ML20151P129
| ML20151P129 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/15/1988 |
| From: | Flynn H Federal Emergency Management Agency |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20151P103 | List: |
| References | |
| OL, NUDOCS 8804260092 | |
| Download: ML20151P129 (8) | |
Text
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L UNITED STATES OF AMERICA OfflCE 07 SEC5ETAK' NUCLEAR REGULATORY COMMISSION 00CKElWGl.SEkV E y
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i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
+
h JUDGE IVAN W. SMITH, CHAIRMAN JUDGE JERRY HARBOUR JUDGE GUSTAVE A. LINENBEFCER, JR.
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In the Matter of
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Public Service Co. of New Hampshire,
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Docket No. 50-443-OL et al.
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50-444-OL
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Offsite Emergency (Seabrook Station,-Units 1 & 2)
)
Planning Issues
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)
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f RESPONSE OF THE FEDZRAL EMERGENCY MANAGEMENT AGDICY TO APPLICANTS' REQUESTS FCk PRODUCTION OF DOCUMDITS t
Applicants' Request No., 1:
All documents created since July, 1983 relating to any contact between E. A. Thomas and any official, employee, or representative of The Commonwealth l
of Massachusetts on any matter relating to nuclear power, emergency planning, I
and/or Seabrook Station.
FEMA's Response to Applicants' Request No. 1:
i l
FEMA objects to Applicants' Request for Documents No. 1, to the extent 1
I that it covers matters not eme wpassed in Requests 2 and 3, as unduly
}
burdensome and beyond the proper scope of discovery in that it is not l
reasonably calculated to lead to the discovery of admissable evidence.
4 8804260092 000415 PDR ADOCK 0500 3
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a Applicants' Request No. 2:
All documents relating to any contact between any official, employee, or representative of FEMA (including E. A. Thomas) and any official, employee, or representative of The Commonwealth of Massachusetts regarding the substance of FEMA's or E. A. Thomas's testimony in the above-captioned proceeding.
FEMA's Response to Applicants' Request No. 2:
A search of FEMA's records was conducted at the request of and under the direction of H. Joseph Flynn, FEMA counsel, and no documents responding to y
a Request No. 2 were discovered.
Personal records of FEMA employees not under FEMA's control, not used in the conduct of FEMA's regular activities, and maintained separate from FEMA's official records were not included in the
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f
- search, 7
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Applicants' Pequest No. 2:
I All documents created since July,1985, regarding any contact between any f
FEMA official, employee, or representative (including E. A. Thomas) and any
(
official, employee, or representative of Tha Conmonwealth of Massachusetts l
regarding the views of Regional Assistance Committee members on the issue in the above-captioned matter of shelter for the summer beach population.
FEMA's Response to Applicants' Request No. 2:
l A search of FEMA's records was conducted at the request of and under the f
l i
1 direction of H. Joseph Flynn, FEMA counsel, and no documents responding to 1
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l FEMA'S RESPONSE TO APPLICANTS' REQUEST FOR PRODUCTION, Page 2.
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Request No. 3 were discc/ered. Personal records of FEMA employees not under FEMA's control, not used in the conduct of FEMA's regular activities, and i
maintained separate from FEMA's official records were not included in the i
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search.
I 4
i Respectfully submitted, l
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p u t-li-MOSEPl LYNN Assistant General Counsel Federal Emergency Management Agency 500 C Street, S.W.
1 Washington, D.C. 20472 I
(202) 646-4102 FEMA'S RESFONSE TO APPLICNTIS' REQUEST FOR PRODUCTION, Page 3.
y, 00CKETED April 15,198SSNNC
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3
'88 APR 20 _ P 6 '.43 UNITED STATES OF AMERICA q
NUCLEAR PIGULATORY COMMISSION OFTICEOi5ECEIAM 00CKEl g Q E8VICf-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD JUDGE IVAN W. SMITH, CHAIRMAN
!f JUDGE JERRY HARBOUR JUDGE GUSTAVE A. LINENBERGER, JR.
g k
)
In the Matter of
)
E
)
Ii Public Service Co. of New Hampshire,
)
Docket No. 50-443-OL d
et al.
)
50-444-OL V
)
Offsite Emergency 3
(Seabrook Station, Units 1 & 2)
)
Planning Issues g
)
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1 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Responses of the Federal
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Emergency Management Agency to requests for production of documents from the Applicants and the Intervenors have been served on the following by depositing f
them with the U.S. Postal Service on this 15th day of April, 1988.
Except as g
noted in the Responses, the documents referred to in the Responses have been E
served on only those parties who participated in the depositions of FEMA I
witnesses between bbrch 23 and April 5,1988.
E I
Ivan W. Smith Esq., Chairman g
Atomic Safety and Licensing Board lF Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, Maryland 20814 Dr. Jerry Harbour Administrative Judge Atomic Safety and Licensing Board Nuclear Regulatory Commission Bethesda, Maryland 20555 NI Gustave A. Linenberger, Jr.
Administrative Judge h
Atomic Safety and Licensing Board R
U Nuclear Regulatory Connission Bethesda, Maryland 20555 h
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Beverly Hollingworth 209 Winnacunnet Road Hampton, NH 03842 Sandra'Gavutis, Chairman Board of Selectmen RFD 1 Box 1154 Route 107 Kensington, NH 03827 j
I Carol S. Snieder g
Assistant Attorney General j
Office of'the Attorney General l
One Ashburton Place, 19th Floor
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Boston, MA 02108 Stephen E. Merrill Attorney General George Dana Bisbee Office of the Attorney General 25 Capitol Street Concord NH 03301-6397 Richard A. Hampe, Esq.
New Hampshire Civil Defense Agency' 35 Pleasant Street Concord, NH 03301 Calvin A. Canney, City Manager City Hall 126 Daniel Street Portsmouth, NH 03801 Roberta C. Pevear g
e State Representative Town of Hampton Falls Drinkwater Road Hampton Falls, NH 03844 Robert A. Backus, Esq.
Backus, Meyer & Solomon 116 Lowell Street Manchester, NH 03106 Paul McEachern, Esq.
Mathew T. Brock, Esq.
Shaines & McEachern i
Post Office Box 360 Fortsmouth, NH 03801
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Edward A. Thomas e
Federal. Emergency Management Agency 442 J.W. McCormack (POCH)
Boston, MA 02109 i
Jane Doughty h.
Seacoast Anti-Pollution League
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5 Market Street J
Portsmouth, NH 03801 g
I Atomic Safety and Licensing Appeal
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Panel U.S. Nuclear Regulatory l
Commission Washington, D.C. 20555 r
1 Allen Lampert i
Civil Defense Director Town of Brentwood 20 Franklin Street Exeter, NH 03833 t
Angie Machiros, Chairman Board of Selectmen 25 High Road Newbury, MA 01950 Jerard A. Croteau, Constable 82 Beach Road P.O. Box 5501 Salisbury, MA 01950 Diane Curran, Esq.
Harmon & Weiss I
2001 S Street, N.W.
Suite 430 Washington, D.C. 20009 Philip Ahrens, Esq.
Assistant Attorney General Office of the Attorney General State House Station, #6 Augusta, ME 04333 Thomas G. Dignan, Jr., Esq.
Ropes & Gray 225 Franklin Street Boston, MA 02110 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 t
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Docket and Service Sectica Office of the Secretary _
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 J.P. Nadeau, Esq.
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Selectmen's Representative Board of Selectmen
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10 Central Road R
Rye, NH03870 r,
Michael Santosuosso, Chairman f
Board of Selectmen 9
South Fimpton, NH 01913 k
Mr. Robert Carrigg, Chairman
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Board of Selectmen Town Office Atlantic Avenue k
North Hampton, NH 03862 William Armstrong Civil Defense Director
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Town of Exeter 10 Front Streat Exeter, NH 03833 4
a Peter J. Matthews, Mayor City Hall Newburyport, MA 01930 William S. Lord i*
Board of Selectmen h
Town Hall - Friend Street l
Amesbury, MA 01913 6
I Mrs. Anne E. Goodmar, Chairman E
f Board of Selectmen 13-15 Newmarket Road g
Durham, NH 03824 I
i Gary W. Holmes, Esq.
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Holmes & Ellis l
47 Winnacunnet Road l
Hampton, NH 03842 l
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Sherwin E. Turk, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814 Oreste Russ Pirfo, Esq.
Office of the Executive Legal Director j
U.S. Nuclear Regulatory Commission g
Washington, DC 20555 k
Senator Jordon J. Humphrey U.S. Senate Washington, D.C. 2C510 (Attn: Herb Boynton) f Senator Gordon J. Humphrey 1 Pillsbury Street l
Concord, NH 03301 (Attn: Herb Boynton)
Thomas F. Powers, III Town Manager Town of Exeter 10 Front Street Exeter, NF, 03833 Brentwood Board of Selectmen i
RFD Dalton Road Brentwood, NH 03833 Dated: April 15, 1988 d.41 \\
j w H. 40SEPH FLnJN Assistant,d'eneral Counsel f
Federal Emergency Management Agency l
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