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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] |
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'89 MAR 27 P3 :55 March 24, 1989 ,
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. UNITED STATES DF hAMERICA
\
, NUCLEAR REGULATORY COMMISSION ;
before the ATOMIC SAFETY AND LICENSING BOARD d
) '
In the Matter of. )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL
'NEW HAMPSHIRE, et al. ) 50-444-OL
) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues j
)
) .
l APPLICANTS' VOLUNTARY RESPONSES TO "MA ATTORNEY GENERAL'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS 1 THAT PERTAIN TO EXERCISE ARCA'S."
Applicants voluntarily respond herein to the, informal discovery request of the Attorney General for the Commonwealth of Mass &chusetts (" Mass AG") dated March 10, k 1989. Applicants will produce the documents requested at Seabrook Station during business hours upon reasonable notice to undersigned counsel on the same conditions to which the I
parties have agreed in the past.
Interrogatory No. 1 Please state the name, title / position and business address of the person answering these interrogatories.
8903290145 890324 3 DR ADOCK 0500 pi
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,7 l-x, Aeolicants' Response Applicants' incorporate herein their response to Interrogatory'No. 9. .] !
Interrogatory No. 2
-l Please state any and all steps that have been taken to i date to correct, modify, enhance, or otherwise effect the .i areas requiring corrective action (ARCA'S) noted on pages 207, 226, and 231 of the Exercise Report of the Seabrook Nuclear Power Station prepared by the Federal Emergency Management Agency (FEMA) dated Sept. 1, 1988 ("the Exercise Report").
Aeolicants' Response
- 1. As to the ARCA noted on page 207:
- a. SPMC, IP 2.8, was revised in. Amendment 6 to include instructions to repeat directives to field workers approximately every 30 minutes. SPMC, IP 1.4 was not revised because the Communications Coordinator to whom this procedure pertains monitors radio traffic in the ORO EOC only (unless an equipment problem occurs at the staging area). IP 2.8 contains the directions for those individuals in the Staging Area, the EOC, or the field who are in radio contact with field workers.
- b. The EMS radio at the staging area has been repaired. ,
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c.. .The ranges ~of the 800 mHz'and EMS radio networks are adequate to perform activities in: support of the SPMC from the designated ORO staging area.
- 2. As to'the-ARCA noted on page 226:
- a. Issue #1: The ARCA;concerning instructions for' Bus Drivers and. Route Guides has'been noted in the annual update training module for Route. Guides, EM !
1054.
- b. IssueJ#2: As indicated on page 282 of the same report, NH Yankee committed that the FEMA-identifiediconcerns for incomplete instructions or ,
details on mapa for day care centers and' nurseries.
will be addressed by June, 1989. .These maps are.in-the process of being enhanced to provide clearer and more detailed directions and instructions.for' use by the drivers of the vehicles that would be'
'l assigned to these facilities. The location of each' '
of the day care centers and nurseries is being field-verified to ensure accuracy and the maps on which they appear are being redrawn with improved I
legibility techniques and with features that will assist the driver. This work and the enhanced version of the maps will complete by the June, 1989 commitment.
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- 3. As to-the ARCA noted on page 231, no actions have currently been:taken.
Interrogatory No. 3 Please state any and all steps that have beeniplanned; ;
and/or will be taken in the future to correct, modify, j
- enhance,.or.otherwise effect [ sic]'the.ARCA'S'noted on pages 4 207, 226, and 231 of the Exercisa Report. I r
Aeolicants Response-Applicants object to this Interrogatory insofar as it- i seeks information concerning any and all steps that.will be taken in the future that would affect the'ARCAs identified. I
- The question is. overly broad'in that Applicants may undertake some' action in the' future that they have not yet considered or planned for but which may affect the areas'that received' l ARCAs. Without waiving the foregoing objection, Applicants i respond.as follows concerning. steps that Applicants have planned or that Applicants currently believe will-be taken in the future
- 1. As to the ARCA noted on Page 207:
- a. A revision will be made to~ Annual Update Training Modules, including EM 1020, EM 1038, EM 1039, EM 1043, EM 1045, EM 1054, and EM 1055 to include a discussion of this ARCA and problems that may be encountered by heavy radio traffic. I
- b. Radio systems of new ambulance support companies I
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'. .. . . . h____ _ ___ _.____
R will be reviewed to ensure compatibility with the staging area. radio.
- 2. As to the ARCA noted on page 226: i
- a. . Language for inclusion in SPMC, IP 2.10,. indicating l
that Route Guides and Bus Drivers are to follow l l '
designated routes, has been approved and the procedure will be' revised. 1
- b. See response 2.b to Interrogatory No. 2.
I
- 3. As to the ARCA noted on page 231:
Training for MS-1 hospital. staffs is scheduled.
Interrogatory No. 4 3
i For any and all steps identified in response to Interrogatories l'and/or 2 (sic] [should be 2 and/or 3]
please-state-the dates (s) on which those steps were taken or are expected to be taken.
Anolicants' Resoonse
- 1. As the to ARCA noted on page 207:
- a. The revision to SPMC, IP 2.8 was approved on July 7, 1988 and issued in Amendment 6 of the SPMC. l
- b. The EMS radio was repaired and in service on September 23, 1988. !
- c. Revisions to Lesson Plans EM 1038, EM 1039, EM l 1043, EM 1045, EM 1053, and EM 1054 will be completed on March 31, 1989.
- 2. As to the ARCA noted on page 226:
n..
a-
- a. The proposed revision'to SPMC,.IP 2.10.was' approved on August 18, 1988 and will be issued in the next amendment to the SPMC.. .
b.\ . Lesson Plan EM 1054 was; revised-and approved for.
use'on January 25, 1989.
.c. SeeLresponse 2.b to Interrogatory No. 2.
- 3. As>to the:ARCA noted on page 231:
Training;is scheduled for>MS-1 hospital staffs on June 9, 1989..
Interroaatorv No. 5
-For any and all steps. identified in response.to Interrogatories 1 and/or 2 [ sic] [should be 2 and/or 3]
please stateLthe name(s),and title / position of the persons (s) who' decided to take those steps and the name(s) and-title / position'ofLthe person (s) who has" implemented-or is expected to implement those steps.
ADolicants' ResDonse As to. Interrogatory'No. 2, step:
- 1. a. was' implemented by P. Capone, emergency planning consultant,-approved by M. Hawkins, Manager of
-i' Emergency Planning, and reviewed and approved by the Change Control Team (CCT) which consists of the Director of Emergency Preparedness, Manager of !
l Performances Services, Manager of Response and. !
Implementation, Manager of Resources and Facilities,' Manager of Community Relations, i
~6-
B i<
I Specialty: Training Manager, and Manager of Emergency Planning.
- 1. b. was implemented by G. Catapano,' communications consultant,'and approved by P. Prugnarola, Manager of Computer Services of NHY.
- 2. a. was implemented by R. Thompson, Emergency Preparedness Training Supervisor, and approved by T. Grew, Specialty Training Manager.
- 2. b. The commitment and actions outlined in response to ,
, i Interrogatory No. 2 were recommended by management members of the NH Yankee Emergency Preparedness and the Community Relations Subdivision to its l Executive Director, G.R. Gram, who approved the commitment and the corrective actions. The I
corrective actions are being implemented by a team of NH Yankee and contracted personnel coordinated by J.A. Mcdonald. j As to Interrogatory No. 3, step: j
- 1. a. will be implemented by R. Thompson, Emergency Preparedness Training Supervisor, and approved by T. Grew, Specialty Training Manager.
- 1. b. will be implemented by G. Catapano, communications consultant, and approved by P. Prugnarola, Manager l i
of Computer Services, NHY. )
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- 2. a. was' implemented'hy D..Bovino, Supervisor of' Plans and Procedures, approved by M. Hawkins,-Manager of Emergency Planning, and reviewed,and' approved by l n !
the CCT.: .
- 2. b.- See' response 2.b to Interrogatory _No. 2 above.
'3. willLbe implemented by R.: Thompson, Emergency Preparedness Training Supervisor, and approved by.
T. Grew, Specialty Training Manager, and S.J.1 H
'Ellis, Response and Implementation Manager.
Interrogatory No. 6 For'any and'all steps identified in response to Interrogatories 11and/or 2 [ sic] [should be 2'and/or 3],
please describe in detail the manner in which:those steps have been implemented or will.be implemented.
ADolicants' ResDonse As to Interrogatory No. 2, step:
- 1. 'a. The procedure revision was originated by an emergency planner and approved by the Manager of Emergency Planning and reviewed and approved by the CCT for incorporation into.the SPMC. The revision was incorporated into Amendment 6 of.the SPMC.
l The EMS radio unit was delivered to Edward L.
- 1. b.
Thompson & Son, Inc., Chelmsford, Massachusetts, on August 4, 1988 for repair, and returned to the staging area and placed into service on September 23, 1988.
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- 2. a. LThe implementation of the revisions to the training.
. materials'were done'in accordance with established- .l processes)for: training materials revisions. An assigned instructor in. conjunction with the Emergency Preparedness Training Supervisor produced new materials or revised previously' existing materials to reflect the needed changes as noted in.
Interrogatory 2. . The materials then were sent to
~ designated subject matter experts for review.
After comments from the subject matter experts were
' resolved, the Emergency Preparedness Training Supervisor and the Specialty Training Manager !
reviewed and approved the materials. The revisions were completed prior to training in 1989. The' materials will be used during the 1989 training cycle. This assures that all responders have been trained on the revised materials. l Revision to the training materials for lesson plan '
EM 1020 will reflect emphasis in limiting radio use i I
to essential emergency communications. The j l
materials will be revised in a similar fashion to j the process described above.
- 2. b. See response 2.b to Interrogatory No. 2.
As to the Interrogatory No 3, steps; l
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- 1. . a. See response 2.a above.
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- 1. b. The radio frequencies' utilized by'new ambulance support companies-have been requested and will be reviewed by the NHY communications consultant, ,
G. Catapano, to determine compatibility with the existing system. j
- 2. a.- The procedure ~ revision'was originated by the-Supervisor of Plans and Procedures, approved by1the .
Manager'of Emergency Planning, and reviewed and approved by the CCT for incorporation in the next amendment of the SPMC.
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- 2. b. See response to 2.b toj Interrogatory.No. 2.
- 3. The training sessions for the MS-1 hospitals-are conducted periodically. The specific requirements for the issues stated in the ARCA of page 231 were compared with the content of previous programs.
The content of-the training was. observed to cover the necessary topics. In addition, the training group will provide input to the program to. explain to the participants that training on the biological effects of radiation and the terminology associated l l
with radiation has been identified as an area requiring corrective action.
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l Interroaatorv No. 7 For each and every ARCA noted by FEMA on pages 207, 226 y and 231 on the Exercise RepoIL, please state whether or not the Applicants acknowledges that the ARCA'S reflect inadequacies of performanac in the June, 1988 exercise of the Seabrook Plan for Massachuset.ts Communities.(SPMC).
h2plicants' Resoonse The FEMA Final Exercise Report of the Seabrook Nuclear Power Station, dated September 1, 1988, Appendix A, at page A-3, defines ARCAs as." Demonstrated and observed inadequacies of performance and although their correction is required, they are not considered, by themselves, to adversely impact public health and safety."
Interrocatorv No. 8 For each and every ARCA noted by FEMA on pages 207, 226 and 231 of the Exercise Report, if the Applicants maintain that the ARCA does not adversely impact public~hetith and safety, please state in detail the reasons,for and basis of that belief.
Acolicants' Resoonse Applicants incorporate herein their response to Interrogatory No. 7.
Interrogatory No. 9 Please identify by name(s), title / position and business address any and all individuals who were consulted in, or who otherwise contributed to, the answering to the above interrogatories.
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i Anolicants' Resoonsq
- 1. .D. Tailleart, Manager of Emergency Planning, New Hampshire Yankee - Seabrook Station.-
- 2. D.' Bovino, Supervisor of Plans and. Procedures, New.
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' Hampshire Yankee - Seabrook Station.
- 4. T.. Grew, Specialty Training Manager, New Hampshire i Yankee - Seabrook Station.
- 5. R. Thompson, Emergency Preparedness Training Supervisor, New Hampshire Yankee - Seabrook Station.
- 6. P. Prugnarola, Manager of Computer Services, New Hampshire Yankee - Seabrook Station.
- 7. J.A. MacDonald, Radiological Assessment Manager, New Hampshire Yankee - Seabrook Station.
- 8. G. Catapano, communications consultant, New Hampshire Yankee - Seabrook Station.
- 9. J. Baer, emergency planning consultant, New Hampshire Yankee - Seabrook Station.
Interrogatory No. 10 Please identify any and all documents that were consulted, referred to, or otherwise referenced in answering the above interrogatories by stating the author, date, title, addressee (s) and s.lbject matter of the document.
ADolicants' Resoonse
- 1. FEMA Exercise Report of the Seabrook Nuclear Power Station dated 9/1/88.
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L 2. Lesson Plan EM 1054, " Annual Update for Group 17"-(Route Guides), written by Ronald Thompson, Emergency Preparedness Training Supervisor. This lesson was developed for an audience of Route Guides only. The subject matter reviews the folloeing material with particular emphasis as it relates to Route Guides: FEMA ARCAs, Amendment 6 changes to plans and procedures, pending changes to plans and procedures, and the expected response of ORO members prior to a full power operating license.
- 3. CCT Package #293: Author: P. Capone Date: 7/8/89
Title:
N/A Addresses: N/A
Subject:
Directives to emergency workers.
- 4. CCT Package #316: Author: D. Bovino 1
Date: 8/18/89
Title:
N/A Addresses: N/A
Subject:
Instructions not to deviate from routes by Route Guides and Bus Drivers.
- 5. IP 2.8, SPMC, Amendment 6.
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Egeuest No. 1 Please produce any and all' documents that were identified in answer to Interrogatory #10. !
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'ADolicants' ResDonse <
Applicants will produce the cocuments-identified.in Interrogatory No. 10 that hase'not already,been made f available to the parties.
Recuest No. 2 Please produce any and all documents that reflect, pertain to, or otherwise'were generated or received in connection with any stepr. identified in response to Interrogatories 1 and 2 [ sic] [should be 2 and 3].
ADolicants' ResDonse Applicants will produce the documents. identified in response to interrogatories Nos. 2 and 3 that have not already been made available to the parties.
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. MAR'24.89-15t08
. . . . . . .THY.E-PLAN
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Ted C. Feis p baum Vice-President - Engineering,-Quality ~
Programs and Licensing.
New Hampshire Yankee ~ Diviolon of ,.
Public Service Company of New Hampshire j _'
March 24, 1989 STATE OF NEW HAMP5 HIRE Rcchingham, ss.
Then appeared before me the above subscribed Ted C. Feigenbaum and made
. cath that he is the Vice-President - Engineering Quality P H:w Hampshire Yankee Division of Public service Company of New Hampshirerogr cuthorized to execute the foregoing responses to interrogatories on behalf of ,
the~ Applicants, and that he made inquiry and believes that ng the foregoi answers accurately set forth information as is available to the Applicants. .
Before me, JP>b b tu4 My CommisWion Expires Mac4h 6, 1990 i
1 As to objections and responses to request for production of documents:
/
/
W/W ._ E/E r/ t' b Thomas G. Di George H. Lt. afd Xathryr. A. 8elleck -
% Jr[ ~ A .
Jeffrey P. Trout Jay Bradford 9mith 6ecffrey C. Oook Ropes fr Gray one International Place ,
Boston, MA 02110 (617) 951-7000 Counsel for Applicants
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' M-CERTIFICATE OF SERVICE I, Geoffrey C. Cook, one of the attorneys for the *@ppppc}ptP 3 :55 l herein, hereby certify that on March 24, 1989, I made servLce of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or, where indicatedjyby.
f depositing in the United States mail, first class postade paid,. "
addressed to):
Administrative Judge Ivan W. Smith Administrative Judg6 Peter B.
Chairman, Atomic Safety and Bloch, Chairman, Atomic Licensing Board Safety and Licensing Board 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 Dr. Jerry Harbour 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 Bethesda, MD 20814 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Kenneth A. Administrative Judge Emmoth A.
McCollom Luebke 1107 West Knapp Street 4515 Willard Avenue Stillwater, OK 74075 Chevy Chase, MD 20815 James H. Carpenter, Alternate Robert R. Pierce, Esquire Technical Member Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towerr Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20$14 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Offico of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Comnission 2ast West Towers Building One White Flint North, 15th F1.
4350 East West Highway 11555 Rockville Pike Betheuda, MD 20814 Rockville, MD 20852
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- Atomic' Safety'and Licensing. Robert A. Backus,' Esquire Appeal Board 116 Lowell Street U.S.' Nuclear Regulatory P. O. Box 516'
, Commission. Manchester, }nr '03105 Washington, DC 20555 Philip Ahrens, Esquire Mr. J. P. Nadeau !
Assistant' Attorney General Selectmen's Office j Department,of the Attorney 10 Central Road j General Rye, NH .03870 l 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 (Attn: Herb Boynton) Boston, MA 02110 Mr. Thomas F. Powers e 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
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- ' Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH -03842 . Concord, NH 03301 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 i
Ashod N. Amirian, Esquire Robert Carrigg, Chairman ,
145 South Main: Street Board of Selectmen P.O. Box 38 Town Office, Atlantic Avenue Bradford, MA 01835 North Hampton, NH 03862 Diane Curran, Esquire John P. Arnold, Esquire Andrea C. Ferster, Esquire Attorney General Harmon, Curran & Tousley George Dana Bisbee, Esquire Suite 430 Assistant Attorney General 2001 S Street, N.W. Office of the Attorney General Washington, DC 20009 25 Capitol Street Concord, NH 03301-6397 r- ,/ .
/' ~j Geoffrep 2C k
(*= Ordinary U.S. First Class Mail) i
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