ML20052A276

Suppl to 811110 Petition to Intervene,Filing Contentions to Be Litigated.Certificate of Svc Encl

ML20052A276
Person / Time
Site:	Seabrook
Issue date:	04/21/1982
From:	Chiesa R SOCIETY FOR THE PROTECTION OF THE ENVIRONMENT OF, WADLEIGH, STARR, PETERS, DUNN & KOHLS
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8204280114
Download: ML20052A276 (5)

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W g UNITED STATES OF AMERICA e NUCLEAR REGULATORY COMMISSION S ATOMIC SAFETY AND LICENSING BOARD '82 is 2'a P 1 1 RECElVED Before Administrative Judges:

[. pAPR ut 2T 193>

g. E Helen F. Hoyt, Chairperson EE8 g, Dr. Emmeth A. Luebke

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Dr. Oscar H. Paris

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In the Matter.of )

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PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ET AL. ) D'ocket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2 )

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) April 21, 1982 SUPPLEMENT TO PETITION TO INTERVENE PURSUANT TO 10 C.F.R. 52.714(b)

CONTENTIONS WHICH PETITIONER SEEKS TO HAVE LITIGATED NOW COMES THE SOCIETY FOR THE PROTECTION OF THE ENVIRONMENT OF SOUTH-EASTERN NEW HAMPSHIRE, by its Attorneys, Wadleigh, Starr, Peters, Dunn &

Kohls, and pursuant to 10 C.F.R. 62.714(b) states as follows:

1. On November 10, 1981 said Society filed a Petition to Intervene in the License Application for the Seabrook, New Hampshire Station.

2. On November 25, 1981 the NRC Staff Response to the Petition to Intervene and Request for Hearing of The Society for the Protection of the l Environment of Southeastern New Hampshire was filed stating that the peti-tioners should file Affidavits of the members of the Society who wishcd to be heard.

3. On December 23, 1981 the Society filed a Motion to Amend the Petition to Intervene setting forth Affidavits of approximately fifteen members of the Society and their interest in the matter being heard before 82042RG M '- I a

the Nuclear Regulatory Commission.

4. On January 12, 1982, the NRC Staff filed a Response to the Amer.d-ments to the Petition for Leave to Intervene by The Society for the Protec-tion of the Environment of Southeastern New Hampshire concluding that the

. Society's amended Petition satisfies the interest requirements of 10 C.T.R.

$2.714 as well as designates an aspect of this operating license proceeding with respect to which it wishes to intervene.

5. On March 15, 1982, counsel for the Society received a Memorandu:

and Order Setting Special Prehearing Conference stating in Paragraph 4 of said Memorandum and Order that copies of any Amended Petitions to Inter-vene will be filed not later than thirty (30) days prior to the Special Prehearing Conference. That counsel did not wish to amend its Petition and did not believe that said Paragraph 4 of said Order designation of issues as set forth in 10 C.F.R. $2.714(b).

WHEREFORE your Petitioner prays that this Honorable Court allow it to file the following contentions to be litigated:

A ." The Society wishes to litigate the proposed route of transmission lines through the Town of South Hampton, and more particularly, as they relate to the historic sites which are located in said Town; the effect that the transmission route would have on an archeological site known as " Indian Ground Hill" which archeologists say represents a wealth of information concerning the indians who occupied the land prior to its.

colonization; the effect the proposed transmission line would have as it crosses the Pow Wow River into our neighboring state of Massach~setts u

and the effect that it would have as a recreation site as well as its esthetic beauty.

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3-B. The effect that the proximity of the proposed transmission lines 1

to present dwellings in the Town of South Hampten and the effect that such proximity would have on the health of the inhabitants of the dwellings.

C. The esthetic effect which the proposed transmission line route would have on the Town. \

I Respectfully submitted, THE SOCIETY FOR THE PROTECTION OF THE ENVIRONMENT OF SOUTHEASTERN NEW HAMPSEIRE By its Attorneys, WADLEIGHv 5TAkR, PETERS, DUNN & KOHLS By:s/-

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[/ Robert L. Chiesa

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5 CERTIFICATE SF SERVICE I, Robert L. Chiesa, hereby certify that a copy of the foregoing

'57 2<, P' Supplement to Petition to Intervene Pursuant to 10 C.F.R. $2.714(b)

Contentions which Petitie:er Seeks to hive Litigated has been mailed this

.& f 21st day of April, 1982, by first-class tail, postage prepaid, to:

Helen F. Hoyt, Chairperse: Paula Gold Asst. AG Administrative Judge Stephen M. Leonard, Asst. AG Atomic Safety & Licensing Board Panel Jo Ann Shotwell, Asst. AG U.S. NRC Office of the Attorney General Washington, D.C. 20555 One Ashburton Place, 19th Floor Boston MA 02108 Dr. Oscar H. Paris Administrative Judge Nicholas J. Costello Atomic Safety & Licensing 3oard Panel First Essex District U.S. NRC Whitehall Road Washington, D.C. 20555 Amesbury MA 01913 Lynn Chong Tomlin P. Kendrick Bill Corkum P.O. Box 596 Gary McCool Hampton NH 03842 Box 65 Plymouth, NH 03264 William S. Jordan, II Osquire Ellyn R. Weiss, Esquire Roy P. Lessy, Jr., Esquire Harmon & Weiss Office of Executive Legal Director 1725 I Street, N.W.

U.S. NRC Suite 506 Washington, D.C. 20555 Washington, D.C. 20006 Robert A. Backus, Esquire Phillip Ahrens, Esquire P.O. Box 516 Assistant Attorney General Manchester, NH 03105 State House, Station #6 Augusta FE 04333 Rep. Arnie Wight State of New Hampshire Donald L. Herzberger, M.D.

House of Representatives Hitchcock Hospital Concord, NH 03301 Hanover NH 03755 Paul A. Fritzche, Esquire Thomas G. Dignan, Jr., Esquire Public Advocate Ropes & Gray  ;

State House, Station #12 225 Franklin Street ]

Augusta ME 04333 Boston MA 02110

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Dr. Emmeth A. Luebke Atomic Safety & Licensing Appeal Board Administrative Judge U.S. NRC Atomic Saf ety & Licensing ioard Panel Washington, D.C. 20555 U.S. NRC Washington, D.C. 20555

2-Docketing and Service Secretary Senator Robert L. Preston Office of the Secretary State of New Hampshire U.S. NRC Senate Chambers Washington, D.C. 20555 Concord NH 03301 ,

P4 . Patti Jacobson Atocic Safety & Licensing Board Panel 3 Orange Street U.S. NRC Newburyport MA 01950 Washington, D.C. 20555 ,

Wilfred L. Sanders, Jr., Esquire David A. Repka, Esquire ,

Sanders & McDermott Counsel for NRC Staff 408 Lafayette Road U.S. NRC Hampton NH 03842 Washington, D.C. 20555

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/ Robert L. Chiesa l i

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