ML20069F644

Supplemental Response to 821208 Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20069F644
Person / Time
Site:	Seabrook
Issue date:	03/16/1983
From:	Bisbee G, Fan S NEW HAMPSHIRE, STATE OF, NEW HAMPSHIRE, UNIV. OF, DURHAM, NH
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20069F632	List: ML20069F629 ML20069F644
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.2, TASK-TM NUDOCS 8303230256
Download: ML20069F644 (5)

Text

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.~ .,c. .a .....w UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'03 II .21 fin ,.33 Before the -

ATOMIC SAFETY AND LICENSING BOARD

)

In the matter of: )

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PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE) Docket Nos.: 50-443 ET AL. ) and

) 50-444

. (Seabrook Station, Units 1 and 2) )

) March 16, 1983 THE STATE OF NEW HAMPSHIRE'S SUPPLEMENTAL RESPONSE TO THE APPLICANT'S INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FILED DECEMBER 8, 1982 Pursuant to the Order of the Atomic Safety and Licensing Board dated March 1, 1983, relative to Applicant's Motion to

( Compel Answers to Interrogatories to the State of New Hampshire, New Hampshire offers the following answers.

l 8303230256 830316 PDR ADOCK 05000443 g PDR

A. Interrogatories XI-2 through XI-6, XIV-2 through XIV-8, XVI-2 through XVI-8, XX-2'through XX-4, XXI-2 through XXI-7, XXXII-2 through XXXII-13, and XXXIII-2 through XXXIII-20 New Hampshire retains an interest in litigati.ng the contentions which are the subject of the above enumerated interrogatories. At this time, however, New Hampshire has no position on these contentions. This constitutes the complete answer to each of the above-listed interrogatores.

B. Interrogatories II-8 and II-9 As it has stated previously,1/ New Hampshire maintains that it is placed in the untenable position of being required to provide specific comments on an incomplete project. By the Applicant's admission, its Detailed Control Room Design Review is approximately 50% complete, and the Safety Parameter Display System design is not yet developed. It is for this reason that New Hampshire has not as yet performed an in depth analysis of the control room design, and has, therefore, not yet developed any proposed changes to the present design.

New Hampshire can state at this time, however, that one

" change" that must be incorporated into the Seabrook design is the development of a design for the Safety Parameter Display 1/ See New Hampshire's February 9, 1983 Answer to .

Applicant's notion to Compel, at pages 7-8.

e System, as required by NUREG-0737, Item I.D.2. This is required for all nuclear power plants in the United States.

Respectfully submitted, THE STATE OF NEU HAMPSHIRE GREGORY H. SMITH ATTORNEY GENERAL

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L3 Dated: March 16, 198'3 By: M NA ,

George Qana Bisbee, Attorney Environmental Protection Division Office of Attorney _ General State House Annex Concord, New Hampshire 03301 603-271-3678 I, the undersigned, being first duly sworn, do depose and say that the foregoing ansvers are true except insofar as they are based on information that is available to the State of New Hampshire and the New Hampshire Attorney General, but not within my personal knowledge as to which we, based on such information, believe them to be true.

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Ylh.) WJ Dr. Ste@en'S. T. Fan Chairman and Professor College of Engineering and Physical Sciences Department of Chemical Engineering Kingsbury Hall University of New Hampshire Durham, New Hampshire 03824 THE STATE OF NEW HAMPSHIRE STRAFFORD, SS.

Personally appeared this 16th day of March, 1983, Dr. Stephen S.T. Fan, before me, the undersigned officer, and made oath that the foregoing statements are true to the best of his knowledge and belief. -

( , , f'

.  :-c. l Notary Public/ Justice of the Peace s*) wel -

..to

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CERTIFICATE OF SERVICE I, George Dana Bisbee, Esquire, do hereby certify thaq Y 21 130:31 copy of the foregoing State of New Hampshire's Supplemental Response to the Applicant's Interrogatories and Requests for Production of Documents Filed December 8, 1982 has been mailed this 16th day of March, 1983, by first class mail, postage prepaid, to:

Helen F. Hoyt, Chm. Dr. Emmeth A. Luebke Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. NRC U.S. NRC Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry Harbour Jo Ann Shotwell, Asst. AG Administrative Judge Office of the Attorney General Atomic Safety and Licensing One Ashburton Place, 19th Floor Board Panel Boston, MA 02108 U.S. URC Washington, D.C. 20555 Mrs. Beverly Hollingsworth 822 Lafayette Road Roy P. Lessy, Jr., Esquire P.O. Box 596 Robert Perliss, Esquire Hampton, New Hampshire 03842 Office of Executive Legal Dir.

U.S. NRC William S. Jordan, II, Esquire Washington, D.C. 20555 Ellyn R. Weiss, Esquire Harmon and Weiss Robert A. Backus, Esquire 1725 I Street, N.W.

116 Lowell Street Suite 506 P.O. Box 516 Washington, D.C. 20006 Manchester, N.H. 03105 Edward J. McDermott, Esquire Phillip Ahrens, Esquire Sanders and McDermott Assistant Attorney General 408 Lafayette Road State House, Station #6 Hampton, N.H. 03842 Augusta, Maine 04333 Atcaic Safety and Licensing Robert K. Gad, Esquire Board Panel Thomas G. Dignan, Jr., Esquire U.S. NRC Ropes and Gray Washington, D.C. 20555 225 Franklin Street Boston, Massachusetts 02110 David R. Lewis, Esquire Atomic Safety and Licensing Office of Selectmen Board Town of Brentwood U.S. NRC - Room E/W - 439 Brentwood, New Hampshire 03833 Washington, D.C. 20555

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..'o Office of Selectmen Rep. Roberta C. Pevear Town of Hampton Town of Hampton Falls Hampton, New Hampshire 03842 Drinkwater Road Hampton Falls, New Hampshire 03844 Office of Selectmen Ms. Sandra Gavutisson Town of Kensington Office of Selectmen Kensington, New Hampshire 03833 Town of East Kingston RFD 1 East Kingston, New Hampshire 03848 Mr. Calvin A. Canney Mr. Patrick J. McKeon City Manager Office of Selectmen City of Portsmouth Town of Rye 126 Daniel Street 10 Central Road Portsmouth, New Hampshire 03801 Rye, New Hampshire 03870

$g e M l George Dana Bisbee V Dated: March 16, 1983 t