ML20211N672
| ML20211N672 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/27/1986 |
| From: | Gad R PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-824 OL, NUDOCS 8607030182 | |
| Download: ML20211N672 (4) | |
Text
.-
, T,
'w, Dated:
June 27, 1986 SkU UNITED STATES OF AMERICA
- II. -2 gl g NUCLEAR REGULATORY COMMISSIO gOCMb FflAnw Fr/cr before the 8
VICE ATOMIC SAFETY AND LICENSING BOARD 8 P.
l
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.
)
50-444-OL
)
On-site Emergency Planning (Seabrook Station, Units 1 and 2) )
and Safety Issues
)
)
APPLICANTS' RESPONSE TO. TOWN OF HAMPTON REQUEST FOR HEARING ON PENDING ON-SITE EMERGENCY PLANNING AND SAFETY CONTENTIONS Under date of June 23, 1986, the Town of Hampton (Hampton) filed a " Request for Hearing on Pending On-Site Emergency Planning and Safety Contentions."
Applicants' herein answer that request and say that the same should be denied.
Hampton originally sought participation in this proceeding because of " vital interests in the Baord's review of emergency preparedness plans for the site."
Hampton Request to Participate as an Interested Municipality (December 15, 1982).
The Board's drder admitting Hampton as 8607030182 860627 PDR ADOCK O y3 p5b3
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)
an Interested Municipality directed Hampton "to indicate a
with reasonable specificity the subject matters on which i
Iit] desire [s] to participate.
Such [ response is] to be i
filed within 30 days of service of this Order" ASLB Order l
(Admitting Towns of Brentwood and Hampton as Interested Municipalities) (December 20, 1982) at 1.
Hampton never complied with this Order.
Hampton never filed proposed findings with respect to the on-site emergency planning and safety issues.
Before the "off-site" Board Hampton has I
j filed contentions relating only to the matter of off-site 2
Hampton has no standing to make the 1
request at bar.
Moreover, Hampton has ignored the portion of this i
Board's Order of November 4, 1985, that the record was being reopened only for supplementation not a retrial of matters already heard.
Hampton has made no demonstration as to why i
it needs a prehearing conference, discovery, or cross-examination in an evidentiary hearing with respect to 1
the Staff filings applicants have requested the Board to l
j incorporate into the record.
By their attorneys,
.M N G.'D giJr.
R. K. Gad m Ropes & Gray 225 Franklin Street i
Boston, MA 02110 (617) 423-6100 i '
I
s v
CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr.,
one of the attorneys for the Applicants herein, hereby certify that on June 27, 1986, I made service of the within document by mailing copies thereof, postage prepaid, to:
Administrative Judge Sheldon J.
Stephen E. Merrill, Esquire Wolfe, Esquire, Chairman Attorney General Atomic Safety and Licensing George Dana Bisbee, Esquire Board Panel Assistant Attorney General U.S. Nuclear Regulatory Office of the Attorney General Commission 25 Capitol Street Washington, DC 20555 Concord, NH 03301-6397 Dr. Emmeth A. Luebke Dr. Jerry Harbour Atomic Safety and Licensing Atomic Safety an'd Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Robert Carrigg, Chairman Richard A. Hampe, Esquire Board of Selectmen Hampe and McNicholas Town Office 35 Pleasant Street Atlantic Avenue Concord, NH 03301 North Hampton, NH 03862 Andrea C.
Eerster, Esquire Sherwin E. Turk, Esquire Diane Curran, Esquire Office of the Executive Legal Harmon & Weiss Director Suite 430 U.S.
Nuclear Regulatory 2001 S Street, N.W.
Commission Washington DC 20009 Washington, DC 20555 Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street i
Commission P.O.
Box 516 l
Washington, DC 20555 Manchester, NH 03105 Atomic Safety and Licensing Mr. Ed Thomas Board Panel FEMA, Region I U.S. Nuclear Regulatory 442 John W. McCormack Post Commission Office and Court House Washington, DC 20555 Post Office Square Boston, MA 02109 i
i
s Paul McEachern, Esquire Carol S.
Sneider, Esquire Matthew T.
Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 Fortsmouth, NH 03801 i
Gary W. Holmes, Esquire Mr. Peter J. Matthews Holmes & Ells Mayor 4~l Winnacunnet Road City Hall Hampton, NH 03841 Newburyport, MA 01950 Mrs. Sandra Gavutis Mr. Calvin A.
Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Kensington, NH 03827 126 Daniel Street Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. Angie Machiros U.S.
Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn:
Tom Burack)
Town of Newbury Newbury, MA 01950 Senator Gordon J. Humphrey Mr.
J.
P. Nadeau 1 Pillsbury Street Selectmen's Office Concord, NH 03301 10 Central Road (Attn:
Herb Boynton)
Rye, NH 03870 Mr. Thomas F.
Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amesbury, MA 01913 H.
Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
Judith H. Mizner, Esquire Washington, DC 20472 Silvergate, Gertner, Baker Fine, Good & Mizner Philip Ahrens, Esquire 88 Broad Street Assistant Attorney General Boston, MA 02110 Department of the Attorney General Augusta, ME 04333
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