ML20071C008
| ML20071C008 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/25/1983 |
| From: | Hollingworth B CHAMBER OF COMMERCE, HAMPTON BEACH AREA, NH |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8303010407 | |
| Download: ML20071C008 (2) | |
Text
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s Filtd: Ftbrutry 25, 1983 b
UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION
'83 FEB 28 P1:38 before the ATOMIC SAFETY AND LICENSING BOARD
,yh3kI 3 rat;ckh' ICE
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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 OL HAMPSHIRE, et al.
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50-444 OL
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(Seabrook Station, Units 1 & 2)
)
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ANSWER TO MEMORANDUM AND ORDER FROM THE HAMPTON BEACH AREA CHAMBER OF COMMERCE On September 13, 1982, the Atomic Safety and Licensing Board, underAdministrativeJudgeHelenF.Hoytf, Chairwoman, admitted the Hampton Beach Area Chamber of Commerce (HBACC, formerly'the Coastal Chamber of Commerce of New Hampshire) accepted three con--
tentions for litigation. On February 14, 1983, the' Applicant filed a motion to compel answers to their interrogatories as did the NRC 1
Staff on February 4, 1983. At this same time the Staff filed to dis-miss the HBACC if it had not' filed answers to the Staff's interroga-tories. While it is true that the HBACC has not responded to these motions, it is also true that the representative was not aware that the Chamber could be dismissed. The Chamber representative has been-trying very hard over these many weeks to glean from the many cor-respondences of intervenors, Staff and Applicant how to pegin to tackle
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what to her seemed an impossible task.
The representative admits to a lack of-expertise in this. area, but soon realized that other inter-venors also were overwhelmed by the task before them! The represen-tative, when entering into this process for the Chamber believed the process of licensing was to bring all matters of concern *o6 ne this Board. The representative for HBACC admits to confusion when the NRC Staff informed her that the "NRC Staff must do what is fair for their client", and the inference is that the Applicant is that client. The Representative for the Chamber was under the impres-sion that the American taxpayer was the " client", paying for the safety and protection of its people.
The HBACC has no resources and therefore no expert witness which it planned to have testify. The HBACC has not relied on ex-perts for its previously filed contentions.
The HBACC's knowledge (limited), views, positions, and proposed testimony (which it can-not give until all the facts are in) are the representative's.
All 8303010407 B30225 PDR ADOCK 05000443 PDR T663 g
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Document materials come from the NRC, the UNH Library, the State Li-brary, Franklin Pierce, and newspapers.
As to what may be used during procedure, it is impossible to determine at this time. What the HBACC representative had intended when it filed its three accepted contentions, not the Emetgency Planning Contentions, was to present a case through cross examina-tion and/or to urge denial (or allowance) of the pending application on the basis of the topic or contention.
Now the pr'oblem comes that the representative fears that she cannot be more specific than she has been in this letter to the Board.
The representative is taking steps to become more informed on the licensing process, but this will not correct her inability to answer those interrogatories from Staff and Applicant anymore specifically than it has to this Board.
If the Board so orders, th'e representative would like to con-tinue with its intervention on the Emergency Planning as well as, if possible, on its three contentions.
It is not the attempt of this representative to be anything but truthful and to continue to inter-vene for the HBACC.
Respectfully submitted, f
Beverly A. Hollingworth for the Hampton Beach Area Chamber of Commerce BAH:LG i
cc: To All Parties to Proceeding
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