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 CorrespondenceML20236D500 |
Person / Time |
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Site: |
Seabrook |
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Issue date: |
03/16/1989 |
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From: |
Chan E NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
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To: |
HAMPTON, NH |
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References |
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CON-#189-8321 OL, NUDOCS 8903230131 |
Download: ML20236D500 (14) |
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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
. - - - . - . _ _ _ ..
EEWED CORRESPOffD@JC
-. L ft UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *gg tiAR 20 P4 :05 BEFORETHEATOMICSAFETYANDLICENSINGBOARD(
In the Matter of Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF 50-444 OL NEW HAMPSHIRE, et al. Off-site Emergency Planning (Seabrook Station, Units 1 and 2) .
NRC STAFF'S FURTHER SUPPLEMENTAL RESPONSE TO TOWN OF HAMPTON'S FIRST SET OF INTERR0GATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF ON THE JUNE 28-29, EXERCISE (" EXERCISE")
On March 10, 1989, the NRC Staff supplemented its January 27, 1989 response to the " Town of Hampton's First Set of Interrogatories and Request for the Production of Documents to the NRC Staff on the June 28-29, 1985 Exercise (" Exercise"), filed on December 23, 1988. The enclosed document was inadvertently omitted from that filing althcugh it was part of the Staff Response to Massachusetts Attorney General's Informal Discovery Request on MAG-Ex-19, dated March 9, 1989.
Respectfully submitted, Elaine I. Chan Counsel for NRC Staff Dated at Rockville, Maryland this 16th day of March, 1989 :
8903230131 890316 PDR ADOCK 05000443 0 PDR
DOCKEiED UNITED STATES OF AMERICA r NUCLEAR REGULATORY COPWISSION .
'89 11AR 20 P4 :05 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
(
l.' In the Matter of ) y" ..
Docket Nos.' 50-443 OL~
PUBLIC SERVICE COMPANY OF 50-444 OL NEWHAMPSHIRE,et,al. Off-site Emergency Planning Issues (Seabrook Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S FURTHER SUPPLEMENTAL RESPONSE TO TOWN OF HAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF ON THE JUNE 28-29, 1988 EXERCISE (" EXERCISE")"
in..the above captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, by deposit .in the Nuclear Regulatory Commission's internal mail system, this 16th day of March 1989:
Ivan W. Smith, Chairman (2)* Philip Ahrens, Esq.
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission State House Station Washington, DC 20555 Augusta ME 04333 Richard F. Cole
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Consnission One Ashburton P16ce,19th Floor Washington, DC 20555 Boston, MA 02108 Kenneth A. McCollom* Geoffrey Huntington, Esq. !
Administrative Judge Assistant Attorney General 1107 West Knapp Street Office of the Attorney General Stillwater, OK 74075 25 Capitol Street Concord, NH 03301 James H. Carpenter, Alternate
- Administrative Judge Diane Curran, Esq.
Atomic Safety & Licensing Board Harmon, Curran & Tousley U.S. Nuclear Regulatory Commission 2001 S Street, NW Washington, DC 20555 Suite 430 Washington, DC 20009 Thomas G. Dignan, Jr., Esq.
Robert K. Gad, III Esq. Robert A. Backus Esq.
Ropes & Gray Backus, Meyer & Solomon One International Place 116 Lowell Street Boston, MA 02110-2624 Manchester, NH 03106 l
d
_ _ _ _ _ _ _ - _ _ _ = _ _ _ _ - _ _ _ _ ._-________ ______ ____________ ___ _ _ _ ____ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _-
H. J. Flynn, Esq. Judith H. Mizner, Esq.
Assistant General Counsel 79 State Street Federal Emergency Management Agency Newburyport, MA 01950 i 500 C Street, S.W.
Washington, DC 20472 Robert Carrigg, Chairman Board of Selectmen Paul McEachern, Esq. Town Office Shaines & McEachern Atlantic Avenue 25 Maplewood Avenue North Hampton, NH 03862 P.O. Box 360 Portsmouth, NH 03801 William S. Lord Board of Selectmen Charles P. Graham, Esq. Town Hall - Friend Street McKay, Murphy & Graham Amesbury, MA 01913 100 Main Street Amesbury,'MA 01913 Mrs. Anne E. Goodman, Chairman Board of Selectmen Sandra Gavutis, Chairman 13-15 Newmarket Road Board of Selectmen Durham, NH 03824 RFD #1, Box 1154 Kensington, NH 03827 Kensington, NH 03827 Hon. Gordon J. Humphrey Calvin A. Canney United States Senate City Hall 531 Hart Senate Office Building 126 Daniel Street Washington, DC 20510 Portsmouth, NH 03801 Richard R. Donovan R. Scott Hill-Whilton, Esq. Federal Emergency Management Lagoulis, Clark, Hill-Whilton Agency
& McGuire Federal Regional Center 79 State Street 130 228th Street, S.W.
Newburyport, MA 01950 Bothell, Washington 98021-9796 Allen Lampert Peter J. Matthews, Mayor Civil Defense Director City Hall 1 Town of Brentwood Newburyport, MA 01950 l 20 Franklin ,
Exeter, NH 03833 Michael Santosuosso, Chairman Board of Selectmen William Armstrong South Hampton, NH 03827 Civil Defense Director Town of Exeter Ashod N. Amirian, Esq.
10 Front Street Town Counsel for Merrimac ;
Exeter, NH 03833 145 South Main Street P.O. Box 38 Gary W. Holmes, Esq. Bradford, MA 01835 Holmes & Ellis 47 Winnacunnet Road Barbara J. Saint Andre, Esq.
Hampton, NH 03842 Kopelman and Paige, P.C. .
77 Franklin Street ]
Boston, MA 02110 '
F
'Ms. Suzanne Breiseth J. P. Nadeau Board of Selectmen. Board of Selectmen Town of Hampton Falls 10 Central Street Drinkwater Road Rye, NH 03870 Hampton Falls, NH 03844 1 Atomic Safety and Licensing- !
Robert R. Pierce, Esq.* Board Panel (1)*
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission ,
Washington, DC 20555 Ms. Elizabeth Weinhold 3 Godfrey Avenue Atomic Safety and Licensing Hampton, NH 03842 Appeal Panel (5) i U.S. Nuclear Regulatory Commission i Washington,' DC 20555 1
Docketing and Service Section*
Office of the Secretary '
U.S. Nuclear Regulatory Commission Washington, DC 20555 ,
u' Elaine I. Chan Counsel for NRC Staff 1
1 i
l I
g- .
^
OBattelle Pacific Northwest Laboratories I
{ P.O. Box 999 Richland, Washington U.S.A. 99352 Telephone (509) 375-3782 Teles 15 2874 ,
l t
July 18, 1988 Mr. E. F. Fox, Jr. .
U.S. Nuclear Regulatory Commission Region I 475 Allendale Rd. i King of Prussia, PA 19406
Dear Ed:
SEABROOK EXERCISE, JUNE 28, 1988 EnclosedismyfinalreportasthePacificNorthwestLaboratory(PNL) l partici ant during the subject exercise. Only minor changes have been made to the raft given to you prior to my leaving the site. The area covered was the Technical Support Center.
1 If you have any questions regarding this report, please contact me on FTS (509) 375-3782.
Sincerely, ,
1 J. . Jam son, Project Manager Operational Health Physics Occupational & Environmental Protection Section HEALTH PHYSICS DEPARTMENT JDJ/ chb Enclosure cc: WD Travers, w/ enclosure LC Ruth, w/ enclosure 18 *
(
o } '.* ' s
l l
i SEABROOK EMERGENCY PREPARE 0 NESS EXERCISE l June 28, 1988 A. Name: J. D. Jamison l
B. Assionment: Technical Support Center (TSC)
C. Site Personnel Contacted: J. Rafalowski, TSC HP Coordinator (Red Team);
R. Starrett, TSC HP Coordinator (White Team); A. Merrill, TSC Controller; R. Littman, TSC Controller; D. Moody, Site Emergency Director (SED) (Red Team); W. DiProfio, Site Emergency Director (White Team); G. Kleine, Technical Support Coordinator (Red Team); J. Linville, Chemistry Coordinator (Red Team); and J. Distefano, YNSD Radiological Engineer (RedTeam). ,
D. Positive Findinos e The TSC was manned quickly and efficiently. The SED carefully established plant conditions through discussion with the control room I (CR) staff before declaring the TSC activated and assuming the role of SED.
. The availability of and access to controlled drawings and technical manuals was excellent, e The display of current and past (trended) plant data on status boards ",
was excellent. Key data were promptly displayed in an easy-to-read manner. (However,theradiologicalsurveymapswerenotusedatall.)
e The engineering group actively pursued alternative lineups for .-
f restoration of containment spray throughout the exercise. (However,the l -
quality and workability of some of the proposed lineups was questionable,andnonewasevercarriedthroughtoexecution.)
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. The turnover to the oncoming white team was orderly and complete,
( although quite noisy.
)
. The extended dose authorizations were processed in a careful and considered manner for workers to be involved in the completion of the CBS pump repair.
. The YNSD Radiological engineer correctly pursued critical organ dose calculations for the particulate constituents of the release in order to confirm the adequacy of the protective action recommendations based only on calculated whole body and thyroid doses.
E. Negative Findinas
. Discussion of the emergency action levels in force seemed to indicate a 1
basic misconception of the classification / deescalation process on the {
-I part of many TSC staff. (This was later clarified by the white team SED.)
. The noise level in the TSC was frequently excessive due to many separate discussions going on simultaneously with little discipline or control. .
. With the RCS depressurized and a major release still in progress, the j chemistry coordinator requested (and received) permission to take an RCS 1 sample because technical specifications require a sample every four l hours if dose equivalent iodine-131 is greater than 1 pCi/gm or gross N
coolant activity is greater than 100/E Ci/gm.) ?
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. Radiological controls in the TSC during the period of the large release l were at times ineffective. ,
\
A frisk station was set up inside the main control room door, however a second access door to the control room complex was uncontrbiled.
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- No self-reading dosimeters were issued to the red team members, I even though they were allowed to leave the TSC and depart the site j with a large release in progress while the wind was shifting. !
- The Health Physics Coordinator removed one air sample head and handled the filter cartridge with bare hands, even though some activity had reportedly entered the CR/TSC ventilation envelope.
. No significant effort was directed at locating and sealing the containment leak.
. There was no objective evaluation or discussion of the impossibility of such a huge release following the relatively minor core mechanical damage and thermal transient. (Total release exceeded Chernobyl).
. Effort to find parts to repair the turbine driven EFW pump continued until nearly 1900, even though the EFW system operability ceased to be a consideration in the accident at 1330 when the large break LOCA occurred.
F. Chronology Time Observation 0840 Arrived in TSC. Three controllers present. No evidence of prestaging. -
l 0902 PA announcement- " Evacuate the primary auxiliary building."
0907 PA announcement--Alert declared.
0912 First staff begin arriving in TSC. -
'0925 TSC not activated yet, coordinator briefs team on status.
0928 HP Coordinator has HP 41C set up for dose calculations.
0933 SED in TSC, gives briefing on plant status.
~
0935 Don Ho'ody ready to assume as SED. ,,
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Time Observation f 0946 Moody declares TSC operational, assumes role of SED.
1002 Maintenance staff reviewing drawings to determine importance of the AFW pipe support work.
1004 SED directs HP Coordinator to look at potential PARS if a leak develops. HP Coordinator goes to FSAR for accident source term.
information.
1010 EOF declared operational.
1020 HP Coordinator and Radiological Engineer locate the analysis for small line break outside containment and scale up the results for the difference in coolant activity.
1047 SED conducts briefing on plant status. HP Coordinator developing PARS for small line break with current RCS activity. Good
,, consideration of potential for AFW line break if AFW initiated with pipe support missing. TSC recommends valving off the affected line until repair complete. ,
1100 HP Coordinator reviews dose projection and PAR with SED.
1119 Habitability check with R0-2, ch'eck of SRDs.
1127 Based on RCS activity, 0.007% of I&NG are in the coolant. '
1130 s,, Trip valve for steam driver EFW pump just went shut. Pipe support team directed to investigate.
1136 Report on EFW system damage.
1146 Escalating to SAE based on damage to EFW system, EAL 18C, 2.
1149 Engineers recommend running motor-driven EFW pump to verify operability. l 1149 PA announcement, Alarm for SAE. '
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Time Observation j
! 1156' Report on EFW damage, briefing by SED.
1215 Discussing alternate cooldown modes, cross connect from diesel fire pump to EFW.
1224 Status update: beaches have been closed. Fire hoses rated at 600 psi have been found for possible cross-connects. Power still trending down, even though controller supposedly stopped the power reduction (Xenon buildup is doing it).
1245 Good status board configuration--good attention to maintenance of boards.
1247 Letdown monitor jumped to 865 pCi/cc.
1309 Results of 1220 RCS sample: Gross activity = 720 pCi/cc; DEI-131
= 70.8 pCi/cc.
1315 Letdown monitor up to 1000 pCi/cc.
1328 Reactor trip, safety injection. Containment high range rad =
2.7E+4R/hr.
1332 General Emergency on " post LOCA reactor trip" (8.d) pressure in containment = 47 psi. Containment spray pump B fails to start.
1340 Good analysis and recommendations regarding the containment spray '
- s. pump.
o 1344 Projected site boundary dose rates (based on CHRRMS and design leak rate) is ~1.5 mr/hr.
1345 WRGMS alarm, reading 4.13E+8 pCi/cc.
1348 Chemistry Director suggests sending the team now preparing for containment gas sample to get a WRGMS sample instead - good thinking.
5 .}.5- :- - .
- l. .
1 Time Observation
( 1350 Engineering has devised a flow path from RHR to CBS. However, it won't work because of location of RHR suction from the RWST. Now working on another path using HPSI pumps.
1404 WRGMS now greater than 109 pCi/sec.
1409 METPAC projection for 1345 release rate is 208 mr/hr WB and 216 mr/hr infant thyroid at 0.6 mi.
1428 Status briefing by SED. Now in cold leg ' recirculation.
1430 Relief crew is being held at EOF pending survey of site access road. Survey requested from OSC.
1442 Technical Support Coordinator directs survey team be expedited out of OSC to survey site access road.
1447 Briefing by ESD on team relief procedure.
1457 Survey of access road complete. Results of 1423 WRGMS sample received. Projection is ~4 R/hr at 2 miles. Lots of particulate and iodine in the release, characterized as " messy" (also very bio i
-- ~30 million Ci) nobody comments on it! Amazing.
1516 Ready to start CBS "B" pump. No success.
1517 Swap breakers on CBS "A" and "B". ~
1522 s,, Relief crew bus is on its way in.
1524 No dosimeters have been issued to TSC staff; HP Coordinator made first habitability survey since 1355, just after release began.
1536 Relief crew coming in.
1538 Relief begins - lots of noise. Most oncoming staff don't have SRDs. Plant survey maps that are posted as status boards were e
i
_______.____ ___________m__... _ _ _ . _ _ _ _ _ _ _ _
Time Observation
( never marked with dose rates etc., as reported by OSC teams or ARM readings.
1602 NRC resident (evaluator) raises concern over quality of licensee's evaluation of the engineering support team and their ideas for
" fixes".
1614 Relief complete - red team directed to assemble outside TSC and take TLDs and dosimeters to EOF. Most, if not all, red team members don't have dosimeters.
1633 Briefing by SED. Simulator and OSC have completed relief.
1638 CBSpump9Brepairedandoperating(controlleraction). Simulator asks permission to start it. Some confusion. Work on the alternate lineup is stopped.
1646 Habitability survey by HP Coordinator. Now processing dose extensions for team to go in and finish repair to CBS pump 9A.
1708 SED briefs TSC team. Containment level still dropping slowly, don't know where its going. Review of PARS now in effect, changes in wind direction likely.
1715 CBS pump 9A repaired and operating (controller action). -
1719 Controller says containment sump not really dropping. Simulator artifact.
1726 SED briefing -- cooling down containment with CBS, WRGMS readings coming down. SED says "have deescalated" on the 8d (containment radiation) EAL to 8c (Site Area Emergency) however, still in GE because calculated dose rate at site boundary is 100 mr/hr.
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_ _ _ _ _ __. ______________________ ____-____- _~
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l Time Observation 1730 Chemistry Coordinator wants to take RCS sample because technical l
. specifications say take one every 4 hrs when DEI-131 >1 pCi/gm or gross activity >199/E pCi/gm. Do these requirements really apply to post accident conditions?
1740 Discussion between SED and Emergency Operations Manager on reasons for blowing down the steam generators (to reduce containment heat load). .
~
[ 1753 Radiological Engineer trying to ' determine if the particulate in
! the effluent are a significant contributor to offsite dose. Could 9
j bet Doesn't their program include these nuclides? METPAC does.
I 1755 SED briefing.
1802 Increase in CR air particulate and dose rates at guard station.
Very noisy! '
1825 Briefing by SED.
1834 Briefing by SED, containment pressure coming down slowly, more
)
slowly than it should. YNSD is asked to work on the question..
f Still talking about declassifying when site boundary dose rate !
l '
comes down.
1842 5,,HP Coordinator changes out air sampler cartridge with bare hands.
1848 EOF calculates SB dose rate ~560 mr/hr.
1850 Forecast is for rain -- Chemistry Coordinator wants to send a team out to " raise the weir" to keep any deposited activity from being flushed into the river. HP Coordinator questions the order to sendamantothewarehouse#3(whichisdirectlyinlinewiththe plume)~ to get the parts for the turbine driven EFW pump. SED sa'ys ,
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f Time Observation (correctly) that the EFW pump isn't that important now. (No g capabilitytocirculatecoolant.)
9
[ 1900 Exercise is suspended.
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