ML20248F853

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

ML20248F853
Person / Time
Site:	Seabrook
Issue date:	04/03/1989
From:	Cook G, George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	MASSACHUSETTS, COMMONWEALTH OF
References
CON-#289-8413 OL, NUDOCS 8904130226
Download: ML20248F853 (10)

Text

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EELATED CORRES,PO..N.DENC$

9y39 U%HC April 3, 1989

'89 APR -7 P4 :16 p .e UNITED STATES OF AMERICA W '

NUCLEAR REGULATORY COMMISSION-before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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PUBLIC SERVICE. COMPANY OF ) Docket Nos. 50-433-OL NEW HAMPSHIRE ) 50-444-OL

) Off-site Emergency.

(Seabrook Station, Units 1 and 2) ) Planning Issues

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l APPLICANTS' VOLUNTARY RESPONSES TO "MA ATTORNEY GENERAL'S INTERROGATORIES ON THE USE OF BED BUSES AND THE SPMC" Applicants voluntarily respond'herein to the informal discovery request of the Attorney Gr 1eral for the Commonwealth of Massachusetts (" Mass AG") dated March 20, 1989.

Interrogatory No. 1 Please state the name, title / position and business -

address of the person answering these interrogatories.

Acolicants' Response

1. a) Robert Boyd, Jr.;

b) Emergency Preparedness Performance Services Manager, New Hampshire Yankee;

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c) Seabrook Station, P. O. Box 300, Seabrook, NH 03874.

2. a) Michael R. Lewis; i

b) Emergency Preparedness Resource Supervisor, New Hampshire Yankee; c) Seabrook Station, P. O. Box 300, Seabrook, NH 03874.

3. a) John B. Hart; b) Emergency Preparedness Licensing, New Hampshire Yankee; c) Seabrook Station, P. O. Box 300, Seabrook,NH 03874.

Interrocatorv No. 2 Please state the names of, business addresses of, business phone numbers of,and contact persons at any and all bus companies that submitted proposals in response to New Hampshire Yankee's invitation to submit proposals for the furnishing of 35 evacuation bed buses.

Aeolicants' Response Applicants object to this interrogatory on the ground that the information it seeks, concerning proposals for the provision of contractual services that have not been accepted, is irrelevant to the admitted contentions. In accordance with New Hampshire Yankee procedures, quotations submitted by bidders contain confidential information and shall be maintained as confidential by New Hampshire Yankee.

Disclosure of the terms of any bid before a particular bid is

i finally accepted would be disruptive and would undermine the confidentiality of the ongoing process of soliciting contractual services.

Interrogatory No. 3 For each and every proposal submitted to New Hampshire i

Yankee in response to the invitation to submit proposals for the furnishing of 35 bed buses, please describe the terms and elements of the proposal including but not limited to:

a. the name of the company submitting the proposal;

b. the price quoted for both purchase and lease options;

c. the number of buses to be furnished by the bus company under the proposal;

d. the number of bus drivers to be furnished by the bus company under the proposal;

e. the names, home addresses and phone numbers of any bus drivers who have signed up to be bus drivers;

f. how many of the buses are new;

g. for each used bus offered under a proposal, please state:

(1) its remaining useful and economic life; (2) its book value; (3) its year, make and mode; (4) its mileage; (5) its mileage and/or hours on its current engine; (6) whether it is registered as a bus / motor bus or school bus; (7) its registration number, 1

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I Aeolicants' Response Applicants incorporate herein their objection to l

Interrogatory No. 2. I Interrogatory No. 4 If New Hampshire Yankee has decided to accept one or more of the proposals, please identify each proposal by furnishing the name of the bus company and whether the proposal is the sale or lease option.

Aeolicants' Resoonne Applicants have not decided.

Interroaatorv No. 5 If New Hampshire Yankee has decided to reject one or more of the proposals, please identify each proposal by furnishing the name of the bus company and whether the proposal is the sale or lease option.

Aeolicants' Response Applicants incorporate herein their objection to Interrogatory No. 2. Any proposals that have been rejected or that may be rejected by the Applicants are not relevant to the admitted contentions.

Interroaatorv No. 6 If New Hampshire Yankee is still considering one or more of the proposals, please identify the proposals by furnishing the name of the bus company and whether the proposal is the sale or lease option.

Aeolicants' Response Applicants incorporate herein their objection to Interrogatory No. 2.

Interrogatory No. 7

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Please state the names and business addresses of the insurance carriers and insurance agents of any and all bus companies whose proposals have been accepted or are still being contemplated by New Hampshire Yankee.

Aeolicants' Resconse  !

Insofar as this Interrogatory asks for.information i concerning proposals that are "still being contemplated", (

Applicants incorporate herein their objection to Interrogatory No. 2. Without waiving the foregoing objection, Applicants respond as follows: See response to l

Interrogatory No. 4.

Interrogatory No. 8 Since the receipt of the bed bus proposals described in response to Interrogatory No. 2, has New Hampshire Yankee decided to, or is New Hampshire Yankee contemplating, implementing bed buses in the SPMC in any way other than contained in the Evacuation Bed Bus Bid Specification attached as Exhibit A?

Aeolicants' Response No. At this time, New Hampshire Yankee has not evaluated -

any other way for " implementing bed buses in the SPMC." New Hampshire Yankee will evaluate the proposals as well as other alternatives for implementation of the plan to use evacuation bed buses.

Interroaatorv No. 9 l

If the answer to Interrogatory No. 8 is in the affirmative, please describe the way(s) that New Hampshire Yankee has decided to implement, or is contemplating, implementing the use of bed buses in the SPMC.

Aeolicants' Response l

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See response to Interrogatory No. 8.

Interrogatory No. 10 Please identify by name(s), title / position and business address any and all individuals who were consulted in, or otherwise contributed to, the answering the above interrogatories.

Aeolicants' Resconse See response to Interrogatory No. 1.

Interroaatorv No. 11 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 subject matter of the document.

Acolicants' Resconse New Hampshire Yankee Procurement Manual: Hid Solicitation and Evaluation (Procedure PM 4.1) Rev 4, 12/2/88.

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As to answers: l M' ~

-m George S./ Thomas ' l Vice President - Nuclear Production,  !

New Hampshire Yankee Division of Public Service Company of New Hampshire STATE OF NEW HAMPSHIRE County of Rockingham Then appeared before me the above subscribed George S. Thomas and made oath that he is the Vice President - Nuclear Production, of New Hampshire Yankee Division, authorized to execute the foregoing responses to interrogatories on behalf of the Applicants, that he made inquiry and believes that the foregoing answers accurately set forth information as is available to the Applicants.

Before me, b b bam.{

My Commiss55h Expires: %rc9 c.1990 As to objections:

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Thomas Gg$igng, Jr.

George H'.'Levald Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith Geoffrey C. Cook Ropes & Gram One International Place Boston, MA 02110 (617) 951-7000 I i

Counsel for Applicants  !

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IC [,hIi k. k y:hiO' CERTIFICATE OF SERVICE I, Geoffrey C. Cook, one of the attorney [h9fohO tI b 1fcants herein, hereby certify that on April 3, 1989, I made service of the within document by depositing copies thereof with. Federal Express, prepaid, for delivery to (or, where ind'icated',' by' depositing in the United States mail, first class' post" age paid, addressed to):

Administrative Judge Ivan W. Smith Administrative Judge 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 Emmeth 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 Towers Building 4350 East West Highway -

4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building One White Flint North, 15th Fl.

4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852 l

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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 L Commission Manchester, NH 03105 l Washington, DC 20555 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,HME 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 i Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen l Town of Exeter Town Hall - Friend Street l 10 Front Street Amesbury, MA 01913 1 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 i

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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

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