ML20212K320

Atty General Jm Shannon Offsite Emergency Planning Interrogatories & Request for Production of Documents to FEMA (Set 1).* Propounds Listed Interrogatories to FEMA to Be Answered in Writing by 870319.Related Correspondence

ML20212K320
Person / Time
Site:	Seabrook
Issue date:	03/05/1987
From:	Bronstein D MASSACHUSETTS, COMMONWEALTH OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20212K324	List: ML20212K320 ML20212K348 ML20212K370
References
CON-#187-2725 OL, NUDOCS 8703090273
Download: ML20212K320 (12)

Text

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r 00CNETED USNRC UNITED STATES OF AMERICA ig sht -6 P3:53 NUCLEAR REGULATORY COMMISSION

, ,, y Before Administrative Judges: #'$h[l[ '

Helen F. Hoyt, Chairperson i Gustave A. Linenberger, Jr.

Jerry Harbour

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In the Matter of )

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PUBLIC SERVICE COMPANY OF NEW ) Docket Nos.

HAMPSHIRE, ET AL. ) 50-443/444-OL (Seabrook Station, Units 1 and 2) ) (Off-Site EP)

) March 5, 1987

)

ATTORNEY GENERAL JAMES M. SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF j DOCUMENTS TO THE FEDERAL EMERGENCY MANAGEMENT AGENCY (SET NO. 1)

Pursuant to 10 C.F.R. S2.740 and 2.740b, Attorney General James M. Shannon hereby propounds the following interrogatories to the Federal Emergency Management Agency (" FEMA"). These interrogatories are to be answered in writing on or before March 19, 1987 and under oath by an employee, representative' ,

or agent with personal knowledge of the facts or information requested in each interrogatory.

Definitions As used in these interrogatories, the following terms have the following meanings:

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1. " Litigate"~with~ regard.'to a topic or contention means to offer direct testimony relating.to, to cross-examine on,.to offer proposed findings or rulings regarding, or to urge:the denial (or allowance subject to conditions) of-the pending application on:the basis-of the topic or contention.

-2. " Contention to be litigated by the Attorney General" means those contentions admitted in this proceeding by the Order of the Licensing Board, dated February 18, 1987 and specified in " Attorney General James M. Shannon's Notice of Intention To Participate On Newly Admitted Contentions," dated .

March 2, 1987. Specifically, those contentions are ToH' Revised-Contention-III; ToH Revised Contention VI; ToH Revised Contention VIII; NECNP Contention RERP-8; SAPL Revised Contention 31; Reasserted SAPL Contention 8; SAPL Contention 8a; Reasserted SAPL Contention 16; SAPL Contention 33; and SAPL Contention 34.

'3.- " Document" means any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks,

e diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

4. . " Identify" with respect to any document means to state the following respecting the document: its title, its date, the author of the document, the person to whom the document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.

5. " Identify" with respect to any action or conduct means to state the following regarding any such action or conduct:

the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; any document recording or documenting such action.

6. " Describe" with respect to any action or matter means to state the following regarding such action or matter: the substance or nature of such action or matter; the persons participating in or having knowledge of such action er matter; the current and past business positions and addresses of such persons; the existence and location of any and all documents relating to such action or matter.

7. " Identify" with respect to an expert witness means to state:

E' (a) The name, mailing address, age and present professional.or employment affiliation of the person; (b) The profession or occupation and field of claimed expertise of the person; (c) The history of formal education or training of the person, including, but not limited to, (i) the name and address of each school where the person received special education or training, (ii) the date those schools were attended, and (iii) a description of each degree earned, including the date and granting institution; (d) The history of specialized training in the area of claimed expertise, including, but not limited to, (i) the type of training received, (ii) the name and address of the institution providing this training, and (iii) the dates of such training; (e) A list of publications of any kind by the person in the area of claimed expertise, including, but not limited to, (i) the title and subject matter, (ii) the name and address of the publisher, and (iii) the date of publication; (f) A list of any and all licenses in the area of claimed expertise, including, but not limited to, (i) the designation of the authority by which the license was issued, (ii) the date(s) of the licensing, (iii) the requirements for obtaining each license, and (iv) the manner by which these requirements were met;

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o (g) The amount of time the person has worked in the field of claimed expertise, stating periods where work was other than on a full-time basis; (h) The name and address of every person, or every corporation or other institution, that has employed the person within the last ten years of employment; (i) All periods of claimed self-employment, including a description of all duties and responsibilities thereof; (j) All previous experience in the field of claimed expertise which involved problems, analyses or studies similar to those concerning which the person is expected to testify in this proceeding; (k) All other litigation in which the person has been consulted, specifying those matters in which the person has testified, including the name of the case or matter and the court or other forum in which testimony was given; and (1) Any other experience in the field of claimed expertise.

8. " Identify" with respect to a non-expert witness means to state:

(a) The name, mailing address, age and present professional or employment affiliation of the witness; (b) The profession or occupation of the witness; (c) The name of the supervisor and department of the witness;

(d) The current employment or professional relationship, if any, between the witness and you; (e) The past employment or professional relationship between the witness and you, including the dates of that relationship; and (f) All litigation in which the person has testified on any matter in which you have had an interest, including the name of the case or matter and the court or other forum in which testimony was given.

Wherever appearing in these interrogatories, the masculine form is defined to include the feminine and/or the neuter and the singular form is defined to include the plural wherever necessary to apply the context to any factual situation that may exist or to render the interrogatory more inclusive in scope.

Notice Regarding Supplementation Your attention is called to the provisions of 10 C.F.R.

S 2.740(e) regarding your obligation to supplement interrogatories and requests for the production of documents.

Request for the Production of Documents Pursuant to 10 C.F.R. S 2.741, you are hereby requested to produce, for inspection and copying, each document identified in response to these interrogatories and each document required

.. p to be identified in response to these interrogatories, at the offices of_ Attorney General James M. Shannon, Room 1902, One Ashburton Place, Boston,-MA 02108 on March 19, 1987 at 10:00 l o' clock a.m. Each document produced in response to~this

(- request should be labeled to indicate the interrogatory or i

interrogatories in response to which it is produced.

I INTERROGATORIES l

1. Describe in detail your position with respect to each contention to be litigated by the Attorney General and each subpart of each such contention. Describe in detail the reasons for your position.

2. Identify and produce all documents on which you have relied, do rely, or will rely to support your position on each of these contentions. Identify the information in each document on which you have relied, do rely, or will rely and the specific subpart of each contention which that information l

l concerns.

l 3. State whether you have relied, do rely, or will rely on i

any study, calculation, or analysis to support your position on each of these contentions. If so, please:

l (a) Describe the nature of the study, calculation or analysis and identify any documents that discuss or describe the study, calculation or analysis; (b) Identify the persons who performed the study, calculation or analysis; t .

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(c)~ State when and where the study, calculation or analysis was performed; (d) Describe in. detail the information or data that was studied, calculated or analyzed; (e)-Describe the results of.the study, calculation or analysis; (f) Explain how such study, calculation, or analysis provides support for your position'on each of these contentions.

4. Do you intend to offer the testimony of any expert witness with respect to any contention to be litigated by the Attorney General? 'If so, please:

(a) Identify each expert witness who you intend to present with respect to each subpart of each such contention; (b) State the substance of the facts to which each expert witness is-expected to testify; (c) State the substance of the opinion or opinions to which each expert witness is expected to testify; (d) Provide a summary of the grounds for each opinion to which each expert witness is expected to testify; (e) State whether the facts and opinions listed in response to the foregoing are contained in any documents (f) State whether the opinion of any expert witness is based in whole or in part on any scientific rule or principle, and, if so, set forth such rule or principles (g) State whether the opinion of any expert witness is based in whole or in part on any code or regulation,

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= governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon; and (h) State whether the opinion of any expert witness is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.

5. Do you intend to offer the testimony of any non-expert witness with respect to any contention to be litigated by the Attorney General? If so, please:

(a) Identify each non-expert witness who you intend to present with respect to each subpart of each such contention; (b) State the substance of the facts to which each non-expert witness is expected to testify; and (c) State whether the facts listed in response to the foregoing are contained in any document, and produce the same.

6. Identify and produce all documents in which you or any agent on your behalf have assessed the adequacy of state and local emergency plans with respect to any contention to be litigated by the Attorney General. Include in your response any documents concerning steps which have been taken or will be taken by the State of New Hampshire or the Applicants to address inadequacies in any past or current local plans.

7. Are peak summer day evacuation time estimates for the populations within two miles, five miles and ten miles of the Seabrook plant longer than the average two-mile, five-mile,

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and ten-mile EPZ evacuation time estimates for nuclear power plants.in this country?

8. Please provide the names of all nuclear power plants that have longer evacuation time estimates for populations located within two miles, five miles and ten miles of those plants than does the Seabrook reactor. Include those respective time estimates for each plant.

9. Is population density greater for the areas within two miles, five miles, and ten miles of the Seabrook plant than the average population densities for areas within two miles, five

-miles and ten miles of all other nuclear reactors in this country?

10. Please provide the names of all nuclear power plants in this country that have higher population densities in the areas within two miles, five miles and ten miles of the plants than does the Seabrook reactor.

11. Is there a larger summer transient population within two miles, five miles or ten miles of the Seabrook plant than there-is within two miles, five miles, or ten miles of all other operating reactors in this country.

12. Please identify all nuclear power plants in this country that have a larger summer transient population than does the Seabrook plant for the areas located within two miles, five miles, or ten miles of the plant, and for each of those reactors indicate what provisions, if any, have been made to

l shelter the transient population; where such population is situated with respect to that reactor; the average dose reduction factor of shelters used for that population; evacuation time estimates for that' population if it were to be evacuated; the location with respect to the transient population of any sheltering they will be expected to use; whether that population is predominantly a beach population; whether sufficient sheltering capacity exists to shelter the entire transient population; and if sufficient capacity does not exist to enable ths sheltering of the entire population,

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state for what percentage of the population sufficient sheltering capacity exasts.

13. Will emergency planning for the area within ten miles of the Seabrook plant effectuate less " dose reduction" than the average dose reduction for all other nuclear plants in this -

country, assuming comparable radiological releases in the event

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of an accident?

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14. compare the average dose reduction expected to be s I #

effectuated for the summer transient beach population within ten miles of the Seabrook plant to the average dose reduction expected to be effectuated, for persons within ten miles of all other reactors in this country, assuming comparable radiological releases in the event of an accident.

15. please provide the basis for your response to interrogatories 13-14 and any documents relevant to your responses.

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16. Do homes withingthe Seabrook ten-mile EPZ have on the i

average a lower dose reduction factor thai do homes around all other nuclear reactors'in this country $ ',

17. Compare the average dose reduction factor of homes within the Seabrook ten-mile EPZ beach area to. average dose reducti'n o factors of homes around other reactors.

18. $1*as'e provide the basis for your responses to interrogatories.16-17 and any documents relevant to your response.

JAMES M. SHANNON ATTORNEY GENERAL

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2 Donald S. Bronstein

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~~ Carol.S. Sneider ~

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Assistant Attorneys General Environmental Protection Division One-Ashburton Place,'Rm. 1902

. Boaton, Massachusetts 02108 617-727-2265 Date: March 5, 1987

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