ML20214T274
| ML20214T274 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/04/1987 |
| From: | Bisbee G, Strome R NEW HAMPSHIRE, STATE OF |
| To: | HAMPTON, NH |
| Shared Package | |
| ML20214T239 | List: |
| References | |
| OL, NUDOCS 8706100190 | |
| Download: ML20214T274 (5) | |
Text
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June 4, 1987 UNITED STATES OF AMERICA 9Eifprf NUCLEAR REGULATORY COMMISSION Before the Nuclear Regulatory Commission'87 JuN -5. P2 37 p
2 t i.w y
In the Matter of
)
Docket Nos. 50-44i-OL'
)
and PUBLIC SERVICE COMPANY OF
)
50-444-OL NEW HAMPSHIRE
)
-(Off-Site Emergency (Seabrook Station, Units 1 and 2
)
Planning Issues)
)
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 ANSWERS TO INTERROGATORIES Interrogatory No. S-1 Please identify, describe and fully answer all interrogatories previously served by the TOWN OF HAMPTON upon the State of New Hampshire as if fully set forth and requested herein.
Please note the errata as referenced in TOWN OF HAMPTON CORRECTIONS TO TOWN OF HAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE STATE OF NEW HAMPSHIRE ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS.
Response
The State's prior responses will be supplemented as necessary.
Interrogatory No. S-2 Please identify and describe the State of New Hampshire's position with respect to all Motions for Summary Disposition, and responses thereto, previously filed in this proceeding.
Response
The State objects to this interrogatory.
The State's pleadings filed in this proceeding speak for themselves.
Without waiving this objection, the State responds as follows:
8706100190 870604 I PDR ADOCK 05000443-O PDR 1
I
The State's motions for summary disposition, objections to.
motions for summary disposition, and affidavits filed with input to i
motions for summary dispostion set forth the State's position.
Interrogatory No. S-3 In response to prior interrogatories, the State of New Hampshire stated "KLD Associates, Inc.'s services relative to Volume 6 of the NHRERP have been retained by the Applicants, not the State of New Hampshire."
Please state whether the State of New Hampshire' has ever independently verified, directly or indirectly, the population estimates contaned in the KLD ETE, including the " resident population", " peak summer weekend population" and " peak summer midweek population", for all EPZ towns, including the Town of Hampton.
If the State, directly or indirectly, has undertaken such verification, please identify and describe:
a.
All efforts so undertaken by the State, the dates thereof, the persons undertaking such efforts, the work performed,
_ and the results and conclusions.
b.
Identify and describe whether the State's population estimates are identical with those set forth in the KLD ETE, or if discrepancies exist, please explain the reasons therefore.
c.
Identify and describe all documents relied upon by the State, directly or indirectly, in support of your answer,
'or generated as a result of your veritication efforts.
Interrogatory No. S-4 If the State of New Hampshire has not undertaken to independently verify the population estimates contained in the KLD ETE, please state whether or not, in the State's opinion, the KLD population estimates described in the previous interrogatory, including those for the Town of Hampton, are accurate and the reasons therefore.
Responses to Interrogatories to S-3 and S-4 The KLD ETE has been reviewed by several members of NHCDA including Richard Strome and Michael Nawoj.
The KLD ETE has also been submitted by the State to FEMA for RAC review.
The State review was not an attempt to independently replicate the evacuation time or population estimation process.
Instead, the review consisted of examining the general reasonableness of major assumptions and input data.
The assumptions, data and results were compared, in general terms, to those for earlier ETE studies for Seabrook Station.
The State is satisfied that the data, assumptions and conclusions are reasonable and within the bounds of accuracy to
- be expected for an ETE.
i l
. Interrogatory No. S-5 Please identify all road repairs and/or modifications, other than routine maintenance, performed, or in progress, by the State of New Hampshire within the EPZ from 1979 up to the present date.
Please specifically identify the locations, dates, and persons in cahrge of performing said repairs or modifications.
Identify and describe all documents upon which you rely in support of this answer.
Response
The State of New Hampshire objects to this question as being over broad, unduly burdensome and not relevant to any admitted contention in this hearing.
Without waiving its objection, the State responds as follows:
A listing of State highway projects in the EPZ as well as those projected for the EPZ is available for review at the Civil Defense Agency headquarters in Concord, New Hampshire.
Interrogatory No. S-6 Please state whether the State of New Hampshire has ever filed any objections or contentions with respect to the off-site emergency plans for Seabrook-Station.
Please identify and describe all documents in support of your answer, or in the alternative, please provide legible copies of said documents with your answer.
Response
The State objects to the interrogatory.
The record in this proceeding speaks for itself.
Interrogatory No. S-7 Please identify, describe and explain the differences in the population estimates for Town of Hampton in prior drafts of the NHRERP as compared with Revision 2.
In your answer, please discuss each population group for Town of Hampton referenced in Interrogatory No. 3.
Response
The Revision 2 population estimates were done by KLD Associates.
The basis for their estimates is explained fully in Volume 6 of the NHRERP.
Any differences in population stimates can be explained by comparing'the basis used by other ETE consultants in arriving at their population estimates, to KLD's basis, i
i
1 7 Interrogatory No. S-8 of Shaines & McEachern, P.A., Identify and produce for inspection and copying at the offices Hampshire 03801 all documents upon which you rely to support your25 M cnswers to Interrogatories 1 - 7.
Response
The documents are available for inspection at the Civil Defense Agency headquarters in Concord, New Ham notice, between the hours of 8:30 a.m. pshire, upon reasonable Friday.
and 4:00 p.m.,
Monday through MOTION FOR PROTECTIVE ORDER Because the State of New Hampshire filed no contentions on the 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, which will not be the subject of direct tstimony proffered by the7 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 cmergency planning issues, the State has voluntarily responded to this set of inerrogatories and request for product of documents.
The State of New Hampshire, protective order that the documents thathowever, moves the Board for a to be produced may be produced at the Town of Hampton requests the offices of the New Hampshire Civil Defense Agency in Concord, New Hampshire.
The majority of the rcquested documents are already in the possession of the Town of Hampton (e.g., NHRERP; RAC Reviews), and the remainder of the 2r3 documents constitutes a large number of pages.
To provide copies of th0 documents by mail to the Town of Hampton would be an undue burden and expense.
Rather, the State of New Hampshire requests that Board require only that the inspection, upon reasonable notice,the requested documents be made available for between the hours of 8:30 a.m.
cnd 4:00 p.m., Monday through Friday, at the Civil Defense Agency h r.dquarters, 107 Pleasant Street, Concord, New Hampshire, 03301.
9,g In addition, the State of New Hampshire moves the Board for a protective order that, interrogatory, for the reasons given with respect to each further:
the following interrogatories need not be answered Interrogatory S-2 C2E Interrogatory S-5 Interrogatory S-6 t
3
.o 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.
/
/
1 If L
/03 Richard H.
Strome Director, Civil Defense Agency Sworn,to before me this
~4th day'of June, 1987:
l2.L N>tJ 0 Yh Nota'ry Public 1,. My' Cominission Expires: 8-/6-N s i s,
,s'.
o,
' N,,
AA"'to ' Objections and Motion for Protection Order:
h4, Mfdr AH George Kana Bisbee
-U Senior At3sistant Attorney General Environmental Protection Bureau Office of the Attorney General-25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3679 O