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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20010G5081981-09-0808 September 1981 Response to Commonwealth of Ma First Set of Document Requests Re TMI Issues.Certificate of Svc Encl ML20005B9251981-09-0101 September 1981 Response to NRC First Set of Interrogatories Directed to Commonwealth of Ma.Certificate of Svc Encl.Related Correspondence ML20005B9301981-08-28028 August 1981 Response to First Set of Interrogatories Re TMI Issues, App B to NUREG-0718.Related Correspondence ML20005B9331981-08-28028 August 1981 Supplemental Response to First Set of Interrogatories Re Emergency Planning in Compliance W/Aslb 810820 Ruling on Discovery.Certificate of Svc Encl.Related Correspondence ML20010C9041981-08-17017 August 1981 Responses to Applicants' Interrogatories Re Emergency Planning & TMI-2 Related Issues.Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20010C5801981-08-14014 August 1981 Interrogatories Directed to NRC Re Emergency Planning & TMI-2 Related Issues.Related Correspondence ML20010C5951981-08-14014 August 1981 Request for Production of Documents Directed to NRC Re TMI-2.Certificate of Svc Encl.Related Correspondence ML20010D1721981-08-14014 August 1981 Response to Commonwealth of Ma Second Set of Interrogatories Re Emergency Planning.Protective Order Re Production & Identification of Repts Prepared by Hmm Associates Should Be Granted.Certificate of Svc Encl.Related Correspondence ML20010B2031981-08-0505 August 1981 Second Set of Requests for Production of Documents Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20010B3071981-08-0505 August 1981 Second Set of Interrogatories Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20010A8811981-08-0404 August 1981 Response to Commonwealth of Ma Request for Production of Documents (First Set).Objects to Certain Requests as Overly Broad & Burdensome.Certificate of Svc Encl.Related Correspondence ML20010A8861981-08-0404 August 1981 Second Set of Interrogatories Directed to Util Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20010A8881981-08-0404 August 1981 Second Set of Requests for Production of Documents Directed to Util Re Emergency Planning.Certificate of Svc Encl. Related Correspondence ML20009F8361981-07-27027 July 1981 Interrogatories Directed to Commonwealth of Ma Re Emergency Planning & TMI-related Issues.Certificate of Svc Encl. Related Correspondence ML20005B9541981-07-20020 July 1981 Response to Commonwealth of Ma First Set of Interrogatories Re Emergency Planning.Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20005B4001981-07-0101 July 1981 First Set of Interrogatories Directed to Applicant Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20005B3981981-07-0101 July 1981 First Set of Interrogatories Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20005B3791981-07-0101 July 1981 First Set of Requests for Production of Documents Re Emergency Planning Directed to Util.Certificate of Svc Encl.Related Correspondence ML20005B4011981-07-0101 July 1981 First Set of Requests for Documents Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML19208D5991979-08-13013 August 1979 Interrogatories Directed to Nrc.Includes Questions Re PSAR, Environ Repts,Demographic Info,Emergency Preparedness, Preferential Sheltering Strategies,Early Thyroid Exposure & Other health- & safety-related Matters ML19241B6321979-06-0808 June 1979 Commonwealth of Ma Interrogatories Directed to Boston Edison Re Need for Power Issue.Certificate of Svc Encl ML19289E8831979-04-19019 April 1979 Interrogatories Submitted to NRC Re Values in Table S-3 of Es Christenbury 790326 Ltr 1981-09-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20039B5361981-12-16016 December 1981 Response to ASLB 811210 Order.Lists Preconst Activities Taken at Proposed Site.Certificate of Svc Encl ML20058M0481981-11-16016 November 1981 Order Granting Partial Initial Decision Vacated on Ground of Mootness ML20011A6091981-10-23023 October 1981 Motion for ASLB Order Allowing Withdrawal of Application & Terminating Adjudicatory Proceeding Before Aslb. Certificate of Svc Encl ML20010H2851981-09-14014 September 1981 Detailed Statement of Commonwealth of Ma TMI-related Contentions.Certificate of Svc Encl.Related Correspondence ML20010H2401981-09-14014 September 1981 Confirms That ASLB Need Not Rule on Motion for Protective Order Re Commonwealth of Ma 810814 Notice of Deposition. Applicant Production of Documents Obviates Need for Deposition.Certificate of Svc Encl.Related Correspondence ML20010H2431981-09-14014 September 1981 Motion to Compel Answers to First Set of Interrogatories Directed to Util Re TMI Issues.Certificate of Svc Encl. Related Correspondence ML20010H2831981-09-14014 September 1981 Conditional Notice of Withdrawal of Listed Portions of 810821 Emergency Planning Contentions.Withdrawal Conditional on Incorporation of Revised Evaucation Study in Psar.W/ Certificate of Svc.Related Correspondence ML20005B8851981-09-0909 September 1981 Errata Sheet to Commonwealth of Ma 810824 Request for Clarification/Motions for Extension of Time for Filing Direct Testimony on Emergency Planning & Ruling Re Rebuttal Testimony.Certificate of Svc Encl.Related Correspondence ML20010G5081981-09-0808 September 1981 Response to Commonwealth of Ma First Set of Document Requests Re TMI Issues.Certificate of Svc Encl ML20005B9081981-09-0202 September 1981 Suppl to Commonwealth of Ma 810824 Motion to Extend Time for Filing Direct Testimony on Emergency Planning.Addl Listed Events,Which Occurred Since Motion Filed,Lend Support to Motion.Certificate of Svc Encl ML20005B9251981-09-0101 September 1981 Response to NRC First Set of Interrogatories Directed to Commonwealth of Ma.Certificate of Svc Encl.Related Correspondence ML20005B9331981-08-28028 August 1981 Supplemental Response to First Set of Interrogatories Re Emergency Planning in Compliance W/Aslb 810820 Ruling on Discovery.Certificate of Svc Encl.Related Correspondence ML20005B9301981-08-28028 August 1981 Response to First Set of Interrogatories Re TMI Issues, App B to NUREG-0718.Related Correspondence ML20010C9041981-08-17017 August 1981 Responses to Applicants' Interrogatories Re Emergency Planning & TMI-2 Related Issues.Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20010D1631981-08-17017 August 1981 Request for Prehearing Conference to Be Held on 810901 & for Rescheduling of Argument on Exceptions to Partial Initial Decision.Certificate of Svc Encl ML20010D1721981-08-14014 August 1981 Response to Commonwealth of Ma Second Set of Interrogatories Re Emergency Planning.Protective Order Re Production & Identification of Repts Prepared by Hmm Associates Should Be Granted.Certificate of Svc Encl.Related Correspondence ML20010C8401981-08-14014 August 1981 Notice of 810904 Depositions of Rh Cunningham,Rj Merlino & Util Employee W/Described Knowledge.Existence,Methodology & Results of Studies Re 10 & 30-mile Evacuation Radius to Be Addressed.W/Certificate of Svc.Related Correspondence ML20010C8451981-08-14014 August 1981 Notice of 810902 Deposition of Persons Designated by NRC to Have Knowledge of Methodology & Results of Analysis of Accident Consequences & Feasibility of Protective Actions. W/Certificate of Svc.Related Correspondence ML20010C8521981-08-14014 August 1981 Motion for Order to Compel Production of Documents Per Commonwealth of Ma 810701 First Set of Requests.Util Response Inconsistent W/Proper Purpose & Scope of Discovery. Certificate of Svc Encl.Related Correspondence ML20010C5951981-08-14014 August 1981 Request for Production of Documents Directed to NRC Re TMI-2.Certificate of Svc Encl.Related Correspondence ML20010C5801981-08-14014 August 1981 Interrogatories Directed to NRC Re Emergency Planning & TMI-2 Related Issues.Related Correspondence ML20010C4411981-08-12012 August 1981 Motion Requesting That Scheduled Aslab 810901 Oral Argument & ASLB 810901 Prehearing Conference Not Be Held on Same Day. Certificate of Svc Encl ML20010C2911981-08-10010 August 1981 Answer in Opposition to Applicant 810804 Motion for Protective Order.Applicant Arguments Are Absurd & Indicative of Lack of Concern for Public Safety.Certificate of Svc Encl ML20010C2981981-08-10010 August 1981 Motion to Reconsider ASLB 810803 Denial of State of Il 810715 Motion to Modify Prehearing Conference Order.Stated Grounds for Denial Are Inaccurate.Certificate of Svc Encl ML20010B2031981-08-0505 August 1981 Second Set of Requests for Production of Documents Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20010B3071981-08-0505 August 1981 Second Set of Interrogatories Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20010A8951981-08-0404 August 1981 Motion for Protective Order & Answer to Commonwealth of Ma Motion to Compel.Motion Should Be Denied.Certificate of Svc Encl.Related Correspondence ML20010A8841981-08-0404 August 1981 Motion to Amend ASLB 810702 Prehearing Conference Order, Changing Commencement Date of Hearing on Emergency Planning Issues from 811009 to 13.Applicant Counsel Has Prior Engagement.Certificate of Svc Encl ML20010A8861981-08-0404 August 1981 Second Set of Interrogatories Directed to Util Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20010A8881981-08-0404 August 1981 Second Set of Requests for Production of Documents Directed to Util Re Emergency Planning.Certificate of Svc Encl. Related Correspondence ML20010A8811981-08-0404 August 1981 Response to Commonwealth of Ma Request for Production of Documents (First Set).Objects to Certain Requests as Overly Broad & Burdensome.Certificate of Svc Encl.Related Correspondence ML20009F8361981-07-27027 July 1981 Interrogatories Directed to Commonwealth of Ma Re Emergency Planning & TMI-related Issues.Certificate of Svc Encl. Related Correspondence ML20009F8511981-07-24024 July 1981 Application for Subpoena Directed to Argonne National Computer Ctr to Produce Any Software or Document Containing or Describing Mod or Improvement to Crac Code Since Development.Certificate of Svc Encl ML20009F8481981-07-24024 July 1981 Answer Opposing NRC 810710 & 15 Motions for Protective Order.Nrc Misperceived & Mischaracterized Nature of Questions.Commonwealth of Ma Is Requesting NRC Position on Issues,Not Info on Issues ML20009F8451981-07-24024 July 1981 Motion to Compel Answers to Commonwealth of Ma First Set of Interrogatories Directed to Util Re Emergency Planning. Interrogatories Are Relevant to Contentions.Certificate of Svc Encl ML20005B9541981-07-20020 July 1981 Response to Commonwealth of Ma First Set of Interrogatories Re Emergency Planning.Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20009D0721981-07-15015 July 1981 Motion to Modify Prehearing Conference Order.Order Should Reflect Commonwealth Objection to Proceed W/Conference W/O Court Reporter,Request for 2-month Discovery Period & Request to Change Date to 810831.W/Certificate of Svc ML20005B4011981-07-0101 July 1981 First Set of Requests for Documents Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20005B4001981-07-0101 July 1981 First Set of Interrogatories Directed to Applicant Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20005B3981981-07-0101 July 1981 First Set of Interrogatories Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20005B3791981-07-0101 July 1981 First Set of Requests for Production of Documents Re Emergency Planning Directed to Util.Certificate of Svc Encl.Related Correspondence ML20005A4071981-06-17017 June 1981 Answer of a & M Cleeton Supporting Applicant Motion for Order Scheduling Further Proceedings Re Emergency Planning. Certificate of Svc Encl ML20005A4361981-06-17017 June 1981 Brief in Opposition to Exceptions Taken by Intervenors Ma Wildlife Federation,Commonwealth of Ma & AR & MW Cleeton Re ASLB 810202 Partial Initial decision,LBP-81-3.Certificate of Svc Encl ML20126M3831981-06-0909 June 1981 Answer Supporting Applicant Motion for Order Scheduling Proceedings on Emergency Planning,W/Suggested Revisions to Proposed Schedule.First Prehearing Conference & Opening of Discovery Would Be on 810622.W/Certificate of Svc ML20004E7901981-06-0404 June 1981 Motion for Order Scheduling Further Proceedings on Emergency Planning as Listed.First Prehearing Conference & Opening of Discovery Should Be on 810622,w/discovery Closing on 810722.Certificate of Svc Encl ML20004B6071981-05-21021 May 1981 Brief Supporting Exceptions to ASLB Partial Initial Decision Findings of Fact & Conclusions of Law on All Matters Except Emergency Planning & TMI-2 Related Issues.Constitutionality of Regulation Should Be Decided.Certificate of Svc Encl ML20004B6051981-05-21021 May 1981 Motion for Leave to File Brief in Support of Exceptions Out of time.Two-day Delay Was Caused by Sudden Illness of Secretary.Certificate of Svc Encl ML20004B6941981-05-19019 May 1981 Exceptions to ASLB Partial Initial Decision.Aslb Erred in Considering Benefits Vs Costs Before Evidentiary Hearings on Emergency Planning & TMI-2 Issues.Certificate of Svc Encl ML20004B6481981-05-19019 May 1981 Brief in Support of Exceptions 1,2 & 6 to ASLB 810202 Partial Initial Decisions.Decision Should Be Reversed & Matter Remanded for Further Considerations of Class 9 Accidents.Certificate of Svc Encl ML20003D2731981-03-12012 March 1981 Joint Motion for Consolidation of Date for Filing Briefs & Extension Until 810519 to File Briefs.Good Cause for Commonwealth of Ma Is Necessity for Thorough Review,Counsel Illness & Litigation Obligations.Certificate of Svc Encl 1981-09-09
[Table view] |
Text
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UNITED STATES OF AMERICA ,9,
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NUCLEAR REGULATORY COMMISSION i-f, before the h ATOMIC SAFETY AND LICENSING BOARD > 3 GMn!oc Swety
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In the Matter of )
BOSTON EDISON COMPANY, et al. Docket No. (-7 (Pilgrim Nuclear Generating )
S If{ f h Station Unit 2 ) 7 L/ ,
) G-gWu%3.l 198;w l APPLICANTS' INTERROGATORIES TO THE COMMON 5 VALTH OF MASSACHUSETTS ON EMERGENCY PLANNING Ah h, f TMI-2 RELATED ISSUES N Pursuant to 10 CFR SS2.740 and 2.740b, the following interrogatories are propounded to the Commonwealth of Massa-chusetts to be answered fully in writing and under oath.
- 1. Please state in detail each respect in which the Commonwealth of Massachusetts contends that the Appli-cants' preliminary plans for coping with emergencies fails to comply with the requirement of 10 CFR 50, z
Appendix E, Part II.
- 2. Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its answer to 9
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interrogatory number 1. Please identify each document, and the particular parts thereof, of which the Common-wealth is aware which supports each fact so identified in this interrogatory. Please further indicate each such document which the Commonwealth intends to offer in evidence in this proceeding. For the purpose of this interrogatory, please utilize the same definition of the word " document" as provided in the Commonwealth's interrogatories to Boston Edison Company.
- 3. Please state in detail each respect in which the Common-wealth of Massachusetts contends that the Applicants either fail to address or inadequately address the provisions of NUREG 0718, Revision 1, in their application for a construction permit, including the PSAR and amendments thereto.
l
- 4. Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its answer to interrogatory number 3. Please identify each document, and the particular parts thereof, of which the Common-
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wealth is aware which supports each ' fact so identified in this interrogatory.' Please further indicate each ,
i such document which the Commonwealth intends to offer l .
l in evidence in this proceeding. For the purpose of l
l l this interrogatory, please utilize the same definition l
I
of the word " document" as provided in the Commonwealth's interrogatories to Boston Edison Company.
- 5. For each item contained under the heading "TMI-2 Related Requirements" in the Staff's Supplement No. 6 to the Safety Evaluation Report for Pilgrim Unit 2 ,
(which items are located on pages 4-51 of that document) please state whether the Commonwealth agrees with the Staff's conclusion. If the Commonwealth disagrees with
- a particular item in any respect, please state, in detail, all reasons for such disagreement. If the Commonwealth takes no position or neither agrees nor disagre,es with a particular item, please state what i
efforts the Commonwealth has undertaken or intends to undertake between now and the date of hearing to estab-lish a position as to such item.
l 6. Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its answer to interrogatory number 5. Please identify each document, and the particular parts thereof, of which the Common-
- - wealth is aware which suppor[s each~ fact so identified l in this interrogatory. Please further indicate each ,
l such document which the Commonwealth intends to offer in evidence in this proceeding. For the purpose of l
i l
l
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this interrogatory, please utilize the same definition of the word " document" as provided in the Commonwealth's interrogatories to Boston Edison.
- 7. For each item labelled " Requirement" under the heading of " Emergency Planning" in the Staff's Supplement No. 5 to the Safety Evaluation Report for Pilgrim Unit 2 (which items are located on pages 13.3-1 through 13.3-10 of that document) please state whether the Common-wealth agrees with the Staff's conclusion. If the Commonwealth disagrees with a particular item in any respect please state, in detail, all reasons for such disagreement. If the Commonwealth takes no position or neither agrees nor disagrees with a particular item, please state what efforts the Commonwealth has unGer-taken or intends to undertake between now and the date of the of hearing to establish a position as to such item.
- 8. Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its answer to in'te' rr'ogatofy nu~m'bdr 7 ;
Please' identify each d6cument, I
and the particular parts thereof, of which the Common- -
I wealth is aware which supports each fact so identified -
in this interrogate . Please further indicate each i
l I
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, , , , ~ - . , .- ,- - . _ _ , . . _ _ . ,-,. _, - , ,n,, .,. . , . , , . ,
such document which the Commonwealth intends to offer in evidence in this proceeding. For the purpose of this interrogatory, please utilize the same definition of the word " document" as provided in the Commonwealth's interrogatories to Boston Edison.
- 9. Please identify each witness whom the Commonwealth of Massachusetts intends to have testify on its behalf on the subjects of emergency planning or TMI-2. related issues in this proceeding. Please state the relevant qualifications and background of such witness along with the subject matter upon which such witness is expected to testify and the substance c_ such witness's testimony.
Respectfully submitted,
$ b.4 l Thomas G. Di'g nan , Jr. $ Apy R. K. Gad, III Ropes & Gray 225 Franklin Street Bceton, MA 02110 (617)423-6100 jlj /
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William S. Stowe Boston Edison Company 800 Boylston Street Boston, MA 02199 (617)424-2544 O
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RELATED . CORRESPONDENCE o\
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UNITED STATES OF AMERICA y yj( 201981 > -f j
NUCLEAR REGULATORY COMMISSION --
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In the Matter of )
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BOSTON EDISON COMPANY, et al. ) Docket No. 50-471
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(Pilgrim Nuclear Generating )
Station, Unit 2) )
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CERTIFICATE OF SERVICE I hereby certify that the Applicants' Interrogatories to the Commonwealth of Massachusetts on Emergency Planning and TMI-Related Issues filed in the above-captioned matter has been served on the following by deposit of a copy thereof in the United States mail, first class, postage prepaid:
Andrew C. Goodhope, Esquire Stephen M. Leonard, Esquire Chairman Jo Ann Shotwell, Esquire Atomic Safety and Licensing Board Environmental Protection Division 3320 Estel.le Terrace Department of the Attorney General Wheaton, Maryland 20906 One Ashburton Place, 19th Floor Boston, MA 02108 Dr. A. Dixon Callihan Union Carbide Corporation Francis S. Wright, Esquire P. O. Box Y Berman & Berman Oak Ridge, Tennessee 211 Congress Street Boston, MA 02110 t Dr. Richard F. Cole l Atomic Safety and Licensing Board Henry Herrmann, Esquire l U.S. Nuclear Regulatory Commission Room 1045 I Washington, D.C. 20555 50 Congress Street
! Boston, MA 02110 l Atomic Safety and Licensing . Board._ . .
L _ Panel Mr. and Mrs. Alan R. Cleeton U.S. Nuclear Regulatory Commission 22 Mackintosh Street Franklin, MA 02038 Washington, D.C. ,
Atomic Safety and Licensing William S. Abbott, Esquire l Appeal Panel Suite 925 l U.S. Nuclear Regulatory Commission 50 Congress Street Washington, D.C. 20555 Boston, MA 02109 l
t
_ - ,- _7 , , . _
t Jack R. Goldberg, Esquire Patrick J. Kenny, Esquire Stephen H. Lewis, Esquire Edward L. Selgrade, Esquire Office of the Executive Legal Mass. Office of Energy Resources Director 73 Tremont Street .
U.S. Nuclear Regulatory Commission Boston, MA 02110 Washington, D.C. 20555 office of the Secretary Chief Librarian Docketing and Service Section Plymouth Public Library U.S. Nuclear Regulatory Commission North Street Washington, D.C. 20555 Plymouth, MA 02360 Thomas S. Moore, Chairman Dr. John H. Buck Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Christine N. Kohl, Esquire
~
Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20535
(#/)~ S TL Dated: July 27, 1981 m m 3
e a m.