ML20212F044
| ML20212F044 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/08/1986 |
| From: | Perlis R NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | MASSACHUSETTS, COMMONWEALTH OF |
| Shared Package | |
| ML20212F019 | List: |
| References | |
| OL, NUDOCS 8608130215 | |
| Download: ML20212F044 (3) | |
Text
RGATED CORRLSton:tuut August 8,1986 DOCKETED USNRC UNITED STATES OF AMERICA g g g p3 36 NUCLEAR REGULATORY COMMISSION 0FFICE Cr SEi.hTAA y BEFORE THE ATOf110 SAFETY AND LICENSING BOAYEIEIlini & SiPriu' BRANCH In the f, fatter of
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FUBLIC SERVICE COf.lPANY OF
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Docket Nos. 50-443 OL NEW llAT1PSIIIRE, et al.
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50-444 OL
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(On-Site Emergency Plann-(Seabrook Station, Units 1 and 2)
)
ing and Safety Issues)
NRC STAFF INTERROGATORIES TO TIIE ATTORNEY GENERAL OF PIASSACHUSETTS PURSUANT TO THE BOARD ORDER OF JULY 25, 1986 CONTENTIONS NH-20 AND MECNP III.1 1.
Will the Attorney General be offering any direct testimony on Contentions NH-20 and/or NECUP III.1?
If your answer is yes, please identify the uitness(es) you intend 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 the Attorney General intend to cross-examine any witnesses on Contentions NH-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 documents upon which you desire to conduct cross-examination.
8608130215 860808 PDR ADOCK 05000443 G
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CONTENTION NECNP I.B.2 1.
Will the Attorney General be offering any direct testimony on Contention NECNP I.B.2? If your answer is yes, please identify the witness (es) you intend to sponsor and, for ecch 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 the Attorney General intend to cross-examine any witnesses on Contention NECNP 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.
Will the Attorney General be offering any direct testimony on Contention SAPL Supp. 6?
If your answer is yes, please identify the witness (es) you intend to sponsor and for each witness please provide:
(c) full name; (b) a statement of professional qualifications; and (c) a brief description of the subject matter of the witness' testimony.
2.
Does the Attorney General intend to cross-examine any witnesses on Contentions SAPL Supp. 6?
If your answer to either question 1 or 2 is yes, please answer the following questions:
i' 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?
you contend that the Seabrook Control Room Design fails to 4.
Do comply 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 Seabrook 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, Robert G. Perlis
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Counsel for NRC Staff Dated at Bethesda, Maryland this 8th day of August,1986
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