ML20204B528

Response of FEMA to Town of Hampton Interrogatories & Requests for Production of Documents to FEMA on State of Nh Radiological Emergency Response Plan.* Related Correspondence

ML20204B528
Person / Time
Site:	Seabrook
Issue date:	03/18/1987
From:	Eric Thomas Federal Emergency Management Agency
To:	HAMPTON, NH
Shared Package
ML20204B533	List: ML20204B528 ML20204B587 ML20204B625 ML20204B669
References
CON-#187-2859 OL, NUDOCS 8703250085
Download: ML20204B528 (6)

Text

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3/18/8/B MAR 23 P3 :14 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f0CM S r I} rf BRANCH BEFORE_THE ATOMIC: SAFETY LICENSING BOARD In the Matter of )

) Docket No. 50-443

.Public Service Co. of New Hampshire, ) 50-444 et al. ) (Offsite)

)

(Seabrook Station; Units 1 & 2) )

RESPONSE OF THE FEDERAL EMERGENCY MANAGEMENT AGENCY TO THE TOWN OF HAMPTON'S INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO FEMA ON THE NEW HAMPSHIRE RERP The Federal Emergency Management Agency (FEMA) is not a party to the above-captioned proceeding and it 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.

Interrogatory No. 1:

With respect to each contention and subparts thereof admitted by the Licensing Board order of February 18, 1987, please provide the following information:

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

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

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o This includes all documents used in answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings.

c. 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.

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

Answer No. 1 (a) FEMA has not developed a specific position regarding the admitted contentions or subparts. To the extent that these issues have been con-sidered FEMA's position maybe reflected in review documents listed below which I understand have been served on the parties. FEHA has no specific knowledge of the portions of the state or local plans that are under review or which the State of New Hampshire expects to change at any time in the future other than the information provided by the status reports served on the parties by the Attorney General of New Hampshire. The list of publicly released documents in which FEMA has evaluated the New Hampshire plans and preparedness for responding to a radiological accident at the Seabrook Nuclear power Plant are:

1) FENA 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 a7 accident at Seabrook, together with a cover letter dated April c.1936 f rom

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Edward A. Thomas to Richard H. Strone transmitting and explaining the report.-

11) Final Draf t Report of the exercise of the emergency plans for Seabrook held February 26, 1986, together with a cover letter dated April 30, 1986 from Edward A. Thomas to

. . Richard H. Strome, iii) Final Report of the exercise of the emergency plans for Seabrook held February 26, 1986, together with a cover letter dated June 6,1986 from Edward A. Thomas to Richard H. Strone.

iv) Final review by FEMA and Regional Assistance Connittee (RAC) of the state and local plans submitted by New Hampshire in December 1985, together with a cover letter dated April 30, 1986 fron Edward A. Thomas to Richard H. 5trone.

v) Draft FEMA and RAC Review of the state and local plans submitted by New Hampshire in February 1986, together with a l

cover letter dated April 30, 1986 from Edward A. Tnomas to l.

l Richard H. Strome.

vi) Final FEMA /RAC Review of the state and local plans submitted by New Hampshire in February 1985 together wit 1 I

a cover letter dated April 30, 1986 from Edward A. Thomas 1

to Richard H. Strome.

vii) Draf t FEMA /RAC Review of the New Hampshire submission of April 16, 1986, together with a cover l etter dated Jule 2.

l 1985 f rom Edward A. Th mas to Ricnard H. Strcma.

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Final FEMA /RAC Review of the NewmHampshire ssion sub on April.16, 1986, together with a' cover letter dated Aug ust 8, 1986 fron Edward A.

ix) Thomas to Richard H. Strome.

Final FEMA /RAC Review of theplans state and local submitted by New Hampshire September 8,1986 with together l a cover letter from Edward A. Thomas dated December 12,51986 . Strometo Richard H I

(b) FEMA has not yet developed a specific position admitted in this proceeding. on the contentions I

documents may be used to support our position b to Interrogatory 1(a) sup,ra. eyond those listed in' response (c) FEPA has not yet identified any persons which i t may call as witnesses in this proceeding and can therefore neith of their testinony nor describe any documents which er describe Upon beyond the documents referenced in such witnesses may rely (d) response to Interroga ory 1(a) s_uora.

Since FEMA has not yet developed a position on any of the contentions admitted in this proceeding, it cannot identif y the persons it may_ rely upon for the positions eventually developed f Interrogatory No. 2 .

2)

i Please identify all persons on whose factual knowlea i  ! ge, opinions,

{ f or technical expertise you rely for your position on each c 1 subpart thereof. oncention and Answer No. 2-As indicated in answer to Town of Hampton's Interro FEMA has not yet developed a specific position gatory No. I g.

with respect to any of the issues admitted for litigation by the Licensing Board .

However, empirically 4

'D it appears likely that the FEMA /RAC revie

ws of the New Hampshire plans and preparedness for coping with an accident at the Seab Plant may assess the adequacy of those planrook Nuclear Power issues admftted for litigation in thisng.proceedids with respe

_ Interrogatory No. 3 Identify and describe any deficiencies FEMA Final Exercise Assessment February 26 , including t the State of New Hampshire have not undertak,1986, for w Answer No. 3 en adequate corrective action.

The analysis of the deficiencies in the Feb ruary 26, 1986 Exercise of the New Hampshfre RERP is set forth in the FEMA Fi for the exercise. nal Exercise Assessment Rev. 2 The listing of inadequacies with respect to the N is set forth in the Final FEMA RAC December 12, 1986 Review for R ev. 2 dated i

FEMA has not yet done an analysis of ywhethar of an the deficiencies 3 listed in the report of th e February 26, 1985 have been corrected. exercise To date, this agency has not received plans other on documents which would correct the inadequaci es found in the hHRERP (Rev. 2).

3 I declare, under penalty of perjury, that the fo t

Town of Hampton's Interrogatories and Request f regoing respon are true. . or Product n of Documents

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Ecward A. Inomas, Division Ghtef Natural I4 Technological Hazards

! Region Dated March 18, 1987 Federal Er ergency Management Agency

! Boston, fiassachusetts l

OBJECTION

' Th'e Federal- Emergency-Management Agency (FEMA) objects generally :to. the

- foregoing interrogatories to the extent that they call for the production'or disclosure of the contents of draft or privileged. documents,'except to the extent that such documents have already been identified or disclosed in the

. foregoing answers. See:10 C.F.R.-s 2.740(b)(1);.cf. 10 C.F.R. 5 2.790(a).

Respectful 1y submitted, 7 $ - 2 ! 31 -

H C40sepjFFlynn . /

Assistant General Counsel Federal Emergency Management Agency.

500 C Street S.H.

Washington, D.C.'20472 T

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