ML20210N526

First Set of Interrogatories & Request for Production of Documents Re Radiological Emergency Response Plan.Responses to Specified Contentions Requested.Related Correspondence

ML20210N526
Person / Time
Site:	Seabrook
Issue date:	04/30/1986
From:	Bisbee G NEW HAMPSHIRE, STATE OF
To:	KENSINGTON, NH
Shared Package
ML20210N476	List: ML20210N471 ML20210N489 ML20210N506 ML20210N515 ML20210N526 ML20210N539 ML20210N551
References
OL, NUDOCS 8605050131
Download: ML20210N526 (7)

Text

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ALLM ED COgn UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIOli

$s&fD Berore the ATOMIC SAFETY AND LICENSIt1G BOARD 'd f g I ' 2 /)ff . g

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PUBLIC SERVICE COMPANY OF ) Docket Nos.: 50-443 tied HAMPSHIRE ) and (SeacrooK Station, Units 1 and 2 ) 50-444

) April 30, 1986 THE STATE OF !!EW HAMPSHIRE'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTIOli UF DOCUMENTS TO THE TOWII OF KENSINGTOt3 ON THE NEti HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAT 1 I. ItiSTRUCTIONS Pursuant to 10 C.F.R. Sections 2.71d(c), 2.740(D) and 2.741, tne State or tiew Hampshire requests tnat the attached Interrogator 1ea De answered tully in writing and under oath by any memoera or the Town of Kensington who have personal knowledge thereur. Tne answer to eacn Interrogatory should contain the nacie(s) and identitication of tne person (s) supplying tne answer and wnether or not he or ane has vertried the answer.

As used herein, the term " document" meano all original writings of any nature whatsoever and all non-toentical copies tnereof in the possession, custody, or control of the Town of Kensingtri and includes but is not limited to the following items: c mmunications, correspondence, notee, field notes, studies, reports, summarina, instructions, cnarts, acnedules, sketenes and drawinga, records, accounts and accounting records, opinions and reportu of consultantu.

As useo herein, tne term " identity" means:

1. In tne cane of a natural person:

(a) name; (b) laut-known aacreau; (c) euployer or cuuineua att111ation; and (u) occupation ano ouutneau pouttton nela.

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2. In the case of a cocument:

(a) identity of the person or persons preparing its (b) its title or a description of tne general nature of the suo]ect matter; (c) the identity ot the addressee; (c) date of preparation; (e) identity of persons who can identify it; and (f) all of tne aforementioned information snould be supplied witn sucn reasonable particularity as is sufficient for a spectric demand for production. In lieu of the foregoing, a copy of the document may oe supplied.

3. In the case of oral statements and communications:

(a) when and wnere they were made; (o) identity ot each of the makers and recipients thereof; (c) the mecium of ccmmunication; ano (d) suostance of the statement and/or communication.

Pursuant to 10 C.P.R., Section 2.740(e), responses abould oe supplemented unaer circumutances wnen new or ditferent intornation becomes availaole. If the Town of Kensington cannot answer the Interrogatories in full, so state and indicate when the Town of Kensington expects to be able to answer the Interrogatory.

The State of New ifampshire furtner requests that tne Town ot Kensington, pursuant to 10 C.F.R., Section 2.741, provice copies at or make availaole for inspection and copying the documentu identified by tne Town of Kensington in response to certain of the accompanying Interrogatories, e

II. GENERAL INTERROGATORIES G.1 Please identify tnose contentions admitted by the Board's

. Order or April 1, 1986 on which the Town of Kensington intends to introduce evidence in tais proceeding.

G.2 For each contention identified in Interrogatory U 1, please icenfity all persons whom the Town of Kensington intends to call as witnesses. Please include a summary of the educational and proressional oackground of each identified witness.

G.3 Provide a reasonaale description of the suustance of tne testimony of each witness on each ot the contentions identified in the answer to Interrogatory G.I. Please also identity all documents wnich will be relied on in tnat testimony.

III. INTERROGATORIES RELATED TO SPECIFIC CONTENTIONS CONTENTION KENSINGTON 1 Kensington 1.1 Are tnere presently any alternates for tne positions or Civil Defense Director, Fire Chief, and RADEF Officer in tne Town ot Kensington? It not, is it expected that sucn aJternate pouttions will ce filled? When in it expected that tney Gill ne filleu ? If they are not expected to be tilled, please explain wny not.

Kensington 1.2 Is tnere presently a transportation coordinator ror tne Town ut Kensington? It not, is it expected that t ria t posttron will oe filled? Wnen is it expected to be filled? It it is not expected to De tilled, please explain why not.

Kensington 1.3 Please explain how tne UliRERP, including tne Town at Kensington RExP, should provide tor sufficient manpower to ttli emergency response positions and alternate positions. Please explain the casta of this response, and identtfy all documents supporting the response.

Kensington 1.4 Please explain now tne UllR ER P , including tne Town at Kensington RERP, does not assure that the functions assigned to tne Kensington Fire Department will not ue carried out.

Kensington 1.5 Please explain how fire department personnel are reached in the event of a non-radiological emergency requiring the assistance or the Kensington Volunteer Fire Department. Please also explain why tne same mechanisu for notifying the Volunteer Fire Department is not sufficient for tne Kensington RERP.

Kensington 1.6 Please explain now the UHRERP, including the Town of Kensington RERP, should provide for the emergency response functions designated for the Kensington Fire Department. Please explain the basis of tuis response, and identify all documents supporting the response.

Kensington 1.7 Please explain now tne NHRERP, including the Town of Kensington RERP, does not provide for sufficient personnel or resources to carry out the responsioilities assigned to the Kensington Highway Department. Please include in your response any estimates arrived at by the Town ot Kensington with regard to accidents, stalled cars and other road obstructions that could be expected to occur in the event of an evacuation of the Town of Kensington during a radiological emergency. Please describe the method used to arrive at these estimates. Please also icentify all documents supporting these responses.

Kensington 1.8 Please explain now tne NHRERP, including the Town ot Kenstngton RERP, should provide for sutticient personnel and resources to carry out the respons10111 ties assigned to the Town of Kensington H19nway Department. Please explain the basis or this response, and identify all documents supporting this response.

Kensington 1.9 Please explain what arrangements witn private contractors would De sutticient to ensure tnat these responsioilities will De met.

Kensington 1.10 Pleaue deucrice the procedures which currently exist tor notifying the Town of Kensington Police Chiet of a non-radiological emergency during his ort-cuty nours. Please also describe how the Town of Kensington P' nice Department responds to non-radiological emergencies wnen tne Police Chier is unreachable or incapable ot responding.

Kensington 1.11 Are the procedures outitned in response to the preceding interrogatory sutficient tot emergency response to a rautological cuergency? If not, please explain wny.

1

, Kensington 1.12 2

Please explain how tne NHRERP, including tne Town of Kensington '

l RERP, should provide for sufficient manpower to carry out the functions assigneo to the police chiet in tne Town of Kensington.

Please explain the basis of tnis response, and identify all documents supporting the response.

f CONTENTION KENSINGTON 2 i

Kensinaton 2.1 t

3 Please indicate wnich individual should ce designated as tne i'

Town of Kensington contact person for receipt of notitication of a radiological emergency at Seabrook Station.

i 1 Kensington 2.2 i

Please describe how tne NHRERP, including tue Town of Kensington RERP, snould provide for notification of town officials in the event of a radiological emergency at Seabrook Station.

Kensington 2.3 1

Please explain wnat notirication procedures currently exist in tne Town of Kensington tor non-radiological emergencies tnat require j tne response of tne fire cepartment. Please also state wnetner these procedures can also be used in the event of a raciologtcal e;ae rgency. If not, please explain wny.

8 l Kensington 2.4 Please explain why training in notification procedurcu for Town i of Kensington officials is insufficient. Then please explain how the L

NHRERP, including the Town of Kensington RERP, snould provide for the necessary training and notification procedures. Pleaue explain tne j basis of this response, and identity all doculaents supporting the

response.

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1 CONTENTION KE!1SINGTON 4 Kensington 4.1 What snelter areas should be designated on maps in the NHRERP?

t Kensington 4.2 i

Wnat degree of protection (i.e., what "sheilding factor" as

, discussed in Aldrich, Public Protection Strategies For Potential Nuclear Reactor Accidents: Snelterina Concepts With EX1 sting Public

, Ana Private Structures, Sand 77-1725, Fauruary 1976) is provided oy j tne Kensington Elementary School?

Kensington 4.3 Please explain why this cegree of protection is inadequate for an emergency response in tne event of a radiological emergency at Seaurook Station.

CONTENTION KENSINGTON 6 l Kensington 6.1 Please identify what letters of agreement are attil necessary to ensure the proper implementation of the emergency responsiutlities 1 assigned to tne Town of Kensington.

Kensington 6.2 l Has the Town of Kensington obtained any letters ot agreement with the necessary response organizations and emergency workers, including teachers? It so, please identify all such letters of agreement.

Kensington 6.3 i

Please describe what provisions an " appropriate" letter of l agreement shoald contain.

CollTENTIOff KEtJS INGTON 7

> Kennington 7.1 Please indicate how the IJHRLt<P, including tne Kensington HERP, i snould provide for tne administration of radioprotective drugs.

Please explain the oasts of tnis response, ano tuentify all documents

. supporting the response.

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CONTENTION KENSINGTON 10 Kensington 10.1 please state whether tne Town of Kensington's contention tnat tne state-local communication link is inadequate would be satistled if the red pnone at the Kensington EOC were moved trom tne ground floor to the second floor.

Kensington 10.2 If not, please explain how the NHRERP, including the Kensington RERP, snould be modified to provide properly tar tne communications requirement between state and local governments.

Respectfully submitted, THE STATE UF NEW HAMPSHIHZ STEPHEN E. MERRILL ATTORNEY GENERAL e i

! D,A Dated: April 30, 1986 By FY ' s hb '

George iDana utsoee Assistant Attorney General Enytronuental Protection Bureau Office of the Attorney General 25 Capitol Street concord, NH 03301-6397 Telephone (003) 271-3675

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