ML20214G478
| ML20214G478 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/19/1987 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Federal Emergency Management Agency |
| Shared Package | |
| ML20214G402 | List: |
| References | |
| 82-471-02-OL, 82-471-2-OL, OL, NUDOCS 8705270079 | |
| Download: ML20214G478 (9) | |
Text
- a WEIATED CORRE.S@fi@SA DOCKETNUMBER PROD. & UTIL FAC.,
Nfd 00(.KETED UNITED STATES OF AMERICA
'JSNHC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
'87 HAY 20 P5:58
-Before Administrative Judges:
OFF1'l 2 52 W v Helen F. Hoyt, Chairperson 00CHLiihG % MPviu.
Gustave A. Linenberger, Jr.
BRANCH Dr. Jerry Harbour In the Matter of
)
Docket Nos. 50-433-OL
)
PUBLIC SERVICE COMPANY
)
OF NEW HAMPSHIRE,-31. Al,. )
(ASLBP No. 82-471- 02-OL)
)
(Offsite Emergency Planning)
(Seabrook Station Unit 1)
)
May 19,1987 SEACOAST ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO FEMA ON THE NEW HAMPSHIRE RERP INSTRUCTIONS FOR USE
-The Seacoast Anti-Pollution League hereby requests that FEMA, pursuant to 10 C.F.R. S2.740(b) and S2.741, 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 ducuments herein identified, FEMA file supplemental responses and produce additional documents as required by 10 C.F.R. S2.740(e).
8705270079 870519 PDR ADOCK 05000443 PDR a
G
g, n -Where identification 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, number, 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, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations, and all other written or graphic materials of any nature whatso-ever.
I GENERAL INTERROGATORIES First, SAPL reiterates all of its interrogatories propounded to FEMA on March 5,1987, as corrected on March 11, 1987, and requests that FEMA supplement and update its answers thereto pursuant to 10 CFR S2.740(e).
j Further, SAPL propounds the following additional l
interrogatories:
i
4 va d
i -
C)
For each -witness identified in response to the prior-filed : general interrogatories referenced above, describe the substance of his or her testimony and identify and -
describe any documents and the portions 'thereof that he
.or she may rely-on for basis of testimony.
SPECIFIC INTERROGATORIES 1)'
Has FEMA as of this date received plans or other documents -which would in FEMA's -opinion correct-the inadequacies FEMA has found in NHRERP Rev. 2? If the answer is affirmative, detail the1 nature of the plans or documents and.the nature of the corrections therein.
2)
Has FEMA as of this date done an analysis of whether the deficiencies listed in the report of the February 26, 1986 exercise have been corrected? - If-the answer is affirmative, provide that analysis.
4 3)
Has FEMA, and/or_ its agents specifically assessed the adequacy of the New Hampshire state and local plans with respect to SAPL's contentions?
If the answer is af firmative, provide the. assessment for each contention for which said assessment has been done.
Respectfully submitted, Seacoast Anti-Pollution League By its Attorney BACKUS, M ER & SOLOMON
/ 47 E/
DATED:
MAY l 9, 1987 RoWerfg/. Backus l-116 Eowell Street 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 Requests for Production of Documents To FEMA On the New Hampshire RERP" was sent this date, first class mail, postage prepaid, to all parties on the attached service' list and federal expressed to thos e3 ted by an L
asterink.
//
k Rdbjht"A. Backus l-i l
l-l
. - - =. -
WTEDCORR4%M DOCKET NUMBER $<k3[4/(((-db PROD. & UTIL FAC.n -_
UNITED STATES OF AMERICA 00CMETED USNRC.
NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
+87 MAY 20 P5 :58 Before Administrative Judges:
Helen F. Hoyt, Chairperson OFFICE ;F H Cr% y Gustave A. Linenberger, Jr.
00CKliig.E9Viti.'
Dr. Jerry Harbour In the Matter of
)
-Docket No. 50-433-OL
)
PUBLIC SERVICE COMPANY
)
(ASLBP No. 82-471-02-OL)
OF NEW HAMPSHIRE, et. al.
)
(Offsite Emergency Planning)
)
(Seabrook Station, Unit 1)
.)
SEACOAST ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE STATE OF NEW HAMPSHIRE ON THE NHRERP The Seacoast Anti-Pollution League hereby requests that the
-. State ' of New Hampshire, pursuant to 10 C.F.R. S2.740(b) and
- S2.741, 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 h'erein identified, the State file supplemental responses and produce additional documents as required by 10 CFR S2.740(e).
m
l
. Where identification 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, number, 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, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations, and all other written or graphic materials of any nature whatso-ever.
l SAPL reiterates all of its general and specific l
l interrogatories propounded to the State of New Hampshire on March 5,1987 and requests that the State of New Hampshire i
supplement and update its answers thereto pursuant to 10 CFR S 2.7 40 (e ).
Further, SAPL propounds the following additional l
L
. interrogatories:
GENERAL INTERROGATORIES C)
For each witness identified in response to the prior-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 submitted to FEMA.
SPECIPIC INTERROGATORIES 57)
State the location for each of the 17 New Hampshire municipalities where traffic control devices.will be stored.
Also state the locations of Department of Transportation garages near or within the EPZ.
58)
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 Office in Newington, New Hampshire.
Provide the estimated time for each local liasion to travel from home to the IFO.
59)
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 performing their calculations.
60)
Provide an updated accounting of the evacuation assign-ments to be fulfilled by the 515 buses alleged to be
. Eufficient 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 allocated within the community.
61)
For each of the two transportation staging areas, state how many buses will be staged from each of those loca-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.
62)
Has the American Red Cross obtained agreements with mass care facilities in the host' communities?
List the f acilities involved and their capacity for housing evacuees.
63)
Have 80 CDV-700 Survey Meters been provided to each -
of the host communities as of this time?
64)
Detail the~ procedure to link Local 633 Teamsters Union and the State EOC as mentioned in'the State's response to SAPL Interrogatory (41.
65)
Did the Portsmouth Naval Shipyard raise any concerns in providing emergency assistance to the State during a radiological emergency at Seabrook?-
66)
What host care facility plans for special facilities in the EPZ are yet to be obtained?
- . i
. 67)
Are identification checks to.be done at Access Control Points for determining whether vehicles will be allowed
.into the EPZ in thefevent an evacuation is in progress?
What is the estimated time per vehicle for performance of such an identification check?
6 8). What are the public buildings in the beach area in which transients without transportation may take shelter ' referred to in the " Affidavit of William T.
Wallace on Sheltering" filed by the Applicants on March 25, 19877 Has the permission of the building owners been obtained?
If yes, by whom?
69)
Have campgrounds been equipped with tone alert radios as of this time?
70)
Provide the names of the 15 Rockingham County Sheriff 's deputies and detail to which transportation staging area each is to be assigned.
Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By its Attorney BACKUS, MEYER & SOLOMON DATED: May 19,1987
[p Robert A. Backus 116 Lowell Street 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 the State of New Hampshire on the NHRERP" was sent this date, first class mail, postage prepaid to all those listed on the attached service list and federal expressed to those indicated by an asterisk.
p h
Jp Rdbert A. Backus
CERTIFICATE OF SERVICE AND SERVICE LIST A f.rs H e%H J' ore Asst.Gn.Cnsl.
IIelen Hoyt. Chm.
Thomas Dignan, Esq.*
Fcd. ph Flynndgmt. Agcy.
Admn. Judge Ro3es & Gray Emerg.
500 C.St. Sc. West Atomic Safety & L'E7 M.20 PSM Franklin St.
Washityton, DC 20472 USNRC Boston, MA 02110 Washington, DC g5 ;
00CKE hre *.
e a!.I Office of Selectmen Dr. Jerry Harbour
- BRANC" Docketing & Serv. Sec.
- Town of Hampton Falls Admin. Judge Office of the Secretary Hampton Falls, NII 03844 Atomic Safety & Lic Brd.
USNRC USNRC Washington, DC 20555 Washington,'DC 20555 Sherwin E. Turk, Esq.
51' Dr. Gustave A. Linenberger
- Jane. Doughty Office of Exec. Legl. Dr.
Admin Judge SAPL USNRC Atomic Safety & Lic. Brd, 5 Market Street W;chington, D.C.
20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 Phi 11ip Ahrens, Esq.
Paul McEachern, Esq.
George Dana Bisbee, Esq.
A st. Atty. General Matthew BInck, Esq.
Attorney General's OFF.
State House, Sta. #6 25 Maplewood Ave.
State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsmouth, NH 03801 Carol Sneider, Esq., Asst.AG Diane Curran, Esq.
William S. Lord Ono Ashburton Place, Ila r m o n, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.
Boston, MA 02108 Washington, DC 20009 Amesbury, MA 01913 Richard A. Hampe, Esq.
Maynard Young, Chainmn Sandra Gavutis New Hampshire Civil Detense Board of Selectmen Town of Kensington Agency 10 Central Road Box 1154 Hanpe & McNicholas Rye, MI 03870 East Kingston, N.H.
03827 35 Pleasant St Concord, NI 08301 Judith H. Mizner, Esq.
Edward 'Ihomas Mr. Robert Harrison Silverglate, Gertner, FEMA Pres, & Chief Exec. Officer Baker, Fine, Good & Mizner 442 J.W. McConmck (POGI)
PSCO 88 Broad Street Boston, MA 02109 P.O. Box 330 Boston, MA 02110 Manchester, NH 03105 Roberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, MI 03844