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 CorrespondenceML20205R654 |
Person / Time |
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Site: |
Seabrook ![NextEra Energy icon.png](/w/images/9/9b/NextEra_Energy_icon.png) |
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Issue date: |
11/02/1988 |
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From: |
Lord W AMESBURY, MA |
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To: |
PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
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References |
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CON-#488-7420 OL, NUDOCS 8811100087 |
Download: ML20205R654 (11) |
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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
_ _ _ _ _ _ _ _ _ _
']43d EELATED CORREscor<ocN,c3 DOCKETED v%c UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION TS RT/ -3 P12:18 Before the
,; r r ATOMIC SAFETY AND LICENSING BOARD .
) Novceber 2, 1988 In the Matter of )
) Docket Nos. 50-443-OL PUBLIC SERVICE COMPANY OF ) 50-444-OL NEW HAMPSHIRE, et al, )
) Off-Site Emergency (Scabrook Station, Units 1 and 2) ) Planning
)
TOWN OF AMESBURY RESPONSE TO APPLICANTS' SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO ALL INTEP.VENORS AND PARTICIPATING LOCAL GOVERNMENT 3 CONCERNING JOINT INTERVENOR CONTENTIONS NOW COMES the Town of Amesbury and hereby responds to APPLICANTS' SECOND REQUEST FOR PRODUCTION OF DOCUMENTE TO ALL INTERVENORS AND PARTICIPATING LOCAL GOVERNMENTS CONCERNING JOINT INTERVENOR CONTENTIONS, dated October 14, 1988, as follows:
- 1. Any and all documents reflecting administrative and/or executive orders regarding emergency planning and/or radiological emergency response planning.
RESPONSE
TOA has no information responsive to this request except TOA Board minutes of 11/18/85 and Town Meeting Article and Action of 11/18/85. See attached.1 1
Copies of these documents are being served upon the NRC Staff.
8911100007 801102 DR ADOCK 050 43
t
- 2. Any and all documents reflecting or commenting on draft f
and/or final policies of the Department of Public Safety, and the Massachusetts civil Defense Agency and/or the Department of Public ;
t Health regarding emergency planning and/or radiological emergency j response planning. j RESPONSE ,
TOA has no information responsivo to this request.
F
- 3. Any and all documents reflecting or comment on emergency 1 plans, policies, guidance or implementing procedures developed by any ;
state agency, department, commission or authority.
RESPON8E
) DA has no information responsive to this request. [
i l Respectful submitted,
(
< Dated: November 2, 1988 , _- .
! William Lord N STATE OF NEW HAMPSHIRE ROCKINGHAM, FS.
Personally appeared the above-named William Lord and swore to the ttuth of the foregoing statements based upon personal i knowledge, information or belief.
Before me,
. CtA
).
N 'ary Publ'ic/p u stM o f 't h e Pen?e I
J ANU M. LeTARTE. !!:t:5/ MD My Commissi : E* Fit:5**=iYIs199I 2
2
6 r
ANNL"AL REPQR.T of the Town of Amesbury .
~
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1 g w.
e For the Year Ending December 31 i
o 1985 ~
a b
WARRAN7 TOR SPECIA1, TOWN HECTINO ,
NOVEMBrR 16, 1985 Essex, ss.
To either of the Constables of the Town of Amesbury .
Greetingt f
I In the name of the Conenonwealth of Massachusetts you are hereby directed to notify !
and warn the Town Meeting Herbers qualified to vote in Town affairs to meet at the Town ,
Hall on Honday, November 18, 1985 at 7:30 P.M. then and there to act on the following articles j Article 1. To see if the Town will vote to adopt the following resolutiont f Resolution: Whereast There could be a major release of radiation from Seabrook Station !
in as little as one-half hour (ref. NUREC 0654 P. 13): kHEREAS This radiation could reach l Amesbury, Hassachusetts in less than an hour from the time of release (ref. NUREC. 0654, P.17); [
kHEREAS: It would require approximately 1,000 civilian residents of Amesbury to remain behind !
in a contaminated zone to conduct an evacuations kHEREAS : That in the event of a worst case l
-accident at Seabrook Station, it would be impossible to evacuate safely the entire population l c
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of the Town of Amesbury: THERETORE, BE IT RESOLVED: that the Townbe cannot of Amesbury successful;not and par that
- .icipate in the establishment of an evacuation plan thatthe Town of Amesbu exercine, drills or training for a radiological response to Seabrook Station; and that ths Town of Amesbury, through the Board of Selectmen, BE IT TURTHER RISOLVED:
request that the Governor and the Attorney General of the Conmonwealth of Massachusetts investigate the existing plans and procedures to determine if the safety of the citizens of the Commonwealth is being adequately protected.
Article 2. To see if the Town will adopt an amendment to the Personnel By-Law to be inserted as Art. 5 Flexible Tiee Schedules. A limited flexible tirea.option will be a 35-hour, available to clerical employees subject to the following restrictions:
Hours scheduled must be between 7:00 AM and 5:00 TH, 5 day week shall be worked, b.
- c. a 7-hour day must be worked at all times, d. work hours will be scheduled quarterly,
- 3. all offices will be opened for business from 8:00 AM to 4:00 TH, f. a minimum of 1 clerical employee will be on duty from 8:00 AM to 4:00 PM, g. flexible time schedules must be approved by both the Departeent Head and the Town Kanager.
Article 3. To see if the Town will vote to amend Article VII of the Town Bylaws (Tinance Committee), Section 1 by adding the following To establish the tern of a Finance Committee member who is defeated or is not a candidate for re-election at the Annual Town Election as expiring at the adjournment of the Annual Town Meeting held in hay following said election.
Article 4. To see if the Town will vote to raise and appropriate or take f rom available f unds the sum of $60,000 (Sixty Thousand Dollars) to rehabilitate two or more rettrooms li the old section of the Middle School, or take any other action relative thereto.
Article 5. To see if the Town will vote to transfer the sum of $3$,000 (Thirty-Tive Thousand Ic11ars) f rom the Solid Waste Fund to the Wastewater Treatment Plant Budget
- Part 11 for the removal of sludge, grit and other substances.
Article 6. To see if the Town will vote to take from available funds the sum of Three Thousand Seven Hundred Tifty. Dollars ($3,750.00) to purchase and equip the 1972 Civil Defense Chevrolet Van. Equipment to be purchased includes three (3) mobile radios, one (
4,000 watt general and materials to build consols and cabinets for radios and related equipment or take any other action relative thereto. ;
)
i Article 7. To see if the Town will vote to take f rom available funds the sum of Ten Thousand Dollars ($10,000) to be used by the local Civil Def ense Agency to purchase equipment and renovate existing operating f acilities at the Rings Corner Pumping Station a
or another suitable location de-ided by the Town Kanager, Board of Selectmen, and Directo of Civil Def ense. Equipment replacement includes radio networks and install telephone lines and related equipment, or take any other action relative thereto.
Article 8.
To see if the Town will vote to restore the sum of $10,000.00 (Ten Thousand Dollars) to the Police Budget to fund the third officer position on the late night shift.
Article 9. ko see if the lovn will vote to raise and appropriate the sum of $100.00 (One Hundred rollars) in payment of a Board of Health bill for the previous fiscal year.
i Arcicle 10. To amend the Amesbury Loning Bylaw, Section XI-H, Paragraph 14A, by adding the words "in existing buildings only" af ter the word "apartments".
l
- Article 11. To see if the Town will vote to raine and appropriate or take f rom availat f unds the sum of $24,000.00 (Twenty-Four Thousand Dollars) to construct sidewalks on Fortsmouth Road from Elm Street to honroe Street, a distance of approximately 2,640 feet-l 4d.
l
70VN MEETING j November 18, 1985 ,
The Moderator called the meeting to order at 7:34 P.M. and declared a quorum present (98 Town Meeting Hembers) f Josephine A. Jacques, Town Clerk, read the call of the meeting.
Tellers appointed were Teresa Axten, Barbara Moore, Donald Leeman and James Woodson. [
As there were no objections, the following were allowed to remain in the hall Ed Davis, [
Jason Cohen, Stephen Hallet, Frank Horacek, Greg Rehune. David Schwaf, Cheryl March, Bob I White, Stephen Gerber, Bruce McCarthy, Bill Cleed, Jerry Schuster, Peter Droese, Don Hambidge Fred Anlerson, Dan Edson, Raymond Julien, Barry Sukagian, Lee Bailey, John Quinn, James Cowell, Heal Boucher, Chuck Lord, Jennifer Haydock, Byron & Jason tugrane, Caitlin i McCarthy and members of the press.
k The Moderator temporarily turned over the chair to the Town Clerk, in order to speak +
on Article fl.
The following corrections were made Article #6 - word general changed to generator.
ARTICLE 1. RESPor*E PLAN.
Finance Committee .ecommends adoption.
Planning Board recommends adoption.
i Motion by Edward Anderson, seconded by George Hotsis the re".aumendation of the Tinance Committee.
>t ,lon by Jeremiah Kukene, seconded by Alfred Hotsie for Indefinite Postponement.
Not Voted. YES 41 No 51
'- ~~ Motion for adoption VOTED.- YES 53 No 40 ARTICLE 2. PERTONNEL B.LAW Tinance Committee recommends adoption. .
Motion by Edward Anderson, seconded by James Thivierge to see if the Town will adopt an amendment to the Personnel Bylaw to be inserted as Art. 5-12 Tlexible Time Schedules. A limited flexible time option will be avat ible to clerical employees subject to the following restrictions: (a) a 35-hour, 5 day week all be worked (b) hours scheduled must be between 7:00 AM 'and 5:00 PM, (c) a 7-hour work' day must be worked at all times (d) a 1-hour lunch period will be taken between 11:00 AM and 2:00 PM, (3) work hours will be scheduled quarterly, (f) all offices will be open during normal business hours including lunch periods, (g) a minimum of I clerical employee will be on duty in each depart =pnt during normal business hours,(h) flexible time schedules must be approved by both the Department Head and the Town Hanager.
VOTED.
ARTICLE 3. TINANCE COMMITTEE MDGERS.
Finance Convaittee recessmends adoption.
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Selectmen's Meeting November 18, 1985 l Miss Cashman opened tne meeting. Mr. Motsis, Mr. Thivierge, and Mr. Gonthier ;
were present.
Miss Cashman accepted the minutes of Nov. 4th and Nov. 13th as submitted.
Under correspondence Miss Cashman read an invitation to attend a retirement party for certain call and regular firefighters on Nov. 21st, 6:00 p.m.
! at Sailor BL11's. Mr. Motsis and Mr. Thivierge will attend. l 4
Letter from Barbara Keefe in support of raises for the Policemen. Letter from James McConnell supporting a no vote on Art. 1. Letter from Bob Wallack, 4'
Pres. of the ABA, stating that Association's objections to any work being ,
done on the Friend St. parking . lot until the Spring of 1986.
William Richards infomed the Board that the transfer of his liquor license to W.llowdale Restaurant w!!! not take place and the license will remain in his name.
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James Connor, Exec. Director, Amesbury Housing Auth, requested that f.he two Boards seet and also that the Selectmen tour its facilities. T.1e
- Board will discuss this letter at its Wednesday workshop. ,
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Fr. Berube, on behalf of the Council on Churches, requested that the Board designate Thanksgiving Eve, Nov. 27th, as a time for renewal of community spirit and cooperation. A personal invitation to the inter-faith service is forthcoming.
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Letter from the Governor's Office of Community Services requesting it be notified of any special events to take placi in Amesbury in honor of Martin Luther King's birthday. -- -
2.
Petition from Senior Citizens to make more parking available around the.. _ l Center. Miss Fallon requested to re-open negotiations with the Matti St. !
Congregational Church to use a portion of its parking area which abuts j the Town's parking lot. t
' Mr. Ocnthier would like tc' Board to express its opposition to the following i bills: H6751; S412; H6319 and 52486. He feels these bills are trying to i i undermine. Prop. 25. The Board agreed to discuss this Wednesday evening so tnat <
! all members have a chance to read the informationin the BEACON. Mr. Motsis Mr. Motsis opened a hearing on the request to remove a tree by Helen Leonard through the DPW, Mrs. Leonard was present and explained ti.st the tree roots cause a lot of problems with her sewer lines and it is becoming costly.
There was no opposition to the removal of this tree. Mr. Gonthier voted to re-move the tree and Mr. Thivierge second. Unanimous vote. The DPW will be re-quested to remove the tree as soon as possible.
l The Board reviewed the list of license renewals. Mics Casnman moved to approve.the license renewals as submitted and which will be attached to these j minutes. Mr. Gonthier second and the vote was unanimous.
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" Mr. Santtrier noted , hat the Town Manager had requested in her report that the Selecimen make a decision concerning Alton Stone's building per.att for l
the Grace Baptist Reform Church. Mr. Gonthier moved to waive the fee for Alton 1
Stone's building permit and Mr. Thivierge second. Unanimous. It was noted
. that trie Inspection Dept. fee schedule should be revised.
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Selectmen's Meeting NovemDerif, 1985 2
Henry Fournier spoke tc the Board briefly about Art.18 which is a proposed zonin; change he noted the enange would effect only 10 lots in the R-S district. Mr.
Gonthier moved to Recomend Adoption of this article and Mr. Thivierge second.
Unanimous vote. The Board recessed to attend Town Meeting.
Mr. Motsis re-opened the meeting at 9:34 p.m. Mr. Lord was present.
Mr. Lord moved that the Selectmen adopt as policy and implement A-1. I of the Nov.
18, 1985, Town Meeting. Mr. Thivierge second. Mr. Lord said the Board should consider the article as binding, as should all Town employees. ine Town should not participate in drills, nor expend funds as part of planning for evacuation. The Town will request the Governor and Att. General to investigate ex: sting plans and procedures to determine if the safety of the citizens of tne Stata is being ade-quately protected. Unanimous vote.
Motion made and seconded to adjourn. All in favor and the meet!n; adjourned at 9:50 p.m.
Respectfully submitted, Donna L. Stuart Admin. Assistant
'E8 NW -3 R2:18 CERTIFICATE OF SERVICE if R L :. - :.a I, Matthew T. Brock, one of the attorneys ioY/dtNe1 Todn of Amesbury herein, hereby certify that on November 2, 1988, I made '
service of the foregoing document, TOWN OF AMESBURY RESPONSE TO t l
APPLICANTS' SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO ALL INTERVENORS AND PARTICIPATl.NG LOCAL GOVERNMENTS CONCERNING JOINT :
INTERVENOR- CONTENTIONS by depositing copies thereof in the United i States Mail, first class postage prepaid for delivery (or, where indicated, by Express Mail, prepaid) addressed tot
- Ivan Smith, Esq., Chairman *Dr. Jerry Harbour Atomic Safety & Licensing Board Atomic Safety & Licensing Board (Off-site) (Off-site)
U.S. Nuclear Regulatory Commission U.S. Nuclear Reg'llatory Comm.
East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814
- Judge Gustave. A. Linenberger, Jr.
- Atomic Safety & Licensing Atomic Safety & Licensing Board Appeal Board Panel (Off-Site) U.S. Nuclear Regulatory Comm.
Washington, DC U.S. Nuclear Regulatory Commission 20555 East West Towers Building j 4350 East West Highway
Bethesda, MD 20814 George H. Lewald, Esq.
Kathryn A. Selleck, Esq.
- Adjudicatory File Ropes & Gray 7.tomic Safety & Licensing Board. 225 Frankin Street i Panel Docket (2 copies) Boston, MA 02110 j
U.S. Nuclear Regulatory Commission East West Towers Building
a
) 4350 East West Highway Stephen H. Oleskey, Esq.
i Bethesda, MD 20814 Allan R. Pierce, Esq.
. Department of the Atty. General
- Stephen E. Merrill, Esq. One Ashburton Place George Dana Bisbee, Esq. Boston, MA 02108 office of the Attorney General i State House Annex
I Concord, NH 03301 Andrea C. Ferster, Esq.
- Harnon, Curran & Tousley
- Sherwin E. Turk, Esq. 2001 S Street, N.W., Suite 430
- Office of General Counsel Washington, DC 20009-1125 i U.S. Nuclear Regulatory Commission l 15th Floor - One White Flint North
- Richard R. Donovan 11555 Rockville Pike Federal Emergency Mgmt. Agency
' Rockville, MD 20852 Federal Regional Center 130 228th Street, S.W.
Bothell, Washington' 98021-9796-
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O Philip Ahrens, Esq. Robert A. Backus, Esq.
Assistant Attorney General Backus, Meyer & Solomon Office of the Attorney General ill Lowell Street State House, Station 6 Manchester, NH 03105 Augusta, ME 04333 Jane Doughty Richard A. Hampe, Esq.
Seacoast Anti-Pollution League Hampe and McNicholas 5 Market Street 35 Pleasant Street Portsmouth, NH 03801 Concord, NH 03301 William S. Lord, Chairman Charles P. Grahan, Esq.
Board of Selectman Murphy & Graham Town of Amesbury 33 Low Street Town Hall, Friend Street Newburyport, MA 01950 Amesbury MA 01913 R. Scott Hill-Whilton H. Joseph Flynn, Esq.
Lagoulis, Clark, Hill-Whilton Office of General Counsel
& McGuire Federal Emergency Mgnt. Agency 79 State Street 500 C Street, S.W.
Newburyport, MA 01950 Washington, DC 20472 Ashod N. Amirian, Esquire . . _ _ Judith H. Mizner, Esq. _
376 Main Street 79 State Street Haverhill, MA 01830 2nd Floor Newburyport, MA 01950 Senator Gordon J. Humphrey Senator Gordon J. Humphrey U.S. Senate One Eagle Square, Suite 507 Washington, DC 20510 -
Concord, NH 03301 (Attn: Tom Burack) (Attn: Herb Boynton)
Leonard Kopelman, Esquire ~
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Barbara J. Saint Andre, Esquire Atomic Safety & Licensing Board Itopelman & Paige, P.C. Panel 77 Franklin Street U.S. Nuclear Regulatory Comm.
Boston, MA 02110 East West Towers Building 4350 East West Highway Bethesda, MD 20814 2
i John H. Frye, III James H. Carpenter ,
Alternate Chairman Alternate Technical Member Atomic Safety & Licensing Atomic Cafety & Licensing l Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.
Washington, DC 20555 Washington, DC 20555 -
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