ML20206J869

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

ML20206J869
Person / Time
Site:	Seabrook
Issue date:	11/15/1988
From:	Selleck K PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	MASSACHUSETTS, COMMONWEALTH OF
References
CON-#488-7535 OL, NUDOCS 8811290152
Download: ML20206J869 (14)

Text

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h 7535 l

eaxtito ume EELATED CORRESimOW{

l '83 im 21 P5 G5 l November 15, 1988 i

h UNITED STATES OF AMERICA I 1 I NUCLEAR REGUIATORY COMMISSION  !

before the i

ATOMIC SATETY AND LICENSING 80ARD t i

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) i In the Matter of )  !

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-4 4 3-OL  ;

j NEW HAMPSHIRE, et al. ) 50-444-OL [

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l (Off-site Emergency (Seabrook Station, Units 1 and 2) ) l

) Planning Issues) i i

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l APPLICANTS $ RESPONSE 10 * [M ASS AC 'S] SECOND t REQUEST FOR TME PRODUCTION OF DOCUMENTS TO THE APPLICANTS REGARDING THE (SPMC)"  !

I Mass AG served his Second Request for the Production of l

Documents out of time, and therefore Applicants are not ,

required to respond.1 Ilowever, Applicants have already l produced z.ost of the documents called for in this request in response to Mass AG's earlier, overly broad requests. As of j Novomber 4, 1988, Applicants have made available to the f l

parties relevant, non-privileged documents regarding the admitted contentions on the SPMJ. Moreover, those documents [

i 1 Mass AG served the request on October 19, 1988, ~

I making the time answers would be due November 18, 1988, past the final discovery cut-off date of November 15, 1988  !

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O have been sorted according to the parties' ear 1Jer requests, organized by request numb:r. Thus, Mass /G's Second Request is largely superfluous. Applicanta respond herein, however, to point out in particular their objections to Mass AG's requests. Applicar,ts further note that the response "Applicants have produced the documents requested" means that any responsive documents which exist have been produced.

As to the Place and Manner of productiont Applicants incorporate herein their objections to Mass AG's specification of the place and manner of production as those objections are exclained in Applicants' reply to Mass AJ's first request for documents, aleo filed this date.

As to Definitions and Instructions:

Applicants incorporate herein their objections to Mass AG's "Definitions and Instructions" as those are explained in Applicants' reply to Mass AG's first request for documents.

As to Specific Requests for Production of Documents:

Recuest No. 1 l

Any and all of the follewing generic" plans listed in Appetidix F of tP s SFMCt

a. Generic MS-1 Fae'.lity Plant

b. Generic Host Hospital Plant

c. Generie EP: Hospital Plent

d. Generic Massachusetts Special Facility Plant

e. Generic Massachusetts Nursing Home Plant 2

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f. Generic Massachusetts Public School Plant j

g. Generic Massachusettu Small Pr', -te School Plant  ;

h. Generic Massachusetts Congregate care center f L' Management Plant

1. Generic Bus Provider Plant j t

j. Generic Ambulance Provi - "lant and j

k. Generic Towing Service ca. f Aeolic,an C Resconta f Applia nts have produced the documents requested.

r Reauest No. 2  ;

i Any and all records oc other documents which indicate 'I the individeals, companies, or other orgatznations (sic)  !

which have been provided copies of these "generic" plans, the dates they were provided to each, and any and all responses j received from each of these individuals., companies, or other organizations.

Applicants' nesronse Applicunta have produced the dccumints requested. l Request No. 3  ;

The National Red Cross Preparedness for Nuclear f Accidents Plan, referred to in Appendix T of the SFMC.

Arolicants' Rescense Applicants have produced the docuuents requested.

Reauest No. j The Department of Interior, Parker River Wildlife Refuge, Radiological Emergency Response Plan, referred to in Appendix P of the iFMC.

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Aeolicants' Response Applicants.have produced the documents requested..

Efouest No. s Ambulance Service Procedures and Standing Orders for

• Contaminated and Injured Patiencs, referred to in Appendix F of the SPMC.

Aeolicants' Response Applicants have produced the documents requested.

Reauest No. 5 i

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

Aeolicants' Response Applicants have produced the documents requested.

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.Recuest No. 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.

Aeolicants' Resoongg Applicants have produced the documents requested.

Recuest No. 8 l l

Any and all plans for notification of Public Service Company of New Hampshire (PSNH) Offsite Response Organization (ORO) Personnel, including those referred to in Appendix F of the SPMC. ,

A_ eolicants ' Resoonse Applicants have produced the documents requested. j a l M W

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i Boauest No. 9 Any and all institution-specific radiological emergency l-response plans for schools and day care centers in the Massachusetts EPZ, and any and all documents pertaining to >

such plans.

Aeolicants' 9esconse Applicants have produced the documents requested.

Reauest No. 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.

Aeolicants' Response Applicants have produced the documents requested.

Recuest No. 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 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.

Aeolicants' Resconse Applicants have produced the documents requested.

EgStest No. 12 Any and all documents which estimate, assess, analyze, critique, or otherwise concern the nuitability of using the schools in the Massachusetts EPZ as protective shelters during a radiological emergency at Seabrook Station.

Acolicants' Resoonse i

Applicants have produced the documents requested. [

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i s-Recuest No. 13 Any and all decontamiation (sic) protocols at the host hospitals being relied upon by the SPMC.

Aeolicants' Resoonse Applicants have produced the documents requestud<

Reauest No. 14 Any and all documents, including correspondence and notes from visits, interviews , and telephone conversations, which concern the number of ambulances and wheelchair vans that will be needed to evncuate each hospital, nursing home, and other special facility in the Massachusetts EPZ.

Aeolicants' Response Applicants have produced the documents requested.

Recuest No. 15 Any and all documents which contain, estimate,

. calculate, analyze, assess, critique or otherwise concern the time it will take the ORO's ambulances and wheelchair vans:

(a) to arrive at the hospitals, nursing homes, and other special facilities in the Massachusetts EPZ (b) to load the patients in each of the r facilities; (c) to evacuate with the hospital and special facility patients from the EPZ after a recommendation to evacuate is issued to the area in which the facilities are located.

Aeolicants' Resconse Applicants have produced the documents requested.

Reauest No. 16 Any and all institution-specific radiological emergency response plans for the hospitals, nursing homes and other special facilities in the Massachusetts EPZ.

Arnlicants' ResDonse Applicants have produced the documents requested.

Recuest No. 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 shelters 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.

Adol iqa.nt s ' Resconse i

Applicants have produced the documents requested.

Recuest No. 18 Any and all special needs survey questionnaires used to gather information on the special needs population in the Massachusetts EPZ.

Appl!qants' Resconsa Applicants incorporate herein their objections as stated in "Applicants' Response to '(Mass AG's) First Request for the Productica of Documents to the Applicants Regarding the (SPMC)'" in response to Interrogatory 161 and j. Applicants have produced a copy of the blank questionnaire.

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Eegyest No. 19 Any and all sunmaries of the data collected from the special needs surveys.

AppliciuttR '_ R9MD2nM Applicants incorporate herein their objections as stated in "Applicants' Response to '[ Mass AG's] First Request for the Production of Documents to the Applicants Regarding the (SPMC)'" in response to Interrogatory 161 and j. Further, Applicants state that they have produced the documents requested with confidential material redacted.

Reauest No. 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.

Applicants' Response Applicants have produced the documents requested.

Reauest No. ?,1 Any and all copies of the completed special needs survey questionnaires returned to or obtained by you.

Anolicants' Response Applicants incorporate herein their objections as stated in "Appliuants' Response to '(Mass AC s) First Request for the Production of Documents to the Applicants Regarding the Applicants (SPMC)'" in response to Interrogatory 161 and j.

have produced a copy of the blank questionnaire.

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Recuest No. 22 ,

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

Aeolicants' Resconse Applicants have produced the documents requested.

• Recuest No. 23 Any and all documents which describe the methodology employed in conducting the special needs survey (s) .

Aeolicants' Resconse .

Applicants have produced the documents requested.

Recuest No. 24 An unredacted copy of the current Special Population listings as contained in Appendix M.  ;

Aeolicants' Resconse Applicants incorporate herein their objections as stated in "Applicants' Response to '(Mass AG's] First Request for 1 the Production of Documents to the Applicants Regarding the <

Further, (SPMC)'" in response to Interrogatory 161 and j.

Applicants state that Mass AG has been provided the document requested with confidential material redacted.

Recuest No. 25 ,

3.7-3 A copy of the Special tieeds Poster mentioned on p. '

of tho SPMC.

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Aeolicants' ResDonse Applicants have produced the documents requested.

Recuest No. 26 A diagram of the Monitoring Trailers that has the interior floor space dimensions marked.

Aeolicants' Resconse Applicants have produced the documents requested.

Recuest No. 27 Any and all studies or other documents concerning the actual rate at which individuals can be monitored and decontaminated at (a) the mcnitoring trailors (sic) at reception centers; and (b) the Emergency Worker Facility.

Aeolicants' Resconse Applicants have produced the documents requested.

i Recuest No. 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 in the six (6) Massachusetts EPZ communities.

Aeolicants' Resoonse Applicants have produced the documents requested.

I Recuest No. 29 Any and all studies or other documents which concern the c additional dosages (over that received by rest of the l population) which could be received by those transit-dependent individuals who would have to stand outside along the bus routes awaiting transport.

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Acolicants' Response Applicants have produced the documents requested.

Motion for Protective Order Applicants move that the Board enter a protective order that the discovery objected to herein not be had.

By their attorneys, Thomas G. Dignan, Jr.

George H. Lewald Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith Popes & Gray 225 Franklin Street Boston, Massachusetti: 02110 (617) 423-6100 l

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v 16 Nm/ 21 P5 :35 CERTIFICATE.'T SERVICE * . . uv i I, Kathryn A. Selleck, one of the attorneys ^forithet h

Applicants herein, hereby certify that on November l'5, 1988, I made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):

Administrative Judge Ivan W. Smith Robert Carrigg, Chairman Chairman, Atomic Safety and Board of Selectmen Licensing Board Panel Town office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Judge Gustave A. Linenberger Diane Curran, Esquire Atomic Safety and Licensing Andrea C. Ferster, Esquire Board Panel Harmon & Weiss U.S. Nuclear Regulatory Suite 430 Commission 2001 S Street, N.W.

East West Towers Building Washington, DC 20009 4350 East L.st Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assi.stant Attorney General Office of the Attorney General Commission East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 Sherwin E. Turk, Esquire Adjudicatory File Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building One White Flint North, 15th Fl.

4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 208G2

• Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel 116 Lowell Street U.S. Nuclear Regulatory P. O. Box 516 Manchester, NH 03105 Commission Washington, DC 20555

b-4 Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road 3ye, NH 03870 General Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Assistant Attorney General' Matthew T. Brock, Esquire Department of the Attorney Shaines & McEachern 25 Maplewood Avenue General One Ashburton Place, 19th F1.

P.O. Box 360 Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney City Manager l Chairman, Board of Selectmen City Hall  !

RFD 1 - Box 1154 l Route 107 126 Daniel Street Kensington, NH 33827 Portsmouth, NH 03801

• Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Clark, Hill-Washington, DC 20510 Whilton & McGuire (Attn: Tom Burack) 79 State Street Newburyport, MA 01950

• Senator Gordon J. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 307 Kopelman & Paige, P.C.

Concord, NH 03301 77 Franklin Street Boston, MA 02110 (Attn: Herb Boynton)

Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen l Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301

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Judith H. Mizner, Esquira Mr. Richard R. Donovan 79 State Street, 2nd Floor Federal EF<nrgency Management Newburyport, MA 01950 Agency Federal Regional Center 130 228th Street, S.W.

Bothell, Washington 98021-9796 Ashod N. Amirian, Esquire 376 Main Street Haverhill, MA 01830 Robert R. Pierce, Esquire John H. Frye, III, Alternate Atomic Safety and Licensing Chairman Atomic Safety and Licensing Board Panol U.S. Nuclear Regulatory Board Panel U.S. Nuclear Regulatory Commission East West Towers Building Commission 4350 East West Highway East West Towers Building Bethesda, MD 20814 4350 East West Highway Bethesda, MD 20814 James H. Carpenter, Alternate Technical Member Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 i

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(*=0rdinary U.S. First Class Mail) ,

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