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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20066A3931990-12-26026 December 1990 Commonwealth of Ma Atty General Response to Licensee First Set of Interrogatories Re Remanded Massachussetts Teacher Issues.W/Certificate of Svc.Related Correspondence ML20065T9551990-12-10010 December 1990 Licensee First Set of Interrogatories & First Request for Production of Documents to Commonwealth of Ma Atty General Re Remanded Massachusetts Teacher Issues.* W/Certificate of Svc.Related Correspondence ML20246H7051989-05-0505 May 1989 Applicant Supplementary Response to Intervenors Discovery Requests.* Certificate of Svc Encl.Related Correspondence ML20245E6531989-04-21021 April 1989 Commonwealth of Ma Atty General Supplemental Answer to Applicant Expert Witness Interrogatories.* Prof Qualifications of Expert Witnesses Encl.W/Certificate of Svc.Related Correspondence ML20248F8531989-04-0303 April 1989 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 ML20248F6691989-04-0303 April 1989 Applicant Supplemental Answers to Commonwealth of Ma Atty General Expert Witness Interrogatory.* Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20247A5721989-03-24024 March 1989 Applicant Voluntary Responses to Commonwealth of Ma Atty General Interrogatories & Request for Production of Documents That Pertain to Exercise Areas Requiring Corrective....* W/Certificate of Svc.Related Correspondence ML20247A5921989-03-24024 March 1989 Applicant Voluntary Responses to Commonwealth of Ma Atty General Requests for Documents & Info on Exercise.* W/ Certificate of Svc.Related Correspondence ML20236D5001989-03-16016 March 1989 NRC Staff Further Supplemental Response to Town of Hampton First Set of Interrogatories & Request for Production of Documents to NRC Staff on 880628-29 Exercise (Exercise).* Certificate of Svc Encl.Related Correspondence ML20236C2161989-03-10010 March 1989 NRC Staff Supplemental Response to Town of Hampton First Set of Interrogatories & Request for Production of Documents to NRC Staff on 880628-29 Exercise.* W/Certificate of Svc. Related Correspondence ML20236C3901989-03-0808 March 1989 NRC Staff Supplemental Response to Town of Amesbury First Set of Interrogatories & Request for Production of Documents to NRC on Seabrook Plan for Commonwealth of Ma Communities (Spmc).* W/Certificate of Svc.Related Correspondence ML20236A4311989-03-0707 March 1989 Applicant Supplemental Answers to Intervenors Interrogatories Re Transportation Resources.* Supporting Info & Certificate of Svc Encl.Related Correspondence ML20235V6971989-02-28028 February 1989 Applicant Supplemental Answers to Intervenor Expert Witness Interrogatories.* Certificate of Svc Encl.Related Correspondence ML20235N1821989-02-21021 February 1989 FEMA Responses to Town of Hampton First Set of Interrogatories & Request for Production of Documents to FEMA on 880628-29 Exercise.* W/Certificate of Svc.Related Correspondence ML20206M9271988-11-22022 November 1988 Town of West Newbury Response to NRC Staff Motion to Compel Answers to Interrogatories & Production of Documents by Town of West Newbury.* Certificate of Svc Encl ML20206M9461988-11-22022 November 1988 Responses of FEMA to Town of Amesbury First Set of Interrogatories & Request for Production of Documents to FEMA on Seabrook Plan for Commonwealth of Ma Communities.* W/Certificate of Svc.Related Correspondence ML20206J8331988-11-21021 November 1988 New England Coalition on Nuclear Pollution Second Set of Supplemental Answers to Applicant First Set of Interrogatories Etc & Answers to Applicant Interrogatories & Request For....* Svc List Encl.Related Correspondence ML20206J6811988-11-15015 November 1988 Answers of Commonwealth of Ma Atty General to Applicant Request for Admissions to Commonwealth of Ma Atty General.* Certificate of Svc Encl.Related Correspondence ML20206J6581988-11-15015 November 1988 Joint Intervenors Answers to Applicant Request for Admissions to Intervenors.* Related Correspondence ML20206J6381988-11-15015 November 1988 Commonwealth of Ma Atty General Response to Applicant Second Request for Protection of Documents.* Atty General Will Produce Response Documents from Agencies Listed in Response 2.Related Correspondence ML20206J8691988-11-15015 November 1988 Applicant Response to Commonwealth of Ma Atty General Second Request for Production of Documents to Applicant Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl.Related Correspondence ML20206C5561988-11-11011 November 1988 Seacoast Anti-Pollution League Response to Applicant Second Request for Production of Documents to All Intervenor & Participating Local Govts Concerning Joint Intervenor Contentions.* Svc List Encl.Related Correspondence ML20206C5641988-11-0707 November 1988 Applicant Response to Town of Amesbury First Request for Production of Documents to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl. Related Correspondence ML20206C2611988-11-0404 November 1988 Responses of FEMA to Commonwealth of Ma Atty General First Request for Production of Documents to FEMA Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl.Related Correspondence ML20205R7461988-11-0404 November 1988 Errata to Applicant Response to Town of Amesbury First Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* W/Certificate of Svc. Related Correspondence ML20205R6901988-11-0404 November 1988 Errata to Applicant Response to Commonwealth of Ma Atty General First Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* W/ Certificate of Svc.Related Correspondence ML20205R5781988-11-0303 November 1988 Applicant Response to Commonwealth of Ma Atty General First Request for Production of Documents to Applicant Re Seabrook Plan for Commonwealth of Ma Communities.* W/Certificate of Svc.Related Correspondence ML20205R6541988-11-0202 November 1988 Town of Ambesbury Response to Applicant Second Request for Production of Documents to All Intervenors & Participating Local Govts Concerning Joint Intervenor Contentions.* W/ Related Info & Certificate of Svc.Related Correspondence ML20205R5621988-11-0101 November 1988 Applicant Response to Commonwealth of Ma (Mass Ag) Second Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* W/Certificate of Svc. Related Correspondence ML20205N3061988-10-31031 October 1988 New England Coalition on Nuclear Pollution Supplemental Answers to Applicant First Set of Interrogatories,Etc & Answers to Applicant Interrogatories & Request for Production Of....* W/Svc List.Related Correspondence ML20205N3351988-10-31031 October 1988 Town of West Newbury Supplemental Answers to Applicant First Set of Interrogatories & First Request for Production of Documents to All Parties & Participating Local Govts Re Contentions.* W/Certificate of Svc.Related Correspondence ML20205N3681988-10-27027 October 1988 Seacoast Anti-Pollution League Response to Applicant Interrogatories & Request for Production of Documents to All Intervenors & Participating Local Govts Concerning Joint Intervenor....* W/Svc List.Related Correspondence ML20205F9561988-10-26026 October 1988 Commonwealth of Ma Atty General Jm Shannon Answers & Responses to NRC Staff Second Set of Interrogatories & Second Request for Documents.* Notice of Depositions & Certificate of Svc Encl.Related Correspondence ML20205K2331988-10-26026 October 1988 NRC Staff Response to Town of Amesbury First Set of Interrogatories & Request for Production of Documents to NRC on Seabrook Plan for Commonwealth of Ma Communities.* W/ Certificate of Svc.Related Correspondence ML20205F8001988-10-25025 October 1988 Seacoast Anti-Pollution League Supplemental Answer to Applicant First Set of Interrogatories,Per Board Orders of 881018 & 19.* Supporting Documentation & Svc List Encl. Related Correspondence ML20205F7541988-10-25025 October 1988 Town of Amesbury First Suppl to NRC Staff First Set of Interrogatories & First Request for Production of Documents to Towns of Amesbury,Newbury,Salisbury,West Newbury & Merrimac & City of Newburyport.* Certificate of Svc Encl ML20205K4191988-10-25025 October 1988 Applicant Response to Commonwealth of Ma Atty General First Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20205F9931988-10-25025 October 1988 Response of Commonwealth of Ma Atty General to NRC Staff Third Set of Interrrogatories & Request for Production.* Certificate of Svc Encl ML20205G0351988-10-24024 October 1988 Applicant Response to Town of Amesbury First Set of Interrogatories...To Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Supporting Info & Certificate of Svc Encl.Related Correspondence ML20205E3571988-10-24024 October 1988 Commonwealth of Ma Atty General Supplemental Response to NRC Staff First Set of Interrogatories & First Request for Documents.* Certificate of Svc Encl.Related Correspondence ML20205D7771988-10-19019 October 1988 Commonwealth of Ma Atty General Second Request for Production of Documents to Applicant Re Seabrook Plan for Commonwealth of Ma Communities.* Related Correspondence ML20205D6951988-10-19019 October 1988 Commonwealth of Ma Atty General Second Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Related Correspondence ML20205D8101988-10-19019 October 1988 Commonwealth of Ma Atty General First Request for Production Documents to FEMA Re Seabrook Plan for Commonwealth of Ma Communities.* W/Notice of Deposition of R Donovan on 881109 & Certificate of Svc.Related Correspondence ML20205D7401988-10-14014 October 1988 Applicant Interrogatories & Request for Production of Documents to All Intervenors & Participating Local Govts Concerning Joint Intervenor Contentions 6 & 27-63.* W/Certificate of Svc.Related Correspondence ML20204F9541988-10-14014 October 1988 Applicant Second Request for Production of Documents to All Intervenors & Participating Local Govts Concerning Joint Intervenor Contentions.* Certificate of Svc Encl.Related Correspondence ML20155H4241988-10-11011 October 1988 Applicant Interrogatories & Request for Production of Documents to All Intervenors & Participating Local Govts Concerning Joint Intervenor Contentions 1-26.* Certificate of Svc Encl.Related Correspondence ML20155H3181988-10-0707 October 1988 Commonwealth of Ma Atty General Supplemental Responses to Applicant First Set of Interrogatories.* Certificate of Svc Encl.Related Correspondence ML20155H3111988-10-0707 October 1988 Commonwealth of Ma Atty General First Set of Interrogatories to Applicant on Seabrook Plan for Commonwealth of Ma Communities.* Related Correspondence ML20155H0081988-10-0606 October 1988 Town of Amesbury Interrogatories & Request for Production of Documents to FEMA on Seabrook Plan for Commonwealth of Ma Communities (Spmc).* Certificate of Svc Encl.Related Correspondence ML20204G5731988-10-0606 October 1988 NRC Staff Third Set of Interrogatories & Request for Production of Documents to Towns of Amesbury,Newbury, Salisbury,West Newbury & Merrimac & City of Newburyport....* W/Certificate of Svc.Related Correspondence 1990-12-26
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
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DOCKETED RELATED CORHESPONDE.NQ USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'E3 JL 29 MC 31
'~
ATOMIC SAFETY AND LICENSING BOARD
{
Before Administrative Judges:
Sheldon J. Wolfe, Chairman Emmeth A. Luebke Dr. Jerry Harbour
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket No.(s)
NEW HAMPSHIRE, ET AL. ) 50-443/444-OL-1 (Seabrook Station, Units 1 and 2) ) On-site EP
) July 26, 1988
)
RESPONSE OF MASSACHUSETTS ATTORNEY GENERAL TO APPLICANTS' FIRST REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING AMENDED CONTENTION ON NOTIFICATION SYSTEM Pursuant to 10 C.F.R. S 2.741(d), the Massachusetts Attorney General ("Mass AG") responds to the Applicants' First Request for Production of Documents as follows:
INTRODUCTION On July 12, 1988 the Mass AG filed his response to the Applicants' First Set of Interrogatories on the notification system contention. Some of the interrogatories requested the identity and production of certain documents. The Mass AG incorporates herein objections and responses to those 8808090070 880726 '
PDR ADOCK 05000443 O PDR Ob
.. - - - - - - - - )
interrogatories as if set forth in this response and answers herein those portions of the interrogatories requesting the production / identification of documents. The Mass AG will not produce the numerous documents which come within the scope of the Applicants' requests which were prepared by the Applicants or are within their possession as part of the docket of this proceeding.
PRIVILEGED DOCUMENTS The Mass AG objects to indicating the substance of privileged documents as requested by the Applicants to the extent that it would reveal information otherwise protected.
The following documents are protected from disclosure by 10 C.F.R. S 2.740(b)(2).
- 1. a) March 11, 1988 b) Stephen A. Jonas c) Gregory C. Tocci, Cavanaugh & Tocci Associates, Inc.
d) No title e) 1 f) Letter concerning Amesbury Zoning By-Law
- 2. a) April 5, 1988 and April 4, 1988 letter and attached memo respectively b) Mr. Tocci and Tom Bouliane, respectively c) Mr. Jonas and Mr. Tocci, respectively d) No titles e) 1 and 7, respectively f) The letter encloses and describes the attached memorandum which consists of Mr. Bouliane's comments on "Enclosure to NYN-88025" issued February 26, 1988 by NHY.
- 3. a) May 5, 1988 b) Mr. Tocci c) Mr. Jonas d) No title e) 2
'f) Letter to Mass AG regarding possible hearing damage from VANS siren sound levels.
- 4. a) April 29, 1988 b) Joseph Sataloff, M.D.
c) Mr. Bouliane d) No title e) 1 f) Letter regarding possible hearing damage from VANS siren sound levols
- 5. a) May 19, 1988 b) Mr. Bouliane c) Mr. Jonas d) No title e) 4 f) Letter to Mass AG regarding speech intelligibility from VANS loudspeaking system. Attachment, Manufacturers data sheets from Altec Lansing Corp.,
Electro-Voice and JBL have been produced to Applicants.
4
- 6. a) July-7, 1988 and July 8, 1988 b) Nancy Mason, Investigator, Mass AG c) No address d) No title e) 5 f) Notes of conservations with individuals identified in Mass AG response to Applicants' Interrogatory No. 3.
- 7. a) April 25, 1988 b) Mr. Bouliane c) Dr. Sataloff, cc: Mr. Jonas d) No Title e) 1 f) Request for consulting services and a one page background memo from Cavanaugh Tocci on the VANS system with enclosures of VANS material generated by NHY
- 8. a) April 8, 1988 b) Mr. Bouliane c) Mr. Jonas d) No Title e) 1 f) Letter to Mass AG re: NYN-88042, Encosure 1 to NYN-89042 and~ Enclosure 2 to NYN-89042
- 9. a) December 31, 1987 b) Mr. Tocci c) No addressee d) Affidavit of Gregory C. Tocci e) 15 f) Draft affidavit to NRC Appeal Board re: helicopter system for Newburyport wi&.h single page of handwritten notes attached
-4 -
i o
- 10. a) December 21 and 20, 1987 respectively-b) Mr. Bouliane c) Mr. Tocci
.d) No title; Preliminary Report, Review of "Alternate.
Alerting System Design Description for the City of Newburyport, Massachusetts" issued December 9, 1987 by New Hampshire Yankee, respectively e)-1, 8 respectively f) Letter regarding report and report, respectively
- 11. a) Undated b) No author c) Mr. Tocci d) No title e) 1 f) Notes from conversation with Ken Eldred on acoustical consultant in Concord, MA re: aircraft noise levels published by FAA .4dvisory Circular 36-lD
- 12. a) Undated b) No author c) No addressee d) No title e) 1 f) Notes on helicopter coverage
- 13. a) See below b) No author c) No addressee d) No title e) 2 f) Notes in Cavanaugh Tocci Mass AG file relating to sound levels at mileages from plant
- 14. a) See below b) No author c) No addressee d) No title e) 14 f) 6 sets of notes in Cavanaugh Tocci Mass AG file:
notes re: conversation with representative of Applied Electro Mechanics, Inc.; notes dated November 11, 1987 attaching Speech Reception and Information report from Tech Topics Vol. 5, No. 12 (July, 1987) (which has been-produced); notes re:
helicopter system loudness and NHY.12/6/87 Report; notes re: conversation with representative of Whelen Engineering Co. Inc. on 12/18/87; and 2 sets of notes with calculations DOCUMENT REOUESTS
- 1. With respect to the Mass. AG's answers to each of the interrogatories 6 - 46 that follow, is that answer based upon reference to or knowledge of the existence of one or mort +
documents? If so, please:
(a) Identify each such document on which the answer is based.
(b) Identify the information in each document on which the answer is based.
(c) Identify all documents possessed by or known to exist by the Mass AG which deal with the same subject matter.
(d) Produce all identified documents.
RESPONSE 1: The Mass AG objects to Request No. 1 as overly broad and seeking material not relevant to the subject matter of these proceedings and protected trial preparation materials under 10 C.F.R. S 2.740(b)(2). Without waiving this objection, the Mass AG will produce all relevant, discoverable and non-privileged documents on which the answers to the interrogatories are based, i
1
- 2. With respect to the Mass AG's answers to each of the interrogatories 6 - 46 that follow, is that answer based upon any type of study, calculation, procedure, method, instruction, assumption, conclusion, recommendation or analysis?- If so, please:
(a) Describe the nature of the study, calculation, procedure, method, instruction, assumption, conclusion, recommendation or analysis.
(b) Identify and produce any documents that constitute, discuss or describe it.
(c) Identify the person (s) who performed it, including the institutional affiliation and professional qualifications, if any, of the person (s).
(d) ' State when and where it was prepared or performed.
(e) Describe in detail the information or data that was 1 examined.
(f) Describe the results. ,
(g) Explain how it provides a basis for the answer.
RESPONSE 2: The Mass AG objects to Request No. 2 as overly broad, and seeking information not relevant to the subject matter of these proceedings and protected trial preparation materials under 10 C.F.R. S 2.740(b)(2). Without waiving this objection, the Mass AG will produce all relevant, discoverable and non-privileged documents responsive to Request No. 2.
- 3. With respect to the Mass. AG's answers to each of the interrogatories 6 - 46 that follow, is that answer based upon conversations, consultations, correspondence or any other type of communication with one or more individuals or entities? If so, please:
(a) Identify each such individual or entity.
(b) State the educational and professional background of each such individual, including occupation and institutional affiliates.
9 (c) Describe the nature of each communication with each such individual or entity, when it occurred, and identify
, all other individuals or entities involved.
(d) Describe in detail the information received from each such individual or entity, and explain how it provides a basis for the answer.
(e) Identify and produce each letter, memorandum, contract, tape, note or other document related to each conversation, correspondence, or other communication with such individual or entity.
RESPONSE 3: The Mass AG objects to Request No. 3 as overly broad and seeking information not relevant to the subject matter of these proceedings and protected trial preparation materials under 10 C.F.R. S 2.740(b)(2). Without waiving this objection, the Mass AG adds to its prior interrogatory answer by stating that Cavanaugh Tocci, in performing its consulting services, has had communications with Dr. Sataloff (see above),
Ken Eldred, and representatives of Applied Electro Mechanics, Inc. and Whelen Engineering Co., Inc.
- 4. Does the Mass AG intend to offer the testimony of any expert witness with respect to the Amended Contention on Notification System? If so, please:
(a) Identify each expert witness whom the Mass AG intends to present with respect to this contention.
(b) State the substance of the facts to which each expert witness is expected to testify.
(c) State the substance of the opinion or opinions to which each expert witness is expected to testify.
(d) Provide a summary of the grounds for each opinion to which each expert witness is expected to testify.
(e) State whether the facts and opinions listed in response to the foregoing are contained in any written report, memoranda, calculation, analysis or other transcript, and, if so, whether the Mass AG is willing to produce the same without the necessity of a notice to produce.
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s (f) State whether the opinion of any expert witness is based in whole or in part on any scientific rule or principle, and, if so, set forth_such rule or principle.
(g) State whether the opinion of any expert witness is based in whole or in part on any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon.
(h) State whether the opinion of any expert witness is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.
RESEQHSE_4: Witnesses have not been selected.
- 5. Does the Mass AG intend to offer the testimony of any non-expert witness with respect to the Amended Contention on Notification System? If so, please:
(a) Identify each non-expert witness whom the Mass AG intends to present with respect to this contention.
(b) State the substance of the facts to which each nonexpert witness is expected to testify.
(c) State the substance of the opinion or opinions to which each non-expert witness is expected to testify.
(d) provide a summary of the grounds for each opinion to which each non-expert witness is expected to testify, (e) State whether the facts and opinions listed in response to the foregoing are contained in any written report, memoranda, or other transcript, and, if so, whether the Mass AG is willing to produce the same without the necessity of a request to produce.
(f) State whether the opinion of any non-expert witness is based in whole or in p'rt a on any scientific rule or principle, and, if so, set forth such rule or principle.
l (g) State whether the opinion of any non-expert witness is l based in whole or in part on any code or regulation, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon.
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i (h) State whether the opinion of any non-expert witness is based in whole or in part upon any scientific or engineering book or other publication, and, if so, identify the book or publication.
RESPONSE 5: Witnesses have not been relected.
- 6. Has any representative of or person employed by the Department of the Attorney General of the Commonwealth been in contact with any selectman, civil defense director or other official of Amesbury, Merrimack, Newbury, West Newbury, Newburyport, Salisbury or Haverhill concerning any actual or proposed siren warning system for Seabrook Station? If so, please:
(a) Identify each selectman, civil defense director or other official who was contacted, and the official, representative, or employee who contacted them.
(b) Describe in detail the date, time, manner, place, and substance of the communication, c) Identify and produce every document that reflects, refers to, or relates in any way to any such contact.
RESpOESE 6: The Mass AG objects to Interrogatory No. 6 because, in light of ALAB-883 and the scope of the Mass AG Amended Contention on Notification System, the interrogatory seeks information not relevant to the subject matter of this proceeding.
- 7. Has any other official, representative, or employee of the government of the Commonwealth of Massachusetts been in contact with any selectman, civil defense director or other official of Amesbury, Merrimack, Newbury, West Newbury, Newburyport, Salisbury or Haverhill concerning any actual or proposed siren warning system for Seabrook Station? If so, please:
(a) Identify each selectman, civil defense director or other official who was contacted, and the official, representative, or employee who contacted them.
(b) Describe in detail the date, time, manner, place, and substance of the communication, (c) Identify and produce every document that reflects, refers to, or relates in any way to any such contact.
f
RESPONSE 7: The Mass AG objects to Interrogatory No. 7 because, in light of ALAB-883 and the scope of the Mass AG Amended Contention on notification system, the interrogatory seeks information not relevant to the subject matter of this proceeding.
- 26. Is it the assertion of the Mass AG that a "large" "dispersion angle" would cause more "sound irregularities" than a smaller "dispersion angle"?
(a) If so, please:
(i) state all the facts underlying this assertion, and explain exactly how those facts support the assertion; (ii) identify all persons with whom the Mass AG consulted in developing the assertion, and state the substance of each person's input on the assertion; (iii) identify and produce all documents consulted or relied upon by the Mass AG, or by persons consulted by the Mass AG, in developing the assertion.
( b .' If not, please:
(i) state all the facts underlying this answer, and explain exactly how those facts support the answer; (ii) identify all persons with whom the Mass AG consulted in developing the answer, and state the substance of each person's input on the answer; (iii) identify and produce all documents consulted or relied upon by the Mass AG, or by persons consulted by the Mass AG, in developing the answer.
RESPONSE 26: The Mass AG objects to Request No. 26 as seeking protected trial preparation materials under 10 C.F.R.
S 2.740(b)(2).
- 42. please list and produce all documents possessed by the government of the Commonwealth of Massachusetts or any department, agency, office, commission, authority, official,
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4 employee or representative thereof that reflect, refer to, or relate in any way to any emergency warning sirens installed or contemplated within the Commonwealth of Massachusetts, other than sirens installed by public Service Company of New llamps hi re .
RESEONSE 42: The Mass AG objects to this request as seeking material not relevant to the subject matter of this proceeding. Without waiving this objection, the Mass AG states that no emergency warning sirens in the Commonwealth are installed or contemplated for use in an emergency at Seabrook Station.
- 44. Please identify.and produce all documents consulted or relied upon by the Mass AG, or by any individuals assisting the Mass AG, in preparing the Amended Contention on Notification System.
RESPONSE 41: The Mass AG objects to this request in that it seeks protected trial preparation materials under 10 C.F.R.
2.740(b)(2). Without waiving this objection, the Mass AG will produce all relevant, discoverable and non-privileged documents within the scope of this request.
- 45. Please list, identify the source (including prepacer's name, institutional affiliation and professional qualifications, if any) of, and produce, all studies, tests analyses, procedures, methods, instructions, conclusions, recommendations, computer runs or similar scientific reviews, prepared for or possessed by the Mass AG, and all assumptions and data used therein, relating to:
(a) siren and/or voice mode emergency notification systems; (b) sound and/or ambient noise levels in any areas where emergency planning for Seabrook Station is required; I t
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4 (c) acoustic range models or analyses; (d) road blockage or traffic interruption in connection with the VANS system; (e) meteorological conditions, including but not limited to wind speeds, temperature and precipitation, in connection with the VANS system.
RESPONSE 45: The Mass AG objects to this request in that it seeks protected trial preparation materials under 10 C.F.R.
2.740(b)(2). Without waiving this objection, the Mass AG states that it will produce all discoverable and non-privileged documents within the scope of (a), (b), and (c) of this request. No such documents exist for (d) and (e).
The Mass AG moves for a protective order from this Board that the discovery requested by the Applicants to which the Mass AG objects not be had.
Respectfully submitted, JAMES M. SHANNON ATTORNEY GENERAL
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Stefhen A.dT'nas o
Deputy Chief Public Protection Bureau One Ashburton Place Boston, MA 02108 617-727-2200 Date: July 26, 1988
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!c UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Nh [
18 Ja. 29 A10:11 In the Matter of ) (([f[7 $[$,j'y 7
) SRANDi PUBLIC SERVICE COMPANY OF NEW ) Docket No.(s) 50-443/444-OL-1 HAMPSHIRE, et al. )
(Seabrook Station, Units 1 and 2) )
)
)
CERTIFICATE OF SERVICE I, Stephen A. Jonas, hereby certify that on July 26, 1988, I made service of the Nithin Response of Massachusetts Attorney Genera) to
- Applicants' First Request for Production of Documents Regarding Amended Contention on Notification System, by mailing copies thereof, postage prepaid, by first class mail, or by hand delivery as indicated by (*) to
Sheldon J. Wolfe, Chairperson Dr. Emmeth A. Luebke Atomic Safety & Licensing Board 5500 Friendship Boulevard U.S. Nuclear Regulatory Apartment 1923N Commission Chevy Chase, MD 20815 East West Towers Building 4350 East West Highwr.y Bethesda, MD 20814 Dr. Jerr/ Harbour Sherwin E. Turk, Esq.
Atomic Safety & Licenaing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Office of General Counsel Commission 1717 H Street East West Towers Building Washington, DC 20555
~4350 East West Highway Third Floor Mailroom Bethesda, MD 20814 H. Joseph Flynn, Esq. Stephen E. Herrill Assistant General Counsel Attorney Getieral Office of General Counsel George Dana Bisbee Federal Emergency Management Assistant Attorney General Agency Office of the Attorney Jeneral 500 C Street, S.W. 25 Capitol Street Washington, DC 20472 Concord, NH 03301
Docketing and Service Paul A. Fritzsche, Esq.
U.S. Nuclear Regulatory Office of the Public Advocate
' Commission State House Station 112 Washington, DC. 20555 Augusta, ME 04333 Roberta C. Pevear Ms. Diana P. Randall State Representative 70 Collins Street Town of Hampton Falls Seabrook, NH 03874 Drinkwater-Road' Hampton Falls, NH 03844 Atomic Safety & Licensing Robert A. Backus, Esq.
Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.S. Nuclear Regulatory 5 Market Street Commission Portsmouth, NH 03801 Washington, DC 20555 Matthew T. Brock, Esq. Mr. J. P. Nadeau Shaines & McEachern Board of Selectmen 25 Maplewood Avenue 10 Central Road P.O. Box 360 Rye, NH 03870 Portsmouth, NH 03801 Ms. Sandra Gavutis, Chairperson Mr. Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E. Kingston, NH 03827 Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. Angelo Machiros, Chairman U.S. Senate Board of Selectmen Washington, DC 20510 25 High Road (Attn: Tom Burack) Newbury, MA 10950 Senator Gordon J. Humphrey Edward Molin 1 Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Donald E. Chick Mr. William Lord Town Manager Board of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amesbury, MA 01913 r, ,
i Brentwood Board of Selectmen Gary W. Holmes, Esq.
RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH 03841 philip Ahrens, Esq. Ellyn Weiss, Esq.
Assistant Attorney General Harmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W.
State House Station #6 Washington, DC 20009 Augusta, ME 04333
- Kathryn Selleck, Esq. Richard A. Hampe, Esq.
Thomas G. Dignan, Esq. Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth Ashad A. Ashod, Esq.
209 Winnacunnet Road 376 Main Street Hampton, NH 03842 Haverhill, MA 01830 William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2 10 Front Street South Hampton, NH 03827 Exeter, NH 03833 Robert Carrigg, Chairman Mrs. Anne E. Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-15 Newmarket Road Atlantic Avenue Durham, NH 03824 North Hampton, NH 03862 Allen Lampert Ivan W. Smith, Chairman Civil Defense Director Atomic Safety and Licensing Town of Brentwood Board panel 20 Franklin Street U.S. Nuclear Regulatory Commission Exeter, NH 03833 Washington, DC 20555 Charles P. Graham, Esq. Judith H. Mizner, Esq.
McKay, Murphy & Graham Lagoulis, Clark, Hill-Whilton Old Post Office Square & McGuire 100 Main Street 79 State Street Amesbury, MA 01913 Newburyport, MA 01950 e
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k R. Scott Hill-Whilton, Esq. Barbara A. St. Andre, Esq.
Lagoulis, Clark, Hill-Whilton Kopelman & Paige, P.C.
& McGuire 77 Franklin Street 79 State Street Boston, MA 02110 Newburyport, MA 01950 Charles P. Graham, Esq.
McKay, Murphy & Graham Old Post Office Square 100 Main Street Amesbury, MA 01913 e r' .
V =- /
' 'Stephbn A. Jofis Deputy Chief Public Protection Bureau Office of the Attorney General One Ashburton Place Boston. MA 02108 (617) 727-2200 Dated: July 26, 1988 l
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