ML20214N071
| ML20214N071 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/19/1987 |
| From: | Selleck K PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | HAMPTON, NH |
| References | |
| CON-#287-3558 OL, NUDOCS 8706020051 | |
| Download: ML20214N071 (6) | |
Text
..
%~
ENNP'5WM
' DOCKETED o
.USNRC.
Dated:
May 19, ly7 gyy p j.3 UNITED STATES ~OF' AMERICA
. 0$ff E l ' " u : ~m -
00Cxt. TIN!:4 9 A ::t i
NUCLEAR REGULATORY COMMISSION before the i
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 TOWN OF HAMPTON I.
INSTRUCTIONS Pursuant to 10 C.F.R.
$$ 2.715(c), 2.740(b) and 2.741, Applicants request that the attached Interrogatories be answered fully in writing and under oath by an agent or official of Town of Hampton (TOH).who has personal knowledge thereof.
The answer to each; Interrogatory should'contain the name and identification of the person supplying the answer and whether or not he or she.has verified the answer.
As used herein, the term " document"'or " documents" means all tangible things, whether handwritten, typed, printed, or-otherwise produced and all non-identical copies thereof in the possession, custody, or' control of TOH including, but not limited to, communications, correspondence,' notes, field notes, work sheets, survey instruments, models, disks, tapes, studies, reports, summaries, instructions, charts, i
schedules, photos, sketches and drawings, maps, records, l
accounts and accounting records, opinions, machine readible i
8706020051 870519
~
DR ADOCK 05000443
%500 PDR
\\
records and computer translations, and' reports of-consultants.
As used herein, the term " identify" means:
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 sufficient to permit a specific demand for its 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.
$ 2.740(e), responses should be supplemented under circumstances when new or different information becomes available.
If TOH cannot answer the Interrogatories in full, it shall so state and indicate when TOH expects to be able to answer in full to the Interrogatory.
If a privilege or work product immunity is asserted as a ground for not producing any document, state for each such document its preparation date, author (s), addressee (s),
title (s), pages, recipient (s), custodian, and subject matter to the extent not privileged, as well as the basis for withholding it. (
J
II.
INTERROGATORIES 1.
In reference to "[your) Answer Opposing Applicants' Motion for Summary Disposition (TOH VI)" dated April 15, 1987, and to the Affidavit of Glen French, Executive Director of the Town of Hampton Chamber of Commerce, sponsored by you and incorporated therein:
(a)
Identify the source document (s) on which the summer weekend population estimates are based and the method or model by which the estimates were derived.
(b)
State whether the summer weekend population estimates represent a period of time or the number of persons estimated to be within TOH at one point in time.
If the former, identify the beginning and end of the period of time.
If the latter, identify the point of time.
III.
DOCUMENT REQUEST Applicants request that TOH, pursuant to 10 C.F.R.
S 2.741, provide copies of or make available for inspection and copying at a designated time and place, the documents identified by TOH in response to the foregoing Part II Interrogatories.
s Thombs G.
Dignan, Jr.
George H.
Lewald Kathryn A.
Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for Applicants >
c 1
l DOCKEiED U3 W CERTIFICATE OF SERVICE I,
Kathryn A. Selleck, one of the attorneys for the$7 MAY 27 PI :28 Applicants herein, hereby certify that on May 19, 1987, I,
made service of the within document by depositing copieFFit, "
2r thereof with Federal Express, prepaid, for delivery to QI6r5 %, ' Wl'J where indicated, by depositing in the United States mail, M^ h" 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 l
Bethesda, MD 20814 Judge Gustave A.
Linenberger 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 l
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 l
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 l
Bethesda, MD 20814
(
- Atomic Safety and Licensing Robert A.
Backus, Esquire i
Appeal Board Panel 116 Lowell Street U.S. Nuclear Regulatory P.O.
Dox 516 Commission Manchenter, NH 03105 Washington, DC 20555 j
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 RFD 1 - 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 RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
Washington, DC 20472 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 _
O 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 Kath/yn N. Selleck
(*= Ordinary U.S. First Class Mail.)
I
/
4 1
9 k
i:
_