ML20212K395

Town of Hampton First Set of Interrogatories & Request for Production of Documents to NRC on State of Nh Radiological Emergency Response Plans.* Related Correspondence

ML20212K395
Person / Time
Site:	Seabrook
Issue date:	03/05/1987
From:	Brock M HAMPTON, NH, SHAINES & MCEACHERN
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
Shared Package
ML20212K311	List: ML20212K308 ML20212K360 ML20212K379 ML20212K395 ML20212K408
References
OL, NUDOCS 8703090295
Download: ML20212K395 (4)

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DOCKETED USNRC UNITED STATES OF AMERICA f NUCLEAR REGULATORY COMMISSION h IRR -6 P3 59 BEFORE THE ATOMIC SAFETY AND~ LICENSING BOARD (FFICE OF SECRCIARY s0CHETING A, SERvict.

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Public Service Company of New '

Hampshire, et. al. )

) Docket Hos.

(Seabrook Station, Units 1 and 2) ) 50-443, -444

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t TOWN OF HAMPTON FIRST SET OF INTERROGATORIES j AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO '

THE NUCLEAR REGUTITOR'! COMMISSION ON THE NEW HAMPSHIRE PdDIOLOGYCAL EMERGENCY RESPONSE PLANS i

C JRSTRUCTIDL9 Egg VSE i The following interrogatories are to be answered in writing and i

t under oath by an employee,- representative or agent of the Nuclear Regulatory Conm'.ssion (dCommission" or #NRC") with personal knowledge  !

of the' facts or iNformation requested in each interrogatory.

We t y

q remind you of your obligation to supplement answers to interrogato- [

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ries, un de r 10 C.F.R. S 2.740(e)(1) and (2).  ;

The following definiti.ons shail apply to these interrogatories: 5 i

1. "Dnsament" shall mein any written or graphic mattcr of

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g communication, however produced and reproduced, and is intended t.o be j, f-p/ ccmprehensive and include without limitation any and all r, [.

cer t ispondence, letters, telegrams, agreements, notes, contracts, .

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I instructions, reports, 6cmands, memoranda, data, schedules, notices, wojk papers, recor*.ings, whether electronic or by other means, 43 l PM ,

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SM AINES & MctACHERN . orense.as associne ano.wes

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- . L y computer data, computer printouts, photographs, microfilm, ils microfiche, charts, analyses, intra-corporate or intra-office i communications, notebooks, diaries, sketches, diagrams, forms,

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^ ' manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders,

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' confirmations and all other written or graphic materials of any

' 'yy nature whatsoever. ,

2. " Identify" with respect to any document shall mean to state the'following-respecting the document: its title, its date, the author of the document, the person to whom the document was sent, all persons who received or reviewed the document, the substance and j nature of the document, and the present custodian of the document and j 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; any v.'

'fdocumentrecordingordocumentingsuchacther s

4. " Describe" with respect to a3y Ot ' n or matter shall mean a 3

state the following regarding such action or matter: the substance or nature of such action or matter; the persons participating in or having knowledge of such action or matter; the current and past

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2 S'H AINES & McE ACHERN - encassso.as associatos anomerve 1, [

3 1 business positions and-addresses of such persons; the existence and location of any'and all documents relating to such action or matter.

INTERROGATORIES:

1. With ' respect to each contention and subpart thereof admitted

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by the Licensing Board's order of April 1,1986, please provide the following information:

a. What is.the NRC's posit' ion with respect to each contention and its subparts? Describe in detail the reasons for your position.

b. Identify and provide access to all documents on which you rely during this proceeding to support your position on each of these ' contentions. This includes all documents used in answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings.

c. Identify all persons you may call as witnesses on each of these contentions during these proceedings; describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.

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

2. Please identify and provide access to all documents not identified in response to interrogatory 1(b) that evaluate or discuss 3

SH AINES & McE ACHERN - ortsso.at associavoe avvena.tes

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- the. adequacy of emergency ' planning and preparedness with respect to any of. the issues admitted f or litigation by.the Licensing Board's

. order of February 18,.1987.

Respectfully submitted, Matthew T. Brock SHAINES & McEACHERN, P . A'.

25 Maplewood Avenue Portsmouth, NH 03801 (603) 436-3110 DATED:f$ $7 4

SHAINES & McEACHERN . ==ortsso.a6 associatio= arron=res

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