ML20247G787

Applicant Exhibit A-65,consisting of Applicant Interrogatories & Request for Production of Documents to All Intervenors & Participating Local Govts Re Joint Intervenor Contentions 1-26,dtd 881011

ML20247G787
Person / Time
Site:	Seabrook
Issue date:	04/20/1989
From:	Trout J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	AMESBURY, MA, HAMPTON, NH, MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SOUTHAMPTON, NY
References
OL-A-065, OL-A-65, NUDOCS 8905310070
Download: ML20247G787 (152)

Text

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'89 MAY 23 P1 :47 l l

October 11, 1988 b' r,: ,,,

i UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ,\ 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues

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APPLICANTS' INTERROGATORIES AND REQITEST FOR PRODUCTION OF DOCUMENTS TO ALL INTERVENERS AND PARTICIPATING LOCAL GOVERNMENTS CONCERNING JOINT INTERVENOR CONTENTIONS 1-26 Pursuant to 10 C.F.R. 55 2.740b and 2.741, Applicants hereby request that the Attorney General for the Commonwealth of Massachusetts (" Mass AG"), the New England Coalition on Nuclear Pollution ("NECNP"), the Seacoast Anti-Pollution League (*SAPL") , the Town of Amesbury ("TOA") , the Town of Newbury (" TON"), the City of Newburyport (* CON"), the Town of Salisbury ("TOS"), the Town of West Newbury (" TOWN"), the City of Haverhill ("COH"), and the Town of Merrimac (" TOM")

[ hereinafter collectively "Intervanors") respond to the 8905310070 890420 L PDR ADOCK 05000445' PDR o

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following interrogatories, and produce for inspection and copying the documents requested below.

These interrogatories and requests directly address'the .

assertions made by Interveners in Joint Intervanor  !

Contentions 1-26. Since several of the Intervanors have indicated that they intend to litigate only certain Contentions, those Intervanors need not respond to questions concerning those Contentions that they have stated they will not litigate (unless their intentions have changed). Egg infra nn. 1-26.

Mass AG and NECNP, however, have stated that they intend to litigate all contentions, and so should answer all questions. TOA's intentions have apparently changed between September 30, when Mr. Lord stated under oath that TOA only intended to litigate eleven contentions, and October 6, when TOA served interrogatories and document requests going to all j

sixty-three contentions. Since TOA has now decided to litigate all Contentions, it should answer all questions.

Finally, TOWN, COH, and TOM have failed or refused to state their intentions, and so should answer all questions.

' The production of the documents requested herein (or copies thereof) shall take place at the offices of Ropes &

Gray, 225 Franklin Street, Boston, Massachusetts, at 10 a.m.

on Monday, November 14, 1988. l 1

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I DEFINITIONS AND INSTRUCTIONS 1

1. 'the term " document" is defined to be synonymous in meaning and equal in scope to the usage of the term f l

" documents and tangible things" in Federal Rule of Civil ]

I Procedure 34(a), and therefore shall include, without limitation, any written or otherwise recorded l l

information.

2. To " identify" a document means to either: f (a) state the author, date, title, addressee (s), and subject matter of each individual document; or (b) if a request calls for the identification of more than twenty documents similar in subject matter, ADA those documents are also being produced, list the subject matter categories of documents, indicating the number of responsive documents in each category.

3. To " identify" a person other than an expert witness means to state the person's full name, title, business address, affiliation, and professional qualifications (if any). To " identify" an expert witness means to

. i state, in addition to the foregoing:

(a) the profession or occupation and field (s) of expertise of the person; I

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! l (b) the educational'and specialized training history of the person, including date and granting institution of all degrees earned; (c) a list of publications by the person in the area (s) of expertise; and (d) the age of the person and the amount of time the person has worked in the field of expertise.

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4. If any of the interrogatories or document production requests contained herein are claimed to be objectionable, then please identify the portion (s) to which objection is made and the portion (s) to which answer or production is made.

5. If it is claimed that any document responsive to any request is privileged, please fully identify each privileged document in accordance with Instruction 2(a) above.

6. If any document required to be identified or produced in these answers has been destroyed, please identify the document, state the date of its destruction, identify the person responsible for ordering destruction, state the purpose of destruction, and (if applicable) produce any document retention policy that governed or should have governed the retention or destruction of the document.

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7. "SPMC" means the most current updates of the Seabrook Plan for Massachusetts Communities and all appendices, amendment.s, and attachments thereto.

8. The " Massachusetts EP2' means the Massachusetts portion of the Emergency Planning Zone for Seabrook Station and consists of Amesbury, Merrimac, Newbury, Newburyport, Salisbury, and West Newbury.

9. The term " contention" is defined to include the complete text of the contention itself and all bases and sub-bases thereto.

10. Except for Interrogatories 1-3, all the interrogatories and requests which follow are grouped according to the Joint Intervenor Contention to which they refer. In I case of doubt as to the intended scope of an interrogatory or request, it should be assumed that the request or interrogatory encompasses all information and material within the scope of the referenced contention.

INTERROGATORIES AND REOUESTS FOR PRODUCTION

1. Please produce all analyses, studies, and reports bearing on any and/or all of the factual issues raised in the Joint Intervenor Contentions.

2. In each case where one of the following interrogatories asks for "all the facts" or "all the facts, estimates, and observations", please also identify the person (s) i 1

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.and/or document (s) that are the source (s) of those  ;

i facts,' estimates, and/or observations, and produce all documents that reflect, concern, refer or pertain to any and/or all of those facts, estimates, and observations.

3.- Please identify the person (s) answering or substantially contributing to the answer to each of the f following interrogatories. Please also identify all persons consulted, and identify and produce all communications and documents consulted and/or relied upon, in answering each interrogatory.

l AS TO JI CONTENTION 11

4. Please. describe in detail all the "special difficulties, circumstances, and delays in conducting an evacuation in Massachusetts" which Interveners assert are not adequately taken into account in the KLD Evacuation Time Estimate Study and Traffic Management Plan Update. For each such special difficulty, circumstance, and delay, j i

state all the facts, estimates, and observations  ;

underlying Interveners' assertion.

5. Please describe in detail all the "many effects that i'

result from an 2vacuation conducted under the SPMC" which Interveners assert "the old KLD ETE study . . .

1 The following Interveners have indicated that they do not intend to litigate JI contention 1, and so do n21 need to i respond to the questions concerning it (unless their l intentions have changed): SAPL; TON; CON; TOS.

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did not take into account." For each such "effect", l state all the facts, estimates, and observations underlying Intervanors' assertion.

6. Please state all the facts, and describe in detail the regulatory basis (if any), underlying Intervanors' assertion that "an evacuation time study [must) be done on a case-by-case basis."

AS TO JI CONTENTION 2 2

7. Please state, individually for each town in the Massachusetts EPZ (or for the entire EPZ, if no town figures are available) what the " maximum size of the Massachusetts beach. area vehicle population" is. If i

Interveners do not know what the " maximum size of the Massachusetts beach area vehicle population" is, please so state, and then state all the facts underlying the )

I assertion in MAG Contention 39A that the Applicants' estimate of the " maximum size of the Massachusetts beach area vehicle population . . . is significantly too low."

In either case, state all the facts, estimates, and l

observations underlying your answers.

- 8. Please identify every location in the Massachusetts EPZ, not presently specified in the SPMC as a designated 2 The following Interveners have indicated that they do not intend to litigate JI Contention 2, and so do n21 need to respond to the questions concerning it (unless their SAPL; TON; CON; TOS.

intentions have changed):

Traffic Control Point ("TCP"), which Intervanors assert would require TCP personnel in order to avoid the

" inadequacies" alleged in JI Contention 2. For each such location, describe in detail all the alleged

" inadequacies," and state how many TCP personnel would be required to avoid the " inadequacies" alleged.

Please also state all the facts underlying your answers.

9. Please identify every SPMC TCP location which Interveners assert is inadequately staffed, and state for each' location how much additional personnel would be required to avoid the " inadequacies" alleged in JI Contention 2. Please also state all the facts underlying your answers.

10. For each TCP location which Interveners assert is either inadequately staffed (Interrogatory 9) or omitted altogether from the SPMC (Interrogatory 8), state in detail the precise empirical, observable results that Interveners assert the absence of the allegedly necessary TCP personnel at that location would cause.

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Please also state all the facts underlying your answers.

- 11. Please identify every location where Interveners assert that "the traffic congestion will eliminate two-way road flow, so tow trucks will not always be able to travel to the blockages," indicating for each location why

" traffic congestion will eliminate two-way road flow" I

and how frequently (and for how long) the congestion 1

'would actually impede tow truck access. Please also state all the facts underlying your answers.

12. Please state in detail all the facts underlying Interveners' assertion that "0RO traffic guides will (not) be able to move the traffic in Massachusetts just as fast as state / local professionals would," and define

" State / local professionals."

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13. Please produce all training curricula and training l manuals used to provide traffic control training to l

" State / local professionals" working within the Massachusetts EPZ within the last five years. ,

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14. Please identify every " traffic and access control  ;

diagram" which Interveners assert is " ambiguous" and/or

" confusing" and/or does not " indicate which position at a given intersection should be staffed first" and/or does not "sufficiently inform traffic guides what the term ' discourage' really means," and/or contains "no clear instructions on how to place cones and barriers".

For each diagram identified, state which of the alleged infirmities that diagram has, what facts about the diagram cause it to suffer that alleged infirmity, and all the facts which indicate that infirmity "cannot be remedied by training."

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L 15.. Please state all the facts, other than those discussed l

in response to the preceding interrogatories, underlying Interveners' assertion that " orderly and efficient traffic flow will not be maintained due to the inadequacies in planning for the use of traffic control personnel and for the removal of road blockages by tow trucks", and define " orderly and efficient traffic flow."

16. Please identify every assumption in Applicants' ETE calculations "about road, intersection, and ramp capacities in Massachusetts" which Interveners assert are " higher than can be expected", and state for each assumption exactly how much " higher than can be expected" it is. Please also state in detail all the facts, estimates, and/or observations underlying these assertions.

17. Do the Interveners assert that " road, intersection, and ranp capacities in Massachusetts" differ from the capacities of similar road, intersections, and ramps in l

New Hampshire? If so, please describe in detail every difference, and state all the facts, estimates, and f 4

observations underlying your answers.

18. Please state all the facts, estimates, and observations )

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underlying Interveners' assertion that " data collected I on the major evacuation roads in the Massachusetts l f' 4

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1 portion of the EPZ" would have shown VF "to be in the range of 0.75 of V E*"

19. Please identify all the " specific critical intersections in the Massachusetts EPZ towns" for which Interveners assert Applicants' ETEs "are based on overly optimistic assumptions about the discharge headways that can be achieved." For each such intersection, please state all the facts that Interveners assert make the assumptions overly optimistic, and what assumptions Interveners assert would instead be correct. Please al s'o , for each such intersection, state all the facts, estimates, and observations underlying your answers.

20. Please identify all " assumptions concerning the number of cars that will flow through roads, intersections and j ramps in Massachusetts", other than those identified in j response to the preceding interrogatories, which Interveners assert are " incorrect." For each such ,

assumption, please state all the facts underlying Interveners' assertion that the assumption is incorrect.

21. Please describe in detail the types and causes of

- " delays" Interveners assert "will result from the confusion among the public caused by hearing different emergency messages from different sources," identify all of the "different sources," and quantify each delay.

Please also state all the facts underlying your answers.

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22. Please state whether Interveners still assert that Applicants' ETEs are based upon crossing a " curbed, grassy median that cannot be traversed in adverse I weather." If so, please state all the facts underlying Intervenorp' assertion that the median "cannot be traversed in adverse weather," and define " adverse weather".

23. Please state all the facts, other than those discussed in response to the preceding interrogatory, underlying Interveners' assertion that Applicants' " traffic management plan . . . overestimates the traffic flow l rate through the intersection of Route 110/I-95/ Elm Street in Amesbury."

24. Please state all the facts, estimates, and observations underlying Interveners' assertion that the "SPMC's ETEs do not account for the large number of evacuating vehicles which will travel south on Rt. lA from Seabrook, NH, cross the state line, and seek to evacuate through Salisbury, Massachusetts, on Rt. 1A."

25. Please state all the facts, estimates, and observations

• underlying Interveners' assertion that the "SPMC's ETEs fail to account for the large number of transients who j

regularly visit portions of the Massachusetts EPZ which are D21 in the beach areas." Please also describe in detail all of these " regularly visit [ed) portions",

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state'how many transients visit each location, and state .,

all the facts, estimates, and observations underlying i

your answers.

26.- Please identify all "special event days" in which  !

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' Intervanors assert " huge crowds" not accounted for in Applicants' ETE's would gather in the Massachusetts EPZ.

For each such "special event day," please quantify those

" huge crowds," indicating number of persons, whether they are primarily residents or transients, where they would gather, and for how long. Please also state all the facts, estimates, and observations underlying your l answers.

27. Please identify every other way, not discussed in response to the preceding interrogatories, in which Interveners assert that Applicants' ETEs "are based on an undercount of the number of vehicles evacuating from or through the Massachusetts portion of the EPZ." For each such assertion, state all the facts, estimates, and observations underlying it.

28. Please identify every intersection at which Intervanors

- assert " vehicles will be blocked" from " legitimate reasons to travel against or across the flow of evacuation traffic" if Applicants implement their

" traffic management plan." Please also identify every i

" legitimate reason" why vehicles would be travelling i-p -

I across or against the flow, explain in detail why traffic control personnel would not be able to facilitate such travel when it in' fact is necessary (by L

temporarily moving traffic cones or otherwise), and explain in detail what the consequences of every such asserted blockage would be. State all the facts underlying your answers.

29. Please state how much larger Interveners assert the population of the Massachusetts EP2 is, broken dcwn by individual towns, than was assumed in Applicants' ETEs, l Please state all the facts, estimates, and observations underlying your assertions. ,

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30. Please state what Interveners assert the average number l

of people per evacuating car would be. Please also f

state all the facts, estimates, and observations underlying that assertion.

31. Please identify every " major road" on which Interveners

' assert that there "could be . .

. thousands of 'through'

. vehicles" for which the "ETEs fail to account", and I

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state, for each such road, how many "through vehicles"

- are allegedly unaccounted for. Please state all the facts, estimates, and observations underlying these assertions. l

32. Please identify every instance in which Interveners assert Applicants have underestimated the number of I

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" campground spaces and hotel, motel, and guest house rooms in the Massachusetts portion of the EPZ," and, for 1

each case, provide the number that Interveners antert to ]

1 be correct. Please state all the facts, estimates, and j i

g observations underlying those assertions. l.

33. Is it Interveners' assertion that all traffic control personnel must be in place prior to a recommendation to f

evacuate in order for the SPMC ETEs to be realistic?

Please state all the facts underlying your answer.

34. Please state all the facts, not already discussed in response to the preceding interrogatory, underlying Interveners' assertion that "the traffic contro2 personnel will (not) be able to staff their posts in a timely manner." If this asraertion applies only to certain accident scenarios, identify every such scenario.

35. Please state all the facts underlying Interveners' assertion that " traffic and access control guides will  :

show up . . . intermittently in groups of twos, threes, and fours over a long period of time", and define "long period of time".

36. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying l Interveners' assertion that the SPMC ETEs "are too i

unrealistic to form the basis of~ adequate protective action decision-making."

As TO JI CONTENTION 31

37. Please describe in detail the "real-time, computer-based system to monitor the size of the beach population" envisioned in JI Contention 3. This description should include, but not be limited to:

(a) a description of all components of the system, their locations (including the locations of all roadway traffic counters), and how they would be connected and would interact; (b) a list of every similar system known to Interveners which presently is operational, along with its manufacturer and application, and all computer 1

hardware and software presently available to support such a system; (c) the cost and time to acquire or develop such a system and the cost of maintaining itt (d) the actual or projected reliability of such a system, the name(s) and business addrers(es) of all

• qualified installation and maintenance personnel, and a description of the backup to the system; 3 The following Interveners have indicated that they do not intend to litigate JI contention 3, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS.

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(e) the frequency with which such a system would report its findings; (f) whether the Commonwealth of Massachusetts presently uses or intends to use such a system for radiological or non-radiological emergency planning and, if not, why not.

Please state in detail all the facts underlying this description.

38." Please state all the facts underlying Interveners' assertion that the SPMC is " deficient" absent such a "real-time, computer-based system."

AS TO JI CONTENTION 4 4

39. Please identify every error and ambiguity that Interveners assert existLin Applicants' current traffic Please state all the facts underlying i control diagrams.

each of Interveners' assertions of error or ambiguity.

40. Please state all the facts, other than those stated in )

response to the preceding interrogatory, underlying Interveners' assertion that "the traffic control 4 The following Interveners have indicated that they do not intend to litigate JI Contention 4, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL.

In addition, TOS may limit its responses to just those questions that concern issues which it indicated, in its Request for Limited Participation Status (October 6, 1988),

that it intends to litigate.

diagrams contained in the SPMC are not sufficiently clear to allow the SPMC's traffic management plan to be implemented."

41. Please identify every location along " heavily travelled evacuation routes" where Intervanors assert that more traffic control personnel would be needed "to ensure that two-way traffic flow can be maintained." Please state all the facts underlying your answer.

42. Please state all the facts, for each TCP, underlying Interveners' assertion that more personnel and equipment '

are needed at the traffic control points listed in the SPMC for Newburyport.

43. Please define the following terms used in CON Contention 6:

(a) " staging of TCP equipment";

(b) "readily available";

(c) the time period covered by "the advent of a radiological emergency";

(d) "other transports".

44. Is it Interveners' assertion that TCP equipment must be

. pre-positioned in the field? If so, please state all the facts underlying that assertion. I

45. Please identify every " anticipated and significant choke ,

point" in Amesbury at which Interveners assert that i

i traffic guides would be necessary. Please state all the facts underlying those assertions.

46. Please state all the facts underlying Interveners' assertion that " alteration of TCPs and traffic control devices, in heavy traffic, will present dangerous conditions beyond the capabilities of NHY amployees,"

and define " dangerous conditions".

47. Please state all the facts underlying Interveners' assertion that "the SPMC assigns too few traffic guides and insufficient equipment to the Salisbury Transfer Point and to those points along Beach Road where travel lane reductions occur," and identify every point along Beach-Road "where travel lane reductions occur."

48. Please state what the clearance of the B&M Bridge over Lafayette Road in Salisbury is. Please also state how many tractor trailers incapable of passing that clearance would be diverted along that road under the SPMC, and state all the facts underlying your answer.

49. Please state all the facts underlying Interveners' assertion that "significant traffic congestion can reasonably be assumed" for the specified " critical intersections" in West Newbury.

50. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying

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control personal relied upon by the SPMC is inadequate."

51. Please state all of the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that " insufficient capacity-enhancing measures and other poorly conceived traffic control strategies are utilised by the SPMC's traffic management plan," and define " capacity-enhancing mensures."

52. Please describe in detail all the " problems that will occur during on evacuation in the event that the Gillis Bridge is closed to traffic in order to facilitate the passage of boats" that Interveners assert "the SPMC has not adequately addressed." Please also state when, how frequently and how long the bridge would be closed to traffic. State all the facts, estimates, and observations underlying your answers.

53. Please state all the facts, other than those discussed l in response to the preceding interrogatories, underlying Interveners' assertion that "the traffic control diagrams contained in the SPMC are not sufficiently clear to allow the SPMC's traffic management plan to be implemented."

54. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying

Intervanors' assertion that "the evacuation _ plan contained in the SPMC is so poorly designedLand so inadequately staffed that, even if state and local officials are assumed to make a best efforts response, there is no reasonable assurance that either the permanent residents or the transients can or will be evacuated as efficiently as possible."

1 AS TO JI CONTENTION 55

55. Please describe in detail, and produce all documents that reflect or refer to, the procedures relied upon by the Commonwealth of Massachusetts for " surveillance and removal of road blockages" in the event of radiological emergencies at the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants.

56. Please state all the facts underlying Intervanors' assertions that " Route Guides for the hearing impaired .

. . will likely avoid travel along major evacuation links, and they are not out in sufficient numbers". u l 57. Please state all the facts, other than those discussed l

in response to the preceding interrogatories, underlying Interveners' assertion that "the method utilized by the 5 The following Interveners have indicated that they do not intend to litigate JI contention 5, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; CON; TOS.

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SPMC for surveillance and removal of road blockages is not adequate to ensure that road blockages will be j identified and removed promptly enough", and define "promptly enough".

58. Please state all the facts underlying Intervanors' assertion that "the communications procedures for dispatching tow.vahicles once blockages have been spotted are too cumbersome and ineffective", and define the meaning and consequences of those procedures being "too cumbersome and ineffective."

6 AS TO JI CONTENTION 6

59. Please define the geographic boundaries of the " river basin" referred to in JI Contention 6.

60. Please identify every dockage point, boat launching ramp, and permanent mooring point available on the Merrimac River within the Massachusetts EPZ.

61. Please state all the facts, estimates, and observations underlying Interveners' assertion that "possibly hundreds of commercial and pleasure boaters on the l Merrimac River...may be confined to the river basin . .

. without adequate dockage and transportation ashore."

6 The following Interveners have indicated that they do not intend to litigate JI Contention 6, and so do nat need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON.

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62. Please state ?ll the facts, not stated in response to the preceding interrogatory, underlying Intervenor' assertion that " frequently occurring conditions of wind and tide" would confine boaters to the " river basin,"

and define (with quantification) " frequently".

AS TO JI Coi,i1 120N 77

63. Please state all the facts underlying Intervanors' assertion that, in Newburyport, the SPMC's " method of

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circulatin, buses significantly reduces the reliability of actually accomplishing the retrieval of these individuals and increases the potential for a broad spectrum of the populace . . . to be left behind."

64. Please state all the facts underlying Interveners' assertion that the Newburyport Transfer Point is

" subject to periodic flooding and severe tidal conditions," and define (with quantification) " periodic" and " severe tidal conditions."

65. Please state all the facts underlying Interveners' assertion that the Newburyport Transfer Point is "not 7 The following Interveners have indicated that they do not intend to litigate JI Contention 7, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL.

In addition, TOS may limit its responses to just those questions that concern issues which it indicated, in its Request for Limited Participation Status (October 6, 1988),

that it intends to litigate.

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suitable for the saft sheltering or even staging of large numbers of people."

66. Please state all the fccts underlying Intervanors' assertion that the Newburyport Transfer Point " offers poor visibility and turning access for buses coming into and out of the facility."

67. Please identify the agency and/or individual (s) responsible for placing and maintaining road signs in j Newbury. Explain why adequate road signs have not been placed at each of the locations described in TON j contention 1 as being unmarked and/or poorly marked.

68. Please identify all segments of roads in Newbury that are subject to flooding, and state for each such road how frequently the road is rendered impassable by flooding. State in detail all the facts underlying your answer.

69. Please state all the facts underlying Interveners' assertion that Downfall Road in Newbury is " nonexistent l 1

und impassable".  !

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70. Please identify every bus route within the scope of TOS  !

Contention 14, describe the geographic boundaries of the

" flooding marsh", and state how frequently each segment of each bus route would assertedly be " impassable" due to " weather and tide." Please state all the facts underlying your answer.

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71. Please state what Intervanors assert a realistic estimate of " passenger demand" for each bus. route in Salisbury would be. State all the facts, estimates, and observations underlying your answer.

72. Please identify every intersection at which bus drivers are required to turn in West Newbury where Intervanors assert that there are no street signs, and state all the facts underlying your answer.

73. Please identify the agency and/or individual (s) responsible for placing and maintaining road signs in the West Newbury. Explain why adequate road signs have not been placed at each of the locations listed in response to the preceding interrogatory.

74. Please identify exactly which parts of River Road and Ash Street Interveners assert become impassable due to flooding, state how frequently Interveners assert that such conditions occur for each such part, and state all the facts underlying your answers.

75. Please state all the facts underlying Interveners' assertion that the Stewart Street transfer site is j

" inadequate for a bus turn around."

76. Please state all the facts, other than those discussed J i

in response to the preceding interrogatories, underlying f Intervanors' assertion that "the bus routes proposed for Newbury, Newburyport, West Newbury and Salisbury as I

particularized in their contentions as filed, will not expedite the evacuation of [the transit dependent) population."

AS TO JI CONTENTION 8 8

77. Given the. route maps provided in the SPMC and the notification to the public in EBS mes nges regarding,the start times for bus routes, do Interveners assert that there are further practicable measures that can be taken to shorten the time during which transit dependent persons in Salisbury and West Newbury would wait outside along bus routes? If so, please describe in detail all such measures, including all the steps necessary to make each measure practicable, and state all the facts, estimates, and observations underlying your answer.

78. Please state, for each bus route in Salisbury and West Newbury, how long Interveners assert that the average transit dependent person would be waiting outdoors, and what " radiation dose" and " exposure to the elements" that person would receive during the wait. If Interveners assert that the times, doses, and/or exposures would vary depending on the accident scenario, answer separately for each such scenario. Please state 8 The following Interveners have indicated that they do not intend to litigate JI Contention 8, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): TON; TOS; CON.

all the facts, estimates, and observations underlying your answers.

AS TO JI CONTENTION.99

79. Please identify all emergency personnel whose availability Intervanors assert would be affected in the event of a strike or other form of job actica. S' ate all the facts underlying your answer.

AS TO JI CONTENTION 1010

80. Pleaso identify every Faderal agency that Intervanors assert would not be required to respond to a Seabrook emergency in the manner relied upon in the SPMC. Please state, with respect to each such agency identified, all the facts underlying your assertion.

81. Please describe in detail all the " lessons learned from exercises of the FRERP conducted at the Zion Nuclear Facility in Jui.;,1987" which Interveners essert

" indicate that responsible emergency organizations . . .

should meet and plan adequate interfaces with the NRC to insure effective use of FRERP Federal assistance."

9 The fellowing Interveners have indicated that they do not intend to litigate JI contention 9, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON: CON; TOS.

10 The following Interveners have indicated that they do not intend to litigate JI Contention 10, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON TOS.

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82. 'Please describe in detail all the "lestons learned from q the exercise of the FRERP conducted at the Eion facility I

j in June 1987" which Interveners assert " indicate that the estimate of 3 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for a fe$eral response at Plan 2.3.-2 is totally unrealistic and that 24 to 48- ]

hours would be more reasonable." j

83. Please identify each of "the responsibilities attributed to federal agencies at Plan 0 2.3.3" that Interveners assert exceed "both the FRERP and the policy of these individual agencies." For each such responsibility, pleace state all the factc underlying that assertion.

84. Please identify each " federal support option" that Interveners assert "would be available only in light of a Presidential Disaster Declaration." For each such

' federal support option, please state all the facts ,

underlying your answer.

85. Please describe in detail each instance in which Interveners assert that FEMA has resisted a Presidential

)

Disaster Declaration for radiological emergencies. For each such instance, please state all the facts underlying your answer.

86. Please state all the facts underlying Interveners' assertion that the ORO "is totally unprepared to effectively interface with these Federal agencies in the event of an actual emergency."

87. Please state all the facts underlying Intervanors' assertion that "[m]onitoring and dose assessment information provided to the NRC by the Department of Energy during the Ef.on exercise of the' FRERP in June 1987 overwhelmed the capacities of the NRC."

88. Please state all the facts underlying Interveners' assertion that the SPMC's alleged failure to provide "praecical information" hinders the ORO from

- " assess [ing] whether communication links and other forms of interface between ORO and the Federal agencies will even be possible during an emergency," and define

" practical information."

89. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "the SPMC fails to provide adequate arrangements for requesting and effectively using Federal assistance resources and does not comply with 50.47(b) (3) and NUREG 0654, II.C.1.a, b. and c."

AS TO JI CONTENTION 1111

90. Please state all the facts underlying Intervanors' assertion that "[t]he SPMC does not provide for the 11 The following Interveners have indicated that they ,

do not intend to litigate JI contention 11, and so do D21 /

need to respond to the questions concerning it (unless their I intentions have changed): SAPL; TON; CON: TOS.

1

j capability of continuous operations for a protracted period of time."

91. Please state all the facts underlying Interveners' assertion that "(d)elays can be expected in [ experienced management personnel's) response to requests for assistance."

92. Please identify each position where Interveners assert "there are fewer staff available for some positions than will be reasor. ably necessary on a 24-hour basis during protracted emergency." For each such position, please state all the facts underlying that assertion.

93. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "the SPMC fails to provide for the adequate or continuous staffing of ORO personnel to maintain or sustain an emergency response."

AS TO JI CONTENTION 1;12

94. Please state all the facts underlying Interveners' assertion that "there is no reasonable assurance that an evacuation could be completed within one shift."

95. Please state all the facts underlying Intervanors' assertion that "there is no reasonable assurance ...

12 The following Interveners have indicated that they do not intend to litigate JI Contention 12, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON: CON; TOS.

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1 that during a radiological emergency at Seabrook Station which is serious enough to warrant a second shift for these evacuation-specific positions, enough volunteers can be recruited by Yankee Atomic to fill all such positions."

96. Please state all the facts underlying Intervanors' assertion that Yankee Atomic amployees 'will not volunteer in sufficient numbers or in a timely fashion during a radiological emergency."

97. Please state all the facts underlying Interveners' assertion that "first-shift workers (will) want to minimize dose consequences by getting out of the EPZ as quickly as possible."

98. Please state all the facts underlying Interveners' assertion that "on-the-job training during an emergency, offered by first-shift workers who want to minimize dose consequences by getting out of the EPZ as quickly as possible, is very likely to be inadequate."

99. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying

. Interveners' assertion that "there is no reasonable assurance that there will be adequate second shift manpower capability for certain evacuation-specific positions," and list all of the "certain evacuation-specific positions."

&S TO JI Cukiur10N 133 100. Please state all the facts underlying Intervanors' assertion that "[t]he position of senior manager of a business office does not provide the training skills or experience required to make prudent emergency management decisions," and state all the facts underlying Interveners' further assertion that "[t]he training provided by the SPMC . . . is not adequate to compensate for this deficiency."

101. Please state all the facts underlying Interveners' assertion that "(s)ince the Monitoring / Decontamination Personnel are dealing directly with the public, it is imperative that they have past experienes and training in Health Physics and methods used for the monitoring of and the removal of contamination from personnel and vehicles," anc please state all the facts underlying Interveners ' further assertion that "[t]he training provided by the SPMC . . . is not adequate to compensate for this deficiency."

102. Please state all the facts underlying Intervanors' l

• assertion that "[t]he position of senior manager of a business office doec not provide the training skills or

)

i' 13 The fo11 ewing Interveners have indicated that they do not intend to litigate JI contention 13, and so do n21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON: TOS.

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experience required to direct the mobilization of emergency offsite personnel and the logistics therewith (i.e., bus coordination, traffic control, traffic guides, access control, etc.)," and please state all the L.

facts underlying Intervanors' further assertion that

"[t]he training provided by the SPMC . . . is not adequate to compensate'for this deficiency."

103. Please state all the facts underlying Intervanors' assertion that the SPMC's not enumerating the

" qualifications" listed by Interveners for Technical Advisor amounts to a " deficiency," and please state all the facts underlying Intervanors' further assertion that'

"[t]he training provided by the SPMC . . . is not' adequate to compensate for this deficiency."

104. Please state all the facts underlying Interveners' assertion that the SPMC's not enumerating the

" qualifications" listed by Interveners for Radiological Health Advisor amounts to a " deficiency," and please state all the facts underlying Interveners' further assertion that "[t]he training provided by the

- SPMC . . . is not adequate ' compensate for this deficiency."

105. Please state all the facts underlying Interveners' assertion that the qualification requirements identified in the SPMC for Accident Assessment Coordinator are 3

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" insufficient" and that the " qualifications" listed by Interveners for that position are necessary in order to avoid a " deficiency," and please state all the facts underlying Interveners' further ansertion that "[t]he training provided by the SPMC . . . is not adequate to j compensate for this deficiency."

1 106. Please state all the facts underlying Interveners' j further assertion that the SPMC's not quantifying the '

i experience and training needed to perform the tasks required of Field Monitoring Teams is a " deficiency" and i '

that the skills listed by Interveners for that position are necessary in order to avoid such a " deficiency," and please state in detail all the facts underlying Interveners' further assertion that "[t]he training provided by the SPMC . . . is not adequate to compensate for this deficiency."

107. Please state all the facts underlying Interveners' assertion that the SPMC's not quantifying the experience and training needed to perform the tasks required of Reception Center Coordinator is a " deficiency," describe what qualifications are needed to accomplish adequately the duties listed by Interveners for Reception Center coordinator and state in detail all the facts underlying that assertion, and please state all the facts underlying Interveners' further assertion that "[t]he 1

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training provided by the SPMC . . . is not adequate to compensate for this deficiency."

108. Please state all the facts underlying Intervanors' assertion that the SPMC's not quantifying the experience.

and training needed to perform the tasks required of j l

Reception Center Leader is'a " deficiency," describe what qualifications are needed to accomplish adequately the duties listed by Interveners' for Reception Center Leader and state in detail all the facts underlying that assertion, and please state all the facts underlying Interveners' further assertion that "[t]he training provided by the SPMC . . . is not adequate to compensate for this deficiency." ,

109. Please state all the facts underlying Intervanors' assertion that " qualifications" listed by Interveners for Public Notification Coordinator are necessary in order to avoid a " deficiency," and please state all the facts underlying Interveners' further assertion that

"[t]he training provided by the SPMC . . . is not adequate to compensate for this deficiency."

- 110. Please state all the facts underlying Intervanors' assertion that the requirements listed by Interveners for NHY offsite Response EOC Contact are necessary in order to avoid a " deficiency," and please state all the facts underlying Interveners' further assertion that l 4

1 -as-1

"[t]he training provided by the SPMC . . . is not adequate to compensate for this deficiency."

111.- Please state all the facts underlying Intervanors' assertion that the SPMC's not quantifying the experience and training needed to perform the tasks required of Communication coordinator is a " deficiency," describe what qualifications are needed to accomplish adequately the duties listca by Interveners for Reception Center Leader and state in detail all the facts underlying that assertion, and please state all the facts underlying Interveners' further assertion that "[t]he training I provided by the SPMC . . . is not adequate to compensate for this deficiency."

112.-Please state all the facts underlying Intervanors' assertion that the SPMC's not quantifying the experience and training needed to perform the tasks required of telephone operator is a " deficiency," and that the requirements listed by Interveners for that position are necessary in order to avoid such a " deficiency," and please state all the facts underlying Intervanors'

' further assertion that "[t]he training provided by the SPMC . . . is not adequate to compensate for this deficiency."

113. please state all the facts underlying Interveners' assertion that the SPMC's not quantifying the experience f.

and training needed to perform the tasks required of the Administrative Staff is a " deficiency," describe what qualifications are needed to accomplish adoquately the-l duties listed by Interveners for the Administrative Staff and state all the facts underlying that assertion, and state all the fr, cts underlying Interveners' further assertion that "[t]he training provided by the  ;

SPMC . . . is not' adequate to compensate for this deficiency."

114. Please' state all the facts underlying Interveners' assertion that the SPMC's not quantifying the experience and training needed to perform the tasks required of Special Population Coordinator is a " deficiency," and that the requirements listed by Interveners for that position are.necessary in order to avoid such a

" deficiency," and state all the facts underlying Interveners' further assertion that *(t]he training provided by the SPMC . . . is not adequate to compensate for this deficiency."

115. Please state all the facts underlying Interveners' assertion that the SPMC's not quantifying the experience and training needed to perform the tasks required of Bus Driver is a " deficiency," and that the requirements listed by Interveners for that position are necessary in order to avoid such a " deficiency," and state all the

E# f

_g facts underlying Interveners' further assertion that

"[t]he' training provided by the SPMC . . . is not-adequate _to compensate for this deficiency."

p 116. Please state all the facts underlying Interveners'

)

assertion that "[i)t is inconceivable that Traffic Guides would not be required to have some substantial prior. experience directing congested traffic," define

" substantial prior experience," and state all the facts underlying'Intervanors' further assertion that "[t]he training provided by the SPMC . . . is not adequate to

. compensate for this deficiency."

117. Please' state.all th's facts underlying Interveners' ascertion that-"[t]he ORO personnel to be used for radiological monitoring and dose assessment are inexperienced in the field of radiation and inadequately trained." Please also describe in detail, and produce all documents that reflect or refer to, the training and experience of the personnel relied upon by the Commonwealth of Massachusetts for " radiological monitoring and dose assessment" in the event of radiological emergencies at the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants.

118. Please state all the facts underlying Intervanors' assertions that "[t]he Dose Assessment Technician

("DAT") is not sufficiently experienced in computer-l l

p 4

l based dose projections" e.nd that the experience j requirements are not adequate. .

219. Do Interveners know or have reason to believe that the training developed for the DAT position would not ]

" qualify" an inexperienced computer user for this position or that the level of proficiency of a qualified DAT vsuld in any way be inadequate? If so, please state all the facts that form the basis of that knowledge or belief.

120. Please state all the facts underlying Interveners' assertion that "the Accident Assessment Coordinator who l directs dose assessment and field radiological monitoring has neither sufficient experience in the I field nor adequate training."

- 121. Please state all the facts, other than those discussed )

in response to the preceding interrogatories, underlying Interveners' assertion that "the prerequisite experience required for qualification to hold numerous critical ORO positions, and the training provided by the SPMC fer those positions, is inadequate to provide reasonable assurance that ORO can and will implement adequate protective measures in the event of a radiological emergency at Seabrook Station." Please also identify all such " critical ORO positions," other than those cited in the preceding interrogatories, explain in .

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i detail why Intervanors assert that they are " critical",

and state all the facts underlying your answers.

As To JI CGW-noer idL4 122. Please state, for each individual and/or position to which Intervanors contend that the assertion applies, all the facts underlying Interveners' assertion that the ORO training is " entirely too general in nature, is much too brief, is not well dona, and does not qualify ORO staffers to perform their jobs under the difficult and confusing circumstances that will prevail in the event of a serious radiological emergency at Seabrook Station."

123.-Please state all the facts underlying Interveners' assertion that "there is no reasonable assurance that the bus drivers who purportedly have agreed to respond

.to an emergency at Seabrook in fact have sufficient experience or training to perform this function."

124. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "the SPMC provides inadequate training to members of ORO."

l 14 The following Interveners have indicated that they I do not intend to litigate JI Contention 14, and so do D21.

need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS.

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125. 11 ease explain in detail exactly ghy " State and local governments [ sic) employees . . . are not receiving any training at all on SPMC procedures," and state all the facts underlying your answer.

AS TO JI CONTENTION 1515 126. Please state all the facts underlying Interveners' assertion that "ORO emergency workers will be liable for damages resulting from their actions," and define "their actions."

127.-Please describe all types of " damages resulting from

[ORO emergency workers') actions" that Intervanors assert would be likely to arise during an actual radiological emergency, and state all the facts underlying'your answer.

128. Please describe every consequence that Int venors assert'would arise if "ORO emergency workers" were

" liable for damages resulting from their actions," and state all the facts underlying your answer.

15 The following Interveners have indicated that they do not intend to litigate JI Contention 15, and so do Dat need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS.

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AS TO JT CONTENTION 1616 129. Please state all the facts underlying Interveners' assertion that "the number of monitoring teams . . . and j the training and experience of the personnel is inadequate to adequately monitor radiation levels in the Massachusetts portion of the EPZ." Such answer should include, but not be limited to, a description of the l number and training of the field monitoring teams that the Commonwealth of Massachusetts would supply for radiological emergencies at the Pilgrim, Yankee Rowe, and Vermont Yankee facilities.

130. Please state all the facts underlying Interveners' assertion that "the procedures <lrveloped e to direct and control these field monitoring teams are inadequate."

131. Please state all the facts underlying Interveners' assertions that:

a. "the SPMC provides no assurance that adequate coordination of dose assessment activities taking place at the EOC and the EOF based on a variety of 1 l

different field monitoring teams will exist"; )

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16 The following Interveners have indicated that they do not intend to litigate JI contention 16, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS.

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b .~ "no provision is made for the timely acquisition q and communication of this data to the necessary personnel," and define " timely" and "necessary";

l, 'c. "no criteria exist in the SPMC on the basis of which the Accident Assessment Coordinator or the Field Team Dispatcher could decide to assign specific monitoring locations," and define

" criteria";

d. "the' locations of work and residence for these personnel are such that timely mobilization is not possible," and define " timely";:and

e. "no back-up personnel are provided for these field teams."

132. Please describe in detail all of the " specific. local conditions" for which Interveners assert the SPMC's

" planning for the locations of effective radiological monitoring" does not account, and state all the facts underlying your answer.

133. Please state all the facts underlying Intervanors' assertion that " maps referenced at Plan 3.3-4 are not f: - adequately explained," and define " adequately".

-134. Please describe in detail what Intervanors assert would be "the impact of mobilizing and evacuating traffic on the timely availability of field team members at the dispatch location as well as the further delay in

arriving at a monitoring location," define "tinely", and state all the facts, estimates, and observations underlying your answer.

135. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "the SPMC fails to provide reasonable assurance that adequate methods, systema and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency are in use or could be used."

136. Please state all th? facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' asse1+ 1on that " provisions in the SPMC for radiological monitoring are inadequate."

AS TO JT CONTENTION 17 17 137. Do Interveners assert that there are circumstances for which, following beach closure at the Site Area Emergency classification, greater dose savings would be achieved by an instruction to the transient beach i If so, population to shelter rather than evacuate?

please describe in detail all cuch circumstances, and I state all the facts underlying your answer.

17 The following Interveners have indicated that they do not intend to litigate JI Contention 17, and so do D21 l need to respond to the questions concerning it (unless their intentions have changed): TON: CON; TOS. ,

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138. Please state all the facts underlying Interveners' assertion that " substantial portions of the beach population are entrapped by the traffic congestion generated by an order to evacuate and cannot remove themselves from areas close-in to the plant for many hours," and define (with quantification) " substantial portions" and "many hours."

139. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "no choice of protective actions is set forth in the SPMC for large numbers of e

people," and~ define (with quantification) "large numbers."

AS TO JI CONTENTION 1818 140. Please state what percentage of permanent structures in the Massachusetts EPZ Interveners assert have a shelter protection factor better than .9, and state all the facts, estimates, and observations underlying your f answer.

141. Please state all the facts, and describe in detail the regulatory basis (if any), underlying Interveners' assertion that askin and car deposition" and groundshine r  !

as The following Interveners have indicated that they do not intend to litigate JI Contention 18, and so do D21 need to respond to the questions concerning them (unless their intentions have changed): SAPL; CON; TOS.

~45-i

.aust be considtered in protective action decisionmaking.

Please also describe in detail, and produce all' documents that reflect or refer to, how these factors are considered.(if at all) in protective action decision making at the Pilgrim, Yankee Rowe,'and Vermont nuclear power plants.

142. Please state all the facts underlying Intervanors' assertion that "the SPMC's decision criteria for calculating thyroid shelter assumes an air exchange rate thatLis too high." Please also state what Interveners assert would be the appropriate air exchange rate'to use, and state all the. facts, estimates, and observations underlying that assertion.

143. Please specify by r.ategory each type of structure considered by Interveners in determining,the appropriate air exchange rate for Massachusetts EPZ protective action decisionmaking, state the percentage of the total number of permanent structures in the Massachusetts EPZ within each category, and state all the facts, estimates, and observations underlying your answer.

144. Do Inttrvenors assert that PAR' decision criteria should take into account exposures other than.whole body and thyroid exposure? If so, please state all the facts, and describe in detail the regulatory basis (if any),

underlying your answer.

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_ = _ - _ - - _ _ _ _ _ _ _ - _ - - _ - _ - _ _ _ - - _ _ _ _ - _ - _ - - - _ - _ .

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l 145. Please state all the facts underlying Intervonors'

)

assertion that "the entrapment phenomenon described by {

l NUREG 1210, V.4 at 19-20 . . . will occur at the Seabrook site during times of high beach population, and f define " times of high beach population."

146. Please state all the facts underlying Interveners' i

assertion that the SPMC " fails to adequately consider and plan for the possibility of entrapment due to bad weather, such as blizzards or flooding conditions," and define " adequately."

147. Please state all the facts underlying Intervanors' assertion that the SPMC "under-estimates doses.from iodire and other ground deposited material."

148. Please describe in detail all "non-radiological risks of evacuation" which Interveners assert that the SPMC should consider but does not, and state all the facts underlying your answer.

149. Please state all the facts underlying Interveners' assertion that "there is insufficient and untimely 1 incorporation of meteorological data into PAR decision-

- making," and define " insufficient" and " untimely".

150. Please state all the facts, estimates, and observations underlying Interveners' assertion that " meteorological assumptions made . . . do not adequately reflect or account for features of shoreline meteorology, including  !

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the frequent change of wind direction and the phenomena associated with sea breezes along the coastline," and .

I define "the phenomena associated with sea breezes along the coastline." Please also define (with quantification) " frequent" as used above to describe

" change of wind direction."

151. Please describe in detail the dose assessment programs and protective action decision procedure (s) utilized by the Massachusetts Department of Public Health for the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants. Such description should include, but not be limited to:

a. the results of the most recent FEMA graded exercise I

evaluation of these procedures for each plant;

b. a description of how the procedures consider impediments to evacuation;

c. a description of how the dose assessment program (s) estimate doses from iodine and other groundshine, ,

4 skin and vehicle deposition;

d. a description of how the procedures consider shelter first, rapid identification of hot spots, and relocation later as a PAR;

e. a description of how meteorological data is considered; I

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f. . a_ description of tho' specific meteorological assumptions made for each site; and

g. a description of how and when meteorological data l'

is input and updated into;the dose assessment

% program (s).

Please state all the facts underlying your description.

152. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "the SPMC's decision-making criteria for selecting a sheltering as opposed to an evacuation PAR is (sic) inadequate and inaccurate."

1-. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying

< Interveners' assertion .that "the SPMC does not establish or describe coherent decision criteria to be used by  ;

emergency decision-makers in formulating an appropriate PAR and otherwise fails to provide guidelines.for the choice of protective actions consistent with federal policy," and define " coherent" and " federal policy." l AS TO JI CONTENTION 19 19

• 153. Please state all the facts, estimates, and observations underlying Interveners' assertion that " wind-shifts in i l

-i 19 The following Intervanors have indicated that they do not intend to litigate JI contention 19, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): . SAPL; TON ; CON ; TOS .

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I the area of the plant are so frequent," and define (with quantification) "so frequent" and "in the area of the plant."

154. Please state all the facts, estimates, and observations i

underlying Interveners' assertion that "the phenomena of sea breezes at this site make actual direction of plume travel difficult to predict," and define "the phenomena I

of sea breezes" and " difficult."

155. Please state all the facts, estimates, and observations underlying Interveners' assertion that "for this plant site, the normal potential results of high and low wind

{ speeds as shown on Attachment 6 to IP 2.5 simply are not reliable."

156. Please describe in detail "the sudden 180' wind shift during the course of a serious hazardous materials fire at Seabrook, New Hampshire in March 1988," identify all witnesses who have described the " wind shift" to i

Interveners or their agents, and state all the facts underlying your answer.

l 157. Please state all the facts, estimates, and observations, f

other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that the SPMC's allowing and encouraging " decision-makers to ,

call for an evacuation of EPZ by sectors (S, SW, NE, SE, l

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1 N), even within 5 miles, depending on which way the wind is blowing," is "a deficiency."

AS TO JI CONTENTION.20 20 158. Please describe in detail all the " conditions" that Intervanors assert would be so at variance from "those assumed in the ETE study" as to require that "the ETEs used by protective action decision-makers" be

" adjusted", and define " adequately adjusted.'" Please also state all the facts, estimates, and observations '

underlying your answer.

AS TO JI CONTENTION 2121 159. Please state all the f acts, estimat45, and observations underlying Interveners' assertion that "the figures listed for the permanent residents are incorrect for the current time period," and define " current time period."

160. Please state all the facts, estimates, and observations underlying Interveners' assertion that "the ' peak' population totals for both ' summer midweek' and ' summer l

20 The following Intervanors have indicated that they 1

- do not intend to litigate JI contention 20, and so do D21 need to respond to the questions concerning it unless their intentions have changed): SAPL; TON; CON; TOS.

21 The following Interveners have indicated that they f do not intend to litigate JI Contention 21, and so do D21 I need to respond to the questions concerning it (unless their intentions have changed): SAPL; CON; TOS.

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weekend' are significantly too low", and define (with quantification) "significantly."

161. What do Interveners assert are the correct current.

figures for " permanent residents", " summer midweek peak", and " summer weekend peak" for the Massachusetts EPZ, by municipality? Please state all the facts, estimates, and observations underlying your answer.

AS TO JI CGn2nnrlON 22 22 162. Please state all the facts underlying Interveners' assertion that "the SPMC's evacuation time estimates have been rejected by state and local officials as totally unrealistic and unreliable." Please include in your answer a detailed description of every direct or ,

indirect communication between " local officials" and

" consultants retained by the (Massachusetts) Attorney General" concerning the alleged unreliability of Applicants' ETEs and/or the consultants' estimate of

" realistic evacuation times." Identify all the

. " consultants" and " local officials" involved in these communications.

22 The following Interveners have indicated that they do not intend to litigate JI Contention 22, and so do n21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CONT TOS.

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163. Please identify the person (s) who gave " local officials" to " understand that the ETEs in the SPMC were calculated using incorrect assumptions about notification times, beach population, times to staff traffic posts, an

'early beach closing', and traffic orderliness."

I Describe in detail every communication in which this understanding was conveyed to " local officials", 1 I

identify the " local officials" involved in each

' communication, and produce every document that reflects or refers to any and/or all of those communications.

164. Please describe in detail the types of documentation, data, and advice that Interveners assert " state and local officials" would use to "make an Ad h22 judgment regarding what protective actions are likely to maximize dose reductions." Please also state all the facts underlying your answer.

165. Please state all the facts underlying Intervanors' assertion.that "those decision makers have no alternative set of ETEs available to them."

166. Do Interveners assert that " state and local officials"

. would continue to reject Applicants' PARS throughout the course of a radiological emergency, or only that those L officials would not agree to "immediate implementation" of the PARS. If the latter, state how much delay would 1

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occur and what its consequences would be. Please also j l state all the facts underlying your answers.

167. Please state all the facts underlying Intervanors' assertion that Massachusetts state and local Civil Defense and Public Health professionals, who allegedly lack their own set of ETEs for a radiological emergency at seabrook Station, would in an actual emergency nonetheless automatically reject Applicants' ETEs and the PARS based upon them. Please also state all the facts underlying Interveners' assertion that state and local officials charged with protecting the health and safety of the public would in an actual emergency automatically reject Applicants' ETEs and the PARS based upon them if advised by Civil Defense and/or Public Health officials to use those ETEs and PARS as the best (or only) ones available.

AS TO JI CorrTENTION 2323 168. Please state all the facts underlying Interveners' assertion that "the possibility exists for delayed and conflicting PARS being formulated, transmitted and recommended to the relevant state governments." Please also quantify that " possibility" and the asserted 23 The following Interveners have indicated that they do not intend to litigate JI Contention 23, and so do D21 need to respond to questions concerning it (unless their intentions have changed): SAPL; TON: CON; TOS.

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delays, describe in detail the consequences of the asserted conflicts, and state all the facts underlying l your answer.

AS TO JI CGnarnu CN 24Il 3

169. Please list, describe in detail, and quantify every delay that Interveners assert would occur in the delegation of " authority . . . to perfort. governmental emergency response functions" in an actual radiological emergency at Seabrook State, and define " governmental emergency response functions." If Intervanors assert that the delay (s) would differ for different types of emergencies,. answer separately for each type. Please also a sAe all the facts underlying your answers.

170. Please state all the facts underlying Intervanors' assertion that these alleged delays "would preclude prompt public notification or a timely public emergency response," and define " prompt", " timely", and "public emergency response."

24 The following Intervanors have inditAted that they do not intend to litigate JI contention 24, and so do A21 need to respond to questions concerning it (unless their intentions have changed): SAPL; TON; CON: TOS.

O AS TO JI Cunir n uON 2g 5 171. Please state all the facts underlying Intervanors' assertion that "only a small handful of ORO personnel appear to be trained and qualified to make protective ,

action recommendations," and define (with quantification) "a small handful." Please also state all the facts underlying Intervanors' assertion that "only one individual is designated as having the responsibility to formulate. . . PLRs."

172. Please state all the facts, estimates, and observations underlying Interveners' assertion that the " arrival (of the RHAs) will be delayed because the RHAs live and work too far from EOC," and define (with quantification)

" delayed" and "too far."

j AS TO JI CONTENTION 2626 173. Please list all of the " appropriate officials and agencies at both the state and local levels" whom Interveners assert should receive " prompt notification" concerning "the need for protective measures for the 25 The following Interveners have indicated that they l do not intend to litigate JI Contention 24, and so do D21 <

I need to respond to questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS.

I 26 The following Interveners have indicated that they do not intend to litigate JI Contention 26, and so do n21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS.

O __ __ - . _

ingestion pathway EPZ," define " prompt", and state all the facts underlying that assertion. Please also list the business telephone numbers of all officials and agencies listed in your answer.

174. Please state all the facts underlying Intervunors' assertion that " adequate public information for the ingestion pathway EPZ has not been prepared," and define

" adequate."

175. Please produce copies of all "public information for the ingestion pathway EPZ" maintained by the Massachusetts Civil Defense Agency for use in the event of radiological emergencies at the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants.

176. Please state all the facts underlying Intervanors' assertion that " sampling procedures in the SPMC are inadequate," and define " inadequate."

177. Please state all the facts underlying Interveners' assertion that " field samples will not be adequately gathered, record or tested," and define " adequately."

178. Please define " timely" and " effective" as used in JI contention 26, Basis D, and describe in detail the regulatory basis (if any) for those definitions.

179. Please describe in detail, and produce all documents that reflect or refer to, the following procedures

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utilized by the Massachusetts Department of Public Health:

a. procedures for ensuring " timely and effective" ingestion pathway PARS for the Pilgrim, Yankee Rowe, and f Vermont Yankee nuclear power plants;

b. procedures for the collection, recording, and analysis of field samples from the ingestion pathway of the Pilgrim, Yankee Rowe, and Vermont Yankee nuc1 car power plants; and

c. food and milk sampling procedures (if any) utilized in response to the Chernobyl accident of April 1986.

180. Please state all the facts underlying Interveners' assertion that "the Sample Collection Teams are not adequately trained," and defir.e " adequately".

181. Please state all the facts underlying Interveners' assertion that " persons should be sought who reside within 20 miles of the plant, are familiar with the local areas and are already experienced in sampling l procedures," and define " familiar" and " experienced."

182. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "the provisions, procedures t-

9-and planning for the 50-mile ingestion pathway emergency planning zone are not adequate," and define ' adequate."

By their attorneys.,

s Th'omaE G. Dignan, Jr.

George M. Imwald Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith Ropes & Gray 225 Franklin &;reet Boston, MA 02110 (617) 423-6100 l

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October 14, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

PUBLIC EERVICE COMPAL OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL.

) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planninq Issues

)

)

APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO ALL INTERVENERS AND PARTICIPATING IDCAL GOVERNMENTS CONCERNING JOINT IN M VENOR CONTENTIONS 6 AND 27-63 Pursuant to 10 C.F.R. El 2.740b and 2.741, Applicants

' hereby request that the Attorney General for the Commonwealth of Massachusetts (" Mass AG"), the New England coalition on Nuclear Pollution ("NECNP"), the Seacoast Anti-Pollution League ("SAPL") , the Town of Amesbury ("TOA") , the Town of Newbury (" TON") , the City of Newburyport (" CON"), the Town of Salisbury ("TOS") , the Town of West Newbury (" TOWN") , the City of Haverhill ("COH"), and the Town of Merrimac (" TOM")

[ hereinafter collectively "Intervanors") respond to the

4 I

I following interrogatories, snd produce for inspection and d copying the documents requested below.

These interrogatories and requests directly address the assertions made by Intervanors-in Joint Intervenor q Contentions 6 and 27-63. Since sev3ral of the Interveners j j have infir.ated that they intend to litigate only certain Contentions, those Intervanors need not respond to questions concerning those Contentions that they have stated they will not litigate (unless their intentions have changed). Egg infra nn. 1-34.

Mass AG and NECNP, however, have stated that they intend to litigate-all contentions, and so should answer all questions. Discussions with counsel for TOA have clarified that ToA presently intends to take discovery as to all Contentions. In light of that tact, TOA should answer all questions. Finally, COH and TOM have refused to state their intentions, and so should answer all questions.

The production of the documents requested herein (or copies thereof) shall take place at the offices cf Ropes &

Gray, 225 Franklin Street, Boston, Massachusetts, at 10 a.m.

on Tuesday, November 15, 1988.

DEFINITIONS AND TMSTRUCTIONS

1. The term " document" is defined to be synonymous in meaning and equal in scope to the usage of the term l

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" documents and tangible things" in Federal Rule of Civil Procedure 34 (a) , and therefore shall include, without I limitation, any written or otherwise recorded l information.

2.

To " identify" a document means to either: I '

(a) state the author, date, title, addressee (s), and subject matter of each individual document; or (b) if a request calls for the identification of more than twenty documents similar in subject matter, And those documents are also being produced, list the subject matter categories of documents, indicating the number of responsive documents in each categot3 3.

To " identify" a person other than an expert witness means to state the person's full name, title, business address, affiliation, and professional qualifications (if any). To " identify" un expert witness means to state, in addition to the foregoing:

} (a) the profession or occupation and field (s) of expertise of the persons (b) the educational and specialized training history of the person, including date and granting institution i i

of all degrees earnedt (c) a list of publications by the person in the area (s) .

of expertise; and

M (d) the age of the person and the amount of-time the person has worked in the field of expertise.

l 4. If any of the interrogatories or document production  ;

requests contained herein are claimed to be objectionable, then please identify the portion (s) to which objection is made and the portion (s) to which  !

answer or production is made.

5. .If it is claimed that any document responsive to any 1

request is privileged, please fully identify each privileged document in accordance with Instruction 2(a) above.

6. If any document required to be identified'or produced in these answers has been destroyed, please identify the document, state the date of its destruction, identify the person responsible'for ordering destruction, state the purpose of destruction, and (if applicable) produce any document retention policy that governed or should have governed the retention or destruction of the document.

7. "SPMC" means the most current update of the Seabrook Plan for Massachusetts communities, and all appendices, amendments, and attachments thereto.

8. The " Massachusetts EPZ" means the Ma'ssachusetts portion of the Emergency Planning Zons for Seabrook Station and j l

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consists of Amesbury, Merrimac, Newbury, Newburyport, Salisbury, and West Newbury.

9. The term " contention" is defined to include the complete text of the contention itself and all bases and sub-bases thereto.

10. Except for Interrogatories 1-3, all the interrogatories and requests which follow are grouped according to the Joint Intervenor Contention to which they refer. In case of doubt as to the intended scopo of an interrogatory or request, it should be assumed that the request or interrogatory encompasses all information and material within the scope of the referenced contention.

1 INTERROGATORIES AND REOUESTS FOR PRODUCTION

1. Please produce all analyses, studies, and reports bearing on any and/or all of the factual issues raised I

in Joint Intervenor contentions 27-63.

2. In each case where one of the following interrogatories asks for "all the facts" or "all the facts, estimates, and observations," please also identify the person (s) and/or documents that are the source (s) of those facts, estimates, and/or observations, and produce all documents that reflect, concern, refer or pertain.to any and/or all of those facts, estimates, and observations.

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3. Please identify the person (s)' answering or substantially

. contributing to the answer.to each of the following .f interrogatories. Please also identify all persons consulted, and identify and produce all. communications and document; consulted and/or relied upon, in answering each interrogatory.

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AS TO JI CONTENTION 6 1

4. Please describe in detail, and produce all documents that reflect or refer to, the responsibilities of the Merrimack River Harbormaster with respect to boaters in distress on.the Merrimack River. Please also describe in detail, and produce all documents that describe or refer to, the resources available to the Harbormaster for use in assisting boaters in distress on the Merrimack River.

5. Please identify all state and municipal agencies and personnel, other than the Marrimack River Harbormaster, having a responsibility to assist boaters in distress on the Merrimack River. Please describe in detail, and produce all documents that describe or refer to, the resources available to those state and municipal 1 The following Intervanors have indicated that they do not intend to litigate JI Contention 6, and so do Det need to respond to these further questions concerning it (unless SAPL; TON; CON; TOWN.

their intentions have changed):

1

It agencies and personnel for use in assisting boaters in distress on the Merrimack River.

AS TO JI CONTENTION 272 6.. Please state all the facts underlying Intervanors' assertion that "the liaisons fail to establish any organizational or communicational link between the ORO and the local organization [ sic) which are relied upon to perform certain emergency activities," and list all of those "certain amargency activities."

7. Please state all the facts underlying Intervanors' assertion that "other EPZ towns will not be able to provide such assistance."

8. Please describe in detail, and produce all documents  !

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• hat reflect or refer to, all mutual aid and all Hazmat Division agreements which exist to suppcrt law enforcement, fire and rescue, and/or snow removal capabilities in Amesbury, Merrimac, Newbury, Newburyport, Salisbury, and West Newbury, including (but not limited to) any agreements under which support is

- available from any other municipal, county, state, and/or federal source.

2 The following Interveners have indicated that they do not intend to litigate JI contention 27, and so do n21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS; TOWN.

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9. Please describe.in detail all the "particular problems of security, public health, timely evacuation and emergency-specific rescue needs" that Interveners assert 1

-differ _from those met by " normal emergency functions,"

and define " normal emergency functions." Please also 1i I

state all the facts underlying your answer.' )

1

10. Please list all of the " emergency responsibilities of I police, fire and rescue agencies during a radiological emergency" that Interveners assert the SPMC "has not adequately identified," and define " adequately." Please also state all the facts underlying your answer.

11. Please identify all " local emergency workers or officials" whom Interveners assert would, in the event of an actual radiological emergency, " desire to participate in an Ad h22 fashion" rather than engage in a planned response. State all the facts underlying your answer.

12. Please describe in detail all of the "particular I

established routines existing in these (Massachusetts EPZ) communities for response to amargencies" that Interveners assert the SPMC " totally ignores", and {

state, for each such routine, whether the routine would be followed in the event of a radiological emergency at Seabrook Station. Ple'ase also state all the facts underlying your answer.

(

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13. Please state all the facts underlying Intervanors' assertion that "none of the supporting organizations will'be informed as to who has control and command over any particular portion of the response," and define

'" supporting organizations."

14. Please describe in detail how, why, and in accordance with what criteria the Commonwealth vvuld withhold authorization as to some but not other "energency response activities" by ORO, as asserted by Interveners in JI Contention 27 Basis F. Please also state all the facts underlying your answer.

15. Please define " effective planning" as used in JI Contention 27 Basis G.

16. Please list all "necessary New Hampshire personnel,"

within the meaning of JI Contention 27 Basis G, and state all the facts underlying your answer.

17. Please state all the facts, other than those discussed )

in response to the preceding interrogatories, underlying Interveners' assertion that "at an organizational level, ,

1 the 'SPMC fails to adequately establish and define the l relationships between the ORO and other organizations which are expected and relied upon to perform energency response activities," define " adequately", and list all "other organizations" which Interveners assert are

" relied upon to perform energency response activities."

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18. Please state all facts, other than those discussed in i

response to the preceding interrogatories, underlying i Interveners' assertion that "the SPMC does not adequately provide for effective coordination of effort between or clearly delineate the primary responsibilities of these other organizations and the ORD," and define " adequately", " effective", " clearly",

and " primary".

AS TO JI CONTENTION 283

19. Please state all the facts underlying Intervanors'  !

assertion that "the personnel not scheduled to be on shift will not have their pagers on."

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20. Please state all the facts underlying Interveners' assertion that there are "no back-up personnel at critical positions of the ORO for Stage 2", and list all such " critical positions."

AS TO JI CONTENTION 29 No questions.

3 The following Intervanors have indicated that they do not intend to litigate JI Contention 28, and so do net need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS; TOWN.

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1 L_____________ _ _ _ _ _ _ _ _ _ iJ

AS TO JI CONTENTION 304

21. Please state all the facts underlying Interveners' assertion that " commercial telephone lines will be and should be assumed to be overloaded shortly after the onset of an accident at Seabrook," and define (with quantification) " shortly".

22. Please state all the facts, other than those discussed ,

1 in response to the preceding interrogatory, underlying Interveners' assertion that "the SPMC relies too heavily on commercial telephone links for critical and ecsential emergency communications."

AS TO JI CONTENTION 315

23. Please describe in detail all the specific purposes for which Interveners assert that ORO " emergency field personnel" need a " lateral network of communications directly linking" them to each other, and identify all i

" emergency field personnel" whom Interveners assert have that need. Please also state all the facts underlying your answer.

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[

4 The following Interveners have indicated that they do

( not intend to litigate JI contention 30, and so do nel need

} .

to' respond to the questions concerning it (unless their L intentions have changed): SAPL; TON: TOS.

5 The following Intervanors have indicated that they do not intend to litigate JI contention 31, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON CON; TOS; TOWN.

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24. 'Please state all the facts underlying Interveners' assertion that "the failure to provide a lateral communications system a vill result in " delay, miscommunication and gaps in the communications ])

network."

AS TO JI CONTENTION 326

25. Were Massachusetts state and/or local government officials contacted by the FCC concerning any NHY-ORO application for use of the State and local government emergency radio frequencies referred to in JI contention 32? If so, please describe in detail, and produce all documents that reflect or refer to, any and/or all such contacts. This description should include, but not be limited to:

(a) the identity and title of all state and local officials contacted; and  ;

r (b) _the statemants made by each state and local official to the FCC in response to the FCC's inquiry.

26. Please describe in detail how the following would 6 The following Interveners have indicated that they do not intend to litigate JI contention 32, and so do n21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON: CON; TOS.

normally communicate emergency information to

)

Massachusetts state and/or local government entities:

(a) Massachusetts businesses and private citizens; (b) 'other Massachusetts state or local government l entities; (c) government entities of other states; (d) businesses and private citizens of other states; (a) the federal. government, and all agencies thereof.

If Interveners assert that the answer varies depending upon the nature of the emergency, then each type of emergency should be described separately. Please also state all the facts underlying your answer. If a communications network is used, produce all documents that describe, reflect, or refer to that network.

27. Please state all the facts, other than those discussed

, in response to the preceding interrogatories, underlying ;

Interveners' assertion that "the ORO has no access to emergency radio frequencies used by State and local agencies." l

28. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "the ORO has . . . no alternative to those means of communication."

n

'AS TO JI CONTENTION 337 I l

29. Please describe in detail.the factual and regulatory basis.(if any) for Interveners' assertion that-

" insufficient provisions exist for verification of the Massachusetts Governor's authorization of ORO to

activate and broadcast over the EBS, and_ define

" insufficient". Please also state all the facts underlying your answer.

30. Please state all the facts underlying Interveners' assertion that "in the event of a radiological incident, NHY has an interest'in minimizing the public perception that the plant is a source of danger."-

31. Please describe in detail all instances in which any Massachusetts EBS station was activated by a non-governmental entity. This description'should include, but not be limited to:

1 (a) the date of each instance; (b) the identity, business address, and business telephone number of each EBS station activated in each instance; (c) the identity of the non-governmental entity that requested EBS activation in each instance; 7 The following Intervanors have indicated that they do not intend to litigate JI Contention 33, and so do DEL need to respond to the questions concerning it (unless their intentions have changed); SAPL; TON; CON; TOS; TOWN.

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(d) a detailed dest:ription of all procedures (if any) used to " verify authoriz* tion", for each station in-each instance; and (e). the reason (s) for activation in each instance.

Please also produce all documents that reflect or refer r

! to any and/or all such instances.

32. Please state all the facts, other than those discussed 1 i

in the response to the preceding interrogatories, and 1 1

describe in detail the regulatory basis (if any),

underlying' Interveners' assertion that " federal EBS regulations . . . makes (sic] no provision for third  ;

party activation as envisioned by the drafters of the SPMC."

AS TO JI CONTENTION 34 8 i

33. Please state all the facts underlying Interveners' assertion that "the procedures to be followed by the NHY Offsite Response EOC Contact Point in the event of an accident" are "far too complicated and time-consuming to be performed effectively by one individual," and define

" effectively".

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34. Please state all the facts underlying Intervanors' assertion that " experience as a security guard . . . is l

8 The following Interveners have indicated that they do .

not intend to litigate JI. Contention 34, and so do n21 need to respond to the questions concerning it (unless their ,

intentions have changed): SAPL; CON: TOS; TOWN. f i

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l totally inappropriate" for the "NHY Offsite Response EOC Contact Point." Please describe in detail what .]

" experience" and/or other " prerequisite" Interveners assert would be necessary for that post, and state all the facts underlying that assertion.

35. Please state all the facts underlying Intervanors' assertion that " key ORO personnel . . . have no car phones or other means of communication during their mobilization period." Please also list all such " key ORO personnel", explain in detail why Interveners assert that each one is " key", and state all the facts underlying your answer.

36. Please state all the facts underlying Intervanors' assertion that the "SPMC provides no adeguste means of alerting, notifying and mobilizing key emergency personnel," and define " adequate". Please also list all such " key emergency personnel," explain in detail why 2

Interveners assert that they are " key", and state all- l the facts underlying your answer.

37. Please identify all of the " private organizations and contractors expected-to play emergency roles" whom i

Intervanors assert "are not themselves notified unless and until those ORO personnel responsible for such notification are first alerted and mobilized and arrive at the EOC." For each of these " private organizations l

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1 and contractors", identify the "ORO personnel" whom l Intervanors assert are " responsible for such l l

notification." Planse also state all the facts f I

underlying your answers. ]

38. Please state all the facts underlying Interveners' f l

assertion that the "SPMC provides no assurance that state and local government employees and those providing contract service to the State and local 1 governments . . . will be adequately notified cf an accident at Seabrook," and define " adequately." i

39. Please state whether the Massachusetts Comprehensive Emergency Response Plan includes the six communities of the Massachusetts EPZ. If not, explain in detail why not. If so, describe in detail how " local government employees e.nd those providing contract service to the State and local governments" are notified of an emergency pursuant to that Plan. Please also state all the facts underlying your answers.

40. Please describe in detail the procedures utilized by the Massachusetts State Police to notify the six communities Such !

in the Massachusetts EPZ in emergency situations.

description should include, but not be limited to:

(a) all radio frequencies employed or available to be employed by the State Police for such notification; and

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(b) 'the telephone numbers of local police, fire, and emergency management organizations that would be l contacted.

Please state all the facts underlying your answers, and produce the FCC licenses of all radio frequencies listed. 1

41. Please list tho'name, title, and business telephone number of all Commonwealth officials who would be contacted in the event of radiological emergencies at the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants. For each such official, describe in detail by whom, how, when, and under what circumstances she/he would be contacted. Please also state all the facts underlying your answers.

42. Please state'all the facts, other than those discussed 4 in response to the preceding interrogatories, underlying q Interveners' assertion that "the notification and mobilization of response organizations and personnel is i not adequate," and define " adequate."

l AS TO JI CONTENTION 359 )

1 9 The following Interveners have indicated that they do not intend to litigate JI' Contention 35, and so do D21 need to respond to the questions concerning it (unless their )

intentions have changed): SAPL; TON; CON; TOS; TOWN.

43. Please identify every EBS message " prepared by the ORO" which Interveners assert is " overly long", state for i

sach message all the facts underlying the assertion that i it.is " overly long", and define " overly."

44. Please identify every EBS message " prepared by the ORO" which Intervanors assert is " misleading", and for each such message state all the facts underlying the assertion that it is " misleading."

45. Please identify every EBS message " prepared by the ORO" which Interveners assert is " confusing," and for each such message state all the facts underlying the assertion that it is " confusing".

46. Please identify every EBS message " prepared by the ORO" which interveners assert is "self-contradictory", and for each such cessage state all the facts underlying the assertion that it is "self-contradictory."

-47. Please identify every EBS message " prepared by the ORO" which intervanors assert is " impossible to either broadcast or receive in the time available," state for each such message all the facts underlying the assertion that it is " impossible to either broadcast or receive in the time available," and define (with quantification)

"the time available."

48. Please identify every EBS message " prepared by the ORO" which Interveners assert " ignore [s] important 1

W- ~- - _ _ _ - - ~ _ . _ _

characteristics of the recipient public in Massachusetts and its response to a radiological emergency at Seabrook." For each such message, describe in detail the "important characteristics of the recipient public in Massachusetts and its responsa to a radiological emergency at Seabrook" that Interveners assert the message ignores. Describe in detail the role that state and/or local officials have played in fostering those alleged "important characteristics." Egg Memorandum and Order (Ruline on Contentions on the Seabrook Plan For Massachusetts communities) at 107 (July 22, 1988) (role of Cor.monwealth officials in fostering "an anticipatory disaster subculture"). Please also state all the facts underlying your answers.

49. Please state all the facts underlying Intervanors' assertion that the "SPMC makes no provision and provides no procedure for coordinating emergency messages with participating . .

. state and local governments."

l Please answer separately for each " participating . . .

state and local" government.

50. Please identify all " state and local governments" whom Interveners assert fall in the category of "non-participating." Explain in detail exactly why and how Intervanors assert that Applicants are supposed to "coordinat[e] emergency messages" with each such t

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your answer.

51. Please state all the facts underlying Interveners' assertion that the " messages do not adequately address the issue of their source," and define " adequately."

Please also explain in detail what Intervanors assert "the issue of their source" is, and state all the facts underlying your answer.

52. Please describe in detail, and produce all documents that reflect or refer to (including but not limited to all FEMA, RAC, and/or internal reviews and/or critiques), all EBS messages relied upon by the commonwealth of Massachusetts for use in a radiological emergency at the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants.

53. Please state all the facts underlying Interveners' assertion that the *SPMC provides no adequate procedures for insuring that the emergency messages broadcast to the public correlate with the messages and information provided to the media by the NNY ORO and other officials," and define " adequate", " insuring", and Please also list all "other officials"

~

" correlate".

within the meaning of JI Contention 35 Basis D, and describe in detail what " messages and information" each such official would " provide to the media."

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54. Please describe in detail, and produce all documents that reflect or refer to (including, but not limited to all FEMA, RAC, and/or internal reviews and/or critiques), all procedures for public information coordination to be used in connection with a radiological emergency at the Pilgrim, Vermont Yankee, and Yankee Rowe nuclear power plants.

SS. Please state all the facts underlying Interveners' assertion that "no guidance or training is provided this individual on the essential components of an effective emergency message." Please state what Interveners assert are all of the " essential components of an effective emergency message", define " effective", and state all the facts underlying your answer.

56. Please describe in detail, and produce all documents l

that reflect or refer to, the " guidance or training . . . provided . . . on the essential components of an effective emergency message" relied upon by the Commonwealth of Massachusetts for the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants.

57. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying

• Interveners' assertion that the "energency messages to i be utilized by the ORO in the event of an emergency at I

r. . .

I Seabrook are inadequate and will not be effective in communicating necessary information to the public," and define " inadequate", " effective", and "necessary".-

L KS TO JI CONTENTION 3610 l 58. Please state all the facts underlying Intervanors' assertion that "no adequate procedures for coordinating the activities of the public information staff at the EOC and the personnel at the Media Center are provided,"

and define " adequate".

59. Please state all the facts underlying Intervanors' assertion that " adequate procedures also do not exist for the coordination of the activities of Media relations representatives who will be communicating directly with the press by telephone," define

" adequate", and identify all such " Media relations representatives."

60. Please describe in detail, and produce all documents that reflect or refer to, the " procedures for coordination with the news media" relied upon by the Commonwealth of Massachusetts in the event of 10 The following Interveners have indicated that they do not intend to litigate JI Contention 36, and so do nel need to respond to questions concerning it (unless their intentions have changed): SAPL; TON; CON: TOS; TOWN.

---

_------_---g 1

-l radiological emergencies at the Pilgrim, Yankee Rowe, f and Vermont Yankee nuclear. power plants.  !

61. Please state all the facts, other than those discussed in response to the preceding interrogatories, u1derlying

. Interveners' assertion that the "SPMC does not provide adequate procedures for coordination with the news media," and define " adequate."

AS TO JI CONTENTION 3711

62. Please state all the facts underlying Interveners' assertion that " officials from the Commonwealth will not

'be permitted" at the EOF and EOJ.

63. Please state all the facts, other than those discussed in response to the preceding interrogatory, underlying Interveners' assertion that the "SPMC fails to provide adequate information and access to information at the time of an emergency to those State and local governments c.tich are not participating in emergency planning," and define " adequate".

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12. The following Intervanors have indicated that they  ;

do not intend to litigate JI Contention 37, and so de D21 l need to respond to the questions concerning it (unless thetir intentions have changed): SAPL; TON: CON: TOS; TOWN.

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' As 'r0 JI CGwmuGN 38 12

64. Please state all the facts underlying Interveners' assertion that "no provision is made for the

~

coordination of rumor control efforts.by these sources,"

and identify every one of "these sources" with which-Interveners assert "no provision _is made." Please also de' fine " coordination." .

65. Please state all the facts underlying Interveners' 4

assertion that "without a centralized source of information, no rumor control will be' effective," and define " effective."

166. Please state all the facts underlying Interveners' assertion.that the."0RO itself will be unable to provide coordinated rumor control," and define " coordinated."

Please also define "davalop a strategy" as used in MAG 1

h contention 23 Basis B.

t

67. Please stats all the facts, estimates, and observations underlying Intervanors' assertion that media briefings L "should involve full use of experts and visual and graphic aids to convey technical information in an understandable manner," and define "should" and " full."

12 The following Interveners have indicated that they f do not intend to litigate JI Contention 38, and so do.DSA L

J need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS; TOWN.

l

68. Please state all the facts underlying Intervanors' assertion that the "SPMC assigns public information personnel responsibilities without any guidance as to the manner in which those responsibilities are to be carried out," and define " guidance."

69. Please state all the facts, estimates, and observations underlying Interveners' assertion that "information can not [ sic) be effectively communicated to the public unless public information staff are [ sic) fully informed of developments and have access to technical experts capable of addressing areas of uncertainty," and define

" effectively" and " access."

70. Please state all the facts, estimates, and observations underlying Interveners' assertion that "any plan which does not recognize the public's extraordinary appetite for information, and does not specifically assign a role in information preparation and dissemination to I

technicians and experts in [ sic) inadequate," and define

" recognize", "specifically assign," " technicians",

"expeits", and " inadequate."

71. Please describe in detail, and produce all documents that reflect or refer to, the " procedures for rumor control during an emergency" relied upon by the Commonwealth of Massachusetts for the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants.

p

' 1 I

m; -

zemt ,

3 i

li~

- 7 2. - Please state all the facts, other than those discussed in response-to the preceding interrogatories, underlying Interveners' assertion that the "SPMC provides inadequate procedures for rumor control during an emergency," and define ~" inadequate."

AS TO JI CGn11.niiON 39 13 73.- 'Please state how many " thousands of transients who

-frequent the Massachusetts portions of the Seabrook EPZ" Interveners. assert will not have "available to them either prior to or at the time of an emergency any information concerning the methods and times required

^ for notification, the protective actions planned, the nature and effects of radiation or a list of sources of additional informatica," and define "available." Please

' also state all the facts, estimates, and observations underlying your answer.

74. Please state all the facts, other than those discussed in response to the' preceding interrogatory, underlying Intervencra' assertion that " plans and procedures for disseminating pre-emergency information is (sic) inadequate," and define " inadequate".

13 The following Interveners have-indicated that they do not intend to litigate JI contention 39, and so do DR1 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON: CON; TOS; TOWN.

N ---_1- - -___-______m_______ _ , , _ _ _ _ _ , _ . ,

p. ,

~

l .

I

75. Please state all the facts underlying Intervanors' assertion th*4t " inadequate provisions'have been made to insure that the special needs population receive necessary pre-emergency information," and define

" inadequate," "special needs population", and "necessary". The definition of "special needs population" should include, but not be limited to, a list of all groups whom Interveners assert are part of the "special needs population."

76. Please describe in detail, and produce all documents that reflect or refer to (including but not limited to all FEMA, RAC, and/or internal reviews and/or critiques), the " pre-emergency information" relied upon by the Commonwealth for the Pilgrim, Yankee Rowe, and vermont Yankee nuclear power plants, including (but not limited to) the pre-emergency information" disseminated to the "special needs population" in the EPZ of each of those plants.  !

77. Please state all the facts underlying Interveners' assertion that "the discussion of the health risks of .

I radiation is inadequate and will confuse the reader as to the need for and proper circumstances of emergency response," and define " inadequate" and " confuse".

78. Please state all the facts underlying Intervanors' assertion that "the information is not adequately i

)

L presented to the reader as important emergency information that should be retained," and define

" adequately."

79.. Please state whether Intervanors assert that Applicants should include in the " pre-emergency information" a discussion of the fact that "the Stata and local governments" have refused to protect the health and safety of the public through emergency planning, and that Applicants have had to fill the void left by that abdication of responsibility by "the State and local l governments." If not, please describe in detail what sort of discussion of-"the lack of participation in emergency planning by the State and local governments" Interveners assert that Applicants should include.

State all the facts, and describe in detail the regulatory basis (if any) underlying your answers.

80. Please state all the facts underlying Intervanors' assertion that "no adequate discussion is presented concerning the ORO and the nature of the SPMC as a utility plan, and the relationship (s) during an emergency between the ORO and State and local governments," and define " adequate". Please also describe in detail what Interveners assert to be "the relationship (s) during an emergency between the ORO and State and local governments" which Intervanors assert l

I e

4 that Applicants should describe, and state all the facts underlying your answer.

81. ' Please state 'all the facts underlying Intervanors' assertion that " inadequate information is provided to parents regarding procedures to be employed in the event of an evacuation of school children," and define

" inadequate".

82. Please state all the facts underlying Interveners' assertion that " inadequate information is provided with respect to 'How To Take Shelter'," and define

" inadequate",

' 83. Please identify all'"information . . . provided with respect to respiratory protection" that Interveners assert is " inadequate" and/or " inappropriate",-and' define " inadequate" and " inappropriate". Please also state all the facts underlying your answer.

84. Please state all the facts, estimates, and observations' underlying Intervanors' assertion that "most pet owners would be unwilling to leave their pets at home in the event of a radiological emergency and therefore might be discouraged from reporting to reception centers," and define "might" and " discouraged".

[

l

85. Please state all the facts,'other than those discussed in response to the preceding ir.terrogatory, underlying Interveners' assertion that " inappropriate information 1

l

= - - - _ _ _ - - - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _

K I , 1 [ l is provided with respect to pets," and define L

                                                " inappropriate".

i

86. Please state all the facts, other than those discussed i

                                                                                                                                         )

in response to the preceding interrogatories, underlying I:stervenors' assertion that the " content of the pre-emergency information made available to the public'is o not adequate," and define " adequate".

87. Please describe in detail, and' quantify, the "many special needs persons" whom Intervanors assert that "the types of-[public education) materials to be utilized will not be effective in reaching", define " effective",

and state all the facts, estimates, and observations underlying your answer. For each type of " materials" and each group of "special needs persons", state all the facts underlying Intervernors' assertion that that type-of material "will not be effective in reaching" that group of people.

88. Please state all the facts underlying Intervanors' assertion that "the public information materials which have been provided contain too little rnd inadequate information to establish adequate preparedness for those who have disabilities," and define "too little",

inadequate", and " adequate". Please also list all

                                                 " disabilities" concerning which Interver ors make this assertion.
                                                                            -?
- - _ _ _ _ _ - _ - _ _ - _ _ _ _ _ _ _ _ _   _   . _ _ _                                                                               l

39. Please describe in detail in what ways (if any)

                               . Interveners assert that pre-emergency " preparedness for those who have disabilities" for a radiological emergency would differ from " preparedness" for other types of emergencies such as fires, hurricanes, chemical spills, and blizzards, and state all the facts underlying your answer.

90. Please state all the facts underlying Interveners' assertion that "the materials have not been designed using channels or methodologies which are appropriate to specific handicap-type (sic)," and define "appropr' ate".

For each " specific handicap" type, describe in detail what " channels or methodologies" Interveners assert

                                'would be appropriate, and state all the facts underlying those assertions.

91. Please state all the facts underlying Intervanors' assertion that "to adequately prepare for addressing the needs of those who have special needs during an emergency, specific information about the needs of those individuals must be targeted to the general public and emergency workers," and define " adequately".

92. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "the information to be nada available to the public pursuant to the SPMC prior to an

                                                            = _ _ _ - - _ _ - - _ _ _ _ _ _

9 9 emergency does not meet the regulatory standards as set forth at 50. 47 (b) (7) , NUREG- 0654 II.G. and 10 CFR Part 50, Appendix E, IV. D.2." AS TO CGn11.n uGN JI 4014 !' 93. Please describe in detail, and produce every document that reflects or refers'to (including but not limited to ! all TEMA, RAC, and/or internal reviews and/or critiques) the procedures and methods relied upon by the Commonwealth of Massachusetts to identify and notify

                                                             " residents who have special notification needs" in the plume EPZ for the Pilgrim, Yankee Rowe, and. Vermont' Yankee' nuclear power plants.

94.- Please state all the facts underlying Intervanors'

                                                           ' assertion that "the list of hearing-impaired individuals in Appendix M'does not contain the names of many hearing-impaired residents," define " hearing-impaired",

define (with quantification) "many", and list the names and addresses of all " hearing-impaired residents" known to. Interveners who are not listed in Appendix M.

95. Please state all the facts underlying Interveners' assertion that "the procedures themselves cannot result 14 The following Intervanors have indicated that they.

do not intend to litigate JI contention 40, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON: TOS; TOWN.

9 i

                                           .in a. timely dispatch of the Route Guides," and define
                                            " timely".

96. Please state all the facts underlying Intervanors' assertion that the Route Guidea will be " unfamiliar []

with the area." 97.- Please state all the facts underlying Intervanors' assertion that "many hearing-impaired individuals will simply not hear their banging or shouts at the door, or an apartment ' buzzer'," and define (with quantification)

                                            "many". Please also state all the facts underlying Inte rvenors ' implied assertion that the only means available to the Route Guides to alert those hearing-impaired individuals would be banging, shouting, or buzzing.

98. Please state all the facts underlying Interveners' assertion that "many hearing-impaired individuals will not let the Route Guides in," and define (with quantification) "many".

99. Please state all the facts underlying Intervanors' assertion that "none of [the pre-scripted written messages) are adequate for the situation," and define

                                              " adequate" and " situation".

100. Please state all the facts underlying Intervanors' assertion that "the Route Guide's procedures . . . are u_______ _ _ _ _ _ _ . _ _ _ _ _ _

inadequate, ambiguous, and confusing," and define

                                                                               " inadequate", " ambiguous", and " confusing".

101. Please state all the facts underlying Intervanors' assertion that "special equipment should be provided to each household in the Massachusetts EPZ with a deaf or nearly deaf member." Describe this "special equipment" in detail, and list the name(s) and business address (es) of the manufacturer (s) of it. Does the Commonwealth of Massachusetts ensure that such "special equipment" is "provided to each household . . . with a deaf or nearly deaf member" in the Massachusetts plume EPZs of the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants? If not, explain in detail why not, and state all the facts underlying your answer. 102. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Intervanors' assertion that the "SPMC does not contain an appropriate or timely alert and notification system for residents who have special notification needs," and state all the facts underlying your answer. AS TO JI CGiur.nriOWS 41-43 No questions. _m _____..-__ _____.-_ ._._m-m,- . _ _ _ . _ _ __

L 4 AS TO JI CONTENTIONS 44A AND 44B15 103. Please list all emer(ency response actions, other than l those listed in Basis A.2 and footnote 25 of JI Contention 44A, which Interveners assert that NNY-ORO-could not legally implement without prior government authorization. For each response action listed in your answer, and for each response action listed in Basis A.2  ! and footnote 25, state what government official (s) or entity (ies) could grant such authorization to:

                                           '(a)                      NHY-ORO:

(b) a foreign corporation; (c) private individuals not residents of H Massachusetts; (d) private individuals who are residents of Massachusetts; (e) a Massachusetts corporation; (f) a Massachusetts regulated utility. j Please state all the facts underlying your answers. 104. Please state all the facts underlying Intervanors' assertion that "to the extent New Hampshire Yankee is functioning only as a ' managing agent' for the Seabrook 1 15 The following Interveners have indicated that they do not intend to litigate JI Contentions 44A and 448, and so do D21 need to respond to the questions concerning it (unless l their intentions have changed): SAPL; TON; CON; TOS; TOWN.

, . ,. 3, .

o > ,  ; j

 ,1 Owners'then its pledge of'its own resources is suspect,"

F and define " suspect". 105.:Please describe in detail, and produce all documents  ; that reflect or refer to, every delegation of amargency r response authority to private individuals or. entities 1 that has occurred within the last fifty years pursuant p to any and/or all of the following Massachusetts statutes (and/or=their predecessor statutes): ll (a) Special Laws ch. 31, 54; (b)' General Laws ch. 48, 510;-

                                                          "       "   ch. 48, 544A; (c)
                                                           "      "   ch. 90s, 525; (d)

!- "' -" ch. 22, 56; (e)-

                                                            "-    "   ch. 85, 55; and (f)
                                                 '(g)        "    "   ch. 31, 548.

AS TO JI CGn u.= IION 45 16 106. Please identify all " schools" in the Massachusetts EPZ which Interveners assert do not have " adequate school-specific plans" for a radiological emergency, and state all-the facts underlying your answer. 16 The following Interveners have indicated that they do not intend to litigate JI Contention 45, and so do D21 need to respond to the questions concerning it unless their intentions have changed): SAPL; TON: CON; TOS.

f 107. Please state all the facts underlying Intervanors' assertion that " existing emergency plans . . . are. wholly inadequate for responding to a radiological emergency," and define " inadequate." 108. For each " school" referred to in response to the preceding two interrogatories, please identify the

                     " school" employee (s) and government official (s)         :

responsible for preparing plans to protect the health and safety of the " school" children in the event of a radiological emergency, and explain in detail why those individuals have not prepared " adequate school-specific plans." State all the facts underlying your answer. 109. Please state all the facts underlying Interveners' assertion that "the schools have rao knowledge of" the

                      " Generic Massachusetts Public School Plan". Identify the " school" principals and school district superintendents,'in the Massachusetts EPZ, whom Interveners assert have "no knowledge of" that Plan, and explain in detail why those officials lack that knowledge. State all the facts underlying your answer.

110. Please identify all " school" officials whom Interveners assert "would not keep or use" the " Generic Massachusetts Public School Plan" if it were " offered by NHY", and state all the facts underlying that assertion. For each such official, state whether or not they would I

l i:

                               " keep or.use" a " school-specific plan" if it were
                               " offered by.NHY", and state all facts underlying your answer.

111. Please state all the facts underlying Intervanors' assertion that a " generic plan" could "[n]ever be adequate for the vide range of different types of schools," and define " adequate". 112. Does every " school" in the Massachusetts portions of the plume EPZs for the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants have a " school-specific plan" for radiological emergencies? If so, please prodece all such plans. If not, please explain in I 3 detail why not, state all the facts underlying your answer, and produce copies of all " generic" or " school-specific" plans that do exist. 113. Please define " serious and fast-developing . . . radiological emergency" as that term is used in Mass AG , Contention 47 Basis A. 114. Does any agency of the commonwealth of Massachusetts require, possess, and/or engage in " school-specific" planning for any type of esargency? If so, please produce all such plans for " schools" within the Massachusetts EPZ. If not, explain in detail why not, and state in detail all the facts underlying your answer. If the Commonwealth uses " generic" plans, 1

l l explain in detail how such plans account for "the wide range of different types of schools, which have vastly different student populations, student age groupings, student / teacher ratios, class sizes, layouts and construction (for sheltering), organizational capabilities, composition of special needs children, different methods of notifying parents, etc." state all the facts underlying your answer. 115. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that " absent the existence of institution-specific radiological emergency response plans to address the different preparedness needs of each school, there is no reasonable assurance that adequate protective measures can and will be provided to school children." 116. Please state all the facts underlying Interveners' assertion that the " implementing procedures for the School Coordinator and School Liaisons are poorly drafted, vague, end confusing," and define "poorly drafted", "vcgue", and " confusing." 117. Please state all the facts underlying Intervanors' assertion that "the procedures for the Coordinator and School Liaisons" are not "sufficiently integrated with-each other to ensure that confusion and mistakes will L i I;

1

           '6.

I i not occur," and define " integrated", " ensure",

                                                                                                          }
                      " confusion", and " mistakes."

118.'Please state all the facts underlying Intervanors' assertion that "the remaining (bus) companies do not have sufficient drivers and buses to transport all ,

                     . school children out of the EPZ in a timely fashion,"'and define " timely".

119. Please state all the facts, estimates, and-observations underlying Interveners'. assertion that "there are more students than-have been estimated, especia11y'in day cure'and nurseries, but also in the schools." 120. Please state all the facts underlying Interveners' assertion that "during an emergency additional adult supervision will be needed on each bus." 121.LPlease state all the facts, estimates, and observations underlying Interveners' assertion that "the average capacity of the buses has been overestimated." 122. Please state all the facts, estimates, and observations, other than those discussed in response to the preceding interrogatories, underlying Intervonors' assertion that l the "SPMC underestinstes the number of school buses that i will be needed." 123. Please list the names and business telephone numbers of all " school superintendents" in the Massachusetts EPZ l l l I i __ __ - - o

      ~-
         ~;                                                                           q whose " phone numbers" Interveners assert "are not even listed in Appendix M."

124. Please state all the~ facts underlying Intervanors' assertion that "the phone conversations with each superintendent could be quite lengthy," and define (with. quantification) "could" and "quite lengthy". 125. Please state all-the facts underlying Interveners' assertion that "each superintendent ... . will have had no prior emergency response training and will not know a great deal," and define "a great deal." 126. Please state all the facts, other than those discussed in response to the preceding three interrogatories, I underlying Intervanors' assertion that "the last Superintendent may not be notified for a number of hours after.an Alert is declared," and define (with quantification) "may" and'"a number of". 127. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners'. assertion that the "sPMC~ procedures for notification to the school (sic) Coordinator and the confusing implementing procedures for the school coordinator (sic) in both Pro 1.9 and 2.7, prohibit a timely offer of information and transport resources to a school superintendents (sic) for all public schools," and define " confusing" and " timely". 1 I u_-__-__ ___ _ ____ _-

t 128. Please state all the facts underlying Interveners' assertion that "the last (private) school will not be notified for many hours after an alert has been declared," and define (with quantification) "many". 129. Please state all the facts underlying Interveners' assertion'that "the EBS messages will become extremely long and drawn out", and define (with quantification) l

                                                                              " extremely long."

130. Please state all the facts underlying Interveners' assertion that, "for those facilities which have no sheltering plan, the message simply affords inadequate guidance on how to implement a timely,. safe and affective sheltering response," and define " inadequate",

                                                                              " guidance", " timely", " safe", and " effective".

131. Please identify all " schools" in the Massachusetts EPZ which Interveners assert "have no sheltering plan", explain in detail why they lack such plans, and state all the facts underlying your answers. l' 132. Please state all the facts, other than those discussed l in response to the preceding interrogatories, underlying l Interveners' assertion that "the SPMC's provisions offer no reasonable assurance that sheltering can or will be implemented appropriately or in a timely fashion in the schools," and define " appropriately" and "in a timely fashion."

133. Please identify all schools in.the Massachusetts EPZ that Interveners assert "would be totally inappropriate

                                                                    -for sheltering scho71 children."    For each such school, state all the facts underlying Interveners' assertion
                                                                     'that it "would be totally inappropriate for sheltering-school children," and define " totally inappropriate."

134. Please identify all schools in the Massachusetts EPZ that Intervanors assert have " climate control systems that are totally reliant on outside air." L 135. Please state all the facts underlying Interveners' assertion that "most schools will not be able to respond I with any reasonable degree of certainty if they try to guess how many of their regular contracted buses will show up." 136. Please state all the facts underlying Intervanors' assertion that "the School Liaisons will'not be able to state how quickly the SPMC/ORO buses will arrive at given schools."

                                                               -137. Please describe in detail the "Ad h2g transportation scheme [s)" that Interveners assert " prudent school officials . . ._.will seek to implement," and state all the facts underlying your answers.

138. Please state whether " institution-by-institution evacuation time estimates" exist for the " schools" in Massachusetts portiens of the plume EPZs of the Pilgrim, I

                                                                                                                                                                                                                               'I

7 l l i i Yankee Rowe, and Vermont Yankee nuclear power plants. I If so, please produce all documents that reflect or i' refer to any and/or all of those ETEs, and all documents that reflect or refer to the procedures used to. 1 calculate them. If not, explain in detail why not. 139. Please provide the following information for all

                             " schools" in the Massachusetts EPZ:

(a) the " school" name, address, and telephone number, unless such information is already contained in the SPMC; (b) the number of staff and of students, unless such

                                  -information is correctly stated in the SPMC;
                            .(c)   the source and number of " regular contracted" or school-owned buses, and the capacity of each bus; (d)   copies of all documents that reflect or refer to procedures for early dismissal, snow days, and school cancellation; (e)   which." schools" are on split sessions, what the hours of those sessions are, and how many students are in each session; (f)   how many students, at each " school", walk or drive
  .                                                                                                          I to school; (g)   how many mentally or physically handicapped students attend each " school", and how they get there each day;

7 i E (h) the average percentage of: absenteeism per day for each " school";

                                                     -(i) the number of buses that can be simultaneously boarded by students at'each'" school"; and
                                                       ~( j)  how much adult supervision-is provided on each
                                                               " school" bus during daily transportation and day i

trips, for each " school". 140. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners ' assertion that the "5PMC fails to offer reasonable assurance that. adequate protective measures can and will be taken in a timely fashion for. schools and day care centers," and define " adequate" and

                                                         " timely".                                                l l
                                                                                                                 .i AS TO JI COiur4 TION 46 17 14'1. Please state all the facts underlying Interveners' assertion that "in the event of an evacuation, accommodations would be required for approximately 148 patients."

17 .The following Interveners have indicated that they J do not intend to litigate JI contention 46, and so do not need tc respond to the questions concerning it (unless their intentions have changed): TON: CON; TOS; TOWN. , 1

 ^'E        _ - - _ -   . _ _ _ _ _ _ _ _ _ .

E, .

                                                                                                                                        )
  ~

142. Please state all the facts underlying each of the following assertions by Intervanors:

                                                                             " Hospital A .       . would be able to provide only (a)                    .

five beds at best"; (b). " Hospital B has no intention of treating radiologically contaminated individuals"; (c) " Hospital C would only be able to accommodate approximately ten very severely injured patients," and define "very severely injured"; i (d) " Hospital E has . . . 20 (beds) usually available" and "does not have the facilities to handle radiologically contaminated individuals"; (e) " Hospital F (has) a capacity for 108 beds of which 90 are usually filled"; (f) " Hospital G could accommodate approximately forty patients in the event of an emergency"; (g) " Hospital H . . . might have approximately ten beds available in the event of an emergency"; and (h) " Hospital I. . . could provide approximately thirty beds." 143. Please state all the facts, estimates, and observations, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "in the event of an evacuation, the two hospitals located within the EPZ have more patients than can be 1

accommodated by the hospitals with which NHY has reached agreements." 144. Please state all the facts, estimates, and observations underlying Interveners' assertion that the SPMC " fails to ensure that adequate accommodations will be available for the radiologically injured in the event of an emergency," and define " ensure" and " adequate". Please also describe in detail, and produce all documents that reflect or refer to, the qualifications required for Massachusetts host hospitals that are to receive, monitor, and decontaminate patients transferred from hospitals within the plume EPZs of the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants. 145. Please state all the facts underlying Interveners' assertion that evacuation of the Amesbury and Anna Jaques Hospitals would take "sany hours", and define (with quantifi' cation) "many". 146. Do the Amesbury and Anna Jaques Hospitals possess evacuation plans for any type (s) of energency? If so, produce copies of all such plans. If not, explain in detail why not. 147. Please state all the facts underlying Intervanors' assertion that the "SPMC has arrangements for an inadequate number of ambulances to evacuate all those who may reasonably need such transportation." Please also state how many people Intervanors assert "may reasonably need such transportation" and what would be an adequate " number of ambulances," and state all the facts, estimates, and observations underlying your answers. 148. Do Intervanors assert that the Amesbury and Anna Jaques hospitals are not " suitable as shelter in a radiological I emergency"? If so, please explain in detail why they assertedly are not " suitable", and state all the facts , i underlying your answer. 149. Please state all the facts underlying Interveners' assertion that "the sheltering instructions provided to hospitals by ORO are wholly inadequate to provide reasonable assurance that adequate sheltering measures can and will be taken by hospitals," and define

                                              " adequate". Please also produce copies of the
                                              " sheltering instructions" provided to hospitals in the Massachusetts portions of the plume EPZs of the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants.

150. Please state all the facts underlying Intervanors' assertion that "the Generic EPZ Hospital Plan mentioned in Appendix G is too vague to be of any real benefit to the hospitals." 151. Please state all the facts underlying Intervanors' assertion that "only site-specific EPZ hospital plans

l

                                                                                                                  )

I can provide reasonable assurance of adequate j l preparedness, and then only when backed up with a staff l l trained in appropriate emergency response actions." 152. Please state whether the Commonwealth of Massachusetts relies upon " site-specific EPZ hospital plans . . . backed up with a staff trained in appropriate emergency response actions" for all hospitals within the Massachusetts portions of the plume EPZs of the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants. If so, please produce all documents that reflect or refer to such plans. If not, explain in detail why not. 153. Please state all the facts underlying Interveners' assertion that."the SPMC provisions are inadequate with respect to the provision of KI to persons in hospitals whose immediate evacuation may be infeasible or very difficult." Please also produce copies of all procedures for "the provision of KI to persons in hospitals whose immediate evacuation may be infeasible or very difficult" relied upon by the Commonwealth of Massachusetts for the plume EPZs of the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants. 154. Please state all the facts, estimates, and observations, other than those discussed in response to the preceding interrogatories, underlying Intervanors' assertion that "the SPHC fails to provide reasonable assurance that

o adequate protective measures can and will be implemented for all those persons who are patients in the two hospitals within the Massachusetts EPZ and for those who become injured during the emergency, from radiation contamination / exposure." 18 AS TO JT GGiu14 TION 47 155. Please state all the facts underlying Intervanors' assertion that "there is no reasonable assurance in the event of an emergency in whcih (sic) the general f population is advised to evacuate that there will be sufficient medical and other support staff available to L care for the patients who are unable to evacuate," and define " sufficient". 156. Please state all the facts underlying Interveners' assertion that the SPMC procedure for KI distribution to hospitals "does not provide reasonable assurance that KI can and will be distributed and administered to patients prior to plume arrival." 157. Does the Commonwealth of Massachusetts rely on 1 stockpiles of KI at the hospitals within the Massachusetts portions of the plume EPZs of the Pilgrim, 18 The following Interveners have indicated that they do not intend to litigate JI Contention 47, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON: CON; TOS; TOWN.

O Yankee Rowe, and Vermont Yankee nuclear power plants in c~ der _to " provide reasonable assurance that KI can and

v 21 be distributed and administered to patients prior i

to ruume .*rrival"? If so, please produce all documents

                               .that reflect or refer to such stockpiling procedures.

If not, explain in detail why not, and produce all documents that reflect or refer to the Commonwealth's policies on the distribution of KI. j 158. Please state all the facts, other than those discussed l in response to the preceding ihterrogatoriss, underlying

                                                                                             'I Interveners' assertion that "there is no reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook Station for institutionalized persons .    . . who cannot be evacuated," and define " adequate".

AS TO JI CONTEYrION 4B 19 159. Please identify all persons whom Intervanors assert

                                  " refused to complete forms in protest," state how many and which ones (if any) of those persons in fact are (or reside with) " homebound persons in need of special f

f 19 The following Interveners have indicated that they do not intend to litigate JI contentica 48, and so do Dat need to respond to the questions cencarning it (unless their intentions have changed): SAPL; Con; TOS; TOWN. l I E--__.____________ _ _ ___

i assistance," and state all the facts underlying your I 1 answers. )

                                                                                                    )

160. Please identify all persons whom Interveners assert

                                                                                                   ]

1

                       " reported that members of their families had special                        l J

needs when, in fact, they did not." Please also explain j why these persons alleged submitted false and misleading information. State all the facts underlying your answer. 161. Please identify all " opposition groups" that " collected" forms to keep them from being sent in. State the number of forms each " group" "collecte ' , and the identities of all' persons whose forms were " collected". Describe in detail the collection methods used, and identify all j persons who encouraged, participated, directed, counseled, assisted, or were aware before the fact of those collection efforts. Please also state whether all the persons whose forms were collected knew, and-consented to, that their forms would be "not sent in". State all the facts underlying your answers. 162. Describe in detail all communications, concerning the special needs survey, which Intervanors and/or any official of the commonwealth of Massachusetts has had with any of the persons and groups identified in response to the preceding three interrogatories, and .

                                                  ~53-w   _ _ _ _ _.___-

produce all documents that reflect or refer to any and/or all such communications. 163. Please state all the facts underlying Intervanors' assertion that "the deeply-felt and widespread opposition to of (sic) does not engender confidence on the part of special needs persons that the information they might submit will be kept confidential, thereby i- discouraging submission of such data," and define

                                                               " discouraging".

164. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying 'l l Interveners' assertion that " periodic special needs i surveys by mail" are " unreliable for a number of reasons." 165. Please state all the facts underlying Interveners' assertion that "NHY" cannot " provide reasonable  ! assurance of adequate security" for the confidentiality of special needs information, and define " adequate". 166. Please state all the facts underlying Interveners' i assertion that "much information on functional ,

      .                                                         characteristics and needs could and should be obtained to enable appropriate and timely assistance to be provided," and define "much", " appropriate", and
                                                                " timely".

l. l l L--____________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ l

167. Please state all the facts underlying the assertion that the SPMC "provides no reasonable assurance that the information collected will be validated, updated, or maintained," and define " validated". 4 168. Please provide the following information concerning "special needs resident population" data for the Massachusetts portions of the plume EPZs.cf the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants: (a) all procedures used "to identify persons with special needs"; (b) all procedures for protecting the confidentiality of special needs data collected; (c) all " individualized determinations of functional characteristics of special needs persons necessary. to cope with a radiological emergency"; (d) all " individuals and organizations", other than

                                                                             " transporters during evacuation", identified in    ,

advance as " capable of assisting handicapped persons"; and (e) all procedures used to ensure that "the information collected will be validated, updated, or maintained." Please also produce copies of all procedures requested

                                                                    .about, and state all the facts underlying your answers.

1 1. l' l:

1 i l ' l 169. Please identify all "special needs resident (s)" whom Interveners assert are not " identified" in the SPMC.  ! 170. Please state all the facts, estimates, and observations, J other than those discussed in response to the preceding interrogatories, underlying Intervanors' assertion that "the SPMC . . . has not identified all or even most of the special needs resident population, has not sufficiently assured the security of acquired information about special needs individuals, has not adequately determined the specific assistance needed by identified individuals to cope with a radiological emergency, has not identified other individuals and organizations capable of assisting and the type of

                                                                 -assistance required, and has no adequate procedures for assuring that this data is periodically validated," and define "most", "sufficiently", " adequately", " adequate",
                                                                    " periodically", and " validated."

20 AS TO JI CONTENTION 49 171. Please state all the facts underlying Intervanors' assertion that "this generic plan is inadequate to meet l the different needs of different categories of l 20 The following Intervanors have indicated that they do not intend to litigate JI Contention 49, and so do D21 need to respond to the qu2stions concerning it (unless their intention ) shave changed): SAPL; CON; TOS; TOWN.  !

                                                                                                   =2-_--_-____                                            _

o . a ,

                                                                                                                    'l
  - r l-l handicapped individuals for each step in the process needed to engage in adequate sheltering or evacuation,"          f and define " adequate".

172. Please state all the. facts underlying Interveners' l assertion that " separate protective action plans need to be developed for each of the main categories of handicapped individuals present in the EPZ in order to provide reasonable assurance that adequate protective measures can and will be taken," and define " adequate." Please also list all such " main categories of handicapped individuals present in the EP2." 173. Please state all the facts underlying Interveners' assertion that "for each handit'.pped individual who needs assistance with preparing to shelter, sheltering, evacuation preparation, travel processing through a reception center, living in a relocation (congregate care) facility, or r6covery/re-entry, there needs to be a responsible and knowledgeable contact person to provide communication and physical assistance." Please also state whether Interveners assert that such a

                                                    " contact. person" could only assist one " handicapped individual" and, if so, state all the facts underlying that assertion.

174. Please state all the facts underlying Interveners' i

asscrtion that "such contact people need to be identified in advance for each individual." 175. Plesse state all the facts, estimates, and observations underlying Interveners' assertion that "there are an inadequate number of ambulances and wheelcar vans to transport (home-bound mobility-impaired persons) in a timely fashion," and define " timely". 176. Please identify and describe in detail all

                                                                           " accessibility problems" that Intervanors assert exist at "the reception centers and the host special facility."

177. Please state all the facts underlying Interveners' assertion that " inadequate provision is made to have KI available for those whose immediate evacuation may be infeasible or very difficult," and define " inadequate". 178. Please state all the facts underlying Interveners' assertion that "the non-functional and emotionally disturbed will need the assistance of trained staff on a one-to-one or'other appropriate ratio." 179. Please state all the facts underlying Interveners'

            .                                                             assertion th9t "at the Monitoring / Reception Center, a special area should be set aside for registering,                                      :

nonitoring, and decontamination of the mentally and emotionally disturbed," and describe such a "special area" in detail. l 1

180. Please state all the facts underlying Interveners' assertion that " agreements to receive a specific number of individuals should be made with mental facilities outside the EPZ, to accommodate non-functional severe cases," and define "non-functional severe cases." 181. Please state all the facts underlying Interveners' assertion that " responsible staff should remain with each' mentally or emotionally impaired homebound person throughout the reception and recovery / reentry phases." 182. Please- state all the facts underlying Interveners' assertion that the SPMC does not make " adequate plans for offering of KI" to " mentally and emotionally impaired homebound persons," and define " adequate". 183. With regards to the Massachusetts portions of the plume EPZs of the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants, please provide (and produce all documents that reflect or refer to) the following information: (a) whether " separate protective plans" have been I

                                  " developed for each of the main categories of       I i

handicapped individuals present in the EPZ," and,  ! if not, why nots (b) whether "each handicapped individual who needs assistance with preparing to shelter, sheltering, i evacuation preparation, travel processing through a L--______-___- -

Ps l i J reception center, living in a relocation (congregate care) facility, or recovery / reentry" has-a " responsible and knowledgeable contact person", " identified in advance", to'" provide communication and physical assistance," and, if not, why not; (c) whether "the non-functional and emotionally disturbed" would have, during an evacuation, "the assistance of trained staff on a one-to-one or other appropriate ratio," and, if not, why nott (d) whether "a special area" is set aside "for registering, monitoring, and decontamination of the mentally and emotionally disturbed," and, if not, why not; (e) whether " responsible staff" would " remain with each l mentally or emotionally impaired homebound person

• throughout the reception and recovery / reentry phases," and, if not, why not; and (f) what provisions have been made for " offering of KI" to " mentally and emotionally impaired homebound  ;

persons." 184. For all " schools" and "special facilities" in Newbury, please describe in detail what Intervanors assert are j the "special transportation requirements" for each 4 i s 1 L-. . i!

                                                                                                                             +

facility, and state all the facts underlying your answers. 185. Please state all the facts underlying Intervanors' assertion that "the SPMC fails to identify reasonable i l routes c; access to and departure from the (Newbury) facilities,' and define " reasonable." 186. Please state all the facts, other than those discussed in response-to the preceding interrogatories, underlying Interveners' assertion that "the SPac's provisions for assisting'the special needs resident population in taking protective actions are grossly deficient and provide no reasonable assurance that adequate protective measures can and will be taken by this population," and define " adequate." AS TO JT CONTENTION 5021 187. Please state all the facts, estimates, and observations underlying Intervanors' assertion that "not all the special facilities have been identified or listed in the , SPMC." Please also list the name and address of all "special facilities" which Interveners assert "have [not) been identified or listed in the SPMC." j 21 The following Interveners have indicated that they j do not intend to litigate JI contention 50, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): CON; TOS; TOWN.

                                                                                                                               )

l ____m...___mu_ m m.m_m_. -

i-

    .                                               188. Please state all the facts underlying Intervanors' assertion that "without adequate facility-specific plans for each special facility, there is no reasonable assurance that adequate protective measures can and will be taken for those in special facilities," and define
                                                           " adequate".

189. Please state whether the Commonwealth of Massachusetts relies:upon " facility-specific plans for each special facility" in the Massachusetts' portions of the plume EPZs of_the Pilgrim, Yankee Rowe, and Vermont Yankee nuclear power plants. If so, produce copies of all such plans. If not, explain in detail why not. 190. Please state all the facts underlying Intervanors' assertion that "no generic plan for all special facilities, given their diverse populations, can provide i the guidance necessary for each facility to respond appropriately," and define " appropriately". 191. Please state all the facts underlying Interveners' assertion that "the special facilities have not seen i such a plan, and many will not keep it or rely on it even if NHY sends it to them". Please also identify all the "special facilities" that Interveners assert "will l ' not keep (the plan) or rely on it". 192. Please state all the facts underlying Interveners' assertion that, "without adequate emergency response l l l

k + 1 e i plans for each special facility, there is no assurance p that special facility staff can and will perform all 7 , these support and assistance functions," and define

           . <                                                         " adequate". Please also identify "sach special facility" in the Massachusetts EPZ that Intervanors assert does not have non-radiological " emergency response plans" that are " adequate", and state all the g                                                                 facts' underlying those assertions.

193. Please state all the facts underlying Interveners' assertion that "the implementing procedures for the special population liaisons are poorly drafted, vague, and confusing." 194. Please state all the facts underlying Interveners' assertion that "the procedures for the special-Population Liaisons . . . are neither identical nor sufficiently integrated with each other to ensure that confusion and mistakes will not occur."' r. L 195. Please state all the facts underlying Intervanors' I assertion that "there is no reasonable assurance that the Special Population Liaison can and will be able to ) perform her functions in a timely manner (from the staging krea)," and define " timely". Please also state how likely-Intervanors assert it is that the "Special Population Liaison must perform her functions from the l i 1 1;

b l l staging area, rather than at a local EOC," and state all l

                     'the facts underlying your answer.

196. Please state all the facts underlying Intervanors' assertion that "there is no assurance . . . that upon her admittance to a local Eoc she will have timely access to a telephone," and define " timely." 197. Please state all the facts underlying Intervanors' assertions that "the remaining companies do not have sufficient drivers and buses to transport all those persons'in special facilities out of the EPZ in a timely fashion," and define " timely". 198. Please state all the facts underlying Interveners' assertion that " buses . . . are unsuitable modes of transportation for large numbers of those who are elderly or mentally retarded," define "unsuitab):d, and define (with quantification) "large numbers." 199. Please state all the facts, other than thos,e discussed i in response to the preceding interrogatory, underlying Intervanors' assertion that "the SPMC significantly underestimates the number of ambulances and wheelchair

                      . vans needed," and define "significantly."

200. Please state all the facts underlyint Interveners' assertion that "most administrators of nursing homes will not permit the frail elderly or others who may be 1 L__ --- - -

r_ _ _ _ _ ._ _ _ L ie bedridden to be transported in bed buses," and define "most". 201. Please state all'the facts underlying Intervanors' assertion that "the plans call for an insufficient number of ambulances to relocate all those in special facilities (non-hospitals) who need to be transported by ambulance in the event of an' evacuation." 202. Please state all the facts underlying Intervanors' assertion that "there is no reasonable assurance that, in the event of an emergency, the ORO will be able to produce sufficient responding ambulances to evacuate those in special facilities in a timely fashion," and define (with quantification) " sufficient" and " timely". 203. Please state all the facts underlying Intervanors' assertion that, "for those facilities which have no sheltering plans, the message simply affords inadequate guidance on how to implement a timely, safe, and 1 i effective sheltering response," and define " inadequate",

                               " guidance", and " timely". Please also identify all
                               " facilities" which Intervanors assert "have no sheltering plans."

204. Please state all the facts underlying Intervanors' assertion that there is "no assurance that enough KI I will be available for all those in special facilities l l \ -___ _ ___ -_

1 I whose immediate evacuation may be unfeasible or very difficult." 205. Please state all the facts underlying'Intervanors' assertion that "the SPMC contains inadequate provisions 1 for the distribution of dosimetry and KI to those in I special f acilities whose ima =41ste evacuation may be infeasible or very difficu;L," and define " inadequate". 206. Please state the following information for each " day-care / nursery" school in Newbury which Intervanors assert is not identified in the SPMC; (a) the facility name, address, and telephone number; (b) "the number of infants and other children enrolled"; and l (c) "the number of staff personnel"; and. i (d) "any special transportation requirements" of the 1 facility. 207. Pleace state all the facts underlying Interveners' assertion that the Host Special Facility "does not l assure an adequate facility for receipt of special facility residents or clients," and define " adequate." 208. Please state all the facts underlying Intervanors' l assertion that "the [ bus) numbers set forth in (the SPMC) are not at all reasonable given the numbers of special facility residents in those communities." Please also state what Interveners assert to be "the

                                                                                                                           )<

numbers of special facility residents in those communities," and state all the. facts, estimates, and I observations underlying that assertion. 209. Please state all the facts,-other'than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that "the people in special i facilities will not be adequately protected in the event of an emergency," and define " adequately". AS TO JI CGiu r.4 TION 51 22

                                 '210. Please state all the facts underlying Interveners' assertion-that "the SPMC's plans for use of [the Special Host Facility) do not provide reasonable assurance that it will be available in a timely fashion in the event of an emergency," and define " timely".

211. Please state all the facts underlying Interveners' assertion that "the maximum feasible number of special facility and mobility-impaired individuals who can be adequately cared for overnight is significantly less than 2,000," and define " adequately" and "significantly". 22 .The following Intervanors have indicated that they do not intend to litigate JI contention 51, and so do Dal need to respond to the questions concerning it (unless their TON 00N; TOS; TOWN. inte,ntions'have changed):

i 212. Please state all the facts, estimates, and observations underlying Intervanors' assertion that the assumption "that only 80% of those individuals who are in special

                                           ~ f acilities or who are mobility-impaired will require overnight shelter" is imprudent", and define                                   !
                                            " imprudent" .

213. Please state all the facts, estimates, and observations underlying Interveners' assertion that "at least 2,500 special needs individuals would need care at this special host facility." Please also state how many of that 2500 Interveners assert would " require overnight shelter" as well as "need care", and state all the facts, estimates, and observations underlying your answer. I 214. Please state all the facts underlying Intervanors' assertion that "there is no reasonable assurance that the Red Cross can and will respond in a timely manner, or at all, to provide the beds, blankets, food, or any other assistance needed at this special host facility," and define " timely". 215. Please state all the facts underlying Intervanors' assertion that "most of those who operate and staff the special facilities will not permit those in their care to be relocated to this host facility."

                                                                     ~68-l l
     .__E.2________   __ _ _ _ _ _ _ _ _ _

c l 216. Please state all the facts underlying Interveners' l assertion that, " absent certification by the American Red Cross, there is no reasonable assurance that the ARC will in fact establish this shelter during an emergency." 217 Please state all the facts underlying Intervanors' assertion that "the facility does not meet the American Red Cross criteria for shelters for nuclear power plant disasters." , i 218. Please state all the facts underlying Interveners' assertion that "the facility itself is not suitable for  ! use as a host special facility for the population i intended," and define " suitable". 219. Please define " transfer trauma" as used by Interveners, explain in detail how transfer out of the EPZ to the ) Special Host Facility "will be hazardous to the health j l and well-being of thase individuals," and state all the  ! facts underlying your answer. 220. Please state all the facts, other than those discussed i in response to the preceding interrogatories, undarlying Intervanors' assertion that "the WPMC's plans for use of this facility do not provide reasonable assurance that . . . it will be adequate for use as a special needs congregate care center, or that the care available l will be adequate for the number and kin' of special

needs individuals to be sent there," and define

                                                                              " adequate".

I AS TO JI CONTENTION 5223 221. Please state all the facts underlying Intervanors' assertion that "the EOF and EOC should not be housed in the sams building." 222. Please state all the facts underlying Intervanors' asertion that "the EOC and the Media Center are not accessible to Massachusetts state or local government officials during an emergency at Seabrook," and define

                                                                               " accessible".

223. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying i Interveners' assertion that the EOF, EOC, and Media ] Center "are inadequate for the purposes required," and f define " inadequate". l 1 23 The following Intervanors have indicated that they do not intend to litigate JI contention 52, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS; TOWN.

AS TO JI CONTENTION 5324 224. Please state all the facts underlying Intervanors' assertion that "the facility identified as a staging area located in Haverhill at 145-185 Water Street is not i now available to the ORO for this purpose." 225. Please identify all assistants, employees, or agents of the Mass AG who communicated with the Mayor of Haverhill or any member of the Zoning Board of Appeals of Haverhill concerning use of the Water Street property as a staging area. Please also describe in detail (including the date and manner of communication), and produce all documents that reflect or refer to, all such communications. L AS TO JI CONTENTION 5425 226. Please state all the facts underlying Interveners' l assertions that "[ijn the event of an amargency at Seabrook Station, the American Red Cross response would 24 The following Intervanors have indicated that they do not intend to litigate JI contention 53, and so do D21

   -                                                    need to respond to the questions concerning it (unless their intentions have changes):      TON: CON; TOS; TOWN.

25 The following Intervanors have indicated that they do not intend to litigate JI contention 54, and so do D2% , need to respond to the questions concerning it (unless their ] intentions have changed): SAPL; TON; CON; TOS; TOWN. ] 4 (

1 be at best ad hoc" and that "[sjuch a response does not provide reasonable assurance that any of the congregate care centers or the host special facility will be l i operated by the American Red Cross or that, if the Red i Cross does act to establish mass care centers in l Massachusetts, it can be done in a timely fashion." l 227. Please identify and produce all documents reflecting planning for any disasters, including, but not limited to, nuclear power plant disasters, by the American Red Cross in concert with governmental planning efforts. 228. Please identify and produce all documents utilized by the Commonwealth of Massachusetts for providing mass care for people who may be relocated for any type of emergency within or outside the Commonwealth of I Massachusetts. 229. With respect to JI Contention 54, do Interveners intend to rely on any facts, other than those stated in response to the three previous Interrogatories, to i establish the assertions stated therein? If so, please state all the facts underlying Interveners' assertions. I i 4 AS To JT CONTENTION 5526 26 The following Interveners have indicated that they ' do not intend to litigate JI Contention 55, and so do n21 need to respond to the questions concerning it (unless their l intentions have changed): CON; TOS. I l

                                                                                                                              )

230. Please state all the facts underlying Intervanors' ) assertion that "(a)t least eight of the 16 companies l I have either confirmed that~they will not participate or. that they will offer only the buses, vans and drivers that might be available, if any, at the time of the emergency." 231. Please state all the facts underlying Intervanors' assertion that "[t]he remaining companies do not have sufficient drivers, buses and vans to evacuate the transport-dependent / mobility-impaired population and all those in hospitals, special facilities, and schools, and  ; daycare/ nurseries who need bus / van transportation" and that "[t]his number is larger than the SPMC estimates." 232. To the extent Interveners assert that the SPMC  ! underestimates the number of drivers, buses and vans needed for the evacuation, please state what Interveners consider to be the necessary numbers of drivers, buses, and vans needed to evacuate each of the following: (1) l transport-dependent / mobility-impaired persons, (2) persons in hospitals, (2) persons in special facilities,

     .                                                             (4) persons in schools and (5) persons in day care / nurseries. For those persons listed in categories (2) - (5), pisase state how many of those persons will

[ L require transportation to be provided by someone other than the institution (hospital, special facility, etc.) 1 _____1_____ _ _ _ j

l l i with which they are affiliated. Please state all the facts, estimates, and observations underlying your , t. answers. j 233. Please state what Intervanors would consider to be a i

                                              " timely response."                                             l 234. Please state all the facts underlying Interveners' assertion that "the SPMC's procedures in Pro. 2.10 for notifying bus companies, determining the availability of buses and drivers, assigning particular buses to             f particular bus needs, assigning Bus Dispatchers,. Route Guides, and Dosimetry Recordkeepers, and sending these ORO staffers off to the assigned bus yards is designed for a slow-breaking radiological emergency" and define
                                                 " slow-breaking radiological emergency."

235. Please state all the facts underlying Interveners' assertion that "[t]hese procedures are too cumbersome and time-consuming to ensure a timely response to a fast-breaking accident" and define " fast-breaking accident." 236. Please state all the facts underlying Intervanors' assertion that " convoys of buses always travel more slowly than individual buses do, and convoys will have a , much more difficult time traveling into the EPZ against evacuating traffic than single buses would." j i

                                                                                - - - x - - -______- _______-____ -___________

f 237. Please state all the facts underlying Intervanors' assertions'that "(i)n seeking to enlist the participation of these ambulance companies and their drivers, NNY led at least some of the companies and their. drivers to believe that they would not be driving into areas close to seabrook station which were radiologically contaminated" and that "[t]his was done through a combination of active misrepresentation and critical omission of facts regarding what kinds of individuals might need ambulance services and where they would be located." 238. Please state all the facts underlying Intervanors' assertion that "[e)ven if all (the vehicles relied on by the NHY ORO) could respond, there would not be  ! sufficient tow vehicles to remove all the road impediments in a timely fashion that can reasonably be expected during an evacuation of the entire EPZ in !- Massachusetts." 239. Please state how many road impediments "can reasonably be expected during an evacuation of the entire EPZ in

         '                     Massachusetts" and define " timely fashion" in this context.                                                                l 240. Please state what percentage of "the many automobile p

accidents, vehicles overheating and stalling, vehicles running out of gas, and vehicles abandoned during an f l l l j

l evacuation" Interveners aswert would require tow vehicles in order to avoid obstructing evacuating vehicles, and state all the facts, estimates, and 1 observations underlying your answer. 241. Please state how many tow vehicles Intervanors assert  ! I would be necessary to respond to the number of j incapacitated vehicles requiring tow truck assistance, and state all the facts underlying that assertion. 4 242. Please state all the facts underlying Intervanors' l assertion that "(a) third company will not renew its agreement to participate after the first year, and even now cannot provide reasonable assurance that its drivers will show up in the event of a radiological emergency." 243. Please state all the facts underlying Interveners' assertion that "[t]he final company (two tow trucks) can l give no reasonable assurance that it would respond and feels that it is under no contractual obligation to do so." 244. Please state all the facts underlying Intervanors' assertion that "[the number of tow trucks deployed by the SPFC) is far short of the number needed to clear the l evacuation routes of all reasonably anticipated blockages in a timely fashion," and define " timely". 245. Please state all the facts underlying Intervanors' f assertion that "[t]he method utilized by the SPMC for (

i surveillance for road blockages is not adequate to ensure that road blockages will be identified promptly enough to dispatch tow trucks to remove them in a timely fashion," and define (with quantification) "promptly" and " timely". 246. Please state all the facts underlying Interveners' assertion that Route Guides for the hearing impaired "are not out in sufficient numbers." l 247. Please state all the facts underlying Interveners' assertion that "[m)ost of the many miles of key evacuation roads will not be visible to (Route Guides), especially at night." 248. Please state all the facts underlying Interveners' assertion that "the SPMC fails to demonstrate that those individuals deemed 'available' to perform emergency services have in fact been asked, and agreed, to provide these services in an actual emergency, or that these individuals, many employed far from the EPZ, could promptly be located, notified, and deployed to respond to a nuclear accident", and define (with quantification)

                         "many", "far", and "promptly".

249. Please state all the facts underlying Interveners' assertion that " traffic accidents or additional delay will occur." Please also state how many " traffic accidents" and what (and how long) " additional delays" 1

1 l l 1 Interveners assert will occur, and state also the facts, l estimates, and observations underlying your answers. 250. Please state all the facts underlying Interveners' assertion that " substantial delay in deploying emergency i transportation will occur," and define (with quantification) " substantial". 251. Please state all the facts underlying Intervanors' assertion that "there is no reasonable assurance that ' the bus drivers who . . . have agreed to respond to an emergency at seabrook in fact have sufficient experience j or training to perform this function," and define l

                       " sufficient".

252. Please state all the facts underlying Interveners' assertion that "the plan does not . . . provide any basis for a finding that the number'(of tow trucks) will be adequate to respond to disabled vehicles." 253. Please state all the facts underlying Interveners' assertion that there is not "any reasonable assurance that the trucks would be able to effectively reach disabled vehicles in West Newbury in a timely manner," and define (with quantification) " timely". 254. Please state all the facts, estimates, and observations, other than those discussed in response to the preceding interrogatories, underlying Intervanors' assertion that "the SPMC fails to provide reasonable assurance that an i 4. l' .

adequate number. of. buses, ambulances, wheelcar vans, Lvans,. tow trucks, drivers and road crews can and will-respond in a-timely fashion," and define " adequate" and

                                                              " timely".
!?

AS TO JI CONTENTION 5627 255. Please. state all the facts, estimates, and. observations L

                                                        -underlying Interveners' assertion that "approximately 1.2 minutes to get each evacues passed through a
                                                      . monitoring station" is "not possible in the real world."
                                            ' 256. Please state all the facts underlying Intervanors' assertion that "the capacity of the Emergency Worker Facility" is "unlikely to be available for use by anyone other than emergency wor.cers."

257. Please state all the facts underlying Interveners' assertion that Applicants' plans for monitoring and decontamination have " deficiencies in regard to questions about the size of the (facilities) and the availability of survey meters." 258. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Intervanors' assertion that "the SPMC fails to provide 27 The following Interveners have indicated that they do not intend to litigate JI contention 56, and so do nat need to-respond to the questions concerning it (unless their

                                              . intentions have changed):                                                   TON; CON; TOS; TOWN.

                       -_ __. -                        = _ _ _ _ _ _ _ _ _ _        __    _

u 1- ,o , i. reasonable asuurance that adequate procedures, personnel, equipment und facilities for radiological monitoring and decontamination of general public evacuees, emergency workers and special facility evacuees . . . have been established," and define

                                                                             " adequate".

AS TO JI CGuriTION 57 28 259. Please' state all the. facts underlying Intervanors' assertion that "[ajdequate personnel to perform (the ttuk of double bagging, labeling, setting aside and guarding contaminated articles) are not designated," and state what Interveners assert would be an adequate number of personnel to perform this task. p-260.'Is the sole basis for Intervanors' assertion that "there are no adequate procedures ... yet identified for handling waste materials" that the radwaste disposal letter of agreement with Chen Nuclear was due to expire in July, 19887- If not, please state all the facts underlying Intervanors' assertion. I l 261. Is the sole basis for Intervanors' assertion that "there are no adequate ... personnel yet identified for l; l. 28 The following Interveners have indicated that they !? do not intend to litigate JI Contention 57, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): TON; CON: TOS; TOWN.

           ------a.-              _ _ _ _ . _ _ , _ _

n b, handling waste materials" that "(a]dequate personnel to perform (the task of double bagging, labeling, setting aside and guarding contaminated articles) are not designated"? If not, please state all the facts I-

~'

underlying Intervanors' assertion. 262. Please state all the facts, other than thosed discussed in response to the preceding interrogatories, underlying Interveners' assertion that "the SPMC fails to provide { adequate means for.the handling and disposal of contaminated waste water and contaminated materials," and define " adequate." AS TO JI CONTENTION 58 29 263. Please identify each organization or resource provider with which Interveners contend that there is no letter of agreement or that there is an inadequate agreement. For each organization or resource providsr identified, please state all the facts underlying Intervanors' assertion. 264. For each organization or resource provider identified in

    .                                                                the previous Interrogatory, do Intervanors contend that a letter of agreement is necessary? If so, please state 29     The following Intervanors have indicated that they do not intend to litigate JI Contention 58, and so do D21 need to respond to the questions concerning it (unless their intentions have changed):      SAPL; TON   CON; TOS; TOWN.

L - all the' facts underlying Interveners' assertion. If not, please state what type of agreement Intervanors i consider to be necessary. 1 265. Please state all the facts, other than those discussed 11n response to too preceding interrogator ias, underlying

                                            . Interveners' assertion thas "the SPMC fails to
                                             -demonstrate that each principal response organization has staff to respond and to augment ita' initial response on.a continuous basis (and). fails to provide for an adequate number of'available manned emergency vehicles."

AS TO JI CONTENTION 59 30 266. Do Interveners assert thht contracts that run between private suppliers and NHY are executory? If so, please state all the facts underlying that assertion. 267. Please explain why, in the context of licensing, Interveners consider that the need for Bankruptcy Court approval, giving the debtor-in-possession the option to assume or reject contracts, makes these contracts f t. unreliable, and state all the facts underlying your

   ;                                           answer.

30 The foiAoving Interveners have indicated that they do not intend to litigate JI Contention 59, and so do Dqt need to respond to the questions concerning it (unless their intentions have changed): SAPL; TON: CON; TOS; TOWN. L l I

1 A

        ..i.

268. Please state all the facts, other than those discussed in response to the preceding Interrogatories, underlying Interveners' assertion that "there is no assurance that resources "elied on in the SPMC will be adequate at the time of an emergency." AS TO JI CONTENTION 6031 269. Please state all the facts underlying Intervanors' assertion that "[t]he SPMC fails to identify the equipment available for use in discouraging or encouraging direction of traffic flows." 270. Please identify each location in Newbury, Newburyport, Salisbury, and West Newbury where Interveners assert that the SPMC calls for the use of an inadequate number of traffic control devices, and state "[t]he number and location of cones, barricades and other control devices" i that Interveners consider to be e.dequate for each location. Please also state all the facts underlying your answer. 271. Please state all the facts underlying Intervanors' assertions that "[i]n the event that [ traffic control)  ; devices are to be brought into Newbury, this will be 31 The following Intervanors have indicated that they do i' not intend to litigate JI contention 60, and so do nat need to respond to the questions concerning it (unless their intentions have changed): SAPL; TOS.

h , ) .. 1

'\ j J _'

np difficult or impossible if an energency is rapidly- l developing and evacuation has commenced without traffic h controls in place" and that "[t]hereafter, gaining timely access to control points will be unlikely." p 272. Please state all the facts underlying Interveners' L assertion that "the Utility plan fails to provide for an adequate equipment inventory, in particular blinking light cones, to be maintained at the staging area." 273. Do Interveners assert that " blinking light cones" are required by the regulations? 274.JPlease state all the facts, other than those discussed Li in response to the preceding interrogatories, underlying j Interveners' assertion that "the SPMC fails to adequately identify the emergency equipment available for use in implementing the plan." l

                                                                                                                     ;\

As To JI CCmim4 TION 6p2 275. Please state oil the facts underlying Intervenor's assertion that Applicants "have failed to show what energency response asasures will be taken by the

            .                                              Massachusetts state and local governments in the event that Mode 1 cf the SPMC is followed."

32- The following Interveners have indicated that they do not intend to litigate JI Contention 61, and so do D21 need to respond.to the questions concerning it (unless their intentions have changed): SAPL; TON; CON; TOS; TOWN. i

276. Please state all the facts underlying Intervenor's , assertion that "[t]he means by which the state and local governments are thus presumed to ' follow' the SPMC in Mode 1 consists only of using Applicants' resources in carrying out an ad hoc response." 277. Please state all the facts underlying Intervenor's assertion that "[t]he mere provision of resources to support an unplanned emergency response does not adequately compensate for the state and local governments' lack of preparedness > respond to an accident at Seabrook." AS TO JI CGivmTION 62 33 278. Please state all the facts underlying Interveners' ass.ortion that "to the extent that it contemplates the integration of state / local emergency response functions l with those of the ORO, the SPMC is hopelessly cumbersome  ; ar.d confusing. " 279. Please state all the facts underlying Intervanors' assertion that the " parallel existence of government and ORO emergency response organizations" creates

                                             " cumbersome communication and coordination problems."

33 The following Interveners have indicated that they do not intend to litigate JI contention 62, and so do D21 need to respond to the questions concerning it (unless their intentions have changed): SAPLt CON; TCSr TOWN.

t. I 1 l l I 1 280. Please state all the facts underlying Interveners' assertion that the " steps of communicating and . l coordinating" are " time-consuming," identify each step and the personnel involved, and state how much time is required for each step.  ! 281. Please state all the facts underlying Interveners' j assertion that "(flor each function" the " steps of agreeing on divisions of responsibilities and all of the accompanying logistics, including communication and sharing of equipment and personnel" cre. -time-consuming," identify nach step and the personnel involved, and state how much time is required for each step. 282. Are the facts stated in your responses to the previous three interrogatories all the facts underlying Intervanors' assertion that the "SPMC does not provide a mechanism by which the state and local governments can swiftly and efficiently interact with ORO officials to mount a timely and adequate response to an accident." If not, please state all the facts underlying that , assertion. 283. Please state all the facts underlying Intervanors' assertion that "the result of any attempt by Massachusetts governments to ' follow' the SPMC would be utter confusion." f l

1

 ",,             8 i.

1; 284. Please. state all the facts underlying Interveners' assertion that "(gliven the high population density of j 4 the Seabrook EPZ and the relatively long time. required ] to evacuate the area, there is no room for the confusion and delay that would arise if state and local governments attempted to implement the SPMC during a 1 Radiological emergency." Please also state what-Interveners assert is the " population' density of the

                             -Seabroo) EPZ" and the " time required to evacuate the area," and state all the facts, estimates, and observations underlying your answers.

285. Is the sole basis for Intervanors' assertion that

                              "[p)ublic. notification, and coordinated PARS between the states, will at a minimum, be unreasonably delayed under actual smergency conditions" that "(a]any government officials in both states are unfamiliar with the I

planning documents"? If not, please state all the facts underlying that assertion. 286. Please state all the facts underlying Interveners' f i I assertion that "(a]any government officials in both states are unfamiliar with the planning documents," and identify all the " government officials" who wonid be involved in a radiological emergency response whom Interveners assert "are unfamiliar with the planning documents." 4

4 287. Please state all the facts underlying Interveners' assertion' ths'. "Newbury officials in command and control of emergency functions are unfamiliar with the contents of the SPMC." 288. Please state all the. facts, other than those discussed in response to the preceding interrogatories, underlying. Interveners' assertion that the SPMC *does not compensate adequately for the lack of preparedness of h state and local officials to respond to.a radiological emergency at Seabrook," and define " adequately". 34

                                                                                                     &LTO JI CGiurEION 63
                                                                     '289.          Please state all the facts underlying Interveners' assertion that the statement in the SPMC that the Massachusetts Eoc at Framingham "could be used to provide support in the event of an emergency at Seabrook h                                                                                     Station, just as it might be used for response provided J.

to an accident at any other nuclear generating station affecting.the state" is " false." 34 The follewing Interveners have indicated that they i . do not intend to litigate JI contention 63, and so do nel need to respond to the questions concerning it (unless their intentions have changed: SAPLt CON. l In addition, TOS any Limit its responses to just those questions that concern is' sues which it indicated, in 1988), its Request for Limited Participation Status (October 5, that it intends to litigate.

i. I 290. Please state all the facts underlying Intervanors I assertion that "[n)o current planning exists that would l coordinate the state ECC and the response'of the local I' l communities to a seabrook amargency." l 291. ~ Please state all the facts underlying Intervanors' assertion that "[t]he State Area I EOC in Tewksbury is also inadequately staffed for a radio; s/ cal t emergency at Seabrook." 292 -Please state all the facts underlying Interveners' assertion that "[t]here are inadequate maps, communications lines and other materials and information , at the Area-I Eoc to provide a response to a radiological emergency at Seabrook," and identify all 1 4

                              "other materials and information."

l' 293. Please identify, by type of equipment and use, all 1' communications systems currently utilized by Massachusetts Civil Defense in coordinating any emergency response with local communities including, but not limited to, the six Massachusetts EPZ communities. 294. Please state all the facts underlying Interveners' I' assertion that "[t)he local EOCs'in the 6 Massachusetts communities are not adequate to handle a radiological emergency at seabrook." 295. Please state all the facts underlying Interveners'

                                                                     ~

assertion that the local Eocs in the six Massachusetts 1 l

(. t r . l EPZ communities'"are inadequately staffed for such a contigency and do not have the communications links necessary, either between themselves or with the ORO EOC to provide any emergency support for such an accident." 296. Please describe the communications link for emergency use currently existing between the six Massachusetts EPZ communities, including, but not limited to, all law enforcement, fire and emergency medical radio frequencies and the hardware to support use, all commercial telephone lines and numbers, and all specially dedicated lines and numbers. I 297.'Do Interveners consider that the lack of "other planning" is an inadequacy?- If so, plar w 4enscribe in detail what "other planning ... to coordinate other resourses available to the state ... and make these resources available in a timely and effective manner in the event of an emergency at Seabrook" Interveners assert would be adequate. 298. Please identify, and produce all documents that describe or refer to, all governmental resources available for response to a radiological emergency at Seabrook Station, whether those resources are considered adequate l or inadequate by Intervanors. 299. Do I A .ervanosa assert that prior coordination or planning with the Massachusetts State Police is possible l _-_ -- -- - - - 8

e m, > @p - 4., , l.[i 7; .

• 'and/or necessary? If so, please describe what
• Interveners assert this coordination and planning should entail.

300. Do Interveners assert that the Massachusetts State Police are not ready or willing to respond to any emergency, including, but not limited to, a radiological emergency at Seabrook station? If so,.please state all the facts underlying that assertion.- 301..Please describe, based on internal police procedures, i. what response from the Massachusetts State Police can be expected in the event of a radiological emergency at Seabrook Station. 302.~Please state all the facts underlying Interveners' assertion that "[t]he Town of West Newbury has  ; inadequate resources to effectively implement, oversee, or adequately participate in a safe and effective evacuation of the town pursuant to the plan." Also, please describe those resources that are available and describe those additional resources that Interveners assert would be necessary to " effectively implement, oversee, or adequately participate in a safe and effective evacuation of the town pursuant to the plan." 303. Please state all the facts underlying Intervanors' assertion that " Salisbury does not now have nor is it likely to acquire sufficient policamen, firemen, public l l l j

m ,. l I works employees, or civil defense employees to I effectively implement, oversee, or participate in a safe evacuation of the entire town." Also, please describe .i a those resources that are available and describe those additional resources that Intervanors assert would be necessary to " effectively implement, oversee, or participate in a safe and effective evacuation of the entire town." 304. Please state all the facts underlying Intervanors' assertion that " equipment and personnel resources available to the (Town of Newbury are inadequate) to effectively or reasonably enable it to (implement the.

                                                                          'SPMC)." .Also, please describe those resources that are available and describe those additional resources that L                                                                           Interveners assert would be necessary for Town of Newbury to implement the SPMC.

305. Please state all the facts, other than those discussed in response to the preceding interrogatories, underlying Interveners' assertion that " adequate emergency facilities and equipment are not provided and  !

    .                                                                      maintained by state and local governments for an emergency at Seabrook," and define " adequate."

306. Please state all the facts, other than those discussed I f in response to the preceding interrogatories, underlying Interveners' assertion that "the SPMC fails to provide

    .u                                                                                                             t l
         .                                                                                                         i i

i l i adequate arrangements for requesting and effectively using assistance and resources that are purportedly  !

                                                          .available to the State and local governments," and define " adequate."

By their attorneys, EW Thonias G. Dignan, Jr. George H. Imwald Kathryn A. Selleck-Jeffrey P. Trout Jay Bradford Smith Ropes & Gray 225 Franklin Street Boston, MA 02110  ! (617) 423-6100 t l I J f' l l _ _ _ - _ _--_ - _ - -}}