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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] |
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i (E!ATED.CORREpgDW Nh UNITED STATFS OF AMERICA NUCLEAR REGULATORY COMMISSION 88 OCT 21 P 3 :44 ATOMIC SAFE'.1 AND LICENSING BOARD f r uc > 4' O C K E E ' ;- ' ' ",L I '.
Before the Administrative Judges: N Ivan W. Smith, Chairman Gustave A. Linenberger, Jr.
Dr. Jerry Harbour
)
In the Matter of ) Dor:ket Nos . 5 0-4 4 3 -OL- Y
) 50-444-OL-;A PUBLIC SERVICE COMPANY ) (Off-Site EP)
OF NEW NAMPSHIRE, EI AL. )
)
(Seabrooh Station, Units 1 and 2) ) October 19, 1988
__. )
MASSACHUSETTS ATTORNEY GENERAL'S FIRST REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE FEDERAL EMERGENCY MANAGEMENT AGENCY REGARDING THE SEABROOK PLAN E0R MASSAGUSETIS_COM1U111'IIES Pursuant to 10 C.F.R. S 2.741, James M. Shannon, the Massachusetts Attorney General ("MAG"), hereby requests that the Federal Emergency Management Agency ("FEMA") produce for inspection and copying at the offices of the Attorney General, One Ashburton Place, Bo s t.on , Massachusetts, at 10:00 a.m. on November 4, 1988. the follo'aing documents in their possession or under their control.
LEFllllH0!1S_AllD_111STRUCT10BS A. As used herein, the term "NHY" shall mean the Public Service Company of N3w Hampshire's New Hampshire Yankee 8010270212 001019 PDR ADOCK 05000443 G PDH
t Division, any of its representatives, officers, employees, agents, servants, affiliates, or subsidiaries. The term "0R0" shall mean NHY's Offsite Response Organization for ,
1 Massachusetts. The term FEMA shall mean the Federal Emergency ;
Management Agency, any of its representatives, officers, employees, agents, servants, or affiliates. The term "RAC" shall mean FEMA's Regional Assistance Committce and all its l 4 ;
i members, individually and collectively. The term "SPMC" means f 9 :
the Seabrook Plan for Massachusetts Communities, and all E
]
appendices, amendments, and attachments thereto. The "Massachusetts EPZ" means the Massachusetts portion of the ,
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1 Emergency Planning Zone for Seabrook Station. !
B. Each document request shall be deemed continuing, and i
i
! Applicants are requested to supplement responses with additional documents in accordance with S2.704(e) of the NRC's 4
Rules of Practice.
C. As used herein, the term "person" shall mean any [
natural person, corporation, partnership, firm, trust, group, i
association or other organization and, where appropriate, the
{ use of the singular includes the plural and the use of the j plural includes the singular.
I D. As used herein, the term "document" shall mean the 1
j original, and any and all copies which differ in any way from ;
the original, of any notes, correspondence, memoranda ;
(including written memoranda of telephone conversations, other communications, discussions, agreements and any other acts, l 1
l i
I i
a
i .
1 transactions or activ ties), time sheets, contracts, agreements, pamphlets, receipts, order forms, records, bonds, requisitions, bills, plans, blueprints, layouts, drawings, specifications, sound recordings, minutes, diaries, by-laws, notebooks, logs, bulletins, circulars, brochures, forms, statements, journals, letters, telegrams, notices, interoffice and intraoffice communications, photostats, microfilms, studies, r. ports, analyses, messages, comparisons, graphs, charts, summaries, films, photographs, tapes, transcripts, advertisements and any other written natter of any kind including, but without limitation, any marginal comments appearing on any documents or any other writing.
E. As used herein, the term "communication" shall mean any oral or written transmittal of information, or request for information, made from one person to another person, whether made in person, by telephone or by any other means and includes any documents made only for the purpose recording a communication, idea, statement, opinion or belief.
F. Wherever appropriate, the masculine fo.m of a word shall be interpreted as feminine, and vice versa, so as to bring within the scope of these document requests a.'y information that might otherwise be construed to be outside their scope.
F. please produce each document in the form and condition in which it exists on the date of service of this request, including all comments, notes, remarks, and other material that
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may have been added to the document after its initial preparation.
G. If the plaintiff should withhold any document otherwise responsive to the requests set forth below on the ground of privilege or for any other reason, each such document should be listed and fully identified in writing with sufficient particularity to enable a court a rule on the validity of the ground on which it is withheld, and the ground for withholding it should be fully set forth, except that the substance of such withheld document need not be described to the extent it is claimed to be privileged. To "identify" a document means to provide a description sufficient to identify that document for purposes of a subpeona duces tecum and is further to state:
(1) the date on which the document was prepared; (2) the author or authors of the document; (3) the addressee (s) of the document, if any; (4) the .itle of the document, if any; (5) the number of pages; and (6) the substance thereof to the extent not privileged.
H. For any document or part of a document that was at one time, but is no longer, in Applicants' possession, custody or control, or which is no longer in existence, or which cannot be located or produced, identify the document, state where ard how it passed out of existence or why it can no longer be located
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e and reasons therefor, and identify each person having knowledge concerning such disposition or loss and the coritents of the document, and identify each document evidencing its prior existence and/or any fact concerning its nonexistence or loss.
I. All requests for documents which are stated in the conjunctive are to be read as if also stated in the disjunctive, and vice versa.
J. All documents produced shall be segregated by the request number to which they are responsive.
K. "Concerns," "concerning" or any other derivative thereof, includes referring to, responding to, relating to, pertaining to, in connection with, comprising, memorializing, commenting on, regarding, discussing, showing, describing, reflecting, analyzing, supporting, contradicting, and constituting.
BEQUESIS
- 1. Any and all reports, surveys, studies or analyses generated by or on behalf of or in the possession of FEMA concerning the SpMC, including but not limited to the following general issues: Evacuation Process, Personnel and Training, PAR Generation, Communications / tiotification, Legal Issues, Protective Actions For Particular Populations, Evacuation l
Equipment and Facilities, and Coordination of Gevernmental Resources and Response.
i
- 2. Any and all documents generated or received by FEMA concerning the adequacy of the SPMC, including but not limited to internal and external communications.
- 3. Any and all documents constituting o: reflecting communications between NilY (and/or N!!Y ORO) and FEMA since January 1, 1987, pertaining to (a) the need for a utility-generated plan for the Massachusetts EPZ and how it should be designed and staffed; (b) the SPMC itself and its review by FEMA and the NRC; (c) the RAC review process, including comments, suggestions, recommendations, and concerns of the RAC and responses thereto; (d) requests for further information and responses thereto (e) changes to the regula' cions of the NRC and FEMA; (f) and changes to the NRC/ FEMA guidance documents, including NUREG-0654.
- 4. Any and all documents constituting or reflecting c'smmunications between 11RC and FEMA since January 1, 1987, pertaining to (a) the need for a utility-generated plan for the Massachusetts EPZ and how it rhould be designed and staffed; (b) the SPMC itself and its review by FEMA and the flRC; (c) the RAC review process, including comments, suggestions, recommendations, and ccncerns of the RAC and responses thereto; (d) changes to the rtqu.n ations of the NRC and PEMA; (e) and changes to the NRC/ FEMA guidance documents, including f1V R EG- 0 6 5 4 .
o 1
- 5. Any and all communications, including attachments thereto, between FEMA and any fcderal agen.y, other than the NRC, concerning the SPMC or radiological emergency planning for the Massachusetts portion of the Seabrook EPZ. including but not limited to communications with the White Ho'ase and the Executive Branch, EPA, DOE, DOI, FAA, FDA, NOAA, the Defense Department and the U.S. Coast Guard.
- 6. Any and all documents constituting or reflecting communications between FEMA and Argonne National Labs and Idaho National Engineering I,ab, including but not limited to reports, surveys, studies or analyses, concerning the SPMC as well as FEMA's contracts with these entities.
7.Any and all documents concerning the appointment of Richard Donovan as RAC Chairman for FEMA Region I for the review of the SPMC, as well as any and all documents which reflect his experience in the reveiw of radiological emergency response preparedness, including but not limited to internal and external communications including attachments thereto, and Mr. Donovan's resume.
- 8. Any and all minutes / transcripts from RAC meetings where the SPMC was discussed by the RAC.
- 9. Any and all documents, including attachments thereto, which constitute or reflect communications between FEMA and the RAC concerning the review of the SPMC.
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o
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- 10. Any and all documents which constitute or reflect communications between FEMA and the Governor of New Hampshire, John Sununu or his office concerning the SPMC.
- 11. Any and all documents which concern or reflect the activities of Richard Donovan from September 1, 1987 to the present to the extent those activities reflect or concern his efforts as the FEMA official responsible for evaluating the SPMC, including without limitation, memoranda gnerated or recieved by Mr. Donovan, correspondence and written notes of meetings and conversations.
Respectfully submitted, JAMES M. SHANNON ATTORNEY GENERAL COMMONWEALTH OF MASSACHUSETTS By: . .. ___
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ohn Traficon e A'ssistant Attorney General luclear Safety Unit One Ashburton Place, Room 1901 Boston, MA 02108 (617) 727-2200 DATED: October 13, 1988 8-
{
tELAW.0 CORRES@,DM (xdQC UNITED STATES OF AMERICA U W"s NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOAEb EI 2I g ...t^**
Before theW.
Ivan Administrative Judgep;CNO Smith, Chairman 00
^H Gustave A. Linenberger, Jr. W#
Dr. Jerry Harbour
)
In the Matter of ) Docket Nos. 50-443-OL-
) 50-444-OL-PUDLIC SERVICE COMPANY ) (Oft-Site EP OF NEW HAMPSHIRE, ET AL. )
)
(Seabrook Station, Units 1 and 2 ) October 19, 1988
)
hdTICE_DE_ DEPOSITION Pursuant to 10 C.F.H.S 2.740(a) the Massachusetts Attorney General hereby notices the deposition of Richard Donovan, Rep. Program officer / Chairman of RAC for FEMA Region X (in charge of review of SPMC for FEMA Region I), for 10:00 a.m., Wednesday November 9, 1988 at the offices of the Attorney General on the 19th floor of the John McCormick Building at 1 Ashburton Place, Boston, MA. The deposition shall continue from day to day until complete. You are invited to attend and cross-examine, j Massachusetts Attorney General J
ur4A cha Traficonte
'sistant Attorney General Department of the Attorney General 1 Ashburton Place Boston, MA 02108 (617) 727-2200 DATED: Oc tobilt 19, 1988
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B i M i f.?
Ut3ITED STATES OF AMERICA LW C t1UCLEAR REGUI.ATORY COMMISSIO!1'88 OCI 21 P3 :45 cm .
00D i 'g , ,
)
In the Matter of )
)
PUBLIC SERVICE COMPA!1Y OF ) Docket tio.(s) flew HAMPSHIRE, ET AL. ) 50-443/444-OL (Seabrook Station, Units 1 and 2) ) (Off-site EP)
)
_ _ _ _ _ )
CERTIElCATE_Of_ SERV _LCE I, Allan R. Fierce, hereby cert:if y that on October 19, 1988 I made service of the within MASSACHUSETTS ATTORNEY GENERAL'S SECO!1D SET OF._
INTERROGATORIES TO APPLICAtlTS ON THE SEABROOK PLAN FOR MASSACilUSETTS.
COMMUNITIES; MASSACilUSETTS ATTOR! LEY GENERAL'S SECO!1D REQUEST FOR Tile PRODUCTIOli OF DOCUMENTS TO THE APPLICANTS REGARDING THE SEABROOK P L A_N FOR MASSACHUSETTS COMMUNITIES; MASSACHUSETTS ATTORNEY GENERAL'S FIRST PEUUEST FOR THE PRODUCTION OF DOCUMEllTS TO THE FEDERAL EMERGENCY MAllAGEMEt1T AGENCY REGARDIllG THE SEABROOK PLAN FOR MASSACHUSETTS COMMUt1TTIES; and fOTICE OF DEPOSITION, by First Class Mail, or by hand-delivery as Indicated by (*) to the following parties:
Sherwin E. Turk, Esq. Docketing and Service U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission office of General Counsel Washington, DC 20555 15th Floor 11555 Rockville Pike Rockville, MD 20852 Ivan Smith, Chairman Gustavo A. Linenberger, Jr.
Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Pegulatory U.S. fluclear Regulatory Commission Commission East West Towers DuiIding East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda. V i 20814 Dr. Jerry Harbour Robert R. Pierce, Esq.
Atomic Safety & Licensing Board Atomic Safety & Licenstnq Hoard U.S. Nuclear Regulatory U.S. 11uc le a r Regulatoty Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway B e t. h u n d a , MD 20814 Bethe.sda, MD 20814
,4 H. Joseph Flynn, Esq. Stephen E. Merrill Assistant General Counsel Attorney General Office of General Counsel George Dana Disbee Federal Emergency Management Assistant Attorney General Agency Office of the Attorney General 500 C Street, S.W. 25 Capitol Street Washington, DC 20472 Concord, 11H 03301 Docketing and Service Paul A. Fritzsche, Esq.
U.S. fluclear Regulatory Office of the Public Advocate Commission State House Station 112 Washington, DC. 20555 Augusta, ME 04333 Roberta C. Pevear Diana P. Randall State Representative 70 Collins Street Town of Hampton Falls Seabrook, flH 03874 Drinkwater Road Hampton Falls, 11H 03844 Atomic Safety & Licensing Robert A. BactJs, Esq.
Appeal Board Panel Dackus, Meyer & Solomon U.S. tiuclear Regulatory 116 Lowell Street .
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Commission P.O. Box 516 Washington, DC 20555 Manchester, t1H 03106 [
Atomic Safety & Licensing Jane Doughty -
Board Panel Seacoast Anti-Pollution League U.S. fluclea r Regulatory 5 Market Street Commission Portsmouth, t1H 03801 Washington, DC 20555 Matt. hew T. Brock. Esq. J. P. 11adeau Shaines & McBachern Board of Selectmen 25 Maplewood Avenue 10 Central Road P.O. Dox 360 Rye, Illi 02870 Portsmouth, ilH 03801 Sandra Gavutis, Chairperson Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street Kensington, llH 03827 Portsmouth, llH 03801 6
} Senator Gordon J. Ilumphrey Angelo Machiros, Chairman i U.S. Senate Board of Selectmen Washington, DC 20510 25 High Road
- (Attn
- Tom Burack) flewbu ry , MA 10950 Senator Gordon J. Ilumphrey Edward G. Molin i 1 Eagle Square, Suite 507 Mayor 1 Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 l
Donald E. Chick William Lord Town Manager Board of Selectmen Town of Exeter Town liall 10 Front Street Friend Street 4
Exeter, till 03833 Amesbury, MA 01913 i
j Brentwood Board of Selectmen Gary W. Holmes, Esq.
- RFD Dalton Road fiolmes & Ellis Brentwood, 1111 03033 47 Winnacunnet Road Hampton, !JH 03841 Philip Ahrens, Esq. Ellyn Weiss, Esq. ,_
Assistant Attorney General Harmon & Weiss p Department of the Attorney Suite 430 ,
General 2001 S Street, fl . W .
State House Station #6 Washington, DC 20009 Augusta, ME 04333
- Thomas G. Dignan, Esq. Richard A. Hampe, Esq.
Ropes & Gray Hampe & Mctlicholas 225 Franklin Street 35 Pleasant Street Roston, MA 02110 Concord, !!H 03301 Deverly Hollingworth Ashod t). Amirian, Esq.
209 Winnacuntlet Road 376 Main Street Hamptot. IIH 03842 Haverhill, MA 01830 William Armstrong Michael Santosue,so, Chairman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2 10 Front Street South Hampton, PH 03827 Exeter, !JH 03833 Robert Carrigg, Chairman Anne E. Goodman, Chairperson
, Board of Selectmen Board of Selectmen ,
l Town Dffice 13-15 tiewmarket Road j l Atlantic Avenue Dutham, 11H 03824 ;
fl o r t h fl a m p t o n , 1111 03062 I
Allen Lampert Sheldon J. Wolfe, Chairperson Civil Defense Director 1110 Wimbledun Drive Town of Hteritwood McLean, VA 22101 20 Franklin Street i Exeter, flJ 03833 l
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Charles P. Graham, Esq. Barbara St. Andre, Esq.
Murphy & Graham Kopelman & Paige, P.C.
33 Low Street 77 Franklin Street tiewbu rypo t t , MA 01950 Boston, MA 02110
.1udith H. Mizner, Esq. R. Scott Hill-Whilton, Esq.
Lagoulis, Clark, Hill-Whilton Laqoulis, Clark, Hill-Whilton
& McGuire & McGuire 79 State Street 79 State Street tiewbu.yport, MA 01950 tiewburyport, MA 01.*;50 t
- M ___
Allan R. Fierce !
Assistant Attorney General tiuclear Safety Unit .
Department of the Attorney General l One Ashburton Place [
Doston, MA 02108-1698 I (617) 727-2200 DATED: October 19, 1968 [~
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