ML20151G671

Commonwealth of Ma Atty General Second Set of Interrogatories Re Siren Contentions.* Related Correspondence

ML20151G671
Person / Time
Site:	Seabrook
Issue date:	07/18/1988
From:	Jonas S MASSACHUSETTS, COMMONWEALTH OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#388-6781 OL-1, NUDOCS 8807290079
Download: ML20151G671 (3)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00gKTED before the T '

'88 JA. 22 Pl2:16 AIOMIC SAFETY AND LICENSING BOARD OFFtLL W E WiM1 ,

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BRANCH 1

l I ) Docket-Nos.-

In the Matter of ) 50-443-OL-1

) 50-444-OL-1 PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, ET AL ) (On-site Emergency (Seabrook Station, Units 1 and 2) ) Planning and Safety

) Issues)

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THE MASSACHUSETTS ATTORNEY GENERAL'S SECOND SET OF INTERROGATORIES REGARDING SIREN CONTENTIONS General Definitions and Instructions

1. "Document" meens any written or graphic mctter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, l recordings, whether electronic or by other means, computer 1

data, computer printouts, photographs, microfilm,

.nicrofiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, 8807290079 880718 PDR ADOCK 05000443 Tj Q PDR N' O

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ca}endars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

2. "Identify" with respect to any document means'to state-the.

following respecting the document: its 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, nature and consents of the document, and the present custodian of the document and of any and all copies of the document.

3. "Identify" with respect to a commercial entity or individual metinF, to state:

a. the name and mailing address of the party.

b. the present professional ot employment affiliation of the 'rty,

c. the ch: ent employment or professional relationship between the Applicant and the party, including the dates of that relationship.

4. "Affiliate", as used in the context of Interrogatory number two (2) refers to any party, whether a commercial or an individual entity, which provided any service, goods, consultation, information or assistance or who entered into any contract, agreement or other document or communication related to the procurement, use or location of any pre-selected acoustic area or VANS staging area.

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Interrocatories 1.-~Please identify each. person, whether a commercial entity orEan' individual, with whom the-Applicants or their agent (s)1 contracted or. agreed in writing or orally for the sale,. procurement,~1 ease or other use of any,and all of the.

pre-selected acoustic' areas and staging. areas.

2. Please identify a'll documents which relate to any of the contracts and/or agreements referred to in Interrogatory No. 1.

Respectfully submitted, JAMES M. SHANNON ATTORNEY GENERAL COMMONEWEALTH OF MASSACHUSETTS Dy: - "l15- s' 11 Stephen A. Jonas Pamela Talbot s Assistant Attorneys General Department of the Attorney General Nuclear Safety Unit One Ashburton Place Boston, MA 02108 DATED: July 18, 1988 e

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