ML20083A594

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Advises of Results of Settlement Discussions W/Fema on Motion to Compel Answers to Certain Interrogatories Re Emergency Planning for State of Nh.Atty General Bellotti Will Not Press 831116 Motion to Compel
ML20083A594
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 12/13/1983
From: Shotwell J
MASSACHUSETTS, COMMONWEALTH OF
To: Harbour J, Hoyt H, Luebke E
Atomic Safety and Licensing Board Panel
References
ALAB-739, NUDOCS 8312200336
Download: ML20083A594 (2)


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dSi THE COMMONWEALTH OF M ASSACHUSETTS h h DEPARTMENT OF THE ATTORNEY GENERAL

=. JOHN W. Mc CORMACK BTATE OFFICE Bull. DING i' ,

ONE ASHBURTON PLACE. 90570N 02105

'83 December 13, 1983

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a .. tto m OEC 16 00Cgf7Onn NO 0F 72 l4 Helen F. Hoyt, Esquire, Chairperson Dr. Emmeth Luebke Dr. Jerry Harbour Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555

. Re: Seabrook Operating License Proceeding, Docket Nos. 50-443 and 50-444

Dear Members of the Board:

I write to advise you as to the results of settlement discussions between FEMA and this Department relative to the motion to compel answers to certain interrogatories which we directed to_ FEMA relative to emergency planning for the State of New Hampshire. As' a result of my discussions with Brian Cassidy, FEMA counsel, Attorney General Bellotti is withdrawing his motion to compel with respect to Interrogatory 8; FEMA has

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agreed to supply the additional response for which we moved with respect to Interrogatory 4; FEMA has agreed to supplement its answer to Interrogatory 9 to address emergency initiating conditions,Jrather than emergency classifications; FEMA has

. agreed to supply answers to Interrogatories 17 and 18, in light of our definition of the phrase " adverse health effects" as used in those questions to include radiation sickness, early f atality, latent f atality, and genetic and developmental defects, and to exclude sunburn; and FEMA has agreed to review Interrogatories 19 and 20 again and'to consider providing responses to those questions voluntarily.at-the time it supplements the.other interrogatory answers.

Attorney General Bellotti further agreed to redraft his i Interrogatory 5 and has done so as follows:

l In the opinion of FEMA, what is the number of persons for which the State of New Hampshire must assure medical services pursuant to 10 C.F.R. 5 50. 4 7 (b) (12) ?

State the bases for your answer in detail, describing the types of injuries and sources or levels of contamination for which your estimate accounts.

Identify and produce all documents upon which you rely for any portion of your answer.

8312200336 831213 PDR ADOCK 05000443 9563

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FEMA has agreed to consider responding voluntarily to Interrogatory 5 as redrafted. It has further agreed to reconsider its objection to Interrogatory 6, a follow-up to Interrogatory 5, in light of this redrafting.

In light of these agr'eements, Attorney General Bellotti does not at this time press his motion to compel. filed on Novemb er 16, 1983. The Attorney General does, however, reserve his right to renew that motion in the event that full -

and ccmplete answers are not supplied on or before December 31, 1983, to those interrogatories as to which FEMA has agreed to supplSment its answers or to take a second look.

Very truly yours, J' n Shotwel A istant Attorney General Environmental Protection Division One Ashburton Place Boston, Massachusetts 02108 (617) 727-2265 JAS/EF cc: Service List H

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