ML20064N727
| ML20064N727 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/09/1983 |
| From: | Dignan T, Gad R PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20064N729 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8302160323 | |
| Download: ML20064N727 (5) | |
Text
BELATED CORRESPONDENCE Filed: Fcbrunry 9, 1983 00LKETED USNRC
'83 FEB 15 N1 :47 UNITED STATES OF AMERICn f;hh!;.3ffg[jik i.
GRA!!CH NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD.
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In the Matter of
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PUBLIC SERVICE COMPANY OF NEW
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Docket Nos. 50-443 OL HAMPSHIRE, et al.
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50-444 OL
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(Seabrook Station, Units 1 & 2)
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APPLICANTS' SIXTEENTH MOTION FOR
SUMMARY
DISPOSITION (CONTENTION NECNP I.M)
Pursuant to 10 CFR S 2.749, the Applicants hereby move for summary disposition of contention NECNP I.M This motion is submitted upon the affidavit of Edward A.
Sawyer, attached hereto.
As is set forth in i
the affidavit of Mr. Sawyer, the Seabrook Fire Protection Plan satisfies the requirements of GDC 3 as implimented by the Commission is CLI-80-21.
The FPP B302160323 830209 PDR ADOCK 05000443 1s03
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meets all the specifics of Branch Technical Position 9.5-1, Appendix A or provides equivalent alternative protection, which has been reviewed by and accepted by the Staff.
The FPP also meets all the applicable requirements of 10 CFR, Part 50, Appendix R or provides equivalent alternative protection, which has also been reviewed by and accepted by the Staff.
For these reasons, there is no needs of evidentiary hearings and Contention I.M should be dismissed.
Respectfully submitted, p / / Anua
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d' Thomas G.
Dignan, Jr.
R. K. Gad III Ropes & Gray 225 F anklin Street Boston, Massachusetts 02110 Telephone:
423-6100 Dated:
February 9, 1983 l 1
D STATTh ' OF MATERIAL FACTS AS TO WHICH THERE IS NO DISPUTE 1.
The Seabrook Fire Protection Plan ("FPP") meets all the technical requirements of Branch Technical Position 9.5-1, Appendix A, er provides equivalent alternative protection.
The Staff has reviewed the FPP against BTP 9.5-1 and accepted it.
-2.
The Seabrook Fire Protection Plan ("FPP") meets all the technical requirements of 10 CFR, Part 50, Appendix R, or provides equivalent alternative protection.
Thejstaff has reviewed the FPP against Appendix R and' accepted it.
3.
The FPP meets the requirements of General Design Criterion 3, as'implimented by the Commission in CLI-80-21.
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CERTIFICATE OF SERVICE I, R. K. Gad II7 one of the attorneys for the Applicants herein,.sereby certify that on February 9,
- 1983, I made service of the within " Applicants' Sixteenth Motion for Summary Disposition (Contention NECNP I.M)" by mailing copies thereof, postage prepaid, to:
Helen Hoyt, Chairperson Rep. Beverly Hollingworth Atomic Safety and Licensing Coastal Chamber of Commerce Board Panel 209 Winnacunnet Road U.S.
Nuclear Regulatory Commission Hampton, NH 03842 Washington, DC 20555 Dr. Smmeth A.
Luebke William S. Jordan, III, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 1725 I Street, N.W.
U.S. Nuclear Regulatory Commission Suite 506 Washington, DC 20555 Washington, DC 20006 Dr. Jerry Harbour E. Tupper Kinder, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Office of the Attorney General U.S. Nuclear Regulatory Commission 208 State House Annex Washington, DC 20555 Concord, NH 03301 Atomic Safety and Licensing Roy P. Leasy, Jr.,
Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Robert A. Backus, Esquire Board Panel 116 Lowell Street U.S.
Nuclear Regulatory Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 -_
Philip Ahrens, Esquire Edward J. McDermott, Esquire Assistant Attorney General Sanders and McDermott Department of the Attorney Professional Association General 408 Lafayette Road Augusta, ME 04333 Hampton, NH 03842 David L. Lewis Jo Ann Shotwell, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission Department of the Attorney General Rm. E/W-439 One Ashburton Place, 19th Floor Washington, DC 20555 Boston, MA 02108 Mr. John B. Tanzer Ms. Olive L. Tash Designated Representative of Designated Representative of the Town of Hampton the Town of Brentwood 5 Morningside Drive R.F.D.
1, Dalton Road Hampton, NH 03842 Brentwood, NH 03833 Roberta C. Pevear Edward F. Meany Designated Representative of Designated Representative of the Town of Hampton Falls the Town of Rye Drinkwater Road 155 Washington Road Hampton Falls, NH 03844 Rye, NH 03870 Mrs. Sandra Gavutis Designated Representative of the Town of Kensington RED 1 East Kingston, NH 03827 r
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