ML20212K278
| ML20212K278 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/05/1987 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | SEACOAST ANTI-POLLUTION LEAGUE |
| References | |
| CON-#187-2722 OL, NUDOCS 8703090260 | |
| Download: ML20212K278 (6) | |
Text
-
()Q 47ZL
^
WTED COMMt WMSA DOCKETED USNRC Dated:
March 8
0FflCE CT HCMTAPY UNITED STATES OF AMERICA DOCHETING A SERVICI.
OE#UC" NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
)
50-444-OL
)
Off-site Emergency (Seabrook Station, Units 1 and 2) )
Planning Issues
)
)
APPLICANTS' OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO SEACOAST ANTI-POLLUTION LEAGUE (SAPL)
I.
INSTRUCTIONS Pursuant to 10 C.F.R.
Sections 2.715(c), 2.740(b) and 2.741, Applicants' request that the attached Interrogatories be answered fully in writing and under oath by any officer of SAPL who has personal knowledge thereof.
The answer to each Interrogatory should contain the name(s) and identification of the person (s) supplying the.tnswer and whether or not he or she has verified the answer.
As used herein, the term " document" means all original writings of any nature whatsoever and all non-identical copies thereof in the possession, custody, or control of SAPL and includes, but is not limited to, the following items:
communications, correspondence, notes, field notes, studies, reports, summaries, instructions, charts, I
schedules, sketches and drawings, records, accounts and accounting records, opinions and reports of consultants.
As used herein, the term " identify" means:
hd)
D A
,7 7
4 s-1.
In the case of a natural person:
.(a) name; (b) last known~ address;
-(c). employer or business affiliation; and (d)l occupation and' business position held.
2.
in the case of a document:
(a) identity of the person or persons preparing it;'
(b) its title or a description of the general nature of the subject matter; (c) the identity of the addressee; (d) date of preparation; (e) identity of persons who can identify it; and
-(f) all'of the aforementioned information should be supplied with such reasonable particularity as is sufficient for a specific demand for production.
In lieu ~of the foregoing, a copy of the document may be supplied.
3.-
In the case of oral statements and communications:
(a) when and where they were made; (b) identity of each of the makers.and recipients
'thereof; (c) the medium of communication; and (d) substance of the statement and/or communication.
Pursuant to 10 C.F.R.,
Section 2.740(e), responses should be supplemented under circumstances when new or different information becomes available.
If SAPL cannot answer the. Interrogatories in full, so state and indicate when SAPL expects to be able to answer the Interrogatory.
Applicant further requests that SAPL, pursuant to 10 C.F.R.,
Section 2.741, provide copies of or make available for inspection and copying the documents identified by SAPL in response to certain of the accompanying Interrogatories.
II.
GENERAL INTERROCATORIES G.1 Please identify those contentions admitted by the Board's Order of February 18, 1987 on which SAPL intends to introduce evidence in this proceeding.
G.2 For each contention identified in Interrogatory G.1, please identify all persons whom SAPL intends to call as witnesses.
Please include a summary of the educational and professional background of each identified witness.
k 1
G.3 Provide a reasonable description of the substance of the testimony of each witness on each of the contentions identified in the answer to Interrogatory G.I.
Please also identify all documents which will be relied on in that testimony.
-III.
INTERROGATORIES RELATED TO SPECIFIC CONTENTIONS SAPL REVISED CONTENTIONS 8 AND 8A S-1.
.How are the towns, the ability of which you question to respond to a radiological emergency, prepared to-respond to a non-radiological emergency that may require either sheltering or evacuation of a significant portion of the local population, such as a toxic chemical spill, hurricane, or other severe weather condition?
S-2.
-Specifically, what measures are in place to ensure that appropriate local officials are available to make immediate protective response decisions on a 24-hour basis and what measures are in place to ensure that local police, fire, and public works officials are staffed on a 24-hour basis to implement the protective actions?
SAPL Contention 34 S-3.
Please provide the " traffic counts and local business figures" referred to by SAPL in support of its assertion that the Hampton peak summer weekend count used in the ETE is low.
By its attorneys, J
ru Tfiodias T,.41gnan, Jr.
Kathryn A.
Selleck Deborah S.
Steenland Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 Counsel for Aeplicants
s
=er DOCXETED USNRC CERTIFICATE OF SERVICE 1R MMt -6 P3 :21 I,LThomas G. Dignan, Jr., one of the attorneys fo'r the Applicants herein, hereby certify that on March 5, I
made service of the within document by depositing ce};p,q},g 3gg7pg pkgslNG A SEFylCL thereof with Federal Express, prepaid, for delivery to - (WBFCH where indicated, by depositing in the United States mail, first class postage paid, addressed to):
Administrative Judge Helen Hoyt, Robert Carrigg, Chairman-Chairperson, Atomic Safety and Board of Selectmen Licensing Board Panel Town Office U.S. Nuclear Regulatory' Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Luilding 4350 East West Highway Bethesda, MD 20814-Judge Gustave A. Linenberger, Jr.
Diane Curran, Etquire Atomic Safety and Licensing Andrea C.
Forster, Esquire Board Panel Harmon & Weiss U.S. Nuclear Regulatory Suite 430 Commission 2001 S Street, N.W.
East West Towers Building Washington, DC 20009 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. iferrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway concord, NH 03301-6397 Bethesda, MD 20814
- Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Tenth Floor i
7735 Old Georgetown Road Bethesda, MD 20814
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel 116 Lowell' Street U.S. Nuclear Regulatory P.O.
Box 516 Commission Manchester, NH 03105 Washington, DC 20555
{&
N'
$'Nl
~
c.a gr
. v.
p,
)
~
i 4Ph'111p Ahrens, Esquire Mr.
J.P. Nadeau
^
Assistant Attorney General Selectmen's office repartment of the Attorney 10 Central Road' General Rye, NH 03870 Augusta,EME 04333 s-Paul McEachten, Esquire
',Carci 9 Sneider, Esquire Matthew T. Bepck, Esquire Assistar.t Attorney General Shaines & McEachien 25 Maplewood Avenaa Department ei the Attorney General.
One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 Portsmouth, NH 03801
.1fts. Sandra Gavutis Mr. Calvin A. Canney i
Chairman, Board of Selectmen City Manager
(
RF) 1 - Box 1154 City Hall 1
Routejl07 126 Daniel Street M
i Kensington, NH 03827 Portsmouth, NH 03801 V
- Senator Gordon J. Humphrey Mr. Ans.e Machiros U.S. Senate Chairman of the Washington, DC 20510 Board of Selectmen
-(Attn:
Tom.Burack)
Town of Newbury Newbury, MA 01950
- Senat.or Go.3 don J. Humphrey fir. Peter J. Matthews one Enigle Square, Suite 507
, Mayor Concord, NH 03301 City Hall (Attus. Herb boynton)
Newburyport, MA 01950 Mr. Thomas ". Powers, III Mr. William S.
Lord t
Town Manager Board of Selectmen Town of Exeter Town Hall - Fr'iend Street j
10 Front Street Amesbury,tMA 01913 Exeter,..NH 03033 H. Joanph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RED Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency
500 C Street, S.P.
Washington, DC 20472
" Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmeo & Ells Hampe and McNicholas s$47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 m
he U ;
m
.. _. _,. ~ _... - -. _.
e D.
u s
Mr. Ed Thomas Judith H. Mizner, Esquire
~
FEMA, Region I Silverglate, Gertner, Baker, 442~ John W. McCormack Post Fine, Good & Mizner Office and-Court House 88 Broad Street Post Office Square Boston, MA 02110 Boston, MA 02109 Charles P. Graham, Esquire
-McKay, Murphy and Graham 100 Main Street Amesbury, MA 01913 F~~
f
(
/
' Tho ds y ignan, Jr.
(*= Ordinary U.S. First Class Mail.)
,V l
i.
f t :
.