ML20043A671

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Notice of Appeal on Behalf of Seacoast Anti-Pollution League.* Seacoast Anti-Pollution League (Sapl) Separate Appeal of Portion of LBP-90-12 Purporting to Grant Sapl Motion to Withdraw Noted
ML20043A671
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 05/16/1990
From: Backus R
BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:
Shared Package
ML20043A672 List:
References
CON-#290-10373 LBP-90-12, OL, NUDOCS 9005220386
Download: ML20043A671 (2)


Text

d2I b) 1 000KETED UNITED STATES OF AMERICA.

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NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BOARD 90 NO 2I ai Before Administrative Judges:

ng y ncRnMN Ncgnmu r 48Vn G. Paul Bo11werk, III, Chairman i+ ME" Alan S. Rosenthal Howard A. Wilber

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In the Matter of

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Docket No.

50-443-OL PUBLIC SERVICE COMPANY Y f*

OF NEW HAMPSilIRE, ET AL.

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(Seabrook Station, Unit 1)

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May 16, 1990

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NOTICE OF APPEAL ON BEHALF OF SEACOAST ANTI-POLLUTION LEAGUE

.1 NOW COMES the Seacoast Anti-Pollution League and hereby notices its appeal of the Licensing Board's Decision LPB 90-12, dated May 3, 1990 4

SAPL separately appeals that portion'of LBP 90-12 that purports to " grant" SAPL's motion to withdraw.

(SAPL never filed a motion to withdraw.)

See SAPL's letter of January 19, 1990 and SAPL's Objection to Applicants' Motion of January 26, 1990, attached hereto.

SAPL has already noticed its appeal of LDP 90-12 as to other issues by a joint pleading filed through the Massachusetts Attorney General.

Respectfully submitted, Scacoast Anti-Pollution League By its Attorneys, BACKUS, MEYER & SOLOMON h'

By:'

Robert'A'. ~Badkus, Es' quire 116 Lowell Street 9005220386 900516 P.O.

Box 516 PDR ADOCK 05000443 O

PDR' Manchester, NH 03105 (603) 668-7272

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t DATED: -May-16, 1990 I hereby certify that copies of the foregoing Notice of i

Appeal have been forwarded this day by first-class mail, postage prepaid to all persons on the attached service list.

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January 19, 1990 Administrative Judges 3

Ivan W.-Smith, Chairman i

Dr. Richard F. Cole Dr. Kenneth A. McCollom

'US NRC'

. Washington,-DC 20555

.Re:

In the Matter of Public Service Company of New Hampshire, et al.

(Seabrook Station, Unit 1)

Docket No. 50-443-OL

Dear Administrative Judges:

Three days ago I received the Board's Memorandum arid Order of January 11, 1990, the purpose of which was "to pruride to interested parties an opportunity to advise the Board on how to proceed in accordance with the directives of ALAB-924 and how they proposed to participate in the resolution of the remanded issues."

1 My first reaction was that this Order must be in jest.

Surely, the members of this Board could not expect SAPL to have the least interest whatsoever in any further proceedings before the Board, i
given the fact that the Board has decided the issue in the case by directing the "immediate authorization" for a full power. nuclear license.

Perhaps the-Board has forgotten that SAPL intervened in this proceeding to oppose the issuance of a nuclear license for 4

Seabrook.

being in the proceedingIt did not intervene in this proceeding for the sake of uncompensated emergency, planner for PEMA, NRC, or the Newand it'has no inte Hampshire Emergency Management Agency.

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Administrative Judges Ivan W. Smith, Chairman Dr. Richard F. Cole Dr. Kenneth A. McCollom Page 2 January 19, 1990 In case the Board has forgotten FAPL's position in this matter, we enclose a copy of SAPL's Opening Statement.

SAPL's position remains what it has been, there is no " adequate" emergency plan for Seabrook, adequate emergency planning at Seabrook may l

indeed not be feasible, and therefore no nuclear license should be issued.

B Respectfully submitted,

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Seacoast Anti-Pollution League J

By its Attorney, l

f//S/W Robert A. Backus RABtjsr Enclosure l

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IIf it comes to pass that these new proceedings involve licensing, SAPL will again be a participant.

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