ML20154A052

Applicant First Set of Interrogatories & First Request for Production of Documents to All Parties & Participating Local Govts Re Contentions on Seabrook Plan For....* W/ Certificate of Svc.Related Correspondence

ML20154A052
Person / Time
Site:	Seabrook
Issue date:	08/31/1988
From:	Trout J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#388-7006 OL, NUDOCS 8809120032
Download: ML20154A052 (10)

Text

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August 31, 1988

'88 SEP -1 P2 :23 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ((CNC i a . $ ' , - v'Y.'

B R t.Ne before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

PUDLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues

)

)

APPLICANTS' FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO ALL PARTIES AND PARTICIPATING LOCAL GOVERNMENTS REGARDING CONTENTIONS ON THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES Pursuant to 10 C.F.R. 55 2.740b and 2.741, Applicants hereby request that each party, and each local government participating pursuant to 10 C.F.R. 5 2.715(c), respond to the following interrogatories, and produce for inspection and copying the documents requested below. The production of the documents requested herein shall take place at the offices of Ropes & Gray, 225 Franklin Street, Boston, Massachusetts, at 10 a.m. on Monday, October 3, 1988.

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DEFINITIONS AND INSTRUCTIONS

1. The term "document" is defined to be synonymous in meaning and equal in scope to the usage of the term "documents and tangible things" in Federal Rule of Civil Procedure 34(a), and therefore shall include, without L limitation, any written or otherwise recorded information.

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2. To "identify" a document means to either:

(a) state the author, date, title, addressee (s), and ,

subject matter of each individual document; or (b) if a request calls for the identification of more than twenty documents similar in subject matter, And those documents are also being produced, list

• i the subject matter categories of documents, l i

indicating the number of responsive documents in [

each category.

3. To "identify" a person other than an expert witness means to state the person's full name, title, business  ;

address, affiliation, and professional qualifications  ;

(if any). To "identify" an expert witness means to ,

state, in addition to the foregoing:  !

( a ,' the profession or occupation and field (s) of expertise of the persont  ;

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(b) the educational and specialized training history of the person, including date and granting institution of all degrees earned; (c) a list of publications by the person in the area (s) of expertise; and (d) the age of the person and the amount of time the person has worked in the field of expertise.

4. If any of the interrogatories or document production requests contained heroin sre claimed to be objectionable, then please identify the portion (s) to which objection is made and the portion (s) to which answer or production is made.

5. If it is claimed that any document responsive to any request is privileged, please fully identify each privileged document in accordance with Instruction 2(a) above.

6. If any document required to be identified or produced in these answers has been destroyed, please identify the document, state the date of its destruction, identify the person responsible for ordering destruction, state the purpose of destruction, and (if applicable) produce any document retention policy that governed or should have governed the retention or destruction of the document.

7. "SPMC" means the Seabrook Plan for Massachusetts Communities, and all appendices, amendments, and' attachments thereto.

8. The "Emergency Planning Act" means the Emergency '

Planning and Community Right to Know Act of 1986, 42 U.S.C. i 11001 et sea., and all federal and state regulations promulgated pursuant thereto.

9. The "Massachusetts EPZ" means the Massachusetts portion of the Emergency Planning Zone for Seabrook Station and i consists of Amesbury, Merrimack, Newbury, Newburyport, Salisbury, and West Newbury.

10. The term "contention" is defined to include the complete  ;

text of the contention itself and all bases and sub-bases thereto. l l

INTERROGATORIES AND REOUESTS FOR PRODUCTION  ;

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1. Please identify the person (s) answering or substantially contributing to the answer to each of the following interrogatories. [

2. Please identify and produce all documents, and describe in detail all conversations not otherwise reflected in r such documents, which reflect or refer to what actions any Massachusetts state or local government entity or i

official would, could, might, would not, could not, or I

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might not take in the event of an actual radiological emergency at Seabrook Station.

3. Please identify and produce all documents, and describe in detail all conversations not otherwise reflected in such documents, which reflect, refer to, or relate in any way to any action by any Massachusetts state or local government official or entity to block, hinder or delay the licensing of Seabrook Station.

4. Please identify and produce all documents generated after January 1, 1980 that reflect or refer to any emergency planning (other than that engaged in by Applicants) conducted or contemplated for the Massachusetts EPZ or any portion thereof, including but not limited to emergency planning required pursuant to the Emergency Planning Act. Such documents should include, but not be limited to, documents that reflect l

or refer to whether the SPMC or any other plan for l l

dealing with a radiological emergency at Seabrook

• Station has or has not been, or will or will not be, l used in planning for emergency situations other than those involving Seabrook Station.

5. Please list overy admitted SPHC contention which you do not intend to participate in litigating, i.e.,

I concerning which you will not take discovery, present  !

r___ _-__________-______________ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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l evidence, make arguments, conduct cross-examination, or submit proposed findings.

6. For every admitted SPMC contention that you submitted and do not hereby withdraw, and for every other admitted ,

SPMC contention that you did not list in response to Interrogatory 5 above, individually for each such contention please:

(a) State in detail all the facts underlying each assertion contained in the contention; (b) State the source of each such fact. If the source f

is the personal knowledge of one or more persons, identify the person (s). If the source is one or -

more documents, identify and produce the document (s); j (c) Identify any expert witness who is to testify concerning the contention, and state the substance 1

of the facts, opinions, and grounds for opinions to which the expert is expected to testify; (d) Identify any non-expert witness who is to testify  ;

t concerning the contention, and state the substance i

of the facts to which the witness is expected to testify and [

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(e) Identify and produce any documents which reflect or refer to any type of study, calculation or analysis bearing upon the substance of the contention.

By their attorneys,

g dy NMtb Thomas G. Dignan, Jr.

Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smityh Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 l

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'88 SEP -1 P2 :23 '

CERTIFICATE OF SERVICE

.n. .

I, Jeffrey P. Trout, one of the attorneys for $ hat- . . - .-

Applicants herein, hereby certify that on August 31, 1988f5I' mado service of the within document by depositing copies i thereof with Federal Express, prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):

Administrative Judge Ivan W. Smith Robert Carrigg, Chairman Chairman, Atomic Safety and Board of Selectmen Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Judge Gustave A. Linenberger Diane curran, Esquire Atomic Safety and Licensing Andrea C. Ferster, Esquire Board Panel Harmon & Weiss U.S. Nuclear Regulatory Suite 430 l Commission 2001 S Street, N.W.

4 East West Towers Building Washington, DC 20009 .

4350 East West Highway '

Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill ,

Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street  !

4350 East West Highway Concord, NH 03301-6397 l Bethesda, MD 20814 r Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel  :

Board Panel Docket (2 copies) U.S. Nuclear Regulatory [

U.S. Nuclear Regulatog Commission Commission East West Towers Building One White Flint North, 15th Fl.

4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852

• Atomic Safety and Licensing Robert A. Backus, Esquire l Appeal Board Panel 116 Lowell Street l U.S. Nuclear Regulatory P. O. Box 516 l 1 Commission Manchester, NH 03105 l Washington, DC 20555 t

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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 & McCachern Department of the Attorney 25 Maplewood Avenue General P.O. Box 360 One Ashburton Place, 19th Fl.

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 Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

• Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Clark, Hill-Washington, DC 20510 Whilton & McGuire (Attn: Tom Burack) 79 State Street Newburyport, MA 01950

• Senator Gordon J. Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 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, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 1

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l Mr. Ed Thomas Judith 11. Mizner, Esquire FEMA, Region I 79 State Street, 2nd Floor 442 John W. McCormack Post Newburyport, MA 01950 i office and Court House l' Post Office Square Boston, MA 02109 1

Ashod N. Amirian, Esquire Leonard Kopelman, Esquire 376 Main Street Kopelman & Paigo, P.C.

Haverhill, MA 01830 77 Franklin Street Boston, MA 02110

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