ML20205F837: Difference between revisions
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'88 OCI 26 P5 :50 October 25, 1988 .j p ,, | |||
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Sherwin E. Turk, Esquire Office of General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 Re: NRC Staff Motion to Compel Answers to Interrogatories and Production of Documents by Town of Amesbury | |||
==Dear Sherwin:== | |||
Pursuant to the Staff's letter to the Board of October 14, 1988, please advise the Board and this office whether, and to what extent, a ruling on the Staff's motion to compel is required. | |||
V ry truly yours, w _ | |||
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Matthew T. Brock l-MTB/jlr cc: Service list , | |||
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Revision as of 18:45, 29 December 2020
| ML20205F837 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/25/1988 |
| From: | Brock M AMESBURY, MA, SHAINES & MCEACHERN |
| To: | Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| CON-#488-7366 OL, NUDOCS 8810280146 | |
| Download: ML20205F837 (1) | |
Similar Documents at Seabrook | |
|---|---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M8771999-10-25025 October 1999
[Table view]Requests That Industry Studies on long-term Spent Fuel Pool Cooling Be Provided to R Dudley at Listed Mail Stop ML20217M4331999-10-19019 October 1999 Submits Rept 17, Requal Tracking Rept from Operator Tracking Sys. Rept Was Used by NRC to Schedule Requalification Exams for Operators & Record Requal Pass Dates ML20217F5841999-10-13013 October 1999 Requests Revocation of License OP-11038-1 for GE Kingsley. Individual Has Been Reassigned to Position within Naesco ML20217F5811999-10-13013 October 1999 Forwards Insp Data & Naesco Evaluation of a EDG Exhaust Insp Conducted on 990407.Insp Ensured That Unacceptable Wall Thinning Will Not Occur During 40-year Design Lifetime of Sys ML20217C7321999-10-0808 October 1999 Forwards Copy of Seabrook Station Videotape Entitled, Completion of Seal Barrier Installation. Videotape Documents Process of Selecting,Designing & Installing Seal Deterrent Barrier to Preclude Entrapment of Seals ML20217B8621999-10-0505 October 1999 Forwards Rev 28,change 1 to EPIP Er 1.1, Classification & Emergencies, Per 10CFR50.54(q).Rev to Procedure Does Not Decrease Effectiveness of Seabrook Station Radiological Emergency Plan ML20217B7471999-10-0101 October 1999 Provides Notification of Change in PCT of More than 50 F,Per Requirements of 10CFR50.46(a)(3)(i),(ii).Tabulation of Large Break LOCA PCT Margin Utilization Applicable to Seabrook Station,Encl ML20212J8271999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Seabrook Station. Staff Conducted Reviews for All Operating NPPs to Integrate Performance Info & to Plan for Insp Activities at Facility Over Next Six Months.Plant Issues Matrix & Insp Plan Encl ML20216J2381999-09-30030 September 1999 Responds to Re Enforcement Discretion for Nuclear Plants During Y2K Transition.Nrc Expects All Licensees to Operate Nuclear Facilities Safety IAW NRC Regulations & Requirements ML20216J2421999-09-30030 September 1999 Responds to Card Received in Aug 1999,providing Comments on NRC Interim Enforcement Policy Re Enforcement Discretion for Nuclear Plants During Y2K Transition.Informs That Naesc Reported Seabrook as Y2K Ready Prior to 990701 ML20216J2471999-09-30030 September 1999 Responds to Which Provided Comments on NRC Interim Enforcement Policy Re Enforcement Discretion for Nuclear Plants During Y2K Transition.Informs That Naesc Reported Seabrook as Y2K Ready Prior to 990701 ML20212K7921999-09-30030 September 1999 Confirms 990922 Telcon with J D'Antonio & T Grew Re Arrangements Made for NRC to Inspect Licensed Operator Requalification Program at Seabrook Facility ML20212J0301999-09-24024 September 1999 Forwards Insp Rept 50-443/99-10 on 990726-30 & 0809-13.No Violations Noted.Insp Discussed ML20212G5071999-09-21021 September 1999 Submits Complaint to NRC Re NRC Failure to Cite Seabrook Station NPP Operators for Failing to Periodically Calibrate & Establish Adequate Measures to Insure That Relay Equipment Met All Required Calibration Settings Prior to Installation ML20212C1881999-09-20020 September 1999 Ack Receipt of Which Raised Concerns Re NRC Enforcement Actions at Plant & Issuance of NCVs ML20212D1401999-09-17017 September 1999 Forwards SE Accepting Request to Use Proposed Alternative to Certain Weld Repair Requirements in ASME Boiling & Pressure Vessel Code ML20212B9511999-09-17017 September 1999 Forwards NRC Form 396 for MG Sketchley,License SOP-10685, Along with Supporting Medical Exam Info.Nrc Form 396 Has Been Superceded by Revised Version Dtd 971222,which Was Previously Submitted to NRC on 990812.Encl Withheld ML20212C3621999-09-15015 September 1999 Forwards Rev 34 to Seabrook Station Radiological Emergency Plan & Rev 85 to Seabrook Station Emergency Response Manual, Per 10CFR50,App E & 10CFR50.4 ML20212B5021999-09-14014 September 1999 Forwards Licensee Responses to EPA Questions Re Plant Seal Deterrent Barrier.Util Completed Installation of Subject Barriers on All Three Station Offshore Intake Structures on 990818.Barriers Will Preclude Entrapment of Seals ML20211Q8521999-09-0808 September 1999 Informs That Rl Couture,License SOP-11027,terminated Employment at Naesco on 990907.Revocation of License Requested ML20211N8781999-09-0303 September 1999 Forwards Response to 990820 RFI Re NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20211J9291999-09-0303 September 1999 Forwards mark-ups & Retypes of Proposed Conforming License Changes Required in Connection with Transfers Being Sought in 990615 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests ML20211M3221999-09-0202 September 1999 Responds to NRC Re Violations Noted in Insp of License NPF-86 & Proposed Imposition of Civil Penalty. Corrective Actions:Conducted Prompt Review of Layoff Decision to Determine Relevant Facts DD-99-10, Informs That Time Provided by NRC Regulation within Which Commission May Act to Review Director'S Decision (DD-99-10) Expired.Commission Declined Review & Decision Became Final on 990830.With Certificate of Svc.Served on 9909021999-09-0202 September 1999 Informs That Time Provided by NRC Regulation within Which Commission May Act to Review Director'S Decision (DD-99-10) Expired.Commission Declined Review & Decision Became Final on 990830.With Certificate of Svc.Served on 990902 ML20211J8811999-09-0101 September 1999 Forwards Comments on Seabrook Station Review of Reactor Vessel Integrity Database (Rvid)(Version 2).Minor Discrepancies Were Noted.Proposed Changes Are Encl in Order to Correct Discrepancies ML20211J8411999-09-0101 September 1999 Forwards Updated NRC Form 396 for E Decosta,Nrc License OP-10655-1.Without Encl ML20211G9191999-08-27027 August 1999 Informs NRC That Name of New Company, Ref in Order Approving Application Re Corporate Merger Is Nstar Which Is Massachusetts Business Trust ML20211J0401999-08-26026 August 1999 Responds to 990819 Request,On Behalf of Gr Pageau & Williams Power Corp,For Addl Time in Which to Reply to Nov,Issued on 990803.Response Due to NRC by 991008 ML20211H0651999-08-25025 August 1999 Forwards Insp Rept 50-443/99-05 on 990621-0801.One Violation Re Failure to Include Multiple Components within Scope of ISI Test Program Was Identified & Being Treated as NCV, Consistent with App C of Enforcement Policy ML20211G7761999-08-24024 August 1999 Expresses Great Concern Re Lack of Enforcement Actions Against Seabrook Station Despite Citations NRC Has Issued for Violations of Seabrook Operating License ML20211J2171999-08-23023 August 1999 Expresses Disappointment with Lack of Enforcement Action Against Seabrook Station Despite Repeated Safety Violations ML20211J4971999-08-21021 August 1999 Submits Comments Re Violations Cited in Early Mar & 990509 Insps ML20211H8361999-08-19019 August 1999 Submits Concerns Re Violations at Seabrook Station ML20211F2681999-08-19019 August 1999 Discusses Former Chairman Jackson & 990602 Predecisional Enforcement Conference Re Findings of Ofc of Investigations Involving Allegations Raised by Contract Electrician.Determined That Allegations Not Supported ML20211J3241999-08-15015 August 1999 Expresses Disappointment in Apparent Failure of NRC to Cite Seabrook Station NPP for Recent Violations of Safety Regulations Uncovered During Recent Insps in Mar & May ML20211J1831999-08-15015 August 1999 Submits Concerns Over Serious Deficiencies at Seabrook Station That NRC Has Declined to Take Enforcement Actions Against ML20210T1601999-08-13013 August 1999 Informs That as Result of Staff Review of Licensee Responses to GL 92-01,rev,supp1 1, Reactor Vessel Structural Integrity, NRC Revised Info in Reactor Vessel Integrity Database & Is Releasing It as Rvid Version 2 ML20211J2071999-08-13013 August 1999 Expresses Concerns Re Violations Occurring Recently at Seabrook Nuclear Power Station.Requests Effort to See That Measures Taken to Stop Flagrant,Continuing Violations That Hold Danger to Workers & Community ML20210S9611999-08-13013 August 1999 Informs That NRC Received Encl Ltr from Pb Johnston Expressing Concern About Certain Impacts on Shareholders of New England Electric Sys with Respect to Nees Proposed Merger with Natl Grid Group ML20210S9511999-08-13013 August 1999 Responds to to Collins Expressing Concerns with Certain Terms of Proposed Merger Between New England Electric Sys & National Grid Group.Nrc Has No Authority to Interject Itself in Nees Merger with National Grid Group ML20210S2001999-08-12012 August 1999 Forwards NRC Forms 398 & 396 in Support of Applications for Renewal of Operator Licenses for Individuals Listed Below. Without Encls ML20210R8401999-08-11011 August 1999 Forwards Response to NRC Second RAI Re GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves ML20210S7331999-08-11011 August 1999 Submits Third Suppl to 980423 Application to Renew NPDES Permit NH0020338 for Seabrook Station.Suppl Provides Addl Info on Input Streams & Requests Increased Permit Limit for Chemical Used in Makeup Water Treatment Sys ML20210R9581999-08-11011 August 1999 Forwards ISI Exam Rept of Seabrook Station, for RFO 6, Period 3,for Insps Conducted Prior to & During Sixth Refueling Outage Concluded on 990510 ML20210Q7441999-08-11011 August 1999 Forwards Order Approving Indirect Transfer of Control of Canal Interest in Seabrook Station Unit 1 as Requested in Application & SER ML20210R7931999-08-10010 August 1999 Forwards Cycle 7 Startup Rept for Seabrook Station, IAW Requirements of TS 6.8.1.1 ML20210N9421999-08-0505 August 1999 Informs That North Atlantic Suggests Listed Revisions to 990730 Draft Revisions to Committee Rept & Order.Further Revs Consistent with What North Atlantic Proposed at 990608 Hearing ML20210N5721999-08-0303 August 1999 Discusses Investigations Rept 1-98-005 Conducted by OI at Naesco,Seabrook Station & Forwards NOV & Proposed Imposition of Civil Penalty - $55,000.Violation Re Failure to Promptly Correct Incorrectly Terminated Cables of Control Bldg Air ML20210P3361999-08-0303 August 1999 Discusses Investigation Rept 1-98-005 Conducted by Region I OI at Naesco,Seabrook Station & Forwards Nov.Violations Re Electrical Wiring in Control Panel for Control Bldg Air Conditioning Sys ML20210P3161999-08-0303 August 1999 Discusses Investigation Rept 1-98-005,conducted Between 980129 & 0527 at Seabrook Station & Forwards Nov.Violation Re Discrimination of Williams Power Corp,Contractor of Naesco,Against Electrician for Raising Safety Issues 1999-09-08 Category:INCOMING CORRESPONDENCE MONTHYEARML20217F5841999-10-13013 October 1999
[Table view]Requests Revocation of License OP-11038-1 for GE Kingsley. Individual Has Been Reassigned to Position within Naesco ML20217F5811999-10-13013 October 1999 Forwards Insp Data & Naesco Evaluation of a EDG Exhaust Insp Conducted on 990407.Insp Ensured That Unacceptable Wall Thinning Will Not Occur During 40-year Design Lifetime of Sys ML20217B8621999-10-0505 October 1999 Forwards Rev 28,change 1 to EPIP Er 1.1, Classification & Emergencies, Per 10CFR50.54(q).Rev to Procedure Does Not Decrease Effectiveness of Seabrook Station Radiological Emergency Plan ML20217B7471999-10-0101 October 1999 Provides Notification of Change in PCT of More than 50 F,Per Requirements of 10CFR50.46(a)(3)(i),(ii).Tabulation of Large Break LOCA PCT Margin Utilization Applicable to Seabrook Station,Encl ML20212G5071999-09-21021 September 1999 Submits Complaint to NRC Re NRC Failure to Cite Seabrook Station NPP Operators for Failing to Periodically Calibrate & Establish Adequate Measures to Insure That Relay Equipment Met All Required Calibration Settings Prior to Installation ML20212B9511999-09-17017 September 1999 Forwards NRC Form 396 for MG Sketchley,License SOP-10685, Along with Supporting Medical Exam Info.Nrc Form 396 Has Been Superceded by Revised Version Dtd 971222,which Was Previously Submitted to NRC on 990812.Encl Withheld ML20212C3621999-09-15015 September 1999 Forwards Rev 34 to Seabrook Station Radiological Emergency Plan & Rev 85 to Seabrook Station Emergency Response Manual, Per 10CFR50,App E & 10CFR50.4 ML20211Q8521999-09-0808 September 1999 Informs That Rl Couture,License SOP-11027,terminated Employment at Naesco on 990907.Revocation of License Requested ML20211N8781999-09-0303 September 1999 Forwards Response to 990820 RFI Re NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20211J9291999-09-0303 September 1999 Forwards mark-ups & Retypes of Proposed Conforming License Changes Required in Connection with Transfers Being Sought in 990615 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests ML20211M3221999-09-0202 September 1999 Responds to NRC Re Violations Noted in Insp of License NPF-86 & Proposed Imposition of Civil Penalty. Corrective Actions:Conducted Prompt Review of Layoff Decision to Determine Relevant Facts ML20211J8411999-09-0101 September 1999 Forwards Updated NRC Form 396 for E Decosta,Nrc License OP-10655-1.Without Encl ML20211J8811999-09-0101 September 1999 Forwards Comments on Seabrook Station Review of Reactor Vessel Integrity Database (Rvid)(Version 2).Minor Discrepancies Were Noted.Proposed Changes Are Encl in Order to Correct Discrepancies ML20211G9191999-08-27027 August 1999 Informs NRC That Name of New Company, Ref in Order Approving Application Re Corporate Merger Is Nstar Which Is Massachusetts Business Trust ML20211G7761999-08-24024 August 1999 Expresses Great Concern Re Lack of Enforcement Actions Against Seabrook Station Despite Citations NRC Has Issued for Violations of Seabrook Operating License ML20211J2171999-08-23023 August 1999 Expresses Disappointment with Lack of Enforcement Action Against Seabrook Station Despite Repeated Safety Violations ML20211J4971999-08-21021 August 1999 Submits Comments Re Violations Cited in Early Mar & 990509 Insps ML20211H8361999-08-19019 August 1999 Submits Concerns Re Violations at Seabrook Station ML20211J3241999-08-15015 August 1999 Expresses Disappointment in Apparent Failure of NRC to Cite Seabrook Station NPP for Recent Violations of Safety Regulations Uncovered During Recent Insps in Mar & May ML20211J1831999-08-15015 August 1999 Submits Concerns Over Serious Deficiencies at Seabrook Station That NRC Has Declined to Take Enforcement Actions Against ML20211J2071999-08-13013 August 1999 Expresses Concerns Re Violations Occurring Recently at Seabrook Nuclear Power Station.Requests Effort to See That Measures Taken to Stop Flagrant,Continuing Violations That Hold Danger to Workers & Community ML20210S2001999-08-12012 August 1999 Forwards NRC Forms 398 & 396 in Support of Applications for Renewal of Operator Licenses for Individuals Listed Below. Without Encls ML20210R8401999-08-11011 August 1999 Forwards Response to NRC Second RAI Re GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves ML20210R9581999-08-11011 August 1999 Forwards ISI Exam Rept of Seabrook Station, for RFO 6, Period 3,for Insps Conducted Prior to & During Sixth Refueling Outage Concluded on 990510 ML20210R7931999-08-10010 August 1999 Forwards Cycle 7 Startup Rept for Seabrook Station, IAW Requirements of TS 6.8.1.1 ML20210K3281999-07-30030 July 1999 Forwards Response to NRC RAI Re License Amend Request 98-17. North Atlantic Concurs with Staff That Bases Should State That Maintaining ECCS Piping Full of Water from RWST to Reactor Coolant Sys Ensures Sys Will Perform Properly ML20210H8991999-07-27027 July 1999 Forwards Tabulation of Current LBLOCA & SBLOCA Peak Clad Temp Margin Utilization Tables Applicable to Seabrook Station ML20210H0921999-07-27027 July 1999 Forwards Naesc Semi-Annual Fitness-for-Duty Rept,Jan-June 1999, Per 10CFR26.71(d).Rept Includes Data from 990101- 0610 ML20210S9911999-07-18018 July 1999 Requests NRC Intervene for All Shareholders of New England Electric System & to Help with Merger with National Grid Group & That NRC Petition Security & Exchange Commission to Investigate Matter Relative to No Shareholder Options ML20210A2521999-07-15015 July 1999 Forwards Rev 33 to Seabrook Station Radiological Emergency Plan & Rev 84 to Seabrook Station Emergency Response Manual ML20209J0601999-07-14014 July 1999 Forwards Rev 11 to Vols 1-10 of State of Nh Radiological Emergency Response Plan & Vols 11-50 to Town Radiological Emergency Response Plans,In Support of Vermont Yankee & Seabrook Station.Vols 17-19 of Were Not Included ML20209G1351999-07-0909 July 1999 Forwards Relief Request Re Repair Welding on SA-351 Matl to Be Installed in Seabrook Station SW Pumps & SW Cooling Tower Pumps ML20209D2871999-07-0606 July 1999 Submits Response to NRC AL 99-02,re Numerical Estimate of Licensing Actions Expected to Be Submitted in Fy 2000 & 2001.Schedule Does Not Include Activities Which Meet AL Definition of Complex Review ML20209C9021999-06-30030 June 1999 Provides Revised Distribution List for Seabrook Station Correspondence to Reflect Current Organization ML20196G2391999-06-23023 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant Encl ML20196G3381999-06-23023 June 1999 Forwards LAR 99-19 for License NPF-86,increasing AOT for Cracs from 30 Days to 60 Days on One Time Basis for Each Train to Facilitate on-line Implementation of Design Enhancements During Current Operating Cycle ML20195J0981999-06-17017 June 1999 Forwards Responses to Questions Posed in Re Application of New England Power Co for Transfer of Control of Licenses NPF-49 & NPF-86.Copy of 1998 Schedule 13G, Included,As Requested ML20196D0561999-06-16016 June 1999 Forwards Certified Copy of Endorsements 77 & 78 to Nelia to Policy NF-0296 ML20195H1741999-06-15015 June 1999 Forwards Original & Copy of Request for Approval of Certain Indirect & Direct Transfer of License & Ownership Interests of Montaup Electric Co (Montaup) with Respect to Nuclear Facilities Described as Listed ML20195J1221999-06-15015 June 1999 Forwards Addl Clarifying Info to Suppl Info Provided at 990602 Predecisional Enforcement Conference at Region I. Proprietary Declarations by Util Employees to Correct Inaccuracies Encl.Proprietary Info Withheld,Per 10CFR2.790 ML20210K4971999-06-15015 June 1999 Forwards Copy of Ltr from Concerned Constitutent AC Menninger from Franconia,Nh to Senator Smith Re Seabrook Nuclear Power Station Y2K Readiness ML20195E9731999-06-0707 June 1999 Forwards Rev 32 to Seabrook Station Radiological Emergency Plan & Rev 83 to Emergency Response Manual ML20206T4201999-05-20020 May 1999 Forwards Certified Copies of Resolution Adopted by Shareholders of National Grid Group Approving Acquisition of New England Electric Sys & Vote of New England Electric Sys Shareholders Approving Merger with National Grid Group ML20196L2001999-05-0707 May 1999 Forwards Rev 01-07-00 to RE-21, Cycle 7 COLR, Per TS 6.8.1.6.c ML20206K4301999-05-0707 May 1999 Forwards Copy of Corrective Order of Notice by State of Nh Nuclear Decommissioning Financing Committee ML20206J3321999-05-0505 May 1999 Forwards Tabulation of Number of Tubes Plugged in Each of Two SGs Inspected During Sixth Isi,Per Plant TS SR 4.4.5.5a. Sixth ISI Was Completed on 990420 ML20206J3341999-05-0505 May 1999 Informs That on 990501,ISO New England & New England Power Pool Implemented Restructured Wholesale Electricity Market. Summary of Util Action as Result of Implementation of Subject Market,Encl ML20206J2801999-04-30030 April 1999 Forwards 1998 Annual Financial Repts for CT Light & Power Co,Western Ma Electric Co,Public Svc Co of Nh,North Atlantic Energy Corp,Northeast Nuclear Energy Co & North Atlantic Energy Svc Corp,License Holders ML20206G4371999-04-30030 April 1999 Forwards 1998 Annual Environ Operating Rept for Seabrook Station.Encl Rept Is Summary of Implementation of EPP for Period of Jan-Dec 1998 ML20206H4801999-04-30030 April 1999 Forwards 1998 Annual Radioactive Effluent Release Rept for Seabrook Station. Listed Info Provided in Encls 1999-09-08 Category:STATE/LOCAL GOVERNMENT TO NRC MONTHYEARML20062B9721990-10-10010 October 1990
[Table view]Requests Amend to Svc List,Eliminating Gm Huntington. Corrected List Should Read as Indicated.W/Certificate of Svc ML20012F6701990-04-0909 April 1990 Informs That Author Will Present Arguments on Behalf of Town of Hampton in Appeal of Licensing Board Decisions in LPB-89-32 Scheduled to Be Heard Before Recipients on 900418 ML20012F6981990-04-0303 April 1990 Requests That Massachusetts Attorney General Be Permitted to Represent Town of West Newbury at 900418 Appeal Brief ML20012F6921990-04-0303 April 1990 Requests That Commonwealth of Ma Atty General Be Permitted to Represent City of Newburyport & Town of Newbury at 900418 Oral Argument Re Appeal Briefs ML20012F6841990-04-0202 April 1990 Authorizes Commonwealth of Ma Atty General Representative to Make Oral Argument on Behalf of Towns of Salisbury & Amesbury Before Appeal Board ML20012E6451990-03-29029 March 1990 Forwards Intervenors Memo of Law Per Board 900327 Request for Oral Argument & Exhibit 1 Pages 13-15 & 31-33 of Commission Brief Filed in Ucs Case in 1983 Re Nature of Judgment at Issue in Evaluating Preoperational Testing ML20006A0081990-01-10010 January 1990 Public Meeting of 900118.* Requests Opportunity to Make Short Statement on Behalf of Commonwealth of Ma Atty General at NRC 900118 Public Briefing on Plant Readiness.W/ Certificate of Svc.Served on 900111 ML20006B2231989-12-12012 December 1989 Certificate of Svc Seabrook License Proceedings.* Requests That RA Hampe & T Kinder Be Deleted & G Iverson Be Added to Svc List for Proceeding.W/Certificate of Svc ML19332D5001989-11-13013 November 1989 Expresses Concern Re Impartiality in Case,Per R Backus 891108 Ltr Concerning Comments Attributed to Commissioner Roberts by EA Thomas in 891108 Testimony.Roberts Should Consider Apparent Interest of Conflict.Svc List Encl ML19327B6961989-10-30030 October 1989 Intervenors Motion to Admit late-filed Contention & Reopen Record on Spmc Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Network & Wcgy.* Forwards Motion for Filing ML19327B7091989-10-25025 October 1989 Forwards Author 891013 & Jf Bassett 891020 Ltrs,Refuting Util Representations That Util Cooperating W/ Commonwealth of Ma Emergency Broadcast Sys.Certificate of Svc Encl.Served on 891031 ML19327B6921989-10-25025 October 1989 Forwards Author 891013 & Jf Bassett 891020 Ltrs to Util, Contradicting Applicant Submission to NRC That Applicant Cooperating W/Commonwealth of Ma Emergency Broadcast Sys ML19327B6681989-10-25025 October 1989 Forwards KA Doherty Affidavit Excluding Notarization to Substitute for Original Affidavit Submitted W/Intervenors 891018 Motion for Summary Disposition on Contentions JI-Onsite Ex-1 & JI-Onsite Ex-2 ML19327B9831989-10-0404 October 1989 FOIA Request for Eight Categories of Documents Re Testing Program at Plant ML20248J0371989-09-29029 September 1989 Requests That Pj Matthews & L Kopelman Be Deleted from Svc List.Author Represents City of Newburyport ML20247Q6241989-09-21021 September 1989 Forwards Towns of Amesbury & Salisbury & City of Newburyport Proposed Findings of Fact & Conclusions of Law Re Spmc. Certificate of Svc from Notice of Appearance for Town of Salisbury Also Encl ML20247B7321989-09-0707 September 1989 Forwards Filing of Commonwealth of Ma Atty General Comments to ACRS at 890917 Meeting of Seabrook Subcommittee,Dukakis Statement Re Plant & M Black Rept Comparing Emergency Response Potential W/Other Plants.Related Correspondence ML20247B7851989-09-0606 September 1989 Acrs/Seabrook Station Emergency Planning.* Responds to ACRS Subcommittee 890817 Meeting Issues.Matl Info Not Disclosed by Parties Favoring Licensing of Plant & Matl Disclosed Presented in Misleading Manner.Related Correspondence ML20247B8201989-09-0505 September 1989 Emergency Planning.* Forwards Necnp Proposed Findings of Fact & Rulings of Law,Town of Hampton Brief,Governor Dukakis Statement & Proposed Findings, Sections 1 & 10.W/o Findings & Brief.Related Correspondence ML20247Q2611989-08-31031 August 1989 Forwards Notices of Appearance & Withdrawal of Appearance Filed on Behalf of Town of Salisbury,Per Request.W/ Certificate of Svc ML20247A3591989-08-28028 August 1989 Advises That Town of North Hampton Has Cooperated Fully W/ State Agencies for Emergency Disaster Response Planning Out of Obligation.Town Presently Judges Evacuation as Seriously Flawed & Deficient.W/Certificate of Svc.Served on 890907 ML20246F6111989-08-23023 August 1989 Clarifies Ambiguity in Commonwealth of Ma Atty General Jm Shannon Proposed Findings of Fact,Rulings of Law & Conclusions Re Seabrook Plan for Massachusetts Communities & Exercise Contentions ML19332C9971989-08-18018 August 1989 FOIA Request for Documents Re Low Power Testing for Plant ML20246E4661989-08-18018 August 1989 Advises That Commonwealth of Ma Atty General Ofc Objects to Illegal & Inadequate Notice Provided Re ACRS Subcommittee Meeting on 890817 Concerning Emergency Plans for Facility. Related Correspondence ML20247L8891989-08-18018 August 1989 Appeals Failure to Respond to 890731 Request for Documents Re Onsite Exercise ML20246E1671989-08-16016 August 1989 Advises That Commonwealth of Ma Atty General Ofc & Necnp Will File Response by 890818 to Applicant Application for Exemption from 10CFR50,App E,Section IV.F.1 for Licensee Onsite Emergency Plan Exercise Prior to Issuance of License ML20247L8731989-07-31031 July 1989 FOIA Request for Documents Including,But Not Limited to, Records Defined in 10CFR9.13 Re Sept 1989 Onsite Exercise for Plant ML20247D9681989-07-17017 July 1989 Emergency Planning Appeal (Oral Argument).* Advises That Author Will Represent Commonwealth of Ma at Oral Argument Scheduled on 890727.W/Certificate of Svc ML20247R2451989-07-12012 July 1989 Confirms Substance of 890711 Conversation Re State of Nh Independent Inquiry Into Circumstances Leading to Suspension of Low Power Testing at Facility ML20247N2311989-07-12012 July 1989 FOIA Request for pre-low Power Insp Rept,Readiness Assessment Team Rept,Low Power Insp Rept,Low Power Team Rept,Resident Inspector Insp Rept,Region I Inspector Insp rept,94.300 Ltr from Regional Director & Computer Programs ML20247A2281989-07-11011 July 1989 Requests NRC Intervention to Prevent Contamination of Properties & Threat to Life Caused by Operating Discharges from Plant to Town of Essex.Certificate of Svc Encl ML20247R2271989-06-30030 June 1989 Requests Access to Ongoing NRC Investigation of Circumstances Surrounding Shutdown of Low Power Testing of Facility ML20245J6991989-06-26026 June 1989 Advises That Author Will Represent Commonwealth of Ma Atty General Ofc at Oral Argument on 890712 ML20246J4601989-05-11011 May 1989 Forwards Petition for Review of Final Agency Action of NRC, Authorizing Issuance of Low Power License for Plant Operation Up to 5% of Rated Power,Filed in Us Court of Appeals.Related Correspondence ML20246H2931989-05-0909 May 1989 Revised Proposed Witness Schedule.* Forwards Revised Proposed Schedule After Receiving Several Responses to a Fierce .Related Correspondence ML20246H6891989-05-0404 May 1989 Proposed Witness Schedule.* Forwards Proposed Schedule for Remaining Witnesses on Spmc/Exercise Portion of Case.Related Correspondence ML20244C0831989-04-13013 April 1989 Advises That Author Will Present Oral Argument on Behalf of Intervenors Appellant at 890421 Oral Argument ML20248F3251989-03-31031 March 1989 Forwards Corrected Tables 4,5 & 6 to Testimony of Rl Goble, G Thompson & J Beyea Re Adequacy of Seabrook Plan for Commonwealth of Ma Communities Filed on 890221.Related Correspondence ML20247A7121989-03-24024 March 1989 Informal Discovery Request Re Mag EX-19.* Requests That NRC Provide Commonwealth of Ma W/Listed Addl Info Re June 1988 Exercise.Commonwealth Does Want to Question Perrotti by Deposition or cross-examination.Related Correspondence ML20247A7301989-03-23023 March 1989 Expresses Concern That Language in Documentation Re CLI-88-10 Unduly Limits Obligations of Applicant & Bonding Company in Event That Application for Full Power OL Withdrawn or Not Granted.Related Correspondence ML20236D8311989-03-16016 March 1989 Avdises That Parties Agreed to Begin Hearings Next Wk W/ Contentions Re Adequacy of Seabrook Plan for Commonwealth of Ma Communities Traffic Mgt Plan.Sequence Listed ML20236D7821989-03-14014 March 1989 Request for Depositions.* Discusses What Atty General Seeks to Question NRC Witnesses on Re June 1988 Plant Graded Exercise.W/Certificate of Svc.Related Correspondence ML20196F7851988-12-0202 December 1988 Advises That Commonwealth of Ma Atty General Ofc Established Encl Policy & Procedures to Ensure That Protected Info Received Re Plant Licensing Proceedings Not Disclosed to Unauthorized Persons ML20196F7611988-12-0202 December 1988 Discusses Impact of ALAB-903 on Exercise Litigation. Applicant Offered No Interpretation of ALAB-903 But Instead File Addl Written Response to Contentions.Reiterates Listed Points ML20206M9121988-11-21021 November 1988 Advises That Person Designated to Receive Copies of Proceedings Changed from Author to Breiseth at Stated Address ML20206C4891988-11-0909 November 1988 Forwards Corrected Attachment 1 to Motion of Commonwealth of Ma Atty General Jm Shannon Under 10CFR2.734 to Reopen Record to Consider Evidence Re Joint Applicant Decommissioning Plan for Plant.W/Certificate of Svc ML20206C4431988-11-0909 November 1988 Corrects Page 7,Footnote 10 to Answer of Commonwealth of Ma Atty General in Opposition to Applicant Motion for Summary Disposition of Joint Intervenor Contentions 44A & 44B to Read as Stated ML20205R4421988-11-0202 November 1988 Forwards Motions of Commonwealth of Ma Atty General to Reopen Record to Consider Evidence Re Applicant Decommissioning Plan & Financial Qualifications to Operate Plant & late-filed Contentions ML20205K2361988-10-27027 October 1988 Confirms 881027 Conversation Re NRC Motion to Compel Filed on 881012.NRC Has Agreed to Extend Time Until 881104 for Commonwealth of Ma to Respond to Motion.Related Correspondence ML20205F8371988-10-25025 October 1988 Requests That Recipient Advise Board & Author Whether & to What Extent Ruling on NRC Motion to Compel Answers to Interrogatories Required,Per NRC .Related Correspondence 1990-04-09 |
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Sherwin E. Turk, Esquire Office of General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 Re: NRC Staff Motion to Compel Answers to Interrogatories and Production of Documents by Town of Amesbury
Dear Sherwin:
Pursuant to the Staff's letter to the Board of October 14, 1988, please advise the Board and this office whether, and to what extent, a ruling on the Staff's motion to compel is required.
V ry truly yours, w _
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Matthew T. Brock l-MTB/jlr cc: Service list ,
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