ML20206H014
| ML20206H014 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/10/1987 |
| From: | Humphrey G SENATE |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#287-3057 OL-1, NUDOCS 8704150223 | |
| Download: ML20206H014 (5) | |
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i 00LKETED UNITED STATES OF AMERICA U
NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BOARD
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Before Administrative Judges:
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Alan S. Rosenthal, Chairman uGCKET Ga ry J. Edles Howard A. Wilber
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In the matter of
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Docket Nos. 50-443-OL PUBLIC SERVICE COMPANY OF
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50-444-OL NEW HAMPSHIRE, et al.
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On-site Emergency
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Planning Issues (Seabrook Station, Units 1 and 2)
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April 10, 1987
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SENATOR GORDON J. HUMPHREY'S MOTION FOR LEAVE TO FILE AN AMICUS CURTAE BRIEF IN SUPPORT OF ATTORNEY GENERAL JAMES M.
SHANNON'S APPLTCATION FOR A STAY Senator Gordon J. Humphrey hereby requests leave to file an amicus curiae brief, pursuant to 10 CFR Section 2.715(d),
in support of Attorney General James M. Shannon's application of April 6, 1987 for a stay of Licensing Board order i
authorizing issuance of opera. ting license to conduct low-f power operation.
Senator Humphrey's interest in filing a brief amicus curiae stems from the fact that the Seabrook nuclear plant is in the State of New Hampshire.
As a representative of New Hampshire, decisions affecting the Seabrook nuclear plant are of obvious interert to the Senator and his constituency.
In its decision of March 30, 1987, regarding Senator Humphrey's participation on off-site emergency planning 8704150223 B70410 PDR ADOCK 05000443 m (6 G
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...we have not overlooked the Senator's observation that, by virtue of his office, he is called upon to represent the interests ~of his constituents, the citizens of New Hampshire, on all matte'rs relating to the federal government.
In this regard, it is likely that, even though not the official spokesman for the state, the Senator could supply a perspective that would materially aid the Licensing Board's deliberations on the weighty and complex offsite emergency planning. issues that the Board must resolve."
In order to allow the Senator to present his views on issues of fact or law relating to the off-site emergency planning Seabrook proceedings, the Appeal Board decided that the Senator be allowed to participate as an amicus curiae on off-site emergency planning issues.
Senator Humphrey submits that the same reasons expressed by the Appeal Board in its decision of March 30, 1987 apply to this issue regarding issuance of a low-power operating license.
Respectfully nubmitted, GORDON J. HUMPHREY, USS
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Gd' don J. #umphrey'
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Pro Se
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531 Hart Senate Office Building Washington, DC 2051'O (202) 224-2841 DATED:
Washington, District of Columbia April 10, 1987
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UNITED STATES OF AMERICA 00uETE:
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING A PPE AL E8 Ai? 13 P5 :39 In the Matter of 0Fw. -
PUBLIC SERVICE COMPANY OF DOCKET NOS. 50-40 ppb
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O NEW H AMPSHIRE, et al.
50-444 0 (Seabrook Station, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of the enclosed letter have been served on the following by deposit in the United States mail on the 10th day of April, 1987 Alan S.
Rosenthal, Chairman Gary J. Edles Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission East West Towers Bldg East West Towers Bldg Third Floor Mailroom Third Floor Mailroom 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Howard A. Wilber Sheldon J. Wolfe, Chairman Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Bldg East West Towers Bldg Third Floor Mailroom Third Floor Mailroom 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Helen Hoyt, Esa., Chairman Atomic Safety & Licensing Administrative Judge Board Panel I
Atomic Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 East West Towers Building 1
Fourth Floor Docketing and Service 4350 East West Highway U.S. Nuclear Regulatory Bethesda, MD 20814 Commission Washington, D.C.
20555 Dr. Jerry Harbour Administrative Judge Mrs. Anne E. Goodman' l
Atomic Safety and Licensing Board Board of Selectmen U.S. Nuclear Regulatory Comm 13-15 Newmarket Road Washington DC 20555 Durham, NH 03842 m.
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William S.
Lord, Selectman Dr. Emmeth A. Luebke Town Hall Administrative Judge Friend Street Atomic Safety and Licensing Board Amesbury, MA 01913 U.S. Nuclear Regulatory Commission Jane Doughty Washington, D.C.
20555 Seacoast Anti-Pollution League Atomic Safety and Licensing Board 5 Market Street Panel Portsmouth, NH 03801 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Rep. Roberta Pevear Carol S. Sneider, Esq.
Drinkwater Road Assistant Attorney General Hampton Falls, NH 03844 Department of the Attorney General Philip Ahrens, Esq.
One Ashburton Place Assistant Attorney General 19th Floor Office of the Attorney General Boston, MA 02108 State House Station 6 Stanley W. Knowles Augusta, ME 04333 Board of Selectmen P.O. Box 710 Thomas G.
Dignan, Esq.
North Hampton, NH 03826 R.K. Gad II, Esq.
Ropes & Gray J.P. Nadeau, Selectman 225 Franklin Street Town of Rye Boston, MA 02110 155 Washington Road Rye, NH 03870 Robert A. Backus, Esq.
Backus, Meyer & Solomon Richard E. Sullivan, Mayor 111 Lowell Street City Hall Manchester, NH 03105 Newburyport, MA 01950 Robert G.
Perlis, Esq.
Alfred V. Sargent, Chrmn.
Sherwin E. Turk, Esq.
Board of Selectmen Office of the Executive Legal Town of Salisbury,MA 01950 Director 4
U.S. Nuclear Regulatory Diane Curran, Esq.
Commission Harmon & Weiss Tenth Floor 2001 S Street, NW 773501d Georgetown Road Suite 430 Bethesda, MD 20814 Washington, DC 20009-1125 Michael Santosuosso, Chrmn Mr. Angie Machiros, Chairman Board of Selectmen Board of Selectmen Jewell Street Newbury, MA 01950 RFD 2 South Hampton, NH v3842 O*
H. Joseph Flynn, Esq.
Office of General Counsel Allen Lampert Federal Emergency Management Civil Defense Director Agency Town of Brentwood 500 C Street, SW Exeter, NH 03833 Washington, D.C.
20472 Richard A. Hampe,.Esq.
George Dana Bisbee, Esq.
Hampe and McNicholas Stephen E. Merrill, Esq.
35 Pleasant Street Office of the Attorney General Concord, NH 03301 State House Annex Concord, NH 03301 Gary W. Holmes, Esq.
Edward A.
Thomas Holmes & Ellis Federal Emergency Manage-47 Winnacunnet Road ment Agency Hampton, NH 03842 442 J.W. McCormack (POCH)
Boston, MA 02109 William Armstrong Civil Defense Director Sandra Gavutis 10 Front Street Town of Kensington Exeter, NH 03833 RFD 1, Box 1154 East Kensington, NH 03827 Calvin A.
Canney City Manager Charles P. Graham, ESq.
City Hall McKay, Murphy & Graham 126 Daniel Street 100 Main Street Portsmouth, NH 03801 Amesbury, MA 01913 I
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dordon J.' Humphrdy, USS/
Pro Se
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