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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] |
Text
,- - - . _ _ _ _ _ _ _ _ _ - . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . - - - - -
FJ W oga%ss ofs :
UNITED STATES OF AMERICA hhfk NUCLEAR REGULATORY COMMISSIOli before the -
ATOMIC SAFETY LIC"N"ING BOARD T8 MP 22 P5:43 gt,r Ex- 't
) .;'
IN THE MATTER OF ) <
PUBLIC SERVICE COMPANY OF ) Docket l's 50-443-O! !
NEW HAMPSHIRE, ET AL ) 50-444-OL !
Scabrook Station Units 1,2) ) Off-site Emergency Planning
)
i Town of Salisbury's Answers to Interrogatories Propounded by Applicante Interrogatory 01:
Answer:
The material and information provided in these ';;.v nses has !r largely been gathered by Charles P. Graham, Town Counsel for the Town of Salisbury, whose address is 33 Low Street, Newburyport, Massachusetts. The information set forth has been contributed .
to and partially received by Salisbury's former Pc3'te Chief, Edwin Oliviera (now deceased) and citizens withi. t'a town vcrying in number from 5 to 25, all of whom prxticipated in assembling contentions af ter reviewing the SPMC .ind submitted the same to Charles Graham for final assembly and submission. l L
As at least one of these citizens has undergone considnrable !
harassment for her role in reviewing the plan and framing contentions, it is the desire of the neveral cit'.senc involved I i
to remain unidentified until ordered to do otherwise. It may be j
+
fairly said that no public officials of the Town actively or directly participat0d in the preparation of contenlinus og in f answering the instant interrogatories. !
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Interrogatory 02:
Answer:
There are no documents in the possession or control of the Town of Salisbury that in any way reflect or refer to what actions could, might, would, could not, would not, might not, do in the event of a radiological emergency except.the SPMC (a copy at the Board of Selectmen's office without revisions, and a copy at Town Counsel's office with revisions) which plan the Town would not implement for various reasons including primarily the following:
- 1. Under no circumstance will the Town yield or parmit control of an evacuation within the Town to other than the state and local officials charged with the responsibility for the inhabitants' safety and health.
- 2. The Town has no confidence that any private organization can effectively provide the communication, transportation, equipment, and manpower required for a timely evacuation.
- 3. The Town's response in the event of a town-wide
, radiological emergency would likely vary significantly from the SPMC.
- 4. The SPMC has numerous defects ae it relates to Salisbury, all of which suggest that the planners knew little or nothing about the Town and traffic within the Town, and altogether ignored significant management issues relating to communication, human behavior, and l
the resources at the disposal of the Town. '
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, .w- e + m.-- m. - --+ -#-- ,y,-cw--% ----,--7 ,,--w----- w--- - - - - - - - -
There have been countless "conversations" regarding what action the Town o. its officials would or would not take in the the event of a radiological emergency. However, there have been no formal deliberations in any public agency or board of the Town as to Salisbury's response to a radiological emergency. The Town is unaware of any minutes of any meetings wherein any such response was discussed. Generally, the content of casual conversations by Selectmen, police officials, and other town officials over the past several yaars has fallen into one or more of the following categories:
- 1. Whether or not the Plant will open;
- 2. Woeful underestimates of summer beach population and traffic problems within the Town;
- 3. Evacuation of school children by parents and the traffic problems resulting;
- 4. Problems evacuating the Merrimac River Basin;
- 5. Inadaquacios of Town resources;
- 6. Lack of confidence in the planners (plant's) ability to provide additional resources;
- 7. The relative merits and risks of the proposed plant.
I Interrogatory 13:
Answer:
In 1987, at the request of numerous citizens, the Salisbury Town Meeting directed and authorized the Town to seek intervener status in Public Service Co. of New Hampshire vs. West Newbury
and appropriated $1,000.00 to defray the costs. While there were genuine questions as to the authority for the issuance of siren permits and the liability of the Town, it may be fairly said that part of the motivation of the Town Meeting then assembled was to hinder the licensing of Seabrook Yankee. In 1985, the Town Meeting voted not to participate in evacuation planning for Seabrook Station. This was after draft plans had been submitted for Salisbury by the State Civil Defense
, Department, which plans entirely ignored the suggestions and comments of the local planning committee. The Town would object to any assertion that this action was intended to "block, hinder, or delay" the licensing of Seabrook Station.
Interrogatory 44:
Answer:
There are no such documents currently in the possession or control of the Town. The Selectmen have studied the process whereby a committee shall be appointed, a consultant retained, and plans promulgated for non-radiological emergencies within the Town. To the best of the Town's current knowledge, no documents have yet been generated as a result. The Town recognizes its obligation to supplement this answer.
Interrogatory 85:
Answerl
, Town Counsel and the Board of Selectmen are reviewing the admitted contentions to prepare a request for limited 4- ;
. j participation in the current proceeding. As of this writing, such review has not been completed and the Town may not accurately answer this interrogatory. The request, however, will be submitted prior to October 5, 1988 and will delineate with specificity those contentions which Salisbury cares to actively litigate.
Interrogatory d6:
Answer Because of the answer to Interrogat7ry 15, a complete answer may not be provided to this Interrogatory. The following answer, however, will be supplemented as the information required for the response is acquired.
- 1. Town of Salisbury #4.
A. The Plan shows a bus route employing Baker Road in Salisbury which is believed not to be a through street as a portion of it is covered by woodland.
D. Citizen residents of the Town who care not to be identified, particularly as the information is easily ascertainable upon a view.
l C. None.
D. Robert Pike, liighway Surveyor, 63 Lafayette Road, Salisbury, Massachusetts.
E. None.
f
- 2. Town of Salisbury 85.
A. Parts of Baker Road are one lane dirt and seasonably impassable. Parts of Ferry Road are subject to seasonal, storm and tidal flooding.
B. Numerous citizen res! Cents of tho. Town. ,
C. None.
D. Robert Pike, Highway Surveyor, 63 Lafayette Road, Salisbury, Massachusetts.
E. None.
- 3. Town of Salisbury #6 as modified by Board Order-A. The pinn provides for bus turnarounds at the transfer point on Beach Road where the road is too narrow to accommodate the turning radius of a bus. As this is also one of two east to west evacuation routes, additional equipment and personnel are required.
Likewise, Beach Road is'of variable width with two or three travel lanes depending upon location along its length. Where reductions in width occur, there are no guides or equipment assigned.
B. Police Chief Edwin Oliviera (now deceased).
C. None.
D. Lfficer in Charge or Police Chief when new Chief is appointed to fill vacancy.
E. None.
- 4. Town of Salisbury 49 as modified (applicants wording).
i: ' . l h
\
A. The Plan makes no provision for the fact that Gillis Bridge is a draw bridge and therefore fails to compensate for traffic backup occasioned by normal operations due to increased boating traffic resulting from evacuation of the river basin.
B. Common sense and personal experience of numerous citizens in the Town.
C. None.
D. An as yet undesignated police officer, probably the officer in charge or a new Chief upon appointment of same.
E. None.
- 5. Town of Salisbury 113 A. As there is a bar at thn mouth of the Merrimac River, unusually hazardous sea conditions frsquently occur under otherwise benign weather conditions, the most typical of which is a summer sea breeze (east or southeast) of 15+ knots in the course of an outgoing tido. While the rolling waves resulting from this
' condition pose danger to all boats, the danger is substantial for small craft and underpowered craft such as sail boats. The Merrimac hazard is well known to the United States Coast Guard and is set forth in coastal r.avigation publications. For many years, the Coast Guard has maintained a "strobe" type flashing light on Plum Island that operates to warn boaters in the basin when this relatively/ common combination of wind and tide occur to create the dangerous sea condition. Boats are capsized and or,
-lost every year at the mouth of the Merrimac River on account of this condition and an attempted exit by a small or underpowered boat under these conditions may fairly be described as foolhardy and dangerous.
B. Common knowledge to we.ter men and fishermen in the area.
C. None.
D. Asst. Harbormaster William Dickie, Town Hall, Salisbury, Massachusetts.
E. None. 6
- 6. Town of Salisbury #14 i
A. The particular road is Ferry Road as it passes through the marsh north of Ring's Island. Otherwise sec the answer 6-(1) above.
- 7. Town of Salisbury #15 A. The plan documents reviewed indicate that more cones would be placed in locations throughout the EPZ than were shown to be in inventory at the staging area.
B. Not applicable.
C. Not applicable.
D. Not applicable.
E. Not applicable.
1 e- .
- 8. Town of Salisbury fl6 A. The facts. underlying this contention evolve out of a 1-basic contradiction in the provisions of the plan as set forth in the contention.
B. Not applicable.
C. Not applicable.
D. Not applicable ;
E. Not applicable.
- 9. Town of Salisbury (17 A. The B & M Railroad Bridge is too low for several >
typas of tractor trailer trucks. This coupled with the plan's purported diversion of east bound traffic on Route 286 onto Lafayette Road south bound is likely to send tractor trailers arriving off Route 95 to the B & M Bridge where they will likely got stuck '
and back up traffic.
B. Not applicable contained in plan documents.
C. None.
D. Robert Pike, Ifighway Surveyor.
E.'None.
- 10. Town of Galisbury #18. '
A. This contention is likely to be argued by Massachusetts Attorney General, however, the factual basis is the former Police Chief's review of tbs table as it compares to transient beach populations he has dealt with as Chief of Police since 1978.
t
B. Chief Edwin Oliviera, now deceased.
C. None - Massachusetts Attorney General may have documents.
D. Officer in charge or newly appointed Police Chief.
E. None.
- 11. Town of Salisbury fl9.
A. The factual basis for this contention is the plan itself.
B. None.
C. None.
D. Officer in charge or newly appoint Chief of Police.
E. None.
- 12. Town of Salisbury #23.
A. The factual basis for this contention is provided in the following:
- 1. Salisbury has 3 full-time highway employees.
- 2. Salisbury relies substantially upon private contractors for road cleaning and other roadwork in the Town.
- 3. Salisbury has a call fire department with 3 full-time firefighters. Most call firefighters work out of town and would have difficulty returning in an evacuation.
- 4. Salisbury has 16 full-time police officers, two cruisers, and a van. On any given shift, there are 4 police officers available. ,
r
- 5. Salisbury has 3 civil defense employees all of whom are part-time and have other full-time work.
B. Board of Selectmen's personal assessment of Town resources as stated to Town Counsel.
C. None.
D. Member of Board of Selectmen, or Police Chief (yet to t
be determined).
E. None.
Respectfully submitted, Charles P."Graham, Town Counsel Town of Salisbury Murphy and Graham 33 Low Street Newburyport, MA 01950 (508) 45-9051 l
intepanh/2088 F
CERTIFICATE OF SERVICE :f[
I, Charles P. Graham, Counsel for the Town of Salisbury, hereby certify that I made service of the withinggoggpt@ Rfy:43 mailing copies thereof, postage prepaid, to:
Lando W. Zech, Jr., Chairman Thomas M. RobeK$k ,)
Nuclear Regulatory Commission NuclearRegulatbry.0phmisbi,on h
Washington, DC 20555 Washington, DC 20555 Kenneth M. Carr Frederick M. Bernthal Nuclear Regulatory Commission Nuclear Regulatory commission Washington, DC 20555 Washington, DC 20555 Kenneth C. Rogers Nuclear Regulatory Commission Washington, DC 2055 Alan S. Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeni Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Thomas S. Moore Mr. Richard R. Donovan Atomic Safety and Licensing Federal Emergency Management Appeal Panel Agency U.S. Nuclear Regulatory Federal Regional Center Commission 130 228th Street, S.W.
Washington, DC 20555 Bothell, WA 98021-9796 Judge Emmeth A. Luebke Diano Curran, Esquire Atomic Safety and Licensing Ellen Weiss, Esquire Board Panel Harmon & Weiss 550 Friendship Doulevard Suite 430 Apartment 1923N 2001 S Street, N.W.
Chevy Chase, MD 20815 Washington, DC 20009 Dr. Jerry Harbour Sherwin E. Turk, Esquire Atomic Safety and Licensing office of the Executive Legal Board Panel Director U.S. Nuclear Regulatory U.S. Nuclear Reulatory Commission Commission Wr.shington, DC 20555 Washington, DC 02555 Adjudicatory File John Trafficonti, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Docket (2 copies) Department of the Attorney U.S. Nuclear Regulatory General Commissicn Ona Ashburton Place, 19th Fir.
Washington, D.C. 02555 Boston, MA 02108
O.
9 Atomic Safety and Licensing R. Scott Hill-Whilton, Esq.
Appeal Board Panel Lagoulis, Clark, Hill-Whilton U.S. Nuclear Regulatory & McGuire Commission 79 State Street Washington, DC 02555 Newburyport, MA 01950 Paul McEachern, Esquire Edward Molin, Mayor Matthew T. Brock, Esquire City of Newburyport Shaines & McEachern City Hall 25 Maplewood Avenue Newburyport, MA 01950 P.O. Box 360 Portsmouth, NH 03801 Senator Gordon J. Humphrey Betsy St. Andre, Esquire One Eagle Square, Suite 507 Kopelman & Paige Concord, NH 03301 77 Franklin Street Attn: Herb Boynton Boston, MA 02110 H. Joseph Flynn, Esquire Mr. William S. Lord Office of General Counsel Board of Selectmen Fede'ral Emergency Management Town Hall Agency Friend Street 500 C Street, S.W. Amesbury, MA 01913 Washington, DC 20472 Judith H. Hizner, Esquire Thomas G. Dignan, Esq.
79 State Street, 2nd Floor Ropes and Gray Newburyport, MA 01950 225 Franklin Street Boston, MA 02110 Signed under pains and penalties of perjury this 16th day of September, 1988.
A %d Charles'P.Cdraham, Esquire nrcserv/2088