ML20214N099
| ML20214N099 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/21/1987 |
| From: | Humphrey G SENATE |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#287-3572 OL-1, NUDOCS 8706020062 | |
| Download: ML20214N099 (6) | |
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UNITED STATES OF AMERICA 00CKETED NUCLEAR REGULATORY COMMISSION USHRC BEFORE THE COMMISSION T@ MY 22 A7:56 0FFIC:..V 2 J i;d
)
00CXliwi. ~;em In the matter of
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EPieCH
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Docket Nos. 50-443-OL,_f PUBLIC SERVICE COMPANY OF
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50-444-OL i
NEW HAMPSHIRE, et al.
)
On-site Emergency
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Planning Issues (Seabrook Station, Units 1 and 2)
)
)
May 21, 1987
)
SENATOR GORDON J. HUMPHREY 'S MOTION FOR LE AVE TO FILE AN AMICUS CURI AE BRIEF IN SUPPORT OF ATTORNEY GENERAL JAMES M.
SHANNON'S APPLICATION FOR A STAY Senator Gordon J. Humphrey hereby requests leave to file an amicus curiae brief, pursuant to 10 CFR Section 2.715(d),
in support of Attorney General James M. Shannon's application of May 13, 1987 for a stay of Licensing Board order authorizing issuance of an operating license to-conduct-low-power operation.
Senator Humphrey would intend to file by May 28, 1987, the same time period granted ~ to any party.
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wishing to answer service of a stay motion under the Secretary of the Commission's Order of-May 14, 1987, and will not delay the Commission.1/
Senator Humphrey's interest in filing a brief amicus curiae stems from the fact that the Seabrook nuclear plant is 1/
The Attorney General filed his application for a stay on May 13 Under 10 CFR 2.710, "[w]henever a party has'the right or-is required to do some act within a prescribed x,
period after the service of a notice or other paper upon him or her and the notice or paper is served upon by mail, five (5) days shall be added to the prescribed period."
B706020062 870521 PDR ADOCK 05000443 G
PDR 03o3
A
. An the State of New Hampshire.
As a representative of New Hampshire, decisions affecting the Seabrook nuclear plant are of very great interest to the Senator and his constituency.
On April 10, 1987, the Senator filed a motion to file an amicus curiae brief before the Appeal Board r ega rding the Licensing Board's order authorizing issuance of a license to conduct low-power operation.
The Senator's motion was granted by the Appeal Board on April 15, 1987 In its decision of March 30, 1987, regarding Senator Humphrey's participation on off-site emergency planning i
issues, the Appeal Board stated, "...we have not overlooked the Senator's observation-that, by virtue of his office, he is called upon to represent the interests of his constituents, the citizens of New Hampshire, on all matters relating to the federal government.
In this regard,--it is l
likely that, even though not the official spokesman for the state, the Senator could supply a perspective that would materially aid the Licensing Board 's deliberations on the I
weighty and complex offsite emergency planning issues that the Board must resolve."
In order to allow the Senator to present his views on issues of fact or law relating to the off-site er.ergency planning Seabrook pr oc e ed ings, the Appeal 1
Board decided that the Senator be allowed to participate as-an amicus curiae on off-site emergency planning issues.
I l
Senator Humphrey submits that the same reasons expressed by the Appeal Board in its decision of March'30, 19 87 apply 4
3
s
\\
3-to this issue regarding issuance of a low-power operating license.
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Respectfully submitted,
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l N J. H UM P, REY, USS G6rdon J.'Humphrey
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Pro Se
/
531 Hart Senate Office Building Washington, DC 20510 (202) 224-2841 DATED:
Washington, District of Columbia May 21, 1987 4
1 1
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i UNITED STATES ~0F AMERICA DOLKETED
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NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE NUCLEAR-REGULATORY COMMISSION I
'87 MAY 22 A7:56 In the Matter of DFFfW x v.Miw' PUBLIC SERVICE COMPANY OF DOCKET.NOS. 5 0-4 4 3DRhif *RANC" G i. SF A v!rJ' 50-444 OC'sB NEW HAMPSHIRE, et al.
(Seabrook Station, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of the enclosed document, SENATOR GORDON J. HUMPHREY'S MOTION.FOR LEAVE TO FILE AN AMICUS CURIAE BRIEF IN SUPPORT OF ATTORNEY GENERAL JAMES M.
SHANNON'S APPLICATION FOR A STAY, have been served on the following by deposit in the United States mail (or by hand i
where indicated by an asterisk) on the 21st day of May.
- Alan S.
Rosenthal,-Chairman
- Gary J. Edles.
Atomic Safety & Licensing Atomic Safety & Licensing Appeal Panel Appeal Panel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory.
Commission Commission Washington, DC 20555 Washington, DC 20555 4
'Howard A..Wilber
- Sheldon J. Wolfe, Chairman Atomic Safety & Licensing Atomic Safety & Licensing Appeal Panel Board U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commis sio n
~
Washington, DC 20555 Washington, DC 20555 eHelen Hoyt, Esq., Chairman
- Atomic Safety & Licensing
]
Atomic Safety and Licensing. Board Board Panel i
U.S.
Nuclear Regulatory' U.S.
Nuclear Regulatory
]'
Commission Commission i
Washington, DC 20555 Washington,' DC 20555 2
1
- Dr. Jerry Harbour
- Docketing and Service Atomic Safety and Licensing Board U.S.
Nuclear Regulatory.
U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, DC 20555
'Mrs. Anne E.
Good man l
eDr. Emmeth A. Luebke Board of Selectmen I
Atomic. Safety and Licensing Board 13-15 Newmarket Road U.S.
Nuclear Regulatory Durham, NH 03842 Commission Washington, DC 20555 1
~
~_~
B
- Gustave A.
Linenberger, Jr.
Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission Jane Doughty Washington, D.C.
20555 Seacoast Anti-Pollution League William S.
Lord, Selectman 5 Market Street Town Hall Portsmouth, NH 03801 Friend Street Amesbury, MA 01913 Rep. Roberta Pevear Carol S.
Sneider, Esq.
Drinkwater Road Assistant Attorney General Hampton Falls, NH 03844 Department of the Attorney General Philip Ahrens, Esq.
One Ashburton Place Assistant Attorney General 19th Floor Office of the Attorney General Boston, MA 02108 State House Station 6 Stanley W.
Knowles Augusta, ME 04333 Board of Selectmen P.O. Box 710 Thomas G. Dignan, Esq.
North Hampton, NH 03826 R.K.
Gad II, Esq.
Ropes & Gray J.P.
Nadeau, Selectman 225 Franklin Street Town of Rye Boston, MA 02110 155 Washington Road Rye, NH 03870 Robert A.
Backus, Esq.
Backus, Meyer & Solomon Ric h a rd E.
Sullivan, Mayor 111 Lowell Street City Hall Manchester, NH 03105 Newburyport, MA 01950 Robert G. Perlis, Esq.
Alfred V. Sargent, Chrmn.
Sherwin E.
Turk, Esq.
Board of Selectmen Office of the Executive Legal Town of Salisbury,MA 01950 Director U.S.
Nuclear Regulatory Diane Curran, Esq.
Commission Harmon & Weiss Tenth Floor 2001 S Street, NW 77350ld Georgetown Road Suite 430 Bethesda, MD 20814 Washington, DC 20009-1125 Mich'ael Santosuosso, Chrmn Mr. Angie Machiros, Chairman Board of Selectmen I
Board of Selectmen Jewell Street Newbury, MA 01950 RFD 2 South Hampton, NH 03842
.t H. Joseph Flynn, Esq.
Office of General Counsel Allen Lampert Federal Emergency Management Civil Defense Direc tor Agency Town of Brentwood 500 C Street, SW Exeter, NH 03833 Washington, D.C.
20472 Richard A.
Hampe, Esq.
George Dana Bisbee, Esq.
Hampe and McNicholas Stephen E. Herrill, Esq.
35 Pleasant Street Office of the Attorney General Concord, NH 03301 State House Annex Concord, NH 03301 Gary W.
Holmes, Esq.
Edward A.
Thomas Holmes & Ellis Federal Emergency 47 Winnacunnet Road Management Agency Hampton, NH 03842 442 J.W. McCormack (POCH)
Boston, MA 02109 William Armstrong Civil Defense Director Sandra Gavutis 10 Front Street Town of Kensington Exeter, NH 03833 RFD 1, Box 1154 East Kensington, NH 03827 Calvin A.
Canney City Manager Charles P.
Graham, Esq.
City Hall McKay, Murphy & Graham 126 Daniel Street 100 Main Street Portsmouth, NH 03801 Amesbury, MA 01913 Matthew T.
Brock, Esq.
Judith H. Mizner, Esq.
Shaines & McEachern Silvergate, Gertner, et al PO Box 360 88 Broad Street Haplewood Avenue Boston, MA 02110 Portsmouth, NH 03801 Selectmen of North Hampton
- Lando Zech, Chairman North Hampton, NH 03836 U.S.
NRC Washington, DC 20555
' James K. Asselstine, Commissioner
- Kenneth Carr, Commis sio ne r U.S. NRC U.S.
NRC Washington, DC 20555 Washington, DC 20555
' Thomas Roberts, Commissioner
- Frederick Bernthal, U.S.
NRC Commissioner Washington, DC 20555 U.S.
NRC Washington, DC 20555 I
r (o rd on J. ' Hump h rey, USS Pro Se