ML20032D573
| ML20032D573 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/13/1981 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | |
| Shared Package | |
| ML20032D569 | List: |
| References | |
| NUDOCS 8111170273 | |
| Download: ML20032D573 (3) | |
Text
g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Public Service Company of
)
New Hampshire, et al
)
(Seabrook Station, Units 1 & 2
)
SEACOAST ANTI-POLLUTION LEAGUE PETITION TO INTERVENE NOW COMES the Seacoast Anti-Pollution League (&@L) of New Hampshire ar.d respectfully petitions the Commission for leave to intervene in the Domestic Operating License proceedings pursuant to 10 CFR S 2.71.
I.
The Intervenor.
The Seacoast Anti-Pollution League is a public interest group located at 5 Market Street, Portsmouth, New Hampshire.
SAPL is a non-profit, voluntary organization dedicated to promo*ing charitable and educational objectives, including particularly the preservation and enhancement of environ-mental quality in the State of New Hampshire and increasing public awareness of environmental goals.
SAPL's concern is predcminately associated with the 18-mile New Hampshire suacoast area, but including within it and within its members' concern the northeastern Massachusetts coastal area.
II.
The Intervenor's Interests.
SAPL has specifically addressed environmental and safety issues concerning the development of the Seabrook Station project which is located along the 18-mile New Hampshire Seacoast area.
SAPL has been an intervenor in the construction permit and related proceedings from the earliest stages.
SAPL petitions the Commission for leave to intervene in the Domestic Operating License proceedings of the Seabrook Etation, Units 1 and 2, in order to further SAPn's interests as discussed above and as follows:
1) to obtain, analyze and act upon information available to the parties to the proceeding; 2) to insure that all available alternatives to the proposed licensing are fully studied, developed, described, and wherever feasible, implemented when appropriate to insure the well-being, environmental gaality, health and safety of the seacoast region; 9111170273 811113 PDRADOCK05000g C
. 3) to insure, in particular, that a feasible emergency preparedness plan be demonstrated, to include an adequate time frame and standards for evacuation in the event of a Class 9 accident beyond the low population zone; 4) to insure that the propcsed operation of the plant complies and cooperates with local and state emergency preparedness procedures; 5) to insure that the proposed operation of the plant is consistent with that of public health and safety.
III.
Intervenor's Interest in the Subject Matter of the Proceedings.
The grounds for SAPL's intervention would be to further its interests as set out above; and to furnish tLe Commission such infor-mation and analysis as it has regarding the effect of the operation and emergency preparedness on the public safety and environmental quality of the Seacoast region.
IV.
The Position of SAPL.
SAPL's position is that the NRC has failed to require development of an evacuation plan beyond the low population zone and failed to evaluate the consequences of a Class 9 accident, including the necessity for evacuation beyond the low population zone.
As a result, the Public Service Company emergency preparedness plan will not adequately, nor feasibly, protect the public health and safety of the seacoast region of the State of New Hampshire.
SAPL's Petition to Intervene should not cause any delay in the proceeding.
Pespectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By Its Attorneys, LAW OFFICES OF ROBERT A.
BACKUS
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Robert A.
Backus 116 Lowell Street P.
O.
Box 516 Manchester, NH 03105 (603) 668-7272 November 13, 1981
CERTIFICATE OF SERVICE 47-Thisistocertifythatonthis/3'dayofNovember, 1981, the undersigned sent copies o the within by first-class mail, postage prepaid, to all parties indicated below:
Executive Legal Director United States Nuclear Regulatory Commission Washington, DC 20555 Thomas Dignan, Esq.
Ropes and Gray 225 Franklin Street Boston, MA 02110 7 '. 9 Robert A.
Backus
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-.--n-law OFFICES OF RO B ERT A. B AC KU S lis Lowet L SmtcT-P. O. Box sie l..
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Darrell G. Eisenhut, Director 1
i Division of Licensing j
Office of Nuclear Reactor Regulation Nuclear Regulatory Commission l
Washington, DC 20555 1
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