ML20214N315
| ML20214N315 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/19/1987 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| CON-#287-3586 OL, NUDOCS 8706020134 | |
| Download: ML20214N315 (8) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD +87 MY 22 PS:11
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In the Matter of
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Public Service Company of
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New Pampshire, et al.
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Docket Nos. 50-443 OL
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50-444 OL (Seabrook Station, Units 1 & 2)
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OFFSITE EMERGENCY
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PLANNING ISSUES
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NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S SECOND SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO APPLICANTS 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 Applicants with personal knowledge of the f acts or information requested in each interrogatory.
he remind you of your obliga-tion to supplement answers to interrogatories, under 10 C.F.R.
S 2.740(e).
The following definitions shall apply to these inter-rogatories:
1)
" Document" shall mean any written or graphic matter of I
communication, however produced or reproduced, and is intcnded to l
be comprehensive and include without limitation any and all cor-i respondence, 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, i
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microfiche, charts, analyses, intra-corporate or intra-office commu nications, notebooks, diaries, sketches, d iagrams, 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 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 i
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 matter:
the substance or nature of such action or matter; the persons partic-e-,
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.
6)
" Applicants" shall include any of the Seabrook owners; New Hampshire Yankee; or any contractors retained by the Seabrook owners or New Hampshire Yankee to prepare or evaluate the New i
Hampshire Radiological Emergency Response Plan.
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, and March 5, 1987.
2)
Please identify and produce 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 proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan.
This includes but is not limited to all documents used in answers to these inter-rogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings.
f 3)
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 have been admitted in this proceeding with respect to Revision 2 of the New I
Hampshire Radiological Emergency Response Plan.
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4)
Please identify all persons you may call as witnesses on each of the contentions that have been admitted in this pro-ceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan.
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.
5)
In your response to Massachussetts' first set of inter-I rogatories, Interrogatory 141, you stated that the estimate of 2.4 persons / vehicle for beach area traf fic was developed from onsite surveys.
Please identify, describe, and provide access to those surveys, and state the date(s) that these surveys were per-formed.
6)
In your response to Massachussetts' first set of inter-rogatories, Interrogatory 141, you stated that estimates of 1.16 persons / car for employees is based upon census data.
Please identify, describe, and provide access to that data.
1
- 7)
In your response to Massachussetts' first set of inter-rogatories, Interrogatory 138, you stated that the basis for pop-ulation figures in the New Hampshire RERP include " telephone requests to NH Labor Services and Employment Bureaus, U.S. Census Bureau."
Please describe the date of these contacts, the indi-viduals and offices contacted, and the specific information obtained through the contacts.
In addition, please identify and describe all documents that were generated by these contacts.
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8)
Please describe the dates on which Applicants' consul-tants prepared the " Personnel Resources Assessment Summary De. vel-oped in Support of Motions for Summary Disposition" (hereafter
" Personnel Summary").
9)
Please identify all individuals who participated inithe preparation of the Personnel Summary.
10)
Please identify and provide access to all documents generated by or relied upon during the Applicants' personnel review.
11)
For each town studied, please identify all positions for which the reviewers determined that 24-hour staffing was required, as discussed at page 2-1 of the Peisonnel Summary.
Please provide access to all supporting documents..
12)
For each town studied, please identify all positions for which the reviewers determined that 24-hour staffing was not required, as discussed at page 2-1 of the Personnel Summary.
Please provide access to all supporting documents.
13)
Pleese identify and describe all personnel surpluses in the overall offsite emergency response organization, as discussed l
on page 2-3 of the Personnel Summary.
14)
Elease identify and describe all personnel surpluses in the specific emergency response organizations, as discussed on I
page 2-3 of the Personnel Summary.
l 15)
Please describe any plans for a recruiting program, as discuased on page 2-3 of the Personnel Summary.
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16)
Please identify all plans for continuing work on the
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- program", as discussed at page 2-3 of the Personnel Summary.
Have these plans been implemented?
If'so, how and when.
Please identify and provide access to all documents that reflect con-t 3
tinued work or ' plans for continued work on the " program."
17)
Please provide the names, titles, and work and home addresses of all personnel who are listed as "Available" in Table 3.1-3, entitled " Overview of Personnel Requirements for State Agencies Required to Assist Municipalities Unable to Respond to i
an Emergency," Section 3 of the Personnel Summary, page 1 of 3.
For each individual identified above, please provide the follow-ing -information:-
'Has that person been assigned to a specific local emer-a.
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?
.I f 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?
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. Respectfully submitted,
^
1ane Curran HARMON & WEISS 2 001 "S" St reet 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 UPS Next Day Mail 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-
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- Atai; Safety and Luensing RichardE.Sallivan, Mayor Mr. Angie Machiros, Chairun ries F. Grahu, Esq.
Dr. Jerry Harbcur hard Cit /Ha!!
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':in, M;r;hy., Grahas NewDuryport, MA 01950 Newoury, MA 01950
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BoardofSelectmen OfficeofGeneralCounsel
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.80ard Senator Gordon J. Humphrey Washington,D.C. 20472 U.S. NRC y
Washington, D.C. 20555 U.S. Senate Washington,D.C. 20510 GeorgeDanaSisbee,Esq.
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AllenLaspert AtomicSafetyandLicensing Appeal hard Panel Senator Gordon J. Husphrey CivilDefenseDirector 1EagleSquare,Ste507 Tcan of Brentowood U.S. NTtC Exeter, NH 0!S33 rasningtcn,D.C. 20'55 Concord, NH 03301 Ocekering and Service MichaelSantosuciso,Chairsan RichardA.Haspe,Esq.
BoardofSelectaen Haspe and McNicholas U.S. NRC Washington,D.C. 20555 JewellStreet,RfDI2 3SPleasantStreet South Haspton, NH 03842 Concord, NH 03:01 Mrs. Anne E. Goodsan BoardofSelectsen Judith H. Mizner, Esq.
GaryW. Holmes,Esq.
13-15NewMarketRoad Silverglate,Gertner,etal.
HolsestEllis 47WinnacunnentRead brha3,NH 03342 80BroadStreet Boston, MA 02110
' Hampton, NH 03842 Willias S. Lord, Selectsan TownHall--FriendStreet Rep. Roberta C. Fevear WilliasArsstrong Asest,ury, MA 01913 Drinkwater Road CivilDefenseDirector Has; ton, Falls. NH 03844 10 Front Street Exeter, NH 03833 Jane Doughty PhillipAhrens,Es;.
!AFL AssistantAttorneyGeneral CalvinA.Canney 5 Market Street Portssouth, NH 03801 State House, Station i 6 CityManager City. Hall Aagasta ME G4333 126 Danie! Street Carol S. Ineider. Esquire AssistantAttcrneyGeneral ThomasG.Dignan,Esa.
Fortsaouth,NH 03801 1 Ashbrten Place,19th Floor R.K. Gad II, Esa.
Matthew T. Brock, Esq.
Boston,F4 02108 Repes & Gray 225FranklinStreet Shaines & M Eachern
!!a:',!n si. inales Besten, MA 021:0 P.O. foi 3e0 MaplewoodAve.
20ar; Or 3eletti,er:
Fortsmouth,NH 0320!
P.O. ior 710 Robert A. Bades. Esq.
!aths, Meyer t Scicson 111LowellStreet Edward A. theaas Manchester. e 0!!05 FEMA
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