ML20205R851
| ML20205R851 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/03/1988 |
| From: | Trout J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#488-7454 OL, NUDOCS 8811100148 | |
| Download: ML20205R851 (6) | |
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'20 NOV -8 P4 :50 QWRSoyf,Sy30 ogy Nov6mber 3, 1988
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443-OL NEW KAMPSHIP2, et al.
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50-444-OL
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(Seabrook Station, Units 1 and 2)
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(Off-site Emergency
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Planning Issues)
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APPLICANTS' REQUEST FOR ADMISSIONS TO INTERVENORS Pursuant to 10 CFR S 2.742, Applicants request that the Attorney General for the Commonwealth of Massachusetts, Seacoast Anti-Pollution League, New England Coalition On Nuclear Pollution, the towns of Amesbury, Newbury, West Newbury, Salisbury, and Merrimac, and the cities of Haverhill and Newburyport admit the truth of the following facts:
1.
The SPMC provides for early beach closing.
2.
Every school and day care center in the Massachusetts EPZ is required, by law and/or regulation, to have (a) adequate emergency response plans, and (b) the resources (material and human) necessary to implement those plans.
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3.
The following bodies politic, including all their subdivisions, departments, agents, and instrumentalities, have refused to participate in or cooperate with emergency planning for Seabrook Station at all times subsequent to January 1, 1987, and presently continue to refuse to participate in or cooperate with emergency planning for Seabrook Station:
(a) the commonwealth of Massachusetts; (b) the Town of Amesbury; (c) the Town of Merrimac; (d) the Town of Newbury; (e) the City of Newburyport; (f) the Town of Salisbury; (g) the Town of West Newbury; and (h) the city of Haverhill.
4.
Every hospital in the Massachusetts EPZ is required, by law and/or regulation, to have (a) adequate emergency response plans, and (b) the resources (material and human) necessary to implement those plans.
5.
Each of the following types of special facilities in the Massachusetts EPZ is required, by law and/or regulations, to have (i) adequate emergency response plans, and (ii) the resources (material and human) necessary to implement those plans:
(a) nursing homes;.
(b) homes for the mentally retarded; (c) residences for the mentally ill; and (d) local lock-ups.
6.
As required by federal and/or state law and/or regulation, the Commonwealth of Massachusetts and the six Massachusetts EPZ communities have adequate (a) plans, (b) personnel, and (c) resources to respond to a major non-radiological hazardous event (such as the i
chemical release emergency that occurred earlier this year in the Springfield area), should one occur in the Massachusetts EPZ, in such a way as to provide reasonable assurance that adequate protective measures can and will be taken to protect the public health and safety.
By their attorneys, 4
jzom Thcuas G.
Dignan, Jr.
George H.
Lavald Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith Roper, & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100
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,'i,F[$k 28 WV -g p4 50 CERTIFICATE OF SERVICE OF r,.
as I, Kathryn A. Selleck, one of the attorneys fodWf:h'e,Ih..
Applicants herein, hereby certify that on Novemb r 3, 1988, I made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):
Administrative Judge Ivan W. Smith Robert Carrigg, Caairr,an Chairman, Atomic Safety and Board of Selectuer-Licensing Board Panel Town Office U.S.
Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 036'l East West Towers Building 4350 East West Highway Bethesda, MD 20814 Judge Gustave A. Linenberger Diane Curran, Esquire Atomic Safety and Licensing Andrea C.
Forster, Esquire Board Panel Harmon & Weiss U.S.
Nuclear Regulatory Suite 430 Commission 2001 S Street, N.W.
East West Towerk Building Washington, DC 20009 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies)
U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission East West Towers Building One White Flint North, 15th Fl.
I 4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852
- Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel 116 Lowell Street U.S.
Nuclear Regulatory P.
O.
Box 516 Commission Manchester, NH 03105 Washington, DC 20555 l
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Philip Ahrens, Esquire Mr. J.
P. Nadaau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road Getieral Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S.
Sneider, Esquire Matthew T.
Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney
- s Maplewood Avenue General P.O.
Box 360 One Ashburton Place, 19th Fl.
Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey R.
Scott Hill-Whilton, Esquire U.S.
Senate Lagoulis, Clark, Hill-Washington, DC 20510 Whilton & McGuire (Attn Tom Burack) 79 State Street 4
Newburyport, MA 01950
- Senator Gordon J. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 507 Kopelman & Paige, P.C.
Concord, NH 03301 77 Franklin Street (Attn:
Herb Boynton)
Boston, MA 02110 Mr. Thomas F.
Powers, III Mr. William S.
Lord Town Manager Board of Selectmen TUvn of Exeter Town Hall - Friend Street 15 Front Street Amesbury, MA 01913 Exettr, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agoney Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Gary W.
Holmes, Esquire Richard A. Hampe, Ecquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 3-
e 4
b Mr. Richard R.
Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street, 2nd Floor Agenc'f Newburyport, MA 01950 Federal Regional Center 130 228th Street, S.W.
Bothell, Washington 98021-9796 Ashod N.
Amirian, Esquire 376 Main Street Haverhill, MA 01830 Robert R.
Pierce, Esquire John H. Frye, III, Alternato Atomic Safety and Licensing Chairman Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory East West Towers Building Commission 4350 East West Highway East West Towers Building Bethesda, MD 20814 4350 Zast West Highway Bethesda, MD 20814 James H. Carpenter, Alternate Technical Member Atomic Safety and Lice". sing Board Panel U.S.
Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 F4tpryd A.
Seilleck
(*= Ordinary U.S. First Class Mail) l 3
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