ML20214T299

Response of FEMA to Town of Hampton Supplemental Interrogatories & Requests for Production of Documents to FEMA on State of Nh Radiological Emergency Response Plan.* W/Certificate of Svc.Related Correspondence

ML20214T299
Person / Time
Site:	Seabrook
Issue date:	06/04/1987
From:	Eric Thomas Federal Emergency Management Agency
To:	HAMPTON, NH
Shared Package
ML20214T252	List: ML20214T250 ML20214T290 ML20214T299
References
OL, NUDOCS 8706100199
Download: ML20214T299 (9)

Text

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I 6/4/87 UNITED STATES OF AMERICA NUCLEAR REGULATORY COfMISSION BEEORE THE ATOMIC SAFETY LICENSING BOARD In the Matter of )

) Dacket tb. 50-443 Public Service Co. of New Hampshire, ) 50-444

. et al. ) (Offsite)

)

(Seabrook Station, Units 1 & 2) )

RESPONSE OF THE FEDERAL EMERGENCY MANAGEMENT AGENCY TO THE TOWN OF HAMPION'S SUPPLEMENTAL INTERROGATORIES AND REQUESTS EOR PRODUCTION OF DOCLNENIS TO FEMA ON THE NEW HAMPSHIRE RERP The Federal Bnergency Management Agency (FEMA) is not a party to the above-captioned proceeding and it is, for that reason, not obligated to respond to the interrogatories propounded by any intervenors. FEMA voluntarily provides the information supplied below, but reserves the right to object to future discovery requests. ,

Interrogatory No. S-1:

Please supplement, and provide a full and canplete response, to TOW OF HAMPION INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENIS TO THE FEDERAL EMERGENCY MANAGEMENT AGENCY ON THE NEW HAMPSHIRE RADIOLOGICAL RESPONSE PIANS dated March 5,1987 and previously served upon FEMA.

Previous Interrogatory 1

a. What is FEMA's position with respect to each contention and its subparts? Describe in detail the reasons for your position. Identify any relevant portions of the state and local plans that are under revision or which the state expects to change at any time in the future.

8706100199 870604 PDR C ADOCK 05000443 PDR

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b. Identify and provide access to all documents on which you rely during this proceeding to support your position on each of these contentions.

'Ihis includes all docunents used in answers to these interrogatories, sumnary disposition motions, testimony, and crosMxamination of witnesses during ,

hearings.

c. Identify all persons you may call as witnesses on each of these .

contentions during these proceedings; describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.

d. -Identify all persons on whose factual knowledge,, opinions, or technical expertise you rely for your position on each contention and subpart thereof.

Answer No. S-1 (to previous Interrogatory-1)

a. 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 'IllE i

FEDERAL EMERGENCY MANAGEMENT AGENCY TO MASSACHUSETTS ATIORNEY GENERAL, JAMES M. SHANNON'S OFP-SITE EMERGENCY PREPAREDNESS INTERROGATORIES AND REQUEST EOR PRODUCTION OF DOCLMENIS TO FEMA (SET No. 2) (Hereinafter called Appendix A),

which is included with.this filing and incorporated into this Response to the Ibwn of Hampton's Interrogatories. FEMA has no knowledge of the relevant portions of State and local plans that are under revision or which the State expects to change in the future beyond that provided in the status reports served on the parties to this proceeding by the Attorney General of the State of New Hampshire.-

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b. The doctanents on which FEMA relies in support of its position 1

on each of'the contentions is specifically identified in Appendix A. To the best of my knowledge these documents-have.been made available to the

- parties to this pro eding previously or as part of FEMA's subnission"made this day.

J c. FEMA has not yet identified the persons who it will call as witnesses to this proceeding and therefore can neither provide the sub-stance of their testimony nor describe the doctanents that they may rely upon beyond those mentioned in Appendix A or in our previous answer to this question.

d. FEMA relied on the following persons for knowledge, opinions and l technical experience with respect to our positions on the contentions:

.1) FEMA Staff: -

Edward A. Thomas-John C. Iblan Bruce J. Swiren Fenneth Ibrak

11) Argonne National Laboratory Staff:

lbbert Ibspenda Margaret Singh iii) The Members of or Agency Representatives to the Regional Assistance Comnittee, (See attached list)-

iv) Cbservers at the February 26, 1986 Ekercise of the New Hampshire Plans, (See list contained in FEMA's report on this exercise previously served on the l parties).

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Previous Interrogatory 2 Please identify all persons on whose factual knowledge, opinions, or technical expertise you rely for your position on each contention and subpart thereof.

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Answer No. S-1 (to previous Interrogatory-2)

This interrogatory is answered as part of our response to Previous Interrogatory 1 (d.) supra.

Previous Interrogatory No. 3 Identify and describe any deficiencies, including those set forth in FEMA Final Exercise Assessment February 26, 1986, for which Applicant and/or the State of New Hampshire have not undertaken adequate corrective action.

Answer No. S-1 (to previous Interrogatory 3)

The analysis of the deficiencies in the February 26, 1986 Exercise of the New Hampshire RERP is set forth in the FEMA Final Exercise Assessment for the exercise. The listing of inadequacies with respect to the NHRERP Rev. 2 is set forth in the Final FEMA RAC Review for Rev. 2 dated December 12, 1986. FEMA has not yet done an analysis-of whether any of the deficiencies listed in the report of the February 26, 1986 exercise have been corrected. To date, this agency has not received plans on other documents which would correct the inadequacies found in the NHRERP (Rev. 2).

Interrogatory No. S-2 Please identify amd describe FEMA's present position with respect to all Motions for Sumary Disposition, and responses thereto, previously filed in this proceeding.

Answer S-2 FEMA's position on all motions for Sumary Disposition and responses thereto is contained in Appendix A.

Attachments:

RAC Listing P

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I declare, onder penalty of perjury, that the foregoing responses to the Town of Hampton's Interrogatories and Request for Production of Ibctnents are true and complete to the best of my knowledge and. belief.

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Edward A.6 Thcnas, Division Chief

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Natural & Technological Hazards Region I .

Federal anergency Management Agency Dated June 4, 1987 Boston, Massachusetts O

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a g' FEMA REGION 1 Regional Assistance Ccmnittee Members

. Comnittee Menber Mr. Paul IAltz William P. Patterson Regional Dnergency Transportation Rep U.S. Department of the Interior Capt. John Foster Williams Coast Guard Bldg. Regional Environmental Office 408 Atlantic Ne. 1500 Custom House Boston, MA. 02210-2209 165 State St.

Boston, MA 02109

- Mr. Byron Keene U.S. Environmental Protection Agency 2312 JFK Federal Building Boston, MA 02203 (23rd Floor)

Mr. Warren Church Regional Radiological Health Representative U.S. Food & Drug Administration 585 Connercial St.

Boston, MA 02109

- John Stepp U.S. Dept. of Health & Human Services Public Health Service Representative 1401 JFK Federal Bldg. (14th Floor) ~

Boston, MA 02203 John Schumacher Nuclear Regulatory Ctanission Region I 631 Park Ave. .

King of Prussia, PA 19406 lbbert Bores (Seabrook)

Nuclear Regulatory Cmmission 631 Park Ave.

King of Prussia, PA 19406 (Ibrothy Nevitt/ Bob Conley/Cheryl Malina Anna Hart)

Office of anergency Planning USDA - FSIS-PP 14th & Independence Ne., S.W.

Ibam 2940 - South Bldg.

Washington, D.C. 20250 Mr. Herbert G. Fish U.S. Department of Energy Princeton Area Office P.O. Box 102 Princeton, NJ 08542

e s i CERTIFICATE OF SERVICE DOLq p -

og I, Elward A. Ihmas, The FEMA Region I Division Chief for Natural anj7 JUN -5 P2 :16 Technological Hazards, and an Attorney, hereby certify that on June 4, 1987, I made service of the within documents by sending copies by 0FFn ,

guaranteed overnight delivery or by arranging for hand delivery. 00 CME c e, j

- y; Helen Ibyt, Esq., Chairman Stephen E. Merrill Administrative Judge Attorney General Atmic Safety & Licensing Board George Ihna Bisbee U.S. Nuclear Regulatory Comission Assistant Attorney General Washington, DC 20555 Office of the Attorney General 25 Capitol Street Dr. Jerry Harbour Concord, NH 03301 Administrative Judge Atomic Safety and Licensing Board Angie Machiros, Chairman U.S. Nuclear Regulatory Cmmission Board of Selectmen 25 High Road Beverly Hollingworth Newbury, MA 09150 209 Winnacunnet Road Hampton, NH 03842 Allan tampert Civil D3fense Director Sandra Gavutis, Chairman 'Ibwn of Brentwood Board of Selectmen 20 Franklin St.

RFD 1 Box 1154 Exeter, NH - 03833 Kensington, NH 03827 Gustave A. Linenberger, Jr. Charles P. Graham, Esq.

Idministrative Judge McKay, Murphy and Graham Atmic Safety and Licensing Board 100 Main St. ,

U.S. Nuclear Regulatory Cmmission Imesbury, MA 01913 Washington. DC 20555 Diane Curran, Esq.

• Ms. Carol Sneider, Esq. Harmon & Weiss Assistant Attorney General 2001 S. St., N.W.

Office of the Attorney General Suite 430 One Ashburton Place,19th Floor Washington, D.C. 20009 Boston, MA 02108 Sherwin E. Turk, Esq.

Richard A. Hampe, Esq. Office of the Executive I;3 gal Director New Hampshire Civil Defense Agency U.S. Nuclear Regulatory Cmmission 107 Pleasant Street Washington, D.C. 20555 Concord, NH 03301 H.J. Flynn, Esq.

Calvin A. Canney, City Manager Assistant Ceneral Counsel City Hall Federal anergency Management Agency 126 thniel St. 500 C Street, SW Portsmouth, NH 03801 Washington, DC 20472

• Denotes Hand Iblivery I

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N Jane Ibughty Atmic Safety and Licensing Seacoast Anti-Ibilution Appeal Panel 5 Market St.

U.S. Nuclear Pegulatory Camission Ibrtsmouth, NH 03801 Washington, DC 20555 Maynard L. Young, Chairman Paul McEachern, Esq. Board of Selectmen Matthew T. Brock, Esq. 10 Central Ibad Shaines & McEachern So. Hampton, NH 03287 25 Maplewood Ave.

P.O. Box 360 Michael Santosuosso, Chairman Ibrtsmouth, NH 03801 Board of Selectmen South Hampton, NH 03287 lbberta C. Ibvear State Pepresentative Mr. Robert Carrigg, Chainnan Tbwn of Hampton Falls Board of Selectmen Drinkwater Ibad Ibwn Office Hampton Falls, NH 03844 Atlantic Avenue tbrth Hampton, NH 03862 Mr. Ibbert J. Harrison President & Chief Executive Officer

• R.K. Gad III, Esq.

Public Service Co. of New Hampshire Ibpes & Gray P.O. Box 330 225 Franklin Street Manchester, NH 03105 Boston, MA 02110 Robert A. Backus, Esq. Gary W. Holmes, Esq.

Backus, Meyer & Solmon Iblmes & Ellis 116 Iowell St. 47 Winnacunnet Ibad Manchester, NH 03106 Hampton, NH 03842 Philip Ahern, Esq. Ibcketing and Service Section Assistant Attorney General Office of the Secretary Office of the Attorney General U.S. Nuclear Regulatory Camission State House Station #6 Washington, DC 20555 Augusta, MS 04333 William S. tard

• Thmas G. Dignan Jr. , Esq. Board of Selectmen Ropes & Gray Tbwn Hall - Friend Street 225 Franklin St. Anesbury, MA 01913 Boston, MA 02110 Ibter J. Matthews, Mayor William Armstrong City Hall Civil Defense Director Newburyport, MN 09150 Tbwn of Exeter 10 Front St/

• Judith H. Mizner, Esq.

Exeter, NH 03833 Silverglate, Gertner, Baker Fine and Good Atmic Safety and Licensing 88 Broad Street Board Boston, MA 02110 U.S. Nuclear Regulatory Cmmission Washington, DC 20555 0 Denotes Hand Delivery

e Mrs. Anne E. Cbodman', Chairman Board of Selectmen 13-15 Newnarket Bbad-

'Durham, NH 03824

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Honorable Gbrdon J. Htanphrey United States. Senate 531 Hart Senate Office Building

. Washington, DC- 20510

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IMward A. Thomas e

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