ML20205D948: Difference between revisions
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P R O D t. U T I L. M . . . . | |||
COC K E ii' ? | |||
HARMON, CURRAN & TOUSLEY 2001 5 $TREET, N.W, SUITE 43o '88 TT 25 Pf :00 WA$lilNGTON, D.C. 20009 1125 Gall McGREEVY HARMO;* crr TELLPHONE DIANE CURRAN g' p - '(202) 328 )UN FAX DE AN R TOU5 LEY , | |||
ANDREA C. f tR5TER (202) 328-6918 ANNE SPitLBERG* | |||
' Admitted only in Penns3 tranta October 21, 1988 Ivan W. Smith, Chaimaan Dr. Jerry liarbour Gustave Linenberger Atomic Safety and Licensing Board U.S. liuclear Regulstory Commission Washington, D.C. 20555 | |||
==SUBJECT:== | |||
Seabrook operating license cases offsite enercency r>lannina_ issues Dear Administrative Judges I, an. enclosing copics of tiew England Coalition on lluclear Pol-lution's and Town of Hampton's Reply to Applicants' and NRC Staff's Responses to Contentions. TO!!/NECNP EX-2 and Toli/NEC!1P EX-1 In addition, please be advised that Ellyn R. Weiss has left this law firm and will no longer represent the New England Coali-tion on Nuclear Pollution in the Seabrook operating license pro-cooding. The name of the firm has also changed to "Itarmon, Curran | |||
& Tousley." | |||
Sincerely, S~ v.d Diano Curran f' I cc: service list : | |||
l 1 | |||
l l | |||
l hA G | |||
j l}} | |||
Latest revision as of 01:40, 30 December 2020
| ML20205D948 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/21/1988 |
| From: | Curran D HAMPTON, NH, HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | Harbour J, Linenberger G, Smith I Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20205D950 | List: |
| References | |
| CON-#488-7350 OL, NUDOCS 8810270263 | |
| Download: ML20205D948 (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:PUBLIC ENTITY/CITIZEN/ORGANIZATION/MEDIA TO NRC MONTHYEARML20059H2761990-08-29029 August 1990
[Table view]Advises That Intervenors Intend to Prepare & File Further Affidavit Re Emergency Motion to Reopen Record on Adequacy of Staffing of State of Nh Radiological Emergency Response Plan & for Immediate Shutdown.Svc List Encl ML20056B1721990-07-30030 July 1990 Advises That Director'S Decision DD-90-4 Nonresponsive & Noncompliant W/Provisions of 10CFR2.206 & Noncompliant W/ Aslab Memorandum & Order of 900123 for Stated Reasons ML20043C6771990-05-30030 May 1990 Informs That Author Will Be Unable to Attend 900605 Prehearing Conference in Concord,Nh.Counsel for Atty General of Commonwealth of Ma Will Represent Necnp Interests at Prehearing Conference ML20043G9871990-05-16016 May 1990 Advises That Author Established Network to Monitor Emissions from Plant.Mission Statement Outlining Objectives & Methodology of Network Encl.Nrc Will Be Added to Mail List ML20012E7661990-03-27027 March 1990 Advises That Seacoast Anti-Pollution League Has No Intention of Proceeding Further in Proceedings Before Appeal Board Due to Intervenor Inability to Justify Expense of Further Participation.Svc List Encl ML20012E7361990-03-25025 March 1990 Ack Offer to Answer Questions Re NRC Review of Numerous Requests for Relief by Util from Full Compliance W/Plant First 10-yr Inservice Insp Requirements & Submits Questions Re 900327 Ltr ML20012C6671990-03-15015 March 1990 Emergency Petition for Extension of Stay.* Forwards Notarized Copy of Rd Pollard Affidavit Supporting Emergency Petition for Extension of Stay Filed on 900314 ML20006G1201990-02-27027 February 1990 Requests Leave to File Encl Further Comments of Seacoast Anti-Pollution League Re Immediate Effectiveness of Licensing Authorization,Or in Alternative,In Support of Stay.Comments Directed to Substantial Change in State Plan ML20012A3051990-02-26026 February 1990 Requests Info Re What Blueprints,Plans,Diagrams & Catalogs Available to cross-ref Various Welds & Weld Locations at Unit 1 & Why Both Surface & Volumetric Weld Insps Required ML20011E6351990-02-0101 February 1990 Requests NRC Investigation of Allegation That Number of Keycards That Permit Entry to Protected Areas No Longer in Possession of Individuals to Whom They Were Issued ML20006F4391990-02-0101 February 1990 Readiness Review.* Requests Board to Consider Stated Written Views of Attachments to NRC 900108 & 09 Ltrs Due to Intervenors Not Receiving Documents Until Afternoon of 900118 & After Commission Meeting Ended.W/Related Info ML20006D8351990-02-0101 February 1990 Forwards Statement of Issues to Be Included in Seacoast Anti-Pollution League Brief in Support of LBP-89-32,in Response to 900131 Order ML20006D3131990-01-29029 January 1990 Forwards Revised Brief on Appeal of Partial Initial Decision on Spmc & 1988 FEMA-graded Exercise (LBP-89-32) to Include Portions of Transcript Cited in Brief as App ML20006B2381990-01-24024 January 1990 Forwards Seacoast Anti-Pollution League Brief in Support of Petitions for Review of LBP-89-32.Also Joins in Commonwealth of Ma 900122 Brief in Support of Appeal of LBP-89-38 ML20006B1851990-01-19019 January 1990 Forwards Opening Statement on Behalf of Seacoast Anti-Pollution League Re Offsite Emergency Planning & Safety Issues.Adequate Emergency Planning at Facility May Not Be Feasible & License Should Not Be Issued.Svc List Encl ML20006A2621990-01-18018 January 1990 Expresses Concern Re Safety of People That Live Near Plant on Basis That Plant Located in Densely Populated Coastal Area W/Predicted Seismic Activity & Inadequate Evacuation Routes.Plant Should Not Be Licensed ML20006A3141990-01-18018 January 1990 Readiness Review.* Discusses Number of Serious Potential Defects in Design & Const of Plant That Need to Be Addressed & Resolved Before Commission Concludes That Reactor Ready to Operate.Supporting Documentation Encl ML20006A2651990-01-17017 January 1990 Requests Time to Read Ltr at 900118 Hearing Re Facility to Express Concerns of Amesbury Religious Society of Friends, Including Serious Safety Issues & Location of Plant.W/ Certificate of Svc ML20006A2601990-01-17017 January 1990 Requests That Encl Ltrs Added to Transcript of 900118 NRC Hearing & Included in Records,Per Telcon.Served on 900123 ML20006A0681990-01-16016 January 1990 Requests Brief Opportunity to Address Commission at 900118 Meeting & Decries NRC Failure to Comply W/Govt in Sunshine Act in Scheduling Meetings on Plant OL Case w/1 Wk Notice ML20006A4231990-01-11011 January 1990 Forwards Town of Essex 890711 Ltr Requesting That Reactor Safety Issues Be Addressed & Resolved Prior to Licensing of Reactor,For Response.W/Certificate of Svc ML19351A6961989-12-0505 December 1989 Forwards Signature Page for Gc Minor Affidavit,Per Commonwealth of Ma Atty General 891201 Filing of Gc Minor & Sc Sholly Joint Affidavit in Support of Intervenors Application for Stay of LBP-89-32 ML19332F9351989-12-0404 December 1989 Forwards Corrected Title Page to 891121 Filing of Necnp Request for Stay of Immediate Effectiveness of LBP-89-32 Pending Resolution of Outstanding Licensing Issues.Original Had Incorrect Caption Directed to Attention of ASLB ML19332D8941989-11-22022 November 1989 Submits That Recipient 891117 Ltr on Commission Response to Senator Glenn Re Having No Communications W/Governor Sununu Re Plant Emergency Planning Insufficient.Fuller Response from Commissioner Roberts Warranted.Svc List Encl ML19332D7911989-11-21021 November 1989 Forwards Original Signature Page to Gc Minor & Sc Sholly 891117 Affidavit & Objection to No Significant Hazards Determination & Request for Hearing on Proposed Amend to Plant Low Power OL ML19332D5601989-11-17017 November 1989 Forwards Intervenors Motion to Reopen Record & Admit late-filed Contention Re Proposed Amend of Facility Ol,Application,For Filing.Original Signature Page to Affidavit Will Be Forwarded ML19354D5341989-11-0808 November 1989 Requests Determination of Commissioner Roberts Intentions,If Any,To Abstain from Voting on Matters Pending Before Commission Re Adquacy of Emergency Planning at Plant Due to Conflict of Interest.Related Info & Svc List Encl ML19327B7441989-10-21021 October 1989 Expresses Concern Re Financial Status of Util When Judging Ability to Safely Operate Facility.Residents Around Facility Need More than Reasonable Assurance That Operations Will Be Consistent W/Public Health & Safety ML20248D1041989-09-26026 September 1989 Forwards Response to Commission 890822 Order & New England Electric Sys Form 10-Q for Quarter Ending 890630 in Support of Part III of Response Re Insufficient Funding for Operating Plant ML20247Q6781989-09-22022 September 1989 Objects,For Record,Applicant 890920 Motion to Strike Seacoast Anti-Pollution League (Sapl) Response to Aslab 890830 Order.Sapl Response Considered within Framework Intended by Aslab.W/Certificate of Svc ML20247M0731989-09-18018 September 1989 Forwards Corrected Seacoast Anti-Pollution League 890915 Response in Accordance W/Aslab Order of 890830,making Typo & Grammatical Changes ML20247B5591989-09-0606 September 1989 Forwards Seacoast Anti-Pollution League Comments Re ACRS Seabrook Subcommittee 890817 Meeting.Issues Re Plant Not Fully Functional SPDS & Untested Siren Warning Sys Also Discussed.Related Correspondence ML20247A1071989-09-0606 September 1989 Emergency Planning.* Provides Info Re Problem of Summer Beach Population in Plant Area Resorts Not Being Protected During Radiological Emergency.Related Correspondence ML20246F5721989-08-23023 August 1989 ACRS Meeting/Seabrook Nuclear Power Plant.* Advises That Seacoast Anti-Pollution League Joins in Commonwealth of Ma Atty General & Requests Reopened ACRS Subcommitee Meeting W/Opportunity to Be Heard.Related Correspondence ML20246J5491989-08-22022 August 1989 Requests That Augmented Insp Team Insp Rept Be Revised to Include Encl Addl Info ML20246E2891989-08-21021 August 1989 Expresses Appreciation for Opportunity to Address ACRS Subcommittee on Facility at 890817 Meeting.Believes ACRS Failure to Provide Licensee W/Timely Notice of Subj Meeting Unfair.Related Correspondence ML20247A1971989-08-11011 August 1989 Forwards Aerial Photos Submitted as Visual Evidence Supporting Town of Essex,Ma Selectmen Contention That Plant Siting Will Contaminate Marshes.Served on 890907 ML20248E0021989-08-0202 August 1989 OL Case:Offsite Emergency Planning Issues.* Advises That Necnp Does Not Intend to File Proposed Findings & Conclusions of Law Re Spmc or Offsite Emergency Plannning Exercise ML20248E0401989-08-0202 August 1989 Emergency Planning Appeal.* Clarifies Understanding Re History of Contentions on Reception Ctrs & Board Rulings on Litigability of Size of EPZ Population Attending Reception,Per 890727 Oral Argument.Supporting Info Encl ML20247B1511989-07-17017 July 1989 Advises That Author Will Attend Argument Scheduled for 890727 & Present Argument on Behalf of Appellant,Seacoast Anti-Pollution League,Per ASLB 890711 Order.W/Svc List ML20247B7731989-07-13013 July 1989 Emergency Planning Appeal.* Advises That Author Will Argue on Behalf of Necnp at 890727 Oral Argument ML20247B3771989-07-11011 July 1989 Advises That Seacoast Anti-Pollution League Has No Intention of Participating in 890712 Oral Argument,But Will Stand Final Brief Filed W/Aslab on 890413.Svc List Encl ML20246A8241989-07-11011 July 1989 FOIA Request for Records on 890623 Telcon Between EA Brown & Tt Martin Re Confirmatory Action Ltr CAL-89-11 ML20248J3691989-06-30030 June 1989 Forwards to Judge Smith & Documents for Inclusion in Records of Licensing Proceedings for Plant,Per 890629 Instruction ML20248J3721989-06-29029 June 1989 Urges That Commission Decision on Whether People Can Be Evacuated Safely in Event of Nuclear Accident at Plant Not Be Made W/O Reviewing Encl Documents & Testimony.Certificate of Svc Encl ML20244D3881989-06-0808 June 1989 Forwards Reply Brief Addressing Applicant & NRC Briefs on Issues Pending Before Appeal Board.Expedition of Oral Argument & for Argument to Held in State of Nh Requested.W/O Stated Encl ML20246H4691989-05-0808 May 1989 Forwards Testimony Demonstrating That Plant Built Using Conterfeit,Defective Components & Enumerating Other Safety Violations.W/Certificate of Svc.Served on 890510 ML20245E6261989-04-21021 April 1989 Forwards Objection to NRC Motion to Strike Notices of Appeal ML20244C1031989-04-11011 April 1989 OL Case:Offsite Emergency Planning Issues.* Advises That New England Coalition on Nuclear Pollution (Necnp) Has co-sponsored,but Will Not Help Present Commonwealth of Ma Testimony Re Necnp & Town of Hampton Joint Contentions ML20244B7381989-04-0808 April 1989 Urges Commission to Issue Low Power License for Plant,Per CLI-88-10.Certificate of Svc Encl.Served on 890419 1990-08-29 |
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HARMON, CURRAN & TOUSLEY 2001 5 $TREET, N.W, SUITE 43o '88 TT 25 Pf :00 WA$lilNGTON, D.C. 20009 1125 Gall McGREEVY HARMO;* crr TELLPHONE DIANE CURRAN g' p - '(202) 328 )UN FAX DE AN R TOU5 LEY ,
ANDREA C. f tR5TER (202) 328-6918 ANNE SPitLBERG*
' Admitted only in Penns3 tranta October 21, 1988 Ivan W. Smith, Chaimaan Dr. Jerry liarbour Gustave Linenberger Atomic Safety and Licensing Board U.S. liuclear Regulstory Commission Washington, D.C. 20555
SUBJECT:
Seabrook operating license cases offsite enercency r>lannina_ issues Dear Administrative Judges I, an. enclosing copics of tiew England Coalition on lluclear Pol-lution's and Town of Hampton's Reply to Applicants' and NRC Staff's Responses to Contentions. TO!!/NECNP EX-2 and Toli/NEC!1P EX-1 In addition, please be advised that Ellyn R. Weiss has left this law firm and will no longer represent the New England Coali-tion on Nuclear Pollution in the Seabrook operating license pro-cooding. The name of the firm has also changed to "Itarmon, Curran
& Tousley."
Sincerely, S~ v.d Diano Curran f' I cc: service list :
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