ML20071A255

Affidavit of Wn Fadden Supporting Fourteenth Motion for Summary Disposition of Contention Necnp I.D.3.No Contention Issue Warrants Hearings.Certificate of Svc Encl

ML20071A255
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
ML20071A249	List: ML20071A247 ML20071A255
References
NUDOCS 8302180493
Download: ML20071A255 (3)

Text

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AFFIDAVIT OF WILLIAM N. FADDEN ON NECNP I.D.3 WILLIAM N. FADDEN, being on oath, deposes and says ad follows:

1. I an 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).

2. FSAR 1.8-17 lists certain exceptions to Regulatory Guide 1.45. Full compliance has been achieved since that was written. As a result, the Applicant's response to Interrogatory I.D.3-2 states that the Applicant complies with all sections of Regulatory Guide 1.45. Specifically, we have the capability to test and calibrate all leak detection instrumentation during plant operation as required by Regulatory Positirn C.8 of Regulatory Guide 1.45.

, NRC response to Contention I.D.3. Interrogatory 1, states that the Staff does not require that the Rasctor Coolant Pressure Boundary Leakage Detection Systems meet the requirements of General Design Criterion 21 as it is not part of the Reactor Protection Systaa.

The Staff considers compliance with the Regulatory Positions of Regulatory Guide 1.45, " Reactor Coolant Pressure Boundary Leakage Detection Systems",

as meeting the requirements of GDC 30.

Based on the above, I feel there is no ' issue relative to NECNP Contention I.D.3 on which factual hearings are warranted.

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William 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.

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Allen L.'L ., No Public My Commis as Aug 5, 1988 i

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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' Fourteenth Motion for Summary Disposition (Contention NECNP I.D.3)," by mailing copies thereof, postage prepaid, to:

Helen Hoyt, Chairperson Rep. Beverly Hollingworth Atomic Safety and Licensing Coastal Chamber of Cor:merce Board Panel . 209 Winnacunnet Road U.S. Nuclear Regulatory Commission Hampton, NH 03842 Washington, DC 20555 Dr. Emmoth 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. 1;uclear 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 Rer21 story Comunission Washington, DC 205S5 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

Philip Ahrens, Esquire Edward J. McDermott, Esquire Assistant Attorney General Sanders and McDermott Department o: 3 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 4 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. Pevaar Edward F. Meany Designated Representative of Designated Represer.tative of the Town of Hampton Falls the Town of Rye Drinkwater Road 155 Washington load Hampton Falls, NH 03844 Rye, NH 03870 Mrs. Sandra Gavutis Calvin A. Canney Designated Representative of City Manager the Town of Kensington City Hall RED 1 126 Daniel Street East Kingston, NH 03827 Portsmouth, NH 03801 M

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