ML20203L686

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Responses Opposing Seacoast Anti-Pollution League 860808 Interrogatories Re Onsite Emergency Planning & Safety Issues & Requests for Documents to NRC Staff.Affidavits & Certificate of Svc Encl.Related Correspondence
ML20203L686
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 08/25/1986
From: Sherwin Turk
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
SEACOAST ANTI-POLLUTION LEAGUE
References
CON-#386-521 OL-1, NUDOCS 8608290055
Download: ML20203L686 (23)


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4 pp gonttr.srvrwe.mde 08/25/86 DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ALE 28 P3 57 BEFORE THE ATOMIC SAFETY AND LICENS b5b R Pv$$F In the Matter of

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Docket Nos. 50-443 OL-1 PUBLIC SERVICE COMPANY OF

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50-444 OL-1 NEW IIAMPSHIRE, et al.

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Onsite Emergency Planning (Seabrook Station, Units 1 and 2)

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and Safety Issues NRC STAFF'S RESPONSE TO SAPL'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE NRC STAFF The NHC Staff (" Staff") hereby submits its responses to " Seacoast Anti-Pollution League's Interrogatories and Requests for Documents to the NRC Staff," filed August 8g 1986. M SAPL Supplemental Contention 6 (Formerly NH-10)

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The Staff notes that t'ne filing of interrogatories to be answered by the Staff is governed by the procedures set forth in 10 C.F.R.

I 2.720(h)(2)(ii), rather than 10 C.F.R.

I 2.740b, and that SAPL has not demonstrated any attempt to comply with those provisions.

Nonetheless, the Staff has undertaken to provide these discovery responses voluntarily, according to the schedule established by the Board, as if the Staff was subject to 10 C.F.R. I 2.740b. Similarly, without waiving the applicability of 10 C.F.R. I 2.741(e), the Staff has undertaken to respond, voluntarily to these document requests, except as objected to herein.

Insofar as the Staff objects to the instant interrogatories, the Staff hereby requests that the Licensing Board issue a protective order pursuant to 10 C.F.R.

I 2.740(c) that further discovery with respect to these matters not be had.

In addition, the Staff is filing simultaneously herewith a separate motion for protective orcer, which addresses SAPL's effort to expand the scope of SAPL Contention Supp. 6 beyond the scope of NH Contention 10 as that contention had been framed by the State of New Hampshire -- which the Licensing Board has expressly ruled is to define the scope of SAPL Contention Supp. 6.

8600290055 860825 PDR ADOCK 05000443 G

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- The Seabrook Station Control Room Design does sot-comply with General Design Criteria 19 through 22 and 10 C.F.R. Part 50, Appendix A,

and NUREG-0737, Items I.D.1 and I.D.2.

INTERROGATORY 1 List c.ll documentary or other materials the NRC Staff may employ in this proceeding to support its position (s) with respect to this contention.

In addition to listing such documents and other materials, provide a copy i

of all of them pursuant to 10 C.F.R. I 2.741.

RESPONSE

i Documents responsive to this interrogatory, other than privileged documents, if any, will be made available for inspection and copying by SAPL upon reasonable notice to the Staff.

INTERROGATORY 2 State the names and provide the curriculum vita (e) of any person or persons relied upon to substantiate in whole or.in part the Staff's i

position (s) with respect to this contention.

RESPONSE

Richard J.

Eckenrode; a curriculum vita for Mr. Eckenrode has previously been filed in this proceeding.

INTERROGATORY 3 i

^

Identify any person or persons the NRC Staff may call as a witness on this contention, and, if the information has not been provided in response to question 2, provide curriculum vita (e) of said person or persons.

RESPONSE

See response to Interrogatory 2.

The Staff has not yet identified any other persons whom the Staff may call to appear as witnesses on this contention.

l INTERROGATORY 4 Provide a summarization of the proposed testimony, views or positions of all persons named in response to interrogatories (2) and (3) above that may be presented by the NRC Staff in this proceeding.

RESPONSE

The Staff has concluded that the Applicants have conducted a DCRDR for Seabrook that satisfactorily meets the requirements of NUREG-0737, Supplement 1.

The remaining reviews are confirmatory in nature, as are the scheduled implementation of any proposed corrective actions and improvements.

As set forth in SER Supplement 4 (at 18-2).

the Staff has concluded that, with the improvements that have been identified by the Applicants, the potential for operator error leading to serious consequences as a result of human factors considerations in the control room will be sufficiently low to permit safe operation of Seabrook.

While the Staff can not conclude at this time that the SPDS complies with NUREG-0737, Supplement 1, the Staff does not believe that this noncompliance presents a serious safety problem at Seabrook.

The SPDS in its current design will not increase the potential for operator error in l

the event of an abnormal occurrence at Seabrook; the current SPDS does j

provide useful information to the operators (albeit not all the information called for in NUREG-0737, Supplement 1); and the information not presently available on the SPDS is available elsewhere in the control room.

When combined with the fact that NUREG-0737, Supplement i did not require that an SPDS be implemented before full power operation, the l

Staff believes that implementation of the additional SPDS requirements at Seabrook can await the completion of the first refueling outage.

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INTERROGATORY 5 State the specific bases and references to documents which the persons named in response to interrogatories (2) and (3) above may rely upon or reference regarding this contention.

RESPONSE

See response to Interrogatory 1 above.

INTERROGATORY 6 State with specificity the reasons why the Staff believes that stack monitor and steam generator (or steamline) radiation need not be added to the Safety Parameter Display System (SPDS) until prior to restart following the first refueling outage.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 7 Does the Staff hold that the period of operation prior to the first refueling outage is any safer than any other period of operation, and if so, upon what basis or bases?

RESPONSE

i The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 8 State with specificity the reasons why the Draft License for Seabrook Station, NPF-56, holds that the following modifications should be included on the SPDS prior to restart following the first refueling outage.

Provide the Staff's reasons for requiring each of the 6 modifications listed below, treating cach separately:

I.

Continuous display of the top level critical safety function summary at the assigned SPDS control room location, II.

Addition of, or satisfactory justification for, not adding RHR flow and hydrogen concentration parameters - to appropriate SPDS screens, III. Addition of a containment isolation status screen on SPDS, or improvement to the current containment isolation display to be satisfactorily recognized from the assigned SPDS location in the control room, IV. Addition 'of a radiation monitoring screen to display at least steam generator (or steam line) and stack radiation, V.

Improvement of the Heat Sink screen for consistency in labeling, and the Subcriticality screen for mode dependency so as not to mislead operators, and VI. Addition of approved isolation devices between the Reactor Vessel Level Instrumentation System (RVLIS) and SPDS.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

l INTERROGATORY 9 Name the person or persons who were responsible for deciding that the modifications listed in interrogatory 8 could be deferred and handled with license conditions and state when this decision [was] made.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is l

outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 10 State the bases upon which the decision was made to allow Applicants to defer review of the control room furnishings for lluman Engineering Discrepancies (HEDs) until prior to startup from the first refueling outage.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

4 INTERROGATORY 11 Name the person or persons who made the decision referred to in interrogatory 10 and state when this decision was made.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROG ATORY '12 State the bases upon which the decision was made to allow Applicants to defer review of the operator protective equipment and emergency equipment storage for HEDs until prior to startup from the first refueling outage.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 13 Name the person or persons who made the decision referred to in interrogatory 12 and state when this decision was made.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the ' scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence, i

INTERROGATORY 14 Describe the Staff's justification for not requiring that a preliminary evaluation of the control room environment be done prior to fuel loading.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is 4

outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 15 List any other specific actions and/or requirements, if any, that the NRC Staff is allowing Applicants to defer until the first refueling outage.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 16 NUREG-0737 II.B.1 requires that reactor coolant system vents be remotely operated from the control room.

Identify all documents which relate to the Staff's review of the displays and controls which have been added to the control room as a result of II.B.1.

Please produce such documents pursuant to 10 CFR I 2.741.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 17 NUREG-0737 II.D.3 recuires that reactor coolant system relief and safety values [ sic] be provided with positive indication in the control room Identify all documents which relate to the Staff's review of the displays anr1 controls added to the control room as a result of II.D.3 and produce thern pursuant to 10 CFR I 2.741.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 18 NUREG-0737 II.F.1 requires additional accident monitoring instru-mentation and associated displays and controls to be added to the control room.

Identify all documents which relate to the Staff's review of the displays and controls added to the control room as a result of this requirement.

Please produce these documents pursuant to 10 CFR I 2.741.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 19 NUREG-0737 II.F.2 relates to additional instrumentation for detection of inadequate core cooling.

Identify all documents which relate to the Staff's review of the types and locations of displays and alarms to be added to the control room as a result of this instrumentation.

Please produce such documents pursuant to 10 CFR I 2.741.

RESPONSE

.-~.. _ -.

The-Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 20 State whether the NRC Staff has reviewed the results of the July 1986 Westinghouse tests of isolation related to the isolator circuit in the RVLIS monitor output feeding the plant computer (See SBN-987 at 2).

If so, please state the Staff's conclusions based upon review of those tests.

If no review has been done, state why it has not been done.

RESPONSE

The tests in question were not conducted until the week of August 18, 1986, and the results have not yet been reviewed by the Staff.

INTERROGATORY 21 State whether or not the Staff has reviewed the program manual for the computer system methods of exchanging information relative to the SPDS.

If so, please state the Staff's conclusions.

If not, please state the Staff's reasons for not having done so.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is vague and incomprehensible to the Staff.

INTERROGATORY 22 When the NRC Staff performed the combined Design Verification and Design Validation audit of SPDS on May 20-21, 1986, did the human factors audit scheduled for Day 2 at 9 a.m. occur in the Control Room, the TSC, the EOF, the Control Room Simulator or the SPDS engineering simulator?

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RESPONSE

All SPDS display formats were examined in the control room.

A procedure run-through using the SPDS was accomplished in the control room simulator.

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- 10 INTERROGATORY 23 Provide all documents detailing the Staff's SPDS review of the safety analysis report,

the implementation plan and the verification and validation plan and the findings thereof.

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RESPONSE

See response to Interrogatory 1.

INTERROGATORY 24 Describe and present the conclusions of the Staff's review of the Applicant's incorporation of the lessons learned from the Salem ATWS event in the DCRDR.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reas'onably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 25 State whether or not the Staff believes that the Applicants' DCRDR system function and task analysis and subsequent comparison of results of the analysis with the control room inventory fully satisfies the require-ments of Supplement I to NUREG-0737 and name the person or persons who assume responsibility for the Staff's conclusion on this matter.

Provide the documents related to the Staff's review.

RESPONSE

Yes. See NUREG-0896, SER Supplement No. 3, at 18-5.

Richard J. Eckenrode.

See response to Interrogatory 1 above.

INTERROGATORY 26 State whether or not the Staff believes that the Applicants' DCRDR review is satisfactorily completed and HED's satisfactorily resolved for each of the following items and provide any documents detailing the Staff's assessment:

a) video alarm system and associated computer aids to the operator

b) hard-wired annunciators c) radiation monitoring system d) lighting e) control room access and architecture relative to supervision, storage of emergency equipment, escape, limiting access of unauthorized personnel, rest rooms, and eating facilities f) storage of operating procedures and keys, tagging, shift turnover, and other administrative procedures g) remote shutdown panel h)

MSIV panel i) fire panel j) consistent abbreviations k) hierarchical labeling 1) steam dump meter - legibility m) atmospheric dump valve controllers - accessibility

RESPONSE

a)

Yes; yes; color scheme changes have not yet been implemented, b)

Yes; yes; several corrective actions are to be implemented prior to start-up following the first refueling outage.

c)

Yes; yes; corrective actions are to be implemented prior to start-up following the first refueling outage, d)

Yes; no !!EDs were identified, e)

Yes, except as to final review of storage space for emergency equipment; yes.

f)

Yes; no IIEDs were identified.

g)

Yes; no IIEDs were identified, i

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h)

Yes; no HEDs were identified.

1)

Yes; yes.

j)

Yes; yes.

k)

Yes; yes.

1)

Yes; yes, m)

Yes; yes.

See response to Interrogatory 1.

NECNP Contention I.B.2 i

The Applicant has not satisfied the requirements of GDC 4 that all equipment important to safety be environmentally qualified because it has not specified the time duration over which the equipment is qualified.

INTERROGATORY 1 List all documentary or other materials the NRC Staff may employ in this proceeding to support its position (s) which respect to this con-tention.

In addition to listing such documents and other materials, provide a copy of all of them pursuant to 10 C.F.R. I 2.714.

RESPONSE

Documents responsive to this interrogatory and request, other than privileged documents, if any, will be made available for inspection,and copying by SAPL upon reasonable notice to the Staff.

INTERROGATORY 2 State the names and provide the curriculum vita (e) of any person or l

persons relied upon to substantiate in whole or in part the Staff's l

position (s) with respect to this contention.

RESPONSE

Harold Walker; a copy of Mr. Walker's professional qualifications is attached hereto.

INTERROGATORY 3 Identify any person or persons the NRC Staff may call as a witness on this contention, and, if the information has not been provided in response to question 2, provide curriculum vita (e) of said person or persons.

RESPONSE

Sec response to Interrogatory 2.

The Staff has not yet identified any other persons whom the Staff may call to appear as witnesses on this contention.

INTERROGATORY 4 Provide a summarization of the proposed testimony, views or positions of all persons named in response to interrogatories (2) and (3) above that may be presented by the NRC Staff in this proceeding.

RESPONSE

The Staff has reviewed the Seabrook program for the environmental qualification of electrical equipment important to r,afety,

and has concluded that the applicants have satisfactorily specified the time duration for which the-electrical equipment is environmentally qualified.

INTERROGATORY 5 State the specific bases and references to documents which the persons named in response to interrogatories (2) and (3) above may rely upon or reference regarding this contention.

RESPONSE

See response to Interrogatory 1.

l INTERROGATORY 6 i

State whether or not the NRC Staff has reviewed the Applicants' analysis supporting conformance with Reg. Guide 1.75.

If so, provide the documentation related to this review.

RESPONSE

l The Staff objects to this interrogatory on the grounds that it is j

outside the scope of the contention and is not reasonably calculated to

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4 lead to the discovery of admissible evidence.

Without waiving this objection, however, the Staff provides the following response:

Yes.

See Safety Evaluation Report (SER) related to the operation of Seabrook Units 1 and 2, 58.3.3.3; SSER No. 4, 58.3.1.8 and 58.3.3.3.1;

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SSER No. 5, 58.3.3.3.

INTERROGATORY 7 State with specificity the reasons why the NRC Staff position is that an environmentally qualified instrument to monitor the containment sump water temperature and an environmentally qualified instrument to monitor either accumulator tank pressure or accumulator tank level should be installed before startup from the first refueling.

RESPONSE

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The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 8 State why the Staff holds the position that this equipment can be i

done without up until the first refueling but should not be done without thereafter.

RESPONSE

The Staff objects to,this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 9 I

Ilas the NRC Staff independently verified that the results of WCAP-8822, Supplement 2, are applicable to the Seabrook Model F Steam generator?

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RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to l

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lead to the discovery of admissible evidence.

Without waiving this objection, however, the Staff provides the following response:

Yes.

INTERROGATORY 10 What uncertainties are taken into account in the Seabrook Cycle 1 nuclear design calculated shutdown margin at end of life?

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 11 State why the NRC Staff does or does not believe it necessary to consider the scenario of high energy line breaks (HELDs) occurring contemporaneously in both pipe chases.

State what would be expected to occur under such a scenario.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 12 State why the NRC Staff does or does not believe it necessary to consider the scenario of more than one control rod falling to insert contemporaneously with !! ELD in one of the pipe chases.

State what would be expected to occur under such a scenario.

RESPONSE

The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 13 State how the NRC Staff chose the 12 qualification files it audited on February 25, 26, and 27,198(i.

RESPONSE, The Staff normally selects at least 10 files for audit, and will review as many additional files as time permits.

The Staff follows a practice of randomly selecting files to be audited, unless the Staff has reason to believe that discrepancies may exist in certain files, and those files will then be included in the group of files to be audited.

In addition, other considerations may influence the Staff's decision as to which files should be selected for audit, such as the knowledge that some difficulty has existed in qualifying a particular piece of equipment for a similar application in another plant; or where qualification results differ significantly from what would be expaected for a particular piece of equipment; or an indication that insufficient information has been submitted for a particular piece of equipment for the Staff to conclude that the file is complete.

For Seabrook, tl e qualification information (EQ submittal) provided by the applicants to the Staff indicated that seven files appeared to contain conflicting information as to the status of qualification, while four files did not contain sufficient information for the Staff to conclude that the files were complete.

These eleven files were selected for audit, and an additional file was selected on a random basis.

INTERROGATORY 14 State why the NRC Staff did not choose to audit additional files upon having found dtficiencies in the audited files.

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RESPONSE

The primary goals of an environmental qualification audit such as was conducted at Seabrook is to afford the Staff an opportunity to assess the adeqaucy of the plant's equipment qualification program.

A deter-mination of adequacy is based upon engineering judgment, and does not require the complete absence of deficiencies.

For Seabrook, while the audited files did have some deficiencies, these deficiencies were relatively few in number and, in the Staff's opinion, were not sufficiently significant to call into question the adequacy of the applicants' environmental qualification program or to warrant the selection of additional files for auditing.

INTERROGATORY 15 State whether or not the NRC Staff has or intends to verify that the deficiencies identified as a result of the qualification file audit have been or will be corrected prior to fuel load.

RESPONSE

The applicants have provided information to the Staff indicating that all of the EQ audit deficiencies have been corrected.

In addition, the NRC requires that all plants maintain auditable files for their EQ programs, and these files are to be available for subsequent verification by the Staff.

Accordingly, the Staff considers this issue to be resolved.

INTERROGATORY 16 State the Staff's position with respect to the qualification of post-accident monitoring equipment.

Provide any documents the Staff relles upon to support its position.

RESPONSE

l The Staff objects to this interrogatory on the grounds that it is outside the scope of the contention and is not reasonably calculated to lead to the discovery of admissible evidence.

Respectfully submitted, i

)WL k Sherwin E. Turk Senior Supervisory Trial Attorney i

i Dated at Bethesda, Maryland i

this 25th day of August,1986 1

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

PUBLIC SERVICE COMPANY OF

)

Docket Nos. 50-443 OL-1 NEW HAMPSHIRE, et _al.

)

50-444 OL-1

)

Onsite Emergency Planning (Seabrook Station, Units 1 and 2)

)

and Safety Issues AFFIDAVIT I, Richard J. Eckenrode, being duly sworn, hereby state that I am employed as a iluman Factors Engineer, Section A of the Electrical Instrumentation and Control Systems B ranch,

Division of PWR Licensing-A,

Office of Nuclear Reactor Regulation, U.S.

Nuclear Regulatory Commission.

The information reflected in the Staff's responses to " Seacoast Anti-Pollution League's Interrogatories and Requests for Documents to the NRC Staff," related to SAPL Supplemental Contention 6 (formerly NH-10),

attached hereto, is true and correct to the best of my knowledge, information and belief.

Rich d J. Eckenrode Sworn to and subscribed before me this 25th day of August,1986 M

M Notary Public My Commission expires:

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i UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

PUBLIC SERVICE COMPANY OF

)

Docket Nos. 50-443 OL-1 NEW llAMPSHIRE, et al.

)

50-444 OL-1

)

)

Onsite Emergency Planning (Seabrook Station, Units 1 and 2)

)

and Safety Issues AFFIDAVIT I, Harold Walker, being duly sworn, hereby state that I am employed as a Mechanical Engineer in Section A of the Electrical Instrumentation and Control Systema B ranch, Division of PWR Licensing-A, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.

The information reflected in the Staff's responses to " Seacoast Anti-Pollution League's Interrogatories and Requests for Documents to the NRC Staff," relating to NECNP Contention I.B.2, attached hereto, is true and correct to the best of my knowledge, information and belief.

/'

Harold 7Valker Sworn to and subscribed before me this 25th day of August,1986 k

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$1 Jy Notary Public My Commission expires:

7/ /90

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00LKETED USNRC UNITED STATES OF AMERICA 86 ALE 28 P3 57 NUCLEAR REGULATORY COMMISSION OFFICE W ERLIW BEFORE THE ATOMIC SAFETY AND LICENSING BdWidfig;.gNL In the Matter of

)

)

PUBLIC SERVICE COMPANY OF

)

Docket Nos. 50-443 OL-1 NEW HAMPSHIRE, et al.

)

50-444 OL-1 1

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On-site Emergency Planning (Seabrook Station, Units 1 and 2)

)

and Safety Issues CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S RESPONSE TO SAPL'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE NRC STAFF" in the above proceeding have been served on the following by deposit in the United State mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system or, as indicated by a double asterisk, by express mail, this 25th day of August, 1986.

Sheldon J. Wolfe, Chairman

  • Dr. Emmeth A. Luebke*

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission l

Washington, D.C.

20555 Washington, D.C.

20555 Dr. Jerry Harbour

  • Carol Sneider**

Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor Washington, D.C.

20555 Boston, MA 02108 Beverly Hollingworth Stephen E. Merrill 209 Winnacunnet Road Attorney General Hampton, NH 03842 George Dana Bisbee**

Assistant Attorney General Sandra Gavutis, Chairman Office of the Attorney General Board of Selectmen 25 Capitol Street RFD 1 Box 1154 Concord, NH 03301-6397 Kensington, NH 03827 Richard A. Hampe, Esq.

New Hampshire Civil Defense Agency 107 Pleasant Street Concord, NH 03301

Calvin A: Canney, City Manager Allen Lampert City Hall Civil Defense Director 126 Daniel Street Town of Brentwood Portsmouth, NH 03801 20 Franklin Street Exeter, NH 03833 Roberta C. Pevear State Representative Angie Machiros, Chairman Town of Hampton Falls Board of Selectmen Drinkwater Road 25 High Road Hampton Falls, NH 03844 Newbury, MA 09150 Mr. Robert J. Harrison Jerard A. Croteau, Constable President and Chief Executive Officer 82 Beach Road, P.O. Box 5501 Public Service Co. of New Hampshire Salisbury, MA 01950 P.O. Box 330 Manchester, NH 03105 Diane Curran, Esq."

Harmon & Weiss Robert A. Backus, Esq.**

2001 S Street, N.W.

Backus, Meyer & Solomon Suite 430 116 Lowell Street Washington, D.C.

20009 Manchester, NH 03106 Edward A. Thomas Philip Ahrens, Esq.

Fedaral Emergency Management Agency Assistant Attorney General 442 J.W. McCormack (POCH)

Office of the Attorney General Boston, MA 02109 State House Station, #6 Augusta, ME 04333 H..!.

Flynn, Esq.

Thomas G. Dignan, Jr., Esq.

Assistant General Counsel Ropes & Gray Federal Emergency Management Agency 225 Franklin Street 500 C Street, S.W.

Boston, MA 02110 Washington, D.C.

20472 Jane Doughty Atomic Safety and Licensing Seacoast Anti-Pollution League Board

  • 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 lushington, D.C.

20555 Atomic Safety and Licensing Paul McEachern, Esq.

Appeal Panel

  • Matthew T. Brock, Esq.

U.S. Nuclear Regulatory Commission Shaines & McEachern Washington, D.C.

20555 25 Maplewood Avenue P.O. Box 360 Portsmouth, NH 03801

f Docketing and Service Section*

William Armstrong Office of the -Secretary Civil Defense Director -

U.S. Nuclear Regulatory Commission Town of Exeter Washington, D.C.

20555 10 Front Street Exeter, NH 03833 Maynard L. Young, Chairman Board of Selectmen Peter J. Matthews, Mayor 10 Central Road City IIall Rye, NH 03870 Newburyport, MA 09150 Michael Santosuosso, Chairman William S. Lord Board of Selectmen Board of Selectment South Ilampton, NH 03827 Town Hall - Friend Street Amesbury, MA 01913 Mr. Robert Carrigg, Chairman Mrs. Anne E. Goodman, Chairman Board of Selectmen Board of Selectmen Town Office 13-15 Newmarket Road

' Atlantic Avenue Durham, NH 03824 North flampton, NH 03862 R. K. Gad III, Esq.**

Gary W. Holmes, Esq.

Ropes a Gray Holmes & Ellis 225 Franklin Street 47 Winnacunnet Road Boston, MA 02110 Hampton, NH 03842 Judith H. Mizner, Esq.

Silverglate, Gertner, Baker Fine and Good 88 Broad Street Boston, MA 02110 f4wo~ LIA Sherwin E. Turk Senior Supervisory Trial Attorney l

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