ML20212P320

New England Coalition on Nuclear Pollution First Set of Interrogatories & Request for Production of Documents to Applicants on Rev 2 to Util Radiological Emergency Response Plan.* Related Correspondence

ML20212P320
Person / Time
Site:	Seabrook
Issue date:	03/05/1987
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20212P218	List: ML20212P215 ML20212P238 ML20212P273 ML20212P292 ML20212P320 ML20212P331
References
OL, NUDOCS 8703160067
Download: ML20212P320 (6)

Text

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s' March Sp l987' J >

UNITED STATES NUCLEAR REGULATORY COMMISE$0NI ,

BEFORE~THE ATOMIC SAFETY AND LICENSING BOARD

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In -the Ma tter of )

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Public Service Company of )

New Ha mp s hi re, et-al. ,) Docket Nos. 50-443 OL

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, 50-444 OL-(Seabrook Station, Units 1 &'2) ) 'OFFSITE EMEFGENCY-

)" PLANNING ISS'UES

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l NEW ENGLAND COALITICt! ON t;UCLEAD POLLUTICN'J, , ,

FIPST SET OF INTEPPCGATORIES AND RECUEST FOP 4 THE PRODUCTIO!! CF EOCUMENTS [TO APPLICANTS e ON REVISICN 2 .TO THE NFW HAMPS'HIPE RADIOLCGICAL EMEFGENCY HESPONSE PLAN J

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INSTPUCTICt!S FOP USE ~

The following interrogatories are to be answe ed .in wr iting and under oath ty an employee, representative or agont of[the Applicants with personal knowledge of the facts op<information requested in each interrogatory. We remind you of your obliga-

+>y tion to supplement answers to interrogatories, under 10 C.F.F. ,5 2.740(e). ,

.s The following definitions shall apply,tb these inter-rogatories:

1) " Document" shall mean any written or cruphic matter of c ommu nica tion, however produced or reproduced, and dis intended to be comprehensive and include without limitation any and all cor-respondence, letters, telegrams, agreements, notes, con:racts, instructions, reports, demands, memoranda, data, schedules, s notices, work papers, recordings, whether electronic or by other.

8703160067 B70305 PDR ADOCK 05000443 9 PDR

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_2-means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office commu nica tions , notebooks, diaries, sketches, diagrams, forns, 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.

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2) '" Identify" with respect to any document shall mean..to state the following: the document's title, its date, the author o f the document, the person to .whom to document was sent, all persons who received or reviewed the f ocum e n t , the substance and nature of the document, and'the present custooian of the document ano of any and all copies of the document.

3) " Identify" with respect t'o 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; and any document recording or documenting such action.

4) " Identify" with respect to an individual shall mean state the individual's name, address, employer, occupation, and title.

5) " Describe" with respect to any action or matter shall mean state the following regarding such action or matters the k

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a 3-s substance or nature of such action or matter; the persons partic- ,

ipating in or having knowledge of such: action or_ matter; the cut-rent and pant business positions and addresses of such persons; and the existence and location of any and all documents relating to such action or matter.

6) "Applic;snts", shall include any of the Seabrook owners; 1:ew Hampshire Yankee; or any contractor's retained by the Seabroo'k owners or New Hampshire Yankee to prepare or evaluate the ,New

+ Hampshire Radiological Emergency Pesponse Plan.

CENEPAL IMTERFCGATCRIES

1) In' accordance with 10 C.F.P. S 2. 7 4 0( d ) , please supple; nent your answers to MECNP's Fi r st Se t of In ter rogatories and Pequests for the Production of Documents to Applicants on New Hampshire Radioloaical Liergency Pesponse Flans, filed April 30, 1986. '

2) What is Applicants' ~ position en eacn of the contentions

.that has been admitted in this proceeding with respect to Pevi-sion 2 of the New Hampshire Radiological Emergency Response Plan? ,

What is the basis for your position?

3) on or before March 19,. 1987, please produce at the of fice of Harmon & Weiss all documents on which you rely or intend to rely during this proceeding to support your position on

.each of the contentions that have been admitted in this proceed-i

.ing with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan. This inpludes but is not limited to all L

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documents used in answers to these interrogatories, summary dis-position motions, testimony, and cross-examination of witnesses during hearings.

4) Please identify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to rely for your position on each of the contentions that has been admitted in this proceeding with respect to Pevision 2 of the New

!!ampshire Radiological Emergency Pesponse Plan.

5) Please identify all persons you may call as witnesses

..n each of the contentions that has been admitted.in this pro-ceecing with respect to Pevision 2 of the New ifampshire

."adiological Exe rcency Fesponse P lan. Please describe the sub-stance of their testimony; and identify and describe any docu-ments and the portions thereof that they may rely on for.their testimony.

6) Cn or before March 19, 1987, please produce in the office of Harmon & Weiss all documents in the Applicants' posses-sion which analyze or evaluate in any way the adequacy of the New Hampshire REPP or New Hampshire's state of preparedness in the event of a radiological emergency.

7) Please identify all persons who participated in the development or draf ting of Revision 2 to the New Hampshire RERP.

8) Please identify all persons who are responsible for training of emergency response personnel for implementation of Revision 2 to the New Hampshire RERP.

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9) Please describe all plans for training emergency response personnel under Revision 2 of the RERP. Identify all individuals who are responsible for that program.

INTERROGATOPIES REGARDING SPECIFIC CONTENTIONS NHLP-6 and HAMPTON REVISED CCNTENTION IV TO REVISICN 2

, 10) _ Identify, describe and/or produce any communications or agreements between the Teamsters Union and its member drivers regarding the NHREPP.

11) Provide copies of regular employment contracts of drivers in the Teamsters Union who will be relied on during a radiological emergency.

12) Provide all agreements or correspondence between the Teamsters Union or Union of ficials, Applicants, or the State of a

New Hampshire, regarding the possible provision of transportation services by Teamsters members during a radiological emergency.

HAMPTCM REVISED CCNTENTICN VIII TO PEVISION 2

13) NUREC-0654 states that "the overall objective of emer-gency response plans is to provide dose savings (and in some cases immediate life savings for a spectrum of accidents that could produce offsite doses in excess of Protective Action Guidelines (PAGs) ." In this vein, NUREG-0654 requires planners to consider, inter alia, the timing and consequences of potential releases. What spectrum of accidents did Applicants consider in developing Revision 2 to the NHRERP, and what are the character-istics of those accidents? What quantitative dose savings result

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from implementation of the protective measures proposed in Revi-sion 2, given each type of accident that was considered? Please provide all data that supports your conclusion.

14) Assuming that dose reductions are achieved, describe the health effects associated with each of the accidents that you considered in developing Revision 2 to the RERP.

15) Identify and provide access to any and all of Applicants' calculations of potential dose consequences to the public in the event of a radiological emergency at Seabrook, and the bases for those calculations.

c espectfully submitted, J

_ ane Curran HARMON & WEISS 2001 "S" Street N.W. Suite 430 Washington, D. C . 20009 (202) 328-3500 March 5, 1987 I certify that on March 5, 1987, copies of the foregoing interrogatories were served by Federal Express or by hand on the NRC Staff, the Executive Director for Operations, the Licensing Board, the State of New Hampshire, FEMA, and Applicants; and by first-class mail on all other part listed on the attached ser-vice list.

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Diane Curran