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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
' \
l.# gJED CORMESP0fGTTd Filed: May 12, 1986 891{iky
" / n, \
UNITED STATES OF AMERICA ! '\
!! sq1) 9 NUCLEAR REGULATORY COMMISSION l c3 @9 11 before the s
h'b
,qfdp* @
ATOMIC SAFETY AND LICENSING BOARD ~
/'
f
'N fy In the Matter of PUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL NEW HAMPSHIRE, et al 50-444 OL (Seabrook Station, Units 1 and 2) (Off-Site EP)
HAMPTON FALLS ANSWERS TO APPLICANTS' OFF-S1TE EP INTERROGATORIES NOW COMES the Town of Hampton Falls and answers the Interrogatories directed to it by the Applicant as follows:
G-4 (a)
There is a survey, now being performed, to be used as a basis for further defining the needs of the Town of Hampton Falls, and which may bear on this question.
(b) The Board of Selectmen.
1 (c) All town of ficials, plus the volunteer members of the Fire l
Department.
(d) A copy of the survey form is available, an< will be made '
available to the Applicants.
i G-5 (a) Yes. l l
(b) This is an informal plan, and could be called Hampton Falls Emergency Plan.
(c) Yes, by means of survey, Town of Hampton Falls is engaged in '; t s...: n i ng f ea s i b i 1 i t y.
8605160434 8605)*-
PDR ADOCK 0500 .43 G r*DR
p o (d) The survey is a cooperat ive ef fort, and has been underway for several weeks. I t 's expected to be completed in June, and no consultants have been used.
G-6 (a) Town of Hampton Falls obj ects to this question as irrelevant to the issue of whether a plan furnished on behalf of Town of Hampton Falls can be adequate. Without waiving this objection, the answer is not to Town of Hampton Falls knowledge, except that the Selectmen did request day care center operators and a campground operator not to respond to a cer tain sur vey submi t ted by NHCDA, pending complet ion of Town of Hampton Falls own survey, and decision on how to proceed therefrom.
(b) See (a) above.
G-7 (a) See G-6 (a) above.
(b) See G-6 (b) above.
G-8 (a) See answer to G-6 (a) above. In addi t ion, Town of Hampton Falls does claim an attorney / client privilege as to this question.
(b) See G-6 (b) above.
(c) See G-6 (a) above.
l (d) Robert A. Backus is the attorney, Town of Hampton Falls is client. The nature of the representation concerns radiological emergency planning matters, and litigation relating thereto; the privilege attaches because advice of Attorney Backus was related to the scope of his employment.
G-9 (a) Not to our knowledge. )
l (b) N/A. i (c) N/A.
(d) N/A.
1
0 1 TOWN OF HAMPTON FALLS SPECIAL INTERROGATORIES I-1 Yes.
I-2 Town of Hampton Falls is not willing to assume that local of ficials designated in the State Plan submitted on behalf of Town of Hampton Falls are willing to perform the duties assigned to them, because Town of Hampton Falls has a town vote, which the selectmen intend to follow, that no plan will be implemented until approved by voters acting through town meeting. There is, at this t ime, no " local plan" f or Town of Hampton Falls.
I-3 The plan is not workable because there is no plan recognized by Town of Hampton Falls, and all town employees are therefore barred from implementing the plan. See also answer to question I-16.
I-4 Town of Hampton Falls uses " workable" to mean measures that can assure adequate protection for the citizens of the town.
I-5 See G-5 above.
I-6 Not to our knowledge.
I-7 Town of Hampton Falls does not have a fire department, but
- only a volunteer fire department. Therefore, Town of Hampton Falls is nct in a position to order performance of of ficial duties on the part of any member of the volunteer fire department.
I-8 Town of Hampton Falls is not aware of any such instance.
I-9 Town of Hampton Falls does not contend that any teacher or classroom monitor "would" abandon children, but does believe there is a role conflict potential, which raises the possibility that teachers may not be available.
I-10 No.
I-Il N/A.
I-12 Town of Hampton Falls is seeking information to answer Interrogatory I-12, and will supplement this response.
I-13 Yes. The number of contacts, and the dates of meetings, l the subjects discussed at these meet ings, and whether any i changes were made to the plan as a result of the discussions, '
are not information available to Town of Hampton Falls, ;
but may be available through NHCDA. !
I l
l
~
. o 1-14 NHCDA has not indicated any willingness to allow Town of Hampton Falls to have the right to decide whether a plan for Town of Hampton Falls is adequate for Town of Hampton Falls.
I-15 No.
T-16 Town of Hampton Falls believes 85 additional emergency people would be necessary. This would include RADEF additional fire and police personnel, and drivers, based upon the 1980 population.
1-17 Again, Town of Hampton Falls does not say the suggested officials "would," in the event 04' an actual emergency at Seabrook Station, refuse to cooperate and assist in dealing with the emergency. The fire department is not made up of town of ficials. A further answer to this question willl depend, in part, on the results of the survey mentioned in response to question G-4.
I-18 No, although Town of Hampton Falls believes its selectmen and other town officials have expertise concerning the scope of their duties, and their ability to adequately meet requirements that may be placed upon them.
II-1 Yes.
II-2 Since the Hampton Falls volunteer fire department is not an official body in the town, Town of Hampton Falls is without knowledge as to this question.
) II-3 We believe so.
1 II-4 No need for a RADEF Of ficer has existed in the Town's 350 year history.
(
II-5 Yes.
II-6 Town of Hampton Falls has not needed a transportat ion coordinator for its 350 year history.
i II-7 Yes. Yes, II-8 We assume so, although we don't know.
II-9 Yes. Within the limitations of the s tate's resources, and having in mind that there may be many other communities seeking assistance.
I1-10 The RADEF fireman and chief, policeman and chief, Board of Selectmen, Civil Defense Director, Transportation Coordinator. The functions these persons would perform, as suggested in the state's proported plan for Town of 1 Hampton Falls , include alerting functions, traf fic control l
_4_
and coordinat ion, evacuat ion confirmat ion. Town of Hampton Falls objects to this Interrogatory insof ar as it requests it provide an accident scenario. Town of Hampton Falls understands that the federal requirement for planning is based upon the premise that an accident involving radiat ion releases which would af fect, and perhaps require evacuat ion of citizens of Town of Hampton Falls can in fact occur.
II-11 No, although Town of Hampton Falls believes its selectmen and other town officials have expertise concerning the scope of their duties, and their ability to adequately meet requirements that may be placed upon them.
III-1 Yes.
III-2 Town of Hampton Falls has four telephones. Town Clerk, 926-4618; police, 926-4619; selectmen, 926-7101. There is also a telephone in the highway building, but this is not used for general town business. All these phones ring in the town clerk and selectmen's office, and Town of Hampton Falls is the subscriber. These telephones are used for general town business.
III-3 There are four mobil radios.
The first two are two motorola eight-track four channel 120 watt mobils. Frequency no. 1 is 155.250 (Exeter and
)
Seabrook frequency). Frequency No. 2 is 155.475 state-wide car-to-car frequency. Frequency No. 3 is 154.815 Rockingham County repeater. Frequency No. 4 is 155.415 local towns and Rockingham County.
They are licensed as follows.
The first channel is licensed under the Seabrook/Exeter, second is with the' New Hampshire State Police and the third and fourth are with Rockingham County Sherif f's department.
The third mobil radio is a GE Master Execut Ive II, 8 channel l 100 watt mobil. Frequency no. 1 is 156.090. This is l 1
Carter State Police in Concord. Frequency No. 2 is 155.475 state-wide ear-to-car. Frequency No. 3 is 154.815 Rockingham County repeater. Frequency No. 4 is 155.415 local towns Rockingham County. Frequency No. 5 is 155.250 Exeter/Seabrook frequency. Frequency No. 6 is 154.145 Hampton Fall s fi re depar tment. Frequency No. 7 is 154.190, (
Seacoast fire frequency. Frequency No. 8 is empty. ,
1 Channels 1 and 2 are controlled by the New Hampshire State Police. Channels 3 and 4 by the Rockingham County Sherif f.
Channel No. 5 is Seabrook/Exeter. Channel No. 6 is Hampton Falls fire department. Channel No. 7 is Seacoast fire department at work.
The fourth mobil radio is a GE Phoenix S6 16 channel 100 wa t t mobil . Frequency No.1 is 15 6. 090 car to state police Concord. Frequency No. 2 is 155.475 car-to-car state-wide. These two are controlled by the N.H. State Police.
Frequency No. 3 is 154.185 Rockingham County repeater.
Frequency No. 4 is 155.415 local towns Rockingham County.
Nos. 3 and 4 are controlled by the Rockingham County sheriff's department. Frequency No. 5 is 155.250 Seabrook/Exeter police. Frequency No. 6 is 154.755 Hampton Police and is controlled by the Hampton Police. Frequency No. 7 is 154.145 Hampton Falls fire department and that
- takes in thirty-six towns and is controlled by the Hampton Falls fire depar tment. Frequency No. 8 is 154.190 Seacoast Fire and Exeter. Takes in thirty-six towns and is controlled by the Seacost fire network. Frequency No. 9 is 154.540 Circle Motors business frequency and is controlled by Circle Motors. Frequency No. 10 is 154.515 R.B. Merrill Construction frequency and is controlled by R.B. Merrill. Frequency No. 11 is 155.295 O'Brien's Ambulance frequency and is control 1ed by O'Brien's Ambulance. That will be changed to the Seacoast Ambulance Company in Exeter. Frequencies No. 12 through 16 are not used at this time.
There are three portable radios.
The first portable radio one is Motorola HT 220 4 channel 5 watt. Frequency No. 1 is 154.145 Hampton Falls fire department. Frequency No. 2 i s 155. 7475 car-to-ca r s tat e-wide. Frequency No. 3 is 155.250 Seabrook/Exeter police.
Frequency No. 4 is 155.415 locl towns Rockingham County.
Tne second portable radio is Motorola MT 500 4 channel 5 watt and has the same frequencies as the first portable radio.
The third portable is a Motorola MT 500 6 channel 5 watt.
Frequencies 1-4 are the same as the other two. There is a 5th frequency which is 156.090 car-to-car state-wide.
Frequency No. 6 is 154.515 R. B. Mer r ill Cons t ruc t i on.
Concerning the control and all console locations, Rockingham County has consolo and control locations for some f requencies. They use a voting antenna sys tem. Other frequencies are controlled by the N.H. State Police, the towns on the frequency or the business that they are licensed for. Hampton Falls has no console or control point, and has no antenna for any of the f requencies lis ted.
By using page two and the GE Phoenix radio which includes all frequencies used, the bottom half of that page shows a control and console locations. This includes everything used by the Hampton Falls police department.
III-4 No. Hampton Falls has no control stations, consoles or antennas for their police department. We use the services of other departments or agencies. We also have no license frequencies to the Hampton Falls police department.
The frequencies used are listed as follows:
6.090 N.H. state police in Concord.
155.475 N.H. state police.
154.815 Rockingham County sheriff's department.
155.415 Rockingham County sheriff's department.
155.250 Seabrook police /Exeter ....
154.755 Hampton police department.
154.145 Hampton Falls fire netwerk, 36 towns.
154.190 Seacoast fire network, Exeter, 36 towns.
154.540 Cirice Motors Seabrook.
154.515 R. B. Mer r ill Cons t ruct ion, Hampton Falls.
155.295 O'Brien's Ambulance Service, Beverly, MA. That will be changed to Seacoast.
The Hampton Falls poliecdepar tment is able to communicate with all of the towns in Rockingham County on the following frequencies:
154.815 Rockingham County repeater.
155.475 car-to-car state-wide.
Hampton Falls police department is able to communicate with most all of the police departments in the State of N.H. on 155.475 car-to-car state-wide. This is strictly a car-to-car frequency and is limited to 5 through 10 miles. There are case stations on this frequency throughout the State, but they use this for emergencies only.
III-5 No, Rockingham County sheriff acts as the backup for Town j j of Hampton Falls police. ;
III-6 Yes. The selectmen believe the activation of the public alerting sys tem should be controlled from town hall. The town has no fire chief, but a volunteer.
III-7 The entire Hampton Falls fire department, including the chief, are volunteers.
1 III-8 No. Pursuant t o RSA 107:10, the Board of Selectmen has l responsibility for civil defense in the town, and has I designated this function to the town civil defense director, Roberta Pevear.
III-9 Yes. The offer has not been accepted because of the town vote, and the selectmen's decision, not to implement any radiological emergency plan for the town until approval by the town meeting. No plan has been tended to the town meeting, and none has been approved.
o -
111-10 N/A.
111-11 Yes.
III-12 Please see the NHRERP, local plan for Hampton Falls, which has this information.
III-13 The only selectman who is employed is Kenneth Allen. He is employed at Pease Air Force Base, 430-3120, and his hours vary. Selectman Bill Marston is self-employed as a dairy farmer.
III-14 List of employees.
c '. t c e t u.
l l'
Andrew Ghriity, Jr., Chief 185 Kensington Road Hampton Falls, N.H. 926-7106 tc%c i
Denar' Glover, Deputy Chief 279 Exeter Road Hampton Falls, NH 772-2348 Wayne H. Lord, Lieutenant 21 Prospect St.
Exeter, NH (unlisted #) 778-7272 William D. Nichols Patrolman 51 Crank Road Hampton Falls, NH 926-4671 John H. McEachern 15 Depot Road Hampton Falls, NH 926-3188 Hampton Falls Police Dept. outside employment:
. . p .5 . .
Andrew GhrtTt-y, Chi e f 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week on call the balance of the time.
.'re:M e Dener Glover, Deputy Chief 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week on call the balance of the time.
Wayne H. Lord Berry's Transportation School Bus Company North Hampton, NH 964-8085 060021600 Monday through Friday on call the rest of the time.
William D. Nichols Seabrook Police Department Police Lieutenant Operations Supervisor !
Seabrook, NH 474-2217 i
i
j 0800 - 1800 Monday through Thursday on call balance of the time.
John H. McEachern, III Ber ry's ilus Transpor ta t ion Mechanic 0600 - 1600 Monday through Friday on call balance of the time.
III-15 III-16 Town of Hampton Falls does not have a fire department, it is a volunteer organization and not a town department.
III-17 See III-16 atave.
III-18 No.
III-19 Yes, other than a radiological emergency which would af f ect communit les in addit ion to Town of Hampton Falls. No s teps have been taken, other than as set forth in G-4 above.
III-20 Town of Hampton Falls believes 85 additional emergency people would be necessary. This would include RADEF additional fire and police personnel, and drivers, based upon the 1980 population.
Respectfully submitted, TOWN OF HAMPTON FALLS i
Dated: Wd bi / _3 /f8U By:, d r%h dte ark
/
' S u za nn'e B r e i s e t h , Selectman STATE OF NEW HAMPSHIRE COUNTY OF Then personally appeared the above-named Suzanne Breiseth and acknowledged that the foregoing statements by her subscribed are true and correct to the best of her knowledge and belief. Be f ore me.
1 u
4 Notary Pubtie g Justice of th Peace Commission expires 4/21/87
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