ML20155G853
| ML20155G853 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/30/1986 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| Shared Package | |
| ML20155G834 | List: |
| References | |
| OL, NUDOCS 8605070159 | |
| Download: ML20155G853 (4) | |
Text
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WTED CUw.wunot wci UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSICtN MAY -5 m; :o; BEFORE THE ATOMIC SAFETY AND LICENS{f g gpKD 00cnin;;
,h','
BRANC
)-
Public Service Company of New
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Hampshire, et. al.
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Docket Nos.
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50-443, -444 (Seabrook Station, Units 1 and 2)
)
b NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S FIRST SET GF INTERFOGATORIES AND REQUESTS FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANTS CN THE NEW HAMPSHIRE RADIOLCGICAL EMEFGENCY RESPCNSE PLANS INSTRUCTIONS FOR USE The following interrogatories are to be answered in writina and under oath by an employee, representative or agent of the Applicants with personal knowledge of the facts or information j
requested in each interrogatory.
We remind you of your 1
4 obligation to supplement answers to interrogatories, under 10 C.F.R.
S 2.740(e)(1) and (2).
The following definitions shall apply to these inte r rog a to r ie s:
1.
" Document" shall mean any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all i
correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other U
8605070159 860430 PDR ADOCK 05000443 l
G PDR
J.
S.
means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, d iag rams, forms, manuals, brochures, lists, publications, d raf ts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other. written or graphic materials of any nature whatsoever.
2.
"Identi f y" w ith t er,pect to any document shall mean 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 suostance and nature of the document, and the present custodian of the document and of any and all copies of the document.
3.
" Identify" with respect to any action or conduct shall mean state the following regarding any such action or conduct:
the person or persons proposing and taking such action; the date such action w'as proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; any document recording or documenting such action.
4.
" Describe" with respect to any action or matter shall mean state the following regarding such action or matter:
the substance or nature of such action or matter; the persons participating in or having knowledge of sucn action or matter; the current and past business positions and addresses of such persons; the existence and location of any and all documents relating to such action or matter.
I i
L
. INTERROGATORIES:
1.
With respect to each contention and subpart thereof admitted by the Licensing Board's order of April 1, 1986, please provide the following information:
a.
What is the Applicants' position with respect to each contention and its subparts?
Describe in detail the reasons for your position, b.
Identify and provide access to all documents on I
which you rely during this proceeding to support your position on each of.these contentions.
This includes all documents used in answers to these interrogatories, summary aisposition motions,
-testimony, and cross-exacination of witnesses during hearings.
d.
Identify all persons on whose factual knowledge,
)
opinions, or technical expertise you rely for your position on each contention and subpart thereof.
c.
Identify all persons you may call as witnesses on each of these contentions during these proceedings; describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.
2.
Please identify and provide access to all documents not identified in response to interrogatory 1(b) that evaluate or
- discuss the acequacy of emergency planning and preparedness with respect to any of the issues admitted for litigation by the Licensing Board's order of April 1, 1986.
I I
+
.+. Respectfully submitted, Diane Curran
!! aft 1CN & WEISS 2001 S Street, N.W.
Suite 430 Washington, D. C.
20009 (202) 328-3500 April 30, 1986 3