ML20215L783
| ML20215L783 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/28/1986 |
| From: | Graham C AFFILIATION NOT ASSIGNED, MCKAY, MURPHY & GRAHAM, SALISBURY, MA |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| CON-#486-1286 82-471-02-OL, 82-471-2-OL, OL, NUDOCS 8610290283 | |
| Download: ML20215L783 (8) | |
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...*seonociCA C0CKETED United States of America USNRC Nuclear Regulatory Commission Atomic Safety and Licensing Board
'E6 0CT 28 A11 :31 CFFI;; ~..
"0CE i Ph A IN THE MATTER OF
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Docket Nos. 50-443-OL PUBLIC SERVICE COMPANY
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50-444-OL OF NEW HAMPSHIRE, ET AL
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ASLB No. 82-471-02-OL
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TOWN OF SALISBURY'S ANSWERS AND RESPONSES TO INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS FILED BY THE APPLICANTS APRIL 28, 1986 Introductory Response On October 20, 1986, pursuant to an ordara3 dated October 17, 1986 of the Atomic Safety and Licensing Board, the Town of Salisbury was presented with 122 pages of interrogatories and document requests which, if the Town was to benefit from the order, were to be answered and returned within fourteen (14) days.
In consideration of the limited personnel available for immediate attention to the required answers and responses and the perceived need to remain a participant in the licensing proceeding, the Town of Salisbury sets forth the answers required in a format wherein the question does not proceed the e
answer.
This is done to ensure receipt of the answers by all parties prior to the deadline imposed by the Board.
The Town recognizes its obligation to supplement answers and responses herein set forth, and as more information or documents relevent to such interrogatories and requests becomes available to the Town if shall be set forth in the appropriate supplemented response.
Response to Requests for Production of Documents 1.
There are currently no documents in the possession or control of the Town of Salisbury that are in any way within the scope of the request.
The Town recognizes its obligation to supplement this request.
Answers to Interrogatories McKAY, MURPHY General Interrogatories AND GRAHAM G-1 No t.iton;; tis At law (LD P!$t (FFICr 803ARE G-2 No ieo s:An. st,ur AP ESOU;Y, MASS. 0l913 G-3 No Og102h203e6 m n s...sss.
43 0CK 05 pg OS
G-4 (a)
No as to all New Hampshire Towns (b)
Not applicable (c)
Not applicable (d)
Not applicable G-5 (a)
Town of Salisbury has no knowledge as to any emergency plans adopted, or considered by any New Hampshire Town within the Emergency Planning Zone (b)
Not applicable (c)
The Town of Salisbury has not prepared and is not in the process of preparing such a plan.
the Town has no knowledge as to planning preparation of any of the New Hampshire Towns.
(d)
Not applicable G-6 (a)
The Town of Salisbury has no knowledge as to conduct of public officials in New Hampshire Towns with respect to Emergency Planning for Seabrook Station (b)
Not applicable G-7 (a)
The Town of Salisbury has no knowledge as to conduct of public officials in New Hampshire Towns with respect to Emergency Planning for Seabrook Station (b)
Not applicable G-8 (a)
The Town of Salisbury has no knowledge as to conduct of public officials in New Hampshire Towns with respect to Emergency Planning for Seabrook Station (b)
Not applicable (c)
Not applicable (d)
Not applicable G-9 (a)
The Town of Salisbury has no knowledge as to conduct of public officials in New Hampshire Towns with respect to Emergency Planning for Seabrook Station (b)
Not applicable (c)
Not applicable (d)
Not applicable Specific Interrogatories I-l No McKAY. MURPHY AK)cRAHAM II-l No ATT0!XIVs AT L AW otor:srerriersau^"8 III-l No 100 C AIN STRif f casr;.v. rAss. 0iet s IV-1 No (61H 300 9354
9 V-1 No VI-l Yes VI-2 No VI-3 No such studies are known to the Town of Salisbury at this time.
VI-4 Yes.
The 'lown of Salisbury believes that potentially dangerous airborne release of radioactive material on a hot summer weekend day in the beach area could occur in circumstances wherein beach population figures would be so large that sheltering would have to be considered as an alternative to evacuation.
The basis for this response is a general understanding that, under certain combinations of circumstances within the proposed facility, a potentially dangerous airborne release of material could occur within a short enough time from the onset of difficulty to warrant consideration of sheltering certain beach populations as opposed to an attempt to implement a complete evacuation plan for the beaches which must confront obvious topographical and managerial impediments to the timely removal of such populations.
VI-5 No such witness is known at this time.
VII-l No Vill-1 No IX-1 No X-1 No XI-l No XII-l No XIII-l No XIV-1 No McKAY. MURPHY
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AND GRAHAM ATTC/EYS AT LAW
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XV-3 The Town of Salisbury is without sufficient knowledge, belief or expertise to provide an 4:essing, m Ass. ems opinion with respect to this interrogatory at this tom no.nse time.
XV-4 No expert witness with respect to this issue is known to the Town of Salisbury at this time.
XVI-l No XVII-l No XVIII-l No XIX-1 No XX-1 No XXI-l No XXII-l No XXIII-l No XXIV-1 No XXV-1 No XXVI-l No XXVII-l No XXVIII-l No XXIX-1 No XXX-1 No i
XXXI-l No XXXII-l No XXXIII-l No i
XXXIV-1 No XXXV-1 No XXXVI-l No XXXVII-l No l
XXXVIII-l No McKAY. MURPHY AND GRAHAM XXXIX-1 Yes Aff2WtVS At L.AW
( oto nst ernci sou..,
XXXIX-2 Although a precise response is unavailable to the Town of Salisbury at this time, the Town of see u m st. ear
' ariseva. cass. ei,is Salisbury recognizes its obligation to supplement sein see.asse
4 this answer in the event it intends to litigate this contention.
XXXIX-3 No such expert has been identified by the Town of Salisbury at this time.
XL-1 No X LII-l No Respectfully submitted, Town of Salisbury, By its Attorney:
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Charles P.(Graham, Esquire McKay, Murphy and Graham 100 Main Street Amesbury, MA 01913 (617) 388-3354 McKAY MURPHY AN3 eRAHAM KTf!!itTS AT LAW OL3 P;ST CFFICE SQUARt 100 Cf.12 STREff Alt 98URY. Matt. 01813 le87) 300 33S4
i cri sTrn enoRESPONDENC4 COCKETED CERTIFICATE OF SERVICE
' DRC J
I, Charles P. Graham, Attorney for the TOWN OF L
Y, hereby certify that copies of the within Answers and Responses 0FFifi l-to Interrogatories and Request for Production of Dqcoments Filed s
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by the Applicants' April 28, 1986 have been served upon the attached list of parties by first class mail, postage prepaid, this f day of October, 1986.
IIelen Iloyt, Chairperson Robert Carrigg, Chairman Atomic Safety and Licensing Board of Selectmen Board Panel Town Office U.S.
Nuclear Regulatory Atlantic Avenue Commission North Hampton, NII 03862 Washington, DC 20555 Dr. Emmeth A.
Luebke Diane Curran, Esquire Atomic Safety and Licensing Andre, C.
Perster, Esquire Board Panel liarmca & Weiss U.S.
Nuclear Regulatory 2001 S Street, N.W.
Commission Suite 430 Washington, DC 20555 Washington, DC 20009 Dr. Jerry liarbour Stephen E. Merrill, Esquire Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee, Esquire U.S.
Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General Washington, DC 20555 25 Capitol Street Concord, NH 03301-6397 Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the General Counsel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Robert A.
Backus, Esquire McKAY, MURPHY Appeal Board Panel Backus, Meyer & Solomon AND GRAHAM U.S.
Nuclear Regulatory 116 Lowell Street Commission P.O.
Box 516 n, n:,,.., t.,
Washington, DC 20555 Manchester, Nil 03105
- eto ner rrier souA,
100 % Atj STRiti CESOU2Y % ASS. 01913 (617) 300 3354
Philip Ahrens, Esquire Mr. J.P.
Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S.
Sneider, Esquire Matthew T.
Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney 25 Maplewood Avenue General P.O.
Box 360 One Ashburton Place, 19th Floor Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Kensington, NH 03827 126 Daniel Street Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. Angie Machiros U.S.
Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn:
Tom Burack)
Town of Newbury Newbury, MA 01950 Senator Gordon J. Ilumphrey Mr. Peter S. Matthews 1 Pillsbury Street Mayor Concord, Nil 03301 City Hall (Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F.
Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NII 03833 II. Joseph Flynn, Esquire Brentwood Board of Selectmen l
Office of General Counsel RFD Dalton Road j
Federal Emergency Management Brentwood, NH 03833 Agency i
500 C Street, S.W.
Washington, DC 20472 Gary W.
IIolme s, Esquire Richard A. Hampe, Esquire IIolmes & Ells Hampe and McNicholaa 47 Winnacunnet Road 35 Pleasant Street llampton, Nil 03841 Concord, NH 03301 l McKAY. MURPHY AND GRAHAM l
Attsittis AT LAW
! oto P:st crrect souans 110 R4A sinfET
! As ts;un, EAss. etets (son see.ssse i
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Mr. Ed Thomas Judith H. Mizner, Esquira FEMA, Region I Silverlate, Gertner, Baker 442 John W. McCormack Post Fine, Good & Mizner Office and Court House 88 Broad Street Post Office Square Boston, MA 02110 Boston, MA 02109 Mrs. Anne E.
Goodman, Chairman Beverly Hollingworth Board of Selectmen 209 Winnacunnet Road 13-15 Newmarket Road Hampton, NH 03842 Durham, NH 03824 Michael Santasuosso R.K.
Gad III, Esquire Board of Selectmen Ropes & Gray So. Hampton, NH 03827 225 Franklin Street Boston, MA 02110 Allen Lampert Ms. Jane Doughty CD Director SAPL Town of Brentwood 5 Market Street 20 Franklin Street Portsmouth, Nll 03801 Exeter, Nil 03833 Mr. Robert J.
Harrison Roberta C.
Pevear Pres. & CEO Drinkwater Road PSNil llampton Falls, NH 03844 P.O.
Box 330 Manchester, Nil 03105 For the Town of Salisbury:
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Charles Q./ Graham s.
Town Counsel l
McKAY. MURPHY AND GRAHAM A1101~ ETS Af LAW OLD PIST orFICt SQUARt 100 C All STREET
,zts;'u;f, C ASS. Oltt 3 (417) 308-3354