ML20214W615
| ML20214W615 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/09/1987 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20214W617 | List: |
| References | |
| CON-#287-3735 OL, NUDOCS 8706160105 | |
| Download: ML20214W615 (2) | |
Text
3735
- .. n.c UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-k, IU BEFORE THE COMMISSION 87 J!N 11 A10:36 In the Matter of Docket No. 50-443-OL g yy g PUBLIC SERVICE COMPANY
)
((g OF NEW HAMPSHIRE, et al.
)
June 9,1987 dma,4
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(Seabrook Station, Unit 1)
)
JOINT MOTION FOR LEAVE TO FILE A SUPPLEMENT TO MOTIONS FOR STAY OF THE PARTIAL INITIAL DECISION FILED BY SEACOAST ANTI-POLLUTION LEAGUE, ATTORNEY GENERAL JAMES M.
SHANNON AND TOWN OF HAMPTON NOW COME the Seacoast Anti-Pollution League, Attorney James M. Shannon and the Town of Hampton and move for leavo to file a supplement to " Seacoast Anti-Pollution League 's Motion For Continuation of the Stay of the Partial Initial Decision Pending the Outcome of Appeals Thereof" filed with this Commission on May 14,1987, " Attorney General James M. Shannon's Application for a Stay of Licensing Board Order Authorizing Issuance of Operating License to Conduct Low Power Operation" filed May 13,1987 and
" Town of Hampton Motion for a Stay of Licensing Board Order Authorizing Issuance of License To Conduct Low Power Operation" filed with this Commission on May 22, 1987.
As grounds for this joint request the Attorney General, Town of Hampton and SAPL point to the receipt of additional information which is highly pertinent to the Commission 's deliberations, i.e.
Mh Dse
O, *
- 60 Appendix A to the " Response of the Federal Emergency Management Agency to Massachusetts Attorney General James M. Shannon's Off-Site Emergency Preparedness Interrogatories and Request for Production of Documents to FEMA (Set No. 2)" entitled " Current FEMA Position on Admitted Contentions on New Hampshire Plans for Seabrook".
This document points to serious deficiencies in the plans submitted for the New Hampshire portion of the Seabrook Station EPZ such that FEMA is not able to find that the plans meet FEMA's regulatory standard at 44 CFR 350.5(b) that plans
" adequately protect the public health and safety by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiological emergency."
Respectfully submitted Seacoast Anti-Pollution League By its Attorney BACKUS, MEYER & SOLOMON
/
DATED: JUNE 9,1987 Ro6ert A. Backus 116 Lowell Street Manchester, NH 03105 603-668-7272 1
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