ML20195C998
| ML20195C998 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/16/1988 |
| From: | Jonas S MASSACHUSETTS, COMMONWEALTH OF |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| CON-#288-6527 OL-1, NUDOCS 8806230011 | |
| Download: ML20195C998 (8) | |
Text
- a A -g eel.AIED @RRE,Sgo,g UNITED STATES OF AMERICA 00CKETED d '-
NUCLEAR REGULATORY COMMISSION USNRC.
ATOMIC SAFETY AND LICENSING BOARD 8 JW 20 P5 47 Before Administrative Judges:
Sheldon J. Wolfe, Chairman QFF !ct g g (:, j.g,
Emmeth A. Luebke 90ChtIpn,. :py n' dAE6 Jerry Harbour
)
Docket Nos. 50-443-OL-1 In the Matter of
)
50-444-OL-1
)
PUBLIC SERVICE COMPANY OF
)
(On-Site Emergency Planning NEW HAMPSHIRE, et al.
)
and Safety Issues)
)
(Seabrook Station, Units 1 and 2) )
June 16, 1988
)
MASSACHUSETTS ATTORNEY GENERAL'S FIRST PEQUEST TO APPLICANTS FOR PRODUCTION OF DOCUMENTS AND ENTRY UE0!LLAND FOR INSEECTIOfLREGARDING SIRER_LQHTENTION Pursuant to 10 C.F.R. $2.741, James M.
Shannon, the Attorney General for the Commonwealth of Massachusetts ("Mass.
A.G.")
requests that the Applicants produce for inspection and copying at One Ashburton Place, 19th Floor, Boston, Massachusetts 02108, at 10 a.m.
on July 16, 1988, the following documents.
DEFINITIONS AND INSTRUCTIONS 1.
"Document" or "documents" shall mean any writing or any other compilation of information whether handwritten,
[
typewritten, printed, recorded, produced or reproduced by any process.
Documents include basic records and summaries of such records (including computer runs), original versions and copies a.
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that differ in any respect from original versions-including all marginal notes on'any original version or copy; and documents in the. possession, custody and control of the Applicants or f
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consultants, investigators,. counsel or others who have assisted the Applicants'in connection with this licensing proceeding.
2.
"person" shall mean individuals, corporations, partnerships, joint ventures, associations, organizations or groups of individuals.
i 3.
"Relate to" or "relating to":shall mean directly or indirectly mentioning or describing, pertaining to, being connected with, or reflecting upon a stated subject matter.
4.
If you withhold any document described in this request i
under the claim of privilege or other limitation on discovery, please provide.the following information with respect to each document withheld upon such grounds, signed by counsel:
A.
The place, approximate date, and manner of recording or otherwise preparing the document; B.
The name and title of the sender; and C.
The name and title of the recipient (s) of the document; D.
The name of each person or persons (other than stenographic or clerical assistants) participating in the preparation of the document; E.
The name and corporate position, if any, of each person to whom the content of the document has heretofore l
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been communicated by copy, exhibition, reading or substantial summarization; and F.
A statement of the basis on which the privilege or limitation is claimed.
5.
"Design Report" means the Seabrook Station Public Alert and Notification System, FEMA-REP-10 Design Report of New Hampshire Yankee dated April 30, 1988.
6.
"VANS System" means the primary public alert and notification system identified and described in the Design Report.
7.
"Airborne Alerting System" means the backup system to the VANS system described in the Design Report.
8.
All uses of the conjunctive include the disjunctive and vice versa.
DOCUMENTS REOUESTED 1.
Figure 2-2 of the Design Report.
2.
All documents the Applicants were asked to identify in the Massachusetts Attorney General's First Set Of Interrogatories to Applicants Regarding Siren Contentions.
3.
All documents related to Table 2-2 of the Design Report including backup material and raw data on VANS Route Times.
4.
All documents relating to or comprising manufacturer specifications, descriptions and instructions for the VANS trucks, the sirens employed on the VANS vehicles and the
.1-airborne alerting system helicopter, the telescoping crane,.the stabilizing bars or outriggers, the remote control system i
(including the encoder, radio transmitter, receiver and decoding! equipment) and the' helicopter (s) for the airborne alerting system.
5.
All documents relating to the use of the equipment described in the Request No. 4 in poor weather conditions, including, but not limited to, high wind, heavy rain, snow and icy or extreme cold conditions.
6.
All documents relating to authoriti or permission received or sought by the Applicants from either private parties or public authorities for the use and operation of the staging areas and preselected acoustic locations.
7.
All documents relating to possible gaps in sound coverage from the sirens to be used in the VANS system.
8.
The detailed procedures for the testing programs of the siren system described at page 2-21 of the Design Report.
ENTRY REOUESTED The Mass. A.G.
requests that he and his arthorized representatives be permitted to enter upon the Applicants' property for the purpose of inspecting, surveying, photographing and testing the VANS vehicles and related equipment and the airborne alerting system and related
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equipment.
.The Mass.fA.G.. requests such entry at a mutually convenient tinie and date, but in any event, no later than July 16,.1988.
JAMES M.
SHANNON ATTORNEY GENERAL COMMONWEALTH OF MASSACHUSETTS f
"SteVRen A. 4Tnas Deputy Chief.
Public Protection Bureau One Ashburton Place Boston, Massachusetts 02108 (617) 727-4878 Dated:
June 16, 1988 l
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J UNITED' STATES OF AMERICA NUCLEAR REGULATORY COMMISSION C0 TED
'88 JN 20 P5 :47
)
In the Matter of
)
)
0FFICE Or EU PEUdY PUBLIC SERVICE COMPANY OF NEW
)
DocketNo.(s)0$0Ydh'Mhd[d356-1 HAMPSHIRE,-et al.
)
-(Seabrook Station, Units 1 and 2)
)
~
)
)
l CERTIFICATE OF SERVICE I,
Stephen A.
Jonas,-
hereby certify that on June 16, 1988, I made service of the within Mass. A.G.'s First Request To Applicants For Production of Documents And Entry Upon Land For Inspection F.egarding Siren-Contention by mailing a copy thereof, postage prepaid, by first class mail, or as indicated by an asterisk, by hand delivery, to:
Sheldon J.
Wolfe, Chairperson
. Emmeth A.
Luebke Atomic Safety & Licensing Boari
- 500 Friendship Boulevard U.S.
Nuclear Regulatory Apartment 1923N Commission Chevy Citase, MD 20815 East West Towers Building 4350 East West Highway Third Floor Mailroom
-Bethesda, MD 20814 Dr. Jerry Harbour Sherwin E.
Turk, Esq.
Atomic Safety & Licensing Board U.S.
Nuclear Regulatory 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 Counsel George Dana Bisbee Federal Emergency Management Assistant Attorney General Agency Office of the Attorney General 500 C Street, S.W.
25 Capitol Street Washington, DC 20472 Concord, NH 03301
n;
. Docketing and Service Paul A.
Fritzsche, Esq.
U.S.
Nuclear Regulatory Office of'the Public Advocate Commission State House Station 112
- Washington, DC.
20555 Augusta, ME 04333 Roberta C.
Pevear Ms. Diana P.
Randall L
State Representative.
70 Collins ~ Street Town of Hampton. Falls Seabrook, NH 03874 Drinkwater Road Hampton Falls, NH 03844-k' Atomic Safety & Licensing Robert A.LBackus, Esq.
Appeal Board Panel Backus, Meyer & Solomon U.S.
Nuclear Regulatory 116 Lowell Street Commission P.O.
Box 516 Washington,- DC 20555 Manchester, NH 03106 Atomic-Safety & Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.S.
Nuclear Regulatory 5~ Market Street Commission Portsmouth, NH 03801 Washington, DC 20555 Paul McEachern, Esq.
J.
P.
Nadeau Matthew T.
Brock, Esq.
Board of Selectmen Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P.O.
Box 360
.Portsmouth, "H
03801 Ms. Sandra-Gavutis, Chairperson Mr. Calvin A Canney
'Boardlof Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E.
Kingston, NH 03827 Portsmouth, NH 03801 Senator.Gordon J.
Humphrey U.S.-Senate Mr. Angelo Machiros, Chairman Board:of Selectmen Washington,.DC 20510 25 High Road
.(Attn: Tom Burack)
Newbury, MA 10950
. Senator Gordon J. Humphrey Edward Molin
.1 Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton)
Newburyport, MA 01950 Mr. Donald E.
Chick Mr. William Lord Toun Manager Board of Selectmen
-Town of Exeter Town Hall 10 Front Street Friend Street Ex e t e r ', NH 03833 Amesbury, MA 01913
,\\'
Brentwood Board of Selectmen Gary W.
Holmes, Esq.
RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet-Road Hampton, NH 03841 Philip Ahrens, Esq.
Diane Curran, Esq.
Assistant Attorney General Harmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W.
State House Station #6 Washington, DC 20009 Augusta, ME 04333
- Thomas G.
Dignan, Esq.
Richard A.
Hampe, Esq.
R.K.
Gad III, Esq.
Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street C7ncord, NH 03301 Boston, MA 02110 Beverly Hollingworth Edward A. Thomas 209 Winnacunnet Road Federal Emergency Management Hampton, NH 03842 Agency 442 J.W. McCormack (POCH)
Boston, MA 02109 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 Robert Carrigg, Chairman Mrs. Anne E.
Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-15 Newmarket Road
.c Avenue Durham, NH 03824 Atlan 4 North Hampton, NH 03862 Allen Lampert Ivan W.
Smith, Chairman Civil Defense Director Atomic Safety and Licensing Town of Brentwood Board Panel 20 Frannlin Street U.S.
Nuclear Regulatory Commission Exeter, NH 03833 Washington, DC 20555 Charles P. Graham, Esq.
Judith H. Mizner, Esq.
McKay, Murphy & Graham Lagoulis, Clark, Hill-Whilton Old Post Office Square
& McGuire 100 Main Street 79 State Street Amesbury, MA 01913 Newburyport, MA 01950 l
Steph'en A.
J,ddas Dated: June 16, 1988