ML20204B587: Difference between revisions

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                                               .2-with respect to any of the contentions admitted in this proceeding.
                                               .2-with respect to any of the contentions admitted in this proceeding.
b)    FEMA has not yet developed positions ~ on any of the contentions admitted in this proceeding. Therefore, we are unable to articulate a basis for a position. However, we note that empirically it seems likely that the numerous documents in which FEMA and the Federal Regional Assistance Committee (RAC) have assessed the acceptability of the radiolugical plans and preparedness of the State of New Hampshire may well contain our position on many of the contentiobs. I understand that these documents, which are listed below have been served on the parties to this proceeding.
b)    FEMA has not yet developed positions ~ on any of the contentions admitted in this proceeding. Therefore, we are unable to articulate a basis for a position. However, we note that empirically it seems likely that the numerous documents in which FEMA and the Federal Regional Assistance Committee (RAC) have assessed the acceptability of the radiolugical plans and preparedness of the State of New Hampshire may well contain our position on many of the contentiobs. I understand that these documents, which are listed below have been served on the parties to this proceeding.
i)    FEMA report of the deficiencies observed during the February 26, 1986 Exercise of the state and local plans to protect the public in the event of an accident at Seabrook, together with a cover letter dated April 4,1986 from Edward A. Thomas to Richard H. Strome transmitting and explaining the report.
i)    FEMA report of the deficiencies observed during the February 26, 1986 Exercise of the state and local plans to protect the public in the event of an accident at Seabrook, together with a cover {{letter dated|date=April 4, 1986|text=letter dated April 4,1986}} from Edward A. Thomas to Richard H. Strome transmitting and explaining the report.
: 11)    Final Draft Report of the exercise of the emergency plans for Seabrook held February 26, 1986, together with a cover letter dated April 30, 1986 from Edward A. Thomas to Richard H. Strome.
: 11)    Final Draft Report of the exercise of the emergency plans for Seabrook held February 26, 1986, together with a cover {{letter dated|date=April 30, 1986|text=letter dated April 30, 1986}} from Edward A. Thomas to Richard H. Strome.
iii) ~ Final Report of the exercise of the emergency plans for Seabrook held February 26, 1986, together with a cover letter dated June 6,1986 from Edward A. Thones to Richard H. Strome.
iii) ~ Final Report of the exercise of the emergency plans for Seabrook held February 26, 1986, together with a cover {{letter dated|date=June 6, 1986|text=letter dated June 6,1986}} from Edward A. Thones to Richard H. Strome.
Iv)    Final revies by FEMA and Regional Assistance Comittee (AAC) of the state and local plens submitted by New henpshire in December 1985, together with a cover '.ettr Jeed April 30, l            1936 fron Ecward A. Tho. mas to itichard H. Strome, l
Iv)    Final revies by FEMA and Regional Assistance Comittee (AAC) of the state and local plens submitted by New henpshire in December 1985, together with a cover '.ettr Jeed April 30, l            1936 fron Ecward A. Tho. mas to itichard H. Strome, l


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v)  Draft FEMA and RAC Review of-the state and local plans submitted by New Hampshire in February 1986, together with a cover letter dated April 30, 1986 from Edward A. Thomas to Richard H. Strome.
v)  Draft FEMA and RAC Review of-the state and local plans submitted by New Hampshire in February 1986, together with a cover {{letter dated|date=April 30, 1986|text=letter dated April 30, 1986}} from Edward A. Thomas to Richard H. Strome.
vi)    Final FEMA /RAC Review of the state and local plans submitted by New Hampshire in February 1986 together with a cover letter dated April 30, 1986 from Edward A. Thomas to Richard H. Strome.
vi)    Final FEMA /RAC Review of the state and local plans submitted by New Hampshire in February 1986 together with a cover {{letter dated|date=April 30, 1986|text=letter dated April 30, 1986}} from Edward A. Thomas to Richard H. Strome.
vii)    Draft FEMA /RAC Review of the New Hampshire submission of April 16, 1986, together with a cover letter dated June 2, 1986 from Edward A. Thomas to Richard H. Strome.
vii)    Draft FEMA /RAC Review of the New Hampshire submission of April 16, 1986, together with a cover {{letter dated|date=June 2, 1986|text=letter dated June 2, 1986}} from Edward A. Thomas to Richard H. Strome.
viii)    Final FEMA /RAC Review of the New Hampshire submission on April 16, 1986, together with a cover letter dated August 8, 1986 from Edward A. Thomas to Richard H. Strome.
viii)    Final FEMA /RAC Review of the New Hampshire submission on April 16, 1986, together with a cover {{letter dated|date=August 8, 1986|text=letter dated August 8, 1986}} from Edward A. Thomas to Richard H. Strome.
ix)    Final FEMA /RAC Review of the state and local plans submitted by New Hameshire September 8,1986 together with a cover ietter from Edward A. Thomas to Richard H. Stroce dated December 12,* 1986.
ix)    Final FEMA /RAC Review of the state and local plans submitted by New Hameshire September 8,1986 together with a cover ietter from Edward A. Thomas to Richard H. Stroce dated December 12,* 1986.
c)    Since FEMA has not yet developed a position on the contentions admit-ted with respect to this proceeding we are unable to articulate which documents may be used in support of such a position beyond our statement in our answer to Interrogatory A supra.
c)    Since FEMA has not yet developed a position on the contentions admit-ted with respect to this proceeding we are unable to articulate which documents may be used in support of such a position beyond our statement in our answer to Interrogatory A supra.

Latest revision as of 07:00, 7 December 2021

Response of FEMA to Seabrook Anti-Pollution League First Set of Interrogatories & Requests for Production of Documents to FEMA on State of Nh Radiological Emergency Response Plan Rev 2.* Related Correspondence
ML20204B587
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 03/18/1987
From: Eric Thomas
Federal Emergency Management Agency
To:
SEACOAST ANTI-POLLUTION LEAGUE
Shared Package
ML20204B533 List:
References
OL, NUDOCS 8703250101
Download: ML20204B587 (5)
v • d • e


Text

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, 3/18/87 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY LIC_EN_ SING BOARD In the Hatter of )

) Docket No. 50-443 Public Service Co. of New Hampshire, ) 50-444-et al. ) (Offsite)

(Seabrook Station, Units 1 4 2)1 RESPONSE OF THE FEDERAL ENERGENCY MANAGEMENT AGENCY TO THE SEABROOK ANTI-POLLUTION LEAGUE'S FIRST SET OF. INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO. FEMA ON THE NEW HAMPSHIRE RERP REVISION 2-The Federal Emergency Management Agency (FEMA) is not a party to the above-captioned proceeding and it is, for that reason, not obligated to respond to the interrogatories propounded by.any intervenors. FEMA voluntarily provides the information supplied below, but reserves the right to object to future discovery requests.

__ Interrogatory A:

For each and everyone of the admitted SAPL Contentions (#'s 31, 7, 8, 8A, Redrafted 15,16,18, 25, 33, 34 and 37), provide the following information:

a) What witnesses does' FEMA intend to have testify with respect l to this contention?

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b) What position does FEMA intend to take on this contention and

! what is the basis of this position?

l c) What documents will be used in support of FEMA's position on this contention?

Answer A a) FE'M has not yet identified the witnesses it intends to have testify i

l 8703250101 870318

{DR ADOCK 05000443 PDR

.2-with respect to any of the contentions admitted in this proceeding.

b) FEMA has not yet developed positions ~ on any of the contentions admitted in this proceeding. Therefore, we are unable to articulate a basis for a position. However, we note that empirically it seems likely that the numerous documents in which FEMA and the Federal Regional Assistance Committee (RAC) have assessed the acceptability of the radiolugical plans and preparedness of the State of New Hampshire may well contain our position on many of the contentiobs. I understand that these documents, which are listed below have been served on the parties to this proceeding.

i) FEMA report of the deficiencies observed during the February 26, 1986 Exercise of the state and local plans to protect the public in the event of an accident at Seabrook, together with a cover letter dated April 4,1986 from Edward A. Thomas to Richard H. Strome transmitting and explaining the report.

11) Final Draft Report of the exercise of the emergency plans for Seabrook held February 26, 1986, together with a cover letter dated April 30, 1986 from Edward A. Thomas to Richard H. Strome.

iii) ~ Final Report of the exercise of the emergency plans for Seabrook held February 26, 1986, together with a cover letter dated June 6,1986 from Edward A. Thones to Richard H. Strome.

Iv) Final revies by FEMA and Regional Assistance Comittee (AAC) of the state and local plens submitted by New henpshire in December 1985, together with a cover '.ettr Jeed April 30, l 1936 fron Ecward A. Tho. mas to itichard H. Strome, l

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v) Draft FEMA and RAC Review of-the state and local plans submitted by New Hampshire in February 1986, together with a cover letter dated April 30, 1986 from Edward A. Thomas to Richard H. Strome.

vi) Final FEMA /RAC Review of the state and local plans submitted by New Hampshire in February 1986 together with a cover letter dated April 30, 1986 from Edward A. Thomas to Richard H. Strome.

vii) Draft FEMA /RAC Review of the New Hampshire submission of April 16, 1986, together with a cover letter dated June 2, 1986 from Edward A. Thomas to Richard H. Strome.

viii) Final FEMA /RAC Review of the New Hampshire submission on April 16, 1986, together with a cover letter dated August 8, 1986 from Edward A. Thomas to Richard H. Strome.

ix) Final FEMA /RAC Review of the state and local plans submitted by New Hameshire September 8,1986 together with a cover ietter from Edward A. Thomas to Richard H. Stroce dated December 12,* 1986.

c) Since FEMA has not yet developed a position on the contentions admit-ted with respect to this proceeding we are unable to articulate which documents may be used in support of such a position beyond our statement in our answer to Interrogatory A supra.

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

a) Name

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b) Address c) Present professional ' or employment af fil'iation d) Curriculum vita Answer S a, b, c, and d. Since FEHA has not yet identified-witnesses it cannot Provide the information requested.

4 I declare, under penalty of perjury, that the foregoing responses to the Seacoast Anti-Pollution League's Interrogatories and Request for Production of Documents are true.

N Edward A. Thomas, Division Cntef Natural & Technological Hazards Region One Federal Emergency Itaaagement Agency Dated March 18, 1987 at Boston, Massachusetts

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OBJECTION ,

The Federal ~ Emergency Management Agency (FEMA) objects generally to the

_ foregoing interrogatories to the extent.that th'ey call for the production or disclosure of the contents of draf t or privileged documents, except to-the extent that such documents have already been identified.or disclosed in the foregoing answers. See 10 C.F.R. 2.740(b)(1); cf. 10.C.F.R. { 2.790(a).

Respectfully submitred, D A -_ -

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. H.p3feph j Plynn' ' #

AssistantGeneralCo@sel Federal Emergency Management Agency 500 C Street S.W.

Washington, D.C. 20472 3

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