ML20070M151
| ML20070M151 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/07/1983 |
| From: | Bisbee G, Kinder E NEW HAMPSHIRE, STATE OF |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8301120323 | |
| Download: ML20070M151 (6) | |
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- ."PiRC UNITED STATES OF AMERICA
'83 JAN 10 N0 59 NUCLEAR REGULATORY COMMISSION f;,-Wf.-l..-5;(. y GARv -
yyjyERVICE Before the ATOMIC SAFETY AND LICENSING BOARD
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In the matter of:
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PUBLIC~ SERVICE COMPANY OF NEW HAMPSHIRE)
Docket Nos. :
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and T
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50-444
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(Seabrook Station, Units 1 and 2)
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January 7,1983
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THE STATE OF NEW HAMPSHIRE'S THIRD SET OF INTERROGATORIES 1
--y AND REQUEST FOR PRODUCTION OF DOCUMENTS 4
TO THE NUCLEAR REGULATORY COMMISSION STAFF
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"3 Pursuant to 10 C.F.R., Section 2.740(b) and 2.720th)(2)(II), the Intervenor State of New Hampshire req'uests
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P thatythe attached Third Set of Interrogatories be answered fully 5in writing and under oath by any members of the Nuclear i
Regulatory Commission Staff
(" Staff") who have personal
- knowl. edge thereof.
The answer to each Interrogatory should
.Pz-contain the name(s) and identification of the person (s) supplying the answer and whether or not he or she has verified Su the answer.
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"n M used herein, the term " document" means all original writings of any nature whatsoever and all non-identical copies thereof in the possession, custody, or control of Staff and includes but is not limited to the following items:
communications, correspondence, notes, field notes, studies, reports, summaries, instructions, charts, schedules, sketches and drawings, records, accounts and accounting records, opinions and reports of consultants.
'.AWdsedherein, the term " identify" means:
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0301120323 830107 PDR ADOCK 05000443
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In the case of a natural person:
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(a) name;
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(b) last-known address; J
"C" (c) employer or business affiliation'; and
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(d) occupation'and business position held.
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In the case of a document:
j (a) identity of the person or persons preparing 'it; (b) its title or a description of the general nature
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of the subject matter; (c) the identity of the addressee;
,7 (d) date of preparation; h
(e) identity of persons who can identify it; and
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(f) all of the aforementioned information should be supplied with such reasonable particularity as is sufficient for a specific demand for production.
z4pm In lieu of the foregoing, a copy of the document vs, may be supplied.
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' 3[F In the case of oral statements and communications:
(a) when and where they were made; (b) identity of each of the makers and recipients thereof; (c) the medium of communication; and (d) substance of the statement and/or communication.
Pursuant to 10 C.F.R., Section 2.740(e) and 2.720(h)(2)(II), responses must be supplemented under circumstances when new or different information becomes available.
If Staff cannot answer the Interrogatories in full, so state and indicate when Staff expects to be able to answer the Interrogatory.
The State of New Hampshire further requests that Staff, pursuant to 10 C.F.R.,
Section 2.741, provide copies of or make available for inspection and copying the 1
documents identified by Staff in response to the accompanying Interrogatories within thirty (30) days after service hereof.
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Production of such documents shall be at the Office of the Attorney General in Concord,. New Hampshire, or at a mutually.
convenient place.
- INTERROGATORIES RELATED TO SPECIFIC CONTTNTIONS CONTENTION NECNP I.B.1 The Applicant has not satisfied the requirements of
.'. General Design Criteria 4 and General Design Criteria 34 in that all systems required for residual. heat removal, such as steam dump valves, turbine valves,
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and the entire steam dumping system are not safety
~1 grade and environmentally qualified.
NECNP I.B.l.1 Please state the Staff's position on the Applicant's proposed use of the steam generator for residual heat f
removal in the event of an accident.. Identify and produce, pursuant to 10 C.F.R.,
2.741 all documents prepared by or for the NRC relating to the generic
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issue of the use of steam generators"for residual heat
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O removal or for this proposed use at the Seabrook plant specifically.
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NECNP I.B.l.2 Please state the Staff's position on the adequacy of
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the chemical water treatment process used for the steam generator.
Please identify and produce persuant i
e
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d to 10 C.F.R.,
2.741 all documents prepared by or for the NRC relating to this issue.
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Respectfully submitted, THE STATE OF NEW HAMPSHIRE GREGORY H. SMITH ATTORNEY GENERAL By
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Tupper Kinegt Assistant Attorney General Environmental Protection Div.
Office of Attorney General State House Annex Concord, New Hampshire 03301
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Tel. (603) 2 71-3 67 8' ~
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Dated:
January 7, 1983 By George Dana Bisbee u
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Attorney
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Environmental Protection Div.
Office of Attorney General State House Annex y
Concord, New Hampshire 03301 Tel. (603) 271-3678
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NUCLEAR REGULATORY COMMISSION
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Dated:
By Its
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DISTRICT OF COLUMBIA Personally appeared
, before me, the undersigned officer, and made oath that the foregoing statements are true to his best knowledge and belief.
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Notary Public/ Justice of the Peace Date'dA CERTIFICATE OF SERVICE
.I,. E. Tupper Kinder, Esquire, hereby certify that a copy of the foregoing State of New Hampshire's Third Set of Interrogatories and Request for Production of Documents to the Nuclear Regulatory Commission Staff and The State of New F~
Hampshire's Third Set of Interrogatories and Request for Production of Documents to Public Service Company of New Hampshire, Inc. have been mailed this 7th day of January,1983,
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by first class mail, postage prepaid, to:
- 37 HeleWT. Hoyt, Chm.
Dr. Emmeth A. Luebke Admin'istrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S,4NRC U.S.
NRC Washington, D.C.
20555 Washington, D.C. 20555 l -
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Dr. Jerry Harbor Jo Ann Shotwell, Asst. AG Administrative Judge Office of the Attorney General Atomic. Safety and Licensing one Ashburton Place, 19th Floor
~ Board Panel Boston, MA 02108 U.S. NRC, Washington, D.C. 20555 Mrs. Beverly Hollingsworth
?g--g 822 Lafayette-Road Roy-P..*Lessy, Jr., Esquire P.O. Box 596 Robert Perliss, Esquire Hampton, New Hampshire 03842 office of Executive Legal Dir.
U. S.'t;NRC '
William S. Jordan, II, Esquire Washington, D.C.
~20555 Ellyn R. Weiss, Esquire Harmon and Weiss Robert A. Backus, Esquire 1725 I Street, N.W.
116 Lowell Street Suite 506 P.O..lBox 516 Washington, D.C.
20006 Manch~ ester, N.H.
03105
..u n Edward J. McDermott, Esquire Phillip Ahrens, Esquire Sanders and McDermott Assistant Attorney General 408 Lafayette Road StatesHouse, Station #6 Hampton, N.B.
03842
, Augu_sta, Maine 04333 9F.
Atomic Safety and Licensing
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RobertiK. Gad, Esquire Board Panef Thomas"G. Dignan, Jr., Esquire U.S. NRC Ropesfland Gray Washington, D.C.
20555 225 Franklin Street Boston', Massachusetts,02110 David R.
Lewis, Esquire g
Atomic Safety and Licensing r;-;_;n.
Board
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U.S. NRC - Room E/W - 439 g
Washington, D.C.
20555
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\\Qgg E. Tupper Kipder Dated ? January 7, 1983 g
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