ML20065T554

First Set of Interrogatories & Request for Production of Documents.Related Correspondence

ML20065T554
Person / Time
Site:	Seabrook
Issue date:	10/28/1982
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20065T557	List: ML20065T554 ML20065T563
References
NUDOCS 8211020574
Download: ML20065T554 (2)

Text

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l UNITED STATES OE AMERICA D .C0ap 00 gN" l NUCLEAR REGULATORY COMMISSION Y

BEFORE THE ATOMIC SAFETY AND LICENSING g ARD f_.1 mt :13 In the Matter of I

, SEuRt!AHY 1 PUBLIC SERVICE COMPANY OF Docket Nos.

NEW li AMPSillRE, et al. 50-44YCC 50-444 " bl!MC' (Seabrook Station, Units I and 2)

SAPL FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE NUCLEAR REGULATORY COMMISSION STAFF Pursuant to 10 C.F.R.42.744, the Intervenor SAPL requests that the attached Interrogatories be answered fully in writing and under oath by an employee, representative or agent of the NRC Staff with personal knowledge of the facts or informatfor. requested in each interrogatory.

L Identify the relevent site features, including population density associated with accident risk at Seabrook, in comparison to site features at presently operating plants as required by the Interim Policy Statement of June 13, 1980.

2. Identify and provide any study in which the Staff ' considered the likelihood that substantive changes in the Seabrook plant design would compensate for adverse site features.

3. State the basis for the Commission's determination of a reasoned consideration of environmental risks and the methodology used to determine such a reasoned consideration as required in the Interim Policy Statement of June 13, 1980.

4. In ~the Interim Policy Statement of June 13, 1980 the Commission's Staff identified that in certain cases unique circumstances warranted more extensive and detailed consideration of Class 9 events citing the Clinch River Breeder Reactor Plant l and the Perryman site. The Seacoast Anti-Pollution League requests the Staff l to specifically identify the analysis and the basis on which they made or are making an assessment of unique circumstances.

5. What methodology' was used to make this assessment?

Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By its Attorneys, LAW OFFICES OF ROBERT A. BACKUS

,, s/

BY-

, ROBERT A. 'B ACKUS k8#

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8211020574 821028 ' /)

PDR ADOCK 05000443 G PDR U

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P. O. Box 516 Manchester, Nil 03105 (603)668-7272 .

October 28, 1982 e