ML20150D162

Applicant Request for Production of Documents of Fema.* Requests Includes All Documents Created Since Jul 1985 Re Contact Between EA Thomas & Ref Parties Concerning Nuclear Power,Emergency Planning &/Or Plant.Related Correspondence

ML20150D162
Person / Time
Site:	Seabrook
Issue date:	03/15/1988
From:	Selleck K PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Federal Emergency Management Agency
References
CON-#188-5912 OL, NUDOCS 8803230149
Download: ML20150D162 (6)

Text

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[f/h b guemea MP March 15, 1988 18 HM 21 PS :28 UNITED STATES OF AMERICA 0FFICE 0: 5f cq uj -

NUCLEAR REGULATORY COMMISSION 00CKEhm;3 n,;y;cp' BRANCH.

before the ATOMIC SAFETY AND LICENSING BOARD L

)

In the Matter of )

)

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

) 0.!f-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues

)

APPLICANTS' REQUEST FOR PRODUCTION OF DOCUMENTS OF FEDERAL EMERGENCY MANAGEMENT AGENCY Pursuant to 10 CFR 5 2.741, Applicants request that the Federal Emergency Management Agency (FEMA) provide copies of, or make available for inspection and copying at a designated time and place, the documents identified below.1 As used herein, the term "document" or "documents" means ,

all tangible things, whether handwritten, typed, printed, or otherwise produced and all nonidentical copies thereof in the possession, custody, or control of any of FEMA's officials, agents or employees, including, but not limited to, memo-randa, communications, correspondence, notes, field notes, worksheets, disks, tapes, studies, reports, summaries, 1 In accordance with the discussion among the Atomic Safety and Licensing Board and parties on February 10, 1988, II. 9701-9710, Applicants request that the manner of production and any other issues that may arise be handled by telephone as expeditiously as possible.

8803230149 800315 PDR ADOCK 05000443 j $0 3 G PDR l-m , .-

instructions, charts, schedules, photos, sketches, maps, records, accounts, machine readable records and computer translations, and reports or notes of consu'.tants.

As used herein, the term "contact" means any type of communication, written or oral.

As used herein, the term "The Commonwaalth of Massachusetts" means all state offices, agancies, and departments, including those of the Executive, Civil Defense, and the Attorney General.

If any privilege or work product immunity is claimed as a ground for not producing any document, state for each such document its preparation date(s), author (s), addressee (s),

recipient (s), custodian (s), title (s), number of pages, and l

subject matter to the extent not privilegcd, as well as the basis for withholding it.

REOUEST NO. 1 All documents created since July, 1985, relating to any contact between E. A. Thomas and any official, employee, or representative of The Commonwealth of Massachusetts on any matter relating to nuclear power, emergency planning, and/or Seabrook Station.

EEOUEST NO. 2 All documents relating to any contact between any official, employee, or representative of FEMA (including E. A. Thomas) and any official, employee, or representative of The Commonwealth of Massachusetts regarding the substance

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of FEMA's or E. A. Thomas's testimony in the above-captioned proceeding.

REQUEST NO. 3 All documents created since July, 1985, regarding any contact between any FEMA official, employee, or representative (including E. A. Thomas) and any official, employee, or representative of The Commonwealth of Massachusetts regarding the views of Regional Assistance Committee members on the issue in the above-captioned matter of shelter for the summer beach population.

Applicants do not request production of any of the following documents which may otherwise be called for in the above requests:

1. Transmittal letters or other documents dealing solely with the transmittal of FEMA documents which have been served on the parties in the above-captioned matter.

2. Documents which have been filed with the Docketing and Service Branch of the Office of the Secretary of the Nuclear Regulatory Commission.

3. Documents which fall under one of the above requests solely by virtue of the appearance of a representative of The Commonwealth of Massachusetts on a certificate of service or service list.

By their attorneys,

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Thbm/= d. dig 5an, Jr.

George H. Gc.?ald Kathryn A. Solleck Ropes & Gray 225 Franklin Street Boston, PA 02110 (617) 423-6100

'4 CERTIFICATE OF SERVICE h)kC I, Kathryn As Selleck, one of the attorneys for the Applicants herein, hereby certify that on March 15, 1988l$$ KM 21 PS :28 made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or ,. .

where indicated, by depositing in the United States mai1 00ChiibN.Ib$lbf~

first class postage paid, addressed to): BRANCH Administrative Judge Ivan W. Smith Robert Carrigg, Chairman Chairman, Atomic Safety and Board of Selectmen Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Judge Gustave A. Linenberger Diane Curran, Esquire Atomic Safety and Licensing Andrea C. Forster, Esquire Board Panel Harmon & Weiss U.S. Nuclear Regulatory Suite 430 Commission 2001 S Street, N.W.

East West Towers Building Washington, DC 20009 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 l Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the General Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building One White Flint North, 15th Fl.

4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852

• 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 l Washington, DC 20555 l

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' ig Philip AP.rens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire

-Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney 25 Maplewood Avenuo General P.O. Box 360 One Ashburton Place, 19th Flr.

Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

• Senator Gordon J. Humphrey Mr. Angie Machiros U.S. Senate Chairman of the Board of Washington, DC 20510 Selectmen (Attn: Tom Burack) Town of Newbury Newbury, MA 01950

• Senator Gordon J. Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301

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'st Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region I Silverglate, Gertner, Baker, 442 John W. McCormack Post Fine, Good & Mizner Office and Court House 88 Broad Street Post Office Square Boston, MA 02110 Boston, MA 02109 Charles P. Graham, Esquire McKay, Murphy and Graham 100 Main Street Amesbury, MA 01913 +

K4thq9n'A. Selleck

(*= Ordinary U.S. First Class Mail)

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