ML20069C143
| ML20069C143 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/09/1983 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8303170437 | |
| Download: ML20069C143 (5) | |
Text
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%I'D'ated:
March 9, 1983
'83 MR 15 All:00 UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION 4 DER'/ic!'
.. /,11C 8 before the ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY OF NEW
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Docket Nos. 50-443 HAMPSHIRE, et al.
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50-444
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(Seabrook Station, Units 1 & 2)
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APPLICANTS' RESPONSE TO SEACOAST ANTI-POLLUTION LEAGUE'S MOTION FOR
SUMMARY
DISPOSITION (CONTENTION SAPL SUPP. III)
Under date of February 11, 1983, SAPL has filed a motion for summary disposition of SAPL Contention Supp. III.
The Applicants have also moved for summary disposition of this i
contention 'in their-favor.
Applicants' Nineteenth Motion for Summary Disposition (Feb. 11, 1983).
The filing of both of these motions makes clear that the contending parties are agreed as to two matters.
a)
The contention is in order for summary disposition, and b)
The sole issue is whether the FES as it now stands complies with the 8303170437 830309 PDR ADOCK 05000443 0
e directives set out in the NRC Policy Statement of June 13, 1980.
For the reasons set out in the Applicants' motion, we believe that the FES fully complies with the NRC directive.
SAPL's argument accompanying its motion is not grounded upon the language of the NRC Policy Statement; rather, it is
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grounded upon language which SAPL wishes were in fact in the Policy Statement.
The " straightforward statement" (presumably of death and destruction) SAPL claims is l
mandated, simply is not.
What is required is an analysis of probability vs. consequences which is what the charts and graphs in fact are.
SAPL's discussion of the evacuation model says more about SAPL's apparent inability to understand the language of Appendix F to the FES than it does about supposed faults in the assumptions.
SAPL's concern about sabotage is equally irrelevant.
The Policy Statement requires a " discussion", not a " conclusion" and if something is beyond the state. of the art, so stating is a complete " discussion" of the problem.
In addition, as noted in the FES, the consequences at Seabrook from accidents caused by external events would not be different in kind from those resulting from the " internal" events treated.
SAPL does not (indeed cannot) quarrel with that assessment.
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CONCLUSION Summary disposition in favor of the Applicants and against SAPL should be granted with respect to SAPL Contention III.
Respectfully submitted O
Thomas G. Dignan, Jr.
R. K. Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 6
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CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr.,
one of the attorneys for the Applicants herein, hereby certify that on March 9,
- 1983, I made service of the within document by mailing copies thereof, postage prepaid, to:
Helen Hoyt, Chairperson Rep. Beverly Hollingworth Atomic Safety and Licensing Hampton Beach Area Chamber Board Panel of Commerce U.S. Nuclear Regulatory Commission 209 Winnacunnet Road Washington, D.C.
20555 Hampton, NH 03842 Dr. Emmeth A. Luebke William S. Jordan, III, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 1725 I Street, N.W.
U.S. Nuclear Regulatory Commission Suite 506 Washington, DC 20555 Washington, DC 20006 Dr. Jerry Harbour E. Tupper Kinder, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Office,of the Attorney General U.S. Nuclear Regulatory Commission 208 State House Annex Washington, DC 20555 Concord, NH 03301 Atomic Safety and Licensing Roy P.
Lessy, Jr., Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Robert A. Backus, Esquire Board Panel 116 Lowell Street U.S.~ Nuclear' Regulatory Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Edward J. McDermott, Esquire Assistant Attorney General Sanders and McDermott Department of the Attorney Professional Association General 408 Lafayette Road Augusta, ME 04333 Hampton, NH 03842
David L. Lewis Jo Ann Shotwell, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission Department of the Attorney General Rm. E/W-439 One Ashburton Place, 19th Floor Washington, DC 20555 Boston, MA 02108 Mr. John B. Tanzer Ms. Olive L. Tash 5 Morningside Drive R.F.D.
1, Dalton Road Hampton, NH 03842 Brentwood, NH 03833 State Rep. Roberta C. Pevaar Mr. Edward F. Meany Drinkwater Road 155 Washington Road Hampton Falls, NH 03844 Rye, NH 03870 Mrs. Sandra Gavutis Calvin A. Cannery, City Manager RFD 1 City Hall, 126 Daniel Street East Kingston, NH 03827 Portsmouth, NH 03801 Ruthanne G. Miller, Esquire Law Clerk to the Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 ThomEs GT g gnan, Jr.
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