ML20033B932
| ML20033B932 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/25/1981 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20033B905 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8112020467 | |
| Download: ML20033B932 (3) | |
Text
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00tKETED
' "3 N F C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'81 NOV 30 P2:24 before the J SECRETARY l
i LG & SERV!CE ATOMIC SAFETY AND LICENSING BOARD LANCH
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF NEW
)
Docket Nos. 50-443-OL HAMPSHIRE, et al.
)
50-444-OL
)
(Seabrook Station, Units 1 & 2)
)
)
APPLICANTS' ANSWER TO PETITION TO INTERVENE OF COASTAL CHAMBER OF COMMERCE OF NEW HAMPSHIRE On November 18, 1981, the Coastal Chamber of Commerce of New Hampshire (CCCNH) served by mail a petition to intervene in the above-captioned matter.
Pursuant to 10 CFR $ 2.714(c),
the applicants answer that petition by saying that, for the reasona set out below, at least in its present form, the peti-tion should be denied.
The petition recites that CCCNH is, inter alia, a " voluntary organization".
The petition fails to identify any member by name and address who wishes to be represented by CCCNH and, thus, the petition must be denied in its present form.
Virginia Electric & Power Co. (North Anna Nuclear Power Station, Units 1 & 2),
8112020467 811125 PDR ADOCK 05000443 O
_ _ _ - _ _ _ _ _ _ _ = _ - _ _ _ _
5 ALAB-536, 9 NRC 402, 404 (1979).
It is true that it is signed by the executive director, but it contains no allegations as to his personal interest as is required.
See Duke Power Co. (Amend-ment to Materials License SNM-1773), ALAB-528, 9 NEC 146, 151 (1979)'.
The petition does not appear to contain any specific conten-tions or bases therefor.*
Thus, even assuming CCCNH amends its petition to make the necessary personal allegations, interven-tion should not be permitted unless and until CCCNH complies with 10 CFR S 2.714(b).
By their attorneys, Thomas G. Dignan, Jr.
Thomas G.
Dignan, Jr.
R.
K. Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100
- It might be that S IV was intended to set out contentions.
If so, none are valid as there is no requirement in the relevant regulations that the items therein listed be done. -
CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attorneys for the applicants herein, hereby certify that on November 25, 1981, I_made service of the within document by mailing copies thereof, postage prepaid, to:
Robert A. Backus, Esquire
' Mr. Arnie Wight, Chairman 116 Lowell Street House Science and Technology P.O. Box 516 Committee Manchester, NH 03105 House of Representatives-Concord, NH 03301 Mr. Tomlin P. Kendrick Executive Director E. Tupper Kinder, Esquire Coastal Chamber of Commerce Assistant Attorney General of New Hampshire Office of the Attorney General 822 Lafayette Road 208 State House Annex P.O. Box 596 Concord, NH -03301 Hampton, NH 03842 Mr. Robert F. Preston Paul A. Fritzsche, Esquire 226 Winnacunnet Road General Counsel Hampton, NH 03842 Public Advocate State House Station 112 Wilfred L. Sanders, Jr., Esquire Augusta, ME 04333 Sanders and McDermott Professional Association Philip Ahrens, Esquire
.408 Lafayette Road Assistant Attorney General Hampton, NH 03842 Department of the Attorney General Roy P. Lessy, Jr., Esquire Augusta, ME 04333 Office of the Executive Legal Director Jo Anr. Shotwell, Esquire U.S. Nuclear Regulatory Commission Assistant Attorney General Washington, D.C.
20555 Environmental Protection Division Public Protection Bureau Atomic Safety and Licensing Department of the Attorney General Board Panel One Alnburton Place, 19th Floor U.S. Nuclear Regulatory Commission Boston, MA 02108 Washington, D.C.
20555 William S. Jordan, III, Esquire Atomic Safety and Licensing Appeal Harmon & Weiss Board Panel 1725 I Street, N.W.
U.S. Nuclear Regulatory Commission Suite 506 Washington, D.C.
20555 Washington, D.C.
20006 Thomas G. Dignan, Jr.
Thomas G.
Dignan, Jr.