ML20210N539

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

ML20210N539
Person / Time
Site:	Seabrook
Issue date:	04/30/1986
From:	Bisbee G NEW HAMPSHIRE, STATE OF
To:	HAMPTON FALLS, NH
Shared Package
ML20210N476	List: ML20210N471 ML20210N489 ML20210N506 ML20210N515 ML20210N526 ML20210N539 ML20210N551
References
OL, NUDOCS 8605050140
Download: ML20210N539 (5)

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Ptmeu Con UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCME TE'n DiWc Before the -

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

) April 30, 1986 THE STATE OF NEW HAMPSHIRd'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE TOWN OF HAMPTUN FALLS ON THE NEW HAMPSHIRE RADIOLCGICAL EMERGENCY RESPONSE PLAN I. INSTRUCTIONS Pursuant to 10 C.F.R. Sections 2.71S(c), 2.740(u) and 2.741, the State of New Hampshire requests that the attacned Interrogatories ue answered fully in writing and under oatn by any otficials or the Town of Hampton Falls wno nave personal knowledge tnereot. Tne answer to eacn Interrogatory snould contain the name(s) and identification or the person (s) supplying the answer and wnether or not he or sne nas veritied the answer.

As used herein, the term " document" means all original writings of any nature wnatsoever and all non-identical copies tnetect in tue possession, custody, or control of the Town of Hampton Falls and includes but is not limited to tne following items: coumuntcations, correspondence, notes, field notes, studies, reports, summaries, instructions, charts, senedules, sketches and drawings, records, dCCounts and accounting records, opinions and reports of Consultants.

As used herein, the term " identify" means:

1. In the case of a natural person:

(a) name; (c) last-knosn adoress; (c) employer or business affiliation; and (d) occupatton and business position neid.

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2. In the case of a document:  ;

(a) identity of the person or persons preparing it; (b) its title or a description of the general nature of the subject matter; j (c) the identity of the addressee; ,

(d) date ot preparation; (e) identity of persons who can identify it; and I

(f) all of the aforementioned information should be supplied with sucn reasonaole particularity as is sutficient for a specific cemand for production. In lieu of the foregoing, a copy or the document may oe supplied.

3. In ene case or oral statements and communications:

(a) when and wnere they were made; (D) identity of eacn of the makers and recipients thereof; (c) the medium of communication; and I (d) substance of the statement and/or communication, pursuant to 10 C.F.R. Section 2.740(e), responses should ue supplemented under circumstances when new or ditferent intormation becomes available. If the Town of Hampton Falla cannot answer tne Interrogatories in full, so state and indicate when tne Town or Hampton Falls expects to be aole to answer the Interrogatory.

The State of New Hampshire further requests that the Town ot Hampton Falls, pursuant to 10 C.F.R. Section 2.741, provide copies of or make availaole for inspection and copying tne documents identitied by the Town of Hampton Falls in response to certain of the accompanying Interrogatories.

II. GENERAL INTERROGATORIES G.1 Please identify those contentions admitteu oy the Board's Order or April 1, 1986 on which the Town of Hampton Falls intends to introduce evidence in this proceeding.

G.2 For eacn contention identified in Interrogatory G.1, please idenfity all persons whom the Town of Hampton Falls intenas to call as witnesses. Please include a summary of the educational and professional oackground at each identified witness.

G.3 Provide a reasonaole description of the substance ot the testimony of each witness on each of the contentions identitled in tne answer to Interrogatory G.I. please also identity all documents which will De relied on in that testimony.

III. INTERROGATORIES RELATED TO SPECIFIC CONTENTIONS CONTENTION Hampton Falls 1 Hampton Falls 1.1 Is the Town of Hampton Falls developing, or nas it cevelopec, its own radiological emergency response plan? If so, please identify all cocuments relating to tne emergency planning undertaken ny tne Town of Hampton Falls including, without limitation, copies or the plan, craft plans, minutes of planning meetings, and correspondence relating to the Hampton Falls MERP.

Hampton Falls 1.2 If there is no Hampton Falls radiological emergency response plan, please explain how the Town ot Hampton Falls will respond in the event of a radiological emergency at Seabrook Station. In particular, please indicate wnat actions can De taken anc whtch actions will ne taken by the following officials in the Town or Hampton Falls in sucn event:

A) The Board ot Selectmen; B) Fire Department employees; C) Police Department employees; and D) Civil Defense Director.

Hampton Falls 1.3 In the event that officials in the Town of Hampton Falls do not carry out emergency response activities in tne event ot a raclological emergency at Seacrook Station, please indicate what official or agency should take responsibility for suen actions.

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CONTENTION Hampton Falls 2 Hampton Falls 2.1 Are the positions of RADCF officer and transportation officer in the Town of Hampton Falls expectec to De filled? If so, please indicate wnen tney will be filled. If not, please indicate wny they cannot be filled.

Hampton Falls 2.2 Please explain the basis of the Town of Hampton Falls' statement in the basis to Contention 2 that "[t]here is no demonstration that the duties assigned to local authorities in Hampton Falls by the plan can be met on a continuous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> casis".

Hampton Falls 2.3 Please explain how the NHRERP, including the Hampton Falls RERP, should provide for the necessary resources to meet the tasks assigneu to local Hampton Falls officials.

Hampton Falls 2.4 Please explain now the Town of Hampton Falls Fire Department employees respona to non-radiological emergencies requiring assistance from the fire cepartment, considering that "most ot [its]

members work out of town". Please also state whether tnese same procedures can ce used in radiological emergencies, and explain the

! basis for tnis response.

Hampton Falls 2.5 Please explain what procedures presently exist for carrying out the duties of the police chief in the event of a non-radiological emergency requiring the assistance of the police department wnen tne chief is not available. Please also state whetner these same procecures can be used in radiological emergencies, and explain the basis for the response.

CONTENTION Hampton Falls 4 Hampton Falls 4.1 Wno should be the initial point of contact in the event or a radiological emergency in the Town of Hampton Falls.

Hampton Falls 4.2 Wno shoula have the primary responsioility for activation of the puolic alerting system in the Town or Hampton Falls ?

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-S-Hampton Falls 4.3 Upon wnom are tne selectmen in tne Town ot Hampton Falls willing to rely as backup for tne responsibility of activating the public alerting system?

Hampton Falls 4.4 Wno, in the opinion of :ne Hampton Falls Selectmen, should be in direct charge of all emergency operations for the Town of Hampton Falls?

Hampton Falls 4.5 Wnat additional equipment .au s t , in the opinion of the Town of Haupton Falls, De provided f r the proper implementation of its radiological emergency response plan? Please include, without limitation, the following in jour response:

(a) How many pocket vol:e pagers are required; (D) What means or activa:Ing the alerting system is requirea; (c) Wnat numoer of tone alert radio receivers is necessary.

Hampton Falla 4.6 Please icentify eacn or :ne Hampton Falls emergency response organizations ano emergency personnel who, in the opinion of Hampton Ealls, w2'.1 not ce notifiec troperly in the event or a radiological emergency at Seaorook Station. Please explain the oasis ror this response, anc icentify all s.pporting documents.

Respectfully suomittec, THE STATE OF NEW HAMPSHIRE STEPHEN E. MERRILL ATTORNEY GENERAL s

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Dated: April 30, 1986 By /** 'b\ i George Daha Bisoee V Assistant Attorney General Environmental Protection Bureau Office or the Attorney General 25 Capitol Street Concord, New Hampsnire 03301 Telephone (603) 271-3676

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