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Category:AFFIDAVITS
MONTHYEARML20199D2461999-01-19019 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 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 ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20237A0631998-08-0606 August 1998 Affidavit of TC Feigenbaum Re Length of Fuel Cycles at Seabrook Station & of Future Plans for Fuel Cycle Length. W/Certificate of Svc ML20236M5181998-06-27027 June 1998 Affidavit.* Affidavit of J Parker Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M4871998-06-27027 June 1998 Affidavit.* Affidavit of K Conrad Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5091998-06-27027 June 1998 Affidavit.* Affidavit of Sn Haberman Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5231998-06-27027 June 1998 Affidavit.* Affidavit of SA Parker Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M4971998-06-27027 June 1998 Affidavit.* Affidavit of D Bogen Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5061998-06-27027 June 1998 Affidavit.* Affidavit of C Nord Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5401998-06-27027 June 1998 Affidavit.* Affidavit of Eh Mecklejohn Re 980506 License Exemption Request from Operator of Seabrook Station ML20216E0351998-04-13013 April 1998 Affidavit of FW Getman (Great Bay Power Corp) Requesting That NRC Withhold Util Response to NRC RAI Re Proposed Acceleration of Decommissioning Funding for Ownership Share of Seabrook Station ML20140B9711997-06-0404 June 1997 Affidavit of FW Getman Per 10CFR2.790,re Great Bay Power Corp'S Filing of Suppl to Petition for Partial Reconsideration of Exemption Order ML20073E1641991-04-19019 April 1991 Affidavit of J Hausner.* Discusses Facility Offsite Radiological Emergency Planning.W/Certificate of Svc ML20065K3421990-11-0202 November 1990 Affidavit of Cole.* Discusses Issue of Whether Commonwealth of Ma School Teachers & Day Care Ctr Personnel Perform Roles Contemplated in Spmc ML20065K3451990-11-0101 November 1990 Affidavit of Mc Sinclair.* Responds to Questions Posed by Aslab in ALAB-937 Re Whether Spmc Provides Adequate Supervision & Care of Children Evacuated to School Host Facility at Holy Cross College.W/Certificate of Svc ML20062C2781990-10-19019 October 1990 Affidavit of a Callendrello Addressing Issue Re Staffing of Seabrook Plan for Massachusetts Communities School Host Facility as Discussed in Aslab 900918 Decision.W/Certificate of Svc ML20062C2651990-10-18018 October 1990 Affidavit of Ds Mileti Addressing Issue Whether Massachusetts School Teachers & Day Care Ctr Personnel Would Respond to Assignments in Emergency to Escort Children on Buses ML20059M6201990-09-24024 September 1990 Affidavit of GL Iverson.* Responds to Statements Made in Mc Sinclair 900907 Supplemental Affidavit.W/Certificate of Svc ML20059B0021990-08-22022 August 1990 Affidavit of RW Donovan Re Staffing Adequacy for Implementation of New Hampshire Radiological Emergency Response Plan for Plant.W/Certificate of Svc ML20059A9981990-08-21021 August 1990 Affidavit of Jc Dolan Re Adequacy of Staffing for Implementation of New Hampshire Radiological Emergency Response Plan for Plant ML20059B0281990-08-21021 August 1990 Affidavit of GL Iverson Re Position of Governor Media Ctr representative.Twenty-second Initial Vacancy Was New Hampshire Public Utils Commission Lead Engineer ML20059A8911990-08-16016 August 1990 Affidavit of GL Iverson Re Adequate Staffing at New Hampshire Radiological Emergency Plan in Event of Radiological Emergency at Seabrook.W/Certificate of Svc ML20056B2251990-08-0606 August 1990 Affidavit of Mc Sinclair.* Affidavit Re Offsite Radiological Emergency Response Planning for State of Nh & Spmc ML20081E2431990-07-31031 July 1990 Affidavit of a Desrosiers Re Evacuation of Advanced Life Support Patients ML20081E2471990-07-31031 July 1990 Affidavit of B Cohen Re Evacuation of Advanced Life Support Patients ML20081E2401990-07-31031 July 1990 Affidavit of Rl Goble Re Preparation of Advanced Life Support Patients for Evacuation ML20081E2511990-07-31031 July 1990 Affidavit of Sj Plodzik Re Evacuation of Advanced Life Support Patients ML20055G6521990-07-11011 July 1990 Affidavit of T Urbanik Re Licensee Motion for Summary Disposition of Advanced Life Support Patients Issue.* Addresses Issues Re Preparation of Advanced Life Support Patients.W/Certificate of Svc ML20058K8011990-06-25025 June 1990 Affidavit of Am Callendrello.* Addresses Issues Defined by ASLB in LBP-90-12 Re Preparation of Advanced Life Support Patients for Evacuation & Impact on Special Population Evacuation Time Estimates.W/Certificate of Svc ML20058K7811990-06-25025 June 1990 Affidavit of J Bonds.* Addresses Issues Defined by ASLB in LBP-90-12 Re Advanced Life Support Patients & Consideration of Preparation Time for Evacuation Under State of Nh Radiological Emergency Response Plan.W/Certificate of Svc ML20058K7841990-06-25025 June 1990 Affidavit of D Albertson.* Addresses Issues of Advanced Life Support Patient Preparation for Transport.Certificate of Svc Encl ML20058K7941990-06-25025 June 1990 Affidavit of Kj Callahan.* Addresses Issues of Advanced Life Support Patient Preparation for Transport.Certificate of Svc Encl ML20012C6701990-03-15015 March 1990 Affidavit of Rd Pollard.* Advises That Deficiencies Cited in INPO & Other Repts Demonstrate No Basis for Finding That Reactor Complies W/Nrc Regulations or Can Be Operated Safely ML20012C7121990-03-13013 March 1990 Affidavit of Be Beuchel.* Addresses Intervenors Allegations & Whether Significant Safety Issue Present Re Rosemount Transmitters.Supporting Info,Including Beuchel Prof Qualifications & Certificate of Svc Encl ML20006G1151990-02-26026 February 1990 Affidavit of Gc Minor Re Rev of Rosemount Transmitters at Seabrook.* Discusses Potential Safety Impact of Rosemount Transmitter Problems & Need for Changing Faulty Transmitters Before Plant Proceeds W/Power Ascension & Operation ML20011F1291990-02-16016 February 1990 Affidavit of WT Wallace.* Discusses Oct 1988 Amends to State of Nh Radiological Emergency Response Plan.Supporting Info Encl ML20011F1281990-02-16016 February 1990 Affidavit of GL Iverson.* Discusses Oct 1988 Amends to State of Nh Radiological Emergency Response Plan ML19351A7051989-12-0606 December 1989 Affidavit of TC Feigenbaum.* Advises That Further Delay in Obtaining Full Power License for Plant & Reaching Commercial Operations Caused by Further Litigation Will Be Very Costly & Unnecessary.W/Supporting Info & Certificate of Svc ML19332F9701989-11-30030 November 1989 Joint Affidavit of Gc Minor & Sc Sholly.* Opposes Issuance of Full Power OL Until Problems Noted Resolved,Consistent W/ NRC Finding in Confirmatory Action Ltr CAL-RI/89-11.Addl Info & Certificate of Svc Encl ML19332D7011989-11-22022 November 1989 Affidavit of AA Kelsey.* Discusses 1989 Edition of Arbitron Radio County Coverage Rept for Essex County,Ma.Few People in Geographic Area Listen to Whav & Wlyt.W/Certificate of Svc ML20006C4371989-11-21021 November 1989 Affidavit of AA Kelsey.* Discusses Radio Coverage in Merrimac Valley.W/Supporting Info & Certificate of Svc ML19332D5701989-11-17017 November 1989 Joint Affidavit of Gc Minor & Sc Sholly Re New Hampshire Yankee 890921 OL Amend Request (Plant Instrument Air cross-connect to Containment Bldg Air sys,NYN-89116).* Proposed Amend Considered Illogical & W/O Technical Merit ML19332D5301989-11-14014 November 1989 Affidavit of Am Callendrello.* Refutes Intervenors Allegations That Util No Longer Able to Provide Emergency Info to Public as Result of Withdrawal of Agreement Between Util & Wcgy.W/Supporting Info ML19332D5441989-11-14014 November 1989 Affidavit of Gr Gram.* Confirms Util Adherence to 870914 Commitment to Provide Certain Svcs & Equipment for Planning & Implementation of Alerting Sys.W/Supporting Info & Certificate of Svc ML19332D5361989-11-13013 November 1989 Affidavit of Gj Catapano.* Denies Intervenors Allegations That Util Incapable of Providing Prompt Emergency Instructions to Public in Light of Withdrawal of Certain Agreements.Supporting Info Encl ML19354D5121989-11-0909 November 1989 Affidavit of R Boulay Re Voiding of Emergency Broadcast Sys Ltrs of Agreement.* Since Wcgy Voided Ltr of Agreement W/ Util & Withdrew from Emergency Plan,Broadcast Sys for Merrimac Valley Cannot Be Activated.Related Info Encl ML19354D5141989-10-30030 October 1989 Affidavit of R Sawyer Re Voiding of Emergency Broadcast Sys Ltr of Agreement.* Marked-up Affidavit Discussing Impact of Wcgy Voiding Ltr of Agreement W/Util & Withdrawing from Participating in Emergency Planning.W/Certificate of Svc ML19327B7021989-10-27027 October 1989 Affidavit of Jf Bassett Re Voiding of Emergency Broadcast Sys (Ebs) Ltrs of Agreement.* Discusses Fact That Applicant Has Never Followed Through on Commitment to Provide Ebs Equipment,Per 870914 Ltr of Agreement.Supporting Info Encl ML19327B7061989-10-26026 October 1989 Affidavit of Dj Rowe Re Voiding of Emergency Broadcast Sys (Ebs) Ltrs of Agreement.* Discusses Applicant Refusal to Live Up to Commitments to Commonwealth of Ma Ebs.W/ Supporting Info & Certificate of Svc 1999-01-19
[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
________ _ _ _
September 17, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al. ) 50-444-OL-1
) (On-Site Emergency (Seabrook Station, Units 1 and 2) ) Planning and Safety
) Issues)
)
)
AFFIDAVIT Of SEBASTIAN N. CARUSO I, Sebastian N. Caruso, being on oath, depose and say as follows:
- 1. I am a Project Engineer for New Hampshire Yankee.
Since January of 1988 I have had responsibility, as a Project Engineer, for the Massachusetts Vehicular Alert and Notification System (VANS). In particular, I have been responsible for coordinating the design aspects of the VANS vehicles' development program from the assembly of the prototypo through procurement of the vehicles which vill form the VANS fleet. Throughout this effort, I have had significant liaison with the vendors Nhich supply the components of these vehicles, namely the truck manufacturer, 0809260050 000917 PDR ADOCK 05 % y 3 0
the crang manufacturer and the siren manufacturer. I 9 reviewed data developed by these vendors, as well as from independent consultants, in order to assure that the
, vehicles, together with their attached equipment (fully loaded), would remain roadworthy under severe road conditions and would remain operable in weather extremes. A statement of my professional qualifications is attached hereto and marked "A".
- 2. Tne purpose of this affidavit is to address allegations in Contention Bases A.4 and A.6 regarding the Applicants' VANS vehicles. The allegations I address are:
F (1) the VANS vehicles are inadequate for their intended use (Basis A.4); (2) the VANS vehicles cannot withstand and will not operate properly with the weight, amounts and nature of equipment intended to be carried by the vehicles (Bacis A.4);
d and (3) snovy, icy and extreme cold weather conditions will imrode extension of the sirens to their operational position (Busis A.6).
Basis A.4 Adequacy of VANS Vehicles
- 3. As discussed in the following paragraphs, the VANS vehicles can withstand and vill operate properly with the weights, amount and nature of equipment to be carried by the vehicle.
- 4. The only relevant concerns regarding the adequacy of a vehicle carrying or transporting equipment / materials are
the weight of the equipment / materials and the method to be used, if any, to secure it to the vehicle during transit.
- 5. The crane, its sub-base and the truck flatbed will be permanently mounted on a 1988 truck.
The siren will be securely attached tes the crane by means of a structural support constructed from tube steel and steel plates. The siren cradle, siren control cabinets and generator will be securely attached to the truck flatbed.
The siren batteries and the electronics associated with the siren control cabinets are all securely mounted and located within the control cabinets.
- 6. A truck with 10.00 x 20G, 12 ply tires has a gross weight rating from of 29,900 pounds. See attached correspondence from , marked "B".
- 7. The weight of a VANS vehicle and its associated equipment is:
Weight of truck chassis . . . 8895 pounds (neo Attachment B)
Weight of crane and sub-base. 8050 pounds Weight of flatbed . . . . . . 1600 pounds Weight of sirens, siren cradle, control cabinets and miscellaneous hardware. . . . 4500 pounds (estimated)
Allowance for gas, engine fluids, driver. . . . . . . . 955 pounds (estimated)
Total Vehicle Weight. . . 24000 pounds (estimated)
- 8. Thus, the weight of a fully loaded VANS vehicle will be at least 5,900 pounds below the gross vehicle weight rating, and therefore the fully loaded vehicle will operate properly.
- 9. Moreover, as described in the following paragraphs, the VANS vehicles are adequate for their intended use.
- 10. The VANS vehicle is based on a truck-crane combination that is commonly used in the construction industry for lifting heavy loads such as bricks, concrete blocks, and pipes.
- 11. The truck f ront and rear axle weight ratings for a truck with 10.00 x 20G, 12 ply tires, meet requirements for the vehicle to be used in conjunction with a Crane.
- 12. The acceptability of the truck-crane combination for its intended use (i.e., lifting the dtal giren package from its stored position to its operating position) has been demonstrated by analysis as described in the Affidavit of Donald E. Johnson.
- 13. All of the VANS vehicles are designed to operate in snow, icy and/or extreme cold weather conditions. Each vehicle is equipped with (a) an engine block heater, (b) 4
maximum battery package, (c) heated air dryer for the brake system, and (d) dual 10.00 X 20G mud and snow tires on the rear axle, all of which assure vehicle drivability. It should be noted that items (a), (b) and (c) above are consistent with recommendations made by Ford (see attached correspondence marked "C"). A fully equipped VANS vehicle will weigh approximately 24,000 pounds which, when combined with the dual 10.00 X 20G mud and snow tires, provides sufficient traction to propel the vehicle through a snow and ice covered roadway.
Basis A.6: Siren operation in Snovy, Icy, and cold Weather condition
- 14. The rotating mechanism for the sirens received extensive wind tunnel tests by Florida power and Light in August 1981 (see attachment marked "D"). Subs equent to theue tests upgraded the motor to produce sufficient torque to enable the rotation of the siren in winds up to 120 mph (motor upgraded from 100 ft Ib to 550 ft lb). With regards to external temperature effects, the rotor used on the VANS sirens can operate down to -20'F.
- 15. The Flot da powa.r and Light study was conducted with a single siren which has a "sail" area (wind resistance area) slightly smaller than the dual WS-4000.
This study, however, provides sufficient acsurance that the rotating mechanism will turn under wind conditions up to 60 mph, including gusts to 72 mph.
5-
- 16. At discussed in the following paragraphs, the crane will extend and raise the sirens to their operational position even with snow, icy and extreme cold weather conditions for a number of reasons.
- 17. Uidcr the SPMC, Procedure No. Ip-2.16 (copy attached and marked "E"), the VANS operators are responsible for the operation of the VANS Staging Areas including maintaining the VANS vehicles in a state of readiness for deployment (Section 2.0 and Section 5.1.1, Step E). This would necessarily entail the routine removal of snow from the VANS vehicle to prevent accumulation of snow and the formation of ice.
- 18. The VANS vehicle will have a tarpaulin type cover over that portion of the vehicle containing the crana boom, crane hydraulic control levers and siren system. This is consistent with a recommendation by the crane manufacturer (see attachment marked "F"). The shape of the cover will prevent puddles from forming and will deflect any precipitation at an angle down to the ground. In addition, the cover will be designed to automatically uncover when the siren is raised. That is, the VANS operator will not have to remove it manually.
- 19. Even if snow or ice did accumulate on the crane boom or the outriggers, there would be no affect on the operational performance of the crane. There is sufficient force being generated by the hydraulic system to overcome any
snow or ice accumulation on the boom or outriggers. This has also been confirmed by the crane manufacturer (see attachment F).
- 20. The crano hydraulic system will use a commercially available hydraulic fluid, Mobil D.T.E. 10 Series or equivalent, which will operate at -22*F to +140'F.
- 21. In addition, I have reviewed the statements, made by to the Massachusetts Attorney General, to the effect that high winds will not impair the operation of Applicants' VANS crane assembly (see Attachment G). Based upon my own knowledge of that apparatus, I agree with conclusion.
hi$ f. &nar Sebastian N. Caruso STAT. SF NTW HAMPSHIRE Rockingham, ss. September 3 , 1988 The above-subscribed Sebastian N. Caruso appeared before me and made oath that he had read the foregoing affidavit and that the statements set forth therein are true to the best of his knowledge.
Before me,
,81_x Su Em $ S3 7 m, Notary FUblic J My Commission Expires: 3's "U
Caruso Attachacnt A, 1 of 2
.g.
SEBASTIAN N. CARUSO SENIOR ENGINEER CDUCATION Merrimack College - B.S. Civil 3ngineering,1962 Northeastern University - M.S. Civil Engineering. 1964 Massachusetts Institute of Technology - Graduate Credits Towards PR.D.
(1964-1968)
LICENCES AND REGISTRATION Registered Professional Enginner - Massachueetts Registered Profeselonal Engineer - New Hampshire EXPERIENCE
SUMMARY
Hr. Caruso has over 25 years experience in Structural Design and Analysis, and Techni-al Management of Nuclear and non-Nuclear Related Projects.
Pres 6ntly. Me. Car ,o is the Senior Facilities Engineer of New Hampshirs Yankae's Plant Engineering Depart' s ent. His responsibilities include developios project plans, elesigns, engineering, and specifications, as well as sasuring the o <arall technicci excellence of the work performed on essigned projectar Since Jae,ary 1988, he has been assigned as Projet:
Ergineer for the HSasachusetts Vehicular Alert and Notif t ation System (VANS).
Prior to joining New Hampshire Yankee, Mr. Caruso served as a Suptrvising Discipline Engineer for United Engineers & Constructcts, Inc. at their raabrook Nuclear Power Station's Site Engineering Office where he was in charge of the Mechanical Analysis Gioup from 1981 to 1987. fais position included several projsets and entatied aanagement and technical supervision of. over 25 engineers involved in the design and installation of safety
- related aquipment and peripheral components during the plant's construction phase.
Some of the projects under his direction at feabrook Station have included the seismic design and qualification of cable tray and conduit supports, the optimitation of cable tray bracing via state-of-the-ert testing tech-niques, and the design of unique support structuren fot safety-related class lE electrical equipment, ASME components, and instrument and control devices. ,
Mr. Caruso was also inv)1ved with the licensing pr6paration of all safety-related qualification doce.nentation for audits conducted by the NSC's Seismic Qualification Review Teas (SQRT) and the NRC's Pump and Valve Operability L2 view Team (PVORT). He was alsa involved with the Seabrook Station's Piping and Pipe Supports Closeout s'ask Team (PAPSCOTT) in which he served as coordinator for the reconciliation ef fort of all ASME and NNS-1 equipmunt nossle and penetration evaluations.
Caruso Attach:non: A, 2 of 2 j While at Stone and Webster Engineering Corperation, Mr. Caruso held the position of Senior Mechanical Engineer in Stone & Webster's Engineering Mechtnjes Division. For eignt of eleven years he was Lead Mechanf tal Engineer of the Engineering Mechanics Division's Seismic Qualification Group, responsible for technf gol supervision of all seismic qualification of Category I equipt2nt far Stunc $ Webster's Nucjaar Power Projects.
His primary duties included supervising engiaeering personnet and coor-dinating all pha9es of dasign and at.alyses for the purpose of certifying that such safety-related auclear service cooponents or equipment, either f urnished by vendors or dwsigned by Stone & Wehater, were capable of withstan. ting postulated earthquake requiremen;s and sagisfying Licetising commitments as set ferth by the United 5:stes Nuclear Ragulatory Com-mission, In his earlier insitions as Pcwer Engineer and Mechanical Engineer, be coordinated with Stone & Webster clients, construction forces, contractors and sendors on such Nucles Projects as Maine Yankee, Surry Units 1 & 2, North Anna Units 1 & 2, Beaver Valley Units 1 & 2, Jatas A. Fitzpatrick -
Nuclear Power Station and, Millstone Unit 3.
Prior to joining Stone & Webster, M , Caruso served as a Structural Engi-neering Task Leader at ITEK Corporation, whose his primary responsibilities included supervision of structural design sad vibration analysis of Air-borne Photo-Optical Flight Equipment and ground handling 7xJtema used in milita ry applications.
At AVC0 Corporatf.on, Mr. Caruso held the position of Senior Engineer in the Structural Analysis SJetion of AVC0 Corporation's Space Systems Division.
In this positton, he was responsible for all phases of therso-structural stress analysis on the Apollo Command Module's Ablative Heat Shield for environments ranging f rom space flight to re-entry.
Prior to joining AVC0 Corporation, Mr. Caruso held the position of Assistrnt Resident Engineer for Camp, Dresser & McKee, Inc., Consulting Engineers.
This positi, f.avolved structural design and supervision of construction of pumping st4 cions and ewegs disposal f acilities.
As Structural Steel Detailer with General Iron & Steel Works, nls responsi-bilities included the design of suitable connectiona for main and secondary load-carrying membere used in structural steel building feseework.
Since 1966, and concurrent with his present ecployment, Mr. Caruso holds the position of Aaqistant Professor of Kechanical Drawing nnd Graphic Science at Merrimack Collega's Continuing Education Division of Engineering studies where he lectures and instructs on the fendamentain of Engineering Drawing and Destting Techniques.
Caruso Attachment E, 1 of 6 Amendment $
IP 2.16 Pagt 1 Rev. O SEAS 400K PLAN FOR MASSACM/SETTS COMUN! TIES EMPLEMENT!NG PROCEDURE s
IP Number 2 .16 __
(,
Title Vebjef ar Ateet. g g tification P'Mtes Pespered by: _
hv a , ' dJv > Dates bl b L j '
Approved bys . n -
Cates I~ d ' $ (,
New Haeg3 hire Yankee Manager of. Plans and Proced4rst Revision 0 ._
Amendment 5 4
Effective Date
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Caruso Attachmant E, 2 of 6 i
Amendment 5 IP 2.16 Pige 3 Rev. O VEHICULAR ALERT AMD NOT!PICATION SYSTEM 1.0 PV4 POSE This procedure details the actions iteccessry to deploy and activate the Venicular Alert and Notification System (VANS) to accomplish public 31erting in the Matsechusetts portion of the Plume Exposure EPl.
2.0 RJSPohstBILITIES VANS Operators are responsible for the operation of the VAN 5 Stagin)
Areas, including maintaining VANS vehicles in c stcta of readiness. and deploVeent of VANS vehicles m support of Public Aisrt ord Ntif fcation Systes activation.
3.0 PmECAQtyj Frior to VANS t.0tivation, direction is requirtd from the Seatrock Station Shert Tors Weergency Director, Sestrook Stakfon Site Emergency Ofrector,
$seero6.t Station Respnse Menoger e or the New Hampshirt Yankee (NHY) Offa l sita Response Director.
1 4.0 PREREQUISITES An 'JnuWt1 Event or higher emergency classification has been ceclared at Seaercok Station.
L 4
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Carugo Attachment E, 3 of 6 l i.ene ent 3 l IP 2.16 Page 5 Rev. O i
i
- 1. When assigned, additional VANS Cperators drive routes I to verify thJir condition and availability.
- 1. Use a vehicle other than a VANS vehicle, to accomplish this.
- 2. Provide reports to the VANS Operators at the VANS Staging Area of incessable routes or problems with acoystic locations, if any.
J. Raview procedurs Sten 5.1.2 during ths shif t, however, do not impienent fu?ther actions (steps) unless nutified of an A19Ft or higher emergency by the NHY Offsite Response IOC Contd:t.
K. Provici a Oriefing to the oncoming VANS Operator (upon shift e.hange) on the status of the followings o VANS .
o Manpower 3 Raute Ac?st11bil.fty o Communications 5.1.2 Emergency Actions A. Receive notification of en emergency at Seabrook Station I free the NHY Offsite Response IOC Contact over the VANS Atarm System, the NHY Offsite Response Org4Aization (CRO)
Emergency Radio Netteork or commer:161 telephone.
- 1. Log the toergency classification and time of notifi-cation
- 2. ig INEN Notified by the VANS Continite procedure with Alarm Systes 1tep 3.1.1 0 NCtified by radio of Continue procedure with commercia! 9.elephone Step 5.1.2.8
- 8. Inform all VANS Operators at your VANS Staging Area of notification of the energency.
C. Continue this procedure, as applicable, depending on emergency classification notification.
.g g py ( - -- -< - -
Caruso Attachmant E, 4 or 6 l'
Amendent F i 2.16 Page 7 Rev. O i-NOTE The siren say sound upon placing the NIS ir, the P.0 SED position if remote activation from the NNY 3ffsite Response EOC had been initiated while enroute te the VANS acoustical location. If this necurs go to Step 5.1.!.L, then return to Step 5.1.2.0.
- 0. !
Return to the cc' and notify the ANY Offsite Aesponse E0C that the VANS f ! opereele.
CAUTION IF THE SIREN If SOUNtilNQ, THE GENERATOR SHOULO
07 BE STAA7ED UNTIL S!REN ACTIVATION IS COMPLETE.
M. Start the Generate
!. If after repeated atteg ts to start the Generator, it dws not start, all the W offsite ResMnse EOC and '
W,* ore the NN'i Of fsit4 Re* c orte iOC Contact or the t
?.oumunicatim Coordinator . hat th( 4caerator is not
?peratinf.
J. Periodic 311y check the Generator to ensure that it is oe.
X. Periodicslly c,6eck the Interloek 8.ight on the Siren Activation Cnecdwr.
M E3.&i Interlock Light is ON CcPtinue procedJee with StaD 5.1.2.L Interlock L.lght is CFF i. Check that the Manuai toterlock Switch is ir. the Ct.05tD post,dn (open and
- 0. lose the switeh t0 sake sure)
- 2. If the Interlock Light reseins CFF, call the NHY Offsite Response EOC
Caruso Attachmant E, 5 of 6 Amendment 5 IP 2.16 Page 9 i Rev. O
- 3. If no roll cell is initiated, contact and infore the NHY offsite Response EOC Contact, or Communication Coordinator, of the failure of the siren to acti-vote.
4 If dit'octed by the NHY Offsite Response EOC Contact or Communication Coordhetor, to manually activate the siren, perfore tne fo' lowing actions:
e) Turn W manuel activation encoder ON.
b) _
c) Preet and release the A M button.
Press au release the gg!g button.
- 5. Notify the NNY Offsf to Response EOC Contact or Communication Coordinator, of the status of stren citivation.
N.
Standby at the acoustic location, inith the VANS vehicle opet able, sad await further instructions. If notified of stren activatfGn by the kHY Offsite Response EOC Contact or Communication Coordinator, perform Step
- 5. 2.1.0 C. '
Periodically read dnsimetry and log readings on the Emergency Worker Oose Wecord Fora. Report readings to too cxposure Controi coordinator at the Staging Area if they approach limitt. indicated in *he desteetry instructions.
o 175eR or greater on the 0 200 aJt ORD o i3. SR, 10R, ISR, 20R on the 0-00R DAD P. Upon being eelieved by an oncoming VANS cperator at an acoustic location, report to the Emergency Worker Pacil hy to be monitored and decontaminated if required.
Turn in oosimetry and Emergency Worker Dose Record Form to a Dosimetry *ecors eeper.
Q. Upon direction f.*on the NHY Of fsite Reeponse EOC Contact or Communication Coordinator, return to the VANS Staging Area or ott.er location speJified.
o Pirice siren batteries on charge o P.' ovide a debriefing and logs to the VANS Operators o
Await further instructions from the NHY Offsite Response EOC e - , , , - - - - - - , , - - - - - - - - - , - - - - - - - - --- g,
o Caruso Attachm2nt E, 6 of 6 Amendment $
IP 2.16
- age 11 Rev. O Attachment 1 Page 1 of 1 VANS OPERATOR C6WIONOLOGICAL EVENT LOS Pos! TION: VANS Ocerator NAME: AS$1GNMENT:
Community CATE:
VAMS 10 FACILITY: _ VANS Stacina Area -
~
(location /ID) Acoustic Location 10 Time as/pe Event Description I
e l
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