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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
[Table view] |
Text
~, f I f ..
y \ 7,r-s g 's Ma rch 5, 1987 UNITED STATES NUCLEAR REGULATCRY COMMISSION'
(. \
g t BEFOPE THE ATOMIC SAFETY AND LICENSING BCARD In the Matter of )
)-
Public Service Company of '
\ & \ ),
y t'e w t!a mp shir e, et al.
\
). Docket Nos. 50-443 OL
' s. 3 )' 50-444 OL
( Se,a b r'ook S t a t ion, Units 1 & 2) ) OEFSITE EMEPGENCY l ) PLANNING ISSUES
( ) i 1
NEW ENGLAND COALITICN ON I;UCLEAR POLLUTION'S FIRST SET OF INTEPPCGATORIES AND RECUEST FOP THE PRODUCTION CF COCUN Et!'"S TO APPLICANTS ON REVISIOtl 2 TO THE NEW HAPPSHIPE PADIOLOGICAL EMERGENCY RESPONSE PLAN INSTPUCTION FOR USEs, The following interrogatories are to be answered in wr itinc and under oath ty an employee, representative or agent of the Applicants with personal knowledge of the facts or information
\ requested in each interrogatory. We remind you of your obliga-8 tion to supplement answers to interrogatories, under 10 C.F.B. S
} 2.740(e).
The following definitions shall apply to these inter-rogatories:
- 1) "Docunent" shall mean any written or graphic matter of commu nica tion, however produced or reproduced, and is intended to s
be comprehensive and include without limitationsany and all cor-respondence, letters, telegrams, agreements, noteq, contracts, instructions, reports, demands, stemoranda, data, ' schedules, notices, work papers, recordings, $ce'ther electronic or by other
, s.
I ' L'.
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t 8:
2-means, computer data, computer printouts, photographs,, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, draf ts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or kraphic materials of any nature whatsoever.
- 2)
- Identify" with respect to any docwnent shall mean to state the following: the document's Litle, its date, the. author of the document, the person to whom to document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.
- 3) " Identify" with respect to'any action or conduct shall r.ean state the following regarding any such action or conduct:
the person or persons proposing and taking,such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; and any document recording or documenting'such action.
- 4) " Identify" with respect to an individual shall mean state the individual's name, address, emp l oye t ,' occupation, and title. ,
- 5) " Describe" with respec't to any action or matter shall mean state the following regarding such action or matter: the '
W v
1 2
'3-substance or nature of such action or matter; the persons partic-ipating in or having knowledge of such' action or matter; the cut-
- i. r'ent and past' business positions and addresses of such persons; a'n d the existence and location of any and all documenty, relating to such action or matter.
- 6) _" Applicants" shall include any of the Seabrook owners; few Hampshire Yankee; or any ontractors retained by the Seabrook owners or New Hampshire Yankee to prepare or evaluate the New i
Hampshire -Radioingical Emergency Pe sponse Plan.
GENEPAL INTERRCGATCRIES
- 1) In accordance with 10 C.F.P. S 2.740(e), please supple-cent your answers to NECNP's First Set of Interrogatories and Eequests for the . Production of Documents to Applicants on New Hampshire Radiological Energency Response Flans, filed April 30, 1986.
- 2) What is Applicants' position en each of the contentions that has been admitted in this proceeding with respect to Pevi-sion 2 of the New Hampshire Radio.'.ogical Emergency Pesponse Plan?
t that is the basis for your position?
- 3) On or before March 19,;1987, please produce at the of fice of Harmon & Weiss all documents on which you rel'y or 1
2 intend to rely during this proceeding to support your position on each of_the contentions that have been admitted in this proceed-ing with respect to Revision 2 of the New Hampshire Radiological Emergency Response Plan. This includes but is not limited to all i
t I documents used in answers to these interrogatories, summary dis-position motions, testimony, and cross-examination of witnesses during hearings.
- 4) Please identify all persons on whose f actual knowledge, opinions, or technical expertise you rely or intend to rely for
~
your position on each of the contentions that has been admitted in this proceeding with respect to Revision 2 of the New Hampshire Radiological Emergency Pesponse Plan.
1
- 5) Please identify all persons you may call as witnesses on each of the contentions that has been admitted in this pro-ceeding with respect to Pevision 2 of the New Hampshire Fadiological Energency Fesponse Plan. Please describe the sub-stance of their testimony; and identify and describe any docu-ments and the portions thereof that they may rely on for their testimony.
- 6) Cn or before March 19, 1987, please produce in the office of Harmon & Weiss all documents in the Applicants' posses-sion which analyze or evaluate in any way the adequacy of the New Hampshire RERP or New Hampshire's state of preparedness in the event of a radiological energency.
- 7) Please identify all persons who participated in the development or draf ting of Revision 2 to the New Hampshire RERP.
- 8) Please identify all persons who are responsible for 4_
training of emergency response personnel for implementation of Revision 2 to the New Hampshire RERP.
s i
5-l
- 9) Please describe all plans for training emergency response personnel under Revision 2 of the RERP. Identify all individuals who are responsible for that program.
INTERROGATOPIES REGARDING SPECIFIC CONTENTIONS NHLP-6 and HAMPTON REVISED CCNTENTION IV TO REVISION 2
- 10) Identify, describe and/or produce any communications or agreements between the Teamsters Union and its member drivers regarding the NHREPP.
- 11) Provide copies of regular employment contracts of drivers in the Teamsters Union who will be relied on during a radiological energency.
- 12) Provide all agreerents or correspondence between the Teamsters Union or Union of ficials, Applicants, or the State of New Ha.vp s h i r e , regarding the possible provision of transportation services by Teamsters members during a radiological emergency.
HAMPTCM REVISED CCNTENTICN VIII TO PEVISION 2
- 13) NUREC-0654 states that "the overall objective of emer-gency response plans is to provide dose-savings (and in some cases immediate life savings for a spectrum of accidents that could produce offsite doses in excess of Protective Action Guidelines (PAGs) ." In this vein, NUREG-0654 requires planners to consider, inter alia, the timing _and consequences of potential releases. What spectrum of accidents did Applicants consider in developing Revision 2 to the NHRERP, and what are the character-istics of those accidents? What quantitative dose savings result
i i l
i from implementation of the protective measures proposed in Revi-sion 2, given each type of accident that was considered? Please provide all data that supports your conclusion.
- 14) Assuming that dose reductions are achieved, describe the health effects associated with each of the accidents that you considered in developing Revision 2 to the REPP.
- 15) Identify and provide access to any and all of Applicants' calculations of potential dose consequences to the public in the event of a radiological emergency at Seabrook, and the bases for those calculations.
r espectfully suba.itted, J
_ ane Curran HARMCN & WEISS 2001 "S" Street N.W. Suite 4 30
%ashington, D.C. 20009 Farch 5, 1987 (202) 328-3500 I certify that on March 5, 1987, copies of the foregoing interrogatories were served by Federal Express or by hand on the NRC Staff, the Executive Director for Operations, the Licensing Board, the State of New Hampshire, FEMA, and Applicants; and by first-class mail on all other part vice list.
listed on the attached ser-
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Diane Curran l
DXMErg SEH 00I SEAy!CE LIST -- UFFSITE LICENSING B0ARD U%RC sHelen F. Hoyt. Chatraan North Hasoten NH 03826 44 J Atesic Safety and Licensing 8 Robert G. Perlas. E@?,56 tlAR 02:09 30soba.W.
loard J.P. Nadeau Shermin E. Turk Esq.
U.S. NRC Taun of Rye Office of General CGhENE r .. $4ndra.Gavutts Washington,D.C. 20555 155 Washingten Roaa U.S. NRC DOCKER,ng,- #DJtp 6 1154 Rye, New Haspshire 03870 Washington, D.C. 20555 BRANCTast tensington, NH 03327
- Dr. Jerry Hartour Atcelc Safety sad licensing Rathard E. Sullivan Mayor Mr. Angle Machiros, Chairsan Charles P. Grahas. Esq.
Boar 1 CityHall Board of Celectsen Mctar. Murtny and Grahas U.S. NFC Nemourypert MA 31950 Newtury, MA 01950 100 Main Street L!as%1ngtcn,D.C. 20555 Asescurr, MA 01913 Alfred v. ! argent. Chstrean *H. Joseph Flynn. Esa.
sGustase Ltw:er;er toard of Selectaen Of fice of General C;unsel ,,,,,,,,,,,,,,
At stc Safett and Licensing Teen of Salistury. PA 01'350 FEMA lear 1 500 C Street S.W.
- tr hand 0.0. HC Senat:r Gar on J. M oonrer Wasningtcn. D.C. 20472 earningicn 0.C. 20555 U.S :+nate 88 ly Federal Erpress Wasningtcn ;.C. :0510 g eGeorce hna inscee. Ero.
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icara hnel "tf::e er 'te att:rney beneral J.S. MC :electsen et *1r t N ec t t.n : tate ouse Annes easninc!cn. . C. :3555 sortu sot;n. ses m acsntre Qnccr1. 99 ::31
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- acket:ca 3na :ervice ric9ael Lnt:suosso J airsan Richara A. ?asce. Esq.
1.: s8C i: ara er telectsen Haece end ecNicto14s eas.ungten. : 20555 :e.eil areet. AFD I 2 :S Fleasant Street 50uta anot;n. M 23542 Concera .M 0::01 Krs. Anne E. Bocean
! card of Selecisen halth H. "12ner, Esq. Gary W. Halses. Esq.
1;-15 New Far,at soaa Stiverstate 6ertner, et al. Holaes&Ellis Durhaa. NH 0:342 $3 froad Street 47 minnact.nnent Road Boston,MA 02110 Hasoten. NH J3da2 Willias S. Lord. Selectean Taun Fall -, r n..d Street Rep. Roberta C. Fevear WilliasArestreng Asescury, MA 01913 Drinkwater Road Civil Defense Director Hasoten, Falls, NH 03844 10 Front Street Jane Doughty Exeter,NH 03833 SAPL Phillip Grens. Esq.
5 Market Street AssistantAttorneyGeneral CalvinA. Canner Portssouth, H 03801 State House Station i 6 City Manager Augusta. ME 04333 CityHall l Carol S. Sneifer Esquire 126DanielStreet I Assistant Attcrney General ~ esihosas G. Dignan, Esq. Portssouth, NH 03801 1AshburtonPlace,19thFloor R.I.GadII,Esq.
Ioston,MA 02103 Ropes & Gray Matthew T. Brock, Esq.
225FranklinStreet Shaines & McEachern .
Stanley W. Incules loston,MA 02110 P.O. Bor 360 leardofSelectaen MaplewoodAve.
P.O. 80: 710 RobertA.Backus,Esq. Portssouth, NH 03801 -
Backus,Meyer&Solcean -
111LowellStreet EdwardA.Thosas Manchester, NH 03105 FEMA ,.. .a
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