ML20214G441
| ML20214G441 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/19/1987 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| Shared Package | |
| ML20214G402 | List: |
| References | |
| 82-471-02-OL, 82-471-2-OL, OL, NUDOCS 8705270068 | |
| Download: ML20214G441 (5) | |
Text
.
o 4tELMEQ WIWM DOCKET NUMBER g g
4 PROD. & UTIL FAC.,
UNITED STATES OF AMERICA.
000KETED NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
'87 MAY 20 PS :58 Before the Administrative Judges:
Helen F. Hoyt, Chairperson OTFICE F m, - % e Gustave A. Linenberger, Jr.
00CHLig r e vicr.
Dr. Jerry Harbour In the Matter of
)
Docket Nos. 50-433-OL
)
PUBLIC SERVICE COMPANY
)
(ASLBP No. 82-471-0 2-OL)
OF NEW HAMPSHIRE, g l. A l,.
)
(Offsite Emergency Planning)
)
~ (Seabrook Station, Unit 1)
)
May 19,1987 SEACOAST ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO APPLICANTS ON THE NHRERP INSTRUCTIONS FOR USE The Seacoast Anti-Pollution League hereby requests that the Applicants, pursuant to 10 C.F.R. 52.740(b) and S 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce and permit inspection and copying of the original or best copy of all documents identified in their response to interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents herein identified, the Applicants file suppl'emental responses'and produce additional documents as required by 10 C.F.R. S2.740(e).
0705270068 870519 PDR ADOCK 05000443' O
PDR,,
C
,- Where ider.tification of a document is' requested, briefly describe the document (e.g., book, letter, memorandum, report) and state the following information as applicable for the particular document; name, title, numbet, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person (s) having possession of the document.
The term " document [s]" as used herein shall mean 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-corporation or intra-office communications, notebooks, diaries, sketches, diagrams, maps, forms, manuals, brochures, lists, publications, draf ts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations, and all other written or graphic materials of any nature whatso-ever.
SAPL reiterates all of its general and specific interrogatories propounded to Applicants on March 5,1987 and requests that Applicants supplement and update its answers thereto pursuant to 10 CFR S2.740(e).
')
.- Further, SAPL propounds the following additional interroga-tories:
p 1
GENERAL INTERROGATORIES C)
For each witness identified in response to the prior-l' i-filed. general interrogatories referenced above, describe
-the substance of his or her testimony and identify any
. documents and the portions thereof that he or she may rely on for basis of testimony..
D)
_ Describe in detail all of the changes to the NHRERP that are' being made to' Revision 2 and _ state when the changes to the plans will be served on the parties to F
this proceeding.-
l SPECIFIC INTERROGATORIES 58)
Describe the area surveyed in. the_ on-foot survey, how many surveyors conducted the survey and the time of'_ day of the survey referenced in answer a to SAPL
+
Interrogatory 43.
How many dwellings total were in-cluded in the survey?
59)
In conducting its " empirical o6servation of the number of vehicles which can physically be accomodated within the beach' area", what area did KLD include as in the i-
">each area"?
Was Wallis Sands State Park' included?
1 as Odiorne Point State Park included? Was Jenness Beach included?
Was North Hampton Beach State Park included?
60)
State the location for each of the 17 New Hampshire l
-municipalities where traffic control devices will be.
stored.~ Also. state the locations of Department of.
Transportation garages near or within the EPZ as per g
l Applicants' response to SAPL Interrogatory $23.
I I
(
i.
f I
,.,,m m--,
m.-
4 61)
For each of the 17 local communities within the New Hampshire EPZ, state which local liaison is to be.the contact for that community from the NHCDA Incident Field Of fice in Newington, New Hampshire.
Provide the estimated time for each local liaison to travel from home to the IFO.
62)
Which two host care facility letters of agreement for special facilities are still missing (see SAPL Interrogatory 150)?
63)
State the names and qualifications and training of those individuals who performed the dose reduction effectiveness calculations for special facilities in the EPZ.
Detail the methodology they employed in per-forming their calculations.
64)
Provide an updated accounting of the evacuation assign-ments to be fulfilled by the 515 buses alleged to be sufficient for an evacuation of the Seabrook EPZ. For each of-the 17 local communities, provide a listing of the total number of buses needed for that community and then detail how that number of buses will be allotted within the community.
65)
For each of the two transportation staging ~ areas, state how many buses will be staged from each of those loca-l tions.
Detail where the buses will go from each of those areas.
Provide copies of the strip maps to be used to guide buses to the local staging areas.
i l
l l
I
e' O 66)
For each of the six towns dealt with in the " Personnel Resource Assessment Summary Developed in Support of Motions for Summary Disposition", list the names of the
" persons knowledgeable about the specific town" referenced at p. 2-2 with whom surveys were conducted to verify and adjust the numbers of required and available personnel resources.
67)
Are identification checks to be done at Access Control Points for +2ctermining whether vehicles will be allowed into the EPZ in the event an evacuation is in progress?
What is the estimated time per vehicle for performance of such an identification check?
68)
Since it cannot be determined from Appendix N what all of the roadway capacities assigned are, as claimed in answer to SAPL Interrogatory (20, list each roadway section in the EPZ and state to which of the 4 classifi-cations that roadway has been assigned.
Respectfully submitted, Seacoast Anti-Pollution League By its Attorney BACKUS, MEYER & SOLOMON DATED: Fhy 19, 1987
{
gp g u; 7RfBERTA.BACKUS 116 Lowell Street jL/ Manchester,NH 03105 603-668-7272 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing " Seacoast Anti-Pollution League's Interrogatories and Request for the Production of Documents to Applicants on the NHRERP" was sent this date, first class mail, postage prepaid, to all parties on the attached service list, and federal expressed to t e denoted by an asterisk.
SEE M.
n-obert A'. Backus b
-.