ML20213A028

Notifies That Seacoast Anti-Pollution League Filed Brief in Opposition to Applicants Petition Under 10CFR2.758 & 10CFR50.47(c) for Reduction in Size of Facility Plume Exposure Pathway Epz,Per ASLB 870107 Order

ML20213A028
Person / Time
Site:	Seabrook
Issue date:	01/27/1987
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	Harbour J, Hoyt H, Luebke E Atomic Safety and Licensing Board Panel
References
CON-#187-2350 OL, NUDOCS 8702030064
Download: ML20213A028 (2)

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L 2354 BAC K Us, M EY ER & S O LO M o r90te f iG d ArronNEys AT LAW mos cnt A. BACst y g AREA COCC 603 SON ucven- R o 0o= sie '87 JAN 29 P2 :49 e . . .u n j STEVCN A. SOLOMON MANCH ESTER, N. H. ossos *ALSO ACMITTCO M ARilN R. JCN KIN g .

TO MASSACHL/5ETTS BAR

"'C"*"5^*'* 00CKETiN . i . t J,1 9 .l. BRANCH b w" January 27, 1987 l

$ J udge liclen lloyt , Chairperson Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission East West Towers Building

< 4350 East West liighway Be t h es da , MD 2 0 814 i-Dr. Emmeth A. Luebke l Atomic Safety and Licensing Board i U.S. Nuclear Regulatory Commission  !

. East West Towers Building 4

4350 East West Highway Bethesda, MD 20814 i

Dr. J er ry liarbour Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway

' Bethesda, MD 20814

) Re: Public Service Company of New Hampshire, et al Docket No. 5 0-44 3-OL/.5o - # Vf-o L

Dear Administrative Judges:

l SAPL has this date filed " Seacoast Anti-Pollution League's Brief in 1 Opposition to Applicants' Petition Under 10 CFR !2.758 and 10 CFR l 650.47(c) For Reduction in the Size of the Seabrook Station Plume j Exposure Pa thway EPZ" pursuant to the Board's Order of January 7,

!' 1987, i

i it is SAPL's position, for the reasons set forth in our Brief, that i

the Applicants have not made "a pr ima f acie showing" ent itling their

Petition to any further consideration by this Board, or by the

. Commission. SAPL balleves a prima facie case must include the ,

l establishment of sufficient facts so that, if not rebutted, the

! Applicants could be found entitled to the relief which they seek.

, As set for th in our Brief, the Applicants have not met this s tandard.

8702030064 870127 ) bO hDR ADOCK 05000443 i PDR

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Lastly, SAPL wishes to advise the Board that it was not able to complete its submission by this date, and would advise the Board that the " reasonable date certain" by which SAPL expects to be able to complete its response is February 26, 1987. Perhaps SAPL will be able to_ expedite its response before that date, but this will depend in part upon what further activities become necessary in regard to ongoing Seabrook licensing proceedings.

Very truly yours, -

n/s / ,

fl, f h A 4

,/ bert A. Backus RAB/ lab cc: Attached service list d