ML20214N126
| ML20214N126 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/20/1987 |
| From: | Brock M, Mceachern P HAMPTON, NH, SHAINES & MCEACHERN |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| Shared Package | |
| ML20214N112 | List: |
| References | |
| OL, NUDOCS 8706020073 | |
| Download: ML20214N126 (6) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
' 87 MAY 20 P6 :19 BEFORE THE ATOMIC SAFETY AND LICENSING BOARI}.;.,
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Public Service Company of New
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Hampshire, et._al.
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Docket Nos.
(Seabrook Station, Units 1 and 2)
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50-443, -444 0 6 y'.
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TOWN OF HAMPTON SUPPLEMENTAL INTERROGATORIES AND REQUEST 'FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANT ON THE HEH HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS NOW COMES the Town of Hampton and submits the following Supplemental Interrogatories and Request for the Production of Documents to the Applicant:
INSTRUCTIONS EQB HEE The following supplemental interrogatories are to be answered in writing and under oath by an employee, representative or agent of the Applicant with personal knowledge of the f acts or.information requested in each interrogatory.
We remind you of your obligation to supplement answers to interrogatories, under 10 C.F.R. S 2.740 (e)(1) and (2).
The following definitions shall apply to these interrogatories:
1.
" Document" shall mean any written or graphic matter of communication, however produced and reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, 6020073 870519 0
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i work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, mic rof ilm, microfiche, charts, analyses, intra-corporate or intra-of fice communications, notebooks,
- diaries, sketches,
- diagrams, forms,
- manuals, b r o ch u.r e s,
- lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.
2.
"Identifv" with respect to any document shall nean to state the f ollowing 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 nature of the document, and the present custodian of the document and of any and all copies of the document.
3.
"Identifv" with respect to any action or conduct shall mean i
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 document recording or documenting such action.
4.
" Describe" with respect to any action or matter shall mean state the following regarding such action or matte:
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 business 2
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i positions.and addresses of such persons; the existence and location of any and all documents relating to such action or matter.
SUPPLEMENTAL INTERROGATORIES:
S-1: -Please
- identify, describe and f ully' answe r all interrogatories previously served by the TOWN OF HAMPTON upon the Applicant as if fully set forth and requested herein.
Please. note the errata as referenced in TOWN OF1HAMPTON CORRECTIONS TO TOWN'OF H AMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO'THE APPLICANT ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS.
S-2:
With respect to the PERSONNEL RESOURCE ASSESSMENT.
SUMMARY
April 19 87, previously filed by Applicant with the Licensing Board, please identify all persons, including persons employed by or having knowledge of the Town of Hampton, referenced at'page 2-2 which provides
" surveys were conducted with persons knowledgeable about the specific Town to verify and adjust the numbers of required and available personnel resources."
With respect to each such person so identified, please state the dates of any such surveys, discussions, correspondence, or any communications whatsoever, the persons-conducting or involved in each such surveys or communication, the subject matter of each, the information obtained therefrom, and whether this information is relied upon or incorpated into the personnel resource assessment summary, April, 1987.
S-3:
With reference to the personnel resource assessment summary, April, 1987, identify and describe what steps wars taken "to insure 3
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l that each plan. reflected all of the required planning responsibili-what steps were taken "to identify all of the tasks required to ties",
be performed in fulfilling the contemplated emergency response
. functions", and what steps were taken "to identify personnel resources available to fill the emergency response positions for each municipali-ty identified in the procedural walk throu ghs."
In responding to this question, please identify and descFibe all documents relied upon in
. support of the personnel resource assessment summary and in support of this answer.
S-4:
With respect to the Town of Hampton, please identify and describe each document reviewed, considered, or relied upon, to support the personnel resources contained in the personnel resource assessment
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summary.
l S-5:
Please identify and describe all documents supporting your calculations regarding the dose reduction effectiveness of certain 1
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institutions in the Seabrook EPZ, as described in Volume 4, Appendix F of the NHRERP.
i identify and describe the basis for your belief that S-6:
Please the Teamsters Union will provide the drivers referenced in its letter agreement with the Applicant.
Please state how many of such Teamsters you have contacted, directly or indirectly, the dates thereof, and the f
information obtained.
State whether any survey, vote of the Teamsters, or other verification was undertaken to confirm the letter agreement, and the results thereof.
Please identify and describe all documents upon which you rely in support of your answer.
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S-7 :
With referernce to Anthony M.
Callendrello's Affidavit submitted in support of Applicant's. Motion for Summary Disposition on Town of Hampton VI, identify and describe:
"The information available during the preparation of Revision a.
2" upon which Mr.
Callendrello relies to compute the full time, special, or part time police of ficers for the Town of Hampton, and any additional inf ormation presently relCed upon for these computations.
b.
How Mr. Callendrello computed that up to 70 persons are required for Town of Hampton Emergency Response Organization.
i By name and employment position, the 127 persons available to c.
Town of Hampton to serve in an emergency response capacity, and the specific capacity for each, d.
How Mr. Callendrello determined that Town of Hampton will provide 2 police personnel to support traffic control functions in an emergency.
Describe any conversations, correspondence, or communica-tions with Town of Hampton officials, directly or indirectly, concerning this issue, the dates, parties involved, and substance of each.
How Mr. Callendrello computed that 6 Town of Hampton police e.
could be made available by the Town for municipal security.
f.
All conversations, correspondence, communications, or surveys, referenced at paragraph 15 of M r.
Callendrello's Affidavit, including those, directly or indirectly, with Town of Hampton officials, the dates thereof and substance of same.
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t S-8:
Identify and produce for inspection and copying at the i
offices of Shaines & McEa che rn, P.A.,
25 Maplewood Avenue, Portsmouth, New Hampshire 03 801 all documents upon which you rely to support your answers to interrogatories S-1 to S-7.
Please consider the foregoing request to be continuing in nature.
The Town of Hampton requests that the Applicant timely supplement its responses when new and additional information becomes available.
Respe lly ub tte P/ 1 McEachern
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Matthew T. Brock SHAINES & McEACHERN, P.A.
25 Maplewood Avenue Portsmouth, NH 03 801 (603) 436-3110 DATED:
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