ML20205R607
| ML20205R607 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/02/1987 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | NEW HAMPSHIRE, STATE OF |
| Shared Package | |
| ML20205R564 | List: |
| References | |
| OL, NUDOCS 8704060391 | |
| Download: ML20205R607 (7) | |
Text
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4 DOCKETED USNRC April 2,;j87
'n 83f-3 R2:55 UNITED STATES NUCLEAR REGULATORY COMMISSION'
.BEFORE THE ATOMIC SAFETY AND LICENSING B h fT BRANCH
)
In the Matter of
)
)
Public Service Company of
)
New Hampshire, et al.
)
Docket Nos. 50-443 OL
)
50-444 OL (Seabrook Station, Units 1 & 2)
)
OFFSITE EMERGENCY
)
PLANNING ISSUES
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NEW ENCLAND COALITION ON NUCLEAR POLLUTION'S SECOND SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO STATE OF NEW HAMPSHIRE ON REVISION 2 TO THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN INSTRUCTIONS FOR USE The following interrogatories are to be. answered in writing and under oath by an employee, representative or agent of the State of New Hampshire with personal knowledge of the f acts or information requested in each interrogatory.
We remind you of your obligation to supplement answers to interrogatories, under 10 C. F.R. S 2.740(e).
The following definitions shall apply to these inter-rogatories:
1)
" Document" shall mean any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all cor-respondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, 8704060391 870402 PDR ADOCK 05000443 G
- qd' h
9 I microfiche, charts, analyses, intra-corporate or intra-office communications,' notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, draf ts, telephone minutes, minutes of meetings, statements, calendars, j ournals, orders, confirmations and all other written or graphic materials of any nature whatsoever.
2)
" Identify" with respect to any document shall mean to l
state the following:
the document's title, its date, the author 1
of the document, the person to whom to document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the presen't custodian of the document and of any and all copies of the document.
3)
" Identify" with respect to any action or conduct shall mean state the following regarding any such action or conduct:
the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect l
of such action; ard any document recording or documenting such 1
l action.
4)
" Identify" with respect to an individual shall mean state the individual's name, address, employer, occupation, and c
title.
5)
" Describe" with respect to any action or matter shall
)
l mean state the following regarding such action or matter:
the 1
substance or nature of such action or matter; the persons partic-J k
l
. ipating in or having knowledge of such action or matter; the cur-
' rent and past business positions and addresses of such persons; and the existence and location of any and'all documents relating to such action or matter.
INTERROGATORIES 1)
In response to Hampton's First Set of Interrogatories on Fevision 2, Interrogatory 2(1), you state that " drivers serv-ing students with special needs, the disabled, or the medically impaired are expected to be capable of providing services to these individuals based upon previous training or related work experience."
Please des ribe the nature of the " previous train-ing" referred to in this answer, and when this training took place.
Please describe the types of related work experience that are considered to demonstrate capability.
Does the state con-sider related work experience to be an adequate substitute for training?
2)
With respect to interrogatory 1 above, do training and related work experience include experience with transporting j
l physically handicapped individuals in buses, including carrying individuals and manipulating wheelchair hookups?
3)
Please describe the State's means, if any, for verify-ing whether bus drivers identified in response to Interrogatory 2 have had previous training or related work experience.
4)
In answer to Hampton 2(1), you state that sufficient EMS personnel will be available to assist normal route drivers, i
-4 or members of the Teamsters Union, who do not have direct train-ing for handling disabled or medically impaired persons.- How many EMS personnel are available?
For ' each EMS person, is it his or her exclusive responsibility to assist-bus drivers, or does 4
that individual have other responsibilities such ar driving ambulances or assisting. ambulance' drivers?
5)
Please identify all bus drivers who have been trained for an emergency response during a radiological accident at Seabrook.
6)
Please provide the date on which each bus driver was trained, and identify the individual who was responsible for training on that date.
7)
Do the bus drivers identified in response to Inter-rogatory 5 constitute all bus drivers who may be called upon dur-ing a radiological emergency at Seabrook?
If not, how many other bus drivers have not been trained?
Does the State plan to train them?
When will they be trained?
8)
In response to Hampton's First Set of Interrogatories on Revision 2, Interrogatory 8, you stated that-the State has no compensatory plan and that the State is prepared to use as many of its personnel and as much of its equipment as may be necessary to implement any required compensatory actions.
Given that the RERP lists only " key" emergency response personnel, it is not possible to determine from the plans how many_or what types of other personnel may be required.
For each town in the EPZ,
. please provide the State's calculation of the maximum number of additional personne1~ that may oe required to compensate when the town fails to or has difficulty in implementing its plan.
What is the basis for you~ answer?
9)
Please provide your calculations of how many State I
agency personnel are available to take compensatory actions under the.NH RERP.
How many of these personnel have been trained to implement the NH RERP?
Have they received general training or training for specific tasks?
10)
For the personnel identified in response to Inter-rogatory 9, please identify the location (s) of the State office (s) where they work.
11)
Please provide all calculations of how long it would take State agency personnel to get to the EPZ and.begin to-imple-ment emergency response functions.
12)
Please identify, describe and provide access to all l
" mutual aid agreements with neighboring states" identified in response to Hampton's First Set of Interrogatories on Revision 2, Interrogatory 8.
13)
In addition to documents identified in answer to NECNP First Set of Interrogatories on Revision 2, Interrogatory 51, please identify, describe, and provide access to any documents reflecting direct communications between the State of New Hampshire and the leadership of the Teans ters Union concerning the provision of buses and drivers during a radiological emer-gency.
. 14)
In response to Massachussetts' First Set of Inter-rogatories on Revision 2, Interrogatory 91, you state that "[ilt is the position of the State of New Hampshire that sheltering 'is feasible using public facilities for that portion of the transient summer beach population unable to evacuate."
What is the maximum portion of the transient summer beach population that' you consider might be " unable to evacuate? "
What is the maximum portion of the transient summer beach population that could feasibly be sheltered?
Please explain the basis for your answer.
15)
Please provide your calculations of the total transient summer beach population and describe the basis therefor.
16)
Please identify, describe and provide access to all documents that you rely on or consider in answering these inter-rogatories.
Respectfully submitted, 1
( v n-
, h
/ - w:u Diane Curran HARMON & WEISS 2001 "S" Street N.W.
Suite 430 Washington, D. C.
20009 (202) 328-3500 Ap ril. :2, 1987 I certify that on April 2,1987, copies of the foregoing pleading were served on the attached service list by the method (s)- indicated therein.
/
v Asa
(,4(A W Diane Curran
/
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Atesic Safety and Licensing 80ston,MA 02109 loard J.P.Nadeau rSherwin E. Turk, Esq.
U.S. NRC Tenn of Rye Office of General Ccunsel SandraGavutis Washington,D.C. 20555 155 Washington Road U.S. NRC RFD 180: 1154 Rye, New Haspshire 03870 Washington,D.C. 20555 East tensington, NH 03827
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Ioard CityHall Board of Selectaen Mctay, Marchy and Grahas U.S. NFC Newt,uryport, MA 01750 Newburr,MA 01950 100 M11n Street Washingtcn,D.C. 20555 Asestory, MA 01913 Alfred V. Sargent, Chitrain H.JosephFlynn.Esq.
850sta<eLinenterger taara of Selectmen OfficeofGeneralCsunsel Atcsic Safety and Licensing icon of Salisbury, MA 0l?50 FEMA Eoard 500 C Street S.W.
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!aara Fanel 9f fice of the Attorney General U.S. ARC Selectaen of Northas:tcn tate House Anner dasningtcn,S.C. 20555 Mrtnaact:n. New n sosnare Canccri. NH H331
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Holses&Ellis Durtas, NH 0'342 88 Broad Street 47 Winnacunnent Road Bosten,MA 02110 Hasplen, NH 038a2 Willias S. Lerd, Selectaan
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Portssouth, NH 03801 1 Ashburton Place,19th Floor R.I.GadII,Esq.
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225FranklinStreet Shaines & McEachern StanleyW.Incules Boston,MA 02110 P.O. lor 360 loard of Selectaen MaplewoodAve.
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