ML20214T227
| ML20214T227 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/04/1987 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| CON-#287-3697 OL, NUDOCS 8706100169 | |
| Download: ML20214T227 (4) | |
Text
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3677 name comuurOnDemn June 4,1987 09W:P NR v
UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0FFn:.. 7,
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In the Matter of
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Public Service Company of
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New Hampshire, et al.
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Docket Nos. 50-443 OL
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50-444 OL (Seabrook Station, Units 1 & 2)
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OFFSITE EMERGENCY
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PLANNING ISSUES
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NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S RESPONSE TO APPLICANTS' OFF-SITE EP INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS, DATED MAY 19, 1987 The New England Coalition on Nuclear Pollution ("NECNP")
responds below to interrogatories propounded by Applicants on May 19, 1987.
Please note that all of the information requested in interrogatory II was previously supplied by NECNP in its May 20, 1987, response to Applicants' earlier interrogatories on this subject.
ANSWERS TO INTERROGATORIES II.l.
Referring to NECNP's Opposition to Applicants' Motion for Summary Disposition on Contention NHLP-2 at page 6:
(a)
Identify the two towing company officials and the com-panies whom they purportedly represent who, NECNP represents, stated that they "were not aware that they were never [ sic] informed that they were listed in the plans."
ANSWER:
Those individuals are Dave Lavoie of Dave's Garage, 3 21 Ocean Boulevard, Hamp ton, New Hampshire, and Dan Ploth of Lymon's Auto, 7 00 Laf ayette St reet, Hampton, New Hampshire.
(b)
Identify the " owner of one of the [towning] c omp anies" who, NECNP represents, " told NECNP that he did not believe any of his employees would stay to assist in a radiological emergency."
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2-ANSWER:
Dave Lavoie.
(c)
Identify the person and his or her company who, NECNP represents, " told NECNP that it contracts its towing from another company and does not have any vehicles."
ANSWER:
That statement was made by an unidentified individ-ual at the Hampton 66 towing company in Hampton, New Hampshire.
(d)
Identify the NECNP representatives (s) of other per-sons (s) to whom the information recited in the forego-ing Interrogatories 1(a), (b), and (c) was given and identify any related documents.
ANSWER:
The information was given by telephone to Rhonda Kranz, who was at that time employed as a paralegal with the firm of Harmon & Weiss.
Ms. Kranz lives at 1301 15th St. N. W. Ap t.
115, Washington, D.C. 20005.
Documents related to this inter-rogatory consist of NECNP Contention NHLP-2, filed February 24, 1986, and NECNP's Res'ponse to Applicants' Interrogatories and Request for the Production of Documents, dated May 20, 1987, at 17-18, 2.
Referring to NECNP's opposition to Applicants' motion for summary disposition on contention NHLP-4 and to the Af fidavit from Clotilde M. Straus sponsored by you and incorporated therein:
(a)
State in what manner the information concerning Ms.
Straus's hearing impairment was communicated to Public Service Company of New Hampshire.
ANSEER:
Ms. Straus answered a questionnaire that was sent to her by Public Service Company of New Hampshire.
On the questionnaire, she indicated that she was hearing-impaired.
(b)
State when this information was communicated.
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.. ANSWER:
Ms. Straus returned the questionnaire when she received it.
To her best recollection, this was approximately one and one half to two years ago.
(c)
State whether this information was also communicated to the New Hampshire Civil Defense Agency, and, if so, in what manner and when.
ANSWER:
Ms. Straus did not communicate with the New Hampshire Civil Defense Agency, and has no personal knowledge of whether the information was communicated by PSNH to the NHCDA.
III.
Document request.
All documents responsive to Applicants' interrogatories are identified above.
They have been filed with the NRC and served on Applicants.
I certify that the foregoing answers to Applicants' i n te r-rogatories are true and correct to 4hg best of knowledge.
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Diane Curran Respectfully submitted,
'ane Curran l
HARMON & WEISS 2001 "S" Street N.W. Suite 430 Washington, D.C.
20009 (202) 328-3500 l
June 4,1987 I
I certify that on June 4,1987, copies of the foregoing ans-l wers to interrogatories were served by first-class mail or as i
otherwise indicated on the attach ervice list.
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Diane Curran
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