ML20212D130
| ML20212D130 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/23/1986 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#486-2036 OL, NUDOCS 8612310297 | |
| Download: ML20212D130 (3) | |
Text
I 2o 3 (a Filed:
December 23, 1986 000Mfi!:
, av. c UNITED STATES OF AMERICA NUCLEAR REGULATORY CO\\1 MISSION 86 DEC 30 P1 :08 BEFORE THE ATOMIC SAFETY AND LICENSING BOARpgg, 00thf N A m
p f. -.,
in the matter of:
PUBLIC SERVICE COMPANY OF Docket No.
50-443 OL NEW HAMPSHIRE, ET AL (Seabrook Station, Units I and 2)
Offsite Emergency Planning
& Safety Issues SAPL'S MOTION FOR RECONS IDERATION OF THE BOARD'S MEMORANDUM AND ORDER OF DECEMBER 11, 1986 RULING ON NECNP'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL CONTENTIONS ON REVISION 2 OF THE N.H.
STATE AND LOCAL RADIOLOGICAL EMERGENCY RESPONSE PLAN On December 10,
- 1986, the New England Coalition on Nuclear Pollut ion filed a pleading ent i tled "NECNP Supplemental Content ions on Revision 2 of the N.H.
State and Local Radiological Emergency Response Plans" and a motion for leave to file the supplemental contentions.
On December 19, 1986, a Board Memorandum and Order da t ed December 11, 1986 was received at the SAPL of fice which denied NECNP's motion for " lack of good cause shown."
The Board simply reasserted that the date established by the Board for filing content ions based on Revision 2 of the NHRERP was December 1, 1986.
The Board further stated that it would supplement the Order "at an early date."
SAPL moves that the Board reconsider its finding of lack of good cause shown.
SAPL holds that the voluminous nature of the 8612310297 861223 O
PDR ADOCK 05000443 b
G PDR
Revision 2 plans and the short time duration allowed the parties constitute good cause for late filing.
Further, SAPL would hold that some of the matters raised in the above-mentioned NECNP contentions were not raised earlier because of the lack of availability of certain documents to intervening parties until very recently.
FEMA GM MS-1 (s ee NECNP Cont en t ion RERP-15 ) di d no t become available until November 17, 1986 and the Stello Memorandum dated April 30, 1986 (see NECNP Contention RERP-16) was not available to intervenors until even later.
SAPL further holds that certain of the matters raised in NECNP's pleading are of such import that the Board ought raise them sua sponte in the absense of sponsorship by an intervening party.
SAPL would reserve its rights with regard to NECNP's Contentions RERP-15, RERP-16 and RERP-17, in which it would have joined had the Board not so precipitously ruled them inadmissible.
Respectfully submitted, SEAOOAST ANTI-POLLUTION LEAGUE By its attorney, BACKUS, MEYER & SOLOMON
/
s't s'
Robert A.
Backus P. O.
Box 516 116 Lowell Street Manchester, N. fl.
03105 Tel: (603) 668-7272 DATE:
December 23, 1986 I her eby cer t i f y t ha t a copy o f t he wi t h in SAPL'S MOTION FOR RECONS I DERATION OF T!!E BOARD'S MEMEMORANDUM AND ORDER OF DECEMBER 11, 1986 has been sent this date, first class, postage prepaid, to those listed on the attached service list.
7
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~ fo &
Ro be rt A.
Backus
CERTIFICATE OF SERVICE AND SERVICE LIST Joseph Flynn Asst.Gn.Cnsl.
Helen Hoyt. Chm.
Thomas Dignan, Esq.*
Fcd. Emerg. Algmt. Agcy.
Admn. Judge Ropes & Gray 500 C.St. So. West Atomic Safety & Lic Brd.
225 Franklin St.
Washington, DC 20472 USNRC Boston, AIA 02110 Washington, DC 20555 Office of Selectmen Dr. Jerry Harbour
- Docketing & Serv. Sec.
Town of Hampton Falls Admin. Judge Office of the Secretary Hampton Falls, NH 03844 Atomic Safety & Lic Brd.
USNRC USNRC Washington, DC 20555 Washington, DC 20555 Sherwin E. Turk, Esq.
Dr. Emmeth A. Luebke Jane Doughty Office of Exec. Legl. Dr.
Admin Judge SAPL RC Atomic Safety & Lic. Brd.
5 5!arket Street Wahsington, DC 2055o_
USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq.
Paul AlcEachern, Esq.
George Dana Bisbee, Esq.
Asst. Atty. General 5!atthew Brock, Esq.
Attorney General's OFF.
State House, Sta. #6 25 5!aplewood Ave.
State of New Hampshire Augusta, 5!E 04333 P.O. Box 3GO Concord, NH 03301 Portsnouth, NH 03801 Carol Sneider, Esq., Asst. AG Diane Curran, Esq.
William S. Lord One Ashburton Place, IIarmon, Weiss Board of Selectnen 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.
Boston, 51A 02108 Washington, DC 20009 Amesbury, AIA 01913 Richard A. Hampe, Esq.
Afaynard Young, Chaimnn Sandra Gauvutis New Hampshire Civil Deiense Board of Selectmen Town of Kingston Agency 10 Central Road Box 1154 Hampe & 5IcNicholas Rye, h1I 03870 East Kensington, NH 03827 l
35 Pleasant St.
Concord, NH 03301 Judith H. Mizner, Esq.
Edward Thomas lir. Robert Harrison Silverglate, Gertner, FE5!A Pres, & Chief Exec. Officer Baker, Fine, Good & Mizner 442 J.W. 5!cCormack (POCH)
PSCO 88 Broad Street Boston, 5!A 02109 P.O. Box 330 Boston, MA 02110 Slanchester, NH 03105 Roberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, NH 03844
.