ML20215J799
| ML20215J799 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/15/1987 |
| From: | Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20215J802 | List: |
| References | |
| CON-#287-3813 OL, NUDOCS 8706250116 | |
| Download: ML20215J799 (2) | |
Text
r 3g)3 Ju ne.15, 1987
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- nNW UNITED STATES NUCLEAR REGULATORY' COMMISSION BEFORE THE ATOMIC SAFETY AND LLCENSING BOARD 07 DON 18
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In the Ma tter of.
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BPANcu Public-Service Company of
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Nev !!ampshire, et al.
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Docket Nos. 5 0-443 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 MOTION TO COMPEL ANS%ERS TO NECNP' S THIRD SET OF INTERROGATORIES ANC REQUEST FOR THE PRODUCTION OF DOCUMENTS TO STATE OF NEW HAMPSHIRE ON REVISION 2.TO THE MEh HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN The New England Coclition on Nuclear Pollution ("NECNF")
hereby requests'that the Licensing Board order the State of New Hampshire to provide answers to Interrogatory 4, to which the State did not provide a complete answer.
Interrogatory 4(a) requests the State to describe, inter alia, how many state per-nonnel are assigned to the EPZ on a daily basis, how many go only j
once in a while, and what is the frequency of their attendance in' l
the EPZ.
In answering the interrogatory, the State identified a number of agencies having personnel in the EPZ, but did not pro-vide complete information for every agency identified.
For' instance, while the State described how many DRED and Fish & Game j
personnel are in the EPZ every day, it failed to quantify the number of personnel f rom State Police Troop A, DOT, or the New Hampshire Civil Defense Agency.
Moreover, it did not state at what f requency personnel f rom the NHCDA are in the EPZ.
Fi nally,
8706250116.970615 ADOCK05000g3 3 j!
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2-the State did not describe the number of seasonal Fish & Game personnel that are in the E PZ, and at what frequency they attend.
Althougn the Board has ruled that New Hampshire is not t
required to answer NECNP's interrogatories, the State has not objected to this particular interrogatory, and has conceded that it can provide useful information in this litigation.
Therefore, 1
NECNP requests the Board to order the State to complete its ans-1 i
wet to NECNP Interrogatory 4.
i Respectfully submitted,
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Diane Curran HARMON & WEISS 2001 "S" St reet N. W.
Suite 4 30 Washington, C.C.
20009 (202) 328-3500 June 15, 1987 I
I certify that on June 15, 1987, copies of the foregoing Motion to Compel were served by hand, overnight mail, or first-class mail on all parties to this proceeding, as designated on the attached service list.
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v, Diane Curran j
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