ML20040F829

Motion to Amend Seacoast Anti-Pollution League 811113 Petition to Intervene,By Filing Affidavits from Members. Certificate of Svc Encl

ML20040F829
Person / Time
Site:	Seabrook
Issue date:	02/04/1982
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20040F826	List: ML20040F825 ML20040F829
References
ISSUANCES-OL, NUDOCS 8202100350
Download: ML20040F829 (5)

Text

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t a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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C' G I Before the Atomic Safety and Licensing Board In the Matter of Docket Nos. 50-443OL Public Service Company of New Hampshire, 50-4440L et al, (Seabrook Station, Units 1 and 2)

Motion to Amend Petition to Intervene Filed by the Seacoast Anti-Pollution League Pursuant to 10 C.F.R. 52. 714 (a) ( 3)

NOW COMES the Seacoast Anti-Pollution League ("SAPL")

and respectfully requests that the Atomic Safety and Licensing Board allow it to amend its. Petition to Intervene dated November 13, 1981 by filing as a part of its Petition the following information and affidavits:

I. THE INTERVENORS: Two members of SAPL join in the Petition and file the attached affidavits. The members are:

Peter Randall, 36 Mace Road, Hampton, NH 03842 Edward Dumaine, 23 Dumas Avenue, Hampton Beach, NH 03842 Specific contentions are raised in the affidavits.

This amendment is hereby submitted and requested to be incorporated with and made a part of SAPL's original Petition.

Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By Its Attorneys, s

LAW OFFICES OF ROBERT A. BACKUS 8202100350 820204 PDR ADOCK 05000443 O PDR BY:.

DATED: February 4, 1982 Robert A. Backus

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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Before the Atomic Safety and Licensing Board f In the' Matter of Docket Nos. 50-443OL Public Service Company of New Hampshire, 50-4440L et al, (Seabrook Station, Units 1 and 2)

AFFIDAVIT OF EDWARD DUMAINE I, Edward Dumaine, being duly sworn, depose and say that I am a resident of Hampton Beach, County of Rockingham, State of New Hampshire. I presently reside at 23 Dumas Avenue.

My property is situated within/.E~ miles of the proposed Seabrook Nuclear Power Plant and I live within the Emergency Planning Zone. .The proposed Seabrook Plant will affect my health and safety during its operation and in the event of an accident, such as a Class 9 event, emergency procedures may be necessary such as the evacuation of my family and my personal. property.

Furthermore, as a member of SAPL, I contend that the

. proposed plant will cause injury to the environment of the seacoast area.

I hereby authorize SAPL to represent me in the hearings before the Nuclear Regalatory Commission.

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Witness '

EDWARD DUMAINE DATE:

Subscribed and sworn to, before me, this 11 E- day of January, 1982.

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Justice of-the Peace / Notary Public

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J m UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.- p-._. . . . . .

Before the Atomic Safety and Licensing Board I In the Matter of Docket Nos. 50-443OL Public Service Company of New Hampshire, 50-4440L et al, (Seabrook Station, Units 1 and 2)

AFFIDAVIT OF FETER RANDALL I, Petar Randall, being duly sworn, depose and say that I am a resident of Hampton, County of Rockingham, State of New Hampshire. I presently reside at 36 Mace Road.

i My property is situated within 3 miles of the proposed Seabrook Nuclear Power Plant and I live within the Emergency Planning Zone. The proposed Seabrook Plant will affect my health and safety during its operation and

, in the event of an accident, such as a Class 9 event, emergency procedures may be necessary such as the evacuation of my family and ry personal property.

Furthermore, as a member of SAPL, I. contend that the proposed plant will cause injury to the-environment of the seacoast area.'

I hereby authorize SAPL to represent me in the hearings before the Nuclear Regulatory Commission.

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, . .. ; IW Witness Peter Randall DATE:

Subscribed and sworn to, before me, this of January, 1982.

of 8 day

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Justice of the Wace/ Notary Public

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CERTIFICATE OF SERVICE ,_ ; r; ,, 1-

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M This is to certify that on this 4th day of F.ebruary 1982, the undersigned sent copies of the within by first-class mail, postage prepaid, to all parties indicated below:

Roy Lessey, Esq.

Office of the Executive Legal Director U. S. Nuclear Regulatory Comm.

Washington, DC 20555 Thomas Dignan, Esq.

Ropes and Gray 225 Franklin Street Boston, MA 02110 Robert A. Backus

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