ML20205D777

Commonwealth of Ma Atty General Second Request for Production of Documents to Applicant Re Seabrook Plan for Commonwealth of Ma Communities.* Related Correspondence

ML20205D777
Person / Time
Site:	Seabrook
Issue date:	10/19/1988
From:	Fierce A MASSACHUSETTS, COMMONWEALTH OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20205D699	List: ML20205D695 ML20205D777 ML20205D810
References
OL, NUDOCS 8810270204
Download: ML20205D777 (9)

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gygf.p_CORftESPONDEN9 , j DOCKETED UMGC UNITED STATES OF AMERICA l

NUCLEAR REGULATORY COMMISSION 18 DCT 21 P3:45 ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judges: Orrrr ra . . . <

OfcE ; p; , 4 .,

Ivan W. Smith, Chairman  % ?c Gustave A. Linenberger, Jr.

Dr. Jerry Harbour l

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'In the Matter of ) Docket Nos. 50-443-OL-  !

) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP OF NEW HAMPSHIRE, EI AL. )  ;

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(Seabrook Station, Units 1 and 2) ) October 19, 1988 -

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7 MASSACHUSETTS ATTORNEY GENERAL'S ..

SECOND REQUEST FOR THE PRODUCTION OF DOCUMENTS ~

TO THE APPLICANTS REGARDING THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES Pursuant to 10 C.F.R. S 2.741, James M. Shannon, the Messachusetts Attorney General, hereby requests that the  !

Applicants produce for inspection and copying at the offices of the Attorney General, One Ashburton Place, Bostun, r

Massachusetts, at a mutually agreeable time within tna next 30 l days, the following documents in their possession or under  ;

their control, f

DIEIN I T I O N S._A N D . I t{STR11CT I O t1S ,

f A. As used herein, the term "NHY" shall mean the Public ,

Service Company of New Hampshire's New Hampshire Yankee Division, any of its representatives, officers, employees, agents, servants, affiliates, or subsidiaries. The term "ORO" 0

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9 shall mean NHY's Offsite Response Organization for Massachusetts. The "SPMC" means the Seabrook Plan for Massachusetts Communities, and all appendices, anendments, and attachments thereto. The "Massachusetts EPZ" means the Massachusetts portion of the Emergency Planning Zoae for Seabrook Station.

B. Each document request shall be deemed continuing, and Applicants are requested to supplement responses with additional documents in accordance with $2.704(e) of the NRC's Rules of Practice.

C. As used herein, the term "person" shall mean any natural person, corporation, partnership, firm, trust, group, __

r association or other organization and, where appropriate, the .

use of the singular includes the plural and the use of the plural includes the singular.

D. As used herein, the term "document" shall mean the original, and any and all copies which differ in any way from the original, of any notes, correspondence, memoranda (including written memoranda of telephone conversations, other communications, discussions, agreements and any other acte, transactions or activities), time sheets, contracts, agreements, pamphlets, receipts, order forms, records, bonds, requisitions, bills, plans, blueprints, layouts, drawings, specifications, sound recordings, minutes, diaries, by-laws, votebooks, logs, bulletins, circulars, brochures, forms, Etatements, journals, letters, telegrams, notices, interoffice and intraoffice communications, photostats, microfilms, T

computer records, studies, reports, analyses, messages, comparisons, graphs, charts, summaries, films, photographs, tapes, transcripts, advertisements and any other written matter of any kind including, but without limitation, any marginal conments appearing on any documents or any other writing.

E. As used herein, the term "communication" shall mean any oral, written or electronic transmittal of information, or reyisest for information, made from one person to another person, whether made in person, by telephone or by any other means and includes any documents made only for the purpose of recording a communication, idea, statement, opinion or belief.

F. Wherever appropriate, the masculir.e form of a word __

shall be interpreted as feminine, and vice versa, so as to bring within the scope of these document requests any information that might other rise be construed to be outside their scope.

F. please produce each document in the form and condition in which it exists on the date of service of this request, including all comments, notes, remarks, and othet material that may have been added to the document after its initial preparation.

G. If the plaintiff should withhold any document otherwise responsive to the requests set forth below on the ground of privilege or for any other reason, each such document should be listed and fully identified in writing with sufficient particularity to enable a court to rule on the validity of the ground on which it is withheld, and the ground

O for withholdir.g it should be fully set forth, except that the substance of such withheld document need not be described to the extent it is claimed to be privileged. To "identify" a document means to provide a description sufficient to identify that document for purposes of a subpeona duces tecum and is further to state:

(1) the date on which the document was prepared; (2) the author or authors of the document; (3) the addressee (s) of the document, if any; (4) the title of the document, if any; (5) the number of pages; and (6) the substance thereof to the extent not __

e privileged. .

H. For any document or part of a document that was at one~

time, but is no longer, in Applicants' possession, custody or control, or which is no longer in existence, or which canmat be located or produced, identify the document, state where and how it passed out of existence or why it can no longer be located and reasons therefor, and identify each person having knowledge concerning such disposition or loss and the contents of the docuirent. 3nd identify each document evidencing its prior existence and/or any fact concerning its nonexistence or loss.

I. All requests for documents whith are stat.ad in the (

conjunctive are ta be read as if also stated in the disjunct.ive, and vice versa.

J. All documents produced shall be segregated by the tequest number to which they are responsive.

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a K. "Concerns," "concerning" or any other derivative thereof, includes referring to, responding to, relating to, pertaining to, in connection with, comprising, memorializing, commenting on, regarding, discussing, showing, describing, reflecting, analyzing, supporting, contradicting, and constituting.

1. Any and all of the following "generic" plans listed in Appendix F of the SPMC:

a. Generic MS-1 Facility Plan;

b. Generic Host Hospital Plan;

c. Generic EPZ Hospital Plan;

d. Generic Massachusetts Special Facility Plan; e

e. Generic Massachusetts Nursing Home Plan; .

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f. Generic Massachusetts Public School Plan;

g. Generic Massachusetts Small Private School Plan;

h. Genetic Massachusetts Congregate Care Center Management Plan;

i. Generic Bus Provider Plan;

j. Generic Ambulance Provider Plan; and

k. Generic Towing Service Procedure.

2. Any and all records or other documents which indicate the individuals, companies, or other orgaiznations which have been provided copies of these "generic" plans, the dites they were provided to each, and any and all responses received from each of these individuals, companies, or other organizations.

3. The National Red Cross Preparedness for Nuclear Accidents Plan, referred to in Appendix F of the SPMC.

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4. The Department of Interior, Parker River Wildlife Refuge, Radiological Emergency Response Plan, referred to in Appendix F of the SPMC.

5. Ambulance Service Procedures and Standing Orders for Contaminated and Injured Patients, referred to in Appendix F of the SPMC.

6. Any and all plans for EBS stations, including the EBS Station Plan referred to in Appendix F of the SPMC.

7. Any and all plans for notification of Massachusetts Electric Company (MAEC) Offsite Response Organization (ORO)

Personnel, including those referred to in Appendix F of the SPMC. __

8. Any and all plans for notification of Public Service [~

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Company of New Hampshire (PSNH) Offsite Response Organization (ORO) Personnel, including those referred to in Appendix F of the SPMC.

9. Any and all institution-specific radiological emergency response plans for schools and day care centers in the Massachusetts EPZ, and any and all documents pertaining to such plans.

10. Any and all documents which describe non-institution-specific planning conducted by local governments or school officials in the Massachusetts EPZ for protecting the health and safety of school students in a radiological emergency.

11. Any and all documents which contain, estimate, calculate, analyze, assess, critique or otherwise concern the time it will take ORO's buses (a) to arrive at schools in 6-

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the Massachusetts EPZ after a decision is made to evacuate the schools, (b) to load the students, and/or (c) to evacuate with the students outside the EPZ.

12. Any and all documents which estimate, assess, analyze, critique, or otherwise concern the suitability of using the schools in the Massachusetts EPZ as protective shelters during a radiological emergency at Seabrook Station.

13. Any and all decontamiation protocels or other documents concerning decontamination protocols at the host hospitals being relied upon by the SPMC.

14. Any and all documents, including correspondence and notes from visits, interviews, and telephone conversation 3, __

which concern the number of ambulancesandwheelchairvanstha(~

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will be needed to evacuate each hospital, nursing home, and other special facility in the Massachusetts EPZ.

15. Any and all documents which contain, estimate, calculate, analyze, assess, critique or otherwise concern the time it will take the OR3's ambulances and wheelchair vans:

(a) to arrive at the hospitals, nu r s ing hoines , and other special facilities in the Massachusetts EPZ; (b) to load the patients in each of the facilities; (c) to evacuate with the hospital and special facility i

patients from the EFZ after a recommendation to evacuate is issued to the area in which the facilities are located.

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16. Any and all institution-specific radiological l

emergency response plans for the hospitals, nursing homes and other special facilities in the Massachusetts EPZ.

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17. Any and all documents which estimate, assess, analyze critique, or otherwise concern the suitability of the hospitals, nursing homes, and other special facilities in the Massachusetts EpZ as protective sheltets during a radiological emergency at Seabrook Station, including any and all documents which describe or depict the layout of these facilities and/or construction materials used in these facilities.

18. Any and all special needs survey questionnaires used to gather information on the special needs population in the Massachusetts EpZ.

19. Any and all summaries of the data collected from the special needs surveys. __

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20. Any and all documents which assess, analyze, critique .

or otherwise concern the special needs surveys and/or the data ~

collected, including any survey report (s) prepared by those who conducted the survey.

21. Any and all copies of the completed special needs survey questionnaires returned to or obtained by you.

22. Any and all correspondence and other documents f concerning individuals who refused to complete the special needs survey, either in protest of Seabrook or for other i reasons.

23. Any and all documents which describe the methodology employed in conducting the special needs survey (s).

24. An unredacted copy of the current Special Population i

i listings as contained in Appendix M.

25. A copy of the Special tiecds poster mentioned on

p. 3.7-3 of the SpMC.

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26. A diagram of_the Monitoring Trailers that has the interior floor space dimensions marked.

27. Any and all studies or.other documents concerning the actual rate at which individuals can be monitored and decontaminated at'(a) the monitoring trailors at reception centers; and (b) the Emergency Worker Facility.

28. Any and all studies, analyses, critiques, estimates, or other documents which concern the time it will take ORO buses for the transport dependent population to traverse each of the bus routes iri the six (6) Massachusetts EpZ comm' 11 ties.

29. Any and all studies or other documents which concern the additional dosages (over that received by rest of the population) which could be received by those transit-dependent.

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individuals who would have to stand outside along bus routes ,

awaiting transport.

i, Respectfully submitted, .

JAMES M. SIIANNON ATTORNEY GENERAL COMMONWEALTH OF MASSACHUSETTS

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By: _

Allan R. Fierce

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John Traficonte Assistant Attorneys General ,

Nuclear Safety Unit [

One Ashburton Place  !

Boston, MA 02108 i (617) 727-2200  !

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DATED: October 19, 1988 L

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