ML20197G590

Objections & Responses to State of Nh First Set of Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence

ML20197G590
Person / Time
Site:	Seabrook
Issue date:	05/13/1986
From:	Janetos D HAMPTON, NH
To:	NEW HAMPSHIRE, STATE OF
References
CON-#286-139 NUDOCS 8605160299
Download: ML20197G590 (12)

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j -X l UNITED STATES OF AMERICA M NUCLEAR REGULATORY COMMISSION  ; 'My[9 -

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l ATOMIC SAFETY AND LICENSING BOARD

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In the matter of:

PUBLIC SERVICE COMPANY OF Docket Nos. : 50-443 NEW HAMPSHIRE and 50-444 Seabrook Station, Units 1 and 2 May 13, 1986 TOWN OF HAMPTON OBJECTIONS AND RESPONSE TO STATE OF NEW HAMPSHIRE'S FIRST SET OF INTERROGATORIES AND REOUEST EQE PRODUCTION QI DOCUMENTS II. GENERAL INTERROGATORIES G.J. Please identify those contentions admitted by the Board's Order of April 1, 1986 on which the Town of Hampton intends to introduce evidence in this proceeding.

ANSWER: The Town of Hampton intends to introduce evidence on all contentions filed by the Town heretofore or hereafter which are admitted by the Board. As an " interested party," the Town of Hampton reserves the right to introduce evidence on contentions filed by other partcipants to this proceeding as authorized by 10 CFR S 2.715 (c) .

L.2 For each contention identified in Interrogatory G.1, please identify all persons whom the Town of Hampton intends to call as witnesses. Please include a s um m a ry of the educational and prof essional background of each identified witness.

ANSWER: Glyn Eastman, Chairman, Hampton Board of Selectmen; Dona Janetos, Vice Chairman, Hampton Board of Selectmen; John Walker, Board of Selectmen; Ashton Norton, Board of Selectmen; Ansell Palmer, Hampton Board of Selectmen; Philip Richards, Hampton Town Manager; Robert Mark, Hampton Police Chief; Anthony Kuncho, Town of Hampton Fire Chief; George Hardardt, Hampton Public Works Director; Norman Katner, Hampton School Superintendent. All of the above-named individuals shall testify as to deficiencies in the State RERP for Hampton on grounds of lack of personnel, inadequate equipment, and inadequate available protective measures, including sheltering, in the event of radiological emergency as more fully set forth in Bases to Hampton Contentions IV, VI, and VIII. Glen French, Executive Director of the Hampton Chamber 8605160299 860513 PDR ADOCK 05000443 G PDR m e.es c o. . :. ..s.,r.re.. ,

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j .d i of Commerce, shall join with the above-named witnesses to testify with l respect to Town of Hampton population estimates set forth in the State RERP.

! The Town of Hampton reserves the right to identify additional

! witnesses, including experts, for testimony at the licensing hearings when this inf ormation becomes available.

M Provide a reasonable description of the substance of the testimony of each witness on each of the contentions identified in the answer to Interrogatory G.l. Please also identify all documents which will be relied on in that testimony.

ANSWER: See Answer to Question G.2. By way of f urther answer, the Town of Hampton has not determined what documents shall be relied upon in testimony. The Town of Hampton further objects to this interrogatory to the extent it seeks the town's work product.

III. INTERROGATORIES RELATED IQ SPECIFIC CONTENTIONS CONTENTION HAMPTON 1,Y Hamoton IV.1 I

I Has the Town of Hampton estimated the non-auto owning population I in the Town of Hampton? If so, how was the estimate made? Please indicate the numbers of such non-auto owning persons. Please identify all documents supporting this response.

ANSWER: No.

Hamoton IV.2 Has the Town of Hampton estimated the population of the Hampton l schools? Please indicate the population of the Hampton schools.

Please identify all documents supporting this response.

ANSWER: Yes. As of 4/25/86: Center School, 412 students; Marston l School, 226 students; Hampton Academy Junior High School, 529 students; ,

Winnacunnet School, 1201 students; additional estimates shall be l provided upon receipt. Inf ormation obtained from the Hampton School District.

Hamoton IV.3 How many school buses does the Town of Hampton own? How many l school buses does the Hampton School District own?

ANSWER: None.

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How many buses does the Town of Hampton believe would be necessary to ensure a proper response in the event of a radiological emergency at l the Seabrook Station? Please explain the basis of this response and '

I identify all documents supporting the response.

) ANSWER: This interrogatory is objected to on grounds the information sought is inadmissible and is not reasonably calculated to '

lead to the discovery of admissible evidence. The Town of Hampton has already specifically advised the State and all parties to this proceeding that it does not intend to participate in or provide assistance in the f orm of personnel or equipment f or the State RERP prepared f or Hampton. Any equipment in the possession of, or owned by, the Town of Hampton is theref ore irelevant to this proceeding. By way of further answer, the Town of Hampton objects to this interrogatory on grounds that the State, by this question, attempts to shif t the burden

to the Town to specify what would constitute an adequate emergency plan f or the Town of Hampton. The sole issue in this proceeding, however, is whether the State plan prepared f or Hampton, and f or other af f ected municipalities provide reasonable assurance of adequate protective measures. Since the State has failed to request or permit the Town of Hampton to have input into the State RERP prepared for Hampton, inf ormation sought in this interrogatory is irrelevant.

Hamoton IV.5 Are the buses owned by the Town of Hampton or the Hampton School District available for use in an evacuation in the event of an ,

emergency at the Seabrook Station? If not, please explain why not, i ANSWER: See Answers to Questions Hampton IV.3 and Hampton IV.4.

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CONTENTION HAMPTON Y.I l Hamoton VI.1 i

Please explain how the Town of Hampton arrived at the population estimates given in section (A) of the basis of this contention. Please identify all documents supporting this response including, without limitation, documents relating to the total available parking capacity,

! business receipts used in population computation, documents relatng to the extent of seasonal shif ts and the demand f or municipal services, f and documents containing data relied upon by the Town of Hampton in i establishing the population estimates. I ANSWER: As set f orth in the basis to Hampton Contention VI, the Town relied upon estimates and computationc prepared by the Hampton Chamber of Commerce, including the Affidavit of Glen French, Executive Director for the Hampton Chamber of Commerce, previously provided to

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k i all parties in this proceeding. By way of further answer, the Town of l Hampton objects to production of the documents requested on grounds

such docements constitute trial preparation materials, 10 CPR i

S 2.7 4 0 (b) (1) , and further objects to said request for production to the

' extent it seeks documents not within the possession or control of the l Town of Hampton.

Hamoton VI.2 Please state whether the daily peak populations identified by the Town in section (A) of the basis of ths contention refers to the number of people estimated to be in the Town at any given moment, or the number of people who are expected to be in the Town for some part of a given day. If the population totals refer to the estimated numbers of persons in the Town of Hampton over the course of an entire day, please state whethe. this is the population figure that should be relied upon f or state and local emergency planning f or Seabrook Station. If not, plase state what population figure should be relied upon for state and local emergency planning for Seabrook Station.

ANSWER: The daily peak population identified by the Town in section (A) of the basis of this contention refers to the number of people estimated to be in the town at any given moment.

Hameton VI.3 Please explain why eighty (80) regular and special town police officers are not adequate to carry out the functions assigned the Hampton Police Department in the Hampton RERP.

ANSWER: See Answer to Interrogatory Hampton IV.4. Without waiving this objection, approximately 50 of the 80 are "special" police 3

officers without State Police Academy training or training in advanced law enforcement. These "special" officers are typically hired for the

summer only. Additionally, even assuming adequate training, 80 officers cannot reasonably be expected to control or regulate tens of 1 '

i thousands of townspeople and beach goers during an evacuation.

J Hamoton VI.4 Please explain why the "special of ficers" lack the experience, skill, training to provide emergency response f unctions in the event of a radiological emergency.

ANSWER: See Answer to Inter roga tory Hampton IV.4 and VI.3.

Hamoton VI.5 Please describe the training presently provided by the Town of Hampton and the State of New Hampshire to regular and special police 4

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I of ficers f or the Town of Hampton. What additional training must, in b personnel?-the Town of Hampton's opinion, be provided f or its police department ANSWER: See Answers to Interrogatories Hampton IV.3 and IV.4.

I Hamoton VI.6 Please explain why sixty (6 0) public works personnel are not sufficient to carry out the emergency response f unctions assigned to the Hampton Department of Public Works.

ANSWER: See Answer to Interrogatory Hampton IV.4. Without waiving this objection, see basis to Hampton Contention VI which specifically addresses this question.

Hampton VI.7 Please describe the training provided by the Town of Hampton and the State of New Hampshire to the Department of Public Works full-time and temporary employees.

ANSWER: See Answer to Interrogatories Hampton IV.4.

Hamoton VI.8 What additional training, in the estimation of the Town of Hampton, is required to ensure that the Department of Public Works employees emergency.

can adequately respond in the event of a radiological ANSWER: See Answer to Interrogatory Hampton IV.4.

Hamoton VI.9

. Please describe the problems f oreseen by the Town of Hampton in

' ensuring that all evacuation roads are serviceable throughout the course of an evacuation.

ANSWER: See Answer to Interrogatory Hampton IV.4. By way of i f urther answer, see Basis to Town of Hampton Contention V previously served upon the State and all parties to this proceeding.

Hamoton VI.10 Please explain why the Public works Department personnel cannot adequately keep the roads serviceable in the event of an emergency at Seabrook Station.

ANSWER: See Answers to Interrogatories Hampton IV.4 and VI.6.

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Hamoton VI.ll ll -

l Please describe the training currently given by the Town of l Hampton and the State of New Hampshire to the Board of Selectmen I concerning their emergency response and civil defense duties, i

f ANSWER: See Answer to Interrogatory Hampton IV.4. This I

interrogatory is further objected to on grounds that the State of New Hampshire is fully aware of all training, if any, presently provided by the State to the Board of Selectmen concerning their emergency response and civil defense duties.

Hamoton VI.12 Please explain how this training should be improved to ensure that the Board of Selectmen can properly respond to a radiological emergency at Seabrook Station.

ANSWER: See Answer to Interrogatory Hampton IV.4.

Hamoton VI.13 Please explain the basis for the responses given to Interrogatories VI.3-VI.12, and identify all documents supporting those responses.

, ANSWER: See Answer to Interrogatory Hampton IV.4. By way of further answer, this interrogatory is objected to on grounds it is vague and overly broad. The Town of Hampton has already provided f ull and complete answers to Interrogatories V I . 3 -V I .12 to the extent consistent with the Board's discovery rules. The Town is further unaware of any requirement to supply a " basis" for answers to interrogatories or to provide documents in support of such " basis."

, CONTENTION HAMPTON VIII I

l Hamoton VIII.1 Please describe the procedures currently in place for effectuating

an evacuation of the beach population in the Town of Hampton.

ANSWER: None. l Hamo_ ton VIII.2 What provisions must be made in the NHRERP, including the Hampton l RERP, to provide reasonable assurance that adequate and immediate i

protective measures will be available to-the beach population in the Town of Hampton? Please describe in this response all currently L

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existing procedures for evacuating the beaches which should be incorporated in the NERERP, including the Haa:pton RERP. Please explain the basis of this res-ponse and identify all docunents supporting the response.

ANSWER: Thii inerrogatory is objected to on grounds set fortn in Hampton Interrogatory IV.4 Dated: May 13,1936 e

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Dona R. Janetos ,y Vice-Chairman V Town of Hampton, New Hampshire State of New Hampshire Rockingnan, ss. May 13, 1986 Personally appeared Dona R. Janetos, Vice-Chairman of the Board of Selectmen for tne Town of Hampton, and swore to the truth of the foregoing statements based upon her personal knowledge, information and belief.

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l b j UNITED STATES OF AMERICA  ! C, NUCLEAR REGULATORY COMMISSION M4Y{.; 3 g, -

l BEFORE THE ATOMIC SAFETY AHD LICENSING BOARD

! l lIn the matter of '

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'PUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL NEW HAMPSHIRE, et al. 50-444 OL (Seabrook Station, Units 1 and 2)

CERTIFICATE QE SERVICE I hereby certify that copies of Town of Hampton Objections and Response to State of new H a m p s hi r e 's First Set of Interrogatories and Request for Production of Documents in the above-captioned proceeding have been served on the following by deposit in the United States mail on this 13th day of May, 1986.

Helen Hoyt, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 (For Federal Express Mail)

Helen Hoyt, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission East West Towers Building 4th Floor 4350 East West Highway Bethesdia, MD 20814 Dr. Jerry Harbour Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1

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!Beverly Hollingworth l209WinnacunnetRoad lHampton, NH 03842 Sandra Gavutis, Chairman Board of Selectmen RFD 1 Box 1154 Route 107 Kensington, NH 03827 1

Dr. Emmeth A. Luebke Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Carol S. Snieder Assistant Attorney General

. Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 Stephen E. Merrill Attorney General George Dana Bisbee Office of the Attorney General 25 Capitol Street Concord NH 03301-6397 Richard A. Hampe, Esq.

New Hampshire Civil Defense Agency 35 Pleasant Street Concord, NH 03301 Calvin A. Canney, City Manager City Hall l 126 Daniel Street t

Portsmouth, NH 03801 1

1 Roberta C. Pevear State Representative Town of Hampton Falls

! Drinkwater Road l

Hampton Falls, NH 03844 2 l l

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i Robert A. Backus, Esq.

l Backus, Meyer & Solomon i 116 Lowell-Street

! Manchester, NH 03106

! Edward A. Thomas Federal Emergency Management Agency i

442 J.W. McCormack (POCH) i I Boston, MA 02109 H. Joseph Flynn, Esq.

Assistant General Counsel Federal Emergency Management Agency 500 C Street, S.W.

Washington, D.C. 20472 Jane Doughty Seacoast Anti-Pollution League 5 Market Street Portsmouth, NH 03801 Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Allen Lanipert I Civil Defense Director Town of Brentwood 20 Franklin Street Exeter, NH 03833 Angie Machiros, Chairman Board of Selectmen i 25 High Road i

Newbury, MA 09150 Jerard A. Croteau, Constable 82 Beach Road P.O. Box 5501 Salisbury, MA 01950 Diane Curran, Esq.

Harmon & Weiss 2001 S Street, N.W.

Suite 430 l Washington, D.C. 20009 i

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• l Philip Ahrens, Esq.

, Assistant Attorney General Office of the Attorney General i

State House Station, #6 Augusta, ME 04333 Thomas G. Dignan, Jr., Esq.

! Ropes & Gray l! 225 Franklin Street j Boston, MA 02110 l Atomic Safety and Licensing Board j U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docket and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

j J.P. Nadeau, Esq.

Selectmen's Representative i

Board of Selectmen 10 Central Road Rye, NH 03870

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Michael Santosuosso, Chairman Board of Selectmen South Hampton, NH 03827 Stanley W. Knowles, Chairman Board of Selectmen P.O. Box 710 North Hampton, NH 03862 j William Armstrong Civil Defense Director i Town of Exeter

! 10 Front Street l Exeter, NH 03833 Peter J. Matthews, Mayor City Hall Newburypor t , MA 09150 l

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! William s. Lord Board of Selectmen Town Hall - Friend Street Amesbury , MA 01913 Mrs. Anne E. Goodman, Chairman

, Board of Selectmen i 13-15 Newmarket Road I Durham, NH 03824 i

Gary W. Holmes, Esq.

l Holmes & Ellis l 47 Winnacunnet Road l Hampton, NH 03842 Sherwin E. Turk, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814 I Dated: May 13, 1986 qz7

& <. L EvN Matthew T. Brock, Esq.

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