ML20205F396
| ML20205F396 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/15/1986 |
| From: | Sneider C MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-353 OL, NUDOCS 8608190186 | |
| Download: ML20205F396 (6) | |
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00CKETED USNRC UNITED STATES OF AMERICA E ALE 18 A10:25 NUCLEAR REGULATORY COMMISSION OFFICE Cr sqt,q 7py y Before Administrative Judges:00CHETihn a s!pyrcr.
BRANCH Sheldon J. Wolfe, Chairperson Emmeth A. Luebke Jerry Harbour UCngy W1 tdt Prog _
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In the Matter of
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PUBLIC SERVICE COMPANY OF NEW
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Docket Nos.
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50-433/444-OL (Seabrook Station, Units 1 and 2)
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(On-Site EP)
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August 15, 1986
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MOTION FOR RECONSIDERATION Attorney General Francis X. Bellotti hereby moves the Licensing Board to reconsider its Memorandum and Order of July 25, 1986, to the extent that such Order dismissed without any consideration certain objections to Applicants' Motion for Issuance of Operating License for Operation Not in Excess of 5%
Rated Power (hereinafter " Applicants' Motion"] raised by Attorney General Bellotti in his Answer to Applicants' Motion filed July 2, 1986.
In his Answer, Attorney General Bellotti set forth ten numbered objections to Applicants' Motion.
Five of those objections (11 1, 2,
4, 5 and 6) were the subject of a Petition of Attorney General Francis X.
Bellotti to Revoke Regulation 50.47(d) or In the Alternative to Suspend its Application in h
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I the Seabrook Licensing Proceeding [ hereinafter " Petition of Attorney General Bellotti").
These objections were all addressed by the Board in its Memoranda of July 25 and July 30, 1986, at least to a limited extent.
However, Paragraphs 3, 7, 8, 9 and 10 of Attorney General Bellotti's Answer set forth other objections which are not a challenge to Regulation 50.47(d) and which the Board's Order does not address.
Attorney General Bellotti therefore respectfully requests that this Board reconsider its Order of July 17, 1986 insofar as it fails to consider all objections to Applicants' Motion raised by Attorney General Bellotti and in particular to reconsider its Order insofar as it would allow issuance of an operating license for operation not to exceed 5% of rated power prior to:
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(a) the submission of radiological emergency response plans of all state and local governmental entities within the Seabrook Station emergency planning zone as required by 10 C.F.R.
S 50.33(g), see Answer of Attorney General Bellotti at 1 7; j
(b) the filing of a supplement to the Final Environmental Statement for Seabrook Station filed in December, 1982, as required by 10 C.F.R.
S 51.72 to account for the significant new circumstances and information (set forth in Attorney General Bellotti's Answer) relevant to environmental concerns and bearing on the operation of the Seabrook plant at full and low power, see id. at 1 8;.-
N (c) there being in place the design number of notification sirens in all communities within the plume exposure EPZ and procedures and adequate communication equipment for notification by the licensee of the Massachusetts local response organizations as required by 10 C.F.R.
S 50.47(b)(5).
See id. at 1 9 and 47 Fed. Reg. 30232, 30234 (July 13, 1982); and (d) the parties having an opportunity to appeal the dismissal and summary disposition of contentions filed in this proceeding on which, pursuant to Section 189a of the Atomic Energy Act, a hearing is required prior to issuance of low-power operating license, see Answer of Attorney General Bellotti at 1 3.
Attorney General Bellotti further requests that the Board reconsider its Order of July 17, 1986 insofar as it fails to address 1 10 of Attorney General Bellotti's Answer objecting to 1 C(6), the " Emergency Preparedness" provision, of the draft low power license for Seabrook Station proposed by the NRC Staff.
Respectfully submitted, FRANCIS X. BELLOTTI By:
Carol S.
Sneider Assistant Attorney General Environmental Protection Division Department of the Attorney General One Ashburton Place, Room 1902 Boston, MA 02108 (617) 727-2265 Dated:
August 15, 1986. - -
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COLMETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION 16 AUS 18 20:25 In the Matter of
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0FFICE of :-;Ecnt;n(
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Dock ediFNuc4 s s00CHETING ?. SF icy!C[0-433 PUBLIC SERVICE COMPANY OF NEW
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(Seabrook Station, Units 1 and 2)
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CERTIFICATE OF SERVICE I, Carol S. Sneider, hereby certify that on August 15, 1986 I made service of the within document by mailing copies thereof, postage prepaid, by first class mail, or as indicated by an asterisk by express mail to:
- Sheldon J. Wolfe, Chairman
- Dr. Emmeth A. Luebke Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814
- Dr. Jerry Harbour
- Sherwin E. Turk, Esq.
Atomic Safety & Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission East West Towers Building Tenth Floor 4350 East West Highway 7735 Old Georgetown Road Bethesda, MD 20814 Bethesda, MD 20814 l
l H. Joseph Flynn, Esq.
- Stephen E.
Merrill, Esq.
[
Assistant General Counsel Attorney General Office of General Counsel George Dana Bisbee, Esq.
Federal Emergency Management Assistant Attorney General l
Agency Office of the Attorney General l
500 C Street, S.W.
25 Capitol Street Washington, DC 20472 Concord, NH 03301 l
l l
l l
l l
s' 09 o
Docketing and Service Paul A.
Fritzsche, Esq.
U.S. Nuclear Regulatory Office of the Public Advocate Commission State House Station 112 Washington, DC.
20555 Augusta, ME 04333 Roberta C.
Pevear Ms. Diana P. Randall State Representative 70 Collins Street Town of Hampton Falls Scabrook, NH 03874 Drinkwater Road Hampton Falls, NH 03844 Atomic Safety & Licensing Robert A. Backuc, Esq.
Appeal Board Panel Backus, Meyer & Solomon U.S.
Nuclear Regulatory 116 Lowell Street Commission
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P.O. Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.S.
Nuclear. Regulatory 5 Market Street Commission Portsmouth, NH 03801 Washington, DC 20555 Paul McEachern, Esq.
J. P. Nadeau Matthew T.
Brock, Esq.
Board of Selectmen Shaines & McEachern ~
- 10. Central. Road 25 Maplewood Avenue Rye, NH 03870 P.O. Box 360 Portsmouth, NH 03801 Ms. Sandra Gavutis, Chairperson Mr. Calvin A. Canney Board of Selectmen City Manager RFD~1,. Box 1154 City Hal1~
Rte. 107 126 Daniel Street E. Kingston, NH 03827 Portsmouth, NH 03801 Senator Gordon J.
Humphrey Mr. Angelo Machiros, Chairman U.S. Senate Board of Selectmen Washington, DC 20510 25 High Road (Attn: Tom Burack)
Newbury, MA 10950 Senator Gordon J. Humphrey Mr. Peter J.
Matthews 1 Pillsbury Street Mayor Concord, NH 03301 City Hall (Attn:. Herb Boynton)
Newburyport, MA 01950 Mr. Donald E. Chick William Lord Town Manager Board of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amesbury, MA 01913.
F Brentwood Board of Selectmen Gary W. Holmes, Esq.
RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH 03841 Philip Ahrens, Esq.
Diane Curran, Esq.
Assistant Attorney General Harmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W.
State House Station #6 Washington, DC 20009 Augusta, ME 04333 Thomas G. Dignan, Esq.
Richard A. Hampe, Esq.
R.K. Gad III, Epq.
Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth Edward A. Thomas 209 Winnacunnet Road Federal Emergency Management Hampton, NH 03842 Agency 442 J.W. McCormack (POCH)
Boston, MA 02109 William Armstrong Michael Santosuosso, Chairman Civil Defense. Director Board of Selectmen Town' of Exeter.
Jewell Street, RFD 2 10 Front Street South Hampton, NH 03827 Exeter, NH 03833 Robert Carrigg, Chairman Mrs. Anne E. Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-15 Newmarket Road Atlantic Avenue Durham, NH 03824 North Hampton, NH 03862 Allen Lampert Administrative Judge Civil Defense Director Helen F.
Hoyt, Chairperson i
Town of Brentwood Atomic Safety and Licensing 20 Franklin Street Board Panel Exeter, NH 03833 U.S. Nuclear Regulatory Commission Washington, DC 20555 Jerard A. Croteau, Constable 82 Beach Road, P.O. Box 5501 Salisbury, MA 01950 l
M s. 6a. Q Carol S. Sneider Assistant Attorney General i
Environmental Protection Division l
August 15, 1986.
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