ML20212N528
| ML20212N528 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/08/1987 |
| From: | Brock M HAMPTON, NH, SHAINES & MCEACHERN |
| To: | Federal Emergency Management Agency, NEW HAMPSHIRE, STATE OF, NRC OFFICE OF THE GENERAL COUNSEL (OGC), PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| Shared Package | |
| ML20212N510 | List: |
| References | |
| OL, NUDOCS 8703130062 | |
| Download: ML20212N528 (3) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Nuclear Regulatory Comminnion In the matter of Docket Non. 50-443-OL 50-444-OL PUBLIC SERVICE COMPANY OF NEW llAMPSHIRE Seabrook Station, Units I and II TOWN OF HAMPTON CORRECTIONS TO TOWN OF flAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE STATE OF NEW HAMPSHIRE ON THE NEW IIAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS, TOWN OF llAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANT ON THE NEW !!AMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS, TOWN OF llAMPTON FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUC-TION OF DOCUMENTS TO THE FEDERAL EMERGENCY MANAGEMENT AGENCY ON Tile NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS, AND TOWN OF ll AM PTON FIRST SET OF INTERROGATORIES AND REQUEST FOR T!!E PRODUCTION OF DOCUMENTS TO THE NUCLEAR REGULATORY COMMISSION ON IllE NEW llAMPSHIBI,. RAD _IOLOGICAL EMERGENC1._BESEQHSE PLAl{S NOW COMES the Town of Hampton and submits the following corrections to the above-referenced discovery requests.
All prior discovery requents remain in full f orce and ef fect unlent specifically modified horein.
I.
TOWN OF IIAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE STATE OF NEW HAMPSHIRE ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS chall be amended as follows:
2b.
That the number of persons comprising the Town of flampton peak summer weekend population in 36,635.
Picane define " peak nummer weekend population" and f ully explain and provide the Data Bane for why thin figure dif f ers f rom that used in prior draf ts of the NHRERP 0703130062 070309 PDH ADUCK 00000443 0
PDR SH AINES & Mc E ACHE RN. e.cessema6 aeonocen enem=e.s
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e and identify all persons included in this population figure.
2c.
That the number of persons comprising the Town of Hampton g
peak summer midweek population is 34,337.
Please define " peak summer midweek population" and f ully explain and provide the Data Base for why this figure dif fers f rom that used in prior draf ts of the NHRERP and identify all persons included within this population figure.
8b.
The present location of each person,
- vehicle, i te m of equipment or resource identified in Answer # 8(a).
II.
TOWN OP llAMPTON'S PIRST SET OF INTERROGATORIES AND REQUEST POR THE PRODUCTION OF DOCUMENTS TO THE APPLICANT ON Tile NEW llAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS shall be amended as follows:
2b.
That the number of persons comprising the Town of flampton peak summer weekend population is 36,635.
Please define " peak summer weekend population" and fully explain and provide the Data Base f or why this figure dif fers f rom that used in prior draf ts of the NilRERP and identify all persons included in this population figure.
2c.
That the number of persons comprising the Town of flampton peak summer midweek population is 34,337.
Picane define " peak summer midweek population" and f ully explain and provide the Data Base for why this figure diff ers f rom that used in prior draf ts of the NHRERP and identify all persons included within this population figure.
8b.
The present location of each person,
- vehicle, item of equipment or resource identified in Answer # 8(a).
2 swam e e a ue e acar =..........,....
III.
FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE FEDERAL EMERGENCY MANAGEMENT AGENCY ON THE NEW t
l HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS shall be amended as 1
1 follows:
r A.
Page 2, Line 5 shall be amended by deleting "New England Coalition on Nuclear Pollution" and substituting " Town of Hampton" L
therefore; B.
Page 2, Line 6 shall be amended by deleting "NECNP" and substituting " Town of Hampton" therefore; C.
Interrogatory 1, Page 3 shall be amended by deleting " April 1,1986" and substituting " February 18, 1987" therefore; IV.
TOWN OF HAMPTON'S FIRST SET OF INTERROGATORIES AND THE REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NUCLEAR REGULATORY COMMISSION l
l ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS shall be cranded as follows:
Interrogatory 1, Page 3, shall be amended by deleting " April 1, 1
1986" and substituting therefore " February 18, 1987".
Respectfully submitted, SHAINES & McEACHERN, P.A.
Attorney for the Town of Hampton DATED: 3 O
By:
C-k f
Matthew T. Brock 3
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