ML20246H705

Applicant Supplementary Response to Intervenors Discovery Requests.* Certificate of Svc Encl.Related Correspondence

ML20246H705
Person / Time
Site:	Seabrook
Issue date:	05/05/1989
From:	Cook G, Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	HAMPTON, NH
References
CON-#289-8573 OL, NUDOCS 8905160171
Download: ML20246H705 (6)

Text

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k May 5,C1989E0 m ni C UNITED STATES OF AMERICA 89 mY -8 A11 :36 NUCLEAR REGULATORY COMMISSION O M '..

before the DUCu i <>

ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

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(Seabrook Station, Units 1 and 2) ) (Off-site Emergency

) Planning Issues) '

)

APPLICANTS' SUPPLEMENTARY RESPONSE TO INTERVENERS' DISCOVERY REOUESTS ,

Pursuant to 10 C.F.R. 5 2.740(e), Applicants supplement their responses by amending their answers to the " Town of Hampton ["TOH"] First Set of Interrogatories and Request for the Production of Documents to the Applicants on the June 28-29, 1988 Exercise (" Exercise")" and the Massachusetts Attorney General's [" Mass AG"] request for Documents and Information on the Exercise.

1. Applicants' Supplementary Response to TOH's Informal Discovery Requests of December 23, 1988 on the June 29-29, 1988 Exercise.

Interrogatory No. 2 1

Identify all administrators and school personnel other than teachers who performed or participated in protective actions l for school children during the Exercise. For each, state:

8905160171 DR 890505 ADOCK 05000443 PDR i

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4 (a) The nature and extent of the participation or function performed; (b) The school (s) for which each administrator and school.

personnel performed or participated; ADolicants' Response Applicants' response to Interrogatory No. 2 of January 9, 1989 incorrectly identified George Tucker, Dean of Faculty, Phillips Exeter Academy as a school. official who was

. contacted during the June 28-29, 1988 Exercise. Further review of. player and controller information indicates that Mr. Tucker was not contacted. A telephone call was made to Phillips Exeter Academy by Town of Exeter officials. No 1

administrative representative of Phillips Exeter Academy could be contacted.

2. Applicants' Supplementary Response to Mass AG's Request

-of March 10, 1989 for Documents and Information on the Exercise.

Recuest No. 11 Please describe what set of ETEs were used in the METPAC model during the Exercise and why that set was used.

ADolicants' Response Applicants' response to Request No. 11 of March 24, 1989 incorrectly stated that the ETE values listed on Table 5.2.2 of YAEC Report 1618 were derived from a 1983 ETE study which was litigated as part of the onsite proceedings. The ETE values on Table 5.2.2 were derived from an evacuation time study, dated January, 1984, prepared by Costello, Lamasney and de Napoli, Inc. in association with C. E. Maguire, Inc.

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' As to answers:

Ted C. Feigen)(um Vice President - Engineering Quality Programs and Licensing New Hampshire Yankee Division of Public service Company of New Hampshire May 5, 1989 State of New Hampshire Rockingham County, ss Then personally appeared before me the above-stbscribed Ted C. Feigenbaum and made oath that he is the Vice President

- Engineering Quality Programs and Licensing, New Hampshire Yankee Division, authorized to execute the foregoing supplemental responses to interrogatories on behalf of the Applicants, and that he made inquiry and believes that the foregoing responses accurately set forth information as is available to the Applicants.

Before me, .

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bMy commission' Expires Pdue cwusk*sitoksdism.

w o=a6 ***?7 M As to objections and responses to requests for productie'it :of, documents:

f M Thoma . gnan, Jr.

Geor H. wald Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith Geoffrey C. Cook Ropes & Gray one International Place Boston, MA 02110 (617) 951-7000 COUNSEL FOR APPLICi{f.Tft OcrtMS.FE ,

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CERTIFICATE OF SERVICE 89 MY -8 A11 :36 I, Geoffrey C. Cook, one of the attorneys for the Applicants herein, hereby certify that on May 5, 1989, I made" service of the within document by depositing copies thereof with7 Federal Express, prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):

Administrative Judge Ivan W. Smith Adjudicatory File Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board Board Panel Docket (2 copies)

U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Administrative Judge Richard F. Cole Robert R. Pierce, Esquire Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board East West Towers Building U.S. Nuclear Regulatory 4350 East West Highway Commission e Bethesda, MD 20814 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Kenneth A. Sherwin E. Turk, Esquire McCollom Office of General Counsel 1107 West Knapp Street U.S. Nuclear Regulatory Stillwater, OK 74075 Commission one White Flint North, 15th F1.

11555 Rockville Pike Rockville, MD 20852 John P. Arnold, Esquire Diane Curran, Esquire Attorney General Andrea C. Ferster, Esquire George Dana Bisbee, Esquire Harmon, Curran & Tousley Assistant Attorney General Suite 430 Office of the Attorney General 2001 S Street, N.W.

25 Capitol Street Washington, DC 20009 Concord, NH 03301-6397

• Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board 116 Lowell Street U.S. Nuclear Regulatory P. O. Box 516 Commission Manchester, NH 03105 Washington, DC 20555 l

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Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire John Traficonte, Esquire Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue Department of the Attorney P.O. Box 360 . General Portsmouth, NH 03801 One Ashburton Place, 19th Fl.

Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

• Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton &

Washington, DC 20510 Rotondi (Attn: Tom Burack) 79 State Street Newburyport, MA 01950

• Senator Gordon J. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 507 Kopelman & Paige, P.C.

Concord, NH 03301 77 Franklin Street Boston, MA 02110 (Attn: Herb Boynton)

Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Rohd 35 Pleasant Street Hampton, NH 03842 Concord, NH 03301

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'. l Mr.' Richard R. Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street, 2nd Floor Agency _ Newburyport, MA 01950 Federal Regional Center .]

130.228th Street, S.W.

Bothell, Washington 98021-9796 Ashod N. Amirian, Esquire 145 South Main Street P.O. Box 38 Bradford,'MA 01835 Geoffr g C[ Cook W L.

(*= Ordinary U.S. First Class Mail) i l

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