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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] Category:PLEADINGS
MONTHYEARML20210S5641999-08-13013 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 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 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 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 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 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 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 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 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 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 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 ML20236W0931998-07-30030 July 1998 Reply to Staff & Naesco Objections to Joinder of Necnp & to Naesco Objection to Standing.* Advises That Jointer Issue Involves Only Question of How Pleadings May Be Captioned. W/Certificate of Svc ML20236U4221998-07-27027 July 1998 North Atlantic Energy Svc Corp Supplemental Answer Standing Issues.* Request for Hearing & Petition to Intervene,As Applied to Sapl & New England Coalition on Nuclear Pollution,Should Be Denied.W/Certificate of Svc ML20236T5201998-07-27027 July 1998 NRC Staff Response to 980709 Submittal by Seacoast Anti- Pollution League & New England Coalition on Nuclear Pollution (Necnp).* Board Should Deny Intervention by Necnp. Staff Does Not Contest Sapl Standing.W/Certificate of Svc ML20236J1111998-07-0202 July 1998 North Atlantic Energy Svc Corp Answer to Supplemental Petition for Hearing.* Util Will Respond to Any Further Petitions on Schedule Directed by Licensing Board Memorandum & Order of 980618.W/Certificate of Svc ML20249B9151998-06-24024 June 1998 NRC Staff Answer to Seacoast Anti-Pollution League (Sapl) 980605 Request for Hearing & to New England Coalition on Nuclear Pollution 980618 Request for Intervention.* Board Should Not Grant Sapl 980605 Request.W/Certificate of Svc ML20249B7631998-06-18018 June 1998 Supplemental & Amended Petition for Institution of Proceeding & for Intervention Pursuant to 10CFR2.714 on Behalf of Seacoast Anti-Pollution League & New England Coalition on Nuclear Power.* ML20249A9501998-06-12012 June 1998 Supplemental Petition of Great Bay Power Corp for Determination of Reasonable Assurance of Decommissioning Funding ML20199K3861998-01-29029 January 1998 Petition for Determination That Great Bay Power Corp'S Acceleration of Decommissioning Trust Fund Payments Would Provide Reasonable Asurance of Decommissioning Funding Or,In Alternative,Would Merit Permanent Exemption ML20217P7781997-12-18018 December 1997 Petition to Suspend Operating License Until Root Cause Analysis of Leaks in Piping in Train B of RHR Sys Conducted, Per 10CFR2.206 ML20140B9601997-06-0404 June 1997 Suppl to Great Bay Power Corp Petition for Partial Reconsideration of Exemption Order to Submit Requested Cost Data & to Request,In Alternate,Further Exemption ML20135A1051997-02-21021 February 1997 Petition of Great Bay Power Corp for Partial Reconsideration of Exemption Order.* Seeks Reconsideration of Staff'S Preliminary Finding That Great Bay Is Not Electric Utility as Defined by NRC in 10CFR50.2 ML20094N4021992-03-27027 March 1992 App to Appeal of Ofc of Consumer Advocate (Nuclear Decommissioning Finance Committee) Appeal by Petition Per Rsa 541 & Rule 10 ML20076D1281991-07-17017 July 1991 Licensee Motion to Dismiss Appeal.* Appeal Should Be Dismissed Based on Listed Reasons.W/Certificate of Svc ML20073E1301991-04-22022 April 1991 Opposition of Ma Atty General & New England Coalition on Nuclear Pollution to Licensee Motion for Summary Disposition.* Board Should Reopen Record,Permit Discovery & Hold Hearing on Beach Sheltering Issues ML20070V3311991-03-29029 March 1991 Licensee Motion for Summary Disposition of Record Clarification Directive in ALAB-939.* Licensee Request That Motion Be Moved on Grounds That Issues Herein Identified Became Moot & Thus Resolved.W/Certificate of Svc ML20070V4061991-03-25025 March 1991 Massachusetts Atty General Response to Appeal Board 910311 Order.* License Should Be Vacated Until There Is Evidence of Adequate Protective Measure for Special Needs Population. W/Certificate of Svc ML20076N0831991-03-21021 March 1991 Massachusetts Atty General Response to Appeal Board 910308 Order.* Opposes Licensing Board Issuance of Full Power OL Based on Reliance of Adequacy of Plan.W/Certificate of Svc ML20076N1861991-03-19019 March 1991 Intervenors Reply to NRC Staff & Licensee Responses to 910222 Appeal Board Order.* NRC & Licensee Should File Appropriate Motions & Supply Requisite Evidentiary Basis That Will Allow Board to Make Decision.W/Certificate of Svc ML20070M5151991-03-18018 March 1991 Licensee Response to Appeal Board 910308 Order.* Listed Issues Currently Being Appealed Should Be Dismissed as Moot. W/Certificate of Svc ML20076N0671991-03-15015 March 1991 Licensee Response to Appeal Board 910311 Order.* Controversy Re Special Needs Survey Resolved.Next Survey Will Be Designed by Person Selected by State of Ma & Licensee Will Pay Costs.W/Certificate of Svc ML20070M3781991-03-11011 March 1991 Licensee Response to 910222 Appeal Board Order.* Response Opposing Suspending or Otherwise Affecting OL for Plant Re Offsite Emergency Plan That Has Been Twice Exercised W/No Weakness Identified.W/Certificate of Svc & Svc List ML20070M2101991-03-11011 March 1991 Reply to Appeal Board 910222 Order.* Response Opposes ALAB-918 Issues Re Onsite Exercise Contention.W/Certificate of Svc ML20029B6061991-02-28028 February 1991 Response of Ma Atty General to Appeal Board 910222 Order.* Questionable Whether Eight Issues Resolved.To Dismiss Issues Would Be Wrong on Procedural Grounds & Moot on Substantive Grounds.W/Certificate of Svc ML20070E7741991-02-25025 February 1991 Opposition to Licensee Motion to Dismiss Appeal of LPB-89-38.* Believes Board Should Not Dismiss Intervenors Appeal Because There Was No Hearing on Rejected Contentions. Board Should Deny Licensee Motion.W/Certificate of Svc ML20066H0831991-02-12012 February 1991 Licensee Motion to Dismiss Appeal of LBP-89-38.* Appeal Should Be Dismissed Either as Moot or on Grounds That as Matter of Law,Board Correct in Denying Hearing W/Respect to Contentions at Issue.W/Certificate of Svc ML20066H0021991-02-0808 February 1991 Licensee Response to Appeal Board Order of 910204.* W/Certificate of Svc ML20067C5081991-02-0101 February 1991 Ma Atty General Response to Appeal Board Dtd 910122.* Identifies Two Issues That Potentially May Be Resolved. State Will Continue to Investigate Facts Re post-hearing Events That May Effect Pending Issues.W/Certificate of Svc ML20029A0451991-01-28028 January 1991 Licensee Suggestion for Certified Question.* Draft Certified Question for Appeal Board Encl.* W/Certificate of Svc ML20029A0431991-01-28028 January 1991 Licensee Response to 910124 Memorandum & Order.* Common Ref Document Derived from Copying Respective Portions of Emergency Response Plan & Associated Documents Provided.W/ Certificate of Svc ML20070U4811991-01-24024 January 1991 Motion Requesting Limited Oral Argument Before Commission of City of Holyoke Gas & Electric Dept New Hampshire Electric Cooperative Mact Towns ML20029A0091991-01-24024 January 1991 Response to Appeal Board 910111 Order.* Atty General Will Continue Ad Intervenor in Facility Licensing Proceeding. Changes to Emergency Planning for Facility Forthcoming. W/Certificate of Svc ML20029A0121991-01-24024 January 1991 Motion for Substitution of Party.* Atty General s Harshbarger Moves That Secretary of NRC Enter Order Substituting Him in Place Jm Shannon as Intervenor to Proceeding.W/Certificate of Svc 1999-08-03
[Table view] |
Text
. Y {
rv 'nr}g.g a ..
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l Dated : July 2,1987 vot q 7 g.
wg UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '87 JUL -6 P4 :01 1
before the pr )
ATOMIC SAFETY AND LICENSING BOARD !E In the Matter of )
) Docket No. 50-433-CL
) )
l FUBLIC SEFVICE CCMPANY OF ) Of f-site Er.ierg ency i HEW !!AFF EEIPE, et al ) Planning Isuses l
) l (SeabIcok Station, t~r;i t 1) )
SEACCAST ANTI-PCLLUTION LFAGUE'S RESPONSE TO APPLICANTS'
!<0M R. LOF, spttibFy_pMpsJ y.Ipp_ pF_JF.PI _ f DUMLTICF %_23 Pursusnt to 10 CFR S2.749, on the basis of the f acts set l 1
forth in the Affidavit of Ann Hutchinson and the Affidavit of Donald J. Ziegler filed heretofore in this proceeding 1/ and for the reasons stated below, SAPL hereby moves the Board to deny Applicants' Motion for Summary Disposition of SAPL Contention No.
25.
BEbSQES FOR DENYING APPLICANTS' MOTION SAPL Contention No. 25 reads:
The rew Han:pshire State end J ocal rediologicc3 er. er g ency respcree plans dc not reasonably assure that the public beeltt End safety wi31 cdequately be protected beceuse the previsf ors for protecting those persons whose mobility may be inpaired due to such f actors as institutional or other confinement are patently lacking. Therefore, the plans do not meet requirements of 10 CFR S 50.47 (a) (1) , S 50. 47 (b) ( 8) and NUREG-06 54 II .J .10.d .
1/ See " Seacoast Anti-Pollution League 's Response to Applicants '
Motion for Summary Disposition of SAFL Contention No. 25" filed l on April 15, 1987.
6707000232 870702
{DR ADOCK 05000443PDR h
J
. v Contentions are not limited to the specific exenples cited in their staterents of basis. Applicente have not steted that the availability of host care fecilities with sufficient capacity for e)) specit] f tciJ it ies within the EPC Die arranged for ard supported t 1 letters of agreenent. Eost fccility agreerents do not oppear in the NERERP for Eeptworth Douglass Hospital, York Eospital cr Ftrkland Medical Center, the host facilities for Portsmouth Eospital. Further, the Hampstead Hospital can only accept 25 Class I patients while Exeter Hospital has 40-50 such patients. FEMA has stated that it does not yet have assurance, based on the available letters of agreement, that there are adequate provisions for protecting institutionalized per- .
sons. 2/
The NPC 's regulations do require that letters of agreement be prcvided tc guarantee tie tvti3rbi]ity of recepticn certers. The feet tl t:t t!e d(sigp6ted reception centers are "public buildings" does not assure thet they are Evri3eb3e for use in the esent of e rediclecical energency. If they have indeed been assured to be availtble, it should not be difficu3t fot il:e state to cttain J etter s cf agreervent . The Pl.C c cn n en t c i ted b1 ti e Applic t r tt ir tlieir I'otico Cces not i.ddress receptict centels.
IFe C 'Erien Anbulance Conpany has sert e letter to SAPL steting categorically that it will not be participating in a Itdic1cgical emergency response effort (See attached). SAPL has I not yet been abic to cecure an affidcvit from O'nrien or other ambulance companies. The Hutchinson Af fidavit f rom Berry 2/ See the June 4,1987 " Response of the Federal Emergency Management Agency to Massachusetts Attorney General James M.
m___________ _ _ _ _ _ _ )
. 9 I l
J Transportation, however, establishes that the letters of agreement appearing in the NUREEP by no means assure that the en.ergency j r esponse vel icles. will actue))y be provided because drivers in i
ri t.nl irstirces ui]3 refore to drive. Tlere are no letters of og r e c n cr.t tc ensure that erwrgency nedical support perscnnel intend tc participate in e rodio]cgicel ernergency respcrse.Further the Fffidtvit of ronald J. Ziegler describes the probler of ro]e conf]ict. ruring the Tl'Ic e Mile IsJ ord r.uc3 ear eccidert, physicians , rurses, technicians end others required to staff medical f acilities either delayed their responses or 6id not perforra their du ties.
The Applicants now state that "The next revision cf the NHRERP will include a revision that, at the Site Area Energency classification, authorities should determine which patients, who, by virtue of age or medical condition, will require extraordinary assistance in evacuation." There is no showing that such provisions exist. SAPL reserves its right to litigate the adequacy of this revision in the NERERP.
There cre ir.Euf ficient nun.ber of Sheriff 's deputies to assure t bc t n ops w!11 be provided et the local staging trets tc: drivers of emergenc; vebic]es gcirt to institutions tro irdividus] bones.
Crce assin, STFL wishes to preserve its right on the record to Eppeal tre issue of the edequecy of the NECCA Specici Eeeds Survey cro the accurocy of the nun.bers of people requiring specia]
tr or er ori s t icri osnisterce derived theref rom. I 2/ continued : Shsonon 's Of f-site Emergency Preparedness Interrogetcries and Eequest for Production of Documents to FEMA (Set Fc. 2) ", Appendix A at p. 73
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . - - _ _ _ _ _ _ - - - - - - . J
o 5 QZbMNE__ISELIES OF MATERIAL FACT IN DISPUTE (SAPL 25)
- 1. The Hampstead Hospital can accept 25 Class I patients.
The Applicants ' " Statement of Faterial Facts As To Which There Is No Dispute" shows ct #4 thet there are 40-50 Class I patients at Exeter Hospitel that would need to be provided for. Therefore, Ecrpstead Ecspital does not have sufficient capacity for Exeter Eospita] 's Class I patients. The letters of agreement for l
Catholic Medical Center and Concord Hospital only state the l
numbers of Class II and Class III patients they are willing to accept. Up to 25 Exeter Hospital Class I patients may not be provided f or. Further, no host f acility agreements appear in the NHRERP f or the f acilities that are to accept Portsacuth I
i I
Hospital patients. The availability of host facilities with sufficient capacity for all special facilities within the EPZ has a not been de:onstrated.
- 2. There is no showing thet there ere provisiers for patients wrc , bl vir tue of ege or niedical conditice, wi 3 require extz s crdir e:2 assistance.
- 3. Letters of cgreement with reception centers hste not been provided in the plans. There is therefore no resscrable cscurance that t hes e f acilities will be nade available. The RAC comnent cited by the Applicants does not eddress reception centers.
- 4. The letters of argreement with the ambulance companies do not assure that drivers and staff for the ambulances will be available.
- 5. There are insuf ficient numbers of sherif f 's deputies at t a
. N the local staging areas to assure that maps to institutions and ]
I written directions to individual homes will be provided to l l
emergency vehicle drivers. )
l
- 6. The NHCDA Special Needs Survey has underestitcated the )
l number of persons outside of institutions who require special transportation assistance.
- 7. The p1&ns do not account for the effect of role conflict i
cr flict.e personnel counted upon to cenint the mobility irpaired j j
during c tedio3cgice) emergency. ]
F.espectfu)) y setn j tted ,
Seccocst Fn ti-Fo13 0 tion *.e s.gue
! By its Attorney l BACKUS, DLTER & SOL (MCr d /* '~
Dated: July 2,1987 ..
- . . . . . ~ _ -...
F.obert A. Backus 116 Lowell Street Manchester, NH 03105 603-660-7272 GFP3 F 3 CT,'rE OF_ EEFy.1Cf.
I bereti celtify tliet e copy of the within "Eeacoast Anti-Folluticr Leegues ' Motion for Eummary Disposition of EAFL Contention No. 25 " has been sent this date, first class mail, postage prepaid , to those listed on the attccbed service list and has been f ederal expressed to th -
nd' -te b- an asterisk.
/
Robert A. Bacfus l
1
A --
P.O. Box 167 BEVERLY, MASS. 01915 O
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RlENI i LAMBULANG INCJ EDWARD C CUTLER vc2 pnEscENT I
Jane Doughty October 27, 1986 Seacoast Anti-Pollution League 5 Market Street Portsmouth, New Hampshire 03801
Dear Jane:
This letter is to confirm our conversation today on O'Brien
/uhbulance's ability to respond to the Seabrook area. Since our initial co=.unications f rom this past summer our firm has closed our Newburyp: t operation. Therefore, I am sorry to inform you that our cen any will not be able to participate in any type of response in:: the Seabrook area.
If you have any questions, please feel f ree
1-800-922-95'3. ;
j Sincerely, .
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/Ja /
A7 Edward C. Cutler, Vice Presiden:
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l CERTIFICATE OF JERVICE AND SERVICE LIST F
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Joseph Flynn , Asst.Gn.Cnsl. Helen Hoyt. Chm.
- Thomas Dignan,20 Admn. Judge RIS3eri}% -tfrafN :
Fed. Emerg. Mgmt. Agcy. 225 Franklin St.
Atomic Safety & Lic Brd.
500 C.St. So, West Boston, MA 02110 Washington, DC 20472 USNRC Washington, DC 20555 60 i '
f E t.
Dr. Jerry Harbour
Office of Selectmen Office of the Secretary Town of Hampton Falls Admin. Judge Hampton Falls, NH 03844 Atomic Safety & Lic Brd. USNRC USNRC Washington, DC 20555 Washington, DC 20555 Shenvin E. Turk, Esq. W Jane Doughty Dr. Gustave A. Linenberger
- Office of Exec. Legl. Dr. Admin Judge SAPL Atomic Safety & Lic. Brd. 5 Market Street USNRC Portsmouth, NH 03801 Washington, D.C. 20555 USNRC Washington, DC 20555 Paul McEachern, Esq. George Dana Bisbee, Esq.
Phi 31ip /hrens, Esq. Attorney General's OFF Asst. Atty. General Shtthew Brock, Esq.
State of New Hampshire State House , Sta. F6 25 Maplewood Ave.
Concord, NH 03:01 Augusta, ME 04333 P.O. Box 360 Portscouth, NH 03801 Carol Sneider, Esq. , Asst. AG Diane Curran, Esq. William S. lord One Ashburton Place, Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.
Washingmn, DC 20009 Amesbury, MA 01913 Boston, MA 02108 Maynard Young. Chairman Sandra Gavutis Richard A. Hampe. Esq. Town of Kensington New Hampshire Civil Dnense Board of Selectmen 10 Cenjral Road Box 1154 Agency East Kingston, N.H. 038:
Harpe & McNicholas Rye, Np 03S70 35 Pleasant St. a Concord, NH 03301 Edwarc! Thomas Mr. Robert Harrison Judith H. Mizner, Esc.
FEMA Pres & Chief Exec. Office 3 Silverglate, Gertner,' PSCO Baker, Fine, Good & Mirner 442 J.W. McCormack (POCH)
Boston, MA 02109 P.O. Box 330 88 Broad Street MNchester, NH 03105 Boston, M 02110 l
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- Roberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, NH 03844 o
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