ML20154E612
| ML20154E612 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/13/1988 |
| From: | Jonas S MASSACHUSETTS, COMMONWEALTH OF |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| CON-#388-7076 OL-1, NUDOCS 8809190074 | |
| Download: ML20154E612 (7) | |
Text
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eELATED CORRE5f'OfjD.6 UM gg gy 15 N154 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD OFFt n,h 00Ct'!.g'g Before Administrative Judges:
Sheldon J. Wolfe, Chairman Emmeth A.
Luebke Dr. Jerry Harbour
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket No.(s)
)
50-443/444-OL-1 (Seabrook Station, Units 1 and 2)
)
On-site EP
)
September 13, 1988
)
MASSACHUSETTS ATTORNEY GENERAL'S FURTHER REEPONSE TO INTERROGATORIES 6 AND 7 6.
Has any representative of or person employed by the Department of the Attorney General of the Commonwealth been in contact with any selectman, civil defense director or other official of Amesbury, Morrimack, Newbury, West Newbury, Newburyport, Salisbury or Haverhill concerning any actual or proposed siren warning system for Seabrook Station?
If so, please:
(a)
Identify each selectman, civil defense director or other official who was contacted and the ufficial, representative or employee who contacted them.
(b)
Describe in detail the date, time, manner, place, and substance of the communication.
(c)
Identify and produce every document that reflects, refers to, or relates in any way to any such contact.
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Resoonse 6:
The Mass AG has already produced a town ordinance (pertinent to the town of Amesbury) and a i
communication related thereto.
Other than this, the Mass AG knows of no other such ordinance.
In addition, the Mass AG knows of no communication with a town official which would contain probative evidence bearing on the interpretation of any ordinance.
At sometime prior to March 7, 1988, Stephen Jonas of the Mass AG's Office communicated with William Lord from Amesbury.
The Mass AG does not recall the date or time of the conversation or whether it was over the phone.
The full substance of the communication with respect to sirens was an inquiry from Mr. Jonas whether an alternative notification system of the Applicants might violate local I
ordinances or laws.
There may have been more than one such conversation and if there was more than one, the substance f
was identical.
The result of this conversation or i
conversations was the March 7, 1988 letter from William Lord to Stephen Jonas, a copy of which has been provided to the Applicants.
The Mass AG does not recall a conversation of March 7, 1988 identified in the letter.
The Mass AG had no communications after the March 7, 1988 letter with William Lord or any other town official of Amesbury concerning the Amesbury ordinance.
The Mass AG has never had a conversation with any town official of Amesbury at all bearing on the interpretation of the Amesbury zoning by-law.
b o
7.
Has any other official, representative, or employee of the government of the Commonwealth of Massachusetts been in contact with any selectman, civil defense director or other official of Amesbury, Merrimack, Newbury, West Newbury, Newburyport, Salisbury or Haverhill concerning any actual or proposed siren warning system for Seabrook Station?
If so, please:
(a)
Identify each selectman, civil defense director or other official who was contacted and the official, representative or employee who contacted them.
(b)
Describe in detail the date, time, manner, place, and substance of the communication.
(c)
Identify and produce every document that reflects, refers to, or relates in any way to any such contact.
Resnonse_2:
See Response to Interrogatory Number 6.
JAMES M.
SHANNON ATTORNEY GENERAL COMMONWEALTH OF MASSACHUSETTS f f~
Skum 0. Gao By:
Stephdn A. Jonas (/
Assistant Attorney General Deputy Chief Public Protection Bureau Department of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 (617) 727-2200 Dated: September 13, 1988 s
UNITED STATES OF AMERICA hhf NUCLEAR REGULATORY COMMISSION
'88 SEP 15 All :54 l
In the Matter of h[$ R w; U M [
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suhr4 PUBLIC SERVICE COMPANY OF NEW
)
Docket No.(s)
HAMPSHIRE, at al.
)
50-443/444-OL-1 i
J (Seabrook Station, Units 1 and 2)
)
(On-site EP)
)
)
CERTIFICATE OF SERVICE I,
Stephen A. Jonas, hereby certify that on September 13, 1988, I made service of the within Massachusetts Attorney General's Further Responses To Interrogatories 6 And 7, by first class mail, or by Federal Express as indicated by (a], or by hand delivery as indicated by
(**],
to:
Sheldon J. Wolfe, Chairperson Dr. Emmeth A.
Luebke Atomic Safety & Licensing Board 5500 Friendship Boulevard U.S. Nuclear Regulatory Apartment 1923N Commission Chevy Chase, MD 20815 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Sherwin E. Turk, Esq.
Atomic Safety & Licensing Board U.S. Nuclear Regulacory Commission U.S.
Nuclear Regulatory Office of General Counsel Commission 1717 H Street East West Towers Building Washington, DC 20555 4350 East West Highway Third Floor Mailroom Bethesda, MD 20814 H. Joseph Flynn, Esq.
Stephen E. Merrill Assistant General Counsel Attorney General Office of General Counsei George Dana Bisbee Federal Emergency Management Assistant Attorney General Agency Office of the Attorney General 500 C Street, S.W.
25 Capitc1 Street Washington, DC 20472 Concord, NH 03301
M Docketing and Service Paul A.
Fritzsche, Esq.
U.S. Iluclear Regulatory Office of the Public Advocate Commission State House Station 112 Washington, DC.
20555 Augusta, ME 04333 Roberta C.
Pevear Ms. Diana P.
Randall State Representative 70 Collins Street Town of Hampton Falls Seabrook, t1H 03874 Drinkwater Road Hampton Falls, tiH 03844 Atomic Safety & Licensing Robert A.
Backus, Esq.
Appeal Board Panel Backus, Meyer & Solomon U.S.
11uclear Regulatory 116 Lowell Street Commission P.O.
Box 516 Washington, DC 20555 Manchester, ilH 03106 Atomic Safety & Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.S. tiuclear Regulatory 5 Market Street Commission Portsmouth, 11H 03801 Washington, DC 20555 Matthew T.
Brock, Esq.
Mr. J.
P.
11adeau Shaines & McEachern Board of Selectmen 25 Maplewood Avenue 10 Central Road P.O.
Box 360 Rye, t1H 03870 Portsmouth, t1H 03801 Ms. Sandra Gavutis, Chairperson Mr. Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E.
Kingston, 11H 03827 Portsmouth, 11H 03801 Senator Gordon J.
Humphrey Mr. Angelo Machiros, Chairman U.S.
Senato Board of Selectmen Washington, DC 20510 25 High Road (Attn: Tom Burack) tiewbury, MA 10950 Senator Gordon J. Humphrey Edward Molin 1 Eagle Square, Suite 507 Mayor Concord, flH 03301 City Hall (Attn: Herb Boynton) tiewburyport, MA 01950 Mr. Donald E.
Chick Mr. William Lord Town Manager Board of Selectmon Town of Exeter Town Hall 10 Front Street Friend Street Eacter, !1H 03833 Amesbury, MA 01913 2-
.N E
Brentwood Board of Selectmen Gary W.
Holmes, Esq.
I RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH
- 03845, i
Philip Ahrens, Esq.
Ellyn Weiss, Esq.
Assistant Attorney General Harmon & Weiss l
Department of the Attorney Suite 430 t
General 2001 S Street, N.W.
State House Station #6 Washington, DC 20009 I
Augusta, ME 04333 E
- Kathryn Selleck, Esq.
Richard A. Hampe, Esq.
Thomas G. Dignan, Esq.
Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 I
Boston, MA 02110 t
Beverly Hollingworth Ashad A. Ashod, Esq.
l 209 Winnacunnet Road 376 Main Street Hampton, NH 03842 Haverhill, MA 01830 William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2 10 Front Street South Hampton, NH 03827 Exeter, NH 03833 i
Robert Carrigg, Chairman Anne E. Goodman, Chairperson l
Board of Selectmen Board of Selectmen t
Town Office 13-15 Newmarket Road Atlantic Avenue Durham, NH 03824 l
North Hampton, NH 03862 L
Allen Lampert Ivan W.
Smith, Chairman Civil Defense Director Atomic Safety and Licensing Town of Brentwood Board Panel 20 Franklin Street U.S. Nuclear Regulatory Commission Exeter, NH 03833 Washington, DC 20555 Charles P. Graham, Esq.
Jsdith H. Mizner, Esq.
Murphy & Graham Lagoulis, Clark, Hill-Whilton 33 Low Street
& McGuire i
Newburyport, MA 01950 79 State Street
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Newburyport, MA 01950 l
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Scott Hill-Whilton, Esq.
Barbara A. St. Andre, Esq.
Lagoulis, Clark, Hill-Whilton Kopelman & Paige, P.C.
& McGuire 77 Franklin Street 79 State Street Boston, MA 02110 Newburyport, MA 01950
- Sheldon J. Wolfe 1110 Wimbledon Drive McLean, VA 22101 f
(
Stiephe'i A. J Mas Assistant Attorney General Deputy Bureau Chief public Protection Bureau
Je f the Attorney General i ". AL:sourton Place P, a t o r., MA 02108 (617) 727-2200 Dated:
September 13, 1988 I
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