ML20247M477

Responds to Recipeint 890324 Request for Further Voluntary Discovery from NRC Re 1988 Exercise & Other Matters.Perrotti Comments Have Been Considered by NRC & Properly Addressed. Related Correspondence

ML20247M477
Person / Time
Site:	Seabrook
Issue date:	03/27/1989
From:	Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Fierce A MASSACHUSETTS, COMMONWEALTH OF
References
CON-#289-8371 OL, NUDOCS 8904060062
Download: ML20247M477 (1)

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UNITED STATES NUCLEAR REGULATORY COMMISSION 1

j i ,E . wAseMNGTON, D. C. 20555

\***,+/ March 27, 1989 M gi ;c pyo,gmftESPONDENG)

Alan R. Fierce, Esquire '89 MAR 29 P3 51 Assistant Attorney General Department of the Attorney General -ppg ,w, One Ashburton Place,19th Floor 00cKu w,A i imot "

Boston, MA 02108 .Bk m - n In the Matter of PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ET AL.

(Seabrook Station, Units 1 and 2) l Docket Nos. 50-443, 50-444 Off-Site Emergency Planning 4 76

Dear Mr. Fierce:

I have received your letter of March 24, 1989, in which you request further voluntary discovery from the Staff concerning the 1988 exercise and other matters. In this regard. I wish to note the following.

1. Without further specification, I am unable to respond to your inquiry concerning what you refer to as " negative comments" contained in Mr. Perrotti's memorandum. As a general matter, however, you may be sure that the Staff has considered Mr. Perrotti's comments and is satisfied-that they have been properly addressed.

2. Your inquiry as to whether there have been any evaluations by the NRC Staff of the SS-ERO after the 1988 exercise, and as to when a drill might be conducted in 1989 (items 2'and 3 in your letter), are beyond the scope of the matters to be addressed in the evidentiary hearings. Accordingly, and due to the press of other matters currently pending in the litigation, I regret that I am unable to respond to these inquiries at this time.

3. - Contrary to the representation set forth at page two of your letter, you did not indicate in our conversation of March 15 that, "if the NRC was unabTe to get the waiver it was seeking to bring Perrotti in for the hearings, I would depose him now, before'he.left the agency, if that was the only way for the NRC to produce him voluntarily." My letter of March 20 provides an accurate sumary of our conversation in this regard.

Very truly yours, J A.41 b b Sherwin E. Turk Counsel for NRC Staff cc: Service List rista.7 i pk Tf 09'o600 6 A.

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