ML20210N506
| ML20210N506 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/30/1986 |
| From: | Bisbee G NEW HAMPSHIRE, STATE OF |
| To: | HAMPTON, NH |
| Shared Package | |
| ML20210N476 | List: |
| References | |
| OL, NUDOCS 8605050124 | |
| Download: ML20210N506 (6) | |
Text
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FEs,agg UNITED STATES OF AMERICA 00( -
NUCLEAR REGULATORY COMMISSION Di E
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Before tne TM hIf/t !
ATOMIC SAFETY AND LICENSING BOARD CO, BRAhgl_y(y
,q, In ne matter or:
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PUBLIC SERVICE COMPANY OF
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Docket Nos.:
50-443 HEW HAMPSHIRE
)
and (Seacrook Station, Units 1 and 2
)
50-444
)
April 30, 66 THE STATE OF NEW HisM PS H IR E ' S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE TOWN OF HAMPTON ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN I.
INSTRUCTIONS Pursuant to 10 C.F.R.
Sections c.71S(c), 2.740(o), and 2.741, tne State or New Hampanire requests tnat the attacnud Interrogatories ce answered fully in writing and anaer outn oy any otticials or tne Town ot Haupton who nave personal knowledge thereot.
The answer to eacn Interrogatory shoula contain tne na t:.e ( s ) and luentitication ot tne person (s) supplying tne answer and wnether or not ne or.ihe nas veritted tne answer.
As used herein, the term " document" means all original writings of any nature wnatsoever and all non-identical copies tnereot in tne possession, custody, or control of tne Town of Hampton and incluces out is not limited to tne rollowing items:
communtcations, corresponcence, notes, field notes, studies, reports, sunnaries, instructions, charts, schedules, sketches and drawings, reCordJ, accounts and accounting records, opinions and reports or consultants.
As used herein, the term " identify" neans:
1.
In tne case or a natural person:
(a) name; (u) last-known address; (c) enployer or uuniness attillation; and (d) occupation and ousiness position neld.
8605050124 860430 PDR ADOCK 05000443 C
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V o 2.
In tne case of a document:
(a) identity of tne person or persons preparing it; (D) its title or a description of the general nature of the suoject taatter ;
(c) the identity of the addressee; (d) date of preparation; (e) identity of persons wno can identify it; and (f) all of the aforementioned information should be supplie.
with such reasonaole particularity as is sufficient for a specific demand for production.
In lieu ot the foregoing, a copy of the uocument may oe supplied.
3.
In tne case of oral stateraents and communicattons:
(a) when and where they were mace; (o) identity of each or the nasers and recipients titereof; (c) the medium of communication; and (d) suustatice of the statement and/or communication.
Pursuant to 10 C.F.R.,
Section 2.740(e), responses should ue supplemented under circulastances when new or ditterent intoruation becomes available.
If tne Town of Hampton citnnot innswe r the Interrogatories in full, so state and indicate wnen tne Town or Hampton expects to ce aole to answer the Interrogatory.
Tne State of bew Hampsnire turther requests that tne Town ot Hampton, pursuant to 10 C.F.R.,
Section 2.741, provide copies ut or make available for inspection and copying the documents identitled by the Town of Hampton in response to certain or tne accompanying Interrogatories.
.. - - II.
GENERAL INTERROGATORIES G.1 Please identify those contentions admitted by the Board's Orcer or April 1,
1986 on whien tne Town of Hampton intenda to introduce evidence in this proceeding.
G.2 For each contention identified in Interrogatory G.1, please iaenfity all persons whou the Town of Hampton intenas to call as witnesses.
Please include a sumnary of tne educational and professional cackground of each identifiec witness.
G.3 Provide a reasonaole description ot tne suostance of the testinony of each witness on each of che contenticna identified in the answer to Interrogatory G.I.
Please also identif y all documents wnich will be relied on in tnat testimony.
III.
INTERROGATORIES RELATED TO SPECIFIC CONTENTIONS CONTENTION HAMPTON IV Hampton IV.1 Has the Town of Hampton estimated the non-auto owntng population in the Town of Hampton?
It so, how was the estimate made?
Please indicate the nuncers of such non-auto owning persons.
Please icentify all documpnts supporting this response.
Hampton IV.2 has the Town of Hampton estimated the population or tne Hampton schools?
Please indicate the population or the hampton senools.
Please identify all documents supporting tnis response.
Hampton IV.3 How many scnool buses aoes the Town or Hampton own?
How uany school buses does the Hampton Senool District own?
Hampton IV.A How many buses does the Town of Hampton oelleve woulu pe necessary to ensure a proper response in the event or a radiological emergency at the Sedorook Station?
Please expiatn tue uasta of this response and identify all documents supportLng tne responue.
Hampton IV.5 Are the buses owned oy tne Town ot Hampton or tne Haupton School District availaole for use in an evacuation in tne event ut an emergency at the Seaorook. Station?
It not, please explain wny not.
U'--
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CONTENTION HAMPTON VI Hampton VI.1 Please explain how tne Town of Hampton arrived at tne population i
estimates given in section (A) of the basis of this contention.
Please identify all cocuments supporting tnis response including, without limitation, accuments relating to tne total available parking capacity, business receipts used in population computation, accuments relating to tne extent of seasonal shifts and the cemand for municipal services, ano documents containing data relied upon oy the Town o_f Hampton in estaalishing the population estimates.
Hampton VI.2 Please state wnetner the daily peak populations identified oy the Town in section (A) of the casts of tnis contention refers to the numoer of people estimated to De in the Town at any given molaent, or tne number of people who are expected to be in the Town for some part of a given dav.
If the population totals refer to tne estimated nuncers of persons in tte Town of Hampton over the course of an entire day, please state: whether tuis is the population rigure that snould be reliec upon for state and local emergency planning for Seabrook Station.
If not, please state what population figure should ce relied upon for state and local emergency planning for Seabrook Station.
Hampton VI.3 t
Please explain wny eighty (80) regular and special town police officers are not adequate to carry out tne functions assigned tne Hampton police Department in the dampton RERP.
Hampton VI.4 Please explain why the "special otticers" lacr. the experience, skill, and training to provide emergency response functions in the event of a radiological emergency.
Hampton VI.5 Please describe tne training presently provided by tne Town ut Hampton anc the State of bew Hampshire to regular and apecial police otficers for the Town of Hampton.
What additional training must, in tne Town of Hampton's opinion, ce provided for Lts police department personnel?
u
-S-Hampton VI.6 Please explain why sixty (60) puolle works personnel are not sufficient to carry out tne emergency response tunctions assigned to the Hampton Departiaent or Public Works.
Hampton VI.7 Please descrioe tne training provided oy the Town of Hampton and tne State of New Hampshire to the Department of Puolle Works full-tlue and teuporary employees.
Hampton VI.8 What additional training, in the estimation or tne Town of Hampton, is required to ensure that the Department of Puolic Works employees can adequately respona in the event of a radiological emergency.
Hampton VI.9 Please descrioe the prooleins foreseen oy the Town ot Hampton in ensuring that all evacuation roads are serviceaole throughout tne cource of an evacuation.
Hampton VI.10
? lease explain why the Public Works Department personnel cannot acequately Keep the roads serviceaole in the event at an euergency at Seacroon Station.
Hampton VI.ll Please descrice the training currently given by the Town ot Hampton and the State of New Hampshire to the Board ot Selectmen concerning their elaergency response and civil def enae duttes.
Hampton VI.12 Please explain how this training snould be improved to ensure that the Board of Selectmen can properly respond to a radiological elaergency at Seabrook Station.
Hampton VI.13 Please explain tne oacia ior the responses given to Interrogatories VI.3-VI.12, and identify all accumenta aupporting those responses.
. CONTENTION HAMPTON VIII Hampton VIII.1 Please descrice the procecures currently in place tor effectuating an evacuation or the beach population in tne Town of Hampton.
Hampton IIII.2 What provisions must De nace in the NHRERP, including the Hampton RERP, to provide reasonaole assurance that adequate and immediate protective aeasures will oe available to the Deacn population in tne Town or Haupton?
Pleace descrioe in this response all currently existing procedures tor evacuating the beachen which should be incorporated in the NHRERP, including the Hampton RERP.
Please explain the casts of this response and icentify all documents supporting the response.
Respecttully submitted, THE STATE OF NEW HAMPSHIRE STEPHE!1 E.
MERRILL ATTORi1EY GENERAL i
f Dated:
April 30, 1936 By 4%
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George Dana utsoue V i
Assistant Attorney Generai Environmental Protection Hureau Office of tne Attorney General 2S Capitol Street Concord, tiew dampunire U3301 Telephone (603) 271-3678
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