ML20033B636
| ML20033B636 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/17/1981 |
| From: | Kinder E NEW HAMPSHIRE, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20033B631 | List: |
| References | |
| NUDOCS 8112010594 | |
| Download: ML20033B636 (7) | |
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T!:E OF4ECRETARY
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BRANCH ll UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 6
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In the Matter of
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PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ET AL. ) Nos. 50-443 h
1-and 50-444 I.
(Seabrook Station, Units 1 and 2)
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PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR HEARING i
BY THE STATE OF NEW HAMPSHIRE AND GREGORY H.
- SMITH, THE ATTORNEY GENERAL OF THE STATE OF NEW HAMPSHIRE l
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L NOW COME the State of New Hampshire, and Attorney l
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General Gregory H.
Smith, and petition to intervene generally l
I Pursuant to 10 C.
F.
R.
2.714 upon the following bases and terms:
1.
The application of Public Service Company of New Hampshire for operating licenses for Seabrook Nuclear Stations 1 and 2 was docketed by the Nuclear Regulatory Commission on October 5,
1981.
Petitions for Intervention were required to be filed by November 18, 1981.
2.
The State of New Hampshire is one of the
- 4 sovereign states of the United States.
Together with its Attorney General, it has been an intervenor in these l
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o-Proceedings since they began with the construction permit i
application in July of 1973.
The State of New Hampshire and
-t li the Attorney General have participated throughout 'these o
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of New Hampshire.
I t If, 3.
Gregory H.
Smith is Attorney General of the. State
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J of New Hampshire, and posseses the common law powers and i
respon;ibilities of the Attorney General to represent the i
interests of the people of New Hampshire on issues affecting i
u their health, safety and welfare.
The Seabrook Station f
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I Facility will affect those interests.
4.
The Seabrook Station Facility will be located e
within the borders of the State of New Hampshire.
Operation of !
the facility will have an effect on the health, safety and welfare of the citizens who reside in the vicinity of the facility site.
The State and the public have extensive property interests in the vicinity of Seabrook Station including natural resources and publicly owned property.
The State and the public haye a strong economic interest in these procaedings in that the cost and availability of electrical power affects the economic health of the State.
Further the a
electric rate payers of New Hampshire will pay a large share of I i
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-3 the construction and operational costs of the Seabrook Facility.
Additionally, the operation of Seabrook~ Station will !
have an effect on the seacoast area, including.iii beaches H
I which are a major tourist attraction which contributes to the i
State's economic well being.
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I 5.
Any order ir these proceedings will inevitably l
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ti have an impact on the State, its people, its economy and its environment.
The people of the State who live within fifty t
(50) miles of the facility will be responsible for developing and implementing emergency response plans.
The rate payers of the State will be required to pay the cost of construction, operation and decommissioning of the facility.
From an 4
economic point of view, the facility may have an impact on tourism in the Seacoast area.
Further, the operation will have an effect on the cost and availability of electrical energy throughout the State.
Finally, the operation of the facility will have an effect on natural systems due to radiological emissions and thermal discharges from the facility.
1 6.
Specific, aspects of the subject matter of this proceeding as to which the State of New Hampshire and the t
Attorney General wish to intervepe include but are not limited to the following:
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i, (a)
Conformity of construction of the facility to state and federal construction permits.
i' (b)
Conformity of proposed operation of the facility I
with the application and with rules and regulations of the i:
aI Nuclear Regulatory Commission and state law.
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L, ll (c)
Environmental qualific.ation of safety features.
(d)
Compliance with all construction, design, safe?y components and operational requirements established as the i
result of the evaluation of the accident at the Three Mile l
1 Island Nuclear Facility, Dauphin County, Pennsylvania.
(e)
Emergency response capabilities including accident evaluation and the development of appropriate i
emergency response time frames and limits of exposure of the l
public to radiological emissions.
(f)
The storage and disposal of nuclear waste generated by the facility.
(g)
Environmental impact of constraction and operation and monitoring of environmental effects from thermal i
and radiological discharges.
7.
The State of New Hampshire and the A tto r ney i
General request that a hearing with respect to the issuance of i
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the facilities operating licenses be scheduled.
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Respectfully submitted, j
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THE STATE OF NEW HAMPSHIRE AND I 7
ll QREGORY H.
SMITH, ATTORNEY f,
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Date:
By:
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Tupper Klntier l
d Assistant Attorney General i
h Environmental Protection f
Division l
Office of the Attorney i.
General State House Annex j
- Concord, N.H.
03301 (603) 271-3679 N
i CERTIFICATE OF SERVICE I,
E.
Tupper Kinder, Esq., hereby certify that a copy of the foregoing PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR HEARING BY THE STATE OF NEW HAMPSHIRE AND GREGORY H.
- SMITH, ATTORNEY GENERAL OF THE STATE OF NEW HAMPSHIRE and NOTICE OF APPEARANCE FOR THE STATE OF NEW HAMPSHIRE AND GREGORY H.
- SMITH, ATTORNEY GENERAL have been mailed, first-class postage prepaid, on this date to Executive Legal Director, ~ Ur ited States Regulatory Commission and Thomas G.
Dignan, Esq. of Ropes and Gray.
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OOCKETED hl U3RC I!
1 11 NOV 23 N1:28 J
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h r ;CE OF SECRETARY l
y DJCSEill'G & SERVICE a
BRANCH
'l UNITED STATES OF AMERICA j
NUCLEAR REGULATORY COMMISSION il l'
In th e Matter of
)
) Docket
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PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ET AL. ) Nos. 50-443
!I
) and 50-444 l
f (Seabrook Station, Units 1 and 2)s
)
l NOTICE OF APPEARANCE FOR THE STATE OF NEW HAMPSHIRP i
i AND GREGORY H.
SMITH, ATTORNEY GENERAL d
i A.
E.
Tupper Kinder, Assistant Attorney General, i
Office of the Attorney General, 200 State House Annex, Concord, a
New Hampshire 03301, telephone (603) 2i?-3679.
B.
Authorized to practice and in o sod standing before the Federal District Court for the District of New Hampshire, Federal District Court for the District of Massachusetts, Federal Court of Appeals for the First Circuit, United States Supreme Court, New Hampshire Supreme Court, Commonwealth of Massachusetts Supreme Judicial Court.
C.
Appearing on behalf of the State of New Hampshire y
and Attorney General Gregory H.
Smith, Office of the I
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Attorney General, 208 State House Annex, Concord, New Hampshire 03301, telephone (603) 271-3658.
i Respectfully submitted, THE STATE OF NEW HAMPSHIRE AND GREGORY H.
SMITH, ATTORNEY I
GENERAL l
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1ddO / 7, / b Date:
By:
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E.
Tupper Kinder s
Assistant Attorney General Environmental Protection Division Office of the Attorney General State House Annex
- Concord, N.H.
03301 (603) 271-3679 i
CERTIFICATE OF SERVICE I,
E.
Tupper Kinder, Esq., hereby certify that a copy of the foregoing PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR HEARING BY THE STATE OF NEW HAMPSHIRE AND GREGORY H.
- SMITH, ATTORNEY GENERAL OF THE STATE OF NEW HAMPSHIRE and NOTICE OF APPEARANCE FOR THE STATE OF NEW HAMPSHIRE AND GREGORY H.
- SMITH, ATTORNEY GENERAL have been mailed, first-class postage prepaid, on this date to Executive Legal Director, United States Regulatory Commission and Thomas G.
Dignan, Esq. of Ropes and Gray.
(~3 Date:%d/7,/
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