ML20204J890

First Set of Interrogatories & Request for Production of Documents Re Onsite Emergency Planning & Technical Issues. Related Correspondence

ML20204J890
Person / Time
Site:	Seabrook
Issue date:	08/06/1986
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
Shared Package
ML20204J826	List: ML20204J822 ML20204J850 ML20204J876 ML20204J890
References
OL, NUDOCS 8608110226
Download: ML20204J890 (5)

Text

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^" "S' 6 66adifo UNITED STATES NUCLEAR REGULATORY CCMMIS BEFORE THE ATOMIC SAFETY AND LICENg!GAlgMgDgj ;]f

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In the Matter of ) 0FFICE OF SEQit iARY

) 00CMETING A SERVICF' BRANCH Public Service Company of )

New Hampshire, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY

) PLANNING & TECHNICAL

) ISSUES NEW ENGLAND COALITICN ON NUCLEAR POLLUTION'S FIRST SET GF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF INSTRUCTIONS FOR USE The following interrogatories are to ce answered in writing and under oath by an employee, representative or agent of the NRC Staff with personal knowledge of the facts or information re-quested in each interrogatory. We remind you of your obligation to supplement answers to interrogatories, under 10 C .F.R. S 2.740(e).

The following definitions shall apply to these interrogatories:

1) " Document" shall mean any written or graphic matter of commu nica tion, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all cor-respondence, letters, telegrams, agreements, notes, contracts, 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 p

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_ 2-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 whatsoever.

2) " Identify" with respect to any document shall mean to state the following: the document's title, its date, the author of the document, the person to whom to 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 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 was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; and 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 parti-cipating in or having knowledge of such action or matter; the current and past business positions and addresses of such persons; and the existence and location of any and all documents relating to such action or matter.

5) " Identify" with respect to an individual shall mean state the individual's name, acaress, employer, occupation, and title.

INTERROGATORIES

1) What is the NRC's pc.ition on the adequacy of Ap-plicants' environmental qualif ration program with respect to qualification times? What is e basis for your position?

2) Please identify and vide access to all documents on which you rely or intend to rt during this proceeding to sup-port your position on NECNP Cc ntion I . B.2. This includes all documents used in answers to t :e interrogatories, summary dis-position motions, testimony, a: cross-examination fo witnesses duri,ng hearings.

3) Please identify all : sons on whose factual knowledge, opinions, or technical expertis you rely or intend to rely for your position on Contentian I.E. _.

4) Please identify all p ons you may call as witnesses on this contention daring these :roceedings; describe the sub-stance of their testimony; and Mntify and describe any docu-ments and the portions thereof * .a t they may rely on for their testimony.

5) Please provide access to all documents reflecting the NRC staf f's analysis of the adequacy of Applicants' environmental qualification program with respect 'o qualification times.

6) Please provide access to all notes, draf ts, evalua-tions, and reviews, and any other documents prepared in connec-l

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4-tion with the environmental qualification audit conducted by EG&G Idaho and NRC on February 24-27, 1986

7) With respect to the February 2 4-27 audit, please de-scribe the criteria by which the NRC chose the qualification files to be audited and the criteria by which it determined how many files to audit.

8) Please describe the NRC's criteria, if any, for judging the results of envircnmental qualification audits insofar as they reflect on the quality of applicants' and licensees' environmen-tal qualification programs.

9) Please describe the criteria by which the NRC decides whether a licensee's environmental qualification program fails an audit, the steps prescribed by NRC for correction of environmen-tal qualification programs that have failed audits, and the criteria by which the NRC decides whether to order further audits after a licensee or applicant ~has failed an audit.

10) Does the NRC consider that this audit demonstrates an adequate environmental qualification program for Seabrook? If not, in what aspects is it inadequate, and what remedial steps are required?

11) Please describe all follow-up actions that the NRC has taken with respect to the February 24-27 audit, including direc-tions to the Applicants, further audits or inspections, or re-quests for more information.

12) Please provide copies of all notes, memoranda, reports, and any other documents relating to the NRC Staf f's evaluation of

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,d j Applicants' environmental qualification program with respect to qualification times.

L Respectfully submitted,

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Diane Curran HARMON & WEISS 2001 "S" Street N.W. Suite 430 Washington, D. C. 20009 August 6, 1986 (202) 328-3500 l

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