|
---|
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
,
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION n,r urT n BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of: '83 SJ121 0.10 :3 8 PUBLIC SERVICE COMPANY OF Docke.t Nos. - 50-443 OL NEW HAMPSHIRE, et al -
50-444 OL (Seabrook Station, Units 1 and 2)
SAPL'S RESPONSES TO APPLICANT'S INTERROGATORIES AND l
REQUEST FOR THE PRODUCTION OF DOCUMENTS
- 1. DEFINITIONS. .
A. "No."
In answering "No." to any of the applicant's specific interrogatories, the Seacoast Anti-Pollution League does not waive its right to cross examine witnesses or to urge the denial (or allowance subject to conditions) of the pending application on the basis of the topic or contention. In other words, the Seacoast Anti-Pollution League retains its rights under the Prairie Island Rule, found at 2 NRC 392 footnote 6. (In the Mat ter of Nor thern States Power Company) SAPL further asserts that it has discernible interests in the resolution of all contentions admitted in the above-named proceedings.
I1. ANSWERS.
I. "No."
II. "No."
111. "No."
IV. "No."
V. "No."
VI. "No." -
VII. "No."
o----
CK 05 h 43 "
PDR
~ _
VI,II. "No."
IX. "No."
X. "No."
XI. "No."
XI1. "No."
XIII. "No." ,
~
XIV. "No."
XV. "No."
XVI. "No."
XVII. "No."
XVIII. "No."
XIX. "No."
XX. "No."
XXI. "No."
XXII. "No."
XXIII. "No." ,
XXIV. "No."
XXV-1. "Yes."
XXV-2.
First, SAPL believes that it's contention relat.es to the staff's compliance with requirements of the National Environmental Policy Act, as specified in the Commission's Interim Policy Statement and not to the Applicant's environmental report. However, in regard to the environmental report, SAPL believes that the analysis would f all to comply with the Commission's policy statement, if the policy statement in fact related to the environmental report, in the following respects:
- a. The Commission's Policy Statement requires that "approximately equal attention shall be given" to the consequences j of accidents and to the probability of their occurrence. In addi t ion, the Commission's statement requires that accidents whose consequences )
be analyzed should "not be limited" to those that can reasonably be expected to occur. ,
l
- b. The Environmental Report does not disclose the f u'l l l
consequences of a " Class 9" accident. Throughout' the discussion in
' ~
Section 7.4, " Determination of Release Category Consequences", the l
applicant discusses the consequences only in combination with the l
claimed low probability of the accident events. l l
- c. The consequences are not presented on a worst case basis, i contrary to the policy statement's requirement that the accident sequence "not be" limited to those that can be reasonably expected j to occur. For example, the applicant has chosen to use average wind speed, and to use weekday transient compilation concentrations.
- d. Contrary to the requirements of the Interim Policy Statement, the environmental report does not discuss the extent to which events arising from causes external to the plant may be considered possible contributors to the risk. .
The Interim Policy Statement states at page 40103, :"The extent to which events arising from causes external to the plant which are considered possible contributors to the risk associated with the particular plant shall also be discussed." The applicant has f ailed to comply with this provision of the Interim Policy Statement. The applicant has f ailed to consider th'e potential consequences of of f-site f actors which might cause a Class 9 accident, specifically those I !
l l .- -- - -
events related to sabotage activities. Determination of the worst case consequences of a sabotage attack seriously impat ring the ability of safety systems designed to safeguard the public from radiation exposure is not precluded by a limited state of the art with respect to probability analysis. The applicant has classified an act of sabotage as a " unusual occurrence". (See section 11.2 of the FSAR Radiological Emergenc/ Plan.) Consequently, it appears that the applicant is confident in its classification of sabotage activites with respect to emergency planning. Consequently, SAPL asserts that the applicant should be required to disclose the full er.vironmental consequences of the worst case sabotage incident in which emergency systems designed to safeguard the public f rom radiological exposure were seriously impaired.
- e. The accident consequences are mitigated by the assumption of the " benefits of evacuation", again precluding the disclosure of the full consequences of a worst case accident. In any event, the applicant's analysis of the worst case consequences of a core malt accident are premature given that state and local emergency plans l have not yet been completed or disclosed. Due to the status of the l
l plans, an accurate analysis of their mitigating effects upon environmental consequences is impossible.
XXV-3. SAPL contends that the applicant is required to discuss separately.
- 1. The probability of occurrence of a " worst case" core-melt' accident in which the full radio-nuclide inventory of the reactor core is released into the atmosphere, and
_4
- 2. A full, complete, clear and concise analysis of the environmental consequences of a " worst case" core melt accident in which the full radio-nuclide inventory of the reactor core is released into the atmosphere.
With respect to the second analysis, the applicant should assume the highest population density of the year with respect to the ten-mile radius from the site. The highest population density for the year should be determined from reference to the most recent data available. The applicant should also assume " worst case" weather conditions w'.ich would bring the largest body of radio-nuclides into contact with the greatest numbers of people. Included in the l
l applicant's analysis of the environmental consequences of a worst l case " core melt" accident should be an assessment of property damages l
t assuming highest possible population densities and " worst case" weather conditions noted above.
XXV-4. It is not SAPL's responsibility to determine each and every consequence that would result f rom a " worst case" core-melt accident in which either reactor's complete core radio-nuclid'e inventory were released. The responsibility for that determination lies with the Commission's staff and the applicant. To date, the applicant's Environmental Report has not yet included that determination.
XXV-5. SAPL contends that for purposes of analyzing the environmental consequences of a " worst case" core melt accid.ent (see XXV-3, above), the applicant should assume a probability of one occurrence per reactor a year. .
XXV-6. This is consistent with SAPL's contention that the applicant's analysis of worst case accident consequences should be separate and distinct from its analysis of their probability of occurrence.
XXV-7. "Yes."
XXV-8. The accident scenario mandating the requirements would be a " worst case" core melt accident in which
- 1. The full radio-nuclide content of the reactor were released to the atmosphere, water and land surrounding the plant, and 2.' " Worst case" weather conditions created maximum radiation exposure levels among
- 3. the highest population densities predictable within the ten-mile radius from the site.
SITE FEATURES
- 1. Construction of shelters of suf ficient size, location and design to protect maximum populations from injury caused by a Class 9 accident.
- 2. Expansion of existing roadway and bridge networks to permit -
i a rapid evacuation of the beaches and towns with the ten-mile radius from the site.
- 3. Full shutdown of the plant from Memorial Day to Labor Day each year. The extent to which any of the above recommended license conditions would mitigate the property and health damage consequences of a worst case " core melt" accident is unknown. The costs associated with the recommanded conditions are also unknown.
( XXV-9. "Yes."
l A. Richard Kaufman. Age not presently available. Malling i address: Room 105, Demeritt Hall, University of New Hampshire, 1
l Durham, N.H. 03824. Fu ll pro f essor , Phys ics Depar tmen t , UNH ,1960-l
l 63 Lieutenant, United States Air Force, Special Weapons Center.
Formal Education: PhD Yale 1960 Chemistry, MS Yale 1958 Chemistry, BS California Technical Institute, 1957, Chemistry.
SAPL reserves the right to supplement this response should it I
decide to of fer testimony of addltlonal expert witnesses with respect to this contention. )
B. SAPL is unable to answer subparts B-H since it has not yet received responses to its recent Interrogatories and Request for .
Documents directed.to the Commission.
XXVI-1. Yes.
XXVI-2. (1) The radiological emergency plan prepared by the Applicant indicates appropriate procedures to be used,for emergency notification. (See FSAR Radiological Emergency Plan (11.2. ) Section 11.2 reads as follows: " Notification systems for the areas around Seabrook Station will be extensively investigated. A determination of an appropriate system or combination of syst' ems will result from this investigation. Each communi ty wi thin the Plume EPZ will review propesed system details and agreements will be reached between Public Service Company of New Hampshire and local communities prior to installatlon. Local community emergency plans will reflect the final l
l improved systems."
(1)SAPL contends that the notification systems referred to in 6 l 11.2 of the.FSAR Radiological Emergency Plan have not been negotiated for all affected towns, and that such systems should be tested and in place prior to the issuance of an operating license.
(2) The Applicant has not yet produced completed State and local emergency preparedness and response plans. Consequently,
there is no factual indication that the Applicant has achieved its stated objective of " identifying and developing a system for coordination of Federal, State, and Local Authorities avaliable for assistance" as stated in 63.1 of the FSAR Radiological Emergency Plan (page 3-1.)
(3) The Applicant has f ailed to achieve objective No. 4 as stated in 93.1 of the FSAR for the same reason as stated in (2) above.
(4) The Applicant has f ailed to achieve objective No. 8 as stated in 43.1 of the FSAR ,for the same reason as stated in (2) above. SAPL asserts that any " training and emergency plan exercise program" designed to insure the plan's ef f ect iveness must be coordinated with State and Local Emergency Preparedness Plans. The Applicant has yet to state how and when that coordination will be achieved.
(5) SAPL reserves the right to supplement the above responses to specific interrogatory XXVI et. seg. In accordance with Commission regulations.
j XXVI-3 SAPL has not yet retained an expert witness with regard to this contention. Should an expert be retained, SAPL will immediately supplement this response with the appropriate data.
[
XXVII-1 Yes.
l XXVil-2 (1) The Applicant has not complied with the standards set forth in 10 C.F.R. 650.47(b). The regulation provides that:
9 "The on-site and off-site emergency response plans for nuclear power reactors must meet the following standards:
(1) Primary responsibilities for emergency response by the nuclear facililty licensee and by state and local organizations within the Eme,rgency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to augment its initial response on a continuous basis."
Since State and Local Emergency Prepare'dness and Response Plans have not been completed, and the Applicant has not demonstrated its complainee with the above standards.
(2) The Applicant has failed to demonstrate compliance with 10 C.F.R. 650.47(b)(8). The regulation provides that adequate emergency f acilities and equipment to support the emergency response must be provided and maintained. The FSAR Radiological Emergency Plan gives no account ing with respect to State and Local Police, Fire and Ambulance capabililties needed to support an evacuation, should one be deemed necessary. The Applicant indicates only that a " Local Hospital's Support Equipment Kit Checklist" will be included in a future revision to the Emergency Plan.
(3) SAPL reserves the right to supplement the above responses to specific interrogatory XXVII, et. seq.
XXVIII-1. No.
XXIX-1. Yes.
XXIX-2. SAPL adopts as its own the facts and bases set forth in NECNP's Supplemental filing on Emergency Planning Contentions.
XXIX-3.1 (Subpar ts (a)-(d). ) SAPL has not yet f inalized its posi t ion on this contention, therefore it is unable to answer these
~
interrogatories at this time. These answers will be supplemented as required by NRC regulations.
XXIX-3 through 25. Similarly SAPL has not yet fina1ized its position on responses to these interrogatories. These answers will be supplemented as required by NRC regulations.
XXIX-26 As of this date, SAPL has not performed or contracted for the performance on its behalf of any estimates of Seabrook evacuation times.
XXIX-27 N/A XXIX-28 N/A XXIX-29 SAPL has not retained an expert witness to present testimony on this issue. SAPL reserves the right to supplement its response e
to this Interrogatory should an expert be retained.
XXX-1 No.
XXXI-l Yes.
XXXI-2 SAPL has not yet finalized its posit ion on this contention.
Answers to this Interrogatory will be supplemented as requried by NRC regulations.
XXXI-3 SAPL has not yet cetained an expert witness to present exper t testimony with respect to this issue. SAPL reserves the right to supplement its response to this Interrogatory should an expert be retained.
XXXII-l Yes.
w- ,-w -
- 3. . . . -
XXXII-2 through 12. SAPL has not yet finalized its position on this contention. Answers to these interrogatories will be. supplemented as required by NRC regualtions.
XXXII-13. SAPL has not yet retained an expert witness to present testimony with respect to this issue. SAPL reseves the right to supplement its response to this interrogatory should an expert be retained.
XXXIII-1 Yes.
XXXIII-2 through 20. SAPL has not yet finalitzed its position on this contention. Answers to these interrogatories will be supplemented as required by NRC regulations.
XXXIII-21. SAPL has not yet retained an expert witness to present testimony with respect to this issue. SAPL reserves the right to supplement its response to this Interrogatory should an expert be retained.
III. DEFINITIONS.
Response to the Applicant's request for the production of documents.
SAPL will provide all documents identified above if and when they are received through the discovery process to the offices of Public Service Company of New Hampshire, 1000 Elm Street, Manchester, New Hampshire.
SEACOAST ANTI-POLLUTION LEAGUE -
By its Attorneys, BACKUS, SHEA & MEYER BY: $ _.
Robeft A.'EHfekus~
~
P. O. Box 516 Manchester, NH 03105 (603)668-7272 l
l
SERVICE LIST Holen Hoyt, Chm. Thomas G. Dignan, Esq.
Admin. Judge Ropes and Gray Atomic Safety & Lic. Ap. 225 Franklin Street Board - U.S. NRC Boston, MA 02110 Washington, DC 20555 D . Jer bour J dge Docketing and Service Sec.
Atomic Safety &Lic. Ap. O fice of the Secretary ash ngt n D 20555 Washington, DC 20555 Roy P. Lascy, Jr., Esq.
Office of Executive Robert L. Chiesa, Esq. -
Legal Director 95 Market Street U.S. NRC Manchester, NH 03101 Washington, DC 20555 phillip Ahrens, Esq. Jane Doughty Asst. Atty. General Field Director State House, Station #6 SAPL Augusta, ME 04333 5 Market Street Portsmouth, NH 03801 Wilfred L. Sanders, Esq.
Sanders & McDermott Tupper Kinder, Esq.
408 Lafayette Road Attorney General's Office Hampton, NH 03842 State of New liampshire Concord, NH 03301 Dr. Emmeth A. Luebke David R. Lewis Admin. Judge Atomic Safety & Lic. Brd.
Atomic Safety & Lic. Ap. U. S. NRC - Rm. E/W-439 Board - U.S. NRC Washington, DC 20555 Washington, DC 20555 Jo Ann Shotwell, Asst. AG One Ashburton Place, 19th '
Floor Boston, MA 02108 William S. Jordan, II, Esq.
Ellyn R. Weiss, Esq.
1725 I Street, N.W.
Suite 506 Washington, DC 20006 Edward J. McDermott, Esq.
Sanders and McDermott 408 Lafayette Road Hampton, NH 03842
-.