ML20028F008
| ML20028F008 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/21/1983 |
| From: | Curran D NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| NUDOCS 8301280339 | |
| Download: ML20028F008 (26) | |
Text
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' O'OCKETED USNRC January 21' , 1983
. UNITED ';TATES OF AMERICA '83 UA!i27 Pi:i3 NUCLEAR RECULATORY COMMISSION
.BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD
)
In the matter of )
) Docket No. 50-443 PUBLIC SERVICE COMPANY OF ) 50-444 NEW IIAMPSHIRE, et al )
)
(Seabrook Station, Units 1 and 2) )
)
NECNP RESPONSE TO APPLICANTS ' INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS This document constitutes NECNP's response to the interrogatories submitted by Applicants on December.8, 1982..
NECNP is still in the course of evaluating many of the contentions and the materials submitted to us by Applicants and Staff, and where appropriate, answers will be supplemented when our evaluation is completed. We note that-in many cases, we remain unable to fully develop our position on contentions until the Applicants complete and make available certain -
required documents.
Applicants have prefaced their specific interrogatories with three general interrogatories, G-1, G-2 and G-3. With respect to G-1, NECNP identifies the documents' relied upon at the end of each set of interrogatories on a particular f
contention.
NECNP objects, however, to interrogatories G-2 and G-3.
l Interrogatory G-2 is so broad as to encompass-the I
8301280339 830121
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identification of particular mental and analytical processes.
Where mathematical caluclations have been performed by NECNP, we will include these in our responses to the interrogatories.
NECNP will not, however, attempt to describe the mental processes of its members or experts, or include any material which constitutes attorney work product.
NECNP further objects to the request of Interrogatory G-3 that we identity any persons with whom we have communicated regarding tae answers to these interrogatories. The Federal Rules of Civil Pr ocedure, which generally govern NRC proceedings, do not permit discovery of the facts or opinions held by an expert who is not expected to be called at trial.
See Fed. R. Civ. Pro. 26 tb) (4) (B) There is therefore no purpose to be served in identitying all NECNP's sources of technical assistance. In the event that NECNP decides to present the testimony of any of our consultants, we will promptly supplement our answers to these interrogatories to identify those individuals.
I-1-V-4. NECNP has no present intention of litigating the contentions of any other intervenors. We will supplement our answers to these interrogatories if this position should change.
VI-1. Yes.
VI-2-4. Because the Applicants' environmental qualification report is not yet available, NECNP is currently unable to evaluate the status of the qualification of the electric valve operators. We will supplement our response when n
v 3
the environmental report is sutsm it ted .
In general, the basis f or NECNP's contention that electric valve operators have not been qualified to NRC stanoards is that Applicants' FSAR indicates compliance with IEEE-382-1977 and IEEE 323-1974, but does not state that Applicants comply with NUREG-0588, as requirea by the Commission in CLI-80-21.
VI-5. Since Applicants have not submitted their environmental qualification report, NECNP does not have sufficient information with which to answer this question.
VI-6. NECNP has not examined any of the documents containing measurements or estimates of the harshness of the accident environment at Three Mile Island. We will supplement our answer when we have completed our evaluation.
VI-7. As far as NECNP knows, the accident at Three Mile Island still continues, as the core remains inaccessible and the plant continues to rely on instruments exposed to high radiation levels.
VI-8. NECNP has not yet obtained any expert evaluation of this issue. We will supplement our answer when the information becomes available.
VI-9. NECNP has not yet arranged for the testimony by any expert witnesses on NECNP Contention 1.A.2.
G-1. The answers to Applicants' interrogatories on contention I.A.2. are based on the following documents:
1
- VII-l. Yes.
VII-2. NECNP has not yet obtained an expert evaluation of this issue. We will supplement our answer when'the information becomes available.
VII-3. Those components which NECNP now contends must be environmentally qualified are the steam dump valves, turbine valves, and the steam dump control system. NECNP will identify 1 other equipment that must be qualified when we have completed our evaulation of the residual heat removal system.
1 VII-4. See response to VII-2.
I VII-5. See response to VII-2.
VII-6. NECNP has not yet arranged for testimony by any expert witnesses on this contention.
1 G-1. The documents relied on in answering this contention are: NUREG-0510, page A-15 NUREG-0578, page 18 l
NUREG-0705, Task A-45 GDC 4 GDC 34 VIII-1. Yes.
VIII-2. At this time, NECNP contends that duration of qualification has not been established for equipment. listed.in FSAR Table 3.114B)-1 and Appendix 3H. However, NECNP cannot complete its evaluation of the duration of environmental qualification for specific pieces of equipment until Applicants submit their report on environmental qualification.
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VIII-3. Each piece of. equipment should be able to survive i the conditions to which it would be exposed during an accident,-
for the period in which it-would be. required to perform.its safety function.
VIII-4. NECNP is unable at this time to describe.an' exact accident scenario for each and' every piece of equipment listed in response to Interrogatory VIII-2.
VIII-5. As f ar as we know, the accident at Three Mile Island still continues, since the core remains inaccessible and the plant continues to rely on instruments exposed'toihigh radiation levels.
VIII-6. NECNP has not yet arranged for any expert-witnesses to testify with respect to Contention I.B.2.
G-1. The answers to these interrogatories.are based on'the following documents:
NUREG-0588 Memorandum f rom S.II. Ilanauer, Assistant Director forL Plant Systems, DSS, re: Environmental Qualification and Instrumentation (April 6, 1979)
IX-1. Yes.
IX-2. All systems and components in the Emergency Feedwater Pumphouse HVAC which are required to~ monitor pumphouse conditions and maintain the temperature range at.
which the emergency feedwater. system can operate must be considered safety grade. This includes heating and cooling components in the pumphouse ilVAC system.
W IX-3. The basis for NECNP's answer to IX-2 is that since the emergency feedwater pumphouse and its equipment,are' capable of functioning and can be relied upon to function only within a particular temperature range, the HVAC system is required to maintain conditions within that range. Accordingly, it must be environmentally qualified to assure that it will not fail during an accident and thereby allow conditions to occur which would cause the failure of the emergency feedwater system.
IX-4. NECNP contends that, at a minimum, all components identified by Applicants in FSAR 59.4.11 and in answer to NECNP Interrogatory 35 (" Applicants' Answers to NECNP Interrogatories, etc.", dated November 1,1982 at 42-44) must be environmentally qualified. If necessary, we will supplement this answer after we have obtained expert evaluation of the FSAR and Applicants' interrogatory responses.
IX,-5. The IIVAC systems must be able to survive the harshness and duration of conditions to which they would be subjected in an accident.
IX-6. At a minimum, the IIVAC system should be qualified to the parameters of NUREG-0588. NECNP will supply further accident parameters when we have obtained them from our experts.
IX-7. NECNP has not yet arranged for the testimony of any expert witnesses on Contention I.C.
G-1. NECNP relied on the following documents in' answering Applicants' interrogatories with respect to Contention I.C.:
FSAR 59.4.11
FSAR Table 1.3-2, Sheet 14 FSAR Table 3.11 (B)-1, Sheet 4 X-I. Yes X X-5. NECNP is unable to answer these questions since Applicants' " Reactor Vessel. Examination Plan" has not-yet been made available. Moreover, Applicants' FSAR does not provide any specific description of Applicants' preservice or inservice testing program for reactor vessel welds beyond indicating that Reg Guide 1.150 is not fully complied with. NECNP will supplement it answer when the Reactor Vessel Examination Plan is submitted.
X-6. Compliance with Regulatory Guice 1.150'is required-unless Applicants can show some equivalent means of assuring-the integrity of reactor vessel welds.
X-7. The basis for this contention lies in the Applicants'-
FSAR,,which states that Applicants comply wth Reg. Guide 1.150 only to the extent to which " current technology. allows." The PSAR does not indicate-a) what that level of technology is, b) what degree of assurance it provides, or c) what alternative means Applicants will employ to achieve the same level of safety as provided by compliance with the Regulatory Guide.
X-8. NECNP is not aware of other programs for -preservice and inservice inspection of reactor vessel welds.
X-9. NECNP has not yet arranged to have any expert witnesses testify on Contention I.D.1 G-1. The documents relied on f or NECNP's : answers to
interrogatories concerning contention I.D.1 are FSAR at 1.8-57 Reg Guide 1.150 XI-1. Yes.
XI-2. NECNP notes that Amendment 45 to the FSAR reduced the number of protect' ion system actuation functions not tested at full power from twelve to eleven.- For each of these functions, NECNP believes that no justification for not testing each at full power is acceptable.
XI-3. At this time, NECNP does not find any of the justifications for failure to test the twelve functions at full-power to be acceptable.
XI-4. No.
XI-5. Acceptable means of testing actuation devices other than at full power are described in Reg Guide 1.22.
XI-6. The term " reliable" as used in NECNP Contention I.D.2 means providing a reasonable assurance that the equipment will function normally whenever its use is necessary and desirable.
NECNP contends that such assurance can be provided only by testing at full power.
XI-7. NECNP has not yet arranged for' the testimony of any expert witnesses on Contention 1.D.2.
G-1. Documents relied on in answering interrogatories related to Contention I.D.2. are:
FS AR a t 1.8-8, FSAR 57.1.2.5 o
t XII-1. Yes XII-2. At this time, the airborne radioactivity detector appears to us to comply with GDC 21.
XII-3. NECNP is unable at this time to provide a complete list of leakage detection instruments which fail to comply-with GDC 21. They include, however, detection instruments for temperature, flow and humidity as described at FSAR_page 1.8-17.
XII-4. GDC 20 includes, in its definition of protection-systems, those which " sense accident conditions." GDC 21 in turn requires that a protection system "shall be. designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failure and losses of redundancy that may have occurred". Moreover, the leakage detection-system is considered a protection system under IEEE-279-1971, which, states that the nuclear power generating station protection system encompases all electric and mechanical' devices and circuitry ofrom sensors to actuation device input terminals) involved in generating those signals associated wth the protective function. IEEE 279-1971 at 7.
Since the leakage detection system is one which senses accident conditions, NECNP contends that it should be-testable at power as required by GDC 21 and IEEE 279-1971.
XII-5. See answer to XII-4.
XII-6. NECNP has not studied the question of whether the NRC Staf f has required compliance of the leakage detection
system with GDC 21 for other plants.
XII-7. NECNP contends that Seabrook does not comply with positions C.5 and C.8 of Reg. Guide 1.45.
XII-8. See FSAR at 1.8-17 for a: description of Applicants' non-compliance with Reg. Guide 1.45. Applicants fail to comply' with the requirement of position C.8 that "the leakage detection system should be equipped with provision to readily permit testing for operability and calibration during plant operation" Reg. Guide 1.45 at 1.45-4 XII-9. See response to XII-3.
XII-10. See response to XII-3.
XII-ll. See response to XII-4.
XII-12. See response to XII-4.
i XII-13. No.
XII-14. N/A l
XII-15. NECNP has not yet arranged to have any expert 4 .*
witnesses testify on Contention I.D.3.
G-1. The documents relied on by NECNP in answering-Applicants' interrogatories on Contention I.D.3 are listed in
! our response to question XII-4.
XIII-1. In its answers to our interrogatories, the. Staff j has staced that "the Applicant has stated that the Seabrook-I design meets the requirement of IEEE Standard 338-1977." The Staff has also indicated its commitment to enforcing the-requirements of IEEE-338-1977 "unless the Applicants can show an alternative means of achieving the same level of safety."
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See " Responses of the NRC Staff to NECNP's First Set of Interrogatories and Requests for Documents, etc." (December 28,1982) a t - 3 9-4 0. Unless the Applicants should alter their apparent commitment to meet IEEE-338-1977 or the Staff should make a determination of noncompliance with that standard, NECNP does not intend to. pursue this contention. If NECNP's positon should thereby change, we will supplement our answers to Applicants' Interrogatories .
XIV-1. NECNP does not intend to pursue this contention because Applicants have stated thatithey comply with IEEE-323-1974. If NECNP should determine that Applicants do not in fact comply with IEEE 323-1974, we will renew this contention and answer Applicants' interrogatories relating to it. .
XV-1. Yes.
XV-2. As far as NECNP knows, the wide range pressure instruments which are the subject of contention.I.G. are RC-PT-403 and 405, described in " Applicants' Answers to NECNP First Set of Interrogatories and Requests for Documents on Contentions I.D, etc." (November 22, 1982) at page 48.
XV-3. NECNP has not obtained expert evaluation'of the location of the wide range pressure instruments. We will-supplement our answer when this information is available from our consultants.
l XV-4. See response to Interrogatory XV-3.
XV-5. NECNP relies, for its assertion that Seabrook wide i
i I
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range pressure instruments cannot be relied on to provide accurate information, on the information contained in IE Information Notice No. 82-11 ( Apr il 9,198 2) .
XV-6. Yes. NECNP relies in addition on GDC 4, which requires that systems and components important to safety must be designed to accomodate and to be compatible with normal operating and accident conaitions.
XV-7. Yes.
XV-8, XV-9. NECNP objects to these interrogatories in that they call for identification of persons informally consulted by NECNP or discussion of attorney work product, in violation of the Federal Rules of Civil Procedure.
XV-10. NECNP has not yet arranged for testimony by any expert witnesses on Contention I.G.
G-1. NECNP relied on the following documents in answering the interrogatories relating to Contention I.G:
IE Notice 82-11 GDC 4 XVI-1. Yes .
XVI-2. NECNP has not identified a path to cold shutdown for Seabrook. That is the responsibility of Applicants.
XVI-3. See response to XVI-2.
XVI XVI-7. NECNP has not obtained an expert evaluation of these questions. We will supplement our answers as information becomes available.
XVI-8. NECNP has not yet arranged to have any expert I
witnesses testify on Contention I.I.
G-1. NECNP relied on the following documents in answering interrogatories with respect to Contention II:
GDC 4 IE Bulletin 79-01B, Supp. 3 (October 24, 1980)
XVII-1. Applicants' and Staffs' answers to NECNP's interrogatories indicate to us that Applicants have now abandoned the use of acoustic accelerometers. NECNP has asked Applicants to document that change and identify the exact means of determing PORV position which will be used. NECNP is prepared to drop this contention upon assurance from Applicants that direct PORV position indicators are in use at Seabrook.
XVII-2. Applicants' FSAR at Table 1.3-2, Sheet 4 and S5.2.2.8 states that acoustic accelerometers are used to indicate PORV flow. This constitutes an indirect means of indicating PORV position, in violation of NUREG 0737, Clarification Item II.D.1 XVII-3. NECNP relies for its position on NUREG 0737, Clarification Item II.D.l. _
XVII-4. See response to XVII-2.
XVII-5. NECNP has not yet arranged to have any. expert witnesses testify on Contention 1.L.
G-1. See response to XVII-2.
XVIII-1. Yes.
XVIII-2. Applicants are required to comply with Appendix.A to Branch Technical rosition 9.5-1 of the Standard Review Plan
and the requirements set forth in the Commission's final rule on fire protection, 10 CFR 50.48, plus Appendix R to.10 CFR Part 50.
XVIII-3. NECNP Contention I.M. is based on. Applicants
1977 fire protection plan in which Applicants admit various-aspects of noncompliance with Branch Technical Position 9.5-1.
The specific components are listed in NECNP's June 17 filingLat pages 17-18, and in Table 3 of the Applicants' report. See letter from PSNil to NRC dated August 29,1977. Table 3 contains references to Applicants' discussion of the nature of the non-compliance in each case.
In its answers to our interrogatories, the Staff states that Applicants have submitted an updated fire protection evaluation, dated April, 1982. We will update our response to this interrogatory after we have compared the new report with the 19,77 report.
XVIII-4. NECNP has not yet arranged to have any expert witnesses testify on Contention I.M.
G-1. NECNP relied on the following documents in responding to Applicants' interrogatories on Contention I.M.:
Standard Review Plan, BTP 9.5-1 App. A.
10 CFR 50.48 Letter from PSNH to NRC, dated August 29, 1977.
FSAR at 1.8-43.
Response of NRC Staff to NECNP First Set of
Interrogatories, etc. (Dec. 28,_1982), at 58.
XIX-1. No.
XX-1. Yes.
XX-2-4. NECNP has not yet obtained an expert evaluation of the
. materials in this proceeding relating to turbine missiles.. We will supplement our answer when our consultants have made their review.
XX-5. NECNP has not yet arranged to have any expert witnesses testify on contention I.U.
XXI-1. Yes.
XXI 4. NECNP has been concerned in this proceeding that the terms " safety related" and "important to safety"--previously used by the NRC to describe all equipment which must be environmentally qualified--are thought of as distinct categories by Applicants and Staf f, such that equipment defined as "important to safety" would be considered exempt from the NRC's environmental qualification requirements. The NRC has now promulgated a new rule on environmental qualification whose scope includes both equipment that is " safety related" and equipment "whose failure under postulated environmental conditions could prevent'the satisfactory accomplishment of required safety functions-by safety related equipment." 48 Fed. Reg. 2729 (January-21, 1982). NECNP adopts the definitions contained in the new rule for the purpose of determining the proper scope of Applicants' environmental qualification program.
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XXI-5. Yes.
XXI-6. Applicants' updated version of Chapter 17 of the FSAR is still under review by our consultants. We will supplement our answer when the information becomes available.
XXI-7. NECNP has not yet arranged to have any expert witnesses testify on Contention II. B. 1.
G-1. See response to XXI-2-4.
XXII-1. Yes.
XXII-2. The basis for this contention is stated in our filings of April 26 and June 17. NECNP has reviewed Applicants' August 1982 amendments to the FSAR, section 13.1, and concluded that the Quality Assurance program continues to-be defective in that Applicants still have the Nuclear Quality Manager report to a supervisor who is responsible for production. NECNP contends that the Nuclear Quality Manager should instead report to the Vice President for Engineering.
XXII-3. NECNP has not yet arranged -to have any expert witnesses testify on Contention II.B.3.
XXIII-1. Yes.
XXIII-2. NECNP is unable at this time to answer this interrogatory with any further specificity than that provided-in our contention. See filings of April 26 and June 17, 1982.
We will supplement our answer after our consultants have reviewed the FSAR.
XXIII-3. NECNP has not yet arranged to have any expert witnesses testify on Contention II,B.4.
m _
XXIV-1. Yes.
XXIV-2. See answer to interrogatory XXIII-2.
XXIV-3. NECNP has not yet arranged to have any expert' witnesses testify on Contention II.B.S.
XXV XXVIII-3. NECNP does not inte.id at this time to litigate the contentions of any other intervenors. If our position changes, we will supplement our answer.
XXIX-1. Yes.
XXIX-2. The emergency plan does not contain an adequate emergency classification and action level scheme, as required-by 10 CPR 50.4 7 (b) (4) and NUREG 0654, in that:
(a) No justification is given for the classification of various system failures as unusual events, alerts, site area emergencies, or general emergencies, ib) The classification scheme minimizes the potential significance of transients.
(c) The Applicants' classification scheme fails to include consideration of specific plant circumstances, l
such as the anticipated time lag for evacuation due to i
local problems.
- (d) The classification scheme fails to provide a i
reasonable assurance the Seabrook onsite and offsite emergency response apparatus and personnel can be brought to an adequate state of readiness quickly I
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m enough to respond to an accident.
(e) The emergency action level scheme fails to identify emergency action levels or classify them according to the required responses.
If) The scheme is incapable of being implemented effectively to protect the public health and_ safety because it provides no systematic means of identifying, monitoring, analyzing, and responding _to the symptoms of transients and other indicators that transients may occur.
XXIX-3 -21. NECNP has provided examples of the
. deficiencies in Applicants' emergency classification scheme in the bases for its contentions on this issue. We have not had-any experts review this issue, and therefore have nothing to add at this time. This answer will be updated as information becomes available.
i XXIX-22. Yes.
XXIX-23. NECNP contends that Applicants violate 10 CFR 50.47(a) and ib) .
XXIX-24, 25. See response to interrogatories XXIX-3 -21.
l XXIX-26. No.
XXIX-27. N/A.
XXIX-28. At this time, NECNP has'not identified any evacuation time estimates on which it vill rely.
XXIX-29. NECNP has not yet arranged to have any expert witnesses testify on Contention III-l.
4 G-1. NECNP relied on the following documents in answering -
Applicants' interrogatories relating to Contention III.1:
10 CFR 50.47 NUREG 0654 Applicants' Radiological Emergency Plan XXX-1. Yes.
XXX-2. NECNP is unable to answer this interrogatory at this time, since we have not had any experts evaluate _this contention. We will supplement our responses to Applicants' interrogatories on Contention III.2 when we'obtain the necessary expertise.
XXX-3. NECNP considers a " failure of both units" to be any series of events in which, afte,: an accident has. triggered emergencyresponseproceduresib'oneplant, the other plant either a) experiences an accident in which emergency response procedures are also triggered or b) experiences any failure calling for the application of resources or personnel which have already been committed to the accident at the first plant.
XXX-4,5. See response to XXX-2.
XXX-6. See response to XXX-3.
XXX-7,8. See response to XXX-2.
XXX-9. See response to XXX-3 XXX-10,ll. See response to XXX-2.
XXX-12. See response to XXX-3.
XXX-13-25. See NECNP Supplemental._' filing on Emergency Planning Contentions (July 23, 1982) at 5-10.
XXX-26. NECNP has not yet arranged to have any expert witnesses testify in this proceeding.
XXXI-1. Yes.
XXXI-2. In order to conform to Appendix E, SIV(F) of Part 50, Applicants must provide for the training of unit shift I
supervisors to deal with the special situations encountered in emergencies. They include, but are not limited to, making 1
choices amo g alternative responses under stress. NECNP will provide other specific requirements when this information becomes avai) rom our experts.
i XXXI-3. NoCNP has not yet arranged to have-any expert witnesses testify on Contention III.3.
G-1. See response to XXXI-2.
XXXII-1. Yes XXXII-2. The deliciencies in Applicants' evacuation time estima,tes are listed in Contention III.12, NECNP Supplemental Filing on Emergency Planning Contentions (July 23,19 82) at 29-30.
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XXXII-3-8. NECNP has not yet had any experts _ evaluate Contention 111.12. We will supplement our answers to these l interrogatories when the expertise becomes available to us.
E XXXII-9. NECNP has not yet identified "each and every" dilficulty associated with evacuation of the Seabrook area beaches. They include, however,:the narrowness of the beach roads; congest" ion caused by roadside parking; traffic buildup at intersections; the lack of stoplights at intersections;
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) e i -4 limited access roads to the beaches; and the / exfstence in some areas of one-way streets where turning arou,nd~is .
t difficult.
< 8 XXXII-10. NEL.JP has obtained its ' knowledge of the
'T difficulties of leaving the beach'on a crowded weekend through conversations with numerous summer visitors to Seabrook. NECNP did not keep a record of these conversations.
- XXXII-11. Counsel for NECNP interviewed Chief. Robert Mark of the llampton Police Department on July 16, 1982. Any notes of the meeting constitute undiscoverable attorney work l
l product. The conterits of this conversation are described in i -
g NECNP Contention 111.12.- ,,
t XXXII-12. NECNP has had no further conversation with Chief Mark about the evacuation, and cannot supply any additional information besides that contained in the basis of Contention III.12.
s >
X1XII-13. NECNP has got arranged for the testimony of any r-expert witnesses regarding, contention III.12.
G-1. NE:NP relied on the following documents in answering J
Applicants' interrogatories on Contegtion III.12:
i ' '
. NUREG 0654 ,
l ::XX I II-1. Yes d 4
4 -
XXXIII 5. NECNP has not had' Contention III.13 1
evaluated by experts. We will supplement our answers to interrogatories regarding Contention III.13 wben the -
f, i
information becomes available. -
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'XXXIII-6. Evacuee directional bias is the tendency of populations to' move in a particular direction when evacuating in a crisis. ,One study of the accident at Three Mile Island, for example, showed a strong directional bias toward the northwest. The study attributed the bias to such factors as preference for a site upwind from the plant; a psychological i :
attraction to the mountains lin times of danger; and a reluctance to move towar,d more densely populated areas. See Zeigler, et al., " Evacuation from a Nuclear Technological Disaster," Geographical Review, Vol. 71, No. 1, January 1981, at 8-9.
XXXIII-7 NECNP has not performed any evacuation time estimates for Seabrook.
XXXIII-8-9. See response to XXXIII-2-5.
XXXIII-10 The term " evacuation shadow" refers to the j
tendency of an of ficial evacuation advisory to cause departure from a much larger area than was originally intended. See Zeigler, supra at response to XXX~III-7, page 7.
A XXkIII-ll NECNP has n,ot performeo any evacuation time estimates for Seabrook.
XdXIII 20. See response to XXXIII 5.
} ,
XXXIII-21. NECNP has not yet arranged to have any expert
, Ul nesses testify on this contention.
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G-1. NECNP relied on the following documents infanswering
't Applicants' interrogatories on Contention III.13:
i; ,
NUREG 0654 1 3 Zeigler, supra, at response to XXXIII-6.
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I hereby affirm that the facts alleged herein are true and correct to the best of my knowledge and belief.
-~~ f f;5: . . ,. j . i i .-
Diane Curran Subscribed and sworn to before me this 21st day of January, 1983.
.(mu A) 'm WcYM/
Notary Public hig Copa Expecs juk 31. W3I
, Se O
CERTIFICATE OF SERVICE I certify that corrected copies of NECNP's Response to Applicants' Interrogatorien and Requent for the Produc-tion of Documents were mailed January 24, 1983 by first-clanc mail or as otherwise indicated to the-following:
lielen lloyt, 1: h!. , Chai rpermin Phiilip Ahrens, Caq.
Atemic Safet.y and Licensing Anaintant Attorney General Board Panel Depar twent of the Attorney U.S. Nuclear hNul atory Com'ai un wn General Washington, D.C. 20",55 Ahdunt de Ml! 04333 Dr. Emsaeth A. Lucbue !!ohert A. Backus, Esq.
At omic Safety .ohl Licenninil iiI L' swell Street Board Par.cl P.O. Box 516 U.S. Nuclear Regulatory Comminston Manchester, N!! 03105 Washington, D.C. 20555 Dr. Jerry !! arbour Sandra Gavutic Atomic Safety and Licensing RPD 1 Doard Panel East Eensington, Nil 03827 U.S. Nuclear Regulatory Commission Wanhington, D.C. 20555
- Thomas G. Dignan, Esq.
Atomic Safety and Licensing R. K. Gad, III, ESq.
Doard- Panel Ropes and Gray U.S. Nuclear Regulatory Commission 225 Franklin Street Washington, D.C. 20555 lloston, MA 02110 Atomic Safety and Licensing C. Tupper Kinder, Esq.
Appeal Board Panel . Assistant Attorney General U.S. Nuclear Regulatory Comminaion office of the Atty. General Washington, D.C. 20555 208 State llouse Annex Concord, NII 03301 Docketing and Service U.S. Nuclear Pegulatory Roy P. Lessy, Jr.,.Esq.
Commission Robert G. Perlis, Esq.
Washington, D.C. 20555 office of the Executive Legal Director Rep. Beverly lloilingworth Coastal Chamber of Commerce U.S. Ilucicar Regulatory Comj mission 209 Winnacunnet Road Washington, D . 'C . 20555 llampton, NH 03842 Edward J. McDermott, Esq.
Sanders and McDermott Profesnional Association 408 T,afayette Road 1 Ilu m p t o n ,. N il 03842 '
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