ML20081A423

Answer to 831005 First Set of Interrogatories on State of Nh Radiological Emergency Response Plan.Certificate of Svc Encl

ML20081A423
Person / Time
Site:	Seabrook
Issue date:	10/24/1983
From:	Dignan T, Gad R, Johnson W PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	NEW ENGLAND COALITION ON NUCLEAR POLLUTION
Shared Package
ML20081A403	List: ML20081A400 ML20081A413 ML20081A423 ML20081A438
References
ISSUANCES-OL, NUDOCS 8310260266
Download: ML20081A423 (9)

Text

,.

Filed: Octobsr 24, 1983 DOCKETED g USNRC 13 BCT 25 P2:22 UNITED STATES OF AMERICA gpg;g 0F 2C6EIls .

Doct:EilNG a SERVM NUCLEAR REGULATORY COMMISSION BRANCH before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

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

)

(Seabrook Station, Units 1 & 2) )

)

APPLICANTS' ANSWERS TO "NECNP FIRST SET OF INTERROGATORIES TO APPLICANTS ON NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN" Pursuant to 10 CFR $ 2.740b, the Applicants hereby respond to the "NECNP First Set of Interrogatories to l Applicants on New Hampshire Radiological Emergency Response Plan," served on them by mail on October 5, 1983.

l l

l l

l l

l 8310260266 831024 PDR ADOCK 05000443 9 PDR

t 6

SPECIFIC INTERROGATORIES Interrogatory No. 1 Question: >

With respect to NECNP Contentions 1, 2, 3, 4, 5, 7, 9, 10, 12, and 13 on the New Hampshire RERP, please provide the following information:

a. What is Applicant's position with respect to this contention? Describe in detail the reasons for your position.

b. Identify and provide access to all documents on which you rely during this proceeding to support your position on this contention. This includes all documents used in answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings,

c. Identify all persons you may call as witnesses on these contentions during these proceedi?:gs, and describe any documents and the portions thereof that they may rely on for their testimony.

Answer and Objection:

Part b is objected to as being incapable of answer. We do not even know who the witnesses will be who we will cross-examine so we cannot possibly say what documents will be relied upon in the future for such activities. We can say that we relied upon the NHRERP and NUREG-0654 in giving the various answers hereinafter set forth.

With respect to part c, no witnesses have been selected yet.

As to part a Contention 1. The applicants do not agree with the contention because there is no requirement for the index 1

l

O upon which the contention is premised. The required listing's appear in f 7.2.

Contention 2. The applicants disagree with the contention, because we are advised the plans do exist and because in the absence of such plans there are alternatives for basing the necessary 10 CFR $ 50.47 findings.

Contention 3. We disagree. See NHREP $ 1.4.

Contention 4. We disagree. See NHREP $ 2.2, 5 3.1.

Contention 5. We disagree. We are confident that centers will be established before any OL issues. See REPP Table 2.4-1.

Contention 7. We disagree. Applicants have the responsibility to design, install and maintain a system to provide early notification to the public within the Seabrook Station plume exposure emergency planning zone. The design work is underway and it is anticipated taht the system will consist of sirens (with a capability to transmit a verbal message on the beaches) and alerting radio receivers for some locations. This system will alert the public to tune to one of the Emergency Broadcast System stations for information about the emergency condition.

The design effort has only recently been initiated by the contractor and a final design report is expected by December 1983. A preliminary design has been completed and the design information transmit:s? to Public Service Company

of New Hampshire by letter dated October 12, 1983. The preliminary design information includes lists of organizations to receive emergency alerting radio receivers and proposed siren sites in each town within the plume exposure EPZ. A map showing the proposed siren locations is included in the preliminary design informtion package.

Applicant expects that upon establishment of a design for the public alerting system, the New Hampshire RERP will be supplemented accordingly and the necessary additional material regarding emergency message content will be provided.

Contention 9. We disagree. There is no regulatory requirement that the media center be outside the EPZ n, See 10 CFR $ 50.47(b)(7).

Contention 10. We disagree. See RERP i 7.

Contention 12. We disagree. See RERP $ 2.5.

Contention 13. We disagree. See RERP 5 2.8.

Interrogatory No. 2 Question:

Identify and provide access to all documents in your possession relating to or mentioning in any way the New Hampshire Radiological Emergency Response Plan.

d

r Objection:

The request as stated is unduly burdensome to respond to, vague, and lacking in the requisite specificity and, if read literally, irrelevant to the issues admitted for litigation. Indeed the NECNP interrogatories themselves

" relate to" and " mention" the NH RERP.

Signatures As to Answers:

I, Wendell P. Johnson, being first duly sworn, do depose and say that the foregoing answers are true, expect insofar as they are based on information that is available to the Applicants but not within my personal knowledge, as to which I, based on such information, believe them to be true.

Av s T10 % .

Wendell P. 'Jopson Sworn to before me this day of October, 1983:

/ Cw x M>

Not'ary Pub 1'id 6 My Commission expires: I!OC /PJf I /

As to Objections: .

s ~f  ::

//t G.Js Thomas G. Dignan, Jr.

R. K. Gad III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone: 423-6100

CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attorneys for the Applicants herein, hereby certify that on October 24, 1983, I made service of the within Applicants' Answers to "NECNP First Set of Interrogatories to Applicants on New Hampshire Radioloaical Emergency Response Plan" by mailing copies thersof, postage prepaid, to:

Helen Hoyt, Chairperson Diana P. Randall Atomic Safety and Licensing 70 Collins Street Board Panel Seabrook, NH 03874 U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Emmeth A. Luebke William S. Jordan, III, Esquire Atomic Safety and Licensing Harmon & Weiss Board Fanel 1725 I Street, N.W.

U.S. Nuclear Regulatory _ Suite 506 Commission Washington, DC 20006 Washington, DC 20555 Dr. Jerry Harbour G. Dana Bisbee, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Office of the Attorney General U.S. Nuclear Regulatory 208 State House Annex

'ommission Concord, NH 03301 Wathington, DC 20555 Atomic Safety and Licensing Roy P. Lessy, Jr., Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel 116 Lowell Street U.S. Nuclear Regulatory P.O. Box 516 Commission Manchester, NH 03105 Washington, DC 20555

Philip Ahrens, Esquire Anne Verge, Chairperson Assistant Attorney General Board of Selectmen Department of the Attorney Town Hall General South Hampton, NH Augusta, ME 04333

!- David R. Lewis, Esquire Jo Ann Shotwell, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Department of the Attorney General Commission One Ashburton Place, 19th Floor Rm. E/W-439 Boston, MA 02108 Washington, DC 20555 Charles Cross, Esquire Ms. Olive L. Tash Shaines, Madrigan & McEachern Designated Representative of

=

25 Maplewood Avenue the Town of Brentwood P. O. Box 366 R.F.D. 1, Dalton Road Portsmouth, NH 03842 Brentwood, NH 03833 Ms. Roberta C. Pevear Mr. Patrick J. McKeon Designated Representative of Selectmen's Office the Town of Hampton Falls 10 Central Road Drinkwater Road Rye, NH 03870 Hampton Falls, NH 03844 Mrs. Sandra Gavutis Mr. Calvin A. Canney Designated Representative of City Manager the Town of Kensington City Hall

, RED 1 126 Daniel Street East Kingston, NH 03827 Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. Angie Machiros U.S. Senate Chairman of the Washington, D.C. 20510 Board of Selectmen (Attn: Tom Burack) Town of Newbury Newbury, MA 01950

[ Senator Gordon J. Humphrey Mr. Richard E. Sullivan l 1 Pillsbury Street Mayor

[

Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Donald E. Chick Town Manager's Office Town Manager Town Hall Town of Exeter Friend Street

'10 Front Street Amesbury, MA 01913 l Exeter, NH 03833 i

l l

l  :

L

4 Brian P. Cassidy, Esquire Brentwood Board of Selectmen Regional Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency - Region I 442 POCH Boston, MA 02109

-D

'WW>&h Thortfas G. Man, Jr.