ML20151G756
| ML20151G756 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/22/1988 |
| From: | Berry G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#388-6816 OL-1, NUDOCS 8807290208 | |
| Download: ML20151G756 (20) | |
Text
07/22/88 4 gjg DOCKETED USHPC j3 h pg 49 38 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.e..
PEFORETHEATOMICSAFETYANDLICENSINGBOAJD In the Matter of Docket Nos.
50-443 OL-01 PUBLIC SERVICE COPPANY OF 50-444 OL-01 NEW HAMPSHIRE, e,t d.
On-site Ernergency Planning and Safety Issues (Seabrook Station, Units 1 ard 9)
)
NRC STAFF PESP0f:SE TO BOARD REQi!EST OF JULY 20, 1988 INTRODUCTION During a telephere conference held on July 19, 1988 regarding the NECNP's "Motion for Recensideration Or Clarification Of The Board's Order Of June 23, 1988" (hsreinafter "EECNP Mo tion), the Licensing Board directed to respond in writing tc the following questions:
1.
Are performance specifications for an electrical equiprtent itera which is subject to the previsions of 10 C.F.R.
6 50.49 required to be included in the iten;'s environmental cualificatior, file?
F.
If so, does NECt;P Exhibit 4
(cr.tain perfortrance specifications for RG-58 and RG-59 ceaxial cable?
As explained below, the enswer to each of these qucstions is affirmative.
DISCUSSION The answer to the Bcard's first question is found in 10 C.F.R.
i50.49(d).
That section r(quires an applicant to include, inter alia, in an evironrental qualification equipment file
[t]he performance specifications under conditicos existing during and following design basis accidents."
Therefore, the answer to the Board's first question is yes.
8807290208 880722
~
PDR ADOCK 05000443 G
/o,
- l The Board's question whether NECNP Exhibit 4 contains performance specifications for RG-58 and RG-59 coaxial cable must also be answered in the affirmative.
Five months ago, in an affidavit submitted in support of the Staff's respense opposing NECNP's eleventh hour attempt to reopen the record and ac'mit a late-filed contention challenging the environmental qualification of RG-59 cable, the Staff explained why the record (i.e.,
hECNP Ex. 4) provided reasonable assurance that RG-59 cable satisfied the environtrental qualification regulatiers, including the provisions of 10 C.F.R. 6 50.49(d) discussed above.
See Affidavit of Art.ritpal Gill and Harold WeDer at 6-9, attached to fiP.C Staff Response To f'ECNP Motion To F.eopen The fecord And Admit New Contention (February 17, 1988). 1/
The Gill /Wiker affidavit observes that the equiptrent qualification file indicates that the environtrental qualification acceptance criteria --
e.g.,
"performance specificatien" -- for RG-58 and RG-59 coaxial cable is a "total leakage / charging current rate [not to.1 exceed approximately 1.0 e n:p. "
id,. at 7-8; accord NECNP Ex. 4, Pef. 2 at 2.
Thus, the Board's i
secono question must be answered in the affirmative.
I CONCLUSION Fcr the reasons stated in this response and the Staff's response J/
A ccpy of the Gill / Walker Affidavit is attached to this response.
-2/
In ALAB-PE6 the Appeal Board dismissed NECNr's atterrpt to launch an eleventh hour challer.ge to the environmentel qualification test reruits for RG-f9 coaxial cable. See 27 NPC 1 (1988).
Therefore, the acceptance criteria for RG-59 coaxial cable is not subject to j
challence in this retriand proceeding. As the Licensing Board previously has observed, ALAB-886 "is now the law of the case." Tr.
at 1180.
w
+
r
- - * +
I filed July 19,1988,- NECNP's Motion For Clarification Or. Reconsideration Of The Board's Order Of June 23, 1988 should be denied.
R p ctfully submitted, N
Gre ory Ian ehry y
Counsel ar C Staff Deted at Rockville, Maryland this 22nd day of July 1900
\\
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION PEFORE THE AT,OMIC SAFETY AND LICENSING APPEAL _ BOARD In the Matter of
)
)
FUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL-1 NEu HAMPSHIRE, et al.
)
50-444-OL-1
)
(Seabrook Station,
)
(On-site Emergency Planning Units 1 and 2)
)
and Safety issues)
JOINT AFFID,AVIT OF APnlTPA L, S. GILL AND HARO,LD WALKER Ha rold Walker and - Amritpal S. Cill, being first duly sworn, affirm that ;he ar.sv.ers to the following questions are true and correct to the best of ? heir knowlede,e and belief:
01:
Certtemen, piccse state your name, emp!nyer, and occupatiors.
A1: ( V.'alk e r )
My name is Harold Kalker, I arn employed by the United States Nuclear Regulatory Commisslor. as a Reactor Engineer in i
Sectior. E of the Plant Systems Branch, Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulations.
(Cill)
My name is Amritpal S. Gill.
I am employed by the United States Nuclear Regulatory Commission as ; senior electrical engineer in the Electrical Systenis Branch, Division et Engineerino and Systems Technolooy, Office of Nuclear Reactor Regulations.
Q2: Centlenen, please describe your duties.
s A2: (Walker)
As a Reactor Engineer I are responsible for reviews in the area of nuclear power plant protections against various hazards, Including the environmental qualification of electrical coulpment important tc scfety for nuclear power plants as cutlined in 10 C.F.R.
! 50.49.
I have ~ served as the NRC Staff's principal reviewer
'of Applicants' electrical equipment environmental qualification prcgram for approximately the past six years.. As part of my responsibilities, I previously testified in the proceeding concerning NECNF Contention 1.B.2, in August 1983 and Septer'ber 1966.
A statement of my professional qualificatiens is atteched to this affidevit.
(Gill)
As a senior electricel engineer, I an respensible for reviews and evaluations of the electrical power systems ano' associated instrumentation ano controls needed for safe operation and sa fe s hutde.s n of nuclear facilities.
A more detailed statement of my professional quellfications is attached to this affidavit.
t 03: Centlemen, what is the purpose of your joint affidavit?
A3: (Walker, Gill) This affidavit addresses the claims made by J
intervenor New England Coalition On Nuclear Pollution (NECNP) in its "Motion To Reopen The Record And Adrrit New Contention" which was fhad on February 2, 1988.
Our affidtvit also addresses the claims mtde in support of that motion in the affidavit of Robert D.
- Follerd, in brief, this affidtvit will explain why: (1) the RG-50 l
coaxial cable used by Acolicants at the Seabrook Station meets the environmental qualification standards set forth in 10 C.F.R. I 50.49 and (2) Mr. Pollard is incorrect in asserting that 'the "measured insulation resistance of the RC-59 test specimenc-fell below the required insulation resistance during the environmental qualification tests".
04: Centlemen, the contention which NECNP requests be admitted states:
Applicants have failed to comply with the Commission's er.vironmental qualification requirements, 10 C F.R.
F 50.49 and Appendix A to 10 C.F.R.
Part 50, with respect to RC-59 coaxial cable.
Accordito to NECNP, the basis for this contention is that "R C-59 i
cable failed to meet its requirement for insulation resistance during equipment cualification testino."
Do you agree with NECNP that Applicants have failed tn comply v.ith the Commission's environmental qualifications with respect to RC-59 cable?
A4: (halker) No, I do not agree with NECNP.
As I exp!ain in this Lffidavit, my review of the relevant environmental qualification file (NECNP Ex. 4) leuch me to conclude that RC-59 cable will meet its specified r.crformance requiretrents when subjected to the conditions predicted to be present during a postulated design basis event as recuired by 10 C.F.R.150.t9.
05: Mr.
- Walkcr, please identify and explain the environmental qualification requirements spplicable to RC-59 coaxial cable.
4-AS: (Vlalker) The Commission's environmental qualification requirements are set forth in - 10 C.F.R.
I 50.49.
In general, section 50.49 requires that three categories of electric equipment "important to safety" be quallfled for their applicat;on and sets forth specified performance requirements for establishing environmental qualification methods anci qualification parameters.
The three categcries of equipment to which Section 50.49 applies are: (1) safety-related electric coulpment; (2) non-safety-related electric coulpment whose failure under postulated environmental condit.lons could prevent satisfactory accomplishment of sa fety functions by sa fety-related equiptrent ; and (3) cerialn post-accident monitorino equipment.
10 C.F.R.
6 50.49fb)(1).
HUREG-0588 "Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment" and Regulatory Guide 1.89 (RG 1.E9) set forth the methods by which an applicesit can establish that its "importent to safety" electrical equiprrent satisties the requirements of section 50.49.
With' respect to electrical cable, such as RC-59 coaxial cable, the qualification standard is IEEE Standard 383-1974, "lEEE Standard for Type Test of Class 1E Electric Cables, Field Splices, and Connections For Nuclear Power Generating Stations".
This standard is endorsed by NUREC-OSEC and the NRC Staff considers the environmental qualificatier, recuirer.er:ts of 10 C.F.P. 50.49 to have been sctisfied If the cabic is satisfectorily tested in accordarce with IEEE 383-197c.
i 00: Mr. Walker what is tbt IEEE-383 standard and what does it require?
4
A6: (Walker) As previcusly stated at AS, IEEE 383-1974 is an "lEEE Standard for Type Test of Class 1E Electric Cables, Field Sp!!ces, and Connections for Nuclear Power Generating Stations".
The NRC i
considers the environmental qualification requirements of 10 C.F.R.
50.49 to have been satisfiea for cable if the cable is satisfactorily tested in accordance with IEEE 383-1n74.
In general, the testing required by this standard includes thermal aging, gamma irradiation, and expcsure to a loss-of-coolant accident (LOCA).
C7: f.ir. talker, was the RC-59 cr2bie tested in accordance with IEEE-383?
A7: (Y'alk u ) Yes it was.
CB: On v.Lat do you base your answer?
AE: f.ty araswer is baseri eri rv review of NECNP Exhibit 4, which was bataitted in evidence ir. the onsite errergency plannir g and safety issues hearing held in October 1986.
Reference 2 of NECNP Ex. 4 is entitled: "Qualification Tests of Electrical Cables in a Simulated Steari-Line-Break and Loss of Cc<.,lant Accident Environment: 100 Day Furation, RC-11/u and RC-59/u Coaxial Cables." These qualification tests v.ne performed by the Franklin institute Research Laboratory, Inc. (FIR L) of Philadelphia, F(nnsylvania.
At page 2 of Reference 2, the FIRL states:
The objective of this test prograrr was to deracnstrate the ability of coaxial type electrical cabics to perform satisfactorily during a test program including thermal aging, g amrr.a irradiation, ana exposure to a sirrulated
A-steem line break (SLB) and loss-of-coolant accident (LOCA).
The program was based on guidelines provided
+
in IEEE Std 323-1974 and IEEE Std 383-1974.
Q9: What were the results of the tests conducted on the RG-59 coaxial cable?
A9: (talker) The tests shcwed that the RC-59 coaxial cable met all environn;tntal test requirements.
The tests were conducted by the Franklin Institute Research Laboratory, Inc.,
a reputable and respected testing leboratory which is well qualified to conduct environmental qualification tests of the type here involved.
It conducter' these tests in the period March through August 1982, and re. ported in,'anuary 19E3 its conclusion that:
One thermally agert soecirren and one unaged specimen of the PC-11/a and G-59/a types of coaxial cable (4
specin eris total), insulated with XLPE and lacketed with Exane. met the acc eptance criterla by maintaining their electrical load during a 100-day simulated SLB!LOCA e>pcsure, passing a final hend test around tra ndrels havir g a diameter 40 times tlic cable diar eters, and 5-minute ac high-potential-withstand tests at 9.44 and 4.96 j
bv.
respectively, which are ecual to 80 v por mil of inrolation.
The cable Jackcts were not cracked after the Fene; test.
1 NECNP Ex.
4, Ref.
2, p.1 IFootnotes deleted]
{
lt is noted that the Franklin Institute Research Laboratory is a subsidiary of Franklin Institute of Philadelphia, PA.
Q10 t"h y do you state that the tests conducted on the R C-5 9 cable showed it r et environtr. ental qualification requirements?
i A10. (Walker) in accordance with Regulatory Culde 1.89 (NUREC-058R is the original edition of Pr. 1.89), qualification is a verification of a design limited to demonstrating that an iterr of the electric equipment is capabic uf performing its sa fety function under significant environmental stresses resulting from design basis accidents in order-to avoid common mode failure.
RC 1.89 also states that it is essential that safety-related elettric equipment be quallfled to demonstrate that it can per forrr, its sa fety function under the crsvironmental service conditions in which it will be required to function and for the length of tirre its function is required and that rion-safety-related t jectric equipment covered by paragraph 50.49(b)(2) be able to withstand environtrentcl stresses caused by desinn basis accidents under which its failure could prevent sr.tisfactory accomplishrient of sa fety functions by safety-related equipment.
The specific environment for which an individual iter of electric equipment must be qualified depends on the Installed location t.r c the conditions under which it it reovired tc perform its safety function, i.e., functional requirerunts.
The functional requirements for RG-59 as determineci by the
{
aprilicant are noted or F. f of 10 of NECAP Ex. 4.
There are two t
recutrerner ts.
The first re fert rices
- p. 2 of the attached 1963 Franklin Institute Report "Qualification of Tests of Electrical Cables in Simulated Steam 1
Line B reak and Loss of Coolant Accident Environments:
100 Day
^
~
8-Duratien RG-11/v and RC-59/u Coaxial Cable" (Reference 2).
The acceptance criteria identified in the Franklin Report is that it remain energized "wlth client soecified potential and current" during the environmental qualification test.
This was assumed to be satisfied if the total feakage/ charging current rate did not exceed approximately 1.0 tap.
The test report demonstrates that the acceptance criteria were met throughout the test (Ref. 2, p.17).
The second functional rt;quirement of NECNP Ex. 4 is that ' contained in note 7,
which indicates that although there are no specific performance requirements identified in the Franklin test report, the cable was subjected to a high potential withstana test and insulation resistance was r<easured throughout the test that a minimum Ir'sulation rcsistance (IP.) of 160 megohms per 30 feet of cabic was indicated (for test en RC-11); and that the applicant has verified that this minimurn I P.
value is acceptable for use to assure em ir onmental qualification of cable at Scabrook.
(NECNP Ex. 4 p.
9),
it should be noted that for R C-59 cable the minimum IR
\\
value remained at or above 300 megchrrs throughout the test including the perioa when tempereture was 3460 F and the cable had been irradiated.
Pesea on my knowledge and experience. I do no know of any 6pplications in nuclear power safety re!ated applications which require cable to have an IR value as high as 300 rr.cgehms under LOCA test conditions to assure that it will I
l fur.ction as required.
1 ;
4 The test acceptance critsrla that cable not experience total leakage / charging current in excess of approximately -1.0 amp at any time during the test is a reasonabic test criteria to use in environmental qualificatinn tests for cable in order to meet the 4
requirements of IEEE 383-1974.
Of course, the applicant must assure that for all plant specific applications covered by 10 C.F.R.
I 50.49, conditions are encompassed by the test data, in this case, the applicant has done so.
NECNP Ex. 4, Ref. 9.
Q11. Did you alsn examine the test report of the Franklin Institute Research 1.aboratory,
Inc.
(NECNP Ex.
4, Ref.
2), and the Applicants' environmental qualification file on the RC-59 coc>:lal cable (NECNP Ex. 4], to see if eppropriate tests were conducted and reported which could lead to the conclusions regarding the environr, ental qualification of RC-59 cable?
)
1 A11. (V*alker) Yes.
The tests are set out in the Franklin Institute 4
repcr t.
This report, NECNP Ex.
4, Ref. 7, at S-10, set out the test proceaures, the nature of the radiation, steam, chemicals, and humidity to which the cable was exposed.
These tests were appropriate for determining the environmental qualification of the cable.
Further, the test results were reported in detail which showed the resistance of the cable, that no cracks or other irregularities were observed and that there was no apparent visual i
O
-to.
damagc to the cables.
- l5CNP Ex. 4, Ref.
2, at 12-13; Table 2:
Appendices C and D.
Q12: Mr. Gill, do you agree with Mr. Walker's answers?
1 A12: (Cill) Yes I do.
Q13: Centlemen, NECNP contends that the RC-59 cable failed the qualificetton test because its Insulation resistance during the second transient of the steam / chemical spray, high humidity test fell to 300 l
megchms w hich, according to NECNP is substantiellv less than the 1
architect / engineer's specification of 10,000 megohms 0 1000 feet for RG-59 ceaxial cable.
Is NECNP correct in this assertion?
A13: (Gill, Walker)
No.
NC.CNP supports its assertions that the cable failed the qualification tests on the basis cf an affidavit of Robert Pctlard.
Motion at 4 Mr. Pollard premises his assertion on the l
basis that the RC-59 cable old not r.1e e t the insulatiori resistance purchase requirements for the PC-59 cable of 10,000 megohms at 1000 feet since insulation resistance fell to 300 megohms during the environmental o.ualification tests.
Pollard affidavit, t 2.
The conclusion Mr. Pollard drew s is incorrect.
The insulation resistance values of 10,000 megchms at 1000 feet is not relevant to the insulation values to be measured during an environmental qualification test for the RC-59 cable.
The specification cited by Mr. Pollard of insulation resistance of 10,000 megohms at 1,000 feet is not an environmi.retal qualification s pecification.
- Pather,
specification of insulation resistance per 1000 foot of cable is a common practice in the electrical cable industry for a wide variety of It simply identifies resistance normal ambient conditions at the uses.
manufacturers faci!!ty prior to being exposed to. conditions of use -
including safety-related use in nuclear power plants.
Q14: Mr. Gill, Mr. Pollard, states at paragragh 4 of his affidavit that "the measured insulation resistance of the RG-59 [ cable] must be correctea for the length of the test specimen in order to compare it C
quired insulation resistanca."
Do you understand what Mr.
5 Poi s
.neans and if so, do you agree with hirr?
(
A14: (Cill)
I understand Dr. Pollard to be suggesting that the measured insulation resistanct value of the RC-59 specimen during the environnental qt.alification test was obtained on the basis of a cable orily fifteen feet in ength.
He further states that these measured values should be ct+rectect to provide an equivalent insulation resistence value for
',)00 fect in length in order to compare it with t h t.
vendor specification insulation resistance value of 10,000 roegohmt at 1,000 fee t.
Mr. Pollard's assertion that the' insulation r(sistance value of 10,000 megohras must be met during the envir onrr ental qualification test is incorrectly premised.
As I t <plained above, the 10,000 megohrt s at 1,000 feet value has no relevance to the insulation _ resistance values measured during the environmental qualification,tasts.
.n the case of R.G-59 cable, the specimen length 'ised for the qualification test was 30-fee t,
___________m_______._____m
- alth.ough only 15 feet were subjected to the test conditions.
The insulation resistance values measured and shown in NECNP exhibit 4,.
i P.eference
?,. Table 2, page 14 are for 30 feet of RG-59 cable, not J
1,000 feet.
it should he noted that a cable test specimen -of 30-feet length is acceptable under the' IEEE-383-1974.
3 For theu reascr.3, Mr. Po!!ard similarly is incorrect when he states j
at par ag raph 8 of his affidavit that "RG-11 coaxial cable is ne:
environmentally quallfled[. ]"
E>:hibit 4 Indicates that RG-11 coaxial cable meets tlic requirerients of section 50.49 as v ell.
015: Centienien, does this ccmplete your affidavit?
A15: iGih, %Mlker) Yer. It does.
1
---lffI'l jfi Harold 'talke r
.///f M
't An'TrixpTTsill Subscrit ett to and sworn before nic this g,Oday of February 1988 M
?.'.y Commission expires July 1,1990 1,
STATEMENT OF PROFESSIONAL OUALIFICATIONS OF AMRITPAL S. GILL I am a Senior Electrical Engineer in Section 8 of the Electrical Systems Branch, Division of Engineering and Systems Technology, Of fice of Nuciear Reactor Regulation, United States Nuclear Regulatory Commission.
My cuties include serving as a principal reviewer in the area of electrical power systems erd the associated instrumentation and controls neeced for sale operation and safe shutdown of nuclear reactors.
Prior to this assignrrent, I was an electrical engineer in the Electrical, instrumentation anc Contrel System Branch where i reviewed safety issues relating to electrical ccmponents, eaulpment and systems needed for safe operation and shutdown of nuclear facilities.
Prior to being assigned to the E'ectrical lostrumentation and Control Systems Branch, I was an electrical engir.eer in the Power System B ranch where my duties included perfort.Ing technical reviews, analyses anc! evaluations of the adequacy of efectrical equipment, apparatus and corrponents for sa fe operation and rife shutdown of nuclear power plan ts.
I have been performing these duties since joining NRC in 19fil.
I hold e E.E.
degree in electrical erigineerina and f.'. S c. degree in o.!ec t rict.i engineering.
_i am a registered professional engineer in the etatt of t'aryland.
I am an. associate professor and lecturer (part-time) at Ccorge Washington University wher e I teach electrical engineering ecurses te gracuate and practicing er.gineers.
I have written a text Sock, Flectrical Equipment Testir.o and Maintenance, published by Reston Pulslishing Co. (Pre ~ritice Halo,1982.
Prior to joining the NRC, I worked for 17 yerrs in the private sector, including an electrical pov. e r corrpany where my. duties included the select ict end development of specifications for electriccl systems, equip-ment and apparatus.
I also per formed evaluations and testir g of Mectricel cquipment and corrponents usea for c!ectrical systems, j
.,n
--,s.-
/,
s- - -
-a-.
o 9
S','ATEMENT OF PROFESSIONAL r)UALIFICATION JF HAROLD WALKER
! em a Reactor Engineer in Section B cf the Plant Iystems Branch, Division of Engineering end Systems Technology, Office of Nuclear
.l Reactor Regulation, United States Nuclear Regulatory Commission.
My duties include serving as a principal reviewer in the area of nuclear plant protection to assure against various hnards and certain aspec ts of containment, radioactive waste processing and other support systems cssigned to the Branch.
Prior to this assignment I was a Mechanical l
Engineer in the Electrical, instrumentation and Control Systems Branch where I reviewed the integrity,_ operability and functional capability of mechanical and electrical equipment, mechanical components, and supports nece'ed for safe operation and safe shutdown of nuclear facil! ties.
Prior to belno assigned to the Electrical instrumentation a nc' Cont' ol r
Systerns Branch, I was a kchaqlcal Engineer in the Equipment Qualifica-tion G ranch where my dutit.s included performing technical reviews, analyses and evaluations Of the adecuacy of the environmental qualibca-tion of efectrical and mechanical equiprre nt whose failure, due to such environmental c onditions as tert pera tu re,
- humidity, pressure and radiation, could adverse!y affect the performance of safety systems.
I was previously a Meterials Engineer in the Materials Engineering Drench where 'ny duties and responsibilities inv3fved the review and evaluation of rna terials pcr formance from the stenc; point of operability and functional rapabihty and integrity er der normal, at> norma l, and acciaent loading conditions, and analyzing fracture toughness of reactor vessel materials, including specific c ata to assure that the rraterials will behave in e
)
non-brittle manner.
Prior to my position in the Materials Engireering Branch, i vias a
- 1. tat erials Engineer in the EngineerinD B ra nch, Divisien of Operating Recctors.
My ciuties and responsibilities included the review ct operating problems to ceterreine whether safety requirements were being sat:sfied and te assure that operating problems were corrected, with due regard for safety end environmental protection.
Prior to my pesition in the Engineering Branch, I was a ACPS Felicw a.
the Advisory Committee cr Reactor Sa feguards.
My dutles includec collecting a n c' consolidatmg inforrration pertaining to ron-destructive testing r"ethods.
i hold a B.E. degree in mechanical engineering from the City Ce,lege of the City University of New York and I have taken graduate courses at the University of Pittsburgh.
I'rior to joining the NRC, I was an engineer at Westinghouse Research Corporation in Pittsburgh, Pennsylvania where my duties included the application of the state of the art fracture mechanics as well as the study of structural integrity of materials in various environments and under various loading conditions.
PMrETES pgpr UNITEC ST ATES OF AMERIC A NUCLEAR REGUL ATORY COMMISSION Y E 28 A9 '.38 B EF0 P E T H E A T OMIC S A FE,T Y A N D LIC ENSIN G, 8 0 Ahkib. 6 Ubl BT, Mv. -
Ir. the Matter of
)
Docket Nos. 50-443 OL-01 PllPLIC SERVICE COMPANY OF 50-444 O L-01 NEW P AMPSHIRE, g f.
On-site Emergency Planning and Safety Issues
-(Seabrct k Station, Jnits 1 and 2 C E R TIFIC,A,T E O F S E R VIC E I
hereby certify that copies cf "NRC' STAFF
RESPONSE
TO BCARD REQUEST OF JULY 20, 1988" in the above-captioned proceeding have been scrved on the following by deposit in the United States mail, first cl6ss, or as indicated by an asterisk, by deposit in the Nuclear Regulatory Commissitn's interr.61 mail system or, as indicated this 22nd day of July 1988.
Sheldon J. "olfe, Esq., C hairman*
Atomic Safety and Licensing A didnistre Judge Doard*
Atomic Sr.fety er.d Licensing Board ll.S. Nuclear Regulatory Commission U.S. Fuc' ear Regulatory Commission Washington, DC 20555 Washington, D C 20555 Dr. Jerry Harbour
- Docketing ar:d Service Section+
Administrative Judge Office of the Secretary Atomic Safety and Licensing Scard U.S. Nuclear Regulatory Commission U.S. f.ucicar Regulatory Commission Washington, DC 20555 Washington, D C 20555 Dr. Emmeth A. Luebke Thomas G. Dignan, Jr., Esq.
Adrotnistrative Judge Robert K. Gad, III, Esq.
4515 Willard A venue Ropes & Gray Chevy Chase, Maryland 20815 225 Franklin Street Boston, M A 02110 Atomic Safety and Licensing H. J. Fly n n, E s q.
Appeal Panel
- Assistant General Counsel U.S. Nuclear Regulatory Con' mission Federal Emergency Management Agency Washington, D C 20555 500 C Street, SW Washington, D C 20472
- Philip Ahren, Esq.
Calvin A. Canney A:.istant Attorney General City Hall Office of the Attorney General 126 Daniel Street State House Station Portsmouth, NH 03801 Augusta, ME 04333 Mr. Angie Machiros, Chairman Carol 9. Sneider, Esq.
Board of Selectmen Assistai.' Attorney General 25 High Road Office of the Attorney General Newbury, M A 09150 One Ashburton Place,19th Floor Boston, M A 02108 George Dana Eisue, Esq.
Allen Lampert Assistant Attorney General Civil Defense Director Office of the Attorney General Town of Brentwood 25 Capitol Street 20 Franklin Concord, NH 03301 Exeter, N H 03833 Elly n F. Weiss, Es q.
Wiliiam Armstrong Diane Curran, Esq.
Civil Defense Director Harn.cn & Weiss Tcwn of Exeter 2001 S Street, NV 10 Front Street Suite 430 Exeter, N H 03833 Vashinston, D C 20009 Robert A. f.cckus, Esq.
Gary W. Holmes Esq.
Backus, Peyer s Solomon Holmes & Ellis 110 Lowell Street 47 Winnacunnet Road Manchester, N H 03106 Hampton, N H 03842 Paul McEachern, Esq.
J. P. Nadeau-Matthew T. Brock, Esq.
Board of Selectmen Sheines & PcFachern 10 Cer. tral Street 25 Maplewood Avenue Rye, N H 03870 P.O. Box 360 Portsmouth, N H 03801 Judith H. Mizner, Esq.
Ch6rles P. Grahan, Esq.
Silverglate, Gertner, Ba ker, NcKay, Murphy & Graham Fine & Good 100 Pain Street 88 Board Street Amesbury, M A 01913 Boston, M A 02110 Sandra Gcvutis, Chairman Robert Carrigg, Chairman i
Board of Selectmen Board of Selectmen RFD #1, Box 1154 Town OfHce Kensington, N H 03827 Atlantic Avenue North Hampton, NH 03870 William S. Lord Peter J. Matthews, Mayor Board of Selectmen City Hall Town Hall - Friend Street Newburyport, M N 09150 A riesbury, M A 01913
I Mrs. Anne E. Goodman, Chairman Michael Santosuosso, Chairman Poard of Selectmen Board of Selectmen 13-15 Newmarket Road South Hampton, NH 03827 Durham, NH 03824 Hon. Gordon J. Humphrey Ashod N. Amirian, Esq.
linited States Senate Town Counsel for Merrimac 531 Hart Senate Office Building 376 Fain Street Washington, DC 20510 4averhill, P A 08130 f
M Ibn Grescry AJ(n 'Be r\\r Counsel forI N R C JStaff V
1
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