ML20065B092
| ML20065B092 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/16/1983 |
| From: | Bishop L, Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20065B030 | List: |
| References | |
| NUDOCS 8302220392 | |
| Download: ML20065B092 (2) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of
)
)
PUBLIC S"RVICE COMPANY OF
)
Docket Nos. 50-443 NEW HAMPSHIRE, et al.
)
50-444
)
(Seabrook Station, Units 1
)
and 2)
)
)
NECNP MOTION TO COMPEL ANSWERS BY APPLICANTS _TO NECNP THIRD SET OF INTERROGATORIES ON CONTENTIONS I.A.2.,
I.B.l.,
I.B.2.,
and I.C.
Interrogatory No. 7 The answer to this interrogatory is non-responsive.
NECNP asked Applicants to describe in detail the process by which they.have determined -that equipment at seabrook is safety talated.
Applicants merely responded that a determination was made.
The answer should be amended to provide the information requested.
Interrogatory No. 17 Applicants did not answer this interrogatory in the affirmative or negative, as requested.
A yes or no answer must be given.
Applicants also failed to answer Question 17(a).
j NECNP moves to compel answers to Interrogatory 17.
l 8302220392 830216 gDRADOCK 05000443 PDR
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l Interrogatory 21 j
Interrogatory 21(b) asked Applicants, inter alia, to describe the previous experience of individuals responsible for Quality Assurance at Seabrook with former construction projects of PSNH.
Applicants have objected to this interrogatory as
" unintelligible."
The objection is groundless.
The question is a simple one, and should be answered.
Applicants also object to the interrogatory on the ground that it is "not relevant to the admitted contention".
The interrogatory is intended to determine the qualifications and experience of Applicants'.
QA personnel, and is therefore highly relevant to Contentions II B 1 and II.B.3.
Respectfully submitted t-Diane Curran Nl Lee L. Bishop HARMON 5 WEISS 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006 (202) 833-9070 February 16, 1983 i
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