ML20236N831

From kanterella
Jump to navigation Jump to search
NRC Staff Response to Seacoast Anti-Pollution Leagues Motion for Leave to File Supplemental Response to Applicants Motion for Vacation of Stay.* Motion Granted.Certificate of Svc Encl
ML20236N831
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 11/09/1987
From: Berry G
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
NRC COMMISSION (OCM)
References
CON-#487-4809 OL-1, NUDOCS 8711170024
Download: ML20236N831 (6)


Text

_. - _ -

' [Mh 4;

r y

TED' 1

' U'NITED STA.TES OF ' AMERICA 51 itN 10 h253 I

NUCLEAR REGULATORY : COMMISSION

. OFFICE OF SECRf3AtW

.BEFORE THE COMMISSION.

00CKEig'.g.jEiiVICE

.r In the Matter:of

)

)~

Docket Nos. 50-443 OL-01 50-444 OL-01'

PUBLIC SERVICE COMPANY OF

)

. NEW HAMPSillRE, y al.

)

On-site Emergency Planning

)

and ~ Safety issues

. (Seabrook Station, Units 1 and 2

)

r 1

NRC STAFF'S RESPONSE TO SEACOAST ANTI-POLLUTION ~ LEAGUE'S.

MOTION FOR ' LEAVE TO FILE SUPPLEMENTAL RESPONSE TO APPLICANTS'. MOTION: FOR VACATION OF STAY e

a Gregory Alan Berry Counsel for NRC Staff November 9,1987 t

I B711170024 871109 PDR ADOCK 05000443 350]

PDR g

L UNITED STATES OF AMERICA NUCLEAPs REGULATORY COMMISSION BEFODE THE COMMISSION l

In the Matter of

)

)

Docket Nos. 50-443 OL-01 PUB.LIC SERVICE COMPANY OF

)

50-444 OL-01 NEW HAMPSHIRE, g al.

)

On-site Emergency Planning

)

and Safety issues (Seabrook Station, Units 1 and 2)

)

NRC STAFF'S RESPONSE TO SEACOAST ANTI-POLLUTION LEAGUE'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL RESPONSE TO APPLICANTS' MOTION FOR VACATION OF STAY On October 20, 1987, the Seacoast Anti-Pollution League (SAPL) filed a motion for leave to supplement its October 9,

1987 response in opposition to Applicants' motion to vacate the stay of low-power operation

!nitially imposed by the Commission on January 9, 1987.

See Seacoast Anti-Pollution League's Motion For Leave To File Supplemental Response To Applicants' Motion For Vacation Of Stay (October 20, 1987),

SAPL states that it was unable to respond fully to Applicants' motion in its October 9, 1987 filing because it was then fully engaged in the ongoing hearings on offsite emergency planning. Id. at 1.

The NRC Staff does not oppose S AP L's request for leave to supplement its responce to Applicants' motion to the extent that it is relevant thereto.

However, an examination of SAPL's filing Indicates that it largely constitutes a reiteration of various supplemental stay requests which are currently pending before the Commission, rather than a response to Applicants' motion to lift the existing stay.

Only one of SAPL's assertions relates to the Applicants' " utility plan" for portions of

k s

2-the plume exposure-pathway emergency planning zone within l

Massachusetts.

This assertion'was previously addressed by the Staff.

Accordingly, the Staff does not oppose SAPL's motion to the extentL that it is relevant, R

pectfully submitted, I

,2 M

Gregor'(

n tr

/

Counse or NR lStaff Dated at Bethesda, Maryland this 9th day of November 1907 1/

As explained more fully in the NRC Staff's Response To Applicants' Motion For Vacation Of Stay at 6-12 (October 20, 1987), a summary

~

review of the Applicants' plan performed by the Staff indicates that i

the plan is bona fide and that edequate emergency planning is "at l

least in the realm of the possible." The Staff's responses to various other pending stay ' requests may be found in the Staff's filings of June 8 (matters raised on appeal from the I.icensing Board's Partial Initial Decision), June 29 (FEMA's position on beach populations),

and August 17,1987 (financial qualifications).

1

n 4-l-

3 (p,

T

. j-1 DOCKETED USNRC

' UNITED STATES OF AMERICA NUCLEAR; REGULATORY. COMMISSION Il MN 10 Pl253 o

BEFORE THE COMMISSION 0FFICE OF SECRf TAAY' 00CKETING A SERVICI~

BRANCHJ In the Matter of

)

)

Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF

)

50-444. OL-01

'l'!

NEW HAMPSHIRE, et al.-

)

On-site Emergency Planning

).

and Safety issues

~~

(Seabrook Station, Units 1 and 2

)

l

' CERTIFICATE OF SERVICE I

hereby certify tha't copies of "NRC STAFF'S

RESPONSE

TO SEACOAST ANTI-POLLUTION. LEAGUE'S - MOTION FOR. LEAVE TO FILE-SUPPLEMENTAL. RESPONSE TO APPLICANTS MOTION FOR VACATION -

OF STAY" in the, above-captioned proceeding have been. served ' on < the

.following by deposit _ in the United States mall, first class, or as Indicated i by.- an asterisk, by deposit In the Nuclear Regulatory Commission's internal

. mall system, this 9th day of November 1987:

Sheldon J. Wolfe, Esq., ~ Chairman

  • Dr. Emmeth A. Luebke Administrative Judge.

Administrative Judge Atomic Safety and Licensing Board 5500 Friendship Boulevard l

U.S. Nuclear Regulatory Commission Apartment 1923N Washington, DC 20555 Chevy Chase, Maryland 20815 Dr. Jerry Harbour Ms. Carol Sneider, Esq.

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 t

Beverly Hollingworth Richard A. Hampe, Esq.

209 Winnacunnet Road New Hampshire Civil Defense Agency Hampton, NH Os842 107 Pleasant Street 4

Concord, NH 03301 1

Sandra Cavutis, Chairman Calvin A. Canney, City Manager Board of Selectmen City Hall RFD 1 Box 1154 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801 i

y, q g x

1,

3

  • Stephen E. Merrill-

. Paul McEachern',- Esq.

~

y

. 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, NHT 03801 Co' cord, NH 02301-n Roberta C. Pevear Angle M'achiros,' Chairman

' State. Representative

- Board of Selectmen Town of Hampton Falls.

Drinkwater Road-25.. High Road -

Newbury', MAi 09150 :

Hampton Falls, NH 03844 -

Allen Lampert-Mr. Robert J. Harrison 4

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.

l Harmon &. Weiss -

Assistant Attorney General i

2001 'S Street, NW Office of the Attorney General Suite 430 State House Station #6

- Washington, DC 20009 Augusta, ME 04333 Edward A'.. Thomas Thomas G. Digran Jr., Esq.

. Federal Emergency Management Agency Ropes & Gray 442 J.W. McCormack (POCH) 225 Franklin Street-Boston, MA 02109' Boston, MA 02116 H.J.- Flynn, Esq.

William Armstrong Assistant General Counsel Civil Defense Director Federal Emergency Management Agency Town of Exeter 1

500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety. and Licensing Atomic Safety and Licensing Appeal Panel

  • Boa rd*

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission j

i Washington, DC 20555 Washington, DC 20555 i

1 l-

, E

{

t c

e

- 3,-

p ;,

l Jane Doughty.

Docketing and Service Section*

l_'_.

Seacoast: Anti-Pollution League Office of.the Secretary

' W 5 Market Street U.S. Nuclear Regulatory Commission s

Portsmeuth, NH. 03801 '

= Washington, DC 20555 g..

~

Maynard. L.. Young, Chairman William S. Lord

Board of Selectmen

. Board of Selectmen L 10 Central Road

~ Town Hall - Friend Street (South'..Hampton, ;NH 03287 Amesbury, -MA ' 01913 I*

M'Ichael Santosuosso,- Chairman Peter J. Matthews, Mayor l

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 Ill, Esq.

Mrs. Anne E. Goodman, Chairman

/

Ropes 6 Gray Board of Selectmen

'225 Franklin Street 13-15 Newmarket Road i

Boston, MN 02110

.Durham, NH 03824 q

Gary W. Holmes, Esq.

Holmes S Ellis l

-i 47-Winnacunnet. Road Hampton, NH 03842 h

%&f Gregory / slanj3erry

- f Counsel pr mtC Staff f

i 4

9 i

l l

1

..