ML20247A712
| ML20247A712 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/24/1989 |
| From: | Fierce A MASSACHUSETTS, COMMONWEALTH OF |
| To: | Chan E, Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| CON-#189-8351 OL, NUDOCS 8903290174 | |
| Download: ML20247A712 (2) | |
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THE COMMONWEALTH OF MASSACHUbibe h
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DEPARTMENT OF THE ATTORNEY GENERAL lj-j-
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JOHN W. McCoRMACK STATE OFFICE BU LDING
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oNE ASHBURToN PLACE, BOSTON 02108 1698
'89 MAR 27 P4 :10 i
-JAMES M SHANNoN AT?OANEv GENE 8%
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ui< A E March 24, 1989
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-1 BY TELEFAX Sherwin Turk and Elaine Chan, Esq.
Nuclear Regulatory Commission one. White Flint North, 15th floor 11555 Rockville Pike Rockville, MD 20852 RE:
Informal Discovery Request Re MAG EX-19
Dear Mr. Turk and Ms. Chan:
In regard to the Mass A.G.'s ongoing informal discovery with respect to MAG EX-19, we request that tne NRC staff provide us with the following additional information:
1.
What action, if any, did the NRC staff take to follow up'on the " Negative Comments" contained in Mr.
Perrotti's memorandum of July 14, 1988, to Edwin Fox?
2.
Since the June 1988 Graded Exercise, has the NRC staff evaluated any SS-ERO drills or exercises which involved or simulated making offsite PAR's?
If so, state when these drills / exercises occurred, what l
NRC1 staffers were present, and how the drill / exercise was conducted, and how (the methodology) the drill / exercise was evaluated, and what that evaluation was.
Please provide all documents in the possession of the NRC staff which refer or pertain to these drills / exercises and/or the NRC's evaluation of the i
SS-ERO's PAR decision-making.
3.
Please advise us of the date when the 1989 NRC observed exercise for the SS-ERO will be conducted.
We are further requesting that the NRC and the Applicants permit us to have one observer present in 9
the EOF to observe the process by which the SS-ERO formulates offsite PARS.
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Mr. Turk and Ms. Chan March 24, 1989 Page Two I also wish to clarify one aspect of our conversation of March 15, 1989, which you seek to memorialize in your letter of March 20:
One way or the other (by deposition or cross at the hearing) I do want to question Mr. Perrotti, and I want the NRC to produce hTm voluntarily.
In the conversation I said that while my schedule was very tight, if the NRC was unable to get the waiver it was seeking to bring Perrotti in for the hearings, ! would. depose him now, before he left the agency, if that was the only way for the NRC to produce him voluntarily.
Perhaps the-NRC can produce him voluntarily at the hearings after he leaves the agency, even if the waiver is not granted.
Whatever the method, I want the NRC to voluntarily produce Mr.
Perrotti for questioning.
I do not want to be forced to subpoena him to appear at the hearings.
Very truly yours, vDL<>
Allan R.
Pierce Assistant Attorney General Nuclear Safety Unit One Ashburton Place Boston, MA 02108 (617) 727-2200 ARF /jms cc: Service List l
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