ML20064N751
| ML20064N751 | |
| Person / Time | |
|---|---|
| Site: | Seabrook, 05000447  |
| 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 | |
| ML20064N754 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8302160329 | |
| Download: ML20064N751 (5) | |
Text
RELATED CORRESPONDDIO Filed: February 9, 1983 COLKETED U9mC
'83 FEB 15 All:47 y
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UNITED STATES OF AMERICA
.MANCH
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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' ELEVENTH MOTION FOR
SUMMARY
DISPOSITION (CONTENTION NECNP I.C)
Pursuant to 10 CFR 6 2.749, the Applicants hereby move for summary disposition of contention NECNP I.C This motion is submitted upon the affidavit of Peter L. Anderson, attached hereto.
As is set forth in Mr. Anderson's affidavit, all of the equipment necessary to insure those functions of the pumphouse upon which reliance is placed to preserve safety are 8302160329 830209
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PDR ADOCK 05000443
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classified as safety related and are environmentally qualified.
No such reliance is placed upon equipment for indication of impending freezing conditions, since this is accomplished by inspection by personnel with adequate advance warning to allow operator corrective actions.
Respectfully submitted, lGl Iktta as 6.I) aafy.
o / 72. K. Ga _a Thomas G. Dignan, Jr.
R.
K. Gad III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone:
423-6100 Dated:
February 9, 1983 l
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9 STATMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO DISPUTE 1.
Under the regulations, only those portions of the emergency feedwater pumphouse Heat 3ng Ventilation and Air Conditioning ("HVAC") system that are essential to support the safety function associated with the equipment in the pumphouse are required to be classified as safety related and environmentally qualified.
2.
At Seabrook, only the fans, dampers, motors, electrical cable, and instrumentation and control components are, in fact, so relied upon.
That equipment is, in fact, classified as safety related 4
and environmentally qualified.
3.
The primary safety concern of the pumphouse HVAC equipment is its ability to remove heat generated by the emergency feedwater pumps when those pumps are in operation.
The equipment needed to perform that function is classified as safety related and is environmentally qualified.
4.
No reliance is placed upon the HVAC system either to prevent freezing in the pumphouse when the emergency feedwater pumps are in operation or to provide indication of impending freezing conditions.
The former function is provided by the emergency feedwater pumps themselves, since their own heat generation Wall protect the equipment in the pumphouse from freezing.
The latter function is performed by inspection procedures which provide i
adequate advance warning of HVAC malfunctions to allow operator corrective actions.
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F CERTIFICATE OF SERVICE I, R. K. Gad III, one of the attorneys for the Applicants herein, hereby certify that on February 9,
- 1983, I made service of the within " Applicants' Eleventh Motion for Summary Disposition (Contention NECNP I.C)" 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. Emmeth 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 l
Board Panel Office of the Attorney General l
U.S. Nuclear Regulatory Commission 208 State House Annex
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Washington, DC 20555 Concord, NH 03301 Atomic Safety and Licensing Roy P.
Lessy, Jr., Esquire Board Panel Office of the Executive Legal l
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 115 Lowell Street U.S. Nuclear Regulatory Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105,
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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 RFD 1 East Kingston, NH 03827
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K.
Gad III l.-
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