ML20206C261

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

ML20206C261
Person / Time
Site:	Seabrook
Issue date:	11/04/1988
From:	Flynn H Federal Emergency Management Agency
To:	MASSACHUSETTS, COMMONWEALTH OF
References
CON-#488-7468 OL, NUDOCS 8811160191
Download: ML20206C261 (9)

Text

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Lna:c tELATED P RE, N N  !!ovember 4 1988 ,

'88 N07 -9 P3 :49 -

UNITED STATES OF AMERICA ,;r s y NUCLEAR REGULATORY COMMISSIO!! 00LKt as. ..

I Sk: s l ATCNIC SAFETY AND LICDISI!!G BOARD ,

Before the Administrative Judges:

Ivan W. Smith, Chairnan Gustave A. Linenberger, Jr.

Dr. Jerry liarbour

)

In the Matter of ) Docket flos. 50-443-OL-1

) 50-444-OL-1 PUBLIC SERVICE COMPAirl 0F ) (Offsite Emergency NEW HAMPSilIRF., et al. ) Planning Issues)

)

(Seabrook Station, Units 1 and 2) )

)

RESPONSES OF TIE FEDERAL D4ERGDJCY PRJAGEMDIT AGDJCY TO MASSAC!!USLTTS ATTORNEY GDIERAL'S FIRST REQUEST PCR THE PRODUCTION OF DOCUMDITS To THE FEDERAL DERGDJCY FRJAGEMDTT AGDJCY REGARDING 11E SEABROCK PLAN FOR M QSACllUSETTS COMMUNITIES

1. The Federal Emergency Manageuent Agency (FDG) has withheld as privileged or beyond the proper scope of discovery any reports, surveys, l

ntudies or analyses of legal issues concerning the Seabrook Plan for Massachusetts Comunities (SPE) . To the extent that FDM is in possession of any reports, surveys, studies, or analyses of other issues concerning the i SPN , they are produced herewith, Many of thr2 documents produced pursuant to l this Request and several others are subject to protective orders of the Atomic l

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l l 8811160191 801104 I POR ADOCK 05000443 O PDR O

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1. y Safety and Licensing Board. For this reason, copies of the documents are being furnished only to the Massa ausetts Attorney General (MassAG): Ropes &

Gray, attorneys for the Applicants: NRC Staff Counsel; and Shaines &

McEachern, attorneys for the Town of Amesbury, since the same documents are responsive to an outstanding Request for Production f rom the Town of Amesbury.

2. FEMA has withheld as privileged or beyond the proper scope of discovery documents generated or received by TEMA concerning the adequacy of the SPMC, pursuant to the objections previously stated and the ruling of the Atomic Safety and Licensing Board on November 2. 1988.

3. FEMA produces herewith all documents constituting or reflecting communications between New Hampshire Yankee (NITI) or New Hampshire Yankee Offsite Response Organization (ORO) since January 1,1987, except to the extent that the subject matter is changes to the regulitions and guidance of URC and FEMA which communications are protected under the ruling of the ASLB of November 2, 1988.

4. FEMA has withheld as privileged or beyond the proper scope of discovery documeats constituting or reflecting communications between NRC and FEMA since January 1,1987, on the subjects identified in the MassAG's Request No. 4, pursuant to the objections previously stated and the ruling of the Atomic Safety and Licensing Board on November 2,1989.

5. FEMA has withheld as privileged or beyond the proper scope of discovery documents constituting or reflecting communications between FEMA and other Psderal agencies on the subjects identified in MassAG's Request No. 5, FEMA'c Responses to the Massa 3's First Request for Production, page 2. j

- e pursuant to the objections previously stated and the ruling of the Atomic Safety and Licensing Board on November 2, 1998.

6. FEMA has withheld as privileged or beyond the proper scope of discovery documents constituting or reflewting communications between FEMA and l Argonne National Laboratory and Idaho National Engineering Laboratory on the subjects identified in MassAG's Request No. 6, pursuant to the objections previously stated and the ruling of the Atomic Safety and Licensing Board on Novembe r 2,1988.

l 7. FEMA has withheld as privileged er beyond the proper scope of discovery documents concerning the appointment of Richard Donovan as RAC Chairman for Region I for the revieu of the SPMC, pursuant to the objections previously stated and the ruling of the Atomic Safety and Licensing Paard on November 2, 1988. Nevertheless, Mr. Donovan's resume is produced herewith.

8. There are no minutes or transcripts of RAC meetings where the SPMC was discussed.

9. FEMA has withheld as privileged or beyond the proper scope of discovery documents constituting or reflecting communications between TEMA and the RAC concerning the review of the SPMC. pursuant to the objections previously stated and the ruling of the Atomic Safety and Licensing Board on November 2, 1988.

10. FEMA has withheld as privileged or beyond the proper scope of discovery documents constituting or reflecting communications between TEMA and the Governor of New ilampshire or his office concerning the SFHC, pursuant to the objections previously stated and the ruling of the Atomic Safety and I.icensing Board on November 2.1986.

1 Fr?N s Responses to the MassAG's First Request for Production, page 3. I

_ __ _ __ ___________________________.__a

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i e

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11. FEMA has withheld as privileged or beyond the proper scope of discover / docunents concerning the activities of Richard Donovan since September 1, 1987, pursuant to the objections previously stated and the ruling of the Atomic Safety and Licensing Board on November 2, 1998.

Respectfully submitted,

! - A g_

11. aEPH T .H As stant eneral Coun Federal Emergency Man gement Agency 500 C Street, S.W.

Washington, D.C. 20472 Telephone (703) 646-4102 1

FDW s Responses to the MassAG's First Request for production, page 4.

.' \

s C0(METED NovembeNI,1988 i

'68 NOV -9 P3 :49 i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

c. Ors!7 ',: u -a :..

BEFORETitEATOMICSAFETYANDLICENSINGBOA@dI.((!(*]O'M JUDGE IVAN F. SMITH, CitAIRMAN JUDGE JERRY HARBOUR JUDGE GUSTAVE A. LINENBERGER, JR.

,?

! I

'N In the Matter of- )

)

Public Service Co. of New Hampshire, ) Docket No. 50-442-OL

) 50-444-OL et al. Offsite Emergency

)

(Seabrook Station, Units 1 f. 2) ) Planning Issues

)

I i 1

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Responses cf the Federal Emergency Management Agency to Massachusetts Attorney General's First Request for the Production of Documents to the Federal Deergency Management Agency Regarding the Seabrook Plan for Massachusetts Ceaucunities by depositing Those thea with the U.S. Postal Service on this 7th day of November, 1984.

addressees indicated by an asterisk (*) were also served by Tsderal Expt:-= sn j

l November 4, 1988.

Ivan W. Smith, Esq., Chairman Atomic Safety and Licensing Board Nuclear Regulatory Comunission Bethesda, Maryland 20555 Dr. Jerry Itarbour Administrative Judge Atomic Safety and Licensing Board Nuclear R quiatory Comunission fathesda. Maryland 20555 Gustave A. Linenberger, Jr.

Administrative Judge Atomic Safety and Licensing Board Nuclear Regulatory Correission Bethesda, Maryland 20555

Robert R. Pierce, Esq. ',

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Sucretary Nuclear Regulatory Commission Bethesda, Maryland 20555 Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 205$5 Atomic Safety and Licensing Board Panel U.S. Nt:1 ear Regulatory Commission Washington, D.C. 20555 Thomas G. Dignan, Jr. , Esq.

• Ropes & Gray 225 Franklin Street Boston, MA 02110 l Carol S. Snieder*

Assistant Attorney General Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 Ellyn R. Weiss, Esq.

Ha rmon & Weiss 2001 S Street, N.W. l Suite 430 Washington, D.C. 20009 Robert A. Backus, Esq.

Backus, Heyer & Solomon 116 Lowell Street Manchester, tal 03106 l Matthew T. Brock, Esq.

• Shair.es & Mer.achern Post Office Box 360 Portsmouth, tal 03801 Barbara St. Andre. Esq.

Kopelman & Paige 77 Franklin Street Boston, MA 02110 I

i

. . 3 R. Scott liill-Whilton, Esq.

IAgoulis, Clark,Itill-Whilton l

& McGuire 79 State Street f Newburyport, MA 01950 i Ashod N. Amirian, Esq.

Town Counsel for Merrimac 376 Knin Street Haverhil, MA 08130 i Gary W. 5tolmes, Esq.

Ilolmes & Ellis 47 Winnacunnet Road llampton. 't! 03042 J.P. Nadeau, Esq. i Selectmen's Representative j Board of Selectmen 10 Central Road Rye, N!!03870 Charles P. Graham, Esq.

Murphy and Graham 33 Low Street Newburyport, MA 01950 Richard A. Hampe, Esq.

Itampe and McNichols 35 Pleasant Street Concord, NH 03301 Philip Ahrens Assistant Attorney General Office of the Attorney General State llouse Station, s6 Augusta, ME 04333 Geoffrey Ituntington Assistant Attorney General 25 Capitol Street Concord Nil 03301-6397 Sherwin E. Turk. Esq.*

Office of General Counsel U.S. Nuclear Regulatcry Commission Washington, D.C. 20555 Jane Doughty Seacoast Anti-Pollution League 5 Mr.rket Street Portsmouth,t.H 03801 i

. .s 4

William S. Lord Board of Selectmen Town lla11 - Friend Street Amesbury, PA 01913 Sandra Gavutis, Chairman Board of Selectmen RFD 1, Box 1154 Reute 107 Kensington, fat 03827 Allen Lampert Civil Defense Director Town of Brentwood 20 Franklin Street Exeter,ini 03833 Angie Machicos, Chairman Board of Selectmen 25 High Road Newbury, MA 01950 Jerard A< Croteau, Constable 82 Beach Road P.O. Box 5501 Salisbury, PA 01950 Michael Santosuosso, Chairtran Board of Selectmen South flampton, NH 01913 Calvin A. Canney, City Manager City Hall 126 Daniel Straet Portsmouth, NH 03801 Mr. Robert Carrigg, Chairman Board of Selectmen Town Office Atlantic Avenue North flampton, tal 03862 William Armstrong Ci"il Defense Director Town of Exeter 10 Pront Street Exeter, int 0J833 Mrs. Anne E. Goodman, Chairman Bc,ard of Selectmen 13-15 Newm rket Road Durham. 101 03824

Brentwood Board of Selectroen RFD Dalton Road Brentwooo, N11 03833 Peter S. Matthews Mayor City llall Newburyport, MA 01950 Richard R. Donovan Federal Dnergency Managervent Agency Federal Regional Center 130 228th Street, S.W.

Bothell, Washington 98021-9796 f

Senator Gordon J. !!wrphrey j U.S. Senate 531 liart Senate Office Building Washington, D.C. 20510 Dated: November 7, 1988

.A  :

}!. SEPit[n YNN,k sel As tatanV General nage.nent Agency Federal Leergency

• Served by Federal Fxpress, November 4,1988.

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