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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
[Table view] |
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d GELATED CORRESPONDEpegg FILED: April 17, 198G UNITED STATES OF AMERICA NUCLEAR REGUL A TORY COMMISSION 00CKETEP~
tIDmc BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter' of:
T PUBLIC SERVICE COMPANY OF Docket Nos. lU;-443 tS OL NEW HAMPSHIRE, et al 50-444*OL (Seabrook Station, Units 1 and 2 SEACO AST ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE STA TE OF NEW HAMPSHIRE ON EMERGENCY PLANNING FOR THE -
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STATE OF NE.V HAMSPHIRE INSTRUCTIONS FOR USE The Seacoast Anti-Pollution League hereby requests that the State of New Hampshire, pursuant to 10 C.F.R. 92.740(b) and 62.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce and permit inspection and copying of the original or best copy of all documents identified in their response to interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents herein identified, the State file supplemental responses and produce additional documents as required by 10 C.F.R.12.740(e).
Where identification of a document is requested, briefly describe the document (e.g.) book, letter, memorandum, report) and state the following information as applicable for the particular document; name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person (s) having possession of the document.
The term " document [s]" as used herein 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-corporation or intra-office communications, notebooks, diaries, sketches, diagrams, maps, 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.
8604240159 860417 PDR ADOCK 05000443 0 PDR Sd3
- 1. In the opinion of the State of New Hampshire, does the New Hampshire Radiological Emergency Response Plan adequately provide for continuous 24-hour radiological monitoring of the plume exposure pathway EPZ for a protracted period? Please state in detail the factual bases upon which the response rests, including answers, supported by appropriate documentation for the following:
a) How many monitoring staff people are available?
b) What are their ages and states of physical health?
c) What educational qualifications do they have for this task?
d) What additional training have they had? ,
e) What specific methods will they employ?
f) What specific survey instruments will they use?
g) What are the specific detection capabilities of each of the survey instruments to be employed?
h) What assurances are there that each staff person is committed to fulfill his/her functions?
i) What contingency plans have been made to get radiological monitors to their sampling locations if they cannot make their way to designated sampling locations because of impairment of their progress into the EPZ due to an outgoing flow of evacuating vehicles?
j) For how many days (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day) does the State anticipede that monitoring can be carried on on a continuous basis?
k) How long does the State estimate it will take to deploy the radiological monitoring teams to the first monitoring location following a decision that monitoring is necessary?
- 1) How long does the State estimate it will take to get the first samples to Concord for laboratory analysis?
m) What specific provisions have been made for aerial monitoring of the plume?
n) How many State employees have been trained to do aerial monitoring? Please detail the nature of that training.
. 2. In the opinion of the State of New Hampshire, does the N.H.RERP adequately provide means for the radiological decontamination of emergency personnel, wounch, supplies and equipment? Please state in detail the factual bases upon which the response rests, including detailed citations to supporting documents and/or informational sources relied upon for the response and also including answers to the following:
a) Where are emergency personnel to be decontaminated?
b) How will emergency personnel be segregated from others at the decontantination locations to avoid the spread of contaminants?
c) How many showers or other washing facililties are available at the decontamination locations for emergency personnel?
d) Who will monitor the emergency personnel to be certain they have been completely decontaminated?
e) What are the qualifications and training of those individuals who are to assess the adequacy of the decontamination of emergency personnel?
f) How is the contaminated waste water, resulting from the decontamination of emergency personnel, to be isolated?
g) What medical personnel will provide treatment for any wounds incurred by q emergency personnel and at what medical facilities will this treatment take place?
h) What decorporation agents will be employed if emergency personnel suffer excessive internal contamination?
i) Have decorporation agents been stockpiled by the State of New Hampshire? Will they be?
j) What supplites and equipment does the State of New Hampshire anticipate might become contaminated?
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k) What are the plans for decontamination of these supplies and equipment should that prove necessary?
- 1) How will any effluents resulting from decontamination of supplies and equipment be isolated?
- 3. In the opinion of the State of New Hampshire, does the N.H.RERP adequately provide means for the radiological decontamination of evacuees and their vehicles and belongings? Please state with particularity the detailed bases upon which the answer to the above rests, including citations to supporting documents and/or sources of information relied upon in the answer. Please also include answers to the following:
a) How many showers are available in each of the decontamination facilities and how long does the State assume it will take to decontaminate each individual on the average? ,
b) Who will be available to instruct individuals as to the method of thorough washing j and scrubbing needed to effect an adequate external decontamination?
c) How will contaminated individuals be segregated from the non-contaminated at reception centers in order to avoid the spread of contaminants?
d) Who will monitor the individuals concluding their showering to be certain that all surface contamination has been removed?
e) What are the qualifications and training of those " individuals who are to do the monitoring described in part d?
f) How is the contaminated waste water resulting from the decontamination of evacuees to be isolated?
g) Who is to assess whether or not an evacuee is internally contaminated and to refer to appropriate medical facilities those who are so contaminated?
h) What personnel are to monitor the vehicles of evacuees for possible contamination?
i) What vehicle washing facilities are available at the reception centers for vehicle decontamination and how many vehelles can be handled per unit of time?
j) What personnel will monitor the vehicles following the washing process to assure that no contamination remains?
k) How will effluents from vehicle washing activities be isolated?
- 1) Where will contaminated belongings be isolated until they can be disposed of?
- 4. In the opinion of the State of New Hampshire do adequate means and provisions for the disposal of wastes that would result from an adequate radiological emergency response to an accident on the more serious end of the spectrum of potential accidents, which would include decontamination of people and vehicles, exist? Please detail the factual basis upon which the State's response is founded and provide documented answers to the following:
a) What is the name of the " local brokerage" noted at page 2.7-10 of the State plan which is to dispose of waste materials?
t5 Where is the above-mentioned " local brokerage" located?
c) How much waste is this brokerage prepared to accept? Please provide this answer in terms of both volume and curie content.
d) What is the licensed status of this brokerage?
e) When was it first licensed?
f) Has the license ever been suspended for any reason?
g) What contractual arrangement does the State of New llampshire have with this brokerage to ensure its acceptance of the wastes?
h) How are the wastes to be transported to the brokerage?
i) What entity will have responsibility for the transport of the wastes?
j) What contracts or agreements support the expectation that this transport of wastes will be effected and that the applicable Federal, state and local regulations affecting such transport will be complied with?
- 5. In the opinion of the State of New Hampshire, is there adequate manpower for a 24-hour per day emergency response for a protracted period, including 24-hour per day
manning of communications links? Please cite the bases supporting the State's response and provide answers, supported by the appropriate documentation, for the following:
a) How many State Civil Defense employees are there in total?
b) Provide a description of how these employees are to be deployed during a general emergency at Seabrook Station (i.e. how many will remain at the State EOC, how many will be dispatched to the EOF /IFO, how many will be sent into the EPZ, etc.)
c) What is the total number of Division of Public Health Services employees?
d) Provide a description of how these DPHS employees are to be deployed during a general emergency at Seabrook Station (i.e. how many will be stationed at the State EOC, how many will be analyzing field samples in the laboratory, how many will report to reception centers to do monitoring of evacuees, etc.)
e) How many employees are there in the Department of Resources and Economic Development (DRED)?
f) Please state with particularity the location to which these DRED employees will be dispatched, including the number to each location, in the event of a general emergency at Seabrook Station.
g) How mary State Police officers are there in Troop A?
h) Specifically, . ow does the State plan to assist the municipalities in which emergency responsc is impaired due to lack of manpower? What State personnel will be drawn upon to assist municipalitie lacking personnel? Please answer in terms of numbers and the agencies from which the State personnel will be drawn.
- 6. In the opialon of the State of New Hampo.. ire, are there adequate provisions for the sheltering of various segments of the populace in the plume exposure pathway EPZ?
Please state with particularity the facts forming the bases of the State's opinion and provide answers, supported by appropriate documentation, for the following:
l a) Where does the State anticipate that beach populations will be able to take shelter in a radiological emergency if closing the beaches and/or evacuation cannot be implemented quickly enough to effect dose reductions for the i
populations?
i b) Does the State plan to construct shelters at the beaches?
c) If the answer to part b. above is in the affirmative, at what specific locations does the State anticipate that such shelters would be constructed? Please provide any designs that may exist for beach shelters.
d) Are maps of shelter areas being developed by the State as NUREG-0654 II,J.10.a.
requires? l e) Are expected levels of protection to be afforded in residential and other units (schools, nursing homes, etc.) for direct and inhalation exposure being evaluated
, as required by NUREG-0654 II. J.10.m.?
f) If the answer to part e. above is in the affirmative, what entity or entities are performing the evaluations?
g) What are the qualifications of the entity or entitles, named in response to part f, to perform shelter evaluations?
- 7. Is it the opinion of the State of New Hampshire that the N.H. State and local plans make adequate provisions for prompt communications among principal response organizations to emergency personnel? Please relate in detail the factual bases for the State's position and provide answers, supported by appropriate documentation, for 1
the following:
a) How many phone lines are there serving each of the 17 New Hampshire local EOC's?
- 8. In the opinion of the State of New Hampshire, do the N.H. State and local radiological emergenef response plans reasonably assure that those persons whose mobility is impaired due to institutional or other confinement will be adequately protected in the event of a radiol 3gical emergency? Please state with particularity the bases
for the State's response and include answers to the following questions with appropriate supporting documentation:
a) How many "Special Emergency Help" surveys sent out to residents of the EPZ under cover letter of March 20, 1986 by Richard H. Strome, Director, N.H. CDA, were returned?
b) What percentage of the surveys sent out were returned?
c) Judging from the results of the survey, how many people does the State anticipate will need special transportation assistance?
d) What vehicles does the State assume will be available to transport those whose 4
mobility is impaired who are not in institutions?
e) Does the State assume that the ambulance services for which letters of agreement are included in Volume 5 in the State plan will be able to provide assistance to the individuals described in part d. above?
f) If the answer to part e. is in the affirmative, how many people does the State
.l i estimate will be provided transportation by these ambulance survices, and upon what basis is this assumption founded?
i
- 9. In the opinion of the State of New Hampshire, has sufficient funding been made j available to the State for an effective emergency planning process and accompanying l
development of emergency planning documents? Please state in detail the factual basis for this response, supported by appropriate documentation, including answers to the following:
a) Has the State ever been denied, for any reason (s), funds that it has requested for emergency planning purposes?
b) If the answer to part a. is in the affirmative, please detail in full the circumstances of the denial, including the scope of the request, the grounds for the denial and 1
l who authorized the denial.
4 4
. % __-. _ _ _ , , - . , , - _ . , , . . - _ . - - - _____--r__-._.__,__,-_..--_,--,_---__.-______.,
c) How much money has the State of New Hampshire spent on the emergency planning process for Seabrook Station?
l d) How much money did the State of New Hampshire spend over the course of 1985?
e) How much money has the State of New Hampshire spent to date this year?
f) Describe in detail the procedure by which funding requests are made and authorized.
f g) What consultants and/or consulting firms are or have been hired by the State for work related to the development of emergency plans and procedures for Seabrook Station? (Please indicate which are still involved in the planning ,
process.)
h) Were the hirings referred to in part g. the result of competitive bidding processes?
j Respectfully submitted,
>i SEACOAST ANTI-POLLUTION LEAGUE j By Its Attorney
$/E Robert A. Backus BACKUS, MEYER & SOLOMON i P. O. Box 516-
'i Manchester, NH 03105 (603)668-7272 April 17,1986 I hereby certify that copies of the foregoing have been sent to all persons on the attached service list.
{
d/P Robert A."Backus i .
1 '
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s_.- t_, ~ , . , _ _ _ . _ _ . _ . . . . . , _ . . _ _ _ __
CERTIFICATE OF SERVICE AND SERVICE LIST Joseph Flynn Helen Hoyt. Chm. Thomas Dignan, Esq.
Fed. Emerg. Mgmt. Agcy. Admn. Judge Ropes & Gray Region I Atomic Safety & Lic Brd, 225 Franklin St.
J.W. McCormack POCH USNRC Boston, MA 02110 Boston, MA 02109 Washington, DC 20555 Office of Selectmen Dr. Jerry Harbour Docketing & Serv. Sec.
Town of Hampton Falls Admin. Judge Office of the Secretary Hampton Falls, NH 03844 Atomic Safety & Lic Brd. USNRC USNRC Washington, DC 20555 Washington, DC 20555 Shenvin E. Turk, Esq. Jane Doughty Dr. Emmeth A. Luebke Office of Exec. Legl. Dr. Admin Judge SAPL USNRC Atomic Safety & Lic. Brd. 5 Market Street Uahsington, DC 20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 '
Phillip Ahrens, Esq. Paul McEachern, Esq. George Dana Bisbee, Esq.
Asst. Atty. General Matthew Bruck, Esq. Attorney General's OFF.
State House, Sta. 76 25 Maplewood Ave. State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsnuuth, NH 03801 Carul Sneider, Esq. , Asst. AG Diane Curran, Esq. William S. Iord One Ashburton Place, Harmon, Weiss Board of Selectrmn 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.
Boston, MA 02108 Washington, DC 20009 Anusbury, MA 01913 Richard A. Hanpe, Esq. Maynard Young, Chaimnn Sandra Gauvutis New Hampshire Civil Defense Board of Selectnen Town of Kingston Agency 10 Central Road Box 1154 Hanpe & McNicholas Rye, NH 03870 East Kensington, NH 03827 35 Pleasant St.
Concord, NH 03301 Edward 'Ihorms Mr. Robert Harrison FBIA Pres, & Chief Exec. Officer 442 J.W. McCorTmck (POGI) PSCO Boston, MA 02109 P.O. Box 330 Manchester, NH 03105 Poberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, NH 03844 April 17, 10 C,6 The above have been sent first-class, postage prepaid a copy of the enclosed.
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,& Y A obert A. Backus