ML20212K618
| ML20212K618 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/05/1987 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | HAMPTON, NH |
| References | |
| CON-#187-2724 OL, NUDOCS 8703090370 | |
| Download: ML20212K618 (8) | |
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4tLATED CORRESPONDtJ%'A DOCKETED USNRC
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J Dated:
March 5,l9E22 y nm -
UNITED STATES OF AMERICA gy
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NUCLEAR REGULATORY COMMISSION
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!CE BP.AhCH before the ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
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50-444-OL
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Off-site Emergency (Seabrook Station, Units 1 and 2) )
Planning Issues
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APPLICANTS' OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE TOWN OF HAMPTON (TOH)
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 official (s) of TOH who has personal knowledge thereof.
The answer to each Interrogatory should contain the name(s) and identification of the person (s) supplying the answer 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 TOH and includes, but is not limited to, the following items:
communications, correspondence, notes, field notes, studies, reports, summaries, instructions, charts, schedules, sketches and drawings, records, accounts and accounting records, opinions and reports of consultants.
As used herein, the term " identify" means:
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PDR ADOCK 05000443 '
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1.
In the' case of a natural person:
(a) 'name; (b) last known address; (c) employer or business affiliation; and (d) 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 caselof 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 TOH cannot answer the Interrogatories in full, so state and indicate when TOH expects to be able to answer the Interrogatory.
Applicant further requests that TOH, pursuant to 10 l
C.F.R.,
Section 2.741, provide copies of or make available 1
for inspection and copying the documents identified by TOH in response to certain of the accompanying Interrogatories.
II.
GENERAL INTERROGATORIES G.1 Please identify those contentions admitted by the Board's Order of February 18, 1987 on which TOH intends to introduce evidence in this proceeding.
r G.2 For each contention identified in Interrogatory G.1, please identify all persons whom TOH intends to call as witnesses.
Please include a summary of the educational and professional background of each identified witness. ;
g, IC 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 TOH REVISED CONTENTION III TO REVISION 2 S-1.
Identify each document relied upon, in whole'or in part,.for TOH revised Contention III to Revision 2 that the
-Evacuation Time Estimate Study (ETE) prepared by KLD Associates, Inc., Revision 2, Volume 6,.is based.upon:
_ [a]
inaccurate and biased factual data; and [b] unreasonable or misleading assumptions; and which designates in whole or in part: [c] adequate protective measures; and [d] adequate
' facilities, equipment or personnel requisite to provide reasonable assurance that adequate protective measures can' and will be provided.
-S-2.
Identify each document relied upon in whole or in part in TOH Revised Contention III to provide adequate data to compute:
(1) the permanent and transient populations of TOH, (2) proper vehicle occupancy rates and (3) daily a.m.
'and p.m. road capacities for the evacuation of permanent and transient populations from TOH-under all traffic and weather conditions.
S-3.
Identify those sections of the evacuation road routes which become impassable when a vehicle breaks down, runs out of gas, or overheats and thereby becomes disabled.
j-TOH REVISED CONTENTION VI TO REVISION 2 S-4.
Please provide the means by which the Town of Hampton would respond to a non-radiological emergency, such as a toxic chemical spill, hurricane or other severe weather emergency that could require sheltering or evacuation of significant segments of the town population.
S-5.
Please identify the agencies, organizations, and personnel that would be utilized to respond to such an emergency, including names, addresses, and telephone numbers.
In the case of individual personnel, please provide place of employment, name of employer, address and telephone number.
S-6.
If such an emergency would require response that would exceed the capabilities of town resources, please explain the method for requesting outside assistance, including assistance from other local governments, private
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.v sources of assistance, the State of New Hampshire, and.the government of the United States.
What agencies, organizations, and personnel would be utilized to provide assistance?
How would these agencies, organizations, and personnel be contacted?
Who wottid contact them?
S-7.
.Please. provide a list of all personnel that are available-to the town to respond to such an emergency, including names, addresses and telephone numbers, including:
1.
All police personnel, including sworn police personnel, auxiliary police personnel, and volunteer police personnel.
2.
All fire personnel, including paid, full-time fire personnel, call fire personnel, auxiliary fire personnel, and volunteer fire personnel.
3.
All emergency medical personnel, including full-time, part-time, and volunteer.
4 ~.
All public works personnel and other town personnel responsible for road maintenance for the town.
5.
All private contractors that provide the following services to the town.
Snow clearance and clearance of other impediments.
a.
b.
Road maintenance, c.
Vehicle towing.
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otdasMignan, Jr.
Kathryn A.
Selleck Deborah S.
Steenland Ropes & Gray _
225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 Counsel for Applicants
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CERTIFICATE OF' SERVICE
' DOCKETED USNRC y
I,' Thomas G. Dignan,2 Jr., one of the attorneys fg
-6 P3 :22 Applicants herein, hereby certify that on March 5, 1M7,._
made. service.of the within document by depositing copies thereof with Federal Express, prepaid, for delivery dPFIClar,?ECRif/M where indicated, by depositing in the United States MGflittlG A SERVICf.
% RANCH 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 Building.
4350 East West Highway Bethesda,-MD 20814 Judge Gustave A. Linenberger, Jr.
Diane Curran, Esquire Atomic Safety and Licensing Andrea C.
Ferster, 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..Merrill 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 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
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. Philip Ahrens, Esquire Mr. J.P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta,-ME 04333 Paul'McEachern, Esquire Carol.S. Sneider, Esquire Matthew T.' Brock, Esquire Assistant Attorney General Shaines & McEachern-
~ Department of the Attorney General 25 Maplewood Avenue
'One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 Portsmouth, NH 03801
- Mrs.. Sandra Gavutis Mr.. Calvin A. Canney Chairman, Board of Selectmen City Manager RED l?- Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey Mr. Angie Machiros U.S.
Senate Chairman of the
' Washington, DC 20510 Board of Selectmen (Attn:
Tom Burack)
Town of Newbury Newbury, MA 01950
- Senator Gordon J.
Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA. 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RED Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
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_ Washington, DC 20472 j
Gary W. Holmes, Esquire Richard A.
Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 l
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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 Theffigignan, Jr.
(*= ordinary U.S. First Class Mail.) -._......
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