NRC Staff Response to Jf Doherty Third Petition for Leave to Intervene.* Board Should Reject Petition for Lack of Jurisdiction & Failure to Satisfy Stds for Governing late- Filed Contentions.Certificate of Svc EnclML20214S198 |
Person / Time |
---|
Site: |
Seabrook ![NextEra Energy icon.png](/w/images/9/9b/NextEra_Energy_icon.png) |
---|
Issue date: |
05/29/1987 |
---|
From: |
Sherwin Turk Atomic Safety and Licensing Board Panel |
---|
To: |
|
---|
References |
---|
CON-#287-3651 OL, NUDOCS 8706090177 |
Download: ML20214S198 (11) |
|
|
---|
Category:INTERVENTION PETITIONS
MONTHYEARML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20237C6981998-08-18018 August 1998 Sapl/Necnp Reply to Naesco Response to Proposed Contentions.* Board Should Admit Sapl/Necnp Contentions 1-4 & North Atlantic Energy Svcs Corp Arguments to Contrary. W/Certificate of Svc ML20237C6791998-08-18018 August 1998 Sapl/New England Coalition on Nuclear Pollution Reply to Staff Answer to Contentions.* Petitioners Believe Board Can & Should Give Cases Consideration W/O Filing of Addl,But Not Substantively Different Contention.W/Certificate of Svc ML20237A0501998-08-10010 August 1998 North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied ML20236X9281998-08-10010 August 1998 NRC Staff Answer to Contentions.* for Reasons Stated,All of Contentions Proposed Should Be Rejected & Proceeding Should Be Terminated.W/Certificate of Svc ML20066H2581991-02-14014 February 1991 Response of Ma Atty General & Necnp to ASLB Order of 910124.* Intervenors Believe ASLB Should Reopen Record, Permit Discovery & Hold Hearing on Beach Sheltering Issues. W/Certificate of Svc ML19332D7241989-11-21021 November 1989 Intervenors Motion for Clarification Or,In Alternative,For Reconsideration.* Clarification or Reconsideration of Scheduling Requirements Set by Commission 891121 Order Requested.Certificate of Svc Encl ML19332D5191989-11-15015 November 1989 Applicant Answer to Intervenors Motion to Admit late-filed Contention & Reopen Record Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Sys Network & Wcgy.* Motion Should Be Denied Since Results Unlikely to Change ML19325E0171989-10-20020 October 1989 Applicant Answer to Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Motion to Assert Addl Bases for Original Onsite Exercise Contention JI-Onsite Ex-1 Should Be Denied.W/Certificate of Svc ML19325E0011989-10-20020 October 1989 Applicant Response to Intervenors Motion to Amend Intervenors Motions of 890929 & 1013 to Admit Contentions on 890927 Onsite Emergency Plan Exercise.* Issue Re Admittance Committed to Board Discretion.Certificate of Svc Encl ML20248J3511989-10-13013 October 1989 Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Advises That Applicant Contentions Filed on 890929 to Admit Addl Bases Re Scope of Onsite Exercsise Should Be Admitted.W/Certificate of Svc ML20248J0601989-09-28028 September 1989 Intervenors Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Requests Hearing & to Engage in Discovery for Hearing on Contention.Supporting Documentation & Certificate of Svc Encl ML20247Q6761989-09-22022 September 1989 Intervenors Second Informational Suppl to Low Power Contentions Filed on 890721 & 0828.* Incorporates Encl Plant Startup Test Procedure 1-ST-22,Rev 2 Into Low Power Testing Contentions.W/Supporting Info & Certificate of Svc ML20246N1001989-09-0101 September 1989 Intervenors Reply to Responses of Applicant & Staff Re Intervenors Motion to Admit Contention,Or,In Alternative,To Reopen Record & Request for Hearing.* Contention Raises New Issues & Should Be Admitted.W/Certificate of Svc ML20247E0321989-07-21021 July 1989 Intervenors Motion to Admit Contention,Or in Alternative,To Reopen Record & Request for Hearing.* Requests Contentions Re Deficiencies in Training,Mgt Control,Supervision, Communication & Procedure Compliance Be Admitted ML20246P2041989-07-0505 July 1989 Joint Intervenor (Ji) Contentions on Spmc & June 1988 Graded Exercise.* ML20248F4691989-04-0303 April 1989 Seacoast Anti-Pollution League (Sapl) Trial Brief on Contention Ji 56 & Sapl Contentions EX-2,4,6,7,8,12,13 & 14.* Svc List Encl ML20206M9761988-11-23023 November 1988 NRC Staff Response to 881114 Board Order Requesting Comments on Significance of ALAB-903 for Seabrook Proposed General Exercise Contentions.* Contentions & Bases Should Be Denied. Certificate of Svc Encl ML20206M9431988-11-22022 November 1988 New England Coalition on Nuclear Pollution Comments on Significance of ALAB-903 to Seabrook Offsite Exercise Contentions.* Svc List Encl ML20206M9031988-11-22022 November 1988 Seacoast Anti-Pollution League Comments on Significance of ALAB-903 to Exercise Contentions.* Svc List Encl ML20205R7201988-11-0202 November 1988 Town of Hampton Contention on Applicant Plan to Fund Decommissioning Costs of Seabrook Station.* Supporting Documentation & Certificate of Svc Encl ML20205R5661988-11-0202 November 1988 Seacoast Anti-Pollution League Contentions on Applicant Plan in Response to NRC Order CLI-88-07.* Supporting Documentation Encl ML20205R5441988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Financial Qualifications to Operate Seabrook Nuclear Power Station.* Supporting Documentation & Certificate of Svc Encl ML20205R4971988-11-0202 November 1988 New England Coalition on Nuclear Pollution Contentions on Applicant Decommissioning Plan,Motion for Stay of Low Power Operation & Motion to Reopen Record.* Supporting Info & Svc List Encl ML20205R4821988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Decommissioning Plan for Seabrook Nuclear Power Station.* ML20205E0011988-10-24024 October 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to Commonwealth of Ma Atty General Exercise Contentions.* Certificate of Svc Encl ML20205E0271988-10-21021 October 1988 New England Coalition on Nuclear Pollution (Necnp) & Town of Hampton (Toh) Reply to Applicant & NRC Staff Responses to Contentions Toh/Necnp EX-2 & Toh/Necnp EX-3.* Svc List Encl ML20205D8051988-10-21021 October 1988 Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl ML20206C1951988-10-18018 October 1988 Seacoast Anti-Pollution League (Sapl) Reply to Applicant & Staff Responses to Sapl Contentions on June 1988 Graded Exercise.* Svc List Encl ML20204G9731988-10-13013 October 1988 NRC Staff Response to Intervenors Contentions on Graded Exercise.* Proposed General Exercise Contentions Should Be Admitted for Litigation & Proferred Contentions Should Be Denied Admission.Certificate of Svc Encl ML20154S4571988-09-28028 September 1988 Applicant Response to Intervenor Contentions on June 1988 Seabrook Exercise.* Intervenor Contentions Should Be Disposed Of.Certificate of Svc Encl ML20154P3461988-09-21021 September 1988 New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl ML20154K8741988-09-21021 September 1988 Commonwealth of Ma Atty General Exercise Contentions Submitted in Response to June 1988 Plant Initial full- Participation Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154K9331988-09-21021 September 1988 Town of Hampton & New England Coalition on Nuclear Pollution Emergency Planning Contentions on 880628-29 Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154N9061988-09-20020 September 1988 Seacoast Anti-Pollution League Contentions on Graded Exercise.* Svc List Encl ML20154D7431988-09-12012 September 1988 New England Coalition on Nuclear Pollution Petition for Review of ALAB-899.* Petition Should Be Granted on Basis That Integrity of RCS Significantly Paramount to Safe Operation of Plant.W/Certificate of Svc ML20151A6461988-07-0707 July 1988 NRC Staff Response to Town of Salisbury Amended Contentions Re Applicant Plan for Commonwealth of Ma Communities.* Applicant Untimely Amends to Contentions Should Be Rejected. Certificate of Svc Encl ML20151A6301988-07-0606 July 1988 NRC Staff Response to City of Haverhill Detailed Contentions.* City of Haverhill late-filed Contentions Should Be Rejected.Certificate of Svc Encl ML20196G7031988-06-27027 June 1988 Applicant Response to City of Haverhill Detailed Contentions.* Contentions Should Be Rejected & City Should Be Denied Admission as Party,Per 10CFR2.714.Supporting Documentation & Certificate of Svc Encl ML20196A3761988-06-22022 June 1988 New England Coalition on Nuclear Pollution (Necnp) Reply to Applicant & NRC Staff Response to Necnp Contentions on Spmc.* Certificate of Svc Encl ML20196A3991988-06-22022 June 1988 Reply of Massachussetts Atty General to Responses of NRC Staff and Applicant to Contentions 7 Through 83 Filed by Massachussetts Atty General.* Certificate of Svc Encl ML20196A5261988-06-22022 June 1988 Town of Amesbury Reply to NRC Staff & Applicant Responses to Town of Amesbury Contentions on Seabrook Plan for Massachussetts Communities.* Certificate of Svc Encl ML20196A8701988-06-20020 June 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to First Six Contentions Filed by Commonwealth of Ma Atty General.* ML20151N6271988-06-17017 June 1988 Town of Salisbury Reply to Applicant Response to Intervenor Contentions on Seabrook Plan for State of Ma Communities ML20151A8361988-06-17017 June 1988 Reply of Town of West Newbury to Responses of Applicant & NRC Staff to Intervenors Contentions Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl ML20151N6461988-06-17017 June 1988 Town of Salisbury Amended Contentions Re Applicant Plan for State of Ma Communities.Certificate of Svc Encl 1999-07-20
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20237C6981998-08-18018 August 1998 Sapl/Necnp Reply to Naesco Response to Proposed Contentions.* Board Should Admit Sapl/Necnp Contentions 1-4 & North Atlantic Energy Svcs Corp Arguments to Contrary. W/Certificate of Svc ML20237C6791998-08-18018 August 1998 Sapl/New England Coalition on Nuclear Pollution Reply to Staff Answer to Contentions.* Petitioners Believe Board Can & Should Give Cases Consideration W/O Filing of Addl,But Not Substantively Different Contention.W/Certificate of Svc ML20237A0501998-08-10010 August 1998 North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied ML20236X9281998-08-10010 August 1998 NRC Staff Answer to Contentions.* for Reasons Stated,All of Contentions Proposed Should Be Rejected & Proceeding Should Be Terminated.W/Certificate of Svc ML20066H2581991-02-14014 February 1991 Response of Ma Atty General & Necnp to ASLB Order of 910124.* Intervenors Believe ASLB Should Reopen Record, Permit Discovery & Hold Hearing on Beach Sheltering Issues. W/Certificate of Svc ML19332D7241989-11-21021 November 1989 Intervenors Motion for Clarification Or,In Alternative,For Reconsideration.* Clarification or Reconsideration of Scheduling Requirements Set by Commission 891121 Order Requested.Certificate of Svc Encl ML19332D5191989-11-15015 November 1989 Applicant Answer to Intervenors Motion to Admit late-filed Contention & Reopen Record Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Sys Network & Wcgy.* Motion Should Be Denied Since Results Unlikely to Change ML19325E0171989-10-20020 October 1989 Applicant Answer to Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Motion to Assert Addl Bases for Original Onsite Exercise Contention JI-Onsite Ex-1 Should Be Denied.W/Certificate of Svc ML19325E0011989-10-20020 October 1989 Applicant Response to Intervenors Motion to Amend Intervenors Motions of 890929 & 1013 to Admit Contentions on 890927 Onsite Emergency Plan Exercise.* Issue Re Admittance Committed to Board Discretion.Certificate of Svc Encl ML20248J3511989-10-13013 October 1989 Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Advises That Applicant Contentions Filed on 890929 to Admit Addl Bases Re Scope of Onsite Exercsise Should Be Admitted.W/Certificate of Svc ML20248J0601989-09-28028 September 1989 Intervenors Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Requests Hearing & to Engage in Discovery for Hearing on Contention.Supporting Documentation & Certificate of Svc Encl ML20247Q6761989-09-22022 September 1989 Intervenors Second Informational Suppl to Low Power Contentions Filed on 890721 & 0828.* Incorporates Encl Plant Startup Test Procedure 1-ST-22,Rev 2 Into Low Power Testing Contentions.W/Supporting Info & Certificate of Svc ML20246N1001989-09-0101 September 1989 Intervenors Reply to Responses of Applicant & Staff Re Intervenors Motion to Admit Contention,Or,In Alternative,To Reopen Record & Request for Hearing.* Contention Raises New Issues & Should Be Admitted.W/Certificate of Svc ML20247E0321989-07-21021 July 1989 Intervenors Motion to Admit Contention,Or in Alternative,To Reopen Record & Request for Hearing.* Requests Contentions Re Deficiencies in Training,Mgt Control,Supervision, Communication & Procedure Compliance Be Admitted ML20246P2041989-07-0505 July 1989 Joint Intervenor (Ji) Contentions on Spmc & June 1988 Graded Exercise.* ML20248F4691989-04-0303 April 1989 Seacoast Anti-Pollution League (Sapl) Trial Brief on Contention Ji 56 & Sapl Contentions EX-2,4,6,7,8,12,13 & 14.* Svc List Encl ML20206M9761988-11-23023 November 1988 NRC Staff Response to 881114 Board Order Requesting Comments on Significance of ALAB-903 for Seabrook Proposed General Exercise Contentions.* Contentions & Bases Should Be Denied. Certificate of Svc Encl ML20206M9431988-11-22022 November 1988 New England Coalition on Nuclear Pollution Comments on Significance of ALAB-903 to Seabrook Offsite Exercise Contentions.* Svc List Encl ML20206M9031988-11-22022 November 1988 Seacoast Anti-Pollution League Comments on Significance of ALAB-903 to Exercise Contentions.* Svc List Encl ML20205R7201988-11-0202 November 1988 Town of Hampton Contention on Applicant Plan to Fund Decommissioning Costs of Seabrook Station.* Supporting Documentation & Certificate of Svc Encl ML20205R5661988-11-0202 November 1988 Seacoast Anti-Pollution League Contentions on Applicant Plan in Response to NRC Order CLI-88-07.* Supporting Documentation Encl ML20205R5441988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Financial Qualifications to Operate Seabrook Nuclear Power Station.* Supporting Documentation & Certificate of Svc Encl ML20205R4971988-11-0202 November 1988 New England Coalition on Nuclear Pollution Contentions on Applicant Decommissioning Plan,Motion for Stay of Low Power Operation & Motion to Reopen Record.* Supporting Info & Svc List Encl ML20205R4821988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Decommissioning Plan for Seabrook Nuclear Power Station.* ML20205E0011988-10-24024 October 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to Commonwealth of Ma Atty General Exercise Contentions.* Certificate of Svc Encl ML20205E0271988-10-21021 October 1988 New England Coalition on Nuclear Pollution (Necnp) & Town of Hampton (Toh) Reply to Applicant & NRC Staff Responses to Contentions Toh/Necnp EX-2 & Toh/Necnp EX-3.* Svc List Encl ML20205D8051988-10-21021 October 1988 Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl ML20206C1951988-10-18018 October 1988 Seacoast Anti-Pollution League (Sapl) Reply to Applicant & Staff Responses to Sapl Contentions on June 1988 Graded Exercise.* Svc List Encl ML20204G9731988-10-13013 October 1988 NRC Staff Response to Intervenors Contentions on Graded Exercise.* Proposed General Exercise Contentions Should Be Admitted for Litigation & Proferred Contentions Should Be Denied Admission.Certificate of Svc Encl ML20154S4571988-09-28028 September 1988 Applicant Response to Intervenor Contentions on June 1988 Seabrook Exercise.* Intervenor Contentions Should Be Disposed Of.Certificate of Svc Encl ML20154P3461988-09-21021 September 1988 New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl ML20154K8741988-09-21021 September 1988 Commonwealth of Ma Atty General Exercise Contentions Submitted in Response to June 1988 Plant Initial full- Participation Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154K9331988-09-21021 September 1988 Town of Hampton & New England Coalition on Nuclear Pollution Emergency Planning Contentions on 880628-29 Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154N9061988-09-20020 September 1988 Seacoast Anti-Pollution League Contentions on Graded Exercise.* Svc List Encl ML20154D7431988-09-12012 September 1988 New England Coalition on Nuclear Pollution Petition for Review of ALAB-899.* Petition Should Be Granted on Basis That Integrity of RCS Significantly Paramount to Safe Operation of Plant.W/Certificate of Svc ML20151A6461988-07-0707 July 1988 NRC Staff Response to Town of Salisbury Amended Contentions Re Applicant Plan for Commonwealth of Ma Communities.* Applicant Untimely Amends to Contentions Should Be Rejected. Certificate of Svc Encl ML20151A6301988-07-0606 July 1988 NRC Staff Response to City of Haverhill Detailed Contentions.* City of Haverhill late-filed Contentions Should Be Rejected.Certificate of Svc Encl ML20196G7031988-06-27027 June 1988 Applicant Response to City of Haverhill Detailed Contentions.* Contentions Should Be Rejected & City Should Be Denied Admission as Party,Per 10CFR2.714.Supporting Documentation & Certificate of Svc Encl ML20196A3761988-06-22022 June 1988 New England Coalition on Nuclear Pollution (Necnp) Reply to Applicant & NRC Staff Response to Necnp Contentions on Spmc.* Certificate of Svc Encl ML20196A3991988-06-22022 June 1988 Reply of Massachussetts Atty General to Responses of NRC Staff and Applicant to Contentions 7 Through 83 Filed by Massachussetts Atty General.* Certificate of Svc Encl ML20196A5261988-06-22022 June 1988 Town of Amesbury Reply to NRC Staff & Applicant Responses to Town of Amesbury Contentions on Seabrook Plan for Massachussetts Communities.* Certificate of Svc Encl ML20196A8701988-06-20020 June 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to First Six Contentions Filed by Commonwealth of Ma Atty General.* ML20151N6271988-06-17017 June 1988 Town of Salisbury Reply to Applicant Response to Intervenor Contentions on Seabrook Plan for State of Ma Communities ML20151A8361988-06-17017 June 1988 Reply of Town of West Newbury to Responses of Applicant & NRC Staff to Intervenors Contentions Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl ML20151N6461988-06-17017 June 1988 Town of Salisbury Amended Contentions Re Applicant Plan for State of Ma Communities.Certificate of Svc Encl 1999-07-20
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] |
Text
(;
.3/4/
5/29/87 cetEETE0 e' UWC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '87 Jm -4 P4 '4g BEFORE THE ATOMIC SAFETY AND LICENSING BOARDf0Cw;w F
ibI "#m In the Matter of )
) Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF ) 50-444 OL NEW HAMPSHIRE, et al.
)
) Offsite Emergency Planning (Seabrook Station, Units 1 and 2) )
NRC STAFF'S RESDONSE TO JOHN F. DOHERTY'S THIRD PETITION FOR LEAVE TO INTERVENE INTRODUCTION On May 11, 1987, John F. Doherty filed his " Third Petition for Leave to Intervene" (" Petition") pursuant to 10 C.F.R. I 2.714(a). In his Petition, Mr. Doherty presents a late-filed contention asserting that an operating license for Seabrook should be withheld, on the grounds that the Applicants are "unlikely" to operate the facility in compliance with NRC regulations (Petition at 2). In support of this contention, Mr.
Doherty asserts that the Applicants attempted to influence public opinion through media messages sponsored by a non-profit organization which l
they had created and funded, but failed to disclose that relationship to the public; such disclosure allegedly would have required the allocation of l
" equal time" for opposing views to be presented, which might have I induced the media to refuse to carry the Applicants' messages (Id.,
- at 3). In Mr. Doherty's view, the Applicants' " concealment" of this l
l relationship demonstrates a lack of trustworthiness and a willingness to miwal viviations of NRC regulations upon operation of the facility (Id.).
8706090177 870529 PDR G
ADOCK 05000443 PDR
$b i
l For the reasons more fully set forth below, the Licensing Board should reject the Petition for lack of jurisdiction. Further, even if the f
Board had jurisdiction to consider the Petition, it should be rejected for failing to satisfy the standards governing late-filed contentions and reopening the record. II DISCUSSION A. The Board Lacks Jurisdiction to Consider the Petition.
A Partial Initial DeciElon (PID) addressing all issues other than offsite emergency planning was issued by the "on-site" Licensing Board on March 25,1987,El and appeals of that decision are currently pending before the Appeal Board. The sole issues remaining before this Board relate to offsite emergency planning; all other matters are presently before the Appeal Board, in connection with its review of the PID.
Accordingly, the Licensing Board lacks jurisdiction to consider the instant Petition. See generally, Philadelphia Electric Co. (Limerick Generating Station , Units 1 and 2), ALAB-726, 17 NRC 755, 757-58 (1983);
Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit No.1),
ALAB-699,16 NRC 1324,1326-27 (1982); Virginia Electric and Power Co.
-1/ The Petition must also demonstrate standing and interest to intervene, pursuant to 10 C.F.R. I 2.714. However, in light of the discussion and conclusions set forth below with respect to jurisdiction and the standards governing late-filed contentions and reopening the record, it is unnecessary to address these other aspects of the Petition.
-2/
Cee Public Service Co. of New Hampshire (Scabrook Station, Units 1 and 2), LD P-87-10 , 25 NRC (March 25, 1987), slip op. at 4.
f
I.
(North Anna Nuclear Power Station, Units 1 and 2), A LA B-551, 9 NRC 704, 708-09 (1979).
B. The Petition Fails to Satisfy the Late Filing Criteria.
A motion to admit a late-filed contention must satisfy the require-ments of 10 CFR 5 2.714(a)(1). That regulation requires a balancing of the following in determining whether to grant an untimely filing:
(i) Good cause, if any, for failure to file on time; (ii) The availability of other means whereby the petitioner's interest will be protected; (iii) The extent to which the petitioner's participation may reasonably be expected to assist in developing a sound record; (iv) The extent to which the petitioner's interest will be represented by existing parties; (v) The extent to which the petitioner's participation will broaden the issues or delay the
. proceeding.
A balancing of these factors demonstrates that the Petition fails to satisfy the late filing criteria.
- 1. Good Cause for Failure to File On Time. .
The Petition does not indicate when the media messages in question were broadcast or when the Petitioner first learned of Applicants' involvement in financing the Coalition for Reliable Energy ("CFRE"), the non-profit organization which sponsored the media messages. However, the Petition concedes that CFRE revealed it had received $2.8 million from i
- the Seabrook owners "at the end of January,1987" (Petition at 3); and it notes "there had been allegations Applicant had participated and financed CFRE from the start in 1986" (Id. , at 4).
'~
F o .
Under these circumstances, Mr. Doherty appears to have been on notice of the Applicants' involvement in funding CFRE at least since January 1987 -- and quite possibly earlier, when the " allegations" of this involvement came to his attention sometime in 1986. The fact that the Massachusetts Attorney General may not have received equal access time until April 1987 (Id., at 3-4), is immaterial; rather, the timeliness of the Petition must be assessed in light of when the Petitioner, using due diligence, could have learned of Applicants' relationship to CFRE.
Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2),
ALAB-828, 23 NRC 13,18, 21 (1986); Duke Power Co. (Catawba Nuclear Station , Units 1 and 2), ALAB-813, 22 NRC 59, 84-85 (1985);
Commonwealth Edison Co. (Braidwood Nuclear Power Station , Units 1 and 2), LBP-85-11, 21 NRC 609, 628-29 (1985), rev'd and remanded on other grounds, CLI-86-8, 23 NP.C 241 (1986). Accordingly, Petitioner has failed to demonstrate good cause for failing to file the Petition sooner.
- 2. Other Means to Protect Petitioner's Interest.
The Petition does not address this issue; however, the Staff does not contend that other means are available to protect Petitioner's interest.
Accordingly, this factor may be found to weigh in favor of the Petition.
- 3. Contribution to the Development of a Sound Record.
The Petition asserts that Mr. Doherty "has had extensive experience in Commission licensing proceedings and is a recent law school graduate" (Petition at 5). However, the Petition does not identify any witnesses whom the Petitioner might call to testify, and fails to summarize the testimony which they may be expected to present; the Petition thus fails
s to provide the specification required under this criterion. Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), ALAB-743, 18
- NRC 387, 399-400 (1983); Mississippi Power a Light Co. (Grand Gulf Nuclear Station, Units 1 and 2), ALAB-704,16 NRC 1725 (1982). In this regard, the Petitioner must identify his prospective witnesses and demonstrate affirmatively that they, not the Petitioner, are likely to assist in the development of a sound record. Shoreham, supra, 18 NRC at 400-01; Washington Public Power Supply System (WPPSS Nuclear Project No. 3), ALAB-747,18 NRC 1167,1177-78 (1983). Further, the movant's legal skills and familiarity with NRC proceedings are immaterial in connection with the evaluation of this factor. Commonwealth Edison Co.
(Braidwood Nuclear Power Station , Units 1 and 2), CLI-86-8, 23 NRC 241, 246-47 (1986); WPPSS, supra; Houston Lighting and Power Co.
(Allens Creek Nuclear Generating Station, Unit 1), ALAB-671, 15 NRC
. 508, 513 n.14 (1982). Accordingly, this factor weighs against the Petition.
- 4. Representation of Petitioner's Interest By Other Parties.
The Staff concedes that other parties may not be expected to represent Mr. Doherty's interests. Accordingly, this factor weighs in favor of the Petition.
- 5. Broadening and Delay of the Proceeding.
- The' Petition concedes that admission of this late-filed contention j "would broaden and lengthen the proceedings" (Petition, at 5). It should be noted that contention raises an issue that has not been litigated
! previously in this proceeding; the record has been closed since October
! 1986; and a PID has already been issued. Further, a low power license
, r- - , ,-,-,,--, ,.w.,.--,n -,.,,,,,y a..m.n, - - - . . - - - .,n. , . , - - - - - , ~ . . - - . - . - , . . , , - -
e has already been authorized and could be issued once the Commission completes its review of Applicants' motion to vacate CLI-87-02 as moot.
Accordingly, this factor weighs against the Petition. ; '
In sum, factors 1, 3 and 5 weigh against the Petition, while the less important factors, factors 2 and 4, weigh in its favor. This balancing demonstrates that the Petition fails to satisfy the standards governing the admission of late-filed contentions.
C. The Petition Fails to Satisfy the Standards for Reopening.
10 C.F.R. 5 2.734, which codifies prior NRC practice, - requires that a motion to reopen the record be denied if it is untimely, if it fails to address a significant safety or environmental issue, or if it fails to demonstrate that a materfally different result would be or would have been likely had the newly proffered evidence been considered initially.
Further, the motion is required to be accompanied by an affidavit which sets forth the factual and/or technical bases of the proponent's claim that these three criteria have been satisfied. The Petition fails to satisfy these requirements. II
- 1. The Petition Is Untimely.
For the reasons discussed above with respect to " good cause" under 10 C.F.R. 5 2.714(a), the Petition was not filed in a timely fashion.
-3/ Sec Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2), CLI-86-18, 24 NRC 501, 500 n.2 (1986); 51 Fed. Reg.
19535, 19539 (1986).
t
-4/ It should be noted that the proponent of reopening the record bears g, I;ansas Gas and Electric Co. (Wolf a heavy burden. See, e Creek Station , Unit No. 1), ALAB-462, 7 NRC 320, 338 (1978).
an,-,--- - - - , , , , -,c-,- -
I
- 2. Significance of the Issue.
The Petition asserts that the Applicants' trustworthiness to operate a nulcear plant in compliance with NRC regulations is called into; question by their failure to disclose their relationship to CFRE, the non-profit organization which sponsored the pro-Seabrook media messages. This assertion fails to present a significant safety or environmental issue.
While contentions concerning an applicant's trustworthiness to operate a nuclear plant may be admitted for litigation in an operating license proceeding, no such issue is presented here. Even if the facts alleged in the Petition as to Applicants' actions are accepted as true, those actions are simply too insignificant and remote to have any bearing on the determination as to whether the Applicants will operate a nuclear plant in compliance with NRC regulations. See generally, Houston Lighting & Power Co. (South Texas Project, Units 1 and 2), ALAB-799, 21 NRC 360, 3~1 (1985).
- 3. Likelihood of Causinar A Materially Different Result.
As set forth above, the Petition fails to present a significant safety or environmental issue. Accordingly, the Petitioner has failed to l
demonstrate that a materially different result would have been reached by
! the on-site Licensing Board if the Petition had been filed before the close j of the record. See, eg, Public Service Co. of New Hampshire (Seabrook Station, Unit 1), LBP-87-3, 25 NRC (February 6, 1987).
{
In sum, the Petition is untimely, it fails to raise a significant safety or environmental issue, and fails to demonstrate that a materially different result vrould have been reached if the Petition had been filed prior to the close of the record. In addition , the Petition was filed without the
r e
supporting affidavit required by 10 C.F.R. I 2.734(b). Accordingly, the Petition fails to satisfy the standards governing the reopening of the record. .
CONCLUSION For the reasons set forth above, the Licensing Board should reject the Petition for lack of jurisdiction. Further, even if the Board had jurisdiction to consider the Petition, it should be denied for failing to satisfy the standards governing late-filed contentions and the standards for reopening the record.
Respectfully submitted,
, & $u S Y Sherwin E. Turk Senior Supervisory Trial Attorney Dated at Bethesda, Biaryland tilis 29th day of Blay,1987 l
[
F"-
00(.hEiED UmRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '87 Jlli -4 P4 :48 BEFORE THE ATOMIC SAFETY AND LICENSING BOAg7,h j @7ld BH MD In the Matter of )
) Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF ) 50-444 OL NEW HAMPSHIRE, g al. ) Off-site Emergency Planning
)
(Seabrook Station, Unita 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of. "NRC STAFF'S RESPONSE TO JOllN F. DOHERTY'S THIRD PETITION FOR LEAVE TO INTERVENE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system this 29th day of May,1987.
Helen Hoyt, Esq. , Chairman
- Gustave A. Linenberger, Jr.*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board
.U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor Washington, DC 20555 Boston, MA 02108 Beverly Hollingworth Richard A. Hampe, Esq.
209 Winnacunnet Road New Hampshire Civil Defense Agency Hampton, NH 03842 107 Pleasant Street Concord, Nil 03301 Sandra Gavutis, Chairman Calvin A. Canney, City Manager Board of Selectmen City Hall RFD 1 Box 1154 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
y Stephen E. Merrill Paul McEachern, Esq.
Attorney General Matthew T. Brock, Esq.**
George Dana Bisbee Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue Office of the Attorney General P.O. Box 360 .
25 Capitol Street Portsmouth, NH 03801 '
Concord, NH 03301 Roberta C. Pevear Angie Machiros Chairman State Representative Board of Selectmen Town of Hampton Falls 25 High Road Drinkwater Road Newbury, MA 09150 Hampton Falls, NH 03844 Allen Lampert Mr. Robert J. Harrison Civil Defense Director President and Chief Executive Officer Town of Brentwood Public Service Co. of New Hampshire
. 20 Franklin Street P.O. Box 330 Exeter, NH 03833 Manchester, NH 03105 Charles P. Graham, Esq. Robert A. Backus, Esq.
McKay, Murphy and Graham Backus, Meyer & Solomon 100 Main Street 116 Lowell Street Amesbury, MA 01913 Manchester, NH 03106 Diane Curran, Esq. Philip Ahren, Esq.
Harmon & Weiss Assistant Attorney General 2001 S Street, NW Office of the Attorney General i Suite 430 State House Station #6 Washington, DC 20009 Augusta, ME 04333 Edward A. Thomas Thomas G. Dignan Jr. , Esq.
Federal Emergency Management Agency Ropes & Gray 442 J.W. McCormack (POCH) 225 Franklin Street Boston, MA 02109 Boston, MA 02110 l H.J. Flynn, Esq. William Armstrong i Assistant General Counsel Civil Defense Director Federal Emergency Management Agency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel
- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
! Washington, DC 20555 Washington, DC 20555
E ,
i
}
Jane Doughty Docketing and Service Section* ,
Seacoast Anti-Pollution League Office of the Secretary !
5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, DC 20555 Maynard L. Young, Chairman William S. Lord Board of Selectmen Board of Selectmen 10 Central Road Town Hall - Friend Street South Hampton, NH 03287 Amesbury, MA 01913 Michael Santosuosso, Chairman Peter J. Matthews, Mayor Board of Selectmen City Hall South Hampton, NH 03287 Newburyport, MN 09150 Mr. Robert Carrigg, Chairman Judith H. Mizner, Esq.
Board of Selectmen Silverglate, Gertner, Baker Town Office Fine and Good Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Boston MA 02110 R. K. Gad III, Esq. Mrs. Anne E. Goodman, Chairman Ropes a Gray Board of Selectmen 225 Franklin Street 13-15 Newmarket Road Boston, MN 02110 Durham, NH 03824 Gary W. Holmes, Esq. Honorable Gordon J. Humphrey Holmes & Ellis United States Senate 47 Winnacunnet Road 531 Hart Senate Office Building Hampton, NH 03842 Washington, DC 20510 Sherwin E. Turk Senior Supervisory Trial Attorney l
l I
I i
^
. - - _ . - - . _ .