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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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gTb skiLATED GUMW'unsweg h UdlXETET Filed: August 8,1986 UMC UNITED STATES OF AMERICA E 11 A10:47 NUCLEAR REGULATORY COMMISSION OFFICE C a.t ur 00CKETINL *. svig' before the SRANCH ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY OF Docket Nos. 50-443-OL-/
NEW HAMPSHIRE, ET AL 5 0 - 4 4 4 -OL -/
(Seabrook Station, Units 1 and 2) On-Site Issues ,
SEACOAST ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE NRC STAFF INSTRUCTIONS FOR USE The Seacoas t Ant i-Pollut ion League hereby reques ts that the NRC Staf f, pursuant to 10 C.F.R 02.740(b) and 02.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce and permit inspection and copying of the original or best copy of all documents identified in their response to interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents herein identified, the Staff file supplemental responses and produce additional documents as required by 10 C.F.R. 02.740(e). .
Where identification of a document is requested, briefly describe the document (e.g. book, letter, memorandum, report) and state the following information as applicable for the particular document; name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person (s) having possession of the document.
The term " document [s]" as used herein shall mean any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, int ra-corporation or intra-o f f ice communi ca t ions , no t ebooks , dia r ies , s ke t ches , diagrams , maps ,
forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals,
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orders, confirmations and all other writ ten or graphic materials of any nature whatsoever.
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Interrogatories SAPL Supplemental Contention 6 (Formerly NH-10)
The Seabrook Station Control Room Design does not comply with General Design Criteria 19 through 22 and 10 C.F.R.
Par t 50, Appendix A, and NUREG-0737, I tems I .D.1 and I . D. 2
- 1) List all documentary or other materials the NRC Staf f may employ in this proceeding to support its position (s) with respect to this contention. in addition to listing such documents and other materials, provide a copy of all of them pursuant t o 10 C. F. R. 6 2. 741
- 2) State the names and provide the curriculum vita (e) of any person or persons relied upon to substantiate in whole or in part the staff's position (s) with respect to this contention.
- 3) Identify any person or persons the NRC S t a f f may call as a witness on this contention, and, if the information has not been -
provided in response to question 2, provide curriculum vita (e) of said person or persons.
- 4) Provide a summarization of the proposed testimony, views or positions of all persons named in response to interrogatories (2) and (3) above that may be presented by the NRC Staf f in this procedding.
- 5) State the specific bases and references to documents which the persons named in response to interrogatories (2) and (3) above may rely upon or reference regarding this contention.
- 6) State with specificity the reasons why the staf f believes that stack monitor and steam generator (or steamline) radiation need not be added to the Saf ety Parameter Display Sys tem (SPDS) until prior to restart following the first refueling outage.
- 7) Does the staff hold that the period of operation prior to the first refueling outage is any safer than any other period of operation, and if so, upon what basis or bases?
- 8) State with specificity the reasons why the Draft License for Seabrook Station, NPF-56, holds that the following modifications should be included on the SPDS prior to restart following the first refueling outage. Provide the staff's reasons for requiring each of the 6 modifications listed below, treating each separately:
- 1. Continuous display of the top level critical safety function summary at the assigned SPDS control room location,
- 11. Addition of, or satisf actory j ustification for, not adding RHR flow and hydrogen concentration parameters to appropriate SPDS screens,
i III. Addition of a containment isolation status screen on SPDS, or improvement to the current containment isolation display to be satisfactorily recognized from the assigned SPDS location in the control room, .
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IV. Addition of a radiation monitoring screen to display at least steam generator (or steam line) and stack radiation, V. Improvement of the Heat Sink screen for consistency in labeling, and the Suberiticality screen for mode dependency so as not to mislead operators, and VI. Addition of approved isolat ion devices between the Reactor Vessel Level Instrumentation System (RVLIS) and SPDS.
- 9) Name the person or persons who were responsible for deciding that the modifications listed in interrogatory 8 could be deferred and handled with license conditions and state when this decision made.
- 10) State the bases upon which the decision was made to allow ,
Applicants to def er review of the control room f urnishings f or Human Engineering Discrepancies (HEDs) until prior to startup from the first refueling outage.
- 11) Name the person or persons who made the decision referred to in interrogatory 10 and state when this decision was made.
- 12) State the bases upon which the decision was made to allow Applicants to def er review of the operator protective equipment and emergency equipment storage for HEDs until prior to startup f rom the first refueling outage.
- 13) Name the person or persons who made the decision referred to in interrogatory 12 and state when this decision was made.
- 14) Describe the staff's justification for not requiring that a preliminary evaluation of the control room environment be done prior to fuel loading.
- 15) List any other specific actions and/or requirements, if any, that the NRC Staff is allowing Applicants to defer until the first refueling outage.
- 16) NUREG-0737 II.B.1 requires that reactor coolant system vents be remotely operated from the control room. Identify all documents which relate to the staf f's review of the displays and controls which have been added to the control room as a result of II.B.1. Please produce such documents pursuant to 10 CFR I 2.741.
- 17) NUREG-0737 II.D.3 requires that reactor coolant system relief and safety values be provided with positive idication in the control room. Identify all documents which relate to the staff's review of the displays and controls added to the control room as a result of II.D.3 and produce them pursuant to 10 CFR 12.741.
I
- 18) NUREG-0737 II.F.1 requires additional accident monitoring instrumentation and associated displays and controls to be added to the control room. Identify all documents which relate to the staf f's review of the displays and controls added to the control room as a result of this requirement. Please produce these documents pursuant to 10 CFR 92.741.
- 19) NUREG-0737 II.F.2 relates to additional instrumentation for detection of inadequate core cooling. Identify all documents which relate to the staf f's review of the types and locations of displays and alarms to be added to the control room as a result of this instrumentation. Please produce such documents pursuant to 10 CFR 92.741.
- 20) State whether the NRC Staff has reviewed the results of the July 1986 Westinghouse tests of isolation related to the isolator circuit in the RVLIS monitor output feeding the plant computer (See SBN-987 at 2). If so, please state the staff's conclusions based upon review of those tests. I f no review has been done, state why i t ,
has not been done.
- 21) State whether or not the staff has reviewed the program manual for the computer system methods of exchanging information relative to the SPDS. If so, please state the staff's conclusions. If not, please state the staff's reasons for not having done so.
- 22) When the NRC Staff performed the combined Design Verification and Design Validation audi t of SPDS on May 20-21, 1986, did the human factors audit scheduled for Day 2 at 9 AM occur in the Cont rol Room, t he TSC, t h e EOF , the Control Room Simulator or the SPDS engineering simulator?
- 23) Provide all documents detailing the staff's SPDS review of the saf ety analysis report, the implementation plan and the verification and validation plan and the findings thereof.
- 24) Describe and present the conclusions of the staff's review of the Applicant's incorporation of the lessons learned from the Salem ATWS event in the DCRDR.
- 25) State whether or not the staff believes that the Applicants' DCRDR system function and task analysis and subsequent comparison of results of the analysis with the control room inventory fully satisfies the requirements of Supplement 1 to NUREG-0737 and name the person or persons who assume responsibility for the staff's conclusion on this matter. Provide the documents related to the staff's review.
- 26) State whether or not the staff believes that the Applicants' DCRDR review is sa t is f actor ily comple ted and HED's satisfactorily resolved for each of the following items and provide any documents detailing the staff's assessment:
f a) video alarm system and associated computer aids to the operator b) hard-wired annunciators ,
c) radiation monitoring system d) lighting e) control room access and architecture relative to supervision, storage of emergency equipment, escape, limit ing access of unauthorized personnel, rest rooms, and eating facilities f) storage of operating procedures and keys, tagging, shift turnover, and other administrative procedures g) remote shutdown panel h) MSIV panel -L i) fire panel .
j) consistent abbreviations k) hierarchical labeling
- 1) steam dump meter - legibility m) atmospheric dump valve controllers - accessibility NECNP Contention I . B. 2 The Applicant has not satisfied the requirements of GDC 4 that all equipment important to safety be environmentally qualified because it has not specified the time duration over which the equipment is qualified.
- 1) List all documentary or other materials the NRC Staf f may employ in this proceeding to support its position (s) with respect to this contention. In addition to listing such documents and other materials, provide a copy of all of them pursuant t o 10 C. F. R. 0 2. 714
- 2) State the names and provide the curriculum vita (e) of any person or persons. relied upon to substantiate in whole or in part the the staffs position (s) with respect to this contention.
- 3) Identify any person or persons the NRC Staff may call as a witness on this contention, and, if the information has not been provided in response to question 2, provide curriculum vita (e) of said person or persons.
J
- 4) Provide a summarization of the proposed testimony, views or
- positions of all persons named in response to interrogatories (2) and
- (3) above that may be presented by the NRC Staf f in this proceeding.
- 5) State the specific bases and references to documents which the persons named in response to interrogatories (2) and (3) above may rely upon or reference regarding this contention.
- 6) State whether or not the NRC Staf f has reviewed the Applicants' 4 analysis suppor t ing conformance wi th Reg Guide 1.75. If so, provide l the documentation related to this review.
- 7) State with specificity the reasons why the NRC Staff position is that an environmentally qualified instrument to monitor the containment sump water temperature and an environmentally qualified instrument to monitor either accumulator tank pressure or accumulator tank level should be installed before startup from the first refueling.
- 8) State why the staf f holds the position that this equipment can be done without up until the first refueling but should not be done without thereafter.
- 9) Has the NRC Staff independently verified that the results of WCAP-8822, Supplement 2, are applicable to the Seabrook Model F Steam generator?
- 10) What uncertainties are taken into account in the Seabrook Cycle 1 nuclear design calculated shutdown margin at end of life?
- 11) State why the NRC Staff does or does not believe it necessary to consider the scenario of high energy line breaks (HELBs) occurring contemporaneously in both pipe chases. State what would be expected to occur under such a scenario.
- 12) State why the NRC Staff does or does not believe it necessary to consider the scenario of more than one control rod failing to insert contemporaneously with HELB in one of the pipe chases. State what would be expected to occur under such a scenario.
- 13) State how the NRC S ta f f chos e the 12 qualification files it audited on Feb. 25, 26, and 27, 1986.
- 14) State why the NRC Staf f did not choose to audit additional files upon having found deficiencies in the audited files.
- 15) State whether or not the NRC Staff has or intends to verify that the deficiencies identified as a result of the qualification file audit have been or will be corrected prior to fuel load.
- 16) State the staff's position with respect to the qualification of post-accident monitoring equipment. Provide any documents the staff relys upon to support its position.
t' 2
Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By Its Attorneys, BACKUS, MEYER & SOLOMON 4 SChW" R,0 birt A.*Backus
- 4. O. Box 516 Manchester, NH (603)668-7272 -
I hereby certify that copies of the above have been sent Federal Express to those indicated by an
- on the attached service list and first-class postage prepaid to other parties on the service list.
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13eber t A. Ba'c k u s ~
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o 1 CERTIFICATE OF SERVICE AND SERVICE. LIST i
d Jose Asst.Gn.Cnsl. Sheldon J. Wolfe, Chrm." Thomas.Dignan, Esq.+
Fed. ph FlynnEmerg. Egmt. Agcy. Aden. Judge Ropes & Gray 500 C.St. So. West Atomic Safety & Lic Brd. 225, Franklin St.
Washington, DC 20472 USNRC Boston, MA 02110 Washington, DC 20555 l Office of Selectmen Dr. Jerry Harbour. *' Docketing & Serv. Sec.a Town of Hampton Falls Admin. Judge i Hampton Falls, NH 03844 Atomic Safety & Lic Brd.
Office of the Secretar)
USNRC USNRC Washington, DC 20555 Washington, DC 20555 l Off e of ec. Legl Dr. d$11n u ge SA L i Atomic Safety & Lic. Brd. 5 Market Street ahs ngton, DC 20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq. Paul McEachern, Esq. George Dana Bisbee, Esq. -:
Asst. Atty. General Matthew Brock, Esq. Attorney General's OFF.
State H0use, Sta. #6 25 Maplewood Ave. State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsnouth, NH 03801 Cazul Sneider, Esq. , Asst. AG Diane Curran, Esq. William S. Iord One Ashburton Place, Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.
Boston, MA 02108 Washington, DC 20009 Amesbury, MA 01913
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Richard A. Hampe, Esq. Maynard Young, Chairman Sandra Gauvutis New Hampshire Civil Defense Board of Selectmen Town of Kingston
, Agency 10 Central Road Box 1154 Rye, NH 03870 Hampe & McNicholas East Kensington, NH 03827 35 Pleasant St.
- 1 Concord, NH 03301 Edward Thomas Mr. Robert Harrison FDIA Pres, & Chief Exec. Officer 442 J.W. McConmck (POG) PSCD Boston, MA 02109 P.O. Box 330 Manchester, NH 03105 Roberta Pevear i
State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, hTI 03844
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