ML20155H018

Town of Amesbury First Set of Interrogatories & Request for Production of Documents to NRC on Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl. Related Correspondence

ML20155H018
Person / Time
Site:	Seabrook
Issue date:	10/06/1988
From:	Brock M AMESBURY, MA, SHAINES & MCEACHERN
To:	NRC
References
CON-#488-7247 OL, NUDOCS 8810180222
Download: ML20155H018 (9)

Text

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. o ,n UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

• 2 DCT 11 P4 :46 Before the ATOMIC SAFETY AND LICENSING BOARD [

) October k , 1988 In the Matter of )

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

) Off-Site Emergency' (Seabrook Station, Units 1 and 2) ) Planning

)

TOWN OF AMESBURY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NUCLEAR REGULATORY COMMISSION ON THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES (SPMC)

INSTRUCTIONS FOR USE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the 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, under 10 CPR 52.740(e) (1) and (2).

All documents identified in answer to these interrogatories shall be produced within thirty (30) days after service of this Request at the offices of SHAINES & McEACHERN, 25 Maplewood Avenue, Portsmouth, New Hampshiro 03801. Alternatively, production of documents may be 4 made within thirty (30) days after service of this Request by 8810100222 PUR ADOCK h NOO PDR 43 p0)

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forwarding copies to the offices of SHAINES & McEACHERN, P.A., 25 ,

Maplewood Avenue, portsmouth, NH 03801.

The following definitions shall apply to these interrogatorier:

1. "Document" shall mean any written or graphic matter or i

communication, however produced or reproduced and is intended to be comprehensive and include without limitation any and all correspondence, lottars, telegrams, agreements, notes, contracts, i

instructions, reports, demands, memoranda, data, schedules, 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, diaries, sketches, diagrams, forms, manuals, brochures, <

lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatroever.

2. "Identifv" with respect to any document shall mean to state the following respecting the document: its titic, its date, the i

author of the document, the person 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 i of any and all copies of the document.

3. "Identifv" with respect to any action or conduct shall mean I

state the following regarding any such action or conduct: the person or persons proposing and taking such action; the date such action was proposed and/or taaen; all persons with knowledge or information about 2

l such action; the purpose or proposed effect of such action; to identify any document recording or documenting such action, conduct or matter.

4. "Identifv" when used in reference to a natural person means to set forth the following:

(1) his name; (2) his last known residential address; ,.

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(3) his last known business address; (4) his last employer; ._,

(5) his title or position; (6) his area of responsibility; (7) his business or profession; (8) the nature of his association with NRC; and (9) if any of the above information is changed subsequent to the time period referenced in a particular interrogatory, set forth in the answer, and label appropriately, current information as well as the information applicable to the time period referenced in the interrogatory.

5. "Identifv" when used in reference to a corporation or other entity that is not a natural person shall mean to set forth the following:

(1) the full name of such person, including its legal name and any assumed or trade names under which it transacts or has transacted business; (2) the nature or form of such a person, if known; 3

(3) the address of its principal place of business or the principal place where such person is to be found; (4) whether NRC has or has had any relationship or affiliation with such person, its affiliates or subsidiaries, and, if so, a description of such relationship; and (5) if any of the above information has changed subsequent to the time period referenced in a particular interrogatory, set forth in the answer, and label appropriately, current information as well as the information applicable to the time referenced in the interrogatory.

6. If NRC objects to or claims a privilege (attorney-client, work product, or other) with respect to any interrogatory or document request, in whole or in part, or seeks to withhold documents or information because of the alleged proprietary nature of the data, please set forth all reasons and the underlying factual basis for the objection or claim of privilege in sufficient detail to permit the Licensing Board to determine the validity or the objection or claim of privilege. This description by NRC should include with respect to any document: (1) author, addressor, addressee, recipients of indicated and "blind" copies together with their job titles; (2) date of preparation; (3) subject matter; (4) purpose of which the document was prepared; (5) all persons to whom distributed, shown, or explained; (6) present custodian: (7) all persons believed to have a copy of the document; and (8) the nature of the privilege or objection asserted.

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If an objection to any portion d an interrogatory or document request is made, the remaining portion, not deemed objectionable, shall be fully answered.

INTERROGATORIES

1. With respect to each contention and basis admitted by the Licensing Board regarding the SPMC, please provide the following information: , -

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a. What is the NRC's position with respect to each contention ancl._ basin? For each, identify the reasons for taking your position.

b. If the NRC has not yet taken a position on any contention or basis, identify, for each, the information which must be provided, and/or the conditions or contingencies which must be satisfied, before NRC may take a position.

c. Identify all persons you may call as witnesses concerning the SPMC litigation; the particular contention or basis en which each will testify; the subject matter on which ench will j

testify; the substance of each witness' testimony; the grounds for each opinion or testimony; and identify any documents, indicating the relevant portion and citation, that each witness will rely upon to support his testimony, and any documents which NRC '1111 offer into evidence through each witness.

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d. Identify all persons on whose factual knowledge, opinions, or technical expertise you rely for your position on each 5

contention and basis. For each, state the substance of the knowledge, opinions, or technical expertise relied on.

2. Please identify and produce all documents that NRC, or itr agents or contractors, has authored or compiled, and that discuss the adequacy or inadequacy of the SPMC, or any of the contentions or bases admitted for litigation by the Licensing Board on the SPMC.

-- 3. As referenced in 10 C.F.R. 5 50. 47 (c) (1) (iii) (B) , identify the "best efforts" that, in NRC's opinion, the Town of Amesbury will make in the event of a severe, fast-release radiological emergency.

Identify and produce all documents. and state all facts and opinions, upon which NRC relies to support this answer.

4. Identify and produce all documents (1) on which you rely to answer these interrogatories or (2) which you intend to offer as exhibits in this proceeding for any purpose.

Respectfully submitted, TOWN OF AMESBURY By Its Attorneys SHAINES & McEACHERN Professional Corporat-lon

% s DATED: @ W By \

Matthew T. Brock 25 Maplewood Avenue Portsmouth, NH 03801 (603) 436-3110 ,

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a.. .n..t c n:0

'E8 m;T 11 P4 :46 CERTIFICATE OF SERVICE ,.y : _

boCe, . s . '

I, Matthew T. Brock, one of the attorneys Amesbury herein, hereby certify that on October foF'Jthe Town of 6, 1988, I made service of the foregoing document, TOWN OF AMESBURY S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NUCLEAR REGULARTORY COMMISSION ON THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES (S PMC) , by depositing copies thereof in the United States Mail, first class postage prepaid for delivery (or, where indicated, by Express Mail, prepaid) addressed to:

Ivan Smith, Esq., Chairman Dr. Jerry Harbour

-- _ Atomic Safety & Licensing Board Atomic Safety & Licensing Board (Off-Site) (Off-site)

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.

East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Judge Gustavo A. Linenberger, Jr.

Atomic Safety & Licensing Board Atomic Safety & Licensing Appeal Board Panel (Off-Site) U.S. Nuclear Regulatory Comm.

U.S. Nuclear Regulatory Commission Washington, DC 20555 East West Towers Building 4350 East West Highway

• Thomas Dignan, Esq.

Bethesda, MD 20814 George H. Lewald, Esq.

Adjudicatory File Kathryn A. Selleck, Esq.

Ropes & Gray Atomic Safety & Licensing Board 225 Frankin Street Panel Docket (2 copies) boston, MA 02110 U.S. Nuclear Regulatory Commission East West Towers Building Carol S. Sneider, Esq.

4350 East West Highway Stephen H. Oleskey, Esq.

Bethesda, MD 20814 Allan R. Fierce, Esq.

Stephen E. Merrill, Esq. Department of the Atty. General George Dana Disbee, Esq. One Ashburton Place Boston, MA 02106 Office of the Attorney General State House Annex -

Diane Curran, Esq.

Concord, NH 03301 Andrea C. Ferster, Esq.

Harmon & Weiss 2001 S Street, N.W., Suite 430 Washington, DC 20009-1125 t

. _ . - _ _ _ _ _ . _ . - _ _ . ~ , .

• Sherwin E. Turk, Esq.

Office of General Counsel U.S. Nuclear Regulatery Commission

• Richard R. Donovan 15th Floor - One White Flint North Federal Emergency Mgmt. Agency 11555 Rockville Pike Federal Regional Center Rockville, MD 20852 130 228th Street, S.W.

Bothell, Washington 98021-9796 -

Philip Ahrens, Esq. Robert A. Backus, Esq.

Assistant Attorney General Backus, Meyer & Solomon Office of the Attorney General 111 Lowell Street State House, Station 6 Manchester, NH 03105 Augusta, ME 04333 r Jane Doughty Richard A. Hampe, Esq.

Seacoast Anti-Pollution League Hampe and McNicholas 5 Market Street 35 Pleasant Street Portsmouth, NH 03801 Concord, NH 03301 l William S. Lord, Chairman Charles P. Graham, Esq.

Board of Selectman Murphy & Graham Town of Amesbury 33 Low Street i Town Hall, Friend Street Newburyport, MA 01950 Amesbury, MA 01913 R. Scott Hill-Whilton H. Joseph Flynn, Esq.

Lagoulis, Clark, Hill-Whilton office of General Counsel

& McGuire Federal Emergency Mgmt. Agency 79 State Street 500 C Street, S.W.

Newburyport, MA 01950 Washington, DC 20472 Ashod N. Amirian, Esquire Judith H. Mi:ner, Esq.

376 Main Street 79 State Straet Haverhill, MA 01830 2nd Floor Newburyport, MA 01950  ;

Senator Gordon J. Humphrey Senator Gordon J. Humphrey U.S. Senate One Eaglo Square, Suite 507 ,

Washington, DC 20510 Concord, NH 03301 (Attn: Tom Burack) (Attn: Herb Boynton) i 2

' Leonard Kopelman, Esquire Robert R. Pierce, Esq.

Barbara J. Saint Andre, Esquire Atomic Safety & Licensing Board Kopelman & Paige, P.C. Panel 77 Franklin Street U.S. Nuclear Regulatory Comm.

Boston, MA 02110 East West Towers Building 4350 East West Highway Bethesda, MD 20814 i EkT Matthew T. Brock 6

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