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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20066A3931990-12-26026 December 1990 Commonwealth of Ma Atty General Response to Licensee First Set of Interrogatories Re Remanded Massachussetts Teacher Issues.W/Certificate of Svc.Related Correspondence ML20065T9551990-12-10010 December 1990 Licensee First Set of Interrogatories & First Request for Production of Documents to Commonwealth of Ma Atty General Re Remanded Massachusetts Teacher Issues.* W/Certificate of Svc.Related Correspondence ML20246H7051989-05-0505 May 1989 Applicant Supplementary Response to Intervenors Discovery Requests.* Certificate of Svc Encl.Related Correspondence ML20245E6531989-04-21021 April 1989 Commonwealth of Ma Atty General Supplemental Answer to Applicant Expert Witness Interrogatories.* Prof Qualifications of Expert Witnesses Encl.W/Certificate of Svc.Related Correspondence ML20248F8531989-04-0303 April 1989 Applicant Voluntary Responses to Commonwealth of Ma Atty General Interrogatories on Use of Bed Buses & Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl.Related Correspondence ML20248F6691989-04-0303 April 1989 Applicant Supplemental Answers to Commonwealth of Ma Atty General Expert Witness Interrogatory.* Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20247A5721989-03-24024 March 1989 Applicant Voluntary Responses to Commonwealth of Ma Atty General Interrogatories & Request for Production of Documents That Pertain to Exercise Areas Requiring Corrective....* W/Certificate of Svc.Related Correspondence ML20247A5921989-03-24024 March 1989 Applicant Voluntary Responses to Commonwealth of Ma Atty General Requests for Documents & Info on Exercise.* W/ Certificate of Svc.Related Correspondence ML20236D5001989-03-16016 March 1989 NRC Staff Further Supplemental Response to Town of Hampton First Set of Interrogatories & Request for Production of Documents to NRC Staff on 880628-29 Exercise (Exercise).* Certificate of Svc Encl.Related Correspondence ML20236C2161989-03-10010 March 1989 NRC Staff Supplemental Response to Town of Hampton First Set of Interrogatories & Request for Production of Documents to NRC Staff on 880628-29 Exercise.* W/Certificate of Svc. Related Correspondence ML20236C3901989-03-0808 March 1989 NRC Staff Supplemental Response to Town of Amesbury First Set of Interrogatories & Request for Production of Documents to NRC on Seabrook Plan for Commonwealth of Ma Communities (Spmc).* W/Certificate of Svc.Related Correspondence ML20236A4311989-03-0707 March 1989 Applicant Supplemental Answers to Intervenors Interrogatories Re Transportation Resources.* Supporting Info & Certificate of Svc Encl.Related Correspondence ML20235V6971989-02-28028 February 1989 Applicant Supplemental Answers to Intervenor Expert Witness Interrogatories.* Certificate of Svc Encl.Related Correspondence ML20235N1821989-02-21021 February 1989 FEMA Responses to Town of Hampton First Set of Interrogatories & Request for Production of Documents to FEMA on 880628-29 Exercise.* W/Certificate of Svc.Related Correspondence ML20206M9271988-11-22022 November 1988 Town of West Newbury Response to NRC Staff Motion to Compel Answers to Interrogatories & Production of Documents by Town of West Newbury.* Certificate of Svc Encl ML20206M9461988-11-22022 November 1988 Responses of FEMA to Town of Amesbury First Set of Interrogatories & Request for Production of Documents to FEMA on Seabrook Plan for Commonwealth of Ma Communities.* W/Certificate of Svc.Related Correspondence ML20206J8331988-11-21021 November 1988 New England Coalition on Nuclear Pollution Second Set of Supplemental Answers to Applicant First Set of Interrogatories Etc & Answers to Applicant Interrogatories & Request For....* Svc List Encl.Related Correspondence ML20206J6811988-11-15015 November 1988 Answers of Commonwealth of Ma Atty General to Applicant Request for Admissions to Commonwealth of Ma Atty General.* Certificate of Svc Encl.Related Correspondence ML20206J6581988-11-15015 November 1988 Joint Intervenors Answers to Applicant Request for Admissions to Intervenors.* Related Correspondence ML20206J6381988-11-15015 November 1988 Commonwealth of Ma Atty General Response to Applicant Second Request for Protection of Documents.* Atty General Will Produce Response Documents from Agencies Listed in Response 2.Related Correspondence ML20206J8691988-11-15015 November 1988 Applicant Response to Commonwealth of Ma Atty General Second Request for Production of Documents to Applicant Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl.Related Correspondence ML20206C5561988-11-11011 November 1988 Seacoast Anti-Pollution League Response to Applicant Second Request for Production of Documents to All Intervenor & Participating Local Govts Concerning Joint Intervenor Contentions.* Svc List Encl.Related Correspondence ML20206C5641988-11-0707 November 1988 Applicant Response to Town of Amesbury First Request for Production of Documents to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl. Related Correspondence ML20206C2611988-11-0404 November 1988 Responses of FEMA to Commonwealth of Ma Atty General First Request for Production of Documents to FEMA Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl.Related Correspondence ML20205R7461988-11-0404 November 1988 Errata to Applicant Response to Town of Amesbury First Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* W/Certificate of Svc. Related Correspondence ML20205R6901988-11-0404 November 1988 Errata to Applicant Response to Commonwealth of Ma Atty General First Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* W/ Certificate of Svc.Related Correspondence ML20205R5781988-11-0303 November 1988 Applicant Response to Commonwealth of Ma Atty General First Request for Production of Documents to Applicant Re Seabrook Plan for Commonwealth of Ma Communities.* W/Certificate of Svc.Related Correspondence ML20205R6541988-11-0202 November 1988 Town of Ambesbury Response to Applicant Second Request for Production of Documents to All Intervenors & Participating Local Govts Concerning Joint Intervenor Contentions.* W/ Related Info & Certificate of Svc.Related Correspondence ML20205R5621988-11-0101 November 1988 Applicant Response to Commonwealth of Ma (Mass Ag) Second Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* W/Certificate of Svc. Related Correspondence ML20205N3061988-10-31031 October 1988 New England Coalition on Nuclear Pollution Supplemental Answers to Applicant First Set of Interrogatories,Etc & Answers to Applicant Interrogatories & Request for Production Of....* W/Svc List.Related Correspondence ML20205N3351988-10-31031 October 1988 Town of West Newbury Supplemental Answers to Applicant First Set of Interrogatories & First Request for Production of Documents to All Parties & Participating Local Govts Re Contentions.* W/Certificate of Svc.Related Correspondence ML20205N3681988-10-27027 October 1988 Seacoast Anti-Pollution League Response to Applicant Interrogatories & Request for Production of Documents to All Intervenors & Participating Local Govts Concerning Joint Intervenor....* W/Svc List.Related Correspondence ML20205F9561988-10-26026 October 1988 Commonwealth of Ma Atty General Jm Shannon Answers & Responses to NRC Staff Second Set of Interrogatories & Second Request for Documents.* Notice of Depositions & Certificate of Svc Encl.Related Correspondence ML20205K2331988-10-26026 October 1988 NRC Staff Response to Town of Amesbury First Set of Interrogatories & Request for Production of Documents to NRC on Seabrook Plan for Commonwealth of Ma Communities.* W/ Certificate of Svc.Related Correspondence ML20205F8001988-10-25025 October 1988 Seacoast Anti-Pollution League Supplemental Answer to Applicant First Set of Interrogatories,Per Board Orders of 881018 & 19.* Supporting Documentation & Svc List Encl. Related Correspondence ML20205F7541988-10-25025 October 1988 Town of Amesbury First Suppl to NRC Staff First Set of Interrogatories & First Request for Production of Documents to Towns of Amesbury,Newbury,Salisbury,West Newbury & Merrimac & City of Newburyport.* Certificate of Svc Encl ML20205K4191988-10-25025 October 1988 Applicant Response to Commonwealth of Ma Atty General First Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20205F9931988-10-25025 October 1988 Response of Commonwealth of Ma Atty General to NRC Staff Third Set of Interrrogatories & Request for Production.* Certificate of Svc Encl ML20205G0351988-10-24024 October 1988 Applicant Response to Town of Amesbury First Set of Interrogatories...To Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Supporting Info & Certificate of Svc Encl.Related Correspondence ML20205E3571988-10-24024 October 1988 Commonwealth of Ma Atty General Supplemental Response to NRC Staff First Set of Interrogatories & First Request for Documents.* Certificate of Svc Encl.Related Correspondence ML20205D7771988-10-19019 October 1988 Commonwealth of Ma Atty General Second Request for Production of Documents to Applicant Re Seabrook Plan for Commonwealth of Ma Communities.* Related Correspondence ML20205D6951988-10-19019 October 1988 Commonwealth of Ma Atty General Second Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Related Correspondence ML20205D8101988-10-19019 October 1988 Commonwealth of Ma Atty General First Request for Production Documents to FEMA Re Seabrook Plan for Commonwealth of Ma Communities.* W/Notice of Deposition of R Donovan on 881109 & Certificate of Svc.Related Correspondence ML20205D7401988-10-14014 October 1988 Applicant Interrogatories & Request for Production of Documents to All Intervenors & Participating Local Govts Concerning Joint Intervenor Contentions 6 & 27-63.* W/Certificate of Svc.Related Correspondence ML20204F9541988-10-14014 October 1988 Applicant Second Request for Production of Documents to All Intervenors & Participating Local Govts Concerning Joint Intervenor Contentions.* Certificate of Svc Encl.Related Correspondence ML20155H4241988-10-11011 October 1988 Applicant Interrogatories & Request for Production of Documents to All Intervenors & Participating Local Govts Concerning Joint Intervenor Contentions 1-26.* Certificate of Svc Encl.Related Correspondence ML20155H3181988-10-0707 October 1988 Commonwealth of Ma Atty General Supplemental Responses to Applicant First Set of Interrogatories.* Certificate of Svc Encl.Related Correspondence ML20155H3111988-10-0707 October 1988 Commonwealth of Ma Atty General First Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Related Correspondence ML20155H0081988-10-0606 October 1988 Town of Amesbury Interrogatories & Request for Production of Documents to FEMA on Seabrook Plan for Commonwealth of Ma Communities (Spmc).* Certificate of Svc Encl.Related Correspondence ML20204G5731988-10-0606 October 1988 NRC Staff Third Set of Interrogatories & Request for Production of Documents to Towns of Amesbury,Newbury, Salisbury,West Newbury & Merrimac & City of Newburyport....* W/Certificate of Svc.Related Correspondence 1990-12-26
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
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00CKETED USNPC UNITED STATES OF.gElidTW A10I41 NUCLEAR REGULATORY COMMISSION -
, g. - ,: 9 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
Public Service Company of New )
Hampshire, et al. ) Docket Nos.
) 50-443, -444 (3eabrook Station, Units 1 and 2) )
)
NECNP FIRST SET OF INTERROGATORIES TO THE STATE OF NEW HAMPSHIRE ON NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN INSTRUCTIONS FOR USE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent cf the State of New Hampshire with personal knowledge of the f acts or information requested in each interrogatory.
The following definitions shall apply so these interrogatorica:
- 1. " Document" shall mean any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, 8310110175 831005
{DRADOCK 05000443 PDR
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l diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.
- 2. " Identify" with respect to any document shall mean t o state the following respecting the document: its t itle, its date, the author of the document, the person to whom the document was sent, a'.1 persons who r eceived or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.
- 3. " Identify" with respect to any action or conduct shall mean state the following regarding any such action or conduct:
the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or i
proposed effect of such action; any document recording or documenting such action.
- 4. " Describe" with respect to any action or matter shall mean state the following regarding such action or matter: the substance or nature or such action or matter; the persons participating in or having knowledge of such action or matter; the current and past business positions and addresses of such persons; the existence and location of any and all documents a relating to such action or matter.
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General Interrogatory
- 1. With respect to NECNP Contentions 1, 2, 3, 4, 5, 7, 9, 10, 12, and 13 on the New Hampshire RERP, please provide the following information:
- a. What is the State's position with respect to this contention? Describe in detail the reasons for your position.
Ifd the position of the Attorney General differs from that of the State Civil Defesne Agency or any other agency, please describe the dif ference and state the reasons for the dif ferent positions.
- b. Identify and provide access to all documents on which you rely during this proceeding to support your position on this contention. This includes all documents used in answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings,
- c. Identify all persons you may call as witnesses on these contentions during these proceedings, and describe any documents and the portions thereof that they may rely on for their testimony.
- d. Identify and provide access to all documents in your possession containing comments or questions on the adequacy or completeness of the New Hampshire RERP.
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i Contention NHRERP Emergency Response Procedures
- 2. Does the State of New Hampshire intend to submit its emergency response procedures to the Federal Emergency Management Agency (FEMA) for review?
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- a. If the answer to Question 2 is yes, what is the expected date of submission?
- b. If the answer to Question 2 is no, state the reasons why the procedures will not be submitted.
- 3. Identify by name and title all individuals who participated in the preparation of the New Hampshire Radiological Emergency Response Plan, and the specific contribution of each individual to the plan.
- 4. Have the Radiological Emergency Response Procedures for Seabrook been completed?
- a. If the answer is no, identify all areas in which the procedures are incomplete; state the reason for the incompletion and what remains to be done; and state the expected date of completion.
- 5. Identify and describe the criteria used in the preparation of the emergency response procedures.
- 6. Identify all those individuals by title who will have possession of the emergency response procedures during a radiological emergency at Seabrook.
- 7. For each section of the New Hampshire RERP, identify the procedures that are to be followe] to implement it.
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- 8. Describe the purpose of the New Hampshire emergency response procedures.
- 9. In your opinion, are the procedures necessary for the implementation of the New Hampshire RERP? State the basis for your opinion.
- 10. In your opinion, are the procedures necessary for a determination as to whether the New Hamshire RERP provides a reasonable assurance that adequate protective measures can and will be taken by the State of New Hampshire in a radiological emergency at Seabrook? State the basis for your opinion.
Contention NHRERP State and Local Coordination
- 11. Identify all aspects of the planned response to a radiological emergency at Seabrook for which the State expects to take primary responsibility.
- a. Identify all assessments, studies, and calculations of the resources and capability of the state government to carry out an emergency response in these areas,
- b. Identify all areas where the State expects supplementation of its resources by local governments, and the
- degree to which supplementation is needed.
- c. For those areas identified in response to Question 8.b, identify all assessments, studies, and calculations of the resources and capability of the local governments to supplement the State's emergency response.
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- 13. Identify all aspects of the planned response to a radiological emergency at Seabrook for which the State expects local governments to take primary responsibility,
- a. Identify all assessments, studies, and calculations of the resources and capability of the local governments to carry out an emergency response in these areas.
- b. Identify all areas where the State expects to supplement the emergency response effort by local governments, and the degree to which supplementation is needed.
- c. For those areas identified in response to Question 8.b, identify all assessments, studies, and calculations of the resources and capability of the State to supplement the emergency response effort by the local governments.
- 14. Identify a]1 local governments and their officials who were consulted in drafting the New Hampshire RERP, and describe the substance of the consultation.
- 15. Identify and provide access to any and all documents reflecting consultations between the New Hampshire state government and local governments regarding the preparation of the NHRERP.
- 16. Identify all sources of information that were used in
, assessing the capability of local governments to either supplement or take primary responsibility for the emergency response measures outlined in the NHRERP.
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Contention NHRERP Federal Assistance
- 17. Identify and describe all aspects in which the state of New Hampshire will depend on federal assistance to respond to a radiolgical emergency at Seabrook.
- 18. Identify and describe those aspects of the planned emergency response for which federal aid has been secured or committed and describe the specific Federal resource expected, including number of personnel and their training, types and amount of equipment.
- 19. For all federal resources identified and described in answer to Question 14, describe the location at which the resource will be needed and its expected time of arrival at the location.
- 20. Identify and provide access to all documents relating to existing or proposed arrangements for federal aid to the State of New Hampshire for the purpose of implementing the NHRERP.
Contention NHRERP Communication
- 21. Identify the means of communication that are relied on in the NH RERP.
- 22. For each means of communication relied on in the NHRERP, describe the following:
- a. If a telephone line, whether it is commercial or dedicated; and how many users are expected to rely on each channel;
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- b. If a radio, its power source, frequency, and range. For each radio, state whether the message relayed can be monitored by local governments or the general public.
- 23. For all means of communication that do not have an independent source of power such as a battery, identify the source of electricity, and provide access to all data on the reliability of that source.
- 24. Identify all factors known to af fect the reliability of the communication systems relied on in the NHREPP, such as adverse weather, interference and loss of offsite power.
- a. For each factor identified above, demonstrate how each has been considered in the development of a communication system for the NHRERP.
Contention NHRERP Relocation Centers
- 25. Identify and provide access to all documents in your possession regarding the consideration or choice of relocation centers contemplated by the NHRERP.
- 26. Identify and describe all criteria used by the State of New Hampshire in selecting relocation centers.
Cont ent ion NHRERP Notification
- 27. Identify and provide access to all documents in your possession relating to the Audible Alert System for the Seabrook EPZ, including drafts of the design of the Audible Alert System.
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- 28. Describe the manufacture and design of the sirens to be used; the location of sirens in the EPZ; and whether they are monodirectional or omnidirectional.
- 29. Are the sirens to be used in the Seabrook EPZ qualified to withstand 40 years of harsh weather conditions, including the corrosive effects of salt and high atmospheric moisture content? If so, provide the basis for your answer.
If not, please describe your program to inspect and maintain sirens in operating condition throughout the life of the Seabrook plant.
- 30. Identify the range of each siren in terms of decibel level as related to distance from the siren. If a siren cannot be heard equally well in all directions, describe the limitations or variations in the effectiveness of the sound.
- 31. Identify the meteorological conditions that impede the effectiveness of siren warnings. For each such condition, quantify the reduction in effectiveness of the sirens.
- 32. What is the power source for each siren in the EPZ?
- 33. Upon what alternative means of alerting the public does the State rely in the event that power is not available to run the sirens?
- 34. Does the State rely on alerting by vehicles with public address systems if primary notification is inoperable?
If so,
- a. How is it carried out?
- b. What resources are necessary to carry it out?
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- c. What is the capability of the State to carry it out?
- d. What routes will be taken to alert the public, and how will it be assured that the alerting vehicles can pass through traffic?
- e. How long does it take to notify the population of the EpZ by this form of alerting?
- 35. Who is responsible for activating the sirens in a radiological emergency?
- 36. How has the ef fectivness of the N!!RERP's proposed notification system been evaluated? Please identify and provide access to all assessments, studies, and calculations supporting your evaluation (s).
- 37. Are the sirens used for an alert of a radiological emergency also to be used for other purposes? If so, is the type of sound generated recognizably dif ferent for each purpose for which the sirens are activated? Describe the difference.
- 38. What provision has the State made for notification of the population on the beaches, in campgrounds, public parks, hospitals, schools, and factories?
- 39. What is the message intended to be conveyed by a siren alert?
- 40. Please describe in detail the measures that will be taken by the State to assure that the public, including transients, will understand the meaning of the sirens and what they should do when they hear them.
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- 41. Please identify and describe in detail the type and manufacture of tone alert radios that are to be used for initial alerting of a radiological emergency at Seabrook.
- 42. From what location will the alert be broadcast?
- 43. What is the power source of the tone alert radios?
During a power failJre, what backup notification system is provided?
- 44. Identify the segments of the EPZ population that are expected to rely for primary notification on tone alert radios.
- 45. How many tone alert radios will be needed in the EPZ?
- 46. What agency is responsible for distribution of the tone alert radios?
- 47. How is the need for tone alert radios assessed? How will it be assessed on a continuing basis?
- 48. What percentage of the EPZ population are expected to receive emergency instructions via radio and television? How was this assessment arrived at?
- 49. How does the plan provide for instruction of non-English-speaking people in the EPZ via radio and television?
- 50. In the event of a loss of power to radio and television, by what alternative means does the State intend to instruct the public in responding to a radiological emergency?
- 51. How will people without access to radio or television, i.e. people who have none in their homes or offices; people on 2
i the beaches or campgrounds; people walking without. rapid access to a car; people in buses; or others, receive instruction as to the protective actions they should take during a radiological emergency?
Contention NHRERP Sheltering
- 52. If sheltering is chosen as the appropriate protective action in a radiological emergency, how many people must be sheltered in the EPZ under peak summer population conditions?
- 53. How was the figure give in answer to Question 47 arrived at?
< 54. Has the State classified shelters according to their construction type? If so, please describe the classification scheme, and the numbers, locations and capacities of buildings that meet each classification.
- 55. Has the State classified shelters according to their capacity to shield from radiation? If so, please describe the classification scheme, and the numbers, locations, and d
capacities of the buildings that meet each classification.
- 56. Does the State have minimum criteria for the acceptability of shelters for use in a radiological emergency?
If so, please describe them.
- 57. Does the State intend to designate specific buildings a
as shelters to be used in a radiological emergency? If so, identify those buildings, their capacities, and their locations, and describe your reasons for designating those buildings as shelters.
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- 58. If your answer to Question 57 was yes, describe how the public will be notified t hat these shelters should be used in a radiological emergency.
- 59. Describe or map the location of shelters in relation to the spatial distribution of the population in winter and summer.
- 60. Identify and provide access to all documents in your possession relating to the State's assessment of the adequacy of sheltering as a protective measure in the event of a radiological emergency in the Seabrook EPZ.
Contention NHRERP Radiological Monitoring
- 61. The NHRERP states that the state does no? luve the capacity to monitor the location or movement of a radioactive plume from Seabrook. Under those circumstances, by what criteria will decisions be made regarding where to send the three radiological monitoring teams described in the NHRERP in a radiological emergency?
- 62. By what criteria will decisions be made regarding at what stage of an emergency to send radiological monitoring teams into the field?
- 63. Describe and estimate the time required to carry out each of the steps by which radiological emergency personnel will be contacted and deployed following a decision to use them.
- 64. For each type of information to be gathered or test to i be performed by the radiological monitoring teams, estimate the amount of time that will pass between the moment that radiological monitoring personnel are notified and the results
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of their monitoring tests are communicated to decisionmaking authorities. What is the basis for your estimate (s)?
- 65. Describe in detail the criteria by which monitoring results will be interpreted and used to make decisions regarding appropriate energency responses. Identify and provide access to any and all documents relating to these criteria.
Contention NHRERP Medical Services
- 66. What is the maximum projected need for medical services to contaminated or injured ano evotaminated individuals in the Seabrook EPZ in the event of a radiological emergency? Describe the criteria by which this calculation was made.
- 67. Identify the facilities available for care and decontamination of individuals in a radiological emergency.
- a. What is the location of each facility?
- b. What is the capacity of each facility, including egaipment, personnel, and number of patients that can be handled, to treat injured individuals?
- c. What is the capacity of each f acilit y, including equipment, personnel, and number of patients that can be handled, to treat contaminated individuals?
- d. What is the capacity of each facility, including equipment, personnel, and number of patients that can be handled, to treat individuals who are both injured and contaminated?
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- 68. Do your answers to Questions 59(a) through (d) describe f acility capacity in addition to the demands on the i facility posed by normal use? If not, state by percentage the extent to which each facility is occupied or used on an average day in summer and winter, and describe how existing use of the facilities would be affected by an influx of contaminated injured individuals from the Seabrook EPZ.
- 69. How many ambulances will be available during an emergency to transport injured and contaminated individuals?
7 0., Describe the means by which ambulance drivers will be able to communicate with care facilities in order to determine where to transport their passengers.
- 71. Identify and provide access to all documents in your possessionrelating to the State's assessment of the adequacy of medical services during a radiological emergency at Seabrook.
Respectfully submitted,
,/)
Diane Curriin I
l William S. Jor n III HARMON & WEISS 1725 I Street, U.W.
Suite 506 Washington, D.C. 20006 October 5, 1983 (202) 833-9070
,0 CERTIFICATE OF SERVICE D ETEE I certify that on October 5, 1983 copies of NECNP FIRST SET OF A ENCY ON NEW INTERROGATORIES HAMPSHIRE TO THE RADIOLOGICAL FEDERALRESPONSE EMERGENCY EMERGENCY MANAG33E!"fiPgFIkh51 PLAN, Nb SET OF INTERROGATORIES TO APPLICANTS ON NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN, NECNP OBJECTION TO I RQPREEcBOARD CONDUCT, RESPONSE TO APPLICANTS' POSITION AS TO SCHEDUL 4Gy@ghE PLLANNING ISSUES, AND REQUEST FOR HEARING ONSCHEDULE LICEN5IIId, AND $dRGE NECNP FIRST SET OF INTERROGATORIES TO THE STATE OF NEW HAMPSHIRE ON NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN were served on the following by first-class mail, or as otherwise indicated below:
- Helen Hoyt, Esq., Chairperson Rep. Roberta C. Pevear Atomic Saftey and Licensing Board Drinkwater Road Panel Hampton Falls, NH 03844 U.S. Nuclear Regulatory Commission Washington, DC 20555
- Dr. Emmeth A. Luebke Phillip Ahrens, Esq.
Administrative Judge Assistant Attorney General Atomic Saftey and Licensing Board State House, Station #6 U.S. Nuclear Regulatory Commission Augusta, ME 04333 Washington, DC 20555
- Dr. Jerry Harbour Robert A. Backus, Esq.
Administrative Judge 111 Lowell Street Atomic Saftey and Licensing Board Manchester, NH 03105 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Board ** Thomas G. Dignan, Esq.
Panel R. K. Gad, III, Esq.
U.S. Nuclear Regulatory Commission Ropes and Gray Washington, DC 20555 225 Franklin Street Boston, MA 02110 Atomic Safety and Licensing Appeal Dr. Mauray Tye, President Board Panel Sun Valley Asociation U.S. Nuclear Regulatory Commission 209 Summer Street Washington, DC 20555 Haverhill, MA 01830 Docketing and Service *Roy P. Lessy, Jr. Esq.
U.S. Nuclear Regulatory Commission Robert G. Perlis, Esq.
Washington, DC 20555 William F. Patterson Office of the Executive Legal Director Town Manager's Office U.S. Nuclear Regulatory Town Hall - Friend St. Co mmission Amesbury, MA 01913 Washington, DC 20555 Mr. Angie Machiros Anne Verge, Chair Chairman Board of Selectman Board of Selectmen Town Hall Town of Newbury South Hampton, NH 03842
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l Jo Ann Shotwell, Esq. George Dana Bisbee, Esq.
Assistant Attorney General Edward L. Cross, Jr., Esq.
Department of the Attorney Asst. Atty. Generals General State House Annex 1 Ashburton Place, 19th Floor Concord, NH 03301 Boston, MA 02108 John B. Tanzer Letty Hett, Selectman Town of Hampton Town of Brentwood 5 Morningside Drive RFD Dalton Road Hampton, NH 03842 Brentwood, NH 03833 Edward F. Meany Sandra Gavutis Town of Rye Town of Kensington 155 Washington Road RFD 1 Rye, NH 03870 East Kensington, NH 03827
- David R. Lewis, Esq. Diana P. Sidebotham Atomic Safety and Licensing Board R.F.D.2 U.S. Nuclear Regulatory Commission Putney, VT 05346 Washington, DC 20555 Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager Newburyport, MA 01950 10 Front Street Exeter, NH. 03833 .
Alfred V. Sargent, Chairman Brian P. Cassidy, Esq.
Board of Selectmen FEMA Region I Town of Salisbury, MA. 01950 J.W. McCormack Post Office and Courthouse Boston, MA. 02109 Diana P. Randall 70 Collins Street Seabrook, NH. 03874 Senator Gordon J. Humphrey Senator Gordon J. Humphrey U.S. Senate 1 Pillsbury Street Washington, D.C. 20510 Concord, NH 03301 (Attn: Tom Burack) (Attn: Herb Boynton)
Selectmen of Northampton Town of Northampton New Hampshire 03862 Diane Curran Hand Delivered
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