ML20202F932

Third Suppl to Answers to Interrogatories Re Offsite Emergency Planning & Request for Production of Documents,Per Board 860624 Order Granting Applicant Motion to Compel.W/ Certificate of Svc.Related Correspondence

ML20202F932
Person / Time
Site:	Seabrook
Issue date:	07/08/1986
From:	Doughty J SEACOAST ANTI-POLLUTION LEAGUE
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#386-954 OL, NUDOCS 8607150266
Download: ML20202F932 (8)

Text

gg\ enubcoeRuaAhsiggig UNITED STATES OF AMERICA '

DOCKETED USNRC NUCLEAR REGULATORY COm1ISSION before the .

14 pll:yg ATOMIC SAFETY AND LICENSING 1RBA/BD. E CRWn 00 crit B C SEH#IV In the Matter of PUBLIC SERVICE COMPANY OF Docket Nos. 50-443-OL NEW HAMPSHIRE, ET AL 50-444-OL (Seabrook Station, Units 1 and 2) Off-Site Emergency Planning and Safety Issues THIRD SUPPLEMENT TO SAPL'S ANSWERS TO APPLICANTS' OFF-SITE '

EP INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS In response to the Board Order of June 24, 1986 granting Applicants' motion to compel responses to interrogatories, SAPL J

joined in a motion with the Town of Hampton Falls and Town of South

! Hampton filed on July 3, 1986 which asked for reconsideration of that part of the Board's Order which determined that SAPL ought to 4

respond to interrogatories addressed to contentions sponsored by other parties.

Applicants' motion to compel also sought responses to General Interrogatories G-1 through G-3. As was stated earlier in the Joint Objection and Motion for Protective Order filed by SAPL, Hampton Falls and South Hampton on June 6, 1986, General Interrogatories G-1 and G-2 were responded to by SAPL in the context of the answers to the specific Interrogatories to the extent that they applied. SAPL still regards General Interrogatory G-3 es calculated solely to f harass and annoy. Nonetheless, without waiving objection, SAPL i

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,' 9607150266 860708 PDR  !

! l G ADOCK 05000443 PDR _

O O responds to G-3 as it applies to each of the specific interrogatories a

responded to in SAPL's answers of May 12, 1986 as follows:

Answers to G-3 XXXV-1 N/A*1 XXXV-2 SAPL answered this interrogatory based upon the EPA document cited, but then discussed the answer for confirmatory purposes with Dr. Jan Beyea.

(a) See above.

(b) SAPL is aware that Dr. Beyea is affiliated with the National Audubon Society and that he has been affiliated with Princeton University.

(c) Jane Doughty telephoned Dr. Beyes prior to filing responses to the interrogatories.

(d) Dr. Beyea mentioned that confirmatory measurements were very important, particularly when, as in the case of TMI, off-site monitors were not functioning properly if at all.

(e) N/A XXXV-3 See response to M V-2.

1 XXXV-4 through XXXV-8 N/A i

1 3

XXXVI-1 N/A XXXVI-2 Yes.

(a) Donald L. Hertoerg, M.D. l (b) See SAPL's May 12, 1986 response at XXXVI-4.

(c) Jane Doughty has spoken with Dr. Herzberg several .

times over the span of several years. Dr. Herzberg j was a guest speaker at a SAPL quarterly meeting and  ;

Dr. Herzberg and Jane Doughty both were ' guest speakers on a panel on nuclear energy at Phillips Exeter

, Academy. Bruce Deming, a legal intern for Robert i Backus and Jane Doughty also met with Dr. Herzberg

1. *N/A means ei ther that G-3 asks a non-applicable ques tion or that no one was consulted in preparing the response submitted on May 12, l 1986.

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4 back in 1983 or so on the subject of the Radiological Emergency Response Plan. Further, Dr. Herzberg filed a comment on the Draft Environmental Statement for ,

S ea b r on't Stat ion dated July 2, 1982.

(d) This information is available in Dr. Herzberg's

! affidavit filed with SAPL's responses to motions for summary disposition filed on June 9, 1986.

i 1 (e) SAPL has transmitted information to Dr. Herzberg

related to the plans.and NRC documents. SAPL does not have a compilation of all such correspondence.

l XXXVI-3 N/A

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XXXVII-1 through XXXVil-8 N/A J

j XXXVII-9 Someone supplied SAPL with the Town of Hampton Selectmen's j letter but SAPL cannot recall specifically who that was, a

XXXVII-10 N/A l

XXXVII-11 Yes.

(a) SAPL obtained this information from either or both j Sandra Mitchell or Benjamin Lovell.

I (b) SAPL's Field Director has not inquired about the educational background of either of these individuals. Mrs. -Mi tchell is a housewife and Mr.

j Lovell is affiliated with a firm specializing in socially responsible investing.

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! (c) Jane Doughty telephoned each of these individuals to ask the answer to this specific interrogatory around the time when SAPL was preparing its responses.

1 (d) The answer provides the detail.

4 (e) There are none relevant to this answer.

j XXXVil-12 SAPL's bel i e f t ha t the State has insuf ficient manpower is i based in part on many conversations with local seacoast

, citizens and of ficials. It would not be possible to specify j each such individual since SAPL could not possibly recall

all of them. There are many many people who offer this i opinion.

l XXXVIII-1 N/A 1

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XXXIX-1 N/A 1 XL-1 N/A XL-2 through XL-5 N/A XL-6 Yes.

(a) Paul Labonte.

(b) SAPL does not know Mr. Labonte's background other l

than that he is an employee of New England Telephone.

(c) Jane Doughty telephoned Mr. Labonte once or twice prior to responding to this interrogatory. The date of the first call was February 1, 1986.

(d) Mr. Labonte expressed the opinion that it is possible to overload the commercial phone sys tem and that this might be reasonably anticipated if an accident were to occur at Seabrook. This provides a basis for SAPL's concern about rellance on the commercial phone system because there is no guarantee that phone service will be available to all who seek to employ i t.

i' (e) SAPL has some rough notes of the first call to Mr.

Labonte.

XL-7 See answer to XL-6.

XL-8 N/A XLI-1 and XLI-2 N/A XLII-1 N/A XLII-2 N/A XLII-3 Yes.

j (a) Representative Roberta Pevear.

(b) Representative Pevear is the Civil Defense Director of Hampton Falls and a member of the New Hampshire General Court. SAPL does not recall Mrs. Pevear's educational background. l l

(c) Jane Doughty called Representative Pevear to inquire l about her knowledge of individuals in Hampton Falls j l

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requiring special transportation assistance. The date of this specific conversation was not recorded.

SAPL did not inquire if the person in the Curtis Guest Home had been identified to NHCDA.

i (d) See above.

(e) No record was made of the above conversation except for the reference to it in SAPL's contention.

XLil-4 See the answer to XXXVII-12 above.

4 Supplemental Information in Response to XXXV-9 SAPL encloses herein the curriculum vitae of Dr. Richard l

l Piccioni, Ph.D., in further answer to Applicants' Interrogatory I XXXV-9.

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] Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By: b_m> N Jane' Doughty Q f DATE: j g igg STATE OF NEW HAMPSHIRE COUNTY OF HILLSBOROUGH Then personally appeared the above-named Jane Doughty and acknowledged that the foregoing answers to Applicants' Interrogatories G-1 through G-3 are true and correct to the best of her knowledge and belief.

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-Nata r y-Publ i c/J us t i ce o f the Peace

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RICHARD G. PICCIONI SENIOR STAFF SCIENTIST ACCORD RESEARCH AND EDUCATIONAL ASSOCIATES 314 W. 91st ST.

NEW YORK, N.Y. 10024

(212) 580-3889 EDUCATION:

1979 -1980 Postdoctoral Fellowship, Laboratory of Biophysics, The Rockefeller University.

1977 -1979 Postdoctoral Fellowship, Laboratory of Cell Biology, The Rockefeller University.

1972 -1977 Graduate Fellowship, Laboratory of Biophysics, The Rockefeller University. Ph.D, 1977.

1968 - 1972 University of California, Irvine. B.S., 1972.

1 EMPLOYMENT:

1985 - present Data Processing Consultant, Chadmark Systems, Inc., New York City.

1980 - 1985 Assistant Professor, Department of Biological Sciences, Hunter College, City University of New York.

RELEVENT EXPERIENCE:

1986 Consultant to the Coalition Against Food Irradiation, meeting at U.S. Department of Agriculture, Washington, D.C.

1985 Consultant to the Township of West Orange, New Jersey, on remediation of radium contamination of soil surrounding houses.

1984 Testimony presented to the Environmental -

Subcommittee, New York City Council on radwaste incineration. -

t 1983 Testimony presented to the City Council, Mine j i Hill, New Jersey, on the safety of a planned 1

Cobalt-60 irradiation unit.

'o Je 1983 Testimony presented to the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board on the consequences of a serious accident at the Indian Point Nuclear Generating Station.

1980 Testimony presented at the Department of i

Transportation Public Hearing on the transportation of high-level radioactive waste through New York City.

RELEVENT PUBLICATIONS AND PRESENTATIONS:

Pisello, D., and Piccioni, R. Mobile Monitoring of Airborne Radioactives Effluent from the Oyster Creek Nuclear Generating Station. International Perspectives in Public Health 1 (1):7-14, 1984.

Pisello, D., and Piccioni, R. Fetal Mortality and Global Nuclear Weapons Fallout. International Perspectives in Public Health 1 (2):5-9, 1984.

Pisello, D., Putz, R., and Piccioni, R. Nuclear Weapons Fallout and Early Fetal Mortality. Presented at the annual meeting of the American Association for the Advancement of Science, New York City, May, 1984.

Pisello, D., Piccioni, R., and McDaniel, G. Nuclear Weapons Fallout and Fetal Death. Presented at the annual meeting of the American Association for the Advancement of Science, Detroit, May, 1983.

i Franke, B., Pisello, D., and Piccioni, R. The Biological and Health Effects of the Nuclear Industry and Nuclear Weapons: A Current Evaluation. Presented at the annual meeting of the ,

American Association for the Advancement of Science, Washington, D.C., 1983. I e

Harvey, J., Piccioni, R., and Pisello, D. Strontium-90 Released in TMI Venting. Sicherheit in Chemie und Umwelt. March, 1982. [

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Harvey, J., Piccioni, R., and Pisello, D. Critical Comment on the Cleanup of TMI. The Ecologist, May/ June, 1981.

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CERTIFICATE OF SERVICE AND SERVICE LIST Jose Asst.Gn.Cnsl. Helen Hoyt. Chm.

• Thomas Dignan, Esq.*

, Fed. ph FlynnSigmt.

Emerg. Agcy. Admn. Judge Ropes & Gray

500 C.St. So. West Atomic Safety & Lic Brd. 225 Franklin St.

, Washington, DC 20472 USNRC Boston, MA 02110 l Washington, DC 20555

Office of Selectmen Dr. Jerry Harbour

• Docketing & Serv. Sec. *

} Town of Hampton Falls Admin. Judge Office of the Secretary

! Hampton Falls, NH 03S44 Atomic Safety & Lic Brd. USNRC l USNRC Washington, DC 20555 Washington, DC 20555 i

Sherxin E. Turk, Esq.

• Jane Doughty Office of Exec. Legl. Dr.

Dr. Emmeth A. Luebke

Admin Judge SAPL Rg Atomic Safety & Lic. Brd. 5 Market Street Wahsington, DC 205__ USNRC Portsmouth, NH 03801 Washington, DC 20555 f'

i Phillip Ahrens, Esq. Paul McEachern, Esq. Ceorge Dana Bisbee, Esq.

Asst. Atty. General Matthew Brock, Esq. Attorney General's OFF.

l State House, Sta. F6 25 Maplewood Ave. State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsnouth, NH 03801 1

{ Carol Sneider, Esq., Asst.AG Diane Curran, Esq. William S. Iord j One Ashburton Place, Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.

j Boston, MA 02108 Washington, DC 20009 Amesbury, MA 01913 i

Richard A. Harpe, Esq. Maynard Young, Chainmn Sandra Gauvutis i

New Hampshire Civil Defense Board of Selectmen Town of Kingston

Agency 10 Central Road Box 1154 i Harpe & McNicholas Rye, NH 03870 East Kensington, NH 03827 1 35 Pleasant St.

• Concord, NI 03301 i Edward Thomas Mr. Robert Harrison i FBIA Pres, & Chief Exec. Officer l 442 J.W. McContack (P001) PSCO

? Boston, MA 02109 P.O. Box 330 i Manchester, MI 03105 i

l Ecberta Pevear l State Rep.-Town of Hanpt Falls ,

1 Drinkxater Road

,Hanpton Falls, MI 03844 1

i I hereby certify that a copy of the within answers have been sent this i date, #irst class, postage, prepaid, to all counsel on the above service f 4 Q Qil $hfS W j Robert A. Backus I ,

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