ML20235B396
| ML20235B396 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/21/1987 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#387-4419 ALAB-853, CLI-87-02, CLI-87-03, CLI-87-2, CLI-87-3, OL-1, NUDOCS 8709240088 | |
| Download: ML20235B396 (23) | |
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Dated: Sept. 21, 1987
'87 SEP 22 A8 :41 UNITED :aTATES OF AMERICA before the ((
NUCLEAR REGULATORY COMMISSION
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In the Matter of )
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PUBLIC SERVICE COMPANY ) Docket Nos. 50-443-OL-1 OF NEW HAMPSHIRE, EI AL. ) 50-444-OL-1
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(Seabrook Station, Units 1 ) (Onsite Emergency and 2) ) Planning and Safety ,
) Issues) -
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APPLICANTS' MOTION FOR VACATION OF STAY Now come the Applicants and say as follows:
- 1. On November 20, 1986, the Appeal Board in this proceeding issued a decision in which it held, inter alia, that it was not a prerequisite to the issuance of a license to load fuel and perform precriticality testing that an emergency plan for that portion of the Seabrook Station Planning Emergency Zone (EPZ) which lay within the Commonwealth of Massachusetts be filed.
Public Service Comoany of New Hampshire (Seabrook Station, Units 1 and 2), ALAB-853, 24 NRC 711 (1986).
- 2. On January 9, 1987, this Commission issued an order stating its decision to review, sua sconte this aspect of ALAB-853, and staying the Director of Nuclear Reactor Regulation (NRR) from authorizing low power operations at the Seabrook facility l until completion of the review undertaken by the Commission.
8709240088 B70921 ()
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- 3. On April 9, 1987, this Commission issued a Memorandum and order in which it reversed the decision of the Appeal Board in ALAB-853. Public Service Comoany of New Hamoshire (Seabrook Station, Units 1 and 2), CLI-87-02, 25 NRC (April 9, 1987).
- 4. In CLI-87-02, this Commission also stated that it would thereafter address a suaaestion of Mootness and Recuest for vacation of Stay which had been filed by the Applicants on the eve of the issuance of CLI-87-02. The suggestion and request were predicated upon the fact that the Applicants had recently filed an emergency plan for that portion of the Seabrook Emergency Planning Zone which lies within the Commonwealth of Massachusetts. This plan was not a plan developed by the Applicants, but was, rather, an emergency plan which had been drafted by the Commonwealth of Massachusetts prior to the time that the Governor of the Commonwealth made the decision to refuse to participate, or permit the Commonwealth to participate, in the emergency planning process for Seabrook Station.1 It was the position of the Applicants that this document, concededly not a
-true " utility" plan, did serve to meet the requirement laid down i in CLI-87-02 that a demonstration be made that " adequate emergency planning is at least in the realm of the possible." l CLI-87-02 at 7.
- 5. On June 11, 1987 this Commission issued a Memorandum and 1 In a correct characterization of the plan, this Commission stated: "[t]here appears to be no dispute that PSNH's independent contribution to-the plan that it submitted was solely a new cover page." Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), CLI 87-03, 25 NRC (June 11, 1987).
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I l Order forcefully rejecting the position taken by the Applicants l
l and denying the request that the stay preventing NRR from issuing any license authorizing low power operation be lifted. Public Service Company of New' Hampshire (Seabrook Station, Units 1 and 2), CLI-87-03, 25 NRC (June 11, 1987).2
- 6. In CLI-87-03 this Commission stated that CLI-87-02 had imposed two requirements which must be met prior to the issuance of a license authorizing low power operation for Seabrook. These two requirements are:
"(1) PSNH [the lead applicant] was to file a bona fide utility plan, and (2) must demonstrate on summary review that adequate emergency planning is 'at least in the realm of the possible.'" CLI-87-03 at 5.
This Commission further described a " bona fide utility plan" as "one that provides measures to be taken by the utility to compensate for the absence of governmental participation in emergency planning," id., and thus " reflects the utility's compensatory measures and efforts to facilitate the state's participation in the event of an emergency," id. at 7 n.7. In addition, this Commission observed that "[a]n adequate filing in 2 In the earlier decision, CLI-87-02, this Commission stated that it had decided to leave the outstanding fuel loading and precriticality testing license in effect, inter alia, "because there is no safety benefit to be derived from removing the fuel."
CLI-87-02 at 3. In CLI-87-03 this Commission likewise declined to disturb the outstanding fuel loading and precriticality license, and, indeed, acknowledged that activities authorized by that license could continue. CLI-87-03 at 1 ("[T]here can be no low power operation at Seabrook bevond fuel loadina and precriticality testina unless and until the Applicants file a l
bona fide utility offsite emergency plan. . . . "(Emphasis i supplied.)).
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l this case would be one intended for actual implementation as a utility emergency plan, and one intended to be subjected to Staff l l
and FEMA review and litigation on that basis." Id. at 6. The j Commission noted that there was no evidence that such intent existed with respect to the plan then filed; in particular, because there had been no request for review or suggestion that
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litigation on the plan commence. CLI-87-02 at 8. l
- 7. As seen in paragraph 6 above, a total of four requirements must be met in order to establish that a utility emergency plan is bona fida. These requirements are:
- 1. It must describe measures to be taken by the utility to compensate for the absence of governmental participation in emergency planning. -
- 2. It must reflect the utility's efforts to facilitate the state's participation in the event of an emergency.
- 3. It must be a plan intended for actual implementation as a utility emergency plan.
- 4. It must be a plan intended to be subjected to Staff and FEMA review and litigation. (Evidence of such intent being a request for Staff and FEMA review and a suggestion that litigation be commenced).
- 8. Under a letter dated September 18, 1987 (" Letter"), the Applicants have submitted to the Staff and caused to be served upon all parties to this proceeding a comprehensive utility emergency plan entitled "Seabrook Plan for Massachusetts Communities" (SPMC). A copy of the Letter is attached hereto and marked "A." It is to be noted that the letter recites that the SPMC is submitted pursuant to 10 CFR 59 50.30, 50.33, 50. 47 (c) (1) 4 l
for NRC and FEMA review. Letter at 1,3.3 In addition, there is attached hereto and marked "B" a motion which has been filed with the cognizant Licensing Board this date seeking the establishment of a schedule for the' litigation of the plan.
- 9. The SPMC compensates for the lack of planning by thp Commonwealth of Massachusetts by:
"(1) added plans and procedures providing compensating actions; (2) early contacts and close communications with Massachusetts State and local Government emergency response infrastructures and organizations to overcome the potential for delay from the lack of governmental preplanning; (3) added personnel specifically to accompany, advise, and directly provide resources to State and local offic'ials in an actual emergency; (4) added
- personnel to provide protective actioh support that otherwise would have been provided through State and local governmental preplanning; (5) formalized agreements providing facilities, equipment, and supporting services that otherwise would have been provided through State and Local government preplanning; and (6) early, close, and continuing communications with members of the public in the EPZ to ensure that they are kept informed of the status and provisions for response." Letter at 1-2.
Furthermore the SPMC, "does not rely on previously-developed state and local government resources." Id. at 2. As set forth in Attachment 1 to the letter, the Applicants' have purchased or contracted for more than enough resources to carry out 3 As noted in the Letter, Letter at 3,the SPMC is being filed in redacted form in order to protect individuals and organizations supporting the plan as well as certain members of the general public. To the extent that a showing is made that l disclosure of the redacted information is necessary to facilitate f review or lit 5gation of the SPMC, Applicants stand ready to i facilitate such disclosure under appropriate protective orders.
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compensatory actions contemplated by the SPMC and have recruited almost twice the number of necessary personnel. Id., Attach. 1.
- 10. In order to facilit -ce the participation of the Commonwealth in an act'ual emergency, "the plan was developed to be consistent with the Commonwealth of Massachusetts Radiological Emergency Response Plan used for the operating nuclear power plants located in, or within 10 miles of, the Commonwealth's boundaries. . . .
_ Letter at 2. In addition SPMC sets out the training programs for the emergency workars with responsibilities under.the plan; indeed, classroom training has already commenced.
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- 11. In the Letter it is acknowledged that there are five areas wherein the SPMC is not complete. Letter at 3-4. These are:
- 1. The ingestion pathway data needs to be verified and updated due to the passage of time since its original compilation in connection with the Massachusetts Radiological Emergency Response Plan.
- 2. A Letter of Agreement has yet to be obtained from the Department of Interior.
- 3. Route maps must be developed for travel from reception centers to congregate care centers.
- 4. Detailed internal facility plans for individual schools, hospitals and other special facilities must be developed.
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- 5. Alternate prompt notification methodologies must be developed for one Massachusetts community which has elected to tear down sirens owned by it which were contemplated to be part of the prompt notification, system.4 The first three of the above listed items are fairly straight forward matters capable of verification against objective criteria by the Staff when-completed. A good start on the individual facility plans exists in thu form of plans drafted in connection with the Commonwealth's own aborted emergency planning exercise. Furthermore, as stated in the Letter:
"The [SPMC] already includes the necessary information flow, coordination, assignment of resources and actions needed to evacuate if ,
no other facility planning arranger,0nts have been made. This includes letters of agreement for buses, ambulances, vans and host facilities. Should the special facilities not cooperate in the planning effort, the NHY Offsite Response organization, through the actions of the School Liaisons and Special Population Liaisons, can successfully implement an evacuation effort. Because this capability exists in the Seabrook Plan for Massachusetts Communities, there is not a pressing need for explicit facility plans at this time, and these plans will be submitted prior to the graded exercise." Letter at 3.
In addition, as noted in the letter, none of these first four 4 The community is the City of Newburyport. The siren system there was, for the most part, developed prior to the need for the system as part of the Seabrook warning system. Rather its development was accomplished in response to a need for an emergency warning system in the Town fo.' natural disasters. It is our hope that this current attitude will not ultimately prevail in the venerable city, but, as of this time, it must be assumed that these sirens will be unavailable. As noted in the text, there are technical fixes for this problem available, and the Applicants are confident that they can put in effect an appropriate one.
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l items will require additional personnel, facilities or equipment nor will they impact the training now ongoing. Letter at 3.
With respect to the sirens, there are technical fixes available.
Id.
- 12. It has never been the law that an emergency'rplan, when filed for review or even when placed in actual litigntion, had to be complete in every detail. See, e.a., Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2), ALAB-808, 21 l
NRC 1595, 1601 (1985) ("The plan need not be final, just
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sufficiently developed to provide reasonable assurance that adequate protective measures can and will be taken in an emergency.");
Louisiana Power and Licht Co. (Waterford Steam Electric Station, Unit 3). ALAB-732, 17 NRC 1076, 1103-04 (1983).
It is respectfully submitted that the SPMC more than satisfies the necessary degree of completeness required under the cited decisions, and thus satisfies the concept that the submittal should not be: "anything less than would be required of any submittal of materials supporting a license application under the regulations." CLI-87-03 at 6.
- 13. In short, in light of the information set forth in paragraphs 8 - 12 above, it is apparent that all of the criteria for a bona fide utility plan as set out in CLI-87-03 (and summarized in paragraph 7 hereof) are satisfied.
- 14. The other requirement imposed by CLI-87-03 (and CLI 02) is that a summary review of the plan must demonstrate that adequate emergency planning is "at least in the realm of.the 8
possible." CLI-87-03 AT 5. We respectfully submit that a summary review of the SPMC can result in no other conclusion.
The procedures developed, resources purchased or contracted for, the number of individu'als pledged to serve, the consistency with the in-place Massachusetts Radiological Emergency Response Plan all added to the concept of " realism," Lona Island Liahtina Co.
(Shoreham Nuclear Power Station, Unit 1) CLI-86-13, 24 NRC 22 (1986), lead to the ineluctable conclusion that adequate emergency planning for the Massachusetts portion of the Seabrook EPZ is "at least in the realm of the possible."
WHEREFORE the Applicants move the Commission to vacate the -
stay entered in its order of January 9, 1987 prohibiting the Director of Nuclear Reactor Regulation from authorizing low power operations at the Seabrook facility.
By their attorneys, jg M wQ TfiafiiasND gnan,Y George H. Lewald Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for Aeolicants l
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4 George S. Thomas Vice President Nuclear Produchon Public Service of New Hampshire New Hampshire Yankee Division NYN-87113 September 18, 1987 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk
References:
(a) Facility Operating License KPF-56 and Construction Permit CPPR-136, Docket Nos. 50-443 and 50-444 (b) PSNH Letter (NYN-87046), dated April 8, 1987, " Radiological Emergency Response Plan for Commonwealth of Massachusetts," ,
G. S. Thomas to Document Control Desk Subj e ct : Seabrook Plan for Massachusetts Communities
Dear Sir:
In recent discussions with the NRC Staf f (i.e. , meetings of July 30 and September 16, 1987), New Hampshire Yankee (NRY) has stated that a comprehensive utility plan would be submitted for that portion of the Seabrook Station Emergency Planning Zone (EPZ) within the Commons:ealth of Massachusetts.
2nclosed please find nine (9) copies of this utility plan, entitled "Seabrook Plan for Massachusetts Communities", which consists of ten (10) volumes of material. The enclosed Plan supersedes that previously submitted via Reference (b) and is being submitted for NRC Staff and FEMA review pursuant to 10CFR50.33(g) and 10CFR50.47(c)(1).
This Plan was developed in recognition of, and to compensate for, the fact that the Commonwealth of Massachusetts and the local Massachusetts municipalities located within the plume exposure pathway emergency planning zone for Seabrook Station are not currently participating in emergency planning. The compensatory actions which are delineated in the enclosed Plan can range from supporting requests for augmented personnel and resources to perf orming emergency response actions or implementing the total response in place of State and local organizations. The Plan provides a number of features, including (1) added plans and procedures providing compensating actions; (2) early contacts and close communications with Massachusetts State 1 and local government emergency response inf restructures and organizations to overcome the potential for delay from the lack of governmental preplanning; (3) added personnel specifically to accompany, advise, and directly provide resources to State and local of ficials in an actual emergency; (4) added personnel to provide protective action support that otherwise would have been provided through State and local governmental preplanning; (5) formalized o ,_ 5\
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United States Nuclear Regulatory Commission September 18, 1987 Attention: Document Control Desk Page 2 agreements providing facilities, equipment, and supporting services that otherwise would have been provided through State and local government planning; and (6) early, close, and continuing communications with members of the public in the EPZ to ensure that they are kept informed of the status and provisions for response. The plan is intended to be implemented by NHY's Of fsite Response Organization and does not rely on previously-developed State and local government resources. The extent to which NHY has developed the required
. personnel and resources to implement this plan is detailed in Attachment 1 provided herewith. It is NHY's intention to continue developing and obtaining resources in excess of plan requirements to assure the capability to implerant the plan under all circumstances.
In addition to identifying personnel and resources, the Plan describes the training program for offsite organization members to implement its concept of operations. The experience and qualifications of each NHY Offsite Response Organization' member was considered in placing an individual within the response -
organization. This consideration of an individual's experience and qualification during the response organization placement process supports the training program and plan implementation. As recently discussed with the NRC Staff, classroom training began on September 14 and is expected to be completed in October. Folicwing this classroom training, NHY will initiate a program of drills and exercises supplemented as needed by additional classroom training.
All these training activities will culminate in a graded exercise which NHY expects to hold in the Spring of 1988.
- The enclosed Plan was developed to address the sixteen (16) planning standards of 10CFR50.47(b) and NUREG-0654/ FEMA REP-1 as well as other planning concerns such as integration of utility, state, local and federal government response and interfacing with contiguous states. To ensure a smooth integration of response, the Plan was developed to be consistent with the Commonwealth of Massachusetts Radiological Emergency Response Plan used for the operating nuclear power plants located in, or within 10 miles of, the Commonwealth's boundaries, and to be consistent with accepted principles of
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emergency planning with regard to event classification, protective action guides, basis of protective action recommendations, EPZ access control, termination of protective action and recovery /re-entry. This Plan was also subjected to numerous technical reviews which were conducted independent of the planning organization.
An additional feature of the enclosed Plan is to coordinate emergency response efforts in Massachusetts with those in the State of New Hampshire.
To accomplish this, the NHY Of f site Response Organization maintains extensive communications links between its key emergency response facilities and personnel and those of the New Hampshire State Emergency Response Organization; and the procedures to implement this plan delineate steps for contacting and interf acing with the key New Hampshire personnel. This provides for coordination of such crucial emergency functions as accident and dose assessment, activating the prompt notification system and the Emergency Broadcast System, issuing news releases, implementing protective
1 United States Regulatory Commission September 18, 1987 Attention: Document Control Desk Page 3 actions, requesting Federal assistance, and focusing personnel and resources where most needed. The continuous exchange of information between the two organizations and the coordination of key emergency response actions ensures !
that the health and safety of the citizens of both states are protected.
NHY, as recently discussed with the Staff, will be continuing planning efforts in a few areas following submittal of the enclosed Plan. These activities involve verifying and updating, as necessary, ingestion pathway data provided in the Plan, obtaining a Letter of Agreement from the Department of 1 the Interior, developing route maps for traveling from reception centers to j congregate care centers, and assisting in the development, as necessary, of j internal facility plans for schools, hospitals, and other special facilities.
It should be recognized that none of these items will require additional j personnel, facilities or equipment, nor will they impact any ongoing ~ training '
of emergency responders required to implement the concept of operations ,
described in the Plan.
The Letter of Agreement and production of route maps are straightforward activities and should be completed in the near future. The ingestion pathway data included in the plan was extracted from the information contained in the Radiological Emergency Response Plan for the Commonwealth of Massachusetts.
This data base is being verified for completeness by NHY and will be updated where necessary.
5 The detailed plans for special facilities such as schools, nursing homes
'And hospitals were drafted as part of the original Commonwealth of Massachusetts planning efforts in 1985 and 1986. Coordination with these facilities is needed to update, revise and finalize these plans. These plans deal with the f acility's internal shelter and evacuation ef forts and may utilize their own existing resources. The enclosed Plan already includes the necessary information flow, coordination, assignment of resources and actions needed to evacuate if no other facility planning arrangements have been made.
This includes letters of agreement for buses , ambulances , vans and host facilities. Should the special facilities not cooperate in the planning effort, the NHY Offsite Response Organization, through the actions of the School Liaisons and Special Population Liaisons, can successfully implement an evacuation effort. Because this capability currently exists in the Seabrook Plan for Massachusetts Communities, there is not a pressing need for explicit facility plans at this time, and these plans will be submitted prior to the graded exercise.
We recently have been informed that a local Massachusetts' community has initiated the removcl of certain community-owned sirens whic' are part of the prompt notification system. These are the only community-o' ned sirens within the notification system for Seabrook Station. NHY is evaluating the impact of the communities' action and is in the process of developing suitable alternative provisions (e.g.; mobile sirens). NHY will advise the NRC of the action to be taken in response to this development.
United States Nuclear Regulatory Commission September 18, 1987 Attencion: Document Control Desk Page 4 Based on the foregoing and the Plan itself, NHY believes that the Seabrook Plan for the Massachusetts Communities fully compensates for the absence of governmental participation in emergency planning for Massachusetts. This Plan in combination with our commitment to provide the necessary personnel, training, resources, facilities and equipment provides a reasonable basis and framework by which the health and safety of the public will be protected.
Accordingly, NHY vill implement this Plan and herewith submits it, in accordance with 10CFR50.30, 50.33 and 50.47(c)(1), for NRC staff and FEMA review. NHY will, through its counsel, request the Atomic Safety and Licensing Board to establish a hearing schedule for the Plan and will also request the Commission to lift its stay on issuance of a low power license.
Finally it should be noted that the enclosed Plan contains redactions.
These redactions have been made to assure that there will not be any unwarranted invasion of personal privacy of individuals and organizations needed to implement the Plan and certain members of the general public.
One (1) copy of the enclosed redacted plan is being transmitted to each of the interested parties and to each member of the ASLB Panel. Subsequent distributions will be made to appropriate Massachusetts State and local governmental organizations.
Very truly yours, Ge e . Thomas Enclosure cc: Atomic Safety and Licensing Board Service List Mr. William T. Russell (2 cortes and 2 enclosures)
Regi nal Administrator U.S. Nuclear Regulatory Comstssion Region I 631 Park Avenue King of Prussia, PA 19406 Mr. A. C. Cerne (w/o enclosure)
NRC Senior Resident Inspector l Seabrook Station Seabrook, NH 03874 l
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STATE OF NEW HAMPSHIRE Rockingham, ss. September 18, 1987 Then personally appeared before me, the above-named George S. Thomas who, being duly sworn, did state that he is Vice President - Nuclear Production of Public Service Company of New Hampshire, that he is duly authorized to execute and file the foregoing information in the name and on behalf of Public Service Company of New Hampshire, and that the statements therein are true to the best of his knowledge and belief.
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, Marilyn R'. Sullivan, Notary Public l
My Commission Expires: April 29, 1992
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9 ATTACHMENT 1 T0 tWN-87113 RESOURCE
SUMMARY
PERSONNEL Offsite Response Organization Positions Required -
810 Emergency Responders Available -
1221
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FACILITIES All facilities under Contract or Letter of Agreement o Emergency Operations Center - located at utility-owned facility .
o Staging Areas-located at utility-owned f acilities o Reception Centers-located at utility-owned facilities o Transfer Points-located at utility-owned facilities o Congregate Care Centers-over 935,000 sq. ft. available which will shelter in excess of 20,000 evacuees o Hospital-MS-1 Hospital and Backup o Emergency Broadcast System Station IQUIPMENT Numbe r Number Under Number Purchased / Contract or Required Requisitioned Letter of Agreement Portable Radios 200 200 TLD's 1275 2500 Pencil Dosimeters 1275 2500 Monitoring Trailers 3 3 Buses 375 827 Ambulances 46 64 Tow Trucks 12 31 Wheelchair Vans 59 85
ATOMIC SAFETY LICENSING BOARD SERVICE LIST Lando W. Zech, Jr. Chairman Dr. Emmeth A. Luebke U. S. Nuclear Regulatory Commissio9 Atomic Safety and Licensing Board Panel 1717 H. Street Northwest U. S. Nuclear Regulatory Commission Washington', DC 20006 , East West Tower Building 4350 East West Highway Bethesda, MD 20814.
Kenneth Rogers, Commissioner Gustave A. Linenberger U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel 1717 H. Street Northwest U.S. Nuclear Regulatory Commission Washington, DC 20006 East West Tower Building 4350 East West' Highway
( Bethesda, MD' 20814 1
Kenneth M. Carr, Commissioner Dr. Jerry Harbour U. . S . Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel 1717 H. Street Northwest U.S. Nuclear Regulatory Commission Washington, DC 20006 East West Tower Building ,
4350 East West Highway Bethesda, MD 20814 -
Thomas M. Roberts, Commissioner William C. Parler, Esq. General Counsel U. S. Nuclear Regulatory Commission Office of the General Counsel
- 1717.H. Street Northwest U.S. Nuclear Regulatory Commission l Washington, DC 20006 1717 H Street Northwest Washington, DC 20006 Frederick M. Bernthal, Commissioner Martin G. Malsch, Esq. Deputy General U.S. Nuclear Regulatory Commission Counsel for Licensing and Regulation
.1717 H. Street Northwest Office of the General Counsel Washington, DC 20006 U.S. Nuclear Regulatory Commission 1717 H Street Northwest Washington, DC 20006 Ivan W. Smith, Chairman .
Sherwin E. Turk, Esq.
Atomic Safety and Licensing Board Panel Office of the Executive Legal Director U. S. Nuclear Regulatory Commission U.S- Nuclear Regulatory Commission East West Tower Building Tenth Floor 4350 East West Highway 7735 Old Georgetown Road Bethesda, MD 20814 Bethesda, MD 20814 Administrative Judge Sheldon J. H. Joseph Flynn, Esq.
Wolfe, Esq., Chairman Office of General Counsel Atomic Safety and Licensing Board Panel Federal Emergency Management Agency U.S. Nuclear Regulatory Commission 500 C Street, SW East West' Tower Building Washington, DC 20472 4350 East West Highway Bethesda, MD 20814 i
Samuel J. Chilk, Secretary U.S. Nuclear Regulatory Commission 1717 H. Street Northwest Washington, DC 20006 m_______ ________ _ _ _ . _ _ _ _ _ _ _ _
ATOMIC SAFETY LICENSING BOARD SERVICE LIST (continued)
Diane Curran, Esq. Senator Cordon J. Humphrey*
Andrea C. Ferster, Esq. U. S. Senate Harmon & Weiss Washington, DC 20510 Suite 430 (ATTN: Tom Burack) 2001 S. Street, NW Washington, DC 20009 Carol S. Sneider, Esq. Senator Gordon J. Humphrey*
Assistant Attorney General 1 Pillsbury Street Department of the Attorney General Concord , NH 03301 One Ashburton Place, 19th Floor (ATTN: Herb Boynton)
Boston, MA 02108 Paul McEachern, Esq. Mrs. Sandra Cavutis Matthew T. Brock, Esq. Chairman, Board of Selectmen Shaines & McEachern RFD 1 - Box 1154 25 Maplewood Avenue Kensington, NH 03827 P. O. Box 360 Portsmouth, NH 03801 Mr. Ed Thomas Thomas F. Powe rs , III FEHA Region I Town Manager 442 John W. McCormack PO & Courthouse Town of Exeter Boston, MA 02109 10 Front Street Exeter, NH 03833 Stephen E. Merrill, Esq. Brentwood Board of Selectmen Attorney General RFD Dalton Road George Dana Bisbee, Esq. Erentwood, NH 03833
$ssistant Attorney General 25 Capitol Street Concord, NH 03301-6397 Richard A. Hampe, Esq. Calvin A. Canney Hampe and McNicholas City Manager 35 Pleasant Street City Hall Concord, NH 03301 126 Caniel Street Portsmouth, NH 03801 ;
Robert A. Backus, Esq. Philip Ahrens, Ecq. J 116 Lowell Street As sis t ant Attorney General l P. O. Box 516 Department of Attorney General Manchester , NH 03105 Statehouse Station #6 -
Augusta, ME 04333 j i
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I ATOMIC SAFEYY LICENSING BOARD SERVICE LIST (continued) 4 Mr. J. P. Nadeau Mr. William S. Lord Selectmen's Office Board of Selectmen 10 Central Road Town Hall - Friend Street Rye, NH 03870 . Amesbury, MA 01913 Gary W. Holmes, Esq. Peter S. Machews, Mayor Holmes & Ells City Hall 47 Winnacunnet Road Newbu rypo rt , MA '01950 Hampton, NH 03842 Robert Carrigg Judith H. Mizner Town Office Silvergate, Gertner, Baker, Fine, Atlantic Avenue Good & Mizner
. North Hampton, NH 03862 88 Broad Street.
Boston, MA 02110 Mr. Angie Machiros Charles P. Graham, Esq.
Chairman of the Board of Selectmen McKay, Murphy and Grahan Town of Newbury .'
100 Main Street Newbury , MA 01950 Amesbury, MA '1913-
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- Letter of Transmittal Only
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Dated: Sept. 21, 1987 u
s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the s >
9 ATOMIC SAFETi AND LICENSING BOARD
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N. In the Matter of )
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PUBLIC SERVICE COMPANY ) Docket Nos. 50-443-OL OF NEW HAMPSHIRE, ET AL. ) 50-444-OL
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(Seabrook Station, Units 1 ) (Offsite Emergency and 2) ) Planning Issues)
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c APPLICANTS' MOTION FOR SCHEDULE FOR LITIGATION OF MASSACHUSETTS PLAN Under letter dated September 18, 1987, the Applicants have filed a compensatory utility emergency plan for the portion of Xl: ,
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'the Seabrook Emergency Planning Zone (EPZ) which lies within The Commonwealth of Massachusetts. The plan is entitled "Seabrook Plan for Massachusetts Communities" (SPMC) and has been served upon all parties to this proceeding.
WHEREFORE, the Applicants move the Board, after giving all parties an opportunity to be heard with respect thereto, to set a schedule (consistent with the incumbent duties upon the Board and the parties arising out of the already scheduled litigation of the New Hampshire Radiological Erergency Response Plan) for the filing of contentions with respect to the SPMC, the resolution of the admissibility of same, and the pretrial proceedings with k
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I respe'ct to,- and litigation of, those contentions admitted for litigation.
By their attorneys, Thomas G. Dignan, Jr.
George H. Lewald Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for ADolicants.
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CERTIFICATE OF SERVICE 87 SEp 22 . A8:41
.I,. Thomas G._Dignan, Jr. ,one of the attorneys for the Applicants herein, hereby cer tify that on September 21,.
1987, I made-service of the within document by depositing? M copies thereof with Federal Express, prepaid, for delivdry . ' ~
to-(or where indicated, by depositing in the United States mail, first class, postage paid, addressed to):
Alan S. Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensl.ng Atomic Safety and Licensing Appeal Panel _
Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West. Towers' Building. East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814' Gary J. Edles Mr. Ed Thomas '
Atomic Safety and Licensing FEMA, Region I
' Appeal Panel 442 John W. McCormack Post
- U.S. Nuclear Regulatory Office and Court House Commission Post Office Square East West Towers Building Boston, MA 02109 4350 Cast West Highway Bethesda, MD 20814 Administrative Judge Sheldon J. Robert Carrigg, Chairman Wolfe, Esquire, Chairman Board of Selectmen Atomic Safety and Licensing Town Office Board Panel- Atlantic Avenue U.S. Nuclear Regulatory North Hampton, NH 03862 Commission.
East West Towers Building 4350 East West Highway Bethesda, MD 20814 Dr. Emmeth A. Luebke Diane Curran, Esquire Atomic Safety and Licensing Andrea C. Ferster, Esquire Board Panel Harmon & Weiss U.S. Nuclear Regulatory Suite 430 Commission 2001 S Street, N.W. 1 East West Towers Building Washington, DC 20009 4350 East West Highway ;
Bethesda, MD 20814 u
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, e Dr. Jerry Harbour Stephen E. Merrill, Esquire Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee, Esquire U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission East West Towers Building Tenth Floor 4350 East West Highway 7735 Old Georgetown Road Bethesda, MD 20814 Bethesda, MD 20814
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Fr.nel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 .
Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Au gusta , ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney {
Chairman, Board of Selectmen Cit.y Manager j RFD 1 - Box 1154 City Hall l Route 107 126 Daniel Street I Kensington, NH 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey Mr. Angie Machiros U.S. Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn: Tom Burack) Town of Newbury Newbury, MA 01950
- Senator Gordon J. Humphrey Mr. Peter S. Matthews l 1 Pillsbury Street Mayor '
Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 I
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Mr. Thomas-F. Potc;r., III Mr. William S. Lord Town Manager Board of Selectmen
. Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH- 03833 l H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of. General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord,lui 03301 Judith H. Mizner, Esquire Charles P. Graham, Esquire
'Silverglate, Gertner, Baker McKay, Murphy and Graham Fine, Good & Mizner 100 Main Street 88 Broad Street Amesbury, MA- 01913 .
Boston, MA 02110 Lando W. Zech, Jr., Chairman Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 1717 H Street 1717 H Street Washington, DC 20555 Washington, DC 20555 Kenneth M.'Carr, Frederick M. Bernthal,
' Commissioner Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 1717 H Street 1717 H Street Washington, DC 20555 Washington, DC 20555 Kenneth C.. Rogers, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street Washington, DC 20555 __ ,-57 f-Thomas G. W nan, Jr.
(*=U.S. First Class Mail.)
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