ML20204G696
| ML20204G696 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/11/1988 |
| From: | Bergquist S NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#488-7318 OL, NUDOCS 8810240207 | |
| Download: ML20204G696 (19) | |
Text
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7]/7 10/11/88 A
a 00(KETEif Mr UNITrn STALES OF AMERICA NtlCLEAR REGULATORY COMMISSICM
.g g g g 3 7 BEFORE THE ATOMIC SAFET,Y,AND LICENSING BOAPD cre
, i.Cr In the Matter of )
Docket flo. 50-443 (
PUBLIC SERVICE COMPANY OF 50-444 ' .
f.EW HAMPSHIRE, et al.
Offsite Emergency Planning and Safety Issues (Seabrook Station, Units I and 2) )
NRC STAFF'S MOTION TO COMPEL ANSWERS TO INTERR0GATORIES AND PROCUCTION OF DOCUMENTS BY THE TCWN OF AME3 BURY Pursuant to 10 C.F.R. ! ?.740(f), the NRC Staff hereby rreve that the l Town of Amesbury /"T0A") be compelled to answer certain interrogatories l
and produce certain documents requested in "NRC Staff's First Set of Interrogatorier and First Request for Production of Documents to the Towns of Aresbury, Newbury, Salish'rs'. West Newbury, and l'errimac, and the City of Newburyport" (September 6, 1988) (hereinafter "Staff's Interroga-toriet"). On September 23, 1986, TAA filed its interrogatory answers and a rotion for protective order. T0A produced no documents and objected to
irtually every one of the Staff's Interrogatories. While T0A did provide partial arswers to thr. Staff's interrogatories, its responses were often inecrplete, everive, and cryptic. For the reasort set forth below, T0A should be compellec' to provide a proper and certplete response to the Staff's discovery request, hG kOb [
1
//
1 1
- 1. Motion to Compel Production of Documents at the Office of ;
the General Counsel at the NRC The NRC Staff prefaced its Interrogatories by asking that docurents requested be produced "at the Hearing Division, Office of the General Counsel, Nuclear Regulatory Commit.sion,11555 Rockville Pike, Rockville, Maryland."
1 To this, T0A responded:
T0A objects to the ka'f's request that any docurents to be produced by T0A must be provided at Staff offices located in Rockville Maryland. The request is unduly burdensome and costly to TOA, is disruptive of record-keeping raintained by the Town, and could unreasonably compel T0A to transfer documents outside the EPZ. In additier., in view of the great disparity in resources between the Staff and T0A, it is only appropriate that the Staff assume the burden of coming to T0A to inspect any relevant documents of T0A, provided, however, thet said inspection is conducted during the discovery period, during nomal business hours, et a rutually agreeable time, following reasonable notice to T0A.
The objection is without valid foundation, and T0A should be required to produce responsive documents in accordance with the Staff request. Pursuant to 10 C.F.R. 0 2.741(c), document prcduction shell occur at "a reasenable time, place, and manner." There is nothing reasonable in requiring the Staff to travel to TOA, and presumably to every other Intervenor and Governnental entity's many different offices, to inspect relevant documents. Consideration of time and travel expense vercus the relative burden en T0A resultant f rom sending its documents to ine Staff in compliance with the subject request weigh overwhelraingly in 1;t r of the request's reasonableness. Indeed, TOA makes no attempt to identify or enurerate the nurber of docunents involved in justification of its objection but, rather, refers in the most general terms to undue burden, cost, and disruption to recordkeeping. Such unsubstantiated and i
conclusory assertions should be disregarded, and TOA should be conpelled
to produce documents at the Staff's offices as indicated. Nonetheless, the Staff. notes that it is willing to receive '. A's document production at a central document depository, should the Intervenors and interested State and local governments egree to establish the same.
- 2. ?!otio_n to Connel Answers ,to Specific Interroga_ tories I
- a. In terrog atory__ _1.
Interrogatory 1 and T0A's response read as follows:
- 1. Identify and supply each document containing procedures, plans, orders, instructions, directions, and training materials of the Intervenors for any action in the event of:
e) a radiological emergency or disaster stemning from a nuclear plant accident whether the plant is located inside or outside of Massachusetts; b) other radiological emergencies or disasters; and c) all other "energencieS" or disasters as defined in paragraph 4 of the above definitions.
AliSWER:
1 (a-b). This Interrogatory is objected to as overly broad and unduly burdensome. To the extent the Staff seeks identificetion or production of documents concerning Intervenors other than T0A, or information on issees beyond TOA's jurisdiction, the Staff should address those inquiries elsewhere. This Interrogatory is also objected to on grounds that, on information and beliet, the Staff is alraady in possessier ef all !
planning docurnents concerning Seabr- ok Station, which uere generated in conjunction with Applicants and the l Commonwealth, prior to the vote by the Comonwealth and l TOA not to participate further in emergency planning for ,
Seabrook Station. T0A is not in possession of any documents involving radiological emnrgency planning ;
generated since that date.
l 1 (c). T0A has not approved any emergency or disaster plan for the Town.
_a.
T0A's response fails on several grounds. First, it nisreads the Interrogatory, which concerns applicable data pertaining to both radiological eriergencies and disasters generally, and is not confined to emergencies involving Seabrook Station. Further, the Intertogatory is not confined to documents generated follcwing the decision of the Commonwealth and T0A not to participate in further emergency planning for Seabrook Station. In addition, subsection (c) requests relevant information and documents regarding all "emergencies," irrespective of whether TOA has approved any eftergency or disaster plan. Accordingly. T0A's response to subsection (c) must be considered evasive. Finally, T0A's assertions of overbreadth and undue burdensomeness regarding this Interrogatory must be rejected. A request for documants should not be deemed objectionable solely because there might be some burden attendant to their production.
Long Island L,ichting Co. (Shorehan iluclear Power Station, Urit 1),
LBP.??-82, 16 MRC 1144, 1155 (1982). In any event, the assertion that undue burden is involved in searching for the defined decuments is utterly greurdless. With respect to T0A's allegation of overbreadth, it is pertinert to cite the provisions of 10 C.F.R. $ 2.740(b)(1):
Parties may ebtain discovcry regarding any matter, rot ,'
privileged, which is relevant to the subject natter involved in the proceeding . . . including the er.ist-ence, description, nature, custody, condition, and location of any books, documents, or other tangible '
things and the identity and location of persons having knowledge of any discoverable natter.
Answers to interrogatories or requests for documents which do not comply with this provision are inadequate. Illinois Power Co. (Clinton Power Station, Unit 1), LBP-81-61, 14 NRC 1735, 1737-17?8 (1981). Further, a Board may require a party, who has been served with a discovery request l
i
which it believes is overly broad, to explain why the request is too broad and, if feasible, to interpret the request in a reasonable fashicn and supply documents (or answer interrogatories) within the realm of reason.
Texas Utilities Electric Co. (Comanche Peak Steam Electric Station, Units 1 and 2), L8P-85-41, 22 tiP.C 765, 768 (1985). T0A fails to demon-strate in what respect Interrogatory 1 is overly broad. In sum, T0A should be compelled to respond to this Interrogatory in its entirety.
L. Interrogatory 2 Interrogatory 2 and T0A's response read as follows:
- 2. With regard to each document set out in response to Interrogatory 1, describe the fu,1ctions in er,ergencies of any of the following categories of personnel:
- t. ) State and local police, to include persons employed full or part time, and both private and public security personnel, such as special officers and deputies; b) Civil Defense personnel; c) Professional or volunteer fire-fighting personnel; !
d) First aid and rescue personnel; e) Local support services personnel including Civil Defense /Energency Service personnel; i
f) Medical support persennel; I g) Emergency Service personnel;
- l. ) Health and Fnvironmental Departrent personnel; i) National Guard, Militia or Reserve personnel; j) Boards of Educe. tion, School Boards or Depart-ments, and teachers;
T0A has failed to provide any response to this interrogatory.
For the reasons set fortn with regard to T0A's failure to respond to Interrogatories 1 and ?, T0A should be compelled to answer this Interrogatory.
, d. Interrogatory 4 Interrogatory 4 ard T0A's response read as follows:
- 4. Identify the Massachusetts Civil Defense agency areas in which the Seabrook plume emergency planning zore (EPZ) is located. Provide the Civil Defense Plans for 1 those areas and for the Commonwealth.
ANSWEP.:
1 4 See Answer to Interrogatory 1.
This respense is totally unsatisfactory for reasons noted by the Staff relative to T0A's cbjection to Interrogatory 1. Further, while this interrogatory seeks some information which may also be in the possession of other parties (such as the fiass AG), that is not known to the Staff at j this time, and in any event that does not excuse 70A's failure to respond.
TOA should be ordered to furnish the infortnation requested.
- e. Interrogato_ry 5 Interrogatory 5 reads as follows:
- 5. Identify the number of individuals in each of the personnel categories listed in Interregatory 2(a)-
(m),andthenumberofsuchpersonnel: (a) within the 10-mile EPZ plume exposure pathwa
?5 miles of Seabrook Statient (c)y; from (b)25from to 50 10miles to of i Seabrook Station; (d) from 50 to 100 miles of Seabrook Station; and (e) within the Commor. wealth of Passachusetts ;
outside the aferementioned arear..
T0A has answered this interrogatory as to the categories of i irdividuals listed in Interrogatory 2(a)-(k). Hewever, with respect to personnel Category ?(1) (individuals obligated to provide essistance 9
I pursuant to agreements to aid between municipalities or other government units, or. pursuant to other agreements) and 2(m) (individuals available to provide assistance pursuant to agreements to aid between municipalities or other governrent units, or pursuant to other agreements) T0A declines to r.upply the requested infermation, gererally referring to its response to Interrogatory 1. Further, T0A has failed to produce any documents in i response to this interrogatory.
TOA's response is inadequete for reasons discussed above regarding 70A's objection to interrogatory 1. T0A's answer to Interroga-tery 5 to the extent it cor.cerns Interrogatories ?(1) and 2(n) and relies on the cbjections stated in response to Interrogatory 1, should be 1
rejected; and TOA's response to this Interroaatory should be compelled. :
f, Inter _r,onatory C.
Interrogatory 6 and T0A's response read as folicws:
- 6. Identify the types and number of the following resources available for use in the event of emergencies pursuant to the documents identified in Interrogatory 1:
(a) police vehicles; (b) fire trucks; (c) buses; (d) vans;(e)othervehicles;(f)helicoptersandother aircraft; (g) boats; (h) sirens and public notification systems; (i) radios; ard (j) all other equipment.
ANSWER:
- 6. See Answer to Interrogatnries 1 and 2.
This blanket reassertion of TOA's earlier objections fails to justify its, refusal to supply infonnation that is highly relevant to this proceeding. T0A rakes no effort to specify any particular basis for withholding the informatiot, requested. Further, while certain equipment was identified in TOA's answer te Interrogatory 7, it is unclear whether
l
! that answer WSs intended to respond to t11s Interrogatory as well. TOA should be. compelled to respond to interrogatory 6.
- g. Interroaatories 0 to 15 l
l Interrogatories r, to 15, and TOA's responses thereto, read as 1
follows:
C. Identify the number and location cf
!!assachusetts fiational Guard Units in each of the Inter-venor jurisdictions, the number of members of each unit, their distance frcm the Seabrook plume exposure EPZ, and the number and location of the following resources available for use by the National Guard in emergencies:
(a) cars;(b) trucks;(c) vers;(d) helicopters; (e) other means of u ansportation; and (f) communication facilities, includien radios and other means of public notificetion. Supply the same information for any Militia or Reserve unit in such jurisdiction. (Footnote:
If any of the data sought under Interrogatory 8 are withheld on the ground they are classified, please indicate the type of data so withheld.)
AflSWER:
- 8. See Answer to Interrogatory 1.
- 9. Identify any plans made for radiological monitoring in the event of a radiological emergency from any cause, including (a) the number and location of personnel trained and available to accomplish such i monitoring, and (b) a description and enurcration of radiological monitoring equipment available for use in i such an emergency, along with identification of the i
- equipment's location.
ANSWEF:
- 9. See Answer to Interrogatory 1.
- 10. Identify any provision? made for handling of individuals contaminated in a radiological emergency stenming from any cause, including (a) the number and location of personnal trained and available to assist in decontanination of contarainated individuals, and (b) a i description and enuteration of equipment available for use in decontamination, along with identificetion of the equipment's location.
1
ANSWER:
- 10. See Answer to Interrcgatory 1. ,
- 11. Identify any provisions made by the Massachusetts Department of Agriculture, or other state or local governmental agency, concerning protective measures to be used for the 50-mile ingestion pathway from any nuclear plant, including the methods for protecting the public from consumption of contaminated foodstuffs; and identify any procedures for detecting I contaninatien, for imposing protective measures such as interdiction of food supply, impoundment, or quarantine, l and for public notification concerning food contamination and the protective reasures to be followed.
ANSWER:
- 11. See Answer to Interrogatory 1.
- 12. Identify the number of Massachusetts Civil Defense personnel according to location within the Correnwealth, and identify the amount and location of equipment available for their use to protect the public in the event of an enargency. Set out the training of Civil Defense personrel.
ANSWER:
- 12. See Answer to Interrogatory 1. l
- 13. Identify the location of stations authorized to broadcast under Federal Emergency Broadcast System (EBS) regulations and the Massachusetts EBS Operatienal PlTa
("0perational Plan"). Provide a copy of the Operatie:.;1 l Plan. ;
ANSWER:
- 13. See Arswer to Interrogatory 1.
- 14. Identify all documents, agreements and communi-cations dated within the last five years concerning the operation of the EBS. Produce a copy of all such docu-nents, agreer.cnts and corr >unications.
ANSWER:
- 14. See 8,swer to Interrogatory 1.
- 15. R.cntify the provisions of federal or state law which preclude activa + ion of the EBS at the discretion of ranagement of AM, FM, and televisien stations, in connection vith day-to-day emergency situations posing a 1
- - - - , ,= - ., --- , , - - - - ,--. . . - , -.-c. -- ,---n - .- ,, -- n, .-~, --, -n ~-
threat to the safety of life and property, such as hurricanes, floods, icing conditions, heavy snows, fires,
. toxic gases, power failures, industrial explosions, and civil disorders.
ANSWEP.:
- 15. See Answer to Interrogatories 1 and 18.
T0A has ft.iled to provide any response to these interrogatories.
T0A should be compelled to respond to these interrogatories, for the reasons discussed herein regarding TOA's failure to respond to Interrogatories 1 and 18.
- h. Interregatories 17 to 20 Interrogatories 17 to 20, and 70A's responses thereto, read as follows:
- 17. With respect to each document identified in Interrogatory 1, i A ntify any Federal or state law or regulation pursuant to which each such document was prepared.
AhSWFR:
- 17. See Answer to Interrogatory 18.
- 18. Identify all Massachusetts statutes and regula-tions, and all local regulations, ordinances or other provisions, (a) concerning actions tn be taken by state or local authorities, or those acting in their behalf, in the event of erorgencies, including the preparation of plars for actions to be taken in emergencies; (b) con-cernino any prohibitions on any such actions or plans; and(c)concerninganyprohibitionsenanypersonor organization other than state or 1ccal authorities with respect to any such actions or plans.
ANSWER:
- 18. See Answer to Interrogatory 1. By way of further answer, this Interrogatory is objected to as calling for a legal opinion. The Staff may inspect T0A's ordinances in accordance with the conditions set forth in 03JECTION TO PRODUCTION OF DOCLPENTS, supra.
l
- 19. Set out tha conditions, including citations to all applicable provisions of state and local laws and
. regulations, (a) under which state and local authorities
, may pemit private individuals or organizations to take action on their behalf in an emergency; and (b) under which state and local authorities are precluded from authori:ing private individuals or organizations from taking action on their behalf in an emergency.
Af:SVER:
- 19. See Answer to Interrogatory 18.
H
- 20. Set out exarr.ples illustrating the conditions described in Interrogatory 19(a) and (b).
I ANSWEP:
- 20. See Answer to Interrogatory 1. !
The Staff requests that TOA be compelled to respt;nd to Interrogatories 17 to 20 for the reasons discussed above with respect ,
to T0A's respenses to Interrogatory 1. Further, the statutes, I
regulations, and ordinances referred to in Interrogatories 17and 18 cannot be te numerous as to rake a response to these Interregatories unduly onercus. The same is true with respect to the conditions and exarrples requested under Interrogatories 19-20. As regards Interroga-tory 16, there it ro merit in T0A's assertion that the identification of statutes and regulatiens which T0A ney rely upon in challenging the SPfiC's legal authority calls for a "legal opinion." The Staff does !
l not seek T0A's legal conclusiens, but only an identification of the j bases for the challenge made by TOA to the SPPC. Only after those bases are identified can the Board and other parties determine whether there is merit to the challenge. The answers sought by Interrogatories 17, 19 and 20 likewise seek answers of fact, as to the i
l l -
I legal support relied upon by T0A for challenging the Applicants' emer0ency. planning activities. The issues involved in Interrogatories 17 to 20 are relevant to this proceeding, and TOA should be compelled i
to respend to them,
- i. Interrogatories 21 and ?2 Interrogatories 21 and 22 and T0A's responses read as follows:
- 21. Define what you consider to be "the beach" ir, the Massachusetts portion of the Seabrook Station EPZ.
Set cut the geographic boundaries of that "beach" area.
ANSl!ER:
- 21. This Interrogatory is objected to as irrelevant and not likely to lead to the discovery of admissible evidence.
??. Using the definition of "the beach" you supplied ir answer to Interrogatory 21, provide the following data along with a copy of any study or other document relevant to the following information: (a) the maximum numbe.r of cars at the beach en the 10 busiest days within the last five years, along with indication of the time ar.c date of such maxima; (b) the number of cars remaining at the beach following each 1/?-hour interval for the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the aforcrentioned eaximat (c) the number of cars entering and leaving the beach during each 1/2-hour interval within the 8-hour period. If you do not have data for 1/2-hour intervals, supply such data for the periods you have. Indicate whether the foregoing cceputations were made manually or autenatically.
MSWER:
- 22. See Answer to Interrogatories 1 and 21. By way of further answer, TOA adopts the statements, testimony, and evidence presented by Intervenors, to the extent appliceble, in the NHRERP litigation.
Interrogatories 21 and ?? directly relate to issues raised by the Intervenors in this proceeding, ar.d seek to ot'tain a proper definition of the issues and areas encompasscd by admitted contentions. See Stipulation As To Contentions (September 19, 1988), at 1-4. The test 25 to whether particular ratters are discoverable is one of "general
4 relevancy." This test will be easily satisfied unless it is clear that the evidence sought can have no pcssible bearing on the issues.
Comronwealth Edison Co. (Zion Station, Units 1 F 2), ALAB-185, 7 AEC 240 (1974). Interrogateries 21 and 22 clearly rect the test of "general relevancy." Further. T0A's broad reference to all of the evidence submitted by Intervenors in the MIRERP litigation feils to provide reasore.ble notice of the particular matters encompatred in this response.
TCA's refererte tn its response to Interrogatory 1 should be rejected, for the reasons discussed concerning 70A's objection to Interrogatory 1. In sur, TOA's respenses to Interrogatories 21 and 2? should be compelled.
J. Interrogatories 23 andl Interrogatories 23 and 24, and T0A's responses, read as follows:
- 23. Identify all studies conducted during the last five years concerning irproving the rovement of traffic in and out of "the beach" area. Provide a copy of all ruch studies.
ANSWER:
- 23. T0A has conducted no such studies. See Answer to interrogatory 1.
24 Identify aH studies conducted during the last five years concernirn irprnving the movement of traffic in the event of emergancies within the Seabrook Station EPZ which include estimates of the vclure of traffic or the time within which traffic can be evacuated. Provide e ccpy of all such studies.
ANSWER:
- 24. Mene. See Answer to Interrogatories 21 and 23. l TCA has nisconstrued Interrogatories 23 and 24, which request !
identificatinn of "all" studies conducted, not "all studies conducted by l l
T0A." Further, the studies sought are clearly relevant to the issues to l l
be litigated in this proceeding. Fnr these reasons, and for the reasons l l
l
- 15 -
. i discussed above concerning TOA's objections to Interrogatories 1 and 22 T0A should be compelled to respond to these interrogatories,
- k. Irterrogatory 2,5 , !
Interrogatory 25, and T0A's response, read as follows:
(
l 25. Identify all State and local laws and regula- !
tiens concerning the following actinns to be taken in the i event of radiological or other eriergencies (see defini- ;
tion 4): (1)guidingtraffic;(2)blockingroadways, ;
erecting barriers in reedways, and channeling traffict ,
(3) posting traffic signs on roadways; (4) removing !
obstructicns from public roadways, including to:ing I private vehicles; (5) activatin broadcastofEBS'ressages;(6)gsirensanddirectingthe making decisions and !
recorrendations to the public concerning protection !
, actions for the ingestion exposure pathways; (8) making decisions ard recorrendations to the public concerning recovery and reentry; (9) dispensing fuel from tank trucks to automobiles along roadsides; and (10) perforri-
) ing access control et the Emergency Operations Center, the relocation centers, and the EPZ perimeters.
ANSWER:
! 25. See Answer to Irterrogatory 18. l l TCA should be compelled to resperd to Interrogatory 25, for the
- reasons set forth in the Steff's motion to compel a response to j Interrogatory 18.
j 1. Interrogatory 2,6 _
Interrogatcry 26, and T0A's response, are:
- 26. Identify all studies perforred during the last five years concerning the availability and possible use
- of sirens and other means of energency cormunication to
, the public in the event of energencies. Provide a copy '.
of all such studies. ,
ANSWER: ,
i
- 26. T0A has conducted no such studies. TOA adepts, l j
and incorporates by reference all relevant staterents, documents, reports, evidence or other inferration ,
i proferred by the Corr onwealth concerning sirens and stren l l contentions for the Seabrcok EPZ, with supporting i
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documentation as detaiu usly filed in this proceeding. See xn- ry 1.
T0/ has rnisconstrued this Interrt . y as it did Interroga-tories 23 er.d 24, to refer only to stedies conducted by T0A. Further TOA and fails to identify the "relevant statements, documents, reports, evidence or other information proffered by the corronwealth", which it cites herein; and T0A's answer therefore fails to provide any reasonable degree of specificity sufficient to infonn the Staff of the particular documentr referenced by T0A's answer. A response to Interrepatory 26 is merited and should be compelled.
F. Interrogato,ry 27 Interrogatory 27, and T0A's respense are:
- 27. Identify all sirens or other means of emergency communication in the Seabrook EP7 which can be heard by the general public.
ANSWER:
- 27. See Arswer to Inttrrogatories 1, 7(h) and 26.
T0A's reference to its answer to Interrogatory 1, again, should be rejected; its reference tn Interrogatory 7(h) is perplexing, since no fuch interrocatory exists; and its reference to its answer te Interrogatory 26 shculd be rejected for the reasons discussed aboy? in resperse to T0A's cbjection to that Interrogatory. Since no valid obA ction to Irterrogatory 27 remain:, T0A's response should be compelled,
- n. Intr.rrogatory 28 Interrogatory 20, and T0A's response, are as follows:
- 28. Identify all studies performed by Intervenors during the last five years concerning planning for emergencies. Produce a copy of all such studies.
i i
Atl5WER:
- 28. See Answer to Interrogatory 1. :
'T0A's refuse 1 to respond to Interregatory 28 is objectionable for the reasons stated by the Staff with regard to Interrogatory 1. A response to Interrogatory 2G should ba compelled. t r
SUMMARf TOA has failed to provide satisfactory responses to virtually all of -
the Staff's interrogatories, thus precluding the discovery of potentially '
critical facts in this proceeding. Given the rebuttable nature of the ,
presumption inFerent in tia "realista rule", production of this infomation is of vitel iraportance for this litigation as to the adecuacy of the SFMC. T0A's unsupported allegations of burdensoreness, overbreadth, and :
irrelevancy shculd be rejected, and T0A should be cerrpelled to respond to l the Interrogatories identified herein, i Pespectfully submitted.
Wf Y' Stephen A. Rergquist Ofc i
Counsel for NPC Staff ;
bated at Rockville Maryland this litt day of October, 1988 l I
I a
l i
NF UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION EEFORE THE , ATOMIC SAFETY AND,L,ICENSING BRIDCT 19 P4 :17 In the Matter of ,
Docket No0Cg M-443 OL PUBLIC SERVICE COMPANY OF SO+444;0L NEW H/J:PSHIRE, g aj. Off-site Emergency Planning
)
(Seebrook Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify thet copies of "NRC STAFF'S MOTION TO COMPEL ANSWERS TO IflTERF.0GATORIES AND PRODUCTION OF DOCUMENTS BY THE TOWN OF AMESBURY" in the above-coptioned proceeding have been served on the following by deposit in the United States rail, first class or, as indicated by an asterist, by deposit in the Nuclear Regulatory Comission's internal mail systen, this lith day of October 1988:
Iven W. Snith, Chairman
- Atemic Safety and Licensing Administrative Judge Board Panel (1)*
Atonic Safety and Licensing Peard U.S. l'uclear Regulatory Corrission l U.S. t'uclear Regulatory Comission Washington, DC 20555 l Wa:hington, DC 20555 Docketing and Service Section' l Gustcve A. Linenberger, Jr.'- Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Comission Atu11c Safety and Licensirg Enard Washington, DC 20555 U.S. Nuclear Regulatury Comission Washington, DC 20555 Thomas G. Dignan, Jr. , Eso.
Robert K. Gad, III, Esq.
Dr. Jerry Parbour* Ropes & Gray Adn.inistrative Judge 225 Franklin Street Atomic Safety & Licensing Board Roston, MA 0?l10 U.S. Nuclear Regulatory Comission lieshingter., DC 20555 H. J. Flynn Esq AssistantGereraiCounscl Atmic Safety and Licensing Federal Emergency t'anagement Agency Appeal Panel (5)* 500 C Street S.W.
U.S. Nuclear Regulatory Comission Washington, DC 20472 Washington, DC 20555
l j :
! Philip Ahren, Esq. Calvin A. Canney
- Assistant Attorney General City Hall
- Office of the Attorney General 126 Daniel Street t
- State House Station Portsmouth, NH 03801 I
- Augusta, ME 04333 Mr. Angie ifachiros Chaiman !
Cerol S. Sneider, Esq. Board of Selectmen !
Assistent Attorney General 25 High Road t Office cf the Attorney General 1 l'ewbury, MA 091S0 One tshburton Place, 19th Floor 1 Boston, PA C2100 Allen Lampert :'
a Civil Defense Director l
George Dana Bisbee, Esq. Town of Brentwood l l Assistant Attorrey General 20 Franklin -
Office of the Attorney General Exeter. NH 03833 25 Capitol Street i
! Concord, NH 03301 Willitm Arrnstrong '
Civil Defense Director i 4 Ellyr P. Weiss. Esq. Town of Exeter l
- Diane Curran, Esq. 10 Front Street l Harren & Weiss Exeter, NH 03833 ;
0001 S Street, NW .
Suite 430 Gary W. Holmes, Esq. l Washingten, DC 20009 Holmes & Ellis :
i 47 Winnacunnet Road !
d Robert A. Backus, Esq. Hampton, NH 03842 ,
1 Backus, !!cyer & Solomon i i 116 Lowell Street J. p. Nadeau !
l 11anchester, NH 03106 Board of Selectmen 1
10 Central Street i Faul l'cEachern Esq. Rye, NH 03870 '
Mattheu T. Brock, Esq.
Shatnes A PcEachern Judith H. Mizner Esq. i
, 05 Maplewood Avenue Silverglate, Gertner, Baker, ;
4 0.0. Box 360 Fine, & Goed I j Portsmouth, hk 03801 88 Beard Street ;
- Boston,itA 02110 l j Charle. P. Graham, Esq. i McKay, Murphy f. Graham Robert Carrigg, Chairman i 1 100 Main Street Board of Selectren t Aresbury, MA 01013 Town Office i Atlartic Avenue Sandra Gavutis, Chaittan North Hampton, NH 03870 ,
! Dotrd of Selectren l l RFD #1, Lex 1154 l l Kersington, NH 03827 l i
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, William S. Lord Peter J. Matthews, Mayor
! Board of Selectmen City Hall i Town Hall . friend Street Newburyport, MN 09150 !
Amesbury, MA 01913 l Michael Santosuosse Chairman t
- Mrs. Anne E. Goodman, Chairman Board of Selectmen 1 Board of Selectmen South Hampton, t'H 03827 d 13-10 f,'emarket Road i 1
Durhan NH 03824 Ashod N. Amirian, Esq. !
) Town Counsel for Merrimac l i Hon. Gordon J. Hurphrey 376 tiain Street !
1 United States Senate Haverhill, MA 08130 l j 531 Hart Senate Office Building t j Washington, DC 20510 l
) Richard R. Donovan Robert R. Pierce Esq. *
- Federel Erergency itanagement Agency Atenic Safety and Licensing ,
! Federal Regional Center Board Panel ;
130 220th Street, S.W. U.S. huclear Regulatory Comission '
Bothell Washington 98021-9706 Washington, D.C. 20555 7
%4e& vfw' Steptierf A. Bergquist Counsel for NRC Staff l
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