ML20214T163
| ML20214T163 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/04/1987 |
| From: | Brock M, Mceachern P HAMPTON, NH, SHAINES & MCEACHERN |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| CON-#287-3674 OL, NUDOCS 8706100148 | |
| Download: ML20214T163 (6) | |
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~87 JN -5 P2 :02 before the ATOMIC SAFETY AND LICENSING BOARD gg, 3 00CnETi%
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June 4, 1987 In the Matter of
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PUBLIC SERVICE COMPANY OF
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Dockat Nos. 50-443-OL NEW HAMPSHIRE, et al.
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50-444-OL
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Off-site Emergency (Seabrook Station, Units 1 and 2)
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Planning Issues
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s TOWN OF HAMPTON RESPONSE TO-APPLICANTS' OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO TOWN OF HAMPTON AND MOTION FOR PROTECTIVE ORDER NOW COMES the Town of Hampton and responds to Applicants' interroga-tories and request for the production of documents as follows:
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, sponscred 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 If the former, identify the beginning within TOH at one point in time.
and end of the period of time.
If the latter, identify the point of time.
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4 1 V ANSWER:
(a) fall documents identified and/or marked as exhibits in the deposition;of Glen French; Applicants have already examined Mr.
French at deposition with reference to his method or model in computing By way of further answer, Town of Hampton population estimates.
i relies upon those documents identified in, or included as attachments with, TOWN OF HAMPTON ANSWER OPPOSING APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION (TOH VI), including prior drafts of the NHRERP.
Applicants are in possession.of these source documents and the method or model for computing population estimates is as identified therein.
By way of final answer, Town of Hampton relies upon the researches, opinions, I
and conclusions of Alan Luloff.
Applicants were previously provided with a detailed affidavit from Mr. Luloff regarding his ongoing research, The '
which continues at present, on the issue of population estimates.
Town of Hampton further incorporates by reference JOINT RESPONSE BY SHANNON, SEACOAST ANTI-POLLUTION LEAGUE, AND ATTORNEY GENERAL JAMES M.
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TOWN OF HAMPTON TO APPLICAMTS' OFF-SITE EP INTERROGATORIES AND REQ FOR PRODUCTION OF DOCUMENTS TO ATTORNEY GENERAL FOR THE COMMONWEALT OF MASSACHUSETTS, SEACOAST ANTI-POLLUTION LEAGUE, AND TOWN-OF HAMPTON, l
including " motion for protective order to sustain objections set forth in the foregoing answers to interrogatories" filed therewith.
t (b) Applicants' question is not clear.
If by " summer we'ekend-population estimates" Applicants refer to figures identified in the 4
Affidavit of Glen French, Mr. French has already provided a deposition
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If Applicants refer to prior drafts of the NHRERP,-
on this issue.
those population estimates are as noted in those prior drafts.
By way of further answer, The Town of Hampton incorporates by reference JOINT RESPONSE BY ATTORNEY GENERAL JAMES M. SHANNON, SEACOAST ANTI-POLLUTION LEAGUE, AND TOWN OF HAMPTON TO APPLICANTS' OFF-SITE EP INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO ATTORNEY GENERAL FOR TH COMMONWEALTH OF MASSACHUSETTS, SEACOAST ANTI-POLLUTION LEAGUE, AND TOWN OF HAMPTON, including " motion for protective order to sustain objections set forth in the foregoing answers to interrogatories" filed therewith.
DOCUMENT REQUEST S 2.741, Applicants request that TOH, pursuant to 10 C.F.R.
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.
j-ANSWER:
Those documents with reference to the population estimates of l
Glen French have already been provided to Applicants; prior drafts of l
the NHRERP are in Applicants' possession; and by way of final answer, the Town of Hampton incorporates by reference JOINT RESPONSE BY ATTORNEY GENERAL JAMES M. SHANNON, SEACOAST ANTI-POLLUTION LEAGUE, AND 2
SHAIPES En McEACPERN. poorESSIONAL ASSOCIATION 25 MAPLEWOOD AVENUE P O. BOX 3e0. PORTSMOUTH. N M 03eot
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1 TOWN OF HAMPTON TO APPLICANTS' OFF-SITE EP INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS, SEACOAST ANTI-POLLUTION LEAGUE, AND TOWN OF HAMPTON, including " motion for protective order to sustain objections set forth in thd foregoing answers to interrogatories" filed therewith.
Respectfully submitted, THE TOWN OF HAMPTON By Its Attorneys SHAINES &
cEACHERN, P.' A.
By g Paul McEachern s
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Dated:
June 4, 1987 By N
w Matthew T.
Brock l
3 swees a w.acumu. PRMSSOA A55NATOd 25 MAPLEWOOD AVENUE P O BOX $60 PORTSMOUTH N M. 03801
1 CERTIFICATE OF SERVICE 90C PfiiZ
- spr I, Matthew T.
Brock, one of the attorneys for the Town of Hampton herein, hereby certify that on June 4, 1987 I mad
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service of lhe following document TOWN OF HAMPTON RESPONS T
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OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO TOWN OF HAMPTON AND MOTION FOR PROTECTIVE ORDER by de@ sit.ing:.
copies thereof in the United States Mail first class posM@d'Nhr\\J~ Essed to:
'S prepaid for delivery (or, where indicated, by Express Mail, a
- Helen Hoyt, Esq., Chairman
- Judge Gustave A.
Linenberger, Jr.
Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel East West Towers Building U.S. Nuclear Regulatory Comm.
4350 East West Highway East West Towers Building e
Bethesda, MD 20814 4350 East West Highway Bethesda, MD 20814
- Dr. Jerry Harbour Atomic Safety and Licensing Board
- Atomic Safety and Licensing Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.
East West Towers Building Washington, DC 20555 4350 East West Highway Bethesda, MD 20814
- Atomic Safety and Licensing Appeal Board Panel
- Docketing and Service U.S.
Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Mrs. Anne E.
Goodman William S.
Lord, Selectman Board of Selectmen Town Hall 13-15 Newmarket Road Frien.d Street Durham, NH 03842 Amesbury, MA 01913 Jane Doughty Rep. Roberta C. Pevear Seacoast Anti-Pollution League Drinkwater Road 5 Market Street Hampton Falls, NH 03844 Portsmouth, NH 03801
- Fhilip Ahrens, Esq.
- Thomas G.
Dignan, Esq.
Assistant Attorney General George H.
Lewald, Esq.
Office of the Attorney General Kathryn A.
Selleck, Esq.
State House Ropes & Gray Station 6 225 Franklin Street Augusta, ME 04333-Boston, MA 02110 Robert A.
Backus, Esq.
- Sherwin E.
Turk, Esq.
Backus, Meyer & Solomon Office of the Exec. Legal Dir.
111 Lowell Street U.S.
Nuclear Regulatory Comm.
Manchester, NH 03105 Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814 SHAINES & McEACHERN. PROFESSaONAL ASSOCATION 2S MAPLEWOOO AVENUE P O. BOX 360 PORTSMOUTH, N H. 03801
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L5 Mr. Angie Machiros,-Chairman H. Joseph Flynn, Esq.
Board of~ Selectmen Office of General Counsel-Newbury,-MA 01950 Federal Emergency Mgmt. Agency 500 C Street, S.W.
- George Dans Bisbee, Esq.
Washington, DC 20472
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Stephen E. Merrill, Esq.
Office of the Attorney General
- Carol S. Sneider, Esq.-
State House Annex Donald S. Bronstein, Esq.
Concord, NH 03301 Allan.R. Fierce, Esq.
Dept. of the Attorney General One Ashburton Place Stanley W.~Knowles' 19th Floor Board of Selectmen Boston, MA 02108 P.O. Box 710 North Hampton, NH
- 03862 J. P. Nadeau, Selectman Richard E. Sullivan Selectmen's Office Mayor
- 10. Central Road.
City Hall Rye,RNH 03870 Newburyport, MA 01950.
Alfred V. Sargent, Chairman Senator GordonLJ. Humphrey&
Board of Selectmen U.S. Senate Town of Salisbury.
Washington, DC-20510 Salisbury, MA-01950 (Attn:
Tom Burack)-
Michael-Santosuosso, Chairman Allen Lampert Board'of Selectmen Civil Defense Director Jewell St.,.RFD 2 Town of Brentwood So. Hampton, NH
~03827 Exeter, NH 03833 Richard A. Hampe, Esq.
Gary W. Holmes, Esq.
Hampe and McNicholas Holmes and Ellis 35 Pleasant Street 47 Winnacunnet Road Concord, NH 03301 Hampton, NH 03842 William Armstrong Calvin A. Canney, City Manager L
Civil Defense Director City Hall 10 Front. Street 126 Daniel. Street Exeter,ENH
'03833 Portsmouth, NH 03801
- Edward A. Thomas-Sandra Gavutis Federal Emergency Mgmt. Agency Town of Kensington 442 J.W.- McCormack (POCH)
RFD 1, Box 1154 Boston, MA 02109 East Kensington, NH 03827 Charles P. Graham, Esq.
- Diane Curran, Esq.
l-McKay, Murphy & Graham Andrea C. Ferster, Esq.
100 Main Street Harmon & Weiss L
Amesbury, MA-01913 Suite 430 2001 S Street, N.W.
Washington, DC 20009-1125 l
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l SHANES Es McEACHEFW4 PROFESSaONAL ASSOOATION 25 MAPLEWOOD AVENUE R O. BOX 300 PORTSMOUTH, NJt 03501
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l Robert Carrigg,' Chairman Senator Gordon J. Humphrey Board of Selectmen One Eagle Square, Suite 507 Concord, NH 03301 Town Office.,.
Atlantic Avsnue:
(Attn:
Herb Boynton)
North Hampton, NH 03862 Mr. Thomas H. Powers, III Mr. Peter Matthews Town Manager Mayor Town of Exeter City Hall 10 Front Street Newburyport, MA 01950 Exeter, NH 03833 Brentwood Board of Selectmen Judith H. Mizner, Esq.,
RFD Dalton Road Silvergate, Gertner, Baker, Brentwood, NH 03833 Fine, Good & Mizner 88 Broad Street Boston, MA 02110
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Matthew T.
Brock
- UPS NEXT DAY AIR 3
SHAINES to McEACHERN = PROFESSIONAL A$500ATION 25 MAPLEWOOD AVENUE R O. DOX 300. PORTSMOUTH, NN. 03801
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