ML20196F219

Atty General Jm Shannon Offsite Emergency Planning Interrogatories & Request for Production of Documents to Applicant (Set 3).* Interrogatories Should Be Answered by 880328.Related Correspondence

ML20196F219
Person / Time
Site:	Seabrook
Issue date:	02/24/1988
From:	Sneider C MASSACHUSETTS, COMMONWEALTH OF
To:	NEW HAMPSHIRE, STATE OF
Shared Package
ML20196F194	List: ML20196F190 ML20196F219
References
OL, NUDOCS 8803020089
Download: ML20196F219 (13)

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, REl.ATED CORRESPO.NQEg .

UNITED STATES OF AMERICA USNRC -

NUCLEAR REGULATORY COMMISSION M iEB 29 Fi:58 ATOMIC SAFETY AND LICENS;NG' BOARD QHICT U ICLm.w? *'

l Before Administrative Judges: uGCXCI H;r. q;eggy ,

Ivan W. Smith, Chairman ~ U "".T Gustave A. Linenberger,.Jr._ ' '

Dr. Jerry Harbour

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In the Matter of )

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PUBLIC SERVICE COMPANY OF NEW ) Docket Nos.

HAMPSHIRE, ET AL. ) 50-443/444-OL (Seabrook Station, Units 1 and 2) ) (Off-Site EP)

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) February 24, 1988 ATTORNEY GENERAL JAMES M. SHANNON'S OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANTS (SET NO. 3) i Pursuant to 10 C.F.R. 52.740 and 2.740b, Attorney General James M. Shannon hereby propounds the following interrogatories to the Applicants These interrogatories are to be answered in writing on or before March 28, 1988 and under oath by an employee, representative, or agent with personal konvledge of the facts or information requested in each interr )ry.

Definitions As rised in these interrogatories, the following terms have the following meanings:

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1. "Litigate" with regard to a topic or contention means to offer direct testimony relating to, to cross-examine on, to offer propoced findings or rulings regarding, or to urge the donial (or allowance subject to conditions) of the pending application on the basis of the topic or contention.

2 "Document" .. ans any written or graphic matter of communication, however produced or reproduced, and is intended to oe comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, senedules, notices, work papers, recordings, shether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

3. "Identify" wich respect to any document means to state ene following respecting the document: .ts title, its date, the author of the document, the person to whom the document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the present custodian of tne document and of any and all copies of the document.

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4. "Identify" with respect to any action or conduct means to state the following regarding any such action or conduct:

the person or persons proposing and taking such action the date such action was_ proposed and/or taken; all persons with knowledge or information'about such action; tne purpose or proposed effect of such action; any document recording or documenting such action.

5. "Describe" with respect to any action or matter means to state _the following regarding such action or matter: the

. substance or nature of such action or_ matter; the persons participating in or having knowledge of such action or matter; the current and past business positions and addresses of such persons; the existence and location of any and all documents relating to such action or matter.

6. "Identify" with respect to an expert witness means to state:

(a) The name, mailing address, age and presen professional or employment affiliation of the pe. son; (c) The profession or occupation and field of claimed I

expertise of the person; (c) The history of formal education or tra!.ning of the person, including, but not limited to, (i) the name and i

address of each school where the person received special l t

l education or training, (ii) the date those schools were f attended, and (iii) a description of each degree earned, f L

including the cate and granting institution; [

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'd) The history of specialized training in the area of claimed expertise, including, but not limited to, (i) the type of training received, (ii) the name and address of the institution providing :his training, and (iii) the dates of such training; (e) A list of publications of any kind by the person in the area of claimed expertise, including, but not limited to, (i) the title and subject natter, (ii) the name and address of the publisher, and (iii) the date of publication; (f) A list of any and all licenses in the area of claimed expertise, including, but not limited to, (i) the designation of the authority by which the license was issued, (ii) the date(s) of the licensiiig, (iii) the requirements for obtaining each license, and (iv) the manner by which these requirements were met; (g) The amount of time the person has worked in the field of claimed expertise, stating periods where work was other than on a full-time basist (h) The name and address of every person, or every corporation or other institution, that has employed the person within the last ten years of employment; (i) All periods of claimed self-employment, including a description of all duties and responsibilities thereof; (j) All previous experience in ene field of claimed expertise which involved problems, analyses or studies similar to those concerning which the person is expected to testify in this proceeding; 4 -

(k) All other litigation in which the person has been consulted, specifying those matters in which the person has testified, including the name of the case or matter and the court or other forum in which testimony was given; and (1) Any other experience in the field of claimed expertise.

7 "Identify" with respect to a non-expert witness neans to state:

(a) The name, mailing address, age and present professional or employment affiliation of the witness; (o) The profession or occupation of the witness; (c) The name of the supervisor and department of the witness; (d) The current employment or professional relationship, if any, between the witness and your (e) The past employment or professional relationship between the witness and you, including the dates of that relationship; and (f) All litigation in which the person has testified on any matter in which you have had an interest, including the name of the case or matter and the court or other forum in which testimony was given.

Wherever appearing in these interrogatories, the masculine form is defined to include the feminine and/or the neuter and the singular form is defined to include the plural wherever necessary to apply tne context to any factual situation that may oxist or to render the interrogatory more inclusive in scope.

Notice Regarding Supplementation Your attention is called to the provisions of 10 C.F.R.

S 2.740(e) regarding your obligation to supplenent interrogatories and requests for the production of documents.

Request for the Production of Documents Pursuant to 10 C.F.R. S 2.741, you are hereby requested r.o produce, for inspectio and copying, each document identified in response to these interrogatories and each document required to be identified in response to theae interrogatories, at the offices of Attorney General James M. Shannon, Room 1902, One Ashburton Place, Boston, MA 02108 on March 28, 1988 at 10:00 o' clock a.m., attn.: Carol Sneider, Assistant Attorney General. Each document produced in response to this request should be labeled to indicate the interrogatory or interrogatories in response to which it is produced.

INTERROGATORIES

1. Identify all documents on which you will rely to support your position on the sheltering contentions, and nroduce all such documents not previously produced. Identify the information in each document on which you wil?. rely and the specific subpart of each contention which that. information Concerns.

2. State wnether you have relied, do rely, or will rely on any study, calculation, or analysis to support you: position on the sheltering contentions. If so, to the extent you have not already done so, please:

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a. Describe the nature of the study, calculation or dnalysis and identify any documents that discuss or describe the study, calculation or analysis;

b. Identify the persons who performed the stady, calculation or analysis;

c. State when and where the study, calculation or analysis was performed;

d. Describe in detail the information or data that was studied, calcolated or analyzed;

e. Describe the results of the study, calculation or analysis;

f. Explain how such study, calculation, or analysis provides support for your position on each of these contentions.

3. Do you intend to offer the testimony of any expert witness witn respect to sheltering contentions? If so, please:

a. Identify each expert witness who you intend to present with respect to each subpart of each such contention;

b. State the substance of the facts to which each expert witness is expected to testify;

c. State the substance of the opinion or opinions to which each expert witness is expected to testify;

d. Provide a summary of the grounds for each opinion to wnich each expert witness is expected to testify;

e. State whether the facts and opinions listed in response to the foregoing are contained in any document;

f. State whether the opinion of any expert witness is based in whole or in part on any scientific rule or principle, and, if so, set forth such rule or principle;

g. State whether the opinion of any expert witness is based in whole or in part on any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon; and

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n. State whether the opinion of any expert witness is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.

4. Do you intend to offer the testimony of any non-expert witness with respect to the sheltering contentions to be litigated by the Attorney General? If so, please:

a. Identify each non-expert witness who you intend to present with respect to each subpart of each such contention;

b. State the substance of the facts to which each non-expert witness is expected to testify; and

c. State whether the facts listed in response to the foregoing are contained in any document, and produce the same.

5. Identify, as defined in Paragraph 4, all experts and other persons you have retained to prepare testimony on the sheltering contentions and all experts and other persons wien whom you have consulted in preparation of any testimony on the. sheltering contentions, whether or not you have decided to introduce such testimony, and for each such person, please:

a. Identify the contention or subpart of the contention on which he was consulted, or on which he has or is preparing testimony;

b. State the substance of the facts to which each expert may testify

c. State the substance of the opinion or opinions to which each expert may testify:

d. Provide a summary of the grounds for each opinion to wnich each expert may testify;

e. State whether the facts and opinions listed in response to the foregoing are contained in any document; S.

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f. State whether the opinion of any expert is based in whole or in part on any scientific rule or principle, and, if so, set forth such rule or principle;

g. State whether the opinion of any expert is based in whole or in part on any code or regulation, governnental or othewise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon; and

h. State whether the opinion of any expert is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.

6. In accordance with 10 C.F.R. S 2.740(e), please supplement your answers with respect to sheltering contentions to Massachusetts Attorney General's Interrogatories and Requests for Production of Documents, filed March 5, 1987 and May 19, 1987 7 State how and in what manner, if any, your current position with respect to sheltering the summer beach population diilers from the position articulated in Applicants' prefiled Direct Testimony No. 6 on Sheltering, dated September 10, 1987, and provide, for each specific change in position, the basis for that change, including all supporting documentatio'.

8. On p. 3, at 5 2, of the "New Hampshire Response to FEMA Supplemental Testimor y' ("dH Response") it is stated with respect to the State's position on sheltering, "This position does not preclude the State from considering and selecting sheltering as a protective action for the beach population." Please identify and describe:

a. under what conditions the State would consider and migne select sheltering as a protective action for the oeach population;

b. the neans by which the beach population will be instructed to shelter, including any emergency messages;

c. now the buildings which will shelter the beach population will be identified;

d. the specific buildings which will oe relied upon to shelter the beach population;

e. the personnel who may be employed to assist the beach population in seeking shelter, including the numbers of such personnel who may be available and a description of any training such personnel will receive certinent to that tasks and

f. any agreements, understandings, or other connunications with the owners of buildings that may be used as public shelters relating to the owners' consent to use their buildings as public shelters in the event of an accident at Seabrook Station, 9 On page 22 of Applicants' Direct Testimony flo. 6 (Sheltering), dated September 10, 1987, it is stated with respect to ene beach population, that:

Sheltering for example may be the appropriate protective action for a puff release -- a gaseous or gaseous and particulate release -- of less than two nours duration. (Manual of Protective Action Guides, U.S. EPA, p. 129.)

Do you still contend that sheltering of the beach population may be the appropriate p.otective action for a puff release of less than two hours duration?

10 Do you anticipate that there might be circumstances in which transients with access to transportation would be instructed to shelter?

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11. Please define the term "transient beach population" as used in the !1H Response, stating whether the term applies only to day-trippers to the beach area or whether it also includes overnight visitors staying .in notels, hotels or rental cottages.

12. On page 4 of the ilH Response it is stated, "The addition of these precautionary measures alleviates most concerns about sheltering the beach population." What State concerns does it not alleviate?

13. On p. 4 of ne :1H Response it is stated, "These precautionary actions and the Stata emphasis on getting the population out early are consisten: with actions planned at other nuclear power plant sites with transient populations."

a. What are the "other nuclear power plant sites" referred to in the above sentence?

b. What is the size of the transient populations at these other sites?

c. What are une evacuation time estimates for the transient populations at these other nuclear power plant sites?

d. What is the proximity of the transient populations at these other sites to the nuclear power plant?

e. Is any sheltering available for the transient populations at these other sites, and, if so, what are the Dose Reduction Factors (DRF) of these shelters?

14. On p. 7 of the NH Response, it is stated: "It Ithe Shelter Study) identified a large number of shelte:s that may serve as a pool from which public shelter choices will be made."

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a. How and when will such choices be made?

b. On what criteria will the choices be based?

15. Provide copies of all draft or proposed amendments to the NHRERP concerning protective actions for the beach population that the State is presently considering and for each proposed amendment:

a. state whether the State has any present intention to adopt such amendment;

b. describe the aceps that must be taken before such amendment is adopted;

c. provide the anticipated date by which such amendment will be adopted;

d. state whether there are any considerations against cdopting such amendment, and the basis of such considerations; and

e. provide any proposed changes to the draft amendment.

16. Does the term "beach population" as used in the NH Response include permanent residents of the Seabrook and Hampton beach area?

17 Do you foresee any situation in which the transient beach population would be instructed to evacuate and the residents of the Seabrook and Hamption beach area instructed to shelter?

18. On page 29 of Applicants' Direct Testimony No. 6 it states:

The result of the residential survey showed that 34 percent of 3,036 residences in Hampton Beach and 51 percent of 758 residences in Seabrook Beach provide basement and masonry sheltering capability.

Tne remaining percentage of residences provide sheltering characteristics at least as effective as that assumed by the NHRERP, The field survey revealed very few wood-frame residences that would not meet these sheltering characteristics.

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Please produce such survey, and all documentation, notes, calculations and memosanda pertinent thereto, and for each residence surveyed:

a. prcride the address of the residence; b.. indicate the type of residence, e.g., whether it is an apartment, house, condominium, etc.

c. indicate whether the residence has a basement or nasonry sheltering capability;

d. indicate whether the residence does or does not "provide sheltering characteristics at least as effective as that assumed by the NHRERP.*

19. On what basis do you contend that the sirens in the beach area, when used in the voice mode to instruct the beach population, can be intelligably heard and understood by all persons in the beach area't Please provide copies of any and all documentation, calculations and analyses including any acoustical tests, that form, or are in any way relevant to, the basis for your response, whether or not it supports your response.

JAMES M. SHANNON ATTORNEY GENERAL By: A Carol S. Sneider Assistant Attorney General Department of the Attorney Gener:1 One Ashburton Place, Rm. 1902 i Boston, Massachusetts 02108 (617)727-2265 i

Date: February 24, 1988