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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 6/4/87 UNITED STATES OF AMERICA NUCLEAR REGULATORY COfMISSION BEEORE THE ATOMIC SAFETY LICENSING BOARD In the Matter of )
) Dacket tb. 50-443 Public Service Co. of New Hampshire, ) 50-444
. et al. ) (Offsite)
)
(Seabrook Station, Units 1 & 2) )
RESPONSE OF THE FEDERAL EMERGENCY MANAGEMENT AGENCY TO THE TOWN OF HAMPION'S SUPPLEMENTAL INTERROGATORIES AND REQUESTS EOR PRODUCTION OF DOCLNENIS TO FEMA ON THE NEW HAMPSHIRE RERP The Federal Bnergency Management Agency (FEMA) is not a party to the above-captioned proceeding and it is, for that reason, not obligated to respond to the interrogatories propounded by any intervenors. FEMA voluntarily provides the information supplied below, but reserves the right to object to future discovery requests. ,
Interrogatory No. S-1:
Please supplement, and provide a full and canplete response, to TOW OF HAMPION INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENIS TO THE FEDERAL EMERGENCY MANAGEMENT AGENCY ON THE NEW HAMPSHIRE RADIOLOGICAL RESPONSE PIANS dated March 5,1987 and previously served upon FEMA.
Previous Interrogatory 1
- a. What is FEMA's position with respect to each contention and its subparts? Describe in detail the reasons for your position. Identify any relevant portions of the state and local plans that are under revision or which the state expects to change at any time in the future.
8706100199 870604 PDR C ADOCK 05000443 PDR
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- b. Identify and provide access to all documents on which you rely during this proceeding to support your position on each of these contentions.
'Ihis includes all docunents used in answers to these interrogatories, sumnary disposition motions, testimony, and crosMxamination of witnesses during ,
hearings.
- c. Identify all persons you may call as witnesses on each of these .
contentions during these proceedings; describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.
- d. -Identify all persons on whose factual knowledge,, opinions, or technical expertise you rely for your position on each contention and subpart thereof.
Answer No. S-1 (to previous Interrogatory-1)
- a. FEMA has developed a position with respect to each contention (including subparts) admitted for litigation in this proceeding. Our position .
and reasons for the position are set forth in Appendix A of RESPONSE OF 'IllE i
FEDERAL EMERGENCY MANAGEMENT AGENCY TO MASSACHUSETTS ATIORNEY GENERAL, JAMES M. SHANNON'S OFP-SITE EMERGENCY PREPAREDNESS INTERROGATORIES AND REQUEST EOR PRODUCTION OF DOCLMENIS TO FEMA (SET No. 2) (Hereinafter called Appendix A),
which is included with.this filing and incorporated into this Response to the Ibwn of Hampton's Interrogatories. FEMA has no knowledge of the relevant portions of State and local plans that are under revision or which the State expects to change in the future beyond that provided in the status reports served on the parties to this proceeding by the Attorney General of the State of New Hampshire.-
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-1 4
l
- 3/ -
9
- b. The doctanents on which FEMA relies in support of its position 1
on each of'the contentions is specifically identified in Appendix A. To the best of my knowledge these documents-have.been made available to the
- parties to this pro eding previously or as part of FEMA's subnission"made this day.
J c. FEMA has not yet identified the persons who it will call as witnesses to this proceeding and therefore can neither provide the sub-stance of their testimony nor describe the doctanents that they may rely upon beyond those mentioned in Appendix A or in our previous answer to this question.
- d. FEMA relied on the following persons for knowledge, opinions and l technical experience with respect to our positions on the contentions:
.1) FEMA Staff: -
Edward A. Thomas-John C. Iblan Bruce J. Swiren Fenneth Ibrak
- 11) Argonne National Laboratory Staff:
lbbert Ibspenda Margaret Singh iii) The Members of or Agency Representatives to the Regional Assistance Comnittee, (See attached list)-
iv) Cbservers at the February 26, 1986 Ekercise of the New Hampshire Plans, (See list contained in FEMA's report on this exercise previously served on the l parties).
~
- Previous Interrogatory 2 Please identify all persons on whose factual knowledge, opinions, or technical expertise you rely for your position on each contention and subpart thereof.
f'
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Answer No. S-1 (to previous Interrogatory-2)
This interrogatory is answered as part of our response to Previous Interrogatory 1 (d.) supra.
Previous Interrogatory No. 3 Identify and describe any deficiencies, including those set forth in FEMA Final Exercise Assessment February 26, 1986, for which Applicant and/or the State of New Hampshire have not undertaken adequate corrective action.
Answer No. S-1 (to previous Interrogatory 3)
The analysis of the deficiencies in the February 26, 1986 Exercise of the New Hampshire RERP is set forth in the FEMA Final Exercise Assessment for the exercise. The listing of inadequacies with respect to the NHRERP Rev. 2 is set forth in the Final FEMA RAC Review for Rev. 2 dated December 12, 1986. FEMA has not yet done an analysis-of whether any of the deficiencies listed in the report of the February 26, 1986 exercise have been corrected. To date, this agency has not received plans on other documents which would correct the inadequacies found in the NHRERP (Rev. 2).
Interrogatory No. S-2 Please identify amd describe FEMA's present position with respect to all Motions for Sumary Disposition, and responses thereto, previously filed in this proceeding.
Answer S-2 FEMA's position on all motions for Sumary Disposition and responses thereto is contained in Appendix A.
Attachments:
RAC Listing P
1
6 1/
I declare, onder penalty of perjury, that the foregoing responses to the Town of Hampton's Interrogatories and Request for Production of Ibctnents are true and complete to the best of my knowledge and. belief.
/
Edward A.6 Thcnas, Division Chief
~
Natural & Technological Hazards Region I .
Federal anergency Management Agency Dated June 4, 1987 Boston, Massachusetts O
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-_ y g. - . ___ _ . . _ . -. . - - . - _,_.______.7, , __ y ,y, - ,_ _---,7 ,
a g' FEMA REGION 1 Regional Assistance Ccmnittee Members
. Comnittee Menber Mr. Paul IAltz William P. Patterson Regional Dnergency Transportation Rep U.S. Department of the Interior Capt. John Foster Williams Coast Guard Bldg. Regional Environmental Office 408 Atlantic Ne. 1500 Custom House Boston, MA. 02210-2209 165 State St.
Boston, MA 02109
- Mr. Byron Keene U.S. Environmental Protection Agency 2312 JFK Federal Building Boston, MA 02203 (23rd Floor)
Mr. Warren Church Regional Radiological Health Representative U.S. Food & Drug Administration 585 Connercial St.
Boston, MA 02109
- John Stepp U.S. Dept. of Health & Human Services Public Health Service Representative 1401 JFK Federal Bldg. (14th Floor) ~
Boston, MA 02203 John Schumacher Nuclear Regulatory Ctanission Region I 631 Park Ave. .
King of Prussia, PA 19406 lbbert Bores (Seabrook)
Nuclear Regulatory Cmmission 631 Park Ave.
King of Prussia, PA 19406 (Ibrothy Nevitt/ Bob Conley/Cheryl Malina Anna Hart)
Office of anergency Planning USDA - FSIS-PP 14th & Independence Ne., S.W.
Ibam 2940 - South Bldg.
Washington, D.C. 20250 Mr. Herbert G. Fish U.S. Department of Energy Princeton Area Office P.O. Box 102 Princeton, NJ 08542
e s i CERTIFICATE OF SERVICE DOLq p -
og I, Elward A. Ihmas, The FEMA Region I Division Chief for Natural anj7 JUN -5 P2 :16 Technological Hazards, and an Attorney, hereby certify that on June 4, 1987, I made service of the within documents by sending copies by 0FFn ,
guaranteed overnight delivery or by arranging for hand delivery. 00 CME c e, j
- y; Helen Ibyt, Esq., Chairman Stephen E. Merrill Administrative Judge Attorney General Atmic Safety & Licensing Board George Ihna Bisbee U.S. Nuclear Regulatory Comission Assistant Attorney General Washington, DC 20555 Office of the Attorney General 25 Capitol Street Dr. Jerry Harbour Concord, NH 03301 Administrative Judge Atomic Safety and Licensing Board Angie Machiros, Chairman U.S. Nuclear Regulatory Cmmission Board of Selectmen 25 High Road Beverly Hollingworth Newbury, MA 09150 209 Winnacunnet Road Hampton, NH 03842 Allan tampert Civil D3fense Director Sandra Gavutis, Chairman 'Ibwn of Brentwood Board of Selectmen 20 Franklin St.
RFD 1 Box 1154 Exeter, NH - 03833 Kensington, NH 03827 Gustave A. Linenberger, Jr. Charles P. Graham, Esq.
Idministrative Judge McKay, Murphy and Graham Atmic Safety and Licensing Board 100 Main St. ,
U.S. Nuclear Regulatory Cmmission Imesbury, MA 01913 Washington. DC 20555 Diane Curran, Esq.
- Ms. Carol Sneider, Esq. Harmon & Weiss Assistant Attorney General 2001 S. St., N.W.
Office of the Attorney General Suite 430 One Ashburton Place,19th Floor Washington, D.C. 20009 Boston, MA 02108 Sherwin E. Turk, Esq.
Richard A. Hampe, Esq. Office of the Executive I;3 gal Director New Hampshire Civil Defense Agency U.S. Nuclear Regulatory Cmmission 107 Pleasant Street Washington, D.C. 20555 Concord, NH 03301 H.J. Flynn, Esq.
Calvin A. Canney, City Manager Assistant Ceneral Counsel City Hall Federal anergency Management Agency 126 thniel St. 500 C Street, SW Portsmouth, NH 03801 Washington, DC 20472
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N Jane Ibughty Atmic Safety and Licensing Seacoast Anti-Ibilution Appeal Panel 5 Market St.
U.S. Nuclear Pegulatory Camission Ibrtsmouth, NH 03801 Washington, DC 20555 Maynard L. Young, Chairman Paul McEachern, Esq. Board of Selectmen Matthew T. Brock, Esq. 10 Central Ibad Shaines & McEachern So. Hampton, NH 03287 25 Maplewood Ave.
P.O. Box 360 Michael Santosuosso, Chairman Ibrtsmouth, NH 03801 Board of Selectmen South Hampton, NH 03287 lbberta C. Ibvear State Pepresentative Mr. Robert Carrigg, Chainnan Tbwn of Hampton Falls Board of Selectmen Drinkwater Ibad Ibwn Office Hampton Falls, NH 03844 Atlantic Avenue tbrth Hampton, NH 03862 Mr. Ibbert J. Harrison President & Chief Executive Officer
Public Service Co. of New Hampshire Ibpes & Gray P.O. Box 330 225 Franklin Street Manchester, NH 03105 Boston, MA 02110 Robert A. Backus, Esq. Gary W. Holmes, Esq.
Backus, Meyer & Solmon Iblmes & Ellis 116 Iowell St. 47 Winnacunnet Ibad Manchester, NH 03106 Hampton, NH 03842 Philip Ahern, Esq. Ibcketing and Service Section Assistant Attorney General Office of the Secretary Office of the Attorney General U.S. Nuclear Regulatory Camission State House Station #6 Washington, DC 20555 Augusta, MS 04333 William S. tard
- Thmas G. Dignan Jr. , Esq. Board of Selectmen Ropes & Gray Tbwn Hall - Friend Street 225 Franklin St. Anesbury, MA 01913 Boston, MA 02110 Ibter J. Matthews, Mayor William Armstrong City Hall Civil Defense Director Newburyport, MN 09150 Tbwn of Exeter 10 Front St/
Exeter, NH 03833 Silverglate, Gertner, Baker Fine and Good Atmic Safety and Licensing 88 Broad Street Board Boston, MA 02110 U.S. Nuclear Regulatory Cmmission Washington, DC 20555 0 Denotes Hand Delivery
e Mrs. Anne E. Cbodman', Chairman Board of Selectmen 13-15 Newnarket Bbad-
'Durham, NH 03824
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Honorable Gbrdon J. Htanphrey United States. Senate 531 Hart Senate Office Building
. Washington, DC- 20510
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IMward A. Thomas e
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