ML20214T290

Response of FEMA to Seacoast Anti-Pollution League Second Set of Interrogatories & Requests for Production of Documents to FEMA on State of Nh Radiological Emergency Response Plan Rev 2.* Related Correspondence

ML20214T290
Person / Time
Site:	Seabrook
Issue date:	06/04/1987
From:	Eric Thomas Federal Emergency Management Agency
To:	SEACOAST ANTI-POLLUTION LEAGUE
Shared Package
ML20214T252	List: ML20214T250 ML20214T290 ML20214T299
References
OL, NUDOCS 8706100196
Download: ML20214T290 (4)

Text

_ _ _ _ _ _ _ -. ._ . - _ _ _ _ _ _ . - _. - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ __ _ ________-__ -___ ____________ _ - _ ______

n L

i 6/4/87 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY LICENSING BOARD In the Matter of )

) Docket No. 50-443 Public Service Co. of New Hampshire, ) 50-444 ,

et al. ) (Offsite)

)

(Seabrook Station, Units 1 & 2)1 )

RESPONSE OF THE FEDERAL EMERGENCY MANAGEMENT AGENCY TO THE SEABROOK ANTI-POLLUTION LEAGUE'S SECOND SET OF INTERROGATORIES AND RDQUESTS FOR PRODUCTION OF DOCUMENTS TO FEMA ON THE NEW HA>FSHIRE RERP REVISION 2 The Federal anergency Management Agency (FEMA) is not a party to the abov n aptioned proceeding and it is, for that reason,.not obligated to respond i to the interrogatories propounded by any intervenors. FEMA voluntarily provides the information supplied below, but reserves the right to object to future discovery requests.

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 supple-ment and update its answers thereto pursuant to 10 CFR $2.740(e).

I Previous Interrocatory A

,t For each and everyone of the admitted SAPL Contentions (#'s 31, 7, 8, 8A, Redrafted 15,16,18, 25, 33, 34 and 37), provide the following informations a) What witnesses does FEMA intend to have testify with respect to this contention?

0706100196 070604  ?

PDR ADOCK 00000443 0 PDR

,)

, . - . , ._ , , , , .-- ._- .,-=..- ._.. ~ - _ - __,- - - , - -. --, - - - , , - - _ _ - - -_. .

2/

I b) What position does FEMA intend to take on this contention and what is the basis of this position?

c) Miat docunents will be used in support of FEMA's position on this contention?

Answer A a) FEMA has not yet identified the witnesses it intends to have testify with respect to any of the contentions admitted in this proceeding.

b) FEMA has developed a position with respect to each contention (including subparts) admitted for litigation in this proceeding. Our position and reasons for the position are set forth in Appendix A of RESPONSE OF THE FEDERAL EMERGENCY MANMEENT AGENCY TO MASSACHUSETTS ATIORNEY GENERAL, JAMES M. SHANNON'S OFF-SITE EMERGENCY PREPAREINESS INTERROGATORIES AND REQUEST EUR PRODUCTION OF DOWENTS TO FEMA (SET No. 2) (liereinafter called Appendix A),

which is included with this filing and incorporated into this Response to SAPL's Second Set of Interrogatories. '-

c) The docunents on which FEMA relies in support of its position on each of the contentions are specifically identified in Appendix A.

Previous Interrogatory B For each and every witness identified in answer to subpart a above, provide the following information:

a) Name b) Address c) Present professional or enployment affiliation d) Curriculum vita Answer B a, b, c, and d. Since FEMA has not yet identified witnesses it cannot provide the information requested.

1

-o 1/

t Interrogatory 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.

Answer C FEMA has not identified wittnesses nor developed testimony with respect to this proceeding.

Interrogatory 1 Has FEMA as of this date received plans or ther documents which would in FEMA's opinion correct the inadequacies FEMA has found in NHRERP Rev. 2?

If the answer is affirmative, detail the nature of the plans or documents and the nature of the corrections therein. -

Answer 1 m.

Interrogatory 2 Has FEMA as of this date done an anlysis 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.

Answer 2 No.

Interrogatory 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?

-- . . - - . , - n ---- y

e t .fl If the answer is affinnative, provide the assessment for each contention for which said assessment has been done.

Answer 3 Yes. This Assessment is enclosed as Appendix A Attacrunent Appendix A I declare, under penalty of perjury, that the foregoing responses to the Seacoast Anti-lbilution I.eagues's Interrogatories and I6 quest for Production of Ibcuments are true.

Edward A. '1homas, Division Chief Natural & Technological Hazards Region I Federal Dnergency Management Agency Dated June 4,1987 at Boston, Massachusetts

. . _ _ _ _. ~ . , . . _ . . - _ _ . _ ..