|
---|
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
[Table view] |
Text
.
RELATED CORRI5FONDENCE DOCKETED USNRC Util'IED STATES OF NERICA NUCLEAR REGUIATORY COtNISSION
,84 MR -2 A10 :28 BEFORE 'ITE A'IUiIC SAFETY AND LICD2SItG BOARD 77 7 : ,. w. . .,
CC';.iSIUML-E.U 1:CH In the Matter of )
)
PUBLIC SERVICE COtPA:1Y OF ) Docket Nos. 50-443 OL NB1 HA?EdHIRE, et al. ) 50-444 OL
)
(Seabrook Station, Units 1 and 2) )
FEDERAL DEGENCY MANAGDOR AGENCY'S SUPPLDD7fAL RESPCNSES
'IO ATIORNEY GENERAL BELIDTI'S IITIERROGA'IORIES __
I?7IERROGA'IORY 5 AS NiDED In the opinion of FEMA, what is the ntrl)er of persons for which the State of New Hampshire must assure medical services persuant to 10 C.F.R. S 50.47 (b)
(12)? State the basis for your answer in detail, describing the types of in-juries and sources or levels of contamination for which your estimate accounts.
Identify and produce all documents upon which you rely for any portion of your answer.
FEttA'S RESPONSE 'IO ItTIERROGA'IORY 5 In the Matter of Southern California Edison Canpany, et al, ' San Onofre Generating Station, Units 2 and 3),17 N.R.C. 528 (1983), the 0:runission in-terpreted the requirement for arranging for off-site medical services. We Ccmmission held 10 C.F.R. S 50.47 (b)(12) required "that emergency response efforts should include consideration of: (1) those who become injured and also contaminated, and (2) those who may be exposed to dangerous levels of radiation." Matter of Southern California Edison Cmpany,17 N.R.C. at 530.
'Ihe Cmmission construed the NRC regulation to require "immediate or near term care. Advance planning would be most useful for immediate or near term care while long Mm care can be handled on an g hoc basis and
[on G
00 O!b
- m. - -
9 2
should not require advance planning." Matter of Southern California Edison Cmoany,17 N.R.C. at 535.
%e Cmmission went on to hold that:
with respect to individuals who become injured and are also contamin-ated, the arrangements that are currently required for on-site person-nel and emergency workers provide emergency capablities which should be adequate for treatment of members of the general public. %erefore, no additional medical facilities or capabilities are required for the general public.
. Matter of Southern California Fdison Cmpany,17 N.R.C. at 536.
On the basis of this ruling, in order to meet the requirements of 10 C.F.R. S 50.47 (b)(12), the State of New Hampshire should provide medical services for the same n mb2r of contaminated individuals as provided for by the on-site plan. Additional arrangements are not required by this regulation.
We Federal Emergency Management Agency will consult with the Nuclear Regulatory Commission (NRC) Staff to determine if such adequate arrangements have been made in the on-site plan.
As to individuals who are exposed to radiation and who need medical treatmcnt for that reason, the Cm mission has determined:
Here the special hazard is posed by the radiation exposure to the patient. %e nature of the radiation injury is that, while medical treatment may be eventual 3y required in cases of extreme exposure, l the patients are unlikely to need emergency medical care. We non--
i imediacy of the treatment required for radiation-exposed individuals provides onsite and offsite authorities with an additioral period of time to arrange for the required medical service. Rus, any treatment required could be arranged for on an ad hoc basis.
Matter of Southern California Edison Cm pany, 17 N.R.C. at 535-36.
On the basis of the Cmmissions interpretation of 10 C.F.R. S 50.47 (b)(12) the State of New Hampshire need only " identify those local or regional medical f facilities which have the capablities to provide appropriate medical treatment for l radiation exposure. " Matter of Southern California D31 son Cmpany,17 N.R.C. at l 537. .
l i
i 1
=-. _. ..
4 3
4 As to that aspect of the interrogatory that asks for this Aaency to describe the types of injuries and levels of contamination taken into account, under the comission ruling in the Matter of Southern California Edison Company the re-quirement is that the individual suffer a traumatic injury and be contaminated.
No specific level of radiation exposure or contamination is considered.
i.
IlnuoO3A'IORY 6 In the opinion of FD%, can the health care facilities identified in the RERP provide to the ntuber of contaminated injured individuals specified in your answer to interrogatory 5 all medical treatment which could be of help to them? If not, can such treatment be provided by other health care facili-ties in New Hampshire and/or 11assachusetts? State the basis for your answers in detail and identify and produce any documents upon which you rely. List all medical facilities other than those identified in the RERP which might be required to provide care to assure that the full number of persons specified in your answer to interrogatory 5 receive all treatment which could be of help to them.
FEMA RESPONSE 'IO INIERROGA'IORY 6 See response to Interrogatory S.
INI'ERROGA'IORY 9 In the opinion of FDW, has the State established an emergency action level scheme consistent with that established by the Applicants? State the basis for your response in detail and identify and produce documents upon which you rely in support of your answer.
FDM RESPONSE 'IO ItEAM'IORY 9 The State of New Hanpshire has adopted the standard emergency classi-fications, which are identical with those utilized by the utility in the on-site plan. 'Ibe utility still needs to identify the design based plant operating parameters and initiating conditions, which together with the emergency classi-fications constitute the Emergency Action Level scheme. We anticipate that the State of New Hanpshire adopt this same Emergency Action Invel scheme.
i 4 IturmOGNIORY 17 AS AMDIDED In the opinion of FD%, can the transient beach populations in the New
, llampshire coastal ocmrunities within ten miles of the Seabrook site be protected frcn all adverse health effects potentially associated with radiation exposure by means of evacuation in the event of a radiological emergency at Seabrook Station? If your answer is in the negative, indicate what adverse health effects could be experienced by the beach population and the numbers of such persons who may potentially experience each such effect. hhether your answer in in the affirmative or negative, state the basis for it in detail and identify and produce all doctnents upon which you rely.
IT1% RESPONSE 'IO IITTERROGNIORY 17 The planning basis of IUREG-0654/ FDR REP 1, Revision 1 (1980), clearly states that "'Ihe overall objective of emergency response plans is to provide dose savings (and in some cases immediate life saving) for a spectrum of acci-Ments that could produce doses in excess of Protective Action Guides (P1G's)."
There is an implicit recognition of the fact that in some lw prcbability accidents members of the public will be exposed to some level of radiation.
FDR has not undertaken an independent analysis of the issue raised by this contention. 'Ihe NRC has addressed the probability of accident risk and health impacts in section 5.9.5.0, p.5-45 et seg. , of the Final Environmental Statement (CES),IUREG-0895. As stated in the FES the " consequence model also contains provisions for incorporating the consequence-reduction benefits of evacuation, relocation, and other protective actions." p 5-50. Based upon this analysis, under certain scenarios considered by the NRC the transient beach may be exposed to radiation released during an accident at Seabrook.
The basis for FD%'s statement is the FES, IUREG-0895.
I l
l
- > , - - - - _ , , - - - , , - -- , ----m-
T 5
i INTERPOGATORY 18 AS AMD3DED In the opinion of FD%, can the seasonal residents in the beach areas within ten miles of the Seabrook site be protected from all adverse health effects potentially associated with radiation exposure by means of in-place sheltering? If your answer is in the negative, indicate what adverse health effects could be experienced by the seasonal population and the ntsnbers of such persons who may potentially experience each such effect. Whether your answer is in the affirmative or negative, state the basis for it in detail and identify and produce all documents upon which you rely.
FD% RESPONSE TO INTERROGATORY 18 See answer to intentgatory 17.
INTERROGATORY 19 In the opinion of FD%, what is the most efficient evacuation routing scheme for the seasonal and transient beach populations in the coastal New Hampshire comunites within ten miles of the Seabrook site? State the basis for your answer in detail and identify and produce all documents upon which you rely.
Do the routes which you have specified conform in all respects to those assumed by the Applicants in their evacuation time estimates as set forth in Appendix C to the FSAR? To those assumed by Costello, Lomasney & deNapoli/C.E.
Maguire in their " Final Draft of Appendix E Emergency Planning Lone Evacuation Time Study"? If the answer in both cases is no, will FD% require revised evacuation time estimates based on the most efficient routing scheme? Uhen will such estimates be required to be corpleted?
FD% RESPCNSE TO Ilm.xHQMORY 19 FDR has not formed a conclusive opinion on this matter at this time.
FE2% is working with both plume EP2 states with regard to evacuation routing and traffic control planning and coordination.
FD% is also independently doing a detailed conparison of the two studies referenced above in ths Interrogatory.
6 IITTERROGMORY 20 In the opinion of FDR, what traffic management plans or traffic controls will lead to the most efficient evacuation of the seasonal and transient beach populations in the coastal New Harpshire cormunites within 10 miles of the site? State the basis for your answer in detail and identify and produce any documents which you rely. Have these traffic controls and management plans been reflected in the evacuation time estimates prepared by the Applicants?
2ose prepamd by C. E. Maguire? If the answer in both cases is no, will FDR require evacuation time estimates based on such plans and controls? W en will such estimates be required to be completed?
FD% Response see response to interrogatory 19.
Signed this 13 day of February,1984.
A rJ 4 4 y, s m~-w Q
BRUCE J. SWIRHi Drergency Management Specialist Federal Emergency Management Agency Region I 2 en appeared before me Bruce J. Swiren and after having been duly sworn stated that the aforegoing statements were true and accurate to the best of his information and belief.
/ Lw 4
<0m
/
,A TJTARY PUBLIC Date: ,2 e) f- d'Y l My cormission expires:
?-/- $C
~
E -- -- - -m-- +
WJED CORRESPONDENCE UNITED STATES OF AMERICA 000'E~EE NUCLEAR RH3UIA'IORY COMMISSION N BEFORE 'IEE A'IO4IC SAFETY AND LICENSING N '84 KAR -2 A10 :28 LFF;2 ?: SE, -t ;
OCChElih0 ?. SEin .
In the Matter of ) BRANCH
)
PUBLIC SERVICE COMPANY OF ) Dacket Nen. 50-443 OL N W HAMPSHIRE, et _al.
_ ) 50-444 OL (Seabrook Station, Units 1 and 2) )
CERTIFICATE OF SERVICE i
I, Brian P. Cassidy, state that I served a copy of FEMA's Supplemental Response to the Massaschusetts Attorney General's Interrogatories, by mailing in a franked envelope upon the parties identified in the attached service list on this 29th day of February 4. -
4t RRT/ N W ~
m Regional Counsel Fed ral Emergency Managen Agency SERVICE LIST Helen Hoyt, Esq. , Chairman Dr. Jerry Harbour Administrative Judge Administrative Judge Atomic Safety and Licensing Atoric Safety and Licensing Board Board Panel Panel U.S. Nuclear Regulatory Ccxnmission U.S. Nulcear Pegulatory Ccrnmission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Dumeth A. Luebke Robert Perles, Esquire Administrative Judge Office of the Executive Legal Director Atomic Safety and Licensing Board U.S. Nuclear Regulatory Agency ;
Panc1 Washington, D.C. 20555 U.S. Nuclear Regulatory Cmmissicn Washington, D.C. 20555 Edward L. Cross, Jr., Esq. Jo Ann Shotwell, Asst. Attorney General George Dana Bisbee, Esq. Dept. of the Attorney General Environmental Protection Division One Ashburton Place,19th Floor State House Annex Boston, MA 02108 Concord, NH 03301
Nicholas J. Costello Charles Cross, Esq.
1st Essex District Shaines, Madrigan, & McEacher Whitehall Road 25 Maplewood Avenue Ame'sbury, MA 01913 P.O. Box 366 Ibrtsmouth, NH 03801 Sandra Gavutis Senator Gordal J. Humphrey Town of Kensington, New Hampshire 1 Pillsbury Street RFD I Concord,t&I 03301 East Kingston, NH 03827 (Attn: Herb Boynton)
Edward J. Meany Mr. Maynard B. Pearson Town of Rye, New Hampshire Town of Amesbury, Mass.
155 Washington Road 40 Monroe Street Rye, NH 03870 Amesbury, MA 01913 Anne Verge, Gairman Patrick J. McKeon Board of Selectmen Gairman of SelectInen, Rye Town Hall New Hampshire South Hanpton, NH 03842 10 Central Road Rye,t&I 03870 R.K. Gad III, Esq. Town of North Hanpton Ropes and Gray North Hampton, NH 03862 255 Franklin Street i
Doston, MA 02110 l
Deverly Hollingworth Carole F. Kagan, Esq. l 7 A Street Law Clerk to the Board l Hampton Beach, NH 03842 Atomic Safety and Licensing Board l U.S. Nuclear and Regulatory Commission Mr. Robert J. Harrison Washington, D.C. 2055S' President and Chief Executive Officer Public Service Co. of New Hampshire P.O. Box 330 Docketing and Services Section Manchester, tal 03105 Office of the Secretary U.S. Nuclear Regulatory Comnission Robert A. Backus, Esq. Washington, D.C. 20555 116 Imell Street P.O. Box 516 Manchester, NH 03105 Ietty Hett Senator Gordon J. Humpnrey Town of Brentwood U.S. Sentate RFD Dalton Road Washington, D.C. 20510 Brentwood, tal 03833 (Attn: 'itzn Burack)
Thanas G. Dignan, Jr. , Esq. John B. Tanzer Popes & Gray Town of Hanpton, IMw Hanpshire 255 Franklin Street 5 Morningside Drive Doston, MA 02110 Hampton, NH 03842
.a '
l Atomic Safety and Licensing Atmic Safety and Licensing 2
Appeal Panel Board Panel U.S. Nuclear Regulatory Comnission U.S. Nuclear Regulatory Comnission Washington, D.C. -20S55 Washington, D.C. 20555 Jane Doughty Phillip Ahreans, Esq.
Field Director Assistant Attorney General Seacoast Anti-Pollution Imague State House Station #6
-.l- 5 Market Street Augusta, ME 04333 Portsmouth, NH 03801 Calvin A. Canney U1111am S. Jordan, III, Esq.
City Hall Ellyn R. Weiss, esq.
4 126 Daniel Street Harmon & thiss Portsmouth, NH 03801 1725 I Street, N.W.
Suite 506
. Roberta C. Pevear Washington, D.C. 20006
] 7twn of Haupton Falls, New Hanpshire Drinkwater Road
- Hanpton Falls, NH 03844 4
Dr. Murray J. Tye Tufts University School of Medicine 4
Department Of Dermatology
, 209 Sumer Street Haverhill, MA 01830 l
4 s
t i
i l 1
e