ML20214T161
| ML20214T161 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/04/1987 |
| From: | Bisbee G, Strome R NEW HAMPSHIRE, STATE OF |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| References | |
| CON-#287-3675 OL, NUDOCS 8706100147 | |
| Download: ML20214T161 (8) | |
Text
Jeh j,:34 5 June 4, 1987 UNITED STATES OF AMERICA U
NUCLEAR REGULATORY' COMMISSION Before the Nuclear Regulatory Commissio U
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In.the Matter of
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Docket Nos.f50-443-OL
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and PUBLIC SERVICE COMPANY-OF
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50-444-OL tHui HAMPSHIRE
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(Off-Site Emergency (Seabrook Station, Units 1 and 2
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Planning Issues)
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THE STATE OF-NEW HAMPSHIRE'S RESPONSES TO NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S-THIRD SET'OF INTERROGATORIES AND REQUEST.FOR PRODUCTION OF DOCUMENTS TO THE STATE OF NEW HAMPSHIRE; ON REVISION 2 TO THE NEW HAMPHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN AND MOTION FOR PROTECTIVE ORDER ANSWERS TO INTERROGATORIES Interrogatory No
'l In accordance with-10~C.F.R. S2.740(e), please supplement your answers-to NECNP's previous sets of interrogatories, filed April 30, 1986, March 5, 1987, and April 2, 1987.
Response
The State's' answers will be supplemented as necessary.
Interrogatory No. 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 lfollowing information:
a.
Has that person been assigned to a specific local emergency response function?
If so, what are his or her responsibilities?
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. 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?
Response
The State does not have the backup information for the Applicant prepared document cited in this interrogatory, other than the information continued in NHRERP Vols.
4, 4A and 4B, for state agencies, and in Appendix A of Vols. 16-38 for municipal organizations.
Interrogatory No. 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?
Response
The " Personnel Resources Assessment Summary Developed in Support of Motions of Summary Disposition" is a document prepared independently by the applicant and its consultants.
NHCDA employees consulted frequently with Applicants' consultants on an informal basis regarding staffing levels in the six towns discussed in the document.
The primary Civil Defense contacts for the Applicant with regard to this assessment were Robert Pariseau, Michael Poirier and James Litevich, the local liaison staff assigned to cover the six towns.
Supplementary information may have been attained through informal conversations with other members of the NHCDA Technological Hazards Division familiar with the personnel of the towns in the Seabrook EPZ.
These include Michael Nawoj, the Director of the Division, David Deans and Robert Jeffries.
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. Interrogatory No. 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 one-hour drive.
For full implementation of the RERP, approximately 1 to !! hours 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 bsis?
Of these, how many are individuals who are stationed in the EPZ every day?
How many are individuals who may report to the EPZ once in a while?
How frequently do those individuals go to the EPZ?
b.
Would the rest of the State employees come from Concord?
If no, how many would come from Concord?
How many would come from other places, and where would they come from?
How long would it take them to reach the EPZ?
From what other locations would those employees come?
c.
Response
a.
Various agencies or departments of the State of New Hampshire maintain-facilities and personnel within or near the EPZ on a regular basis.
Those with particular roles in.the RERP include:
DRED - Maintains a full-time presence in the EPZ.
Approximately 39 DRED personnel are available on a daily basis at State parks in the EPZ during the summer season.
State Police Troop A - Maintains around the clock presence on a daily basis in the EPZ.
Fish & Game - Approximately 4 personnel assigned to the EPZ area on a daily basis.
Additional personnel are assigned on a seasonal basis.
DOT - Has a number of facilities located in the EPZ which operate on a daily basis.
This includes DOT Division 6 facilities, as well as turnpike personnel.
The New Hampshire Civil Defense Agency has various members working in or near the EPZ on a regular basis at least 3 to 4 days per week.
b.
Those personnel who are not situated in or near the EPZ would be dispatched from Concord.
Responders from greater distances would be used to back up first response personnel, most of whom are situated in or near the EPZ or in or near Concord.
Response time to the EPZ would be on the order of a few minutes to as nuch as 2 hairs.
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c.
As stated in b. above, first shift responders would either come from in or near-the EPZ or in or near Concord, and back up personnel ~could come from other locations within the State as well as from locations outside the State.
Interrogatory No. 5 Please identify, describe and provide access to all documents that you' relied on or considered in answering these interrogatories.
Response
The State relied on the NHRERP, Rev. 2 and the personal knowledge
- of NHCDA staff to compile its responses to the preceding interrogatories.
The State also reviewed, but did not rely upon, the Applicants' " Personnel Resources Assessment Summary Developed in Support of Motions for Summary Disposition."
MOTION FOR PROTECTIVE ORDER Because the State of New Hampshire filed no contentions on the 1
- NHRERP and intends to offer no testimony on any contentions that were filed, the State is not obligated to respond to any interrogatories on the NHRERP.
See this Board's Memorandum and Order (March 1, 1983)
- at 3-4, 7 (Interrogatories which are sponsored by the interrogee and which will not be the subject of direct tetimony proffered by the interrogee need not be answered.)
Recognizing, however, that New Hampshire-state personnel involved in developing the NHRERP can and will provide valuable input in this proceeding on New Hampshire emergency planning issues, the State has voluntarily responded to this set ofinterrogatories and request for product of documents.
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. SIGNATURE I, Richard H.
Strome, being first duly sworn, do depose and say that the foregoing answers are true, except insofar as they are based on information that is available to the State but not within my Personal knowledge, as to which I, based on such information, believe them to be true.
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.y Richard H. 'Strome Director, Civil Defense Agency Swdr'nfto before'me this 4th day of June, 1987:
b dotary Public i
iMy' Commission Expires: 8-/5 -89 As to"dbjections and Motion for Protectior, Order:
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George Daha ~Bisbee \\)
Senior Assistant Attorney General Environmental Protection Bureau Office of the Attorney General
- 25. Capitol Street Concord, NH 03301-6397
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Telephone (603) 271-3679 e
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t CERTIFICATE OF SERVICE I, George Dana.Bisbee, hereby certify that on this 4th day of June, 1987, I made service of the within State of New Hampshire's Supplemental Response to New England Coalition on Nuclear Pollution's Third Set of Interrogatories and Request for the Production of Documents to State of N3w Hampsnire On Revision 2 to the New Hampshire Radiological Emergency Response Plan, the State of New Hampshire's Responses to Attorney General James M. Shannon's Off-Site EP Interrogatories and Request for Production of Documents to the State of New Hampshire, the State of New Hampshire's Responses to Hampton's Interrogatories and Request for Production of Documents to the State of New Hampshire on the New Hampshire Radiological Emergency Response Plan, and the State of New Hampshire's Responses to SAPL's Interrogatories and Request for Production of Documents to the State of New Hampshire NHRERP by mailing copies thereof, postage prepaid, to:
- Administrative Judge Helen Hoyt Administrative Judge Sheldon J.
Chairperson Wolfe, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel 8%
od U.S.
Nuclear Regulatory U.S. Nuclear Regulatory 9I
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Commission Commission a
Washington, DC 20555 Washington, DC 20555 Ti 2]
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- Administrative Judge Gustave
- Dr. Jerry Harbour 73 A.
Linenberger, Jr.
Atomic Safety and Licensing Atomic Safety and Licensing Board Panel IT Board Panel U.S.
Nuclear Regulatory
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U.S.
N.R.C.
Commission Washington, DC 20555 Washington, DC 20555 Philip Ahrens, Esquire
- Thomas G.
Dignan, Jr., Esquire Deputy Attorney General R.
K. Gad, III, Esquire Peter J.
Brann, Esquire Ropes & Gray Assistant Attorney General 225 Franklin Street Department of the Attorney General
- Boston, MA 02110 State House Station 6 Augusta, ME 04333
- Sherwin E. Turk, Esquire Deputy Assistant Chief
- Carol S.
Sneider, Esquire Hearing Counsel Assistant Attorney General Office of the Executive Counsel Department of the Attorney General Director One Ashburton Place, 19th Floor U.S. Nuclear Regulatory Commission Boston, MA 02108 Washington, DC 20555 Ms. Diana P.
Randall
- Robert A. Backus, Esquire 70 Collins Street Backus, Meyer & Solomon Seabrook, NH 03874 116 Lowell Street P.O. Box 516 Manchester, NH 03105
- Served by Express Mail Service.
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- Diane Curran, Esquire
!!armon & Weiss 20001 S Street, N.W.
Chairperson Suite ( t)
Board of Selectmen Washington, DC 20009-1125 Town of South Hampton East Kingston, NH 03827 Jane Doughty 5 Market Street
- Mr. Ed Thomas Portsmouth, NH 03801 FEMA, Region 1 John W. McCormack Post Office Brentwood Board of Selectmen and Court House RFD Dalton Road Post Office Square Brentwood, NH 03833 Boston, MA 02109 Judith H. Mizner, Esquire Charles P. Graham, Esquire Silverglate, Gertner, Baker, McKay, Murphy and Graham Fine, Good, and Mizner 88 Broad Street 100 Main Street Amesbury, MA 01913 Boston, MA 20110
- Paul McEachern, Esquire J. P.
Nadeau, Esquire Matthew T.
Brock, Esquire Selectmen's Office Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P. O. Box 360 Portsmouth, NH 03801 Mr. Calvin A.
Canney City Manager Ms. Roberta C.
Pevear City Hall The Town of Hampton Falls 125 Daniel Street Drinkwater Road Portsmouth, NH 03801 Hampton Falls, NH 03844 Mr. Angie Machiros Mrs. Sandra Gavutis Chairman of the The Town of Kensington Board of Selectmen RFD 1, Box 1154 (Route 107)
Town of Newbury Kensington, NH 03827 Newbury, MA 01950 Senator Gordon J.
Humphrey Peter J. Matthews U.S. Senate Mayor l -
Washington, DC 20510 City Hall (Attn:
Tom Burack)
Newburyport, MA 01950 Senator Gordon J.
Humphrey William S. Lord Board of Selectmen 1 Eagle Square Suite 507 Town Hall Concord, NH 03301 Friend Street Amesbury, MA 01913 i
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.. a Mr. Thomas Powers Gary W.
Holmes, Esquire
-Town Manager -
Holmes &' Ells 47 Winnacunnet Road
. Town ef Exeter 10 Front Street Hampton, NH 03841 Exeter, NH 03833 Richard A. Hampe, Esquire
- H. Joseph Flynn Hampe & McNicholas Assistant General Counsel 35 Pleasant Street Office of General Counsel Concord, NH 03301 Federal Emergency Management
_Mr. Robert Carrigg, t.~1 airman Agency 500 C Street, S.W.
Board of Selectmen Washington, DC 20472 Town Office Atlantic Avenue North Hampton, NH 03862 1
George Dkna Bisbee