ML20155G870

First Set of Interrogatories & Requests for Production of Documents Re State of Nh Radiological Emergency Response Plans.Certificate of Svc Encl.Related Correspondence

ML20155G870
Person / Time
Site:	Seabrook
Issue date:	04/30/1986
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	NRC
Shared Package
ML20155G834	List: ML20155G830 ML20155G853 ML20155G857 ML20155G863 ML20155G870
References
OL, NUDOCS 8605070169
Download: ML20155G870 (6)

Text

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00tMcicp trwur UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI MY -5 A;1.02 BEFOBE TiiE ATOMIC SAFETY AND LICErdffffC MARD UTCV - i nu, ,

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BRANcn Public Service Company of New

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ph Hampshire, et. al. ) Docket Nos.

) 50-443, ~444 (Seabrook Station, Units 1 and 2) )

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NEW ENGLAND COALITION ON NUCIEAR PCLLUTION'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR Tile PRODUCTION OF DOCUMENTS TO THE NUCLEAR REGULATORY COMMISSION ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS INSTRUCTIONS FOR USE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the f Nuclear Regulatory Commission (" Commission" or "NRC") with personal knowledge of the facts or information requested in each interrogatory. We remind you of your obligation to supplement answers to interrogatories, u,nder 10 C . F . R . S 2.740(e)(1) and (2).

The following definitions shall apply to these inte r roga tor ies:

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 correspondence, letters, telegrams, agreements, notes, contracts, instructions, repor ts, demands, memoranda, da ta, schedules, groien MM}h3 G

notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks , d iar ies, sketches, d iagrams , forms, manuals, brochures, l is ts , publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

2. " Identify" with respect to any document shall mean to state the following respecting the document: its title, its date, the author of the document, the persen to whom the document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any ano all copies of the document.

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3. " Identify" with respect to any action or conduct shall mean state the following regarding any such activt or condu c t:

the person or persons proposing and taking such action; the date such action was 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 such action or matter; the current and past business positions and addresses of such

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persons; the existence and location of any and all documents relating to such action or matter.

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 NRC 's 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 which you rely curing this proceeding to support your position on each of these contentions. This includes all documents used in answers to these interrogatories, summary disposition motions, testimony, and cross-examination 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.

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2. Please identify and provide access to all documents not identified in response to interrogatory 1(b) that evaluate or discuss the adequacy 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.

Respectfully submitted, Diane Curran IIARMON & WEISS 2001 S Street, N.W.

Suite 430 Washington, D. C . 20009 (202) 328-3500 April 30, 1386 9

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CERTIFICATE OF SERVICE I certify that on April 10, 1986, copies of NECNP's Interrogatories and Requests for the Production of Documents to Applicants, the NRC, FEMA, and the State of New Hampshire, were served on the following by first-class mail or as otherwise indicated:

He len floy t , Esq. Rep. Ro be r ta C . Pevear Administrative Judge Drinkwater Road

- Atomic Sa fety and Licensing Board Ilamp ton Fa lls, Nil 03844 U.S. Nuc} aar Regulatory Commission

Wa sh i ng ton , D.C. 20555 Dr. Emmeth A. Lu ebk e Ph illip Ah rens, Esq.

Administrative Judge Assistant Attorney Atomic Sa f ety and Licensing Board General U.S. Nuedda t R State !!ouse, Station # 6 Washington, TD .gtulatory C. 20555Commission Augusta, ME 04333 Cr. Jerry Harbour Pober t A. Backus, Esq.

Administrative Judge 111 Lowell Street Atomic Sa fety and Licensing Manchester, N!! 03105 Board 4

U.S. Nuclear Regulatory Commission ** Thomas G. Dignan, Esq.

Washington, D. C . 20555 R.E. Gad, III, Esq.

Ropes and Gray Atomic Safety and Licensing 225 Franklin Street Board Panel Boston, MA 02110 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel Mrs. Anne E. Goodman U.S. Nuclear Regulatory Board of Selectmen Commission 13-15 New Market Rd. Washington, D.C. 20555 Durham, Nil 03824 Docketing and Service *Sherwin E. Turk, Esq.

U.S. Nuclear Regulatory Office of the Executive Commission Legal Director Washington, D. C . 20555 U.S. Nuclear Regulatory Commission William S. Lord, Se lec tman Washington, D. C. 20555 Town Hall - Friend Street Amesbury, MA 01913 Mr. Angie Machiros Chairman, Board Jane Dough ty Board of Selectmen SAPL 5' Ma rket St.

Portsmouth, NH 03801

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Carol S. Sneider, Esquire *ll. Joseph Flynn, Esq.

Assistant Attorney Of fice of General Coundel General Federal Emergency Department of the Attorney Management Agency General 500 C Street, SW "I Ashburton Place, 19th Floor Washington, D. C . - 20472 Boston, MA 02108

• • George Dana Bisbee, Esq.

Edward A. Thomas Stephen E. Me rrill, Esq.

FEMA Assistant At torneys General 442 J.W. McCormack (POCH) State !!ouse Annex Boston, MA 02109 Concord, Nil 03301 J. P. Nadeu, Se lec tma n Allen Lampert Town of Rye Civil Defense Director 155 Washington Road Town of Brentwood Rye, Nil 03870 Exeter, NH 03G33 Sandra Gavutis Richard A. Ilampe, Esq.

Town of Kensington llampe and McNicholas RFD 1 Box 1154 35 Fleasant Street East Kensington, NH 03827 Concord, Nil 03301 Richard E. Sullivan, Mayor Gary W. Ilolmes, Esquire Ci ty lia ll  !!olmes & Ellis Newburyport, MA 01950 47 Winnacunent Rd Hampton, Nil 03842 3 Alfred V. Sargent, Chairman Board of Selectmen William Armstrong Town of Salisoury, MA 01950 Civil Defense Director 10 Front Street

, Senator Gordon J. !! ump hr ey Exeter, NH 03833 U.S. Senate Washington, D. C . 20510 Calvin A. Canney (Attn: Tom Burack) City Manager City Itall Selectment of Northampton 126 Daniel Street Town of Northampton Portsmouth, NH 03801 New Hampshire 03862 Senator Gordon J. Humphrey Mathew T. Br ock , Esq.

1 Pillsbury Street Shaines & McEachern Concord, NH 03301 P.O. Bo x 3 60 tiaplewood Ave.

Michael Santosuosso, Ch airma n Portsmouth, Nil 03801 Board of Selectmen Jewell St., RFD #2 South flampton, N!! 03842

• - By Me ssenger

• • - By Federal Express A

Diane Curran