ML20070W180
| ML20070W180 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/14/1983 |
| From: | Dignan T, Gad R PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8302180322 | |
| Download: ML20070W180 (5) | |
Text
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SmD conPIsPONDENCF Filed:
February 14Y. X,.a,. 9,83 1
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'83 EB 15 P3:59
- OSE YhbE UNITED STATES OF AMERICA
- RANCH 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' SEVENTEENTH MOTION FOR
SUMMARY
DISPOSITION (CONTENTION NECNP I.U)
Pursuant to 10 CFR S 2.749, the Applicants hereby move for summary disposition of contention NECNP I.U.
In their answer to NECNP interrogatory I.U-1 filed November 22, 1982, the Applicants detail the basis on which they believe GDC 4 is satisfied by protecting systems and components important to safety from the effects of turbine missiles.
Per contra, in its 8302180322 830214 x
PDR ADOCK 05000443 CU O
PDR 7
Y answers filed January 21, 1983 to Applicants interrogatories Nos. XX-2 -- XX-4, NECNP has made abundantly clear that it has no basis for disagreeing with the Applicants' analysis given in response to NECNP interrogatory No.
I.V.-l.
Indeed NECNP's answers to these interrogatories make clear that they have no basis for the contention at all.
The same is true of NHAG as demonstrated by its response to Applicants' interrogatories XX-2 -- XX-4 filed by NHAG on January 17, 1983.
Thus, on the basis of the above-described answers to interrogatories now on file, summary disposition of this issue is in order in favor of the Applicants.
Respectfully submitted,
. 9' _
.Y'
' ~~ [frlc > ar Thomas G.
Dignan, Jr.
R. K. Gad III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone:
423-6100 Dated:
February 14, 1983 I
STATMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO DISPUTE 1.
The answers to interrogatories filed by NECNP and NHAG make clear that they have no present basis for the contention.
2.
The Applicants have set forth in their answers to interrogatories a complete analysis as to how GDC 4 is satisfied insofar as it bears on the protection of safety systems and components from turbine missiles.
I r
1 i
CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr.,
one of the attorneys for the Applicants herein, hereby certify that on February 14, 1983, I made service of the within " Applicants' Seventeenth Motion for Summary Disposition (Contention NECNP I.U)," 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 03342 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 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.
- Lessy, 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.
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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 Calvin A. Canney Designated Representative of City Manager the Town of Kensington City Hall RFD 1 126 Daniel Street East Kingston, NH 03827 Portsmouth, NH 03801
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Thomas G. DicinagT