ML20212F012

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Interrogatories Re Onsite Emergency Planning & Safety Issues,Per ASLB 860725 Order.Related Correspondence
ML20212F012
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 08/08/1986
From: Perlis R
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
NEW ENGLAND COALITION ON NUCLEAR POLLUTION
Shared Package
ML20212F019 List:
References
CON-#386-299 OL, NUDOCS 8608130209
Download: ML20212F012 (3)


Text

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August 8,1986 00LKETED 4

USNRC UNITED STATES OF AP! ERICA NUCLEAR REGULATORY COMMISSION

'86 ate 12 P3:36 BEFORE TIIE ATOPTIC SAFETY AND LICENSING BOARI[oC fl[:f F

T G S BRANCH In the Matter of

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PUDLIC SERVICE COf.!PANY OF

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Docket Nos. 50-443 OL-[

NEW HAf1 PSI! IRE, et al.

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50-444 OL-/

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(On-Site Emergency Planrt-(Seabrook Station, Units 1 and 2)

)

ing and Safety Issues)

NRC STAFF INTERROGATORIES TO NECNP PURSilANT TO THE BOARD ORDER OF JULY 25, 1986 CONTENTIONS NH-20 AND NECNP III.1 1.

Uill NECFP be offering any direct testimony on Contentions NH-20 and/or NECNP III.1?

If your answer is yes, please identify the witness (es) NECNP intends to sponsor and for each witness please l

provide: (a) full name; (b) a statement of professional qualifications; and (c) e brief description of the subject matter of the witness' testimony.

i 2.

Does NECNP intend to cross-examine any witnesses on Contentions NII-20 and/or NECNP III.1 with regard to the documents submitted by the Staff and Applicants in response to the Board Order of November 4, 1985?

If your answer is yes, please identify the portions of the

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documents upon which you desire to conduct cross-examination.

8608130209 860808 PDR ADOCK 05000443 O

PDR DESIGNATED ORIGII1L rwttried By 46 6 C 7 Eh

CONTENTION NECNP I.B.2 1.

Will NECNP be offering any direct testimony on Contention NECNP I.D.27 If your answer is ves, please identify the witness (es) NECNP intends to sponsor and for each witness please provide: (a) full name; (b) a statement of professional qualifications; and (c) a brief description of the subject matter of the witness' testimony.

2.

Does NECNP intend to cross-examine any witnesses on Contentions NECMP I.B.2 with regard to the documents submitted by the Staff and Applicants in response to the Board Order of November 4,1985? If your answer is yes, please identify the portions of the documents upon which you desire to conduct cross-examination.

CONTENTION SAPL SUPP. 6 1.

Uill HECNP be offering any direct testimony on Contention SAPL Supp. 67 If your anewer is yes, please identify the witness (es) NECNP intends to sponsor and for each witness please provide: (a) full name; (b) a statement of professional qualifications; and (c) a brief description of the subject matter of the witness' testimony.

I 2.

Does NECNP intend to cross-examine any witnesses on Contentions I

SAPL Supp. 6?

If your answer to either question 1 or 2 is yes, please answer the following questions:

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d

.] 3.

Do you contend that the Seabrook Control Room Design fails to comply with GDC 19?

If so, supply the factual basis for so contending?

4.

Do you contend that the Seabrook Control Room Design fails to cu.dy with GDC 20?

If so, supply the factual basis for so contending?

5.

Do you contend that the Seabrook Control Room Design fails to comply with GDC 21?

If so, supply the factual basis for so contending?

6.

Do you contend that the Seabrook Control Room Design fails to comply with GDC 22?

If so, supply the factual basis for so contending?

7.

Do you contend that the Seabrook Control Room Design fails to comply with Item I.D.1 of NUREG-0737?

If so, supply the factual basis for so contending?

8.

Do you contend that the Scabrook Control Room Design fails to comply with Item I.D.2 of NUREG-0737?

If so, supply the factual basis for so contending?

?

Respectfully submitted, M-Robert G. Perlis Counsel for NRC Staff Dated at Bethesda, Mary!rrid this 8th day of August,1986 f

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