrams, drawings, periodicals, lists, telephone logs, l minutes, photographs, and any published materials and shall also include, 4

without limitation, originals, copies (with or without notes or changes thereon) and drafts.

2. The word "connunications" 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 conversativns, visits,

conferences, internal and external discussions, and exchange of a document or documents.

3. Applicants request that documents produced in compliance with this request be accompanied with an indication as to the particular paragraphs under which the documents are being produced.

4. The word "energencies" shall mean radiological and nonradiological emergencies, and shall include all natural and "manmade" disasters such

5-as floods, tornadoes, fires, hurricanes, earthquakes, riots, industrial accidents, transportation accidents, accidents involving radiation or radiological materials, and accidents involving any other hazardous or dangerous materials.

5. "Intervenor" or "Intervenors" means the towns of Amesbury, Newbury, Salisbury, West Newbury, and Merrimac, and the city of Newburyport, or any of them, or any agency thereof and any agent, employee, consultant, con-tractor, technical advisor, representative or other person acting for or on behalf of them, or at their direction and control, or in concert with or assisting them,

6. "Contractor" means any person, not affiliated with Intervenors, who perfonned work concerning Seabrook on behalf of Intervenors and/or pursuant to a contract with Intervenors or sub-contracto n who performed work on behalf of a contractor with whom the person was not affiliated and pursuant to a contract with such contractor. A person other than a contractor, who contracts with the subcontractor, shall be deemed a sub-contractor.

7. "Concerns." "concerning," or any other derivative thereof, includes referring to, responding to, relating to, pertaining to, in connection with, compromising, memorializing, conenenting on, regarding, discussing, showing, describing, reflecting, analyzing, supporting, contradicting, and constituting.

8. "Identify" when used in reference to a natural person means to set forth the following:

1. his name;

2. his last known residential address;

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3. his last known business address; i

4. his last employer;

5. his title or position; l

6. his area of responsibility; j

7. his business, professional, or other relationship with [

Intervenors; and >

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8. if any of the above infumation is changed subsequent to the time period referenced in a particular interrogatory, i set forth in the answer, and label appropriately, current J 6

q information as well as the information applicable to the i time period referenced in the interrogatory.

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9. "!dentify" when used in reference to a corporation or other entity l I that is not a natural person shall mean to set forth the following:

1. the full name of such person, including its legal name and j j any assumed or trade names under which it transacts or has I transacted business; j i

i i 2. the nature or form of such a person, if known;

3. the address of its principal place of business or the l

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principal place where such person is to be found; l 4, whether intervenors have or have had any relationship or I affiliation with such person, its affiliates or subsid-1 aries, and, if so, a description of such relationship; and 5

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5. if any of the above infomation has changed subsequent to l'

the time period referenced in a particular interrogatory, I

set forth in the answer, and label appropriately, current i l

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7 information as well as the information applicable to the time referenced in the interrogatory.

10. "Identify" when used in reference to a document shall mean to set forth the following:

1. its title;

2. Its subject matter;

3. its date; 4

4. itsauthor;I

5. its addressee;

6. its file designation or other identifying designation; and

7. its present location and present custodian.

11. "Identify" with respect to a contact or comunication shall mean to set forth the following:

1. the date of the comunication;

2. the place of the making and place of receipt of the communication;

3. the type and means of comunication; '

4 the substance of the communication;

5. each person sking a comunication, and his location at the time the comunication was made;

6. each person to whom the comunication was made, and his location at the time the comunication was made;

7. all other persons present during, participating in, or receiving the comunication and the location of each such person at the time;

8. each document concerning such comunication; and

9. each document upon which the comunication is based or which is referred to in the comunication.

Interrogatories and Requests for Production of Documents

1. Identify and supply each document containing procedures, plans, orders, instructions, directions, and training materials of the Inter-venors for any action in the event of:

(a) a radiological emergency or disaster steming from a nuclear plant accident whether the plant is located inside or outside of Massachusetts; (b) other radiological emergencies or disasters; and (c) all other "emergencies" or disasters as defined in paragraph 4 of the above definitions.

2. With regard to each document set out in response to Interrogatory 1.

describe the functions in emergencies of any of the following categories of personnel:

(a) State and local police, to include persons employed full or part time, and both private and public security personnel, such as special officers and deputies; (b) Civil Defense personnel; (c) Professional or volunteer fire-fighting personnel; (d) First aid and rescue personnel;

,(e) local support services personnel including Civil Defense /

Emergency Service personnel;

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(f) Medical support personnel; (g) Emerge:,cy Service personnel; (h) Health and Environmental Department personnel; (1) National Guard. Militia or Reserve personnel; (j) Boards of Education. School Boards or Departments, and teachers; (k) Employees of all other State, local or municipal departments or agencies; (1) Individuals obligated to provide assistance pursuant to agreements to aid between municipalities or other government units, or pursuant to other agreements; and (m) Individuals available to provide assistance pursuant to agree-ments to aid between municipalities or other government units, or pursuant to other agreements.

3. Set out the training each of the category of personnel set out in Interrogatory 2 has to perform its functdon in an "emergency."

4 Identify the Massachusetts Civil Defense agency areas in which the Seabrook plume emergency planning zone (EPZ) is located. Provide the Civil Defense Plans for those areas and for the Comonwealth.

5. Identify the number of individuals in each of the personnel categories listed in Interrogatory 2(a).(m), and the number of such personnel: (a) within the 10 mile EPZ plume exposure pathway; (b) from 10 to 25 miles of Seabrook Station; (c) from 25 to 50 miles of Seabrook Station; (d) from 50 to 100 miles of Seabrook Station; and (e) within the Comonwealth of Massachusetts outside the aforementioned areas.

6. Identify the types and number of the following resources available for use in the event of emergencies pursuant to the documents identified

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in Interrogatory 1: (a) police vehicles; (b) fire trucks; (c) buses; (d) vans; (e) other vehicles; (f) helicopters and other aircraft; (g) boats; l

1 (h) sirens and public notification systems; (1) radios; and (j) all other i

equipment.

1. Identify the resources enumerated pursuant to Interrogatory 6(a)-(j),

4 according to their location: (a)withinthe10-mileEPZplumeexposure pathway; (b) from 10 to 25 miles of Seabrook Station; (c) from 25 to 50 miles

• teabrook Station; (d) fron 50 to 100 miles of Seabrook I

Station N d (e) within the Commonwealth of Massachusetts outside the aforementioned areas.

1 8. Identify the number and location of Massachusetts National Guard j Units in each of the Intervenor jurisdictions, the number of members of j each unit, their distance from the Seabrook plume exposure EPZ, and the

r. umber and location of the following resources available for use by the National Guard in emergencies: (a) cars;(b) trucks;(c) vans;(d) heli-copters; (e) other means of transportation; and (f) cormunication facili-l ties, including radios and other means of public notification. Supply the same information for any Militia or Reserve unit in such jurisdiction. I/ -

9. Identify any plans made for radiological monitoring in the event of a radiological emergency from any cause: including (a)thenumberandloca-i tion of personnel trained and available to accomplish such monitoring, and (b) a dew.iption and enumration of radiological monitoring equipment J./ If any of the data sought under Interrogatory 8 are withheld an the ground they are classified, pisase indicate the type )f data so withheld.

available for use in such an emergency, alcng with identification of the equipment's location.

10. Identify any provisions made for handling of individuals contaminated in a radiological emergency stemming from any cause, including (a) the number and location of personnel trained and available to assist in decontamination of contaminated individuals, and (b) a description and enumeration of equipment avai,ible for use in decontamination, along with identification of the equipment's location.

10a. Identify all doct'"ents in your possession identifying facilities in Massachusetts which have or claim to have equipment, personnel or expertise to treat radiologically contaminsted individuals. Supply such documents.

11. Identify any provisions made by the Massachusetts Department of Agriculture, or other state or local governmental agency, concerning protective measures to be used for the 50-mile ingestion pathway from any nuclear plant, including the methods for protecting the public from consuinption of contaminated foodstuffs; and identify any procedures for detecting contamination, 'or imposing protective measures such as inter-diction of food supply, impoundment, or quarantine, and for public notificatior, concerning fnod contamination and the protective measures to be followed.

12. Identify the number of Massachusetts Civil Defense personnel according to location within the Comorwealth, and identify the amount and location of equipment available for their use to protect the pub

in the event of an emergency. Set out the training of Civil Defense personnel.

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13. Identify the location of stations authorized to broadcast under Federal Emergency Broadcast System (EBS) regulations and the Massachusetts EBS Operational Plan ("Operational Plan"). Provide a copy of the Oper-ational Plan.

14 Identify all documents, agreements and communications dated within the last five years concerning the operation of the EBS. Produce a copy of all such documents, agreements and communications.

15. Identify the provisions of federal or state law which preclude activation of the EBS at the discretion of management of AM, FM, and television stations, in connection with day-to-day emergency situations posing a threat to the safety of life and property, such as hurricanes, .

floods, icing conditions, heavy snows, fires, toxic gases, power failures, industrial explosions, and civil disorders.

16. List all Federal funds received by any Intervenor jurisdiction during the past 5 years for purposes of developing plans, procedures, manuals, and other documents concerning responses to emergencies, and identify, with respect to aach such document, under w' hat statutes these funds were provided and the Federal agencies or departments from which the funds were received.

17. With respect to each document identified in Interrogatory 1, identify any Federal or state law or regulation pursuant to which each such docu-ment was prepared.

18. Identify all Massachusetts statutes and regulations, and all local regulations, ordinances or other provisions (a) cm.cerning actions to be taken by state or local suthorities, or those acting in their behalf, in the event of emergencies, including the preparation of plans for actions

to be taken in emergencies; (b) concerning any prohibitions on any such actions or plans; and (c) concerning any prohibitions on any person or organization other than state or local authorities with respect to any such actions or plans.

19. Set out the conditions, including citations to all applicable provisions of state and local laws and regulations, (a) under which state and local authorities may permit private individuals or organizations to take action on their behalf in an emergency; and (b) under which state and local authorities are precluded from authorizing private individuals or organizations from taking action on their behalf in an emergency.

20. Set out examples illustrating the conditions described in Inter-rogatory 19(a) and (b).

21. Define what you consider to be "the beach" in the Massachusetts portior the Seabrook Station EpZ. Set out the geographic boundaries of i nst "beach" area.

22. Using the definition of "the beach" you supplied in answer to interrogatory 21, provide the following data, along with a copy of any study or other document relevant to the following infonnation: (a)the maximum numoer of cars at the beach on the 10 busiest days within the last five years, along with indication of the time and date of such maxima; (b) the number of cars remaining at the beach following each 1/2-hour interval for the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the aforementioned maxima; (c) the number of cars entering and leaving the beach during each 1/2-hour interval within the 8-hour period. If you do not have data for 1/2-hour intervals, supply such data for the periods you have. Indicate whether the foregoing compu-tations wt.re made manually or automatically.

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'3. Identify all studies conducted during the last five years concerning improving the movement of traffic in and out of "the beach" area. Provide a copy of all such studies.

24. Identify all studies conducted durinp the last five years concerning improving the movement of traffic in the event of emergencies within the Seabrook Station '.'PZ which include estimates of the volume of traffic or the time within which traffic can be evacuated. Provide a copy of ali such studies.

25. Identify all State and local laws and regulations concerning the following actions to be taken in the event of radiological or other emergencies (see definition 4): (21 guiding traffic; (2) blocking road-ways, erecting barriers in roadways, and channeling traffic; (3) posting traffic signs on roadways; (4) removing obstructions from public roadways, including towing private vehicles; (5) activating sirens and directing the broadcast of EBS' messages; (6) making decisions and recomendations to the public concerning protective actions; (7) making decisions and recom-mendations to the public concerning protect:ye actions for the ingestion exposure pathways; (8) making decisions and recomendations to the public concerning recovery and reentry; (9) dispensing fuel from tank trucks to automobiles along roadsides; and (10) performing access control at the Emergency Operations Center, the relocation centers, and the EPZ perimeters.

26. Identify all studies perfonned during the last five years concerning the availability and possible use of sircns and other means of emergency comunication to the public in the event of emergencies. Provide a copy of all such studies.

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27. Identify all sirens or other means of emergency communication in the Seabrook EPZ which can be heard by the general public.

28. Identify all studies performed by Intervenors during the last five years concerning planning for emergencies. Produce a copy of all such studies.

Respectfully submitted, Stephen A. Bergquist Counsel for NRC Staff Dated at Rockville, Maryland this 6th day of September, 1988 I

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.OUETE0 UNITED STATES OF AMERICA um NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '88 SEP 12 P2 :30 In the Matter of arria r, ,

Docket Nos. 50-44300t h 4 i r w:i~

PUBLIC SERVICE COMPANY OF 50-444 OL WID NEW HAMPSHIRE, et al. ) Off-site Emergency Planning

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(Seabrook Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO THE TOWNS OF AMESBURY, NEWBURY, SALISBURY, WEST NEWBURY, AND MERRIMAC, AND THE CITY OF NEWBURYPORT" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Comission's internal mail system, this 6th day of September 1988.

Ivan W. Smith, Chairman (2)* Atomic Safety and Licensing Administrative Judge Board Panel (1)*

Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 Docketing and Service Section*

Gustave A. Linenberger, Jr.* Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Comission Washington, DC 20555 Thomas G. Dignan, Jr. , Esq.

Robert X. Gad, III, Esq.

Dr. Jerry Harbour

• Ropes & Gray Administrative Judge 225 Franklin Street Atomic Safety & Licensing Board Boston, MA 02110 U.S. Nuclear Regulatory Comission Washington, DC 20555 H. J. Flynn, Esq.

Assistant General Counsel Atomic Safety and Licensing Federal Emergency Management Agency Appeal Panel (5)* 500 C Street, S.W.

U.S. Nuclear Regulatory Comission Washington, DC 20472 Washington, DC 20555

Philip Ahren, Esq. Calvin A. Canney Assistant Attorney General City Hall Office of the Attorney General 126 Daniel Street l State House Station Portsmouth, NH 03801 Augusta, ME 04333 Mr. Angie Machiros, Chairman Carol S. Sneider, Esq. Board of Selectmen Assistant Attorney General 25 High Road Office of the Attorney General i;ewbury, MA 09150 One Ashburton Place, 19th Floor Boston, MA 02108 Allen Lampert Civil Defense Director George Dana Bisbee, Esq. Town of Brentwood Assistant Attorney General 20 Franklin Office of the Attorney General Exeter, NH 03833 25 Capitol Street Concord, NH 03301 William Annstrong Civil Defense Director Ellyn R. Weiss, Esq. Town of Exeter Diane Curran, Esq. 10 Front Street I Harmon & Weiss Exeter, NH 03833

, 2001 S Street, NW Gary W. Holmes, Esq.

Suite 430 Washington, DC 20009 Holmes & Ellis l 47 Winnacunnet Road l Robert A. Backus, Esq. Hampton, NH 03842 Backus, Meyer & Solomon 116 Lowell Street J. P. Nadeau Manchester, NH 03106 Board of Selectmen 10 Central Street Paul McEachern, Esq. Rye, NH 03870 Matthew T. Brock, Esq. .

Shaines & McEachern Judith H. Mizner, Esq, 25 Maplewood Avenue Silverglate, Gertner, Baker, P.O. Box 360 Fine, & Good Portsmouth, NH 03801 88 Coard Street Boston, MA 02110 Charles P. Graham, Esq.

McKay, Murphy & Graham Robert Carrigg, Chairman 100 Main Street Board of Selectmen Amesbury, MA 01913 Town Office Atlantic Avenue Sandra Gavutis, Chainnan North Hampton, NH 03870 Board of Selectmen RF0 #1, Box 1154 Kensington, NH 03827

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'- - 3-William S. Lord Peter J. Matthews, Mayor Board of Selectmen City Hall Town Hall - Friend Street Newburyport, MN 09150 Amesbury, MA 01913 Michael Santosuosso, Chairman Mrs. Anne E. Goodman, Chairman Board of Selectmen Board of Selectmen South Hampton, NH 03827 13-15 Newmarket Road Durham, NH 03824 Ashod N. Amirian, Esq.

Town Counsel for Merrimac Hon. Gordon J. Humphrey 376 Main Street United States Senate Haverhill, MA 08130 531 Hart Senate Office Building Washington, DC 20510 Stepheh A. Bergquist ' (/

Counsel for NRC Staff