ML20070W257

Affidavit of Wn Fadden Supporting Thirteenth Motion for Summary Disposition of Contention Necnp I.D.2.No Contention Issue Warrants Hearings.Certificate of Svc Encl

ML20070W257
Person / Time
Site:	Seabrook
Issue date:	02/10/1983
From:	Fadden W PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO.
To:
Shared Package
ML20070W256	List: ML20070W249 ML20070W257
References
NUDOCS 8302180361
Download: ML20070W257 (3)

Text

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AFFIDAVIT OF WILLIAM N. FADDEN I ON NECNP I.D.2 WILLIAM N. FADDEN, being on oath, deposes and says as follows:

1. I am a Senior Instrumentation and Controls Engineer, employed by Yankee Atomic Electric Company. I am currently assigned to the Seabrook Project. My professional qualifications appear in the Operating License Application (FSAR Chapter 13).

.. In response to Applicant's Interrogatory XI-5, NECNP has agreed with the position of the Applicant and the NRC Staff that Regulatory Guide 1.22 provides acceptable methods for performing periodic testing of Protection System actuation functions to show compliance with CDC 21. The Applicant's conformance to Regulatory Guide 1.22 is addressed in FSAR Sections 1.8 and 7.1.2.5.

The Protection System Actuation Functions listed in FSAR Section 1.8 and 7.1.2.5 that are not tested during reactor operation meet the criteria enumerated in that portion of Regulatory Guide 1.22 entitled Regulatory Position D.4. These er.ceptions to testing during reactor operation have been reviewed and accepted by the NRC Staff and are consistent with exceptions justified by operators of similar nuclear power plants that have recently been licensed by the NRC, thus the testing of the Seabrook Protection System actuation functions fully complies with the guidance of Regulatory Guide 1.22.

Any reference to NUREG-0737, Task II.D.1 is not relevant to compliance with CDC 21 as this task only relates to generic testing of relief and safety valves rather than periodic testing of Protection System actuation functions.

Based on the above, I feel there is no issue relative to NECNP Contention I.D.2 on which factual hearings are warranted.

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WillTani N. Fadden COMMONWEALTH OF MASSACHUSETTS Middlesex, ss February 10, 1983 Then appeared before me the above suscribed William N. Fadden and made oath that he was the author of the foregoing affidavit and the statements set forth therein are true to the best of his knowledge, f

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CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attorneys for the Applicants herein, hereby certify that on February 11, 1983, I made service of the within " Applicants' Thirteenth Motion for Summary Disposition (Contention NECNP I.D.2)," 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 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 20535 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 I

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Philip Ahrens, Enquire 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

'[ w ThorrI16 G.p%, Jr.

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