ML20154P657

Town of Salisbury Answers to Interrogatories Propounded by NRC Staff.* Certificate of Svc Encl.Related Correspondence

ML20154P657
Person / Time
Site:	Seabrook
Issue date:	09/21/1988
From:	Graham C MURPHY & GRAHAM, SALISBURY, MA
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#488-7144 OL, NUDOCS 8810030139
Download: ML20154P657 (10)

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'. RELATED CORRESI'Of,0f!)3 UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION U5NRC before the ATOMIC SAFETY LICENSING BOARD

'88 SEP 26 A9:35 GrF C':. : U...

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IN THE MATTER OF )

PUBLIC SERVICE COMPANY OF ) Docket l's 50-443-OL NEW HAMPSHIRE, ET AL ) 50-444-OL Seabrook Station Units 1,2) ) Off-site Emergency Planning

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Town of Salisbury's Answers to Interrogatories Propounded by NRC Staff Interrogatory fle Answer:

A. None B. None.

C. None.

Interrcontory #2:

Apswer:

A. t.hecugh M. Not applicable.

Interrogatory #3 ,

An;;wer ,

No such training has yet been contemplated as no such plans exist for the Town of Salisbury that have originated through local groups or officials. A committee is to be composed to promulgate such plans and the Town recognizes its obligation to supplemer.t these interrogatories in the event such plans are promulgated in draft or otherwise.

8910030139 800921 _1 PDR ADOCK 05000443 O PDR

Interrogatory 94:

Answer:

This information is not known to the Town and is likely to be answered by the Massachusetts Attorney General.

Interrogatory f5:

pnewer:

Thi,s answer applies to Salisbury only. The Town will not for the sake of this answer institute a region-wide information gathering campaign.

A. 16 regular police officers, 1 Chief; B. 3 part-time; C. 3 full-time; 19 call firefighters; D. None (some firemen and policemen may have first aid training);

E. None, except as mentioned above.

F. None.

G. None.

H. One part-time health inspector; I. No National Guard unit in Town; ,

J. 5-man school committee, 14 teachers; K. Other than as mentioned above, town employees include:

1. 3 highway department - full time;

2. Clerk, Treasurer, Accountant, Assessor, Building Inspector (part-time), 6 clerical employees, 3 part-time i clerical employees.

L. Fire mutual aid with other towns (all of which lie within 10 miles of Seabrook Station).

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j M. See L. above.

Interrogatory 96:

Answer:

There are no such documents identified by the Town of Salisbury in Interrogatory fl.

Interrogatory 97:

Answer:

This answer applies to Salisbury resources only.

A. 2 police cars, 1 pclice van; B. 4 fire trucks; C. no buses; D. no vans; E. 2 DPM trucks, 1 rubbish truck; F. No helicopters or airplanes; l G. One skiff; H. no sirens or public notification system; I. 22 rad!os (police), various beepera (call fire department);

J. None.

Interrogatory 18:

Antwor:

There is a National Guard unit in Newburyport. Town of  ;

Salisbury lacks any other information regarding its composition or resources.

Interrogatory 99:

Answer:

There are no such planspromulgated by salisbury or in effect through local officials in Salisbury.

s Interrogatory #10:

Answer:

There are no such documents in Town of Salisbury possession or Control.

Interrogatory #11:

Answer:

Salisbury has made no such provisions.

Interrogatory #12:

Answer:

Salisbury lacks the information required to respond to this interrogatory.

Interrogatory #13:

Answer:

There are none in Salisbury.

Interrogatory 914:

Annwer:

There are no such doctraeuts in ".*cwn of Salisbury possession or control.

Interro,qaterl j'951

.Answere, Salisbury is enaware of such provisions.

Interrogatory #16 f ,

Answer:

Salisbury has received no such funds.

Interrogatory fl7:

Answer:

There were no such documents described in response to Interrogatory fl.

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Interrogatory fl8:

Answer:

Salisbury will not undertake herein a treatise of Massachusetts law as it applies to emergencies particularly where such information is already ascertainable to the NRC Staff.

Salisbury has not adopted any by-law, rule, or policy with

, respect to "actions to be taken in the event of emergencies".

Salisbury, however, may be adopting such by-laws or rules and policies as a result of its current efforts to effect compliance with the emergency planning act. Town of Salisbury recognizes its obligation to supplement this answer in the event of adoption of any of the above on the part of the Town.

Interrogatory fl9:

Answer:

Salisbury Police Department regulations and Salisbury Police Contract (IDPO Local #450) provide that only a police officer

, appointed by the Selectmen is to perform the duties and

, functions of a police officer. Town of Salisbury has not adopted any cther laws or regulations permitting or prohibiting privato action in an ernrgency.

Interrogatory 620:

Answer:

A. None.

B. Traffic control, investigation, arrest, stopping vehicles within the Town, detouring traffic.

Interrogatory #21:

?; Answer:

The land area within 600 yards of and abutting the Gulf of Maine starting at the New Hampshire / Massachusetts state line and continuing southward to the southernmost point in the Town of Newbury that abuts the Gulf of Maine.

Interrogatory #22:

Answer:

Town of Salisbury does not have "data" in response to this information. Town of Salisbury has reviewed data provided in f the course of this litigation from other parties, but has not as yet formulated an estimate which it cares to adopt.

Interrogatory $23:

Answer: '

Town of Salisbury does not have in its possession a copy of the so-called "Broadway Mall" project which is proposed by the State Highway Department (District 5) with partial funding by the federal government. Town of Salisbury is unaware as to any approval of this project in t:he near f uture, but understands its purpose is to facilitate improved traffic flow in the central i recreational area of the beach.

Interrogatory $24:

Answer See number 23 above.

Interrogator $25: i Answers Massachusetts General Laws Chapter 41 charges the highway L

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surveyor with responsibility to keep the roads free of obstructions and impediments to travel.

Article XIII, Section 3. Town of Salisbury By-Laws requires the highway surveyor to remove whatever obstructs the public way.

Section 3 providea that no person shall obstruct a way without first obtaining a permit from the Selectmen.

Towr. of Salisbury contends that numerous other state statutes and regulations bear upon the enumerated activities, a more thorough list of which is likely to be provided by the Massachusetts Attorney General. Town of Salisbury contends that in light of the above, the compilation of the requested information for the purpose of this interrogatory is overburdensome and unjustified.

Interrogatory $26:

Answer:

No such studies have been originated or delivered to Town of Salisbury.

I nte rroga t or y_127 ';

Answer:

Town of .calisbury is unaware of sirens or other mechanisms other than the "fire horn" (which is being replaced with beepers) located within Salisbury which can be heard by the general public.

Interrogatory 028:

Answer:

Salisbury has performed no such study.

l Respectfully submitted,

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Charles P.VGraham, Town Counsel Town of Salisbury Murphy and Graham 33 Loir Street

. Newburyport, MA 01950  ;.

(508) 45-9051 I

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I intenrc/2088 00CKETED

• ~ 'RNi C CERTIFICATE OF SERVICE I, Charles P. Graham, Counsel for the Towni6'fLSall'abury, hereby certify that I made service of the within' document by mailing copies thereof, postage prepaid, to:

Lando W. Zech, Jr., Chairman Thomas M. Roberts Nuclear Regulatory Commission Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Kenneth M. Carr Frederick M. Bernthal Nuclear Regulatory Commission Nuclear Regulatory commission Washington, DC 20555 Washington, DC 20555 Kenneth C. Rogers Nuclear Regulatory Commission Washington, DC 2055 Alan S. Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Thomas S. Moore Mr. Richard R. Donovan Atomic Safety and Licensing Federal Emergency Management 4

Appeal Panel Agency U.S. Nuclear Regulatory Federal Regional Center Commission 130 228th Street, S.W.

Washington, DC 20555 Bothell, WA 98021-9796 Judge Emmoth A. Luebke Diane Curran, Esquire Atomic Safety and Licensing Ellen Weiss, Esquire Board Panel Harmon & Weiss 550 Friendship Boulevard suite 430 Apartment 1923N 2001 S Street, N.W.

Chevy Chase, MD 20815 washington, DC 20009 Dr. Jerry Harbour Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of the Executive Legal Board Panel Director U.S. Nuclear Regulatory U.S. Nuclear Reulatory ,

Commission Commission Washington, DC 20555 Washington, DC 02555 Adjudicatory File John Trafficonti, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Docket (2 copies) Department of the Attorney U.S. Nuclear Regulatory General Commission one Ashburten Place, 19th Fir.

Washington, D.C. 02555 Boston, MA 02108

p.

Atomic Safety and Licensing R. Scott Hill-Whilton, Esq.

Appeal Board Panel Lagoulis, Clark, Hill-Whilton U.S. Nuclear Regulatory & McGuire Commission 79 State Street Washington, DC 02555 Newburyport, MA 019S0 Paul McEachern, Esquire Edward Molin, Mayor Matthew T. Brock, Esquire City of Newburyport Shaines & McEachern City Hall 25 Maplewood Avenue Newburyport, MA 01950 P.O. Box 360 Portsmouth, NH 03801 Senator Gordon J. Humphrey Betsy St. Andre, Esquire One Eagle Square, Suite 507 Kopelman & Paige Concord, NH 03301 77 Franklin Street Attn Herb Boynton Boston, MA 02110 H. Joseph Flynn, Esquire Mr. William S. Lord office of General Counsel Board of Selectmen Federal Emergency Management Town Hall Agency Friend Street 500 C Street, S.W. Amesbury, MA 01913 Washington, DC 20472 Judith H. Mizner, Esquire Thomas G. Dignan, Esq.

79 State Street, 2nd Floor Ropes end Gray Newburyport, MA 01950 225 Franklin Street Boston, MA 02110 t

Signed under pains and penalties of perjury this 21st day of September, 1988.

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Charles P. Graham, Esquire I

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