ML20155H005
| ML20155H005 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/06/1988 |
| From: | Brock M AMESBURY, MA, SHAINES & MCEACHERN |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| CON-#488-7245 OL, NUDOCS 8810180208 | |
| Download: ML20155H005 (14) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIO!I
.E8 00T 11 P4 :47 Before the ATOMIC SAFETY AND LICENSING BOARD
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October
[9 1988 In the Matter of
)
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Docket Nos. 50,443-tL PUBLIC SERVICE COMPANY OF
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50-444-OL NEW HAMPSHIRE, et al,
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Off-Site Emergency (Seabrook Station, Units 1 and 2)
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Planning
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TOWN OF AMESBURY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANTS ON THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES (SPMC)
INSTRUCTIONS FOR USE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the Applicants with personal knowledge of the f acts or information requested in each interrogatory.
We remind you of your obligation to supplement answers to interrogatories, under 10 C.F.R. 5 2. 74 0 (e) (1) and (2).
All docunents identified in answer to these interrogatories shall be produced within thirty (30) days at the offices of SHAINES &
McEACHERN, P.A.,
25 Maplewood Avenue, Portsmouth, Nea Hampshire.
Alternatively, production of documents may be made within thirty (30) days by forwarding copies to the offices of SHAINES & McEACHERN, P.A.,
25 Maplewood Avenue, Portsmouth, NH 03801.
0010100200 001006 PDR ADOCK 05000443 G
PDR D
The following definitions shall apply to these interrogatories:
1.
"Docunent" shall mean any written or graphic matter or 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, forms,
- manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other j
written or graphic materials of any nature whatsoever, i
2.
"Identifv" with respect to any document shall mean to state 1
the following respecting the document:
its title, its date, the author of the document, the person to whom the document was sent, all 4
l persons who received or reviewed the document, the substance and
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nature of the document, and the present custodian of the document and I
of any and all copies of the document.
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3.
"Identifv" with respect to any action, conduct, or matter i
shall mean state the following regarding any such action or conduct:
the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such 2
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action; to identify any document recording or documenting such action, conduct or matter.
4.
"Identifv" when used in reference to a notural person means i
to set forth the following:
(1) his name; (2) his last known residential address; (3) his last known business address; (4) his last employer; (5) his title or position; (6) his area of responsibility; (7) his business or profession; (8) if any of the above information 23 changed subsequent to the time period referenced in a particular interrogatory, set forth in the
- answer, and label appropriately, current information as well as the information applicable to the time period referenced in the interrogatory.
5.
"Identify" when used in reference to a corporation or other entity 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 any assumed or trade names under which it transacts or has transacted business; (2) the nature or form of such a person, if known; (3) the address of its principal place of business or the principal place where such person is to be found; 3
(4) whethnr Applicants have or have had any relationship or affiliation with such person, its affiliates or subsidiaries, and, if so, a description of such relationship; and (5) if any of the above information has changed subsequent to the time period referenced in a particular interrogatory, set forth in the answer, and label appropriately, current information as well as the information applicable to the time referenced in the interrogatory.
6.
If Applicants object to or claim a privilogo (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 information because of the alleged proprietary nature of the da a, please set forth all reasons and the underlying factual basis for the objection or claim of privilege in sufficient detail to permit the l
Licensing Board to determine the validity or the objection or claim of privilege.
This description by Applicants should include with respect to any document:
(1)
- author, addressor, addressee, recipients of I
indicated and "blind" copies together with their job titles; (2) date of preparation; (3) subject matter; (4) purpose of 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, If an objection to any portion of an interrogatory or document recuest is
- made, the remaining
- portion, not deemed objectionable, shall be fully answered.
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INTERROGATORIES 1.
With respect to each contention and basis admitted by the Licensing Board regarding the SPMC, please provide the following information:
a.
What is the Applicants' position with respect to each contention and basis?
Identify the reasons for your position, b.
Identify all persons you may call as witnesses concerning the SPMC litigation; the particular contention or basis on which each will toutify; the subject matter on which each will testify; the substance of each witness' testimony; the grounds for each opinion or testimony; and identify any documents, indicating the relevant portion and citation, that each witness will rely upon to support his testimony, and any documents which Applicants will offer into evidence through each witness.
c.
Identify all persons on whose factual knowledge, opinions, or technical expertise you rely for your position on each contention and basis.
For each, state the substance of the knowledge, opinions, or technical expertise that Applicants rely on.
2.
Identify any portions of the SPMC that are under revision or are expected to be revised in the future.
Identify the purpose, substance, and expected date of each revision.
3.
Identify and produce all amended, supplemental or additional letters of agreement relied upon by Applicants for personnel, transportation, or other resources to implement the SPMC, and not previously served upon Intervenors.
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4.
Identify any letters of agreement that have been rescinded or abrogated.
5.
State the total number of manned vehicles in each category that are necessary, in a severe, fast-break release, to implement the SPMC for the Town of Amesbury: buses, ambulances, special needs vehicles, other vehicles.
Identify and produce all documents, and state every fact or cpinion upon which you rely to support this answer.
6.
State the total number of manned vehicles in each category that are available for actual use in a severe, fast-break release, to impicment the SPMC for the Town of Amesbury:
- buses, ambulances, special needs vehicles, other vehicles.
Identify and produce all documents, and state every fact or opinion upon which you rely to support this answer.
7.
For all towns within the Massachusetts EPZ, inclurting TOA, state the total number of manned vehicles necessary, in a severs, i
j fast-break release, to implement the SPMC:
buses, ambulances, special 1
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needs vehicles, other vehicles.
Identify and produce all documents, and state overy fact or opinion upon which you rely to support this
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i answer.
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8.
For all towns within the Massachusetts EPZ, including TOA, i
state the total number of manned vehicles claimed available for actual j
use, in a severe, fast-break emergency, to implement the SPMC: buses, ambulances, special needs vehicles, other vehicles.
Identify and I
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produce all documents, and state every fact or opinion upon which you rely to support this answer.
9.
For each school located within the Town of Amesbury, state the total number of personnel in each category who are necessary, in a severe, fast-break release, to implement the SPMC and/or assist students in undertaking protective actions:
- teachers, school administrators, other school personnel, ORO personnel,- For each category, identify under the SPMC, the particular actions or duties to be performed.
Identify and produce every document, and state overy fact or opinion, upon which you rely to support this answer.
10.
For each school located within the Town of Amesbury, state the total number of personnel in each category who are available, in a severe, fast-break release, to implement the SPMC and/or assist students in undertaking protective actions:
- teachers, senool administrators, other school personnel, ORO personnel.
For each category, identify the particular actions or duties to be performed.
Identify and produce every document, and state every fact or opinion, upon which you rely to support this answer.
11.
For each school located within the Massachusetts EPZ, including those in TOA, state the total number of personnel in each category who are necessary, in a severe, fast-break release, to implement the SPMC and/or assist students in undertaking protective actions:
teachers, schoo] administrators, other school personnel, ORO personnel.
For each category, identify under the SPMC, the particular actions or duties to be performed.
Identify and produce every 7
document, and stato every fact or opinion, upon whien you rely to support this answer.
12.
For each school located within the the Massachusetts EPZ,
!.ncluding those in TOA, state the total number of personnel in each 5
category who are availabic, in a severe, fast-break release, to implement the SPMC and/or assist students in undertaking protective j
actions: teachers, school administrM. ors, other school personnel, ORO f
personnel.
For each category, identify the particular actions or f
duties to be perforned. _ Identify and produce every document, and t.
I state every fact or opinion, upon which you rely to support this answer.
13.
Identify and produce all documents, and provide all relevant I
citations to the SPMC, which explain or set forth emergency response plans or procedures for schools located within Massachusetts EPZ.
I 14.
For each special needs facility, other than schools, located within the Town of Amesbury, including TOA Hospital, state the total number of personnel in each category necessary, in a severe, fast-i i
break release, to implement the SPMC and/or assist those with special
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needs to undertake protective actions: doctors, nurses, other medical personnel, ORO personnel.
For each category, identify the particular actions or duties to be performed.
Identify and produce every I
document, and state every f act. or opinion, upon which you rely to j
support this answo-15.
For each special needs facility, other than schools, located within the Town of Amesbury, including TOA Hospital, state the total l
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number of personnel in each category who are available for actual use, in a severe, fast-break release, to implement the SPMC and/or to assist those with special needs to undertake protective actions:
i doctors, nurses, other medical personnel, ORO personnel.
For each
- category, state the particular actions or duties to be performed.
Identify and produce overy document, and state overy fact or opinion, upon which_you rely to support this answer.
16.
Identify and produce all documents, and provido all relevant citations to the SPMC, which explain or set forth emergency response I
plans or procedures for special needs facilities, other than schools, l
located within the Town of Amesbury, including TOA Hospital.
17.
State whether Applicants are in possession, or have l
knowledge, of any admissions by the Town of Amesbury and/or any of its officials, agents, employees or personnel regarding the SPMC and/or the adequacy or inadequacy of emergency planning for Town of Amesbury or the Seabrook EPZ.
If you answer yes, identify and produce each such document and identify tha person making each admission, its date, and substance.
18.
Identify the procedure for detornining specific resources avn11able for actual une in the event of an emergency, as referenced at page 182 of APPLICANTS' RESPollSES TO I!iTERVENORS ' C0!!TEliTIO!1S O!!
THE SEABROOK PLAN FOR MASSACHUSETTS COMMUllITIES (SPMC), dated April 26, 196o, (hereinafter "Response").
Estimate the time necessary for completion of this procedure.
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i 19.
In its Response, Applicants state "the SPMC is structured en the theory that governmental agencies only are called upon to do what
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they would be required to do every day in the absence of an emergency at Seabrook."
- Response, p.
183.
With respect to the Town of Amnabury, identify all ToA personnel which, under the SPMC, may be i
"called upon" in the event of an emergency at See ook Station.
For each person, state the activity, function or service to be performed.
Identify and produce all ciocuments, and stato all facts and opinions upon which Applicants rely to cupport their answer.
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20.
As referenced in 10 C.F.R. I SO. 4 7 (c) (1) (iii) (B), identify the f
"best efforts" that, in Applicants' opinion, TOA will make in the event of a radiological emergency at Seabrook Station.
Identify and l
produce all documents, and state all facts and opinions upon which Applicants rely to su,rport this answer.
l 21.
Identify and explain the training in traffic control provided to oRo staff who may staff traffic control points in an actual l
emergency.
22.
Identify each ORO traffic guide with priot experience in
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traffic management or control.
For each, state the nature and extent of experience.
i 23.
Identify each ORO craffic guide who has
- been, or is l
presently, ceployed as a police officer.
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24.
For ToA, identify how each traffic control point in the SPMC 1
and the number of traffic guides for each traffic control point, were 1
determined.
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25.
Identify how traffic control point B-AM-06 will be managed or centrolled in an actual emergency at Seabrook,
.icl u d i ng all relevant SPMC citations.
26.
Identify and produce all documents (1) on which y' ely to answer these interrogatories or (2) which Applicants intend to offer as exhibits in this proceeding for any purpose.
Respectfully submitted, TOWN OF AMESBURY By Its Attorneys, SHAINES & McEACHERN I
Professional Association D~
October [, 1988 By i
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Dated:
1 Matthew T.
Broct 25 Maplewood Avenue Portsmouth, NH 03801 (603) 436-3110 I
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. a n i tr-2 9 :.'
'88 OCT 11 P4 :47 CERTIFICATE OF SERVICE
..J.
DOCA I,
Matthew T.
- Brock, one of the attorneys fort ithe Town of Amesbury herein, hereby certify that on October 6,
- 1988, I made service of the foregoing document, TOWN OF AMESBURY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANTS ON THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES (S PMC),
by depositing copies thereof in the United States Mail, first class postage prepaid for delivery (or, where indicated, by Express Mail, prepaid) addressed to:
Ivan Smith, Esq., Chairman Dr. Jerry Harbour Atomic Safety & Licensing Board Atomic Sa.ety & Licensing Board (Off-Site)
(Off-site)
U.S.
Nuclear Regulatory Conmission U.S. Nuclear Regulatory Comm.
East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Judge Gustave A.
Linenberger, Jr.
Atomic Safety & Licensing Atomic Safety & Licensing Board Appeal Board Panel (Off-Site)
U.S.
Maclear Regulatory Comm.
U.S.
Nuclear Regulatory Commission Washington, DC 20555 East West Towers Building 4350 East West Highway
- Thomas Dignan, Esq.
Bethesda, MD 20814 George H.
Lewald, Esq.
Kathryn A. Selleck, Esq.
Adjudicatory File Ropes & Gray Atomic Safety & Licensing Board 225 Frankin Street Panel Docket (2 copies)
Boston, MA 02110 U.S. Nuclear Regulatory Commission i
East West Towers Building Carol S.
Sneider, Esq.
4350 East West highway Stephen H. Cleskey, Esq.
Bethesda, MD 20814 Allan R.
Pierce, Esq.
Department of the Atty. General Stephen E.
Merrill, Esq.
One Ashburton Place George Dana Bisbee, Esq.
Boston, MA 02108 Office of the Attorney General State House Annex Diane Curran, Esq.
Concord, NH 03301 Andrea C.
Forster, Esq.
Harmon & Weiss 2001 S Street, N.W.,
Suite 430 Washington, DC 20009-1125 i
i
- Sherwin E. Turk, Esq.
Office of General Counsel U.S. Nuclear Regulatory Commission
- Richard R.
Donovan 15th Floor - One White Flint North Federal Emergency Mgmt. Agency 11555 Rockville Pike Federal Regional Center Rockville, MD 20852 130 228th Street, S.W.
Bothell, Washington 98021-9796 Philip Ahrens, Esq.
Robert A.
Backus, Esq.
Assistant Attorney General Backus, Meyer & Solomon office of the Attorney General 111 Lowell Street State House, Station 6 Manchester, NH
- 03105, Augusta, ME 04333 Jane Doughty Richard A.
Hampe, Esq.
Seacoast Anti-Pollution League Hampe and McNicholas 5 Market Street 35 Pleasant Street Portsmouth, NH 03801 Concord, NH 03301--"
William S.
Lord, Chairman Charles P. Graham, Esq.
Board of Selectman Murphy & Graham Town of Amesbury 33 Low Street Town Hall, Friend Street Newburyport, MA 01950 Amesbury, MA 01913 R.
Scott Hill-Whilton H. Joseph Flynn, Esq.
Lagoulis, Clark, Hill-Whilton Office of General Counsel
& McGuire Federal Emergency Mgmt. Agency 79 State Street 500 C Street, S.W.
Newburyport, MA 01950 Washington, DC 2047j Ashod N. Amirian, Esquire Judith H. Mizner, Esq.
370 Main Strect 79 State Street Haverhill, MA 01830 2nd Floor Newburyport, MA 01950 Senator Gordon J. Humphrey Senator Gordon J.
Humphrey U.S.
Senate One Eagle Square, Suite 507 Washington, DC 20510 Concord, NH 03301 (Attn:
Tom Burack)
(Attn:
Herb Boynton)
P 2
'~ *i_ -r3;y Leonard Kopelman, Esquire Robert R.
Pierce, Esq.
Barbara J.
Saint Andre, Esquire Atomic Safety & Licensing Board Kopelman & Paige, P.C.
Panel 77 Franklin Street U.S. Nuclear Regulatory Comm.
Boston, MA 02110 East West Towers Building 4350 East West Highway J
Bethesda, MD 20814 i
D s
k-s, Matthew T.
Brock
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