ML20214N285
| ML20214N285 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/19/1987 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | NEW HAMPSHIRE, STATE OF |
| References | |
| CON-#287-3584 OL, NUDOCS 8706020126 | |
| Download: ML20214N285 (6) | |
Text
r I'(
a
}6 4EtMED CORRESPONDENC(
May 19,1987C:qtum UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BbkRLliAY 22 P5:11 I
)
. e:
In the Matter of
)
)
Public Service Company of
)
New Hampshire, et al.
)
Docket Nos. 5 0-443 OL
)
50-444 OL (Seabrook Station, Units 1 & 2)
)
OFFSITE EMERGENCY
)
PLANNING ISSUES
)
NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S THIRD SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO STATE OF NEW HAMPSHIRE ON REVISION 2 TO THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN INSTRUCTIONS FOR USE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the State of New Hampshire with personal knowledge of the facts or s
3 information requested in each interrogatory.
We remind you of your obligation to supplement answers to interrogatories, under l
10 C.F.R. S 2.740(e).
The following definitions shall apply to these inter-rogatories:
1 1)
" Document" 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 cor-respondence, letters, telegrams, agreements, notes, contracts,
(
instructions, reports, demands, memoranda, data, schedules, noticee, work pap'ers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, 8706020126 870519 PDR ADGCK 05000443 0Sh 0
_.2 microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, j ournals, 1
orders, confirmations and all other written or graphic materials i
of any nature whatsoever.
2)
" Identify" with respect to any document shall mean to state the following:
the document's title, its date, the author of the document, the person to whom to 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; 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.
l 5)
" Describe" with respect to any action or matter shall mean state the following regarding such action or matter:
the substance or nature of such action or matter; the persons partic-
. ipating in or having knowledge of such action or matter; the cur-rent and past business positions and addresses of such persons; and the existence and location of any and all documents relating to such action or matter.
INTERROGATORIES 1)
In accordance with 10 C.F.R.
S
- 2. 740(e), please supple-ment your answers to NECNP's previous sets of interrogatories, filed April 30, 1986, March 5, 1987, and April 2, 1987.
2)
Please provide the names, titles, and work and home addresses of all personnel who are listed as "Available" in Table 3.1-3 of Applicants' " Personnel Resources Assessment Summary Developed in Support of Motions for Summary Disposition."
For each individual identified above, please provide the following information:
a.
Has that person been assigned to a specific local emer-gency response function?
If so, what are his or her responsibilities?
b.
Has that individual been informed of his or her responsibilities during a radiological response at Seabrook?
If so, how was he or she informed?
c.
Has that individual consented to carry out his or her responsibilities?
If so, how was the consent obtained?
d.
Please identify those individuals who have been trained for an emergency response, and state when that training took place and by whom the training was conducted.
Was the training focused on the individual's specific responsibilities?
1
_4-3)
Please identify all New Hampshire state employees who participated in the preparation of or who consulted with Applicants on the preparation of Applicants' " Personnel Resources Assessment Summary Developed in Support of Motions 'for Summary Disposition."
For each such individual, what was that person's role?
4)
In response to NECNP's Second Set of Interrogatories on Revision 2, Interrogatory No.11, you stated that "Many of the responders are stationed in the EPZ on a daily basis.
Some would travel from Concord, approximately a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> drive.
For full implementation of the RERP, approximately 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> would be needed.
This ' figure is based upon exercises and drills that have been conducted."
Please provide the following additional information with respect to these answers:
a.
How many of the responders are stationed in the EPZ on a daily basis?
Of these, how many are individuals who are sta-tiened in the EPZ every day?
How many are individuals who may report to the EPZ once in a while?
How frequently do those indi-viduals go to the EPZ?
b.
Would the rest of the State employees come from Concord?
If not, how many would come f rom Concord?
How many would come from other places, and where would they come from?
How long would it take them to reach the EPZ?
c.
From what other locations would those employees come?
4
m
. 5)
Please identify, describe and provide access to all documents that you relied on or considered in answering these interrogatories.
Respectfully submitted, Diane Curran HARMON & WEISS 2001 "S" Street N.W.
Suite 430 Washington, D.C.
20009 (202) 328-3500 May 19,1987 I certify that on May 19, 1987, copies of the foregoing interrogatories were served by Federal Express on the NRC Staff, the Licensing Board, the State of New Hampshire, and Applicants; and by first-class mail on all other parties listed on the attached service list.
Diane Curran l
y
.~
SEABR001 SERVICE LIST -- 0FFSITE LICENSING BOARD Clen F. Hoyt, Chairsan North Haspton, NH 03826 442J.W.McCoreack(P0CH)
Atoeic Safety and Licensing Boston,MA 02109 Board J.P. Nadeau SherwinE. Turk,Esq.
U.S. NRC Town of Rye OfficeofGeneralCounsel SandraGavutis Washington,D.C. 20555 155WashingtonRoad U.S. NRC RfD 1 Bor 1154 Rye, New Haspshire 03870 Washington, D.C. 20555 East tensington, NH 03927 Dr. Jerry Harbour AtcsicSafetyandLicensing Richard E. Sullivan, Mayor Mr. Angie Machiros, Chairsan CharlesP.Grahaa,Esq.
Board CityHall BoardofSelecteen McKay, Murphy and Grahae U.S. NRC Newburyport MA 01950 Newbury, MA 01950 100 Main Street Washington,D.C. 20555 Asestury, MA 01913 Alfred V. Sargent, Chairean H.JosephFlynn,Esq.
/
GustaveLinenberger BoardofSelecteen OfficeofGeneralCounsel
~
(
Atcaic Safety and Licensing icun of Salisbury, MA 01950 FEMA f"~~~
Board 500 C Street S.W.
/
)
U.S. NRC Senator Gcrdon J. Huophrey Washington,D.C. 20472
/
eN-
.k
/
f Washington,D.C. 20555 U.S. Senate O
[f8g
/
l Washington,D.C. 20510 GeorgeDanaBisbee,Esq.
AtomicSafatyandLicensing (Attn.TooBurack)
Geoffrey M. Huntington, Esq.
jC BoardPanei OfficeoftheAttorneyGeneral
',,vg
/
U.S. NRC SelecteenofNorthaspton State House Annex
,4 *
/
Washington,D.C. 20555 Northaepten,NewHaspshire Concord, NH 03301 03826 i
Atoeic Safety and Licensing AllenLaspert AppealBoardPanel Senator Gordor. J. Huophrey CivilDefenseDirector U.S. NRC 1EagleSquare,Ste507 Town of Brentowood Washington,D.C. 20 55 Concord, NH 03301 Exeter, NH 0!833 DocketingandService MichaelSantosuosso,Chairaan RichardA.Haspe,Esq.
U.S. NRC BoardofSelecteen HaspeandMcNicholas Washington,D.C. 20555 JewellStreet,RFDI2 35PleasantStreet South Haspten, NH 03842 Concord, NH 03301 Mrs. Anne E. Goodean Board of Selecteen Judith H. Mizner, Esq.
GaryW.Holees,Esq.
13-15 New Market Road Silverglate,Gertner,etal.
Holees&Ellis Durhas,NH 03842 88BroadStreet 47WinnacunnentRoad Boston, MA 02110 Haspton, NH 03842 WilliasS. Lord,Selectean l
Town Hall -- Friend Street Rep. Roberta C. Pevear WilliasArestrong l
Asesbury,MA 01913 DrinkwaterRoad CivilDefenseDirector Haspton, Falls, NH 03844 10 Front Street Jane Doughty Exeter, NH 03833 SAFL Phillip Ahrens Esq.
I 5 Mirket Street AssistantAttorneyGeneral CalvinA.Canney Portsmouth, NH 03801 State House, Station i 6 CityManager Augusta, ME 04333 CityHall Carols.Sneider, Esquire 126DanielStreet AssistantAttorneyGeneral Thesas G. Dignan, Esq.
Portsecuth, NH 03801 1AshburtonPlace,19thFloor R.I. Gad II, Esq.
Boston,MA 02108 Ropes & Gray Matthew T. Brock Esq.
225FranklinStreet
$haines&McEachern StanleyW.Inowles Boston,MA 02110 P.O. 80: 360 Board of Selecteen MaplewoodAve.
P.O. Box 710 Robert A. Backus, Esq.
Portssouth, NH 03801 Backus, Meyer & Soloson 111LowellStreet Edward A. Thesas Manchester, NH 03105 FEMA
_ _ _ _ _ _ _ _ _ _ _ _ _ _.