ML20205M272
| ML20205M272 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/05/1987 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20205M150 | List: |
| References | |
| OL, NUDOCS 8704020325 | |
| Download: ML20205M272 (6) | |
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UNITED STATES NUCLEAR FEGULATOPY COMMISSICH
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Docket Nos. 50-443 OL
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OFFISTE EMERGENCY
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. PLANNING ISSUES ss
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NEW ENGLAND CCALITICN CD NUCLEAR PCLLUTION'S FIFST SET OF INTERPCGATCFIES AND REQUEST FCR THE PPCEUCTICM OF CCCUMENTS TO THE NRC STAFF AMD THE EXECUTIVE DIRECTOR FOR OPERATICNS CP REVISICN 2 TO THE NEW HAMPSHIPE PADIOLCGICAL EFEFGENCY FESPCNSE PLAN
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Introduction' The New England Coalition on Nuclear Polfution ("NECMP")
aubmits the following interrogatories and teauests for the pro-2 duction of cocumentf. to the Executive Director ano the NRC Staff.
The requests for procuction of accuments 'are submitteo to the NRC Staff ano the Executive Director for Operations pursuant to 10 l-CFR S 2.744.
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-The interrogatories are being filed with the Licensing Board pursuant to 10 C. F. R.
S 2. 7 20( h) (2 ) (ii).
NECNP requests that the l
Licensing Board, find that answers to these interrogatories are necessary to a proper decision in this proceeding and that ans-i wers to the interrogatories'afd not reasonably obtainable from any other source.
Th ese interrogatories seek to discern the
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position that the Staf f will take in hearings on the adequacy of a
the New Hampshire Radiological Emergency Response Plan, and the 8704020325 870305 PDR ADOCK 05000443 G
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% basis for their position.
As the agency's representative in this procee' ding, the Staff takes an extremely important role in the litigation of the. safety issues that are before the Lic.ensing Board.
In its answer to NECNF's first set of interrogatories on the New Hampshire plans, dated May 13, 1986, the NRC Staff informed NCCNP that it had not developed any positions that were different f rom those of the Federal Emergency Management Agency (" FEMA"),
which is the NRC's chief witness in the emergency planning pro-ceeding.
NECNF has served interrogatories on Revision 2 on FEMA through the hBC Staff.1 Nevertheless, interrogatories against tne NRC Staf f are necessary to cetermine whether the NRC Staff's pcsition on the issues uncer litication differ from FEMA's; and to aiscover any information in the Staff's possession that is not also in FEMA's possession.
INSTRUCTICNS FCF USE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the NEC Staff with personal knowledge of the facts or information requested in each interrogatory.
We remind you of your obliga-tion to supplerent answers to interrogatories, under 10 C. F. F. - S 2.740(e).
1 Although it is not compelled to answer NECNP's interrogatories under the NRC's rules, FEMA has in the past agreed to answer interrogatories that were similar to the ones filed today.
Should FEMA refuse to' answer these interrogatories, NECNP would seek an order from the Board requiring the NRC Staff to answer them pursuant to 10 CPR S
- 2. 7 0( h) (2 ) (ii).
"M 1
1 3-The following definitions shall apply to these inter-togatories:
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 cor-respondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer cata, comp uter pr intouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, d iar ies, sketches, c iagrams, forms, manuals, brochures, lists, puclications, drafts, telephone Tinutes, minutes of meetings, statements, calendars, journals, orcers, confirmations and all other written or graphic raterials af any nature wnatsoever.
2)
"Identif y" w ith respect to any document shall mean to state the following:
the document's title, its date, the author o f 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)
"Iden tif y" w ith 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 i
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1 4 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 partic-ipating in or having knowledge of such action or matter; the cur-rent 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)
"Icent i f y" w ith respect to an individual shall mean state the individual's nace, address, employer, occupation, and title.
INTEPFCGATCFIES 1)
In accordance with 10 C.F.P.
5
- 2. 74 0( e), please supple-cent your answers to NECNP's First Set of Interrogatories and Pequests for the Production of Documents to the NPC Staf f on New Hampshire Fadiological Emergency Fesponse Plans, filed Ap ril 3 0, 1986.
2)
What is the NPC Staf f's position on each of the conten-tions that has been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Pesponse Plan?
What is the basis for your position?
3)
Please identify all documents on which you rely or intend to rely curing this proceeding to support your position on each of the contentions that has been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological
h 5-Emergency Response Plan.
This includes but is not limited to all documents used in answers to these interrogatories, summary dis-position motiona, testimony, and cross-examination of. witnesses during hearings.
For any such documents that are not available to the public pursuant to 10 C. F. R. S 2.790, NECNP requests that the EE0 pro-duce those documents at the of fices of Harmon & Weisa on or before March 19, 1987.
4)
Please identify all documents not identified in response to the previous inter rogatory which analyze or evaluate in any way the adequacy of the New Hampshire F EEP or New
- fampshire's state of preparedness in the event of a radiological energency.
In so doing, please state whether these documents are available to the public pursuant to 10 C.F.P. S 2.790.
For any such documents that are not available to the public pursuant to 10 C. F. R. S 2.790, tiECNP requests that the ECO p ro-duce those documents at the of fice of Harmon & Weiss on or before
. March 19, 1987.
5)
Flease identify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to rely for your position on each of the contentions that has been admitted in this proceeding with respect to Pevision 2 of the New Hampshire Radiological Emergency Pesponse Plan.
6)
Please identify all persons you may call as witnesses on each of the contentions that have been aamitteo in this pro-o ceeding with respect to Revision 2 of the New Hamp shir e Fadiological Emergency Response Plan.
Please describe the sub-stance of their testimony; and identify and describe any docu-ments and the portions thereof that they may rely on for their testimony.
Respectfully submitted, Diane Curran HARMCN & WEISS 2001 "S"
St reet N.W.
Su ite 430 Washington, D.C.
20009 (202) 328-3500 Ma rch 5, 1987 I certify that on Ma rch 5, 1987, copies of the foregoing interrogatories were servec by Federal Express or by hand on the NFC Staff, the Executive Director for Opera tions, the Licensing Board, the State of New I!a nt s h i r e, F E.N A, and Applicants; and by first-class mail on all other parties listed on the attachec ser-vice list.
Crane Curran