ML20197G784

FEMA Response to New England Coalition on Nuclear Pollution First Set of Interrogatories & Requests for Production of Documents Re State & Local Emergency Plans.Certificate of Svc Encl.Related Correspondence

ML20197G784
Person / Time
Site:	Seabrook
Issue date:	05/13/1986
From:	Flynn H, Eric Thomas Federal Emergency Management Agency
To:	NEW ENGLAND COALITION ON NUCLEAR POLLUTION
Shared Package
ML20197G761	List: ML20197G757 ML20197G784
References
OL, NUDOCS 8605160403
Download: ML20197G784 (8)

Text

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o 5/13/86 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY LICENSING BOARD ,

In the Matter of )

)

Public Service Co. of New Hampshire, ) Docket No. 50-443, et al. ) 50-444

) (Offsite)

(Seabrook Station, Units 1 & 2) )

RESPONSE OF THE FEDERAL EMERGENCY MANAGEMENT AGENCY TO THE NEW ENGLAND C0ALITION ON NUCLEAR POLLUTION'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS The Federal Emergency Mangagement Agency (FEMA) is not a party to the above-captioned proceding and is, for that reason, not obligated to respond to the interrogatories propounded by any intervenors. FEMA voluntarily provides the information supplied below, but reserves the right to object to future discovery requests.

Interrcoatory No. 1:

With respect to each contention and subpart thereof admitted by the Licensing Board's order of April 1,1986, please provide the following information:

a. What is FEMA's position with respect to each contention and its subparts? Describe in detall the reasons for your position. Identify any relevant portions of state and local plans that are under revision or which the state expects to change at any time in the future.

8605160403 860513 PDR ADOCK 05000443 G PDR _,

b. Identify ano provide access to all documents on which you rely during this proceeding to support your position on each of these contentions. This .

includes all docu:nents used in answer to these interrogatories, summary disposition, testimony, and cross-examination of witnesses during hearings. -

c. Identify all persons on whose factual knowledge, opinions, or technical expertise you rely for your positions on each contention and subpart thereof.

d. Identify all persons you may call as witnesses on each of these

contentions during these proceedings; describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.

Answer No. 1:

a. To date, FEMA has not developed any positions specifically regarding the admitted contentions or their subparts. To the extent that the issues

raised therein have already been considered, FEMA's position is reflected in the documents identified in Answer No. 2, below. FEMA has no knowledge of any portions of the state and local plans that are under revision or which the state of New Hampshire expects to change at any time in the future other than that provided by the materials served on the parties by the Attorney General of New Hampshire on May 5, 1986.

b. See Answer No. i(a).

c. See Answer No. 1(a).

d. To date, FEMA has not identified the witnesses it will or may call on the admitted contentions.

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Interroaatory No. 2:

Ident1fy and provide access to all documents in which FEMA or its contractors has assessed the adequacy of the state and local emergency plans

~

with respect to any of the issues admitted for litigation by the Licensing Board's order of April 1, 1986.

Answer No. 2:

As indicated in Answer 1(a), FEMA has not developed a position specifically with respect to the admitted contentions. FEMA has assessed in draft or final form the adequacy of the New Hampshire plan submittals of December, 1985 and February, 1986 and the exercise of February 28, 1986.

Empirically, these assessments address many of the issues raised by the admitted contentions. FEMA and the NRC Staff have arranged that these documents will soon be reprodOced and served on all parties to the ASLB proceeding. These docments, which are identified below, represent the only publically released evaluations by FEMA, its contractors, and the RAC of the New Hampshire plans for responding to a radiological accident at the Seabrook Nuclear Power Plant.

a. FEMA report of the deficiencies observed during the February 26, 1986 exercise of the state and local plans to protect the public in the event of an accident at Seabrook together with a cover letter dated April 4, 1986 from Edward A. Thomas to Richard H. Strome transmitting and explaining the report.

b. Final Draft Report of the Exercise of the emergency plans for Seabrook held February 26, 1986, together with a cover letter dated April 30, 1986 from Edeard A. Thomas to Richard H. Strome.

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c. Firal Reilew by FD4A ard the Regional Assistarme Conmittee (RAC) of the state ard local plans autnitted by New Hapshire in December,1985, to-gether with a coter letter dated April 30, 1986, fran Ederd A. Thcmas to Richard H. Strome.

d. Draf t'PUiA ard RAC Review of the state ard local plans submitted by New Hampshire in February,1986, together with a cover letter dated April 30, 1986, fra. Edward A. Thcmas to Richard H. Strane.

DEX'IARATICH I declare, tr. der penalty of perjury, that the foregoirg responses to the New Englard Coalition on Nuclear Pollution's First Set of Interrogatories ard Request for Production are true.

EDERD A. 'm0 MAS Chief Natural ard Technological Hazards Division, Region I ,

Federal Emergency Management Agency l Dated May /1 ,1986 i

at Boston, Massa &usetts l 4-

-,,n . ,- - -- , ---

1 i

OBJECTION

' FEMA objects to these interrogatories to the extent they seek the producti0n of draft or privileged documents, except as to those draft documents' identified herein. See 10 C.F.R. gg 2.740(b)(1); cf. 10 , j C.F.R. g 2.790(a).

. Respectfully submitted, NH. Josept)J1ynn k-p' Assistant General Counsel FEMA t

J

_ _ - -- _ ___ _ _ --_ _____ = =__-__-_:_-________--____-_________---_______

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PUDLIC SERVICE COPIPANY OE ) Docket Nos. 50-443 OL NEW HAf1PSHIRE, et al. ) 50-444 OL

)

(Seabrook Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of (1) "NRC STAFF'S RESPONSE TO NECNP'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR THE PRODUCTION OF DOCUMENTS TO THE NRC ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS" and (2) " RESPONSE OF THE FEDERAL EMERGENCY MANAGEMENT AGENCY TO THE NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS" 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, through deposit in the Nuclear ReFulatory Commission's internal mail system or, as indicated by a double asterisk, by hand delivery, this 13th day of May,1986.

Helen Hoyt, Esq. , Chairman

• Dr. Emmeth A. Luebke*

Administrative Judge Administrative Judge Atomic Safety e.nd Licensing Board Atomic Safety and Licensing Board  !

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D. C. 20555 Dr. Jerry Harbour

• Carol Sneider, Esq.

Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor Uashington , D.C. 20555 Boston, MA 02108 Beverly IIollingworth Stephen E. Merrill, Esq.

209 Winnacunnet Road Attorney General Hampton, Nil 03842 George Dana Bisbee, Esq.

Assistant Attorney General Sandra Gavutis, Chairman Office of the Attorney General Board of Selectmen 25 Capitol Street RFD 1 Box 1154 Concord, NH 03301-6397 Kensington, NH 03827

Calvin A. Canney, City Manager Allen Lampert City Hall Civil Defense Director ^

126 Daniel Street Town of Brentwood Portsmouth, Nil 03801 20 Franklin Street

, Exeter, NH 03833 Poberta C. Pevear -

L State Representative Angie Machiros, Chairmr.n Town of Hampton Falls Board of Selectmen Drinkwater Road 25 High Road Hampton Falls, FH 03844 '

Newbury, MA 09150 Mr. Robert J. Harrison Jerard A. Croteau, Constable President and Chief Executive Officer 82 Beach Road, P.O. Box 5501 Public Service Co. of New Hampshire Salisbury, MA 01950 P.O. Box 330 Manchester, NH 03105 Diane Curran , Esq.**

Ilarmon & Weiss Robert A. Backus, Esq. 2001 S Street, N.W.

Backus, Meyer a Solomon Suite 430 116 Lowell Street Washington, D.C. 20009 Manchester, NH 03106 Edward A. Thomas Philip Ahrens, Esq.

Federal Emergency Management Agency Assistant Attorney General 442 J.P'. McCormack (POCH) Office of the Attorney General Boston, MA 02109 State House Station, #6 Augusta, ME 04333 H.J. Flynn, Esq. Thomas G. Dignan, Jr. , Esq.

Assistant General Counsel Ropes & Gray rederal Emergency Management Agency 225 Franklin Street 500 C Street, S.W. Boston, MA 02110 Washington, D.C. 2047?

Jane Doughty Atomic Safety and Licensing Seacoast Anti-Pollution League Board

• 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, D.C. 20555 i

Atomic Safety and Licensing Paul McEachern, Esq. '

Appeal Panel

• Matthew T. Brock, Esq.

U.S. Nuclear Regulatory Commission Shaines & McEachern Washington, D.C. 20555 25 Maplewood Avenue P.O. Box 3ti0 Portsmouth, NH 03801

. Docketing and Service Section* William Armstrong Office of the Secretary Civil Defense Director Town of Exeter

^

U.S. Nucl. ear Regulatory Co:amission Washington, D.C. 20555 10 Front Street Exeter, NH 03833 Maynard L. Young, Chairman .

Board of Selectmen Peter J. Matthews, Mayor 10 Central Road City Hall Pye, NH 03870 Newburyport, MA 09150 Michael Santosuosso, Chairman William S. Lord Board of Selectmen Board of Selectmen South Hampton, NH 03827 Town Hall - Friend Street Amesbury, MA 01913 Stanley W. Knowles, Chairman Mrs. Anne E. Goodman, Chairman Board of Selectmen Board of Selectmen P.O. Box 710 13-15 Newmarket Road North Hampton, NP 03862 Durham, NH 03824 j R. K. Gad III, Esq. Gary W. Holmes, Esq.

Ropes a Gray Holmes & Ellis 025 Franklin Street 47 Winnacunnet Road Boston, MA 02110 -

Hampton, NH 03842 Richard A. Hanpe, Esq.

New Hampshire Civil Defense Agency 107 Piercant Street Concord, NH 03301 h ok Sherwin E. Turk Deputy Assistant Chief Hearing Counsel