ML20206J833

New England Coalition on Nuclear Pollution Second Set of Supplemental Answers to Applicant First Set of Interrogatories Etc & Answers to Applicant Interrogatories & Request For....* Svc List Encl.Related Correspondence

ML20206J833
Person / Time
Site:	Seabrook
Issue date:	11/21/1988
From:	Curran D HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#488-7539 OL, NUDOCS 8811290136
Download: ML20206J833 (5)

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RE1ATED CORRESPOND' NCL November 21, 1988.t m.

, .. c UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAif6 im 22 P3:31

) , ..

In the Matter of ) 'l% ,

)

Public Service Company of )

New Hampshire, et al. ) Doc):et Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 & 2) ) OFFSITE EMERGENCY

) FLANNING ISSUES [

}

NEW ENGLAND COALIIION ON NUCLEAR POLLUTION'S SECOND SET OF SUPPLEMENTAL ANSWERS TO APPLICANTS' FIRST SET OF IhTERPOGATORIES ETC. AND ANSWERS TO APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMEhTS ... CONCERNING ,

JOINT INTERVENOR CONTENTIONS 6, 1-26 and 27-63 Introduction Pursuant to an agreement with Applicants, the New England coalition on Nuclear Pollution ("NECNP") hereby amends its "Sup-plemental answers to "Applicants' First set of Interrogatories, etc.," and ansvars to "Applicants' Interrogatories and Roquest for the Production of Documents ... Concerning Joint Intervonor Contentions 1-26 and 27-63," filed October 31, 1988.  ;

SUPPLEMENTAL ANSWERS TO INTERROGATORIES AND REQUESTS FOR PRODUC- l TION: 1 Interrogatory 1): Please produce all analyses, studies, and [

reports bearing on &ny and/or all of the factuti issues raised in the Joint Intervenor Contentions.

P ANSWER: NECNP does not possess any such documents, other than correspondence and filings that have already been served on the  !

parties to the Seabrook service list. >

Interrogatory 2) : In each case where one of the following interrogatories asks for "all of the facts" or "all the j8jlD901360011e1 q siDOCK 05000443 PDil ) L

)) ,

facts, estimates, and observations," please also identify the person (s) and/or documents that are the source (s) of

. those facts, estimates, and/or observations, and produce all  ;

documents that reflect, conenrn, refer or pertain to any ,

and/or all of those facts, e:stimates , and observations. j i ANSWER: As discussed in the answers to individual inter-rogatories, the scurce of NECNP's information consists either of  ;

i the SPMC itself, filings in this proceeding submitted by other parties, or counsel's personal observations.

Interrogatory 3): Please identify the person (s) answering i or substantially contributing to tne answer to each of the  ;

i following interrogatories. Please also identify all persons  !

I consulted, and identify and produce all communications and

• i documents consulted and/or relied upon, in answering each

! interrogetory.  !

l ANSWER: The answers to these interrogatories, as well as the 3 answers filed on October 31, 1988, were prepared by Diano curran, .

in reliance on the joint intervenors' contentions and the SPMC.  ;

Interrogatory 280: Please state all the facts underlying Intervenor's assertion that the "ateps of communicating and j J coordinating" are "time-consuming," identify each step and I the personnel involved, and ntate how much time is required l for each step. (

f ANSWERt In addition to its October 31 answers to Applicants' interrogatories, NECNP states the following. To the extent that k the necessary steps of communicating anc coordinating an emer-gency response are described in the SPMC, they appear to be con-t tained or referenced in SPMC Section 3 and in Implementing Proco-dure # 2.14 and its attachments.1 The personnel involved are f J

' described in these sections of the plan. l l  !

l

]

j 1 It should be noted that at this time, NECNP has not l

, evaluated whether the SPMC's procedures are detailed enough to l 1 describe every communications step that must be taken in a [

! radiological emergency in order to adequately carry out the com-  !

]

munication tasks that are generally described in Section 3. (

NECNP has not calculated how much time these procedures will take. NECNP generally asserts that these steps would be time-consuming because during an accident, ORO and Massachusetts offi-cials would have to do nore than agree to carry out pre-assigned rolest they would have to exchange information about each other's capabilities and intentions. For instanco, pursuant to Section 5.2.5 in IP 2.14, the NHY offsite Response Director and/or the Seabrook Station Short-term Emergercy Director is to "describe the capabilities of NHY Offsite Response Organization" to Massa-chussetts officials and "(ajsk the Commonwealth of Massachusetts how they intend to respond." Presumably, these exchanges of information would take mets than a few minutes to accomplish. In addition, DECNP believes that as the accident unfolds and demands on rosources change, the communication steps outlined in IP 2.14

! might have to be repeated several times.

l Interrogatory 281: Please state all the, facts' underlying Intervenor's assertion that "(f)or each function" the "steps 1 of agreeing on division's of responsibilities and all of the accompanying logistics, including communication and sharing of equipment and personnel" are "time-consuming," identify each step and the personnel involved, and state how much time is required for each step.

ANSWER: As stated in response to Interrogatory 280, the ORO and Massachusetts would presumably be discussing their relative capa-bilities, resources, and intentions for implementing an emergency I response for the first time during an accident. The SPMC con-i 1 continued)

t i

tains no preconceived division of responsibilities and resources; thus, decisions on these divisions would have to be made, for each aspect of the emergency responde, on an Ad h22 basis.

Because the decisions would be Ad has, it is impossible to determine how long they would take. It is is clear, however, ,

that they would take longer than agreeing to implement a pre-conceived agreement for division of responsibilities and '

I resources.

t Respectfully submitted, ane Curran HARMON, CUPRAN & TOUSLEY 2001 "S" Street N.W. Suite 430 [

Washington, D.C. 20009 '

I (202) 328-3500 l L

j I, Diane Curran, declare that I prepared the foregoing ans-vers to interrogatories and requests for the production of docu- ,

ments, as well all other answers to Applicants' interrogatories l-and requests for the production of documents that NECNp has filed  ;

i to date regarding the SPMC. Those answers are true to the best '

l-of my knowledge and belief.

Diane Curran November 21, 1988 ,

I CERTIFICATE OF SERVICE (

I certify that on November 21, 1988, copies of the foregoing pleading were served by telef ax or first-class mail on all >

parties to this proceeding, as designated on thu attached service j list. ,

[, ' , w i

Diane Curran

, l I i i

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SEAllROOK SE1VICE LIST Offsite Licensing Bo.y '

. y :i-Stanley W. Knomies Matthew T. Drock, De Nord of Seleomea s

!cC. Sauth. Chairman Ae.n c Safety and Lkens4ng 11oard P.O. Ibs 710 '88 ICI 22 P3 Ghaines& oos m McCuhern U.S Nwctest Regulatory Comenasson North flampece,51103*M Maptemal Aveave Wasbrpon, D C 20$$$ Port mouth.51102)1 J P. ? dess i I/* Y Tc=3 of Ryg ' ' '

4M5 andre Oswets Dr Jerry liar 50s:

Atorme Safety and Lkenasag Doerd 155 Wa*Magton Road '

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Senator Gordon J. livmpbny Rcbert A Ikkwa. T4q G utsvg lau nbergtr U.i Senate Iktu Meyer & 5Aimon Atome Safety anJ Ikening [kard Wuhington. D C 20$10 til Lasil Street Manchester, Nil 031'd U i Swdear Ragwatory Commanon (Atta. Tara Ibrac k)

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Ikarj d Selecimea ikutoa, MA 02109 Je=e: street, RfD # 2 hun llarepton, N110%42 Alfred V. Sargent, Chaaman Jane Doughty Ikiard d selectmea '

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Rc4 & Gray Aautant Attorney Gcaeral 22.3 Frenkbn 5 reet State ll0ae. Stata* d 6 fY tk w a,NLA 02110 Awgata, MF 6til3 Cued i Sne rJet, Dqwrt A: lea Leprt Anannt Attorny General Caul Defeue Doedor 1 AthNrtoa Pt.we.19"i fWr Tomn cd tirento.m2 thta, NLi 021tY E.acter, S11 OM33