ML20212K360
| ML20212K360 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/05/1987 |
| From: | Mceachern P HAMPTON, NH, SHAINES & MCEACHERN |
| To: | NEW HAMPSHIRE, STATE OF |
| Shared Package | |
| ML20212K311 | List: |
| References | |
| OL, NUDOCS 8703090284 | |
| Download: ML20212K360 (8) | |
Text
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s REUTED CORRESPONDM DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION W MR -6 P3 :59 Before the Nuclear Regulatory Commis'sion-50-4 h M {yfy-In the matter of Docket Nos.
50-4 4 4-OIFif Ancy PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE Seabrook Statigar-Units I and II TOWN OF HAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE STATE OF NEW HAMPS}! IRE ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS INSTRUCTIONS EDE LSE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the State of New Hampshire w ith personal knowledge of the facts or information requested in each interrogatory.
We remind you of your obligation to supplement answers to interrogatories, under 10 C.F.R. S 2.740(e)(1) and (2).
The following definitions shall apply to these interrogatories:
1.
"D o c u men.t" shall mean any written or graphic matter or communication, however produced or reproduced and is intended to be comprehensive and include without limitation any and all corres-pondence, letters, tel egrams, agreements, notes, contracts, instruc-tions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts,
- analyses, int ra-co rpo rate or intra-office communications, notebooks, 87030902s4 870305 PDR ADOCK 05000443 9
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- diaries, sketches,
- diagrams, forms,
- manuals, brochures, lists-publications,. drafts, telephone minutes, minutes of meetings, state-ments, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.
2.
" Identify" with respect to any document shall mean 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.
3.
" Identify" with respect to any action or conduct shall mean 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 docu-ment recording or documenting such action.
4.
" Describe" with respect to any action or matter shall mean i
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 or 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.
5.
" Rata Rage" shall mean all facts,
- opinions, documents, statistics, surveys, computations,
- reports, studies, memoranda, 2
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. persons, identified by name, title, position, or other and similar sources, inputs or information, in whatever form, upon which State of New Hampshire relied or relies on to prepare or support the NHRERP Revision 2.
INTERROGATORIES:
1.
With respect to each contention and subpart thereof filed by.
the Town of Hampton and admitted by_ the Licensing Board's order of February 18, 1987, please provide the following information:
a.
What is State of New Hampshire's position with respect to each contention and its subparts?
Describe in detail the reasons for your position.
b.
Identify and provide access to all documents and the Data Base on which you rely to support your position on each of these contentions.
This includes the Data Base used, or to be used, in your answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings.
c.
Identify all persons on whose factual knowledge, opinions, or technical expertise you rely for your position on each contention and subpart thereof.
d.
Identify all persons you may call as witnesses on each of these contentions during these proceedings; describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.
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. 2.. Please explain and provide the Data Base for each.of the following' facts, statements, assumptions or conclusions in the. NHRERP Revision 2, and-identify and provide reasonable access to all docu-mentsion which you rely to~ support your-answers to this interrogatory:
a.
That the number of persons comprising the Town of Hampton resident population is 13,234.
Please define " resident population" and f ully explain ' and provide the Data Base for.why this figure differs from that used in prior drafts of the NHRERP and identify all persons included within this population figure.
b.
That the number of persons comprising the Town of.Hampton peak summer weekend population -is 36,635.
Please define " resident population" and-fully explain and provide the Data Base for why this figure. differs from that used in prior drafts of the NHRERP'and
-identify all persons included within this population figure.
c.
That'the number of persons comprising the Town of Hampton peak summer midweek population is 34,337.
Please define " resident population" and fully explain and provide the Data Base for why this
' figure differs from that used in prior drafts of the NHRERP and identify all persons included -within this population figure.
d.
That there will be a vehicle occupancy rate of 2.4 persons during an evacuation.
f e.
That ETE will be reduced by twenty (20%) percent for rain.
f.
That ETE will be reduced by twenty-five,(25%) percent for snow.
g.
That all roads will remain passable during evacuation.
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h.
Th'at recommended traffic c ont'r ol tactics will b'e in effect during an evacuation.
i.
That' there will be three thousand (3,000) "through" vehicles' traveling through the EPZ at the time of evacuation, j.
That twenty-five (25%) percent of the EPZ population will spontane'ously evacuate.
k.
That evacuees will in fact evacuate to their assigned host communities.
1.
That the bus drivers identified by Letter Agreement, including the teamsters, have the training and experience to evacuate
-the disabled, medically impaired, and student populations.
3.
Provide the total number, and.the Data Base used to compute the following:
a.
Town of Hampton peak beach population, b.
Town of Hampton transit dependent population.
c.
Town of Hampton transient population.
'd.
Town of Hampton school population, including pupils, teachers and administrators.
e.
Town of Hampton special needs population.
f.
Vehicles to be evacuated from the Town of Hampton, including emergency vehicles, under each scenario identified by KLD in its ETE.
g.
For each population group identified in interrogatories 3(a) - (e), number and provide the Data Base for each such group in the entire EPZ.
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4.
Identify, describe,.and provide the-Data Base to-support any change in'the-population figures, for each group identified in Interrogatory #3, between the NHRERP Revision 2 and all prior drafts of.. the NHRERP.
5.
Please identify and describe whether the NHRERP Revision 2 makes provision to modify or provide alternative protective. responses if the wind direction or weatha t should change during an emergency.
. Identify the relevant sectionh of the NHRERP and provide the Data Base to support your answer.
6.-
Please identify and describe whether the NHRERP Revision 2 I
addresses or otherwise makes provision for population growth within the EPZ.
Identify relevant sections of the NHRERP and provide the Data Base to support your answer.
7.
Please identify and describe whether sheltering may be used as a protective response for any population group or groups between May 15th. and September 15th of each year.
Identify and explain whether sheltering during said time period will be utilized or relied on in any manner to satisfy the criteria for licensing set-forth in 10 C.F.R.
S 50.47 (a)(1).
Provide the Data Base to support your answer.
8.
With respect to the Compensatory Plan, please identify, describe, and provide the Data Base, for the following:
a.
All personnel, identified by title and position; equip-ment; evacuation and emergency vehicles; and all other resources of 6
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whatever kind or. description, which State of New Hampshire believes are available to carry out the Compensatory Plan, in the event a municipality or municipalities are unable or unwilling to implement the NHRERP.
b.
The present location of each person, vehicle, item of equipment or resource identified in Answer # 7(a).
c.
The name, title, and position of every school teacher, administrator, or other school official who has volunteered to carry out NHRERP duties, and identify, describe, and provide the complete Data Base in support of your answer.
d.
The name, title, and position of any medical, special needs or health care facility staff, employees, or adminstrators, including any persons employed at the Seacoast Health Center, who have volunteered to carry out any NHRERP duties, and identify, describe, and provide the Data Base in support of your answer.
9.
Identify and describe all corrective actions of whatever kind g
undertaken by, or on behalf of, State of New Hampshire with respect to the deficiencies identified by FEMA in its Final Exercise Assessment, February 26, 1986.
Identify and describe all such deficiencies, or any deficiencies identified by FEMA at any time, which State of New i
i Hampshire believes still require corrective action and the nature of such corrective action, which State of New Hampshire intends to undertake.
10.
Identify and descrica all corrective actions of whatever kind undertaken by, or on behalf of, State of New Hampshire with respect to 7
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,w the RAC comments and recommendations in EAC REVIEE E THE STATE DE HEH HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN EQB SEABROOK.
Identify and describe any such RAC comments or recommendations, or comments or recommendations made by RAC at any time, which State of New Hampshire believes still require corrective action and the nature of the correc-tive action that State of New Hampshire intends to undertake.
11.
Identify and produce for inspection and copying at the offices of Shaines & McEachern, P.A., 25 Maplewood Avenue, Portsmouth, New Hampshire 03801, all documents upon which you rely to support your answers to interrogatories 1 through 10.
Respectfully submitted, SHAINES & McEACHERN, P.A.
Attorneys the Town of mpton aul McEachern 8
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