ML20008D472

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Intervenor Exhibit I-MAG-104,consisting of Applicant 890109 Voluntary Responses to Town of Hampton 881223 First Set of Interrogatories & Request for Production of Documents Re 880628-29 Exercise.Ropes & Gray Encl
ML20008D472
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 05/25/1989
From:
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
HAMPTON, NH
References
OL-I-MAG-104, NUDOCS 9003050155
Download: ML20008D472 (14)


Text

{{#Wiki_filter:. -,7,. M ~ ATTACHPENT 6 do-+/aflMy'-0f 6l2.Sgy ? COLKEIE0' 05NRC '90 JAN 18 P4 :27 gFFICE OF SECRf TARY dk h r b, 1989 ? UNITED STATES OF AMERICA s: t NUCLEAR REGUIATORY COMMISSION before the ATOMIC SAFETY AND LICENSING SCARD l In the Matter of ) ) PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL ) (Off-Site Energenef-(Seabrook Station, Units 1 and 2). ) ' Planning Issues)' ) ) I APPLICANTS' VOLUNTARY RESPONSES TO TOM'S INFORMAL DISCOVERY REQUESTS on December 23, 1988, the Town of Hampton ("TCH")_ served its First Set of Interrogatories and Request for the-Production of. Documents to the Applicants,.on the June 28-29, 1988 Exercise. Applicants volunteer the-following responses. Am To Instmactions For Une l- ~ [ All exercise-related documents that Applicants' retained (/ after the exercise are already available:and have been since [ September 29, 1988, and many of them since July, 1988. Applicants identify herein the documents produced by a summary description. The burden and expense of " identifying" h300155090525 O DOCK 05000443 PDR IS'IA b { (j t[

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.~~.--- -. _._-. ~ - - ~. -... M/ /4 4 s: l^ l by TON's definition each document produced would be excessive and or justified in the circumstances. As To Specific Raauesta Interroaatorv No. 1 -Identify all teachers who performed or participated in protective actions for school children during the Exercise. For each, states-(a) The nature and extent of the participation or function performed (b) The' purpose of the performance or participatient . (c) The school (s) for which each teacher performed or participated (d). The section(s) of the NMRERP tested or exerciseds (e) Whether in Applicants' opinion the performance or participation was adequate, and the basis for that opinions (f) Whether-a log, record, or other documentation concerning the Exercise participation was prepared by or on-t behalf of each teachert l (g) Identify and produce all documents upon-which-i you rely to answer this interrogatory.- f Annlicants' Reanonna i To Applicants' knowledge, no teachers participated in demonstrating protective actions for school children during the Exercise as schools were not in session. Interroaatory No. 2 h Identify all administrators and school personnel other than teachers who performed or participated in protective actions for school children during the Exercise. For each, states s e

. ~ -. -. -g M y ) s (a) The nature and extent of'the participation er function performedt (b) The purpose of the performance or participations 1 (c) The school (s) for which each administrator and school personnel performed or participated: (d) The section(s) of the NMRERP tested or exercised (e) Whether in Applicants' opinion the performance or participation yas adequate, and the basis for that opinion; (f) Whether a log, record, or other documentation concerning the Exercise participation was prepared by or on behalf of each administrator and school personnelt l' (g) Identify and produce all documents upon which you rely to answer this interrogatory, 3 Amelicants' Rennensa 4 (a) Identification of persons participating in the L Exercise cannot be made in the form requested'because the i_nformation is not available to the Applicants. Based on a review'of existing player and controller materials generated during the graded exercise, at least one administrative representative of each of the five Supervisory Administrative. Units and an adminis'trative representative of the Phillins-Esater Academy participated in the exercise. Applicants are unaware of the identities of these personnal with the exception of George Tucker, Dean of reculty, Phillips Exeter Academy. The administrative representatives received at

s 'e 'q 3-i s, least one talenhone call from New Haacshire energency response personnel during the exercise. (b) . The purpose of this participation was to. demonstrate the capability to notify school administrative personnel of emergency conditions: to demonstrate the -i capability to convey precautionary or protective action 1 decisions to schools; and to demonstrate the capability to determine transpostation resource requirements of the schools. (c) (1) SAU 16 i - Exeter High School i - Exeter Junior High School - Lincoln St. School - Main St. Middle School - Region 18 Vocational School - Swasey Central School ) - Newfields Elementary School - Strathan Memorial School l J (2) SAU 21 1 - Winnacunnet High School t - Acadeay Junior High School - Centre School - Marsten School - Seabrook Elementary School l' l l L l 1

fV g -Y ~/. s (3) Portsmouth Superintendent of Schools - Portsmouth Senior High School. - Portsmouth Elementary School - Brackett Elementary School - Sherburne Elementary School - Dondero Elementary School - Little Harbor Elementary School - New Franklin Elementary School. - Wentworth Elementary School (4) SAU 17 - Sanborn Regional Middle School L - Newton Memorial' School 4 - Sanborn Regional High School I - Bakie School 1-l (5) SAU 50 4 j - Greenland Central School L - Rye Elementary ~ - Rye Junior'High School (6) Phillips Exeter Academy, George Tucker, i P Dean of Faculty (No further identification available). (d) Volume 4.8.-State Agency Procedures v - Department of Education - Energency Response Procedures S l l 1 . g. -

l4l ll? ( i r - Director of Pupil Transportation Safety - Energency Response Procedures-NHRERP Town Specific Volumes - Section II, Emergency Response Functions --Section III, Emergency Preparedness Responsibilities - Section IV, Emergency Procedures - Transportation coordinator's Procedure - Appendix F, Special Facilities Plans e (e) As the Exercise' Report for-the June 1988 FEMA graded Exercise states, "The State of New Hampshire demonstrated the ability and resources necessary to implement Protective Actions for school children." (p. 172) (f) As far as can be determined, no log was kept j by or on behalf of administrators and school personnel. (g) Documentation is contained in the following documents.which have been made available to the parties: 1 (1) New Hampshire Radiological Response Plan (2) FEMA Exercise Report - Seabrook Station 1988 Graded Exercise (3) Participating local Emergency Operations Center Logs (4) Controller Reports for the participating ] towns q 1 1 i

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~ -... iiL ~;. :. I., I'. I 1 4 l L i J j ) i 1 b i . t Intarrogatory No. 5 For each school in the New Hampshire.EPE, identify all' communications during the' Exercise between teachers or other i- school personnel and the state of.New Hampshire, its agents or contractors, concerning, protective actions.for school children. With< respect-to each communications (a) Identify the person asking the communications _(b) The method of communication; (c) Time (d) Purpose 'i I E. 2 ,, - + ~ - r v

G. , M... - _ faf /&&1 ~ 1 'o L2 (e) Recipients (f) Responset (g) Any actions taken as a result of the communications and (h) Identify and produce all documents upon which you rely to answer this interrogatory. Ann 11eants' amenanna Identification of persons in the context of'this interrogatory gannot be made in the form requested because the information is not available to the Applicants. A list-( of communications by New Hampshire emergency response personnel pertaining to protective actions for school children is attached as Attachment 1. Documents relied upon to answer this interrogatory have been made available. I r 4 8+e oli = "We 3 ~

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March 20, 1989 R Mr. Matthew Brock, Esq. Office of the Massachusetts Attorney General Nuclear safety Unit McCormack State Office' Bldg. One Ashburton; Place, Boston 02108-1698 ? Ret Clarification of Applicants' Voluntary Responses to 1 i TON's Informal Discovery Requests (January 9,-1989) l

Dear Matt,

o I am sending thi6 1=LLor Lu respond to your letter dated today, in:which you ask for clarification of Applicants voluntary Responses To TON's Informal Discovery Requests R idated Januar Responses"). y.9, 1989)[ hereinafter " Applicants' Voluntary Applicants address your inquiries concerning Interrogatories 8 and 9 by responding to the paragraphs'you have provided as follows:- A. Applicants confirm that prior _to the;date of the d Exercise, Appli' cants or their agents contracted with'3 bus companies to provide all-of the buses and; drivers that would participate in the Exercise. The bus companies that agreed to provide these transportation resources, and ths' number of J buses each company agreed to provida for the Exercise, are identified in Applicants' Response to Interrogatory 8(d). J B., Applicants confirm that prior to the date of the l Exercise,: Applicants or their agents also contracted-with two ambulance companies to provide all of the ambulances and ambulance drivers who would participate in-the Exercise. These ambulance companies and drivers are identified in . Applicants' Supplemental Response to Interrogatory 8(f), ' dated January 27, 1989. j c.. Applicants confirm that during the Exercise each of these bus and ambulance companies provided vehicles and drivers in compliance with the contracts described above. ..i i

g; bp 20) s 1 of EGE5 3 W 'D 2 gg Roct0 0 0nAy Mr. Matthew Brock,fEsq. March 20, 1989 You have also asked for clarification on whether the phone calls numbered 10 through 14 and listed on page 2 of j i of Applicants' voluntary Responses-were actually .made. Applicants state that the telephone calls listed next j .^ to numbers 10, 11, 12, and 14 were simulated. Within the ECC,. individuals assigned to notify the listed schools made phone calls,.and data supplied by controllers was received.- -{ To the best of Applicants' knowledge, and based on an inspection of Exercise Records, the calls listed next to l number 13 were actually made to school personnel. believe the recipient of the call to the swamy school wasApplicants principal Margaret Griffen, and the recipient at the Country Kids school was Joyce Gal,lant. I believe from speaking with you both today and last Monday that the above information should take care-of your questions. Sincerely, Geoffre C. Cook i u L x ? _}}