ML20214N145

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

ML20214N145
Person / Time
Site:	Seabrook
Issue date:	05/19/1987
From:	Brock M, Mceachern P HAMPTON, NH, SHAINES & MCEACHERN
To:	NEW HAMPSHIRE, STATE OF
Shared Package
ML20214N112	List: ML20214N108 ML20214N126 ML20214N145 ML20214N160 ML20214N191
References
OL, NUDOCS 8706020079
Download: ML20214N145 (5)

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?? W UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION '87 MAY 20 P6 :20 BEFORE THE ATOMIC SAFETY AND LICENSING B g ,

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Public Service Company of New )

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) Docket Nos. Mp (Seabrook Station, Units 1 and 2) ) 50-443, -444

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TOWN OF HAMPTON SUPPLEMENTAL INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE STATE OF NEW HAMPSHIRE QH IBI HEW 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 State of New Hampshire:

INSTRUCTIONS EQB HSI The following supplemental interrogatories are to be answered in writing and under oath by an employee, representative or agent of the State of New Hampshire w ith personal knowledge of the facts or information requested in each interrogatory. We remind you of your i

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. "Dasumant" 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, i

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instructions, reports, demands, memoranda, data, schedules, notices,;

l work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings,,

statements, calendars, journals, or:ders, confirmations and all other written or graphic materials of any nature whatsoever.

2. "Identifv" with respect to any document shall m ean to state the following respecting the document: Its title, its date, the author i

! 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 I

! copies of the document.

l l 3. " Identify" with respect to any action or conduct shall mean state the following regarding any such action or conduct: the person l or persons proposing and taking such action; the date such action was i

lproposedand/ortaken; all persons with knowledge or information about i

such action; the purpose or proposed effect of such action; any I

document recording or documenting such action.

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4. "Describg" with respect to any action or natter shall mean l state the f ollowing regarding such action or matte: the substance or fnatureofsuchactionormatter;thepersonsparticipatinginorhaving

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knowledge of such action or matter; the current and past business i

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! positions and addresses of such persons; the existence and location of l

any and all documents relating to such action or matter.

SUPPLEMENTAL INTERROGATORIES:

S-1: Please identify, describe and fully answer all interrogatories previously served by the TOWN OF HAMPTON upon the State of New Hampshire as if fully set forth and requested herein. Please l

l note the errata as referenced in TOWN OF HAMPTON CORRECTIONS TO TOW HAMPTON'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.

S-2: Please identify and describe the State of New Hampshire's i

position with respect to all Motions for Summary Disposition, and responses thereto, previously filed in this proceeding.

S-3: In response to prior interrogatories, the State of New Hampshire stated "KLD Associates, Inc.'s services relative to Volume 6 of the NHRERP have been retained by the Applicants, not the State of New Hampshire". Please state whether the State of New Hampshire has l ever independently verified, directly or indirectly, the population

!' including the " resident estimates contained in the KLD ETE, l population", " peak summer weekend population" and " peak summer midweek population", f or all EPZ towns, incuding the Town of Hampton. If the State, directly or indirectly, has undertaken such verification, please 1

identify and describe

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a. All ef forts so undertaken by the State, the dates thereof, the persons undertaking such ef forts, the work performed, and the results and conclusions.

b. Identify and describe whether the State's population estimates are identical with those set forth in the KLD ETE, or if discrepancies exist, please explain the reasons therefore.

c. Identify and describe all documents relied upon by the State, ,

directly or indirectly, in support of your answer, or generated as a result of your verification efforts.

S-4: If the State of New Hampshire has not undertaken to independently verify the population estimates contained in the KLD ETE, please state whether or not, in the State's opinion, the KLD population estimates described in the previous interrogatory, including those for the Town of Hampton, are accurate and the reasons therefore.

S-5: Please identify all road repairs and/or modifications, other i than routine maintenance, performed, or in progress, by the State of New Hampshire within the EPZ from 1979 up to the present date. Please specifically identify the locations, dates, and persons in charge of performing said repairs or modifications, and the reasons why the repairs or modifications were undertaken. Identify and describe all documents upon which you rely in support of this answer.

S-6: Please state whether the State of New Hampshire has ever filed any objections or contentions with respect to the off-site emergency plans for Seabrook Etation. Please identify and describe all 4

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documents in support of your answer, or in the alternative, please

! provide legible copies of said documents with your answer.

S-7: Please identify, describe and explain the differences in the population estimates for Town of Hampton in prior draf ts of the NHRERP as compared with Revision 2. In your answer, please discuss each population group for Town of Hampton referenced in S-3.

S-8: Identify and produce for inspection and copying at the offices of Shaines & McEachern, P.A., 25 Maplewood Avenue, Portsmouth, New Hampshire 03801 all documents upon which you rely to support your answers to interrogatories S-1 to S-7.

Respe ully ub tte

[au McEachern c ( '

Matthew T. Brock SHAINES & McEACHERN, P. A.

25 Maplewood Avenue Portsmouth, NH 03 801 (603) 436-3110 DATED: /O, N27 l

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SH AINES & McE ACHERN . ==ensee . assoc 4.*e= ano.% s

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