ML20211A404
| ML20211A404 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/08/1986 |
| From: | Brock M HAMPTON, NH, SHAINES & MCEACHERN |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#486-1063 OL, NUDOCS 8610150113 | |
| Download: ML20211A404 (5) | |
Text
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Filed:
October 8,9dffh UNITED STATES OF AMERICA E OCT -9 P3 :08 -
1 NUCLEAR REGULATORY COMMISSION gy g,.
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before the
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ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERV: ICE COMPANY OF Docket Nos.
50-443-OL NEW HAMPSHIRE, ET AL 50-444-OL (Seabrook Station, Units 1 and 2)
Of f-Site Issues TOWN DE HAMPTON MOTION IQ ESTABLISH HEARING SCHEDULE AND EDE ADDITIONAL TIME IQ FILE CONTINTIONS AND FOR INCORPORATION OF CONTENTIONS
-NOW COMES the Town of Hampton, in response. to Appl ica nt s' September 25, 1986 Motion for Decision on Pending Summary Disposition Motions and for Establishment of a Hearing Schedule on New Hampshire Emergency Planning Issues, and req uests this Board to ORDER:
1.
That this Board establish a filing deadline of January 1, I
1987 for contentions.on New Hampshire Radiological Emergency Response Plan Revision #2 on grounds set forth in SEACOAST ANTI-POLLUTION LEAGUE, TOWN OF HAMPTON, TOWN OF HAMPTON FALLS AND TOWN OF SOUTH HAMPTON RESPONSE TO APPLICANTS' MOTION FOR DECISION ON MOTIONS FOR
SUMMARY
DISPOSITION AND HEARING SCHEDULE WITH RESPECT TO NEW HAMPSHIRE EMERGENCY PLANNING ISSUES dated October 6,1986 or 8610150113 861008 PDR ADOCK 05000443 G
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k' 2.
Alternatively, should this Board decline to grant said relief, that the Town of Hampton be granted an extension of time to file contentions on New Hampshire Radiological Emergency Response Plan Revision #2 until December 1, 1986 on grounds:
a.
That f or calendar year,19 86 the State of New Hampshire has now served upon the Town of Hampton a fourth (4th) substantial revision (Revision "2"
so called),
to the New Hampshire Radiological Emergency Response Plan.
b.
That' the Tow n of Hampton understandably, reasonably, and predictably exhausted its legal budget for the Seabrook proceedings in responding l
and filing contentions to the first three r evisions of the N.H.R.E.R.P.
c.
That upon receipt of the fourth revision to the N.H.R.E.R.P. on September 9,1986, the Town of Hampto n, pr omptly, consistent with due regard for the rights of notice to its citizens, convened a I
public meeting to consider appropriation of additional monies for legal representation in the Seabrook proceedings.
d.
That at said public hearing on October 2,
- 1986, the town so approved addtional legal expenditures in this case.
f' b
e.
That 'in view of the f oregoing, the Town of-Hampton, at a minimum, should be granted an additional 30 day s from the date the town so approved further legal expenditures, or until December 1, 1986.
f.
That f undamental f airness req uires that the Town of Hampton at a minimum, be granted said extension of time until December 1,1986 to file contentions on revision #2, since the Town meeting req ui ring further approval of legal expenditures _
was occassioned exclusively by the State of New Hampshire's repeated and substantial modifications to the R.E.R.P.,
which could not reasonably be predicted at the time the town originally allocated its legal expenditures for 1986.
3.
All previous contentions and objections to the Radiological Emergency Response Plan filed by the Town of Hampton are hereby realleged against Revision #2 and are incorprated by reference herein.
Respectfully submitted, THE TOWN OF HAMPTON By Their Attorneys, SHAINES & McEACHERN, P.A.
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DATED: October 8, 1986 Matthew T. Brock I
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I hereby certify that a copy of the w ithin Motion to Establish Hearing Schedule and For Additional Time to File Contention has been sent this date, first class, postage prepaid, to all counsel on the attached service list.
DATED: October 8, 1986 k
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Matthew T. Brock l
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. CERTIFICATE OF SERVICE ANd" SERVICE LIST Joseph Flynn, Asst.,
Helen Hoyt, Cggiqggn.g pyhggas Dignan, esquire General Counsel Admn. Judge Ropes & Gray 500 C. St. So. West Atomic Safety &
225 Franklin Street Washington, DC 20472 Licensing BoMfdl..'
Bv'ggton, MA 02110 Washington,DC205$$g
USNRC 00CAEipi Office of Selectmen Town of Hampton Falls Dr. Jerry Harbour Docketing & Serv. Sec.
Hampton Falls, NH 03844 Admin. Judge Office of the Secretary Atomic Safety &
USNRC Licensing Board Washington, Dc 20555 Washington, DC 20555 Sherwin E. Turk, Esq.
Dr. Emmeth A. Luebke Jane Doughty Of fice of Exec. Legl.
Admin. Judge SAPL Dr.
Atomic Safety & Lic.
5 Market Street USNRC Board Portsmouth, NH 03801 Wachington, DC 20555 USNRC Washington, DC 20555 Phillip Ahrens, Esq.
Diane Curran, Esq.
George Dana Bisbee, Esq.
Asst. Atty. General Harmon & Weiss Attorney General's Off.
State House, Sta. #6 20001 S St. NW State of New Hampshire Augusta, ME 04333 Suite 430 Concord NH 03301 Washington, DC 20009 Carol Sneider, Esq.
Maynard Young, Chrm.
William S. Lord Assistant AG Board of Selectmen Board of Selectmen One Ashburton Place 10 Central Road Town Hall - Friend St.
19th Floor Rye, NH 03870 Amesbury, MA 01913 Boston, MA 02108 Richard A.
Hampe, Esq.
Edward Thomas Sandra Gauvutis NH Civil Defense Agcy.
FEMA Town of Kingston Hampe & McNicholas 442 J.W. McCormack Box 1154 35 Pleasant St.
(POCH)
East Kingston, NH 03827 Concord, INH 03301 Boston, MA 02109 l
Roberta Pevear Robert Backus, Esq.
Mr. Robert Harrison State Rep. Town of Backus, Meyer &
President & Chief Exec.
Hampton Falls Solomon Officer Drinkwater Road 116 Lowell St PSCO Hampton Falls, NH 03844 P.O. Box 516 P.O. Box 330 Manchester, NH 03105 Manchester, NH 03105 l
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