ML20214N160

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

ML20214N160
Person / Time
Site:	Seabrook
Issue date:	05/19/1987
From:	Brock M, Mceachern M HAMPTON, NH, SHAINES & MCEACHERN
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
Shared Package
ML20214N112	List: ML20214N108 ML20214N126 ML20214N145 ML20214N160 ML20214N191
References
OL, NUDOCS 8706020084
Download: ML20214N160 (3)

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REMIED.CORREsqpg ogif: i UNITED STATES OF AMERICA I' NUCLEAR REGUIATORY COMMISSION '87 MAY 20 P6 :20 BEFORE THE ATOMIC SAFETY AND LICENSING E ARD 00CXE-o,.

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Public Service Company of New )

Hampshire, et. al. )

) Docket Nos.

(Seabrook Station, Units 1 and 2) ) 50-443, -444 N ' }

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TOWN OF HAMPTON SUPPLEMENTAL INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NUCLEAR REXiULATORY COMMISSION DE E HRH 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 Nuclear Regulatory Commission:

INSTRUCTIONS f,QE DEX The following supplemental interrogatories are to be answered in writing and under oath by an employee, representative or agent of the Nuclear Regulatory Commission (" Commission" or "NRC") with personal i

knowledge of the f acts or information requested in each interrogatory.

remind you of your obligation to supplement answers to We interrogatories, under 10 C.F.R. S 2.740 (e) (1) and (2) .

The following definitions shall apply to these interrogatories:

1. "D o c u men.t" shall m ean 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, l

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8706020004 870519 j PDR ADOCK 05000443 G l PDR SH AlNES & McE ACHERN . peoresseas assoceawo= a~eesses

instructions, reports, demands, memoranda, data, schedules, notices, lworkpapers, recordings, whether electronic or by other means, computer i data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-of fice communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other l written or graphic materials of any nature whatsoever.

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2. " Identify" with respect to any document shall mean to state the following respecting the document: Its title, its date, the author of the document, the person to whom the document was sent, all persons l

reviewed the document, the substance and nature of the lwhoreceivedor j document, and the present custodian of the document and of any and all I

j copies of the document.

"Idantify" with respect to any action or conduct shall mean 1

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state the f ollowing regarding any such action or conduct: the person

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or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about t

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

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l document recording or, documenting such action.

l l 4. "Rascriba" with respect to any action or matter shall mean i

state the following regarding such action or matte: the substance or l'

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! nature of such action or matter; the persons participating in or having I

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SH A lN ES & Mc E AC H E R N . ==ortssma, assoc a ros a ~o=%e o

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l I l knowledge of such action or matter; the current and past businessj

! positions and addresses of such persons; theexistenceandlocationofl l

' any and all documents relating to such action or matter.

SUPPLEMENTAL INTERROGATORIES:,

S-1: Please supplement, and provide a full and complete response, to TOWN OF HAMPTON INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NUCLEAR REGULATORY COMMISSION ON THE NEW HAMPSHIRE RADIOLOGICAL RESPONSE PLANS dated March 5, 1987 and previously served upon the NRC.

S-2: Please identify and describe the NRC's present position with respect to all Motions for Summary Disposition, and responses thereto, previously filed in this proceeding.

Please consider the foregoing request to be continuing in nature.

The Town of Hampton requests that the NRC timely supplement its responses when new and additional information becomes available.

Respec lly subm'tted l

l' McEachern U && 'e Matthew T. Brock

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SHAINES & McEACHERN, P.A.

25 Maplevood Avenue Portsmouth, NH 03 801 i (603) 436-3110 t

i DATED: Yb /$, /7N

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