ML20211N480
| ML20211N480 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/27/1986 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-811 OL, NUDOCS 8607030121 | |
| Download: ML20211N480 (4) | |
Text
- _ - _ _ _ - _ _ _ _ _ -
((D*
FILED:
June 2 7,.
1 9 8 6 UNITED STATES OF AMERICA D
NUCLEAR REGULATORY COmflSSION O KEfE0 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 16 JL -2 21 2
4 In the matter of:
OFFICE 0; ?Ela t raw y NggC,MEigy*EBvic60-443 OL PUBLIC SERVICE COMPANY OF Docket NEW HAMPSHIRE, et al 50-444 OL (Seabrook Station, Units I and 2)
Off-Site Emergency Planning and Safety Issues MOTION TO CONTINUE HEARING NOW COMES the Seacoas t Ant i-Pollut ion League ("SAPL") and moves pursuant t o 10 C. F. R. 2.711 that the date for prefiling of testimony and for hearing of of f-site emergency planning issues now scheduled by this Board to start on August 4,1986 be continued, and in support states as follows:
1.
This Board's schedule was derived in light of an anticipated commercial operation date for Seabrook Unit I of October 31, 1986.
In the most recent SEC Form 10Q, the lead Applicant, Public Service Company of New Hampshire, has stated that:
"In view of these f actors, the date of commercial operat ion of Seabrook Unit 1 of October 31, 1986 will not be achieved and the Company is unable to predict when commercial operation will in fact occur."
Therefore there is now no reason to expedite the hearings in this docket, even if one is prepared to concede, which SAPL is not, that the Applicants' anticipated date of commercial operation should drive this Board's licensing schedule.
2.
The need for a delay to property prepare for the hearing on the contested off-site emergency planning issues has been set kok030121 860627 g
ADOCK 050o 3
's
=
l forth in the Town of Hampton's Motion to Continue of June 20, 1986, in which SAPL joins.
3.
In addit ion, the need for f urther time to adequately address the issues has been set out by staff counsel for the NRC during the i
March 26, 1986 prehearing c,onference.
Counsel at that time stated:
"I want to advise the Board, however, that under the current schedule it is questionable whether we will be able to j
proceed with a Government--Federal Government view of adequacy under the current schedule.
.I can't make a more definite statement, but I do want to alert you to the f act that various problems have been identified to date which could well delay the Federal Government being ready to support the plans.
I have discussed this briefly with representatives of the State of New Hampshire and with the Applicant, for various reasons, the Applicant is not prepared to delay this current i
schedule, nor is the State willing to be a party to suggest delay.
)
^
As I mentioned, the Staff does not want to cause delay, but these are facts which should come to the Board's 1
attention and probably will in the next several months.
j I want to give you early warning at this time of those i
facts."
4.
SAPL further avers in support of this motion that a single f
set of hearings on the adequacy of emergency plans for the entire s
j emergency planning zone would represent the most appropriate and efficient method to address the emergency planning issues, since NUREG-0654 calls for emergency planning issues to be resolved in an j
integrated f ashion. Since there is no present anticipated commercial operation date, as set forth in paragraph 1 above, opportunities exist to schedule a single hearing, instead of the three or four
]
separate hearings that may be required under the present schedule, (One hearing for the New Hampshire plans, one on the Massachusetts e
plans, if and when submitted, one or two on the results of FEMA I.
graded exercise of the New Hampshire and Massachusetts plans.)
i
, l
1 I
For the foregoing reasons, SAPL hereby moves to continue the hear ings scheduled f or Augus t 4, 1986, and suggests that this Board schedule a further prehearing conference to develop an appropriate schedule in light of the new circumstances.
Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By Its Attorney, BACKUS, MEYER & SOLOMON ffr Robert ~A.
Backus P. O.
Box 516 116 Lowell Street Manchester, NH 03105 (603)6G8-7272 June 27, 1986 I hereby certify that the enclosed has been sent to all persons on the attached service list by first-class, postage prepaid mail.
A
~
Robert A.
Backus
' \\
l i
Thomas Dignan, Esq.*
Jose Asst.Gn.Cnsl.
Helen Hoyt. Chm.
Fed. ph Flynnhigmt. Agcy.
Admn. Judge Ropes & Gray Emerg.
500 C.St. So. West Atomic Safety & Lic Brd.
225 Franklin St.
Washington, DC 20472
'USNRC Boston, 11A 02110 Washington, DC 20555 Office of Selectmen Dr. Jerry Harbour
- Docketing & Serv. Sec.
- Town of Hampton Falls Admin. Judge Of fice of the Secretary Hampton Falls, NH 03844 Atomic Safety & Lic Brd.
USNRC USNRC Washington, DC 20555 Washington, DC 20555 em n k, Eq.
Dr. Emmeth A. Luebke Jane Doughty Office of Exec. Legl. Dr.
Admin Judge SAPL USNRC Atomic Safety & Lic. Brd.
5 Alarket Street Wahsington, DC 20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq.
Paul SicEachern, Esq.
George Dana Bisbee, B q.
Asst. Atty. General 11atthew Brock, Esq.
Attorney General's OFF.
State H0use, Sta. 76 2511aplewood Ave.
State of New Hampshire Augusta, 1!E 04333 P.O. Box 360 Concord, NH 03301 Ports:routh, Nri 03801 Carol Sneider, Esq., Asst. AG Diane Curran, Esq.
William S. Lord i
One Ashburton Place, Ilarmon, Weiss Board of Selectrrnn 19th Floor 20001 S $treet NW Suite 430 Tbwn Hall-Friend St.
Boston, SIA 02108 Washington, DC 20009 Amesbury, 11A 01913 i
Richard A. Ha:rpe, Esq.
5!aynard Young, Chairnnn Sandra Gauvutis New Hampshire Civil Delense Board of Selectmen Town of Kingston-i Agency 10 Central Road Box 1154 Hampe & IIcNicholas Rye, MI 03870 East Kensington, NH 03827 4
35 Pleasant St.
Concord, NI 03301 t
Edwnrd 'Ihomas
-1!r. Robert Harrison FBIA Pres & Chief Exec. Officer 442 J.W.11cConnack (POQI)
PSCO Boston,11A 02109 P.O. Box 330 11anchester, MI 03105 Roberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, MI 03844
_.,..