ML20236N951
| ML20236N951 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/04/1987 |
| From: | Backus R AMESBURY, MA, BACKUS, MEYER & SOLOMON, HAMPTON, NH, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#387-4199 OL, NUDOCS 8708120164 | |
| Download: ML20236N951 (4) | |
Text
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UNITED' STATES OF AMERICA DN 5 u%i c V
NUCLEAR REGULATORY COMMISSION.
- before the
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ATOMIC SAFETY-AND' LICENSING BOARD prg m
-In the Matter of-
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W3 Docket-No. 506-OL[//g(-dd.
- PUBLIC - SERVICE COMPANY OF '. ):
.NEW HAMPSHIRE, et al'
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(Offsite Emergency.
(Seabrook Station,. Unit 1)
).
Planning Issues)-
SEACOAST-ANTI-POLLUTION LEAGUE'S, TOWN OF HAMPTON'S, TOWN-D
. TOWN'OF AMESBURY'S.AND NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S MOTION TO' CONTINUE'THE LICENSING HEARINGS ON THE NEW-HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLANS NOW'COME the-Seacoast Anti-Pollution League,.the New England Coilition~on Nuclear' Pollution,..the Town of.Amesbury and the Town' Lof Hampt'on and move foricontinuance of the offsite portion of the-
' licensing. hearings for'Seabrook Station until such time as i
integrated' hearings'can be. held on both the plans for the Massachusetts portion of the1Scabrook Station Emergency Planning Zone:as well as the New Hampshire portion of the EPZ.
In support of this motion, the above-named interveners state as follows:
- l)
At a meeting held in,Bethesda, Maryland on July 30, 1987, representatives of the-Applicants indicated that a compensatory plan for the Massachusetts portion of the~EPZ-would be filed in September and that a full' scale graded FEMA exercise of that plan, along with the New Hampshire plan, would be held in March of 1988. 1/
1/- Interveners will supplement this pleading.with the transcript
'of the relevant portion of the July 30 meeting when it is received.
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8708120164 870004
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2)
Offsite litigation on the New Hampshire plans is
)
currently scheduled to commence on September 28 and to i
continue intermittently over five weeks that run to
{
Friday, November 20.
2/
It would work a substantial hardship on interveners to bear the burden of partici-j pating both in the offsite litigation and the review I
and preparation of contentions on the Massachusetts plans over the same time span.
The litigation of the offsite New Hampshire plans would encompass a variety of complex issues and would require the full attention of intervenor counsel.
3)
Interveners intend to litigate the results of the graded FEMA exercise of the plans for the full EPZ and the record would therefore need to be held open until after the month of March 1988 to allow for such litigation.
Therefore, the requested continuance would not significantly extend the date by which a final licensing determination could be arrived at by the Board.
4)
There would likely be the opportunity to streamline the hearings to encompass less total time if hearings on plans for the Ngw.Eampshire and Massachusetts portions of the EPZ were held concurrently.
Certain issues can be anticipated to affect the communities in Massachusetts as they affect those in New Hampshire.
Furthermore, the litigation of tha evacuation time estimate study would more sensibly be done in an l
integrated hearing since Volume 6 of the NHRERP also constitutes the ETE study for the Massachusetts portion of the EPZ.
5)
NUREG-0654, " Criteria for Preparr. tion and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" stresses the importance of contiguous-jurisdiction governmental emergency planning and states that:
"The important point is that integrated emergency planning will benefit all of the communities within the Emergency Planning Zones."
Evaluation criterion A.l.b. states that each organization shall "specify its concept of 2/
See Memorandum and Order dated June 30, 1987 and subsequent Memorandum and Order dated July 9, 1987.
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1-operations and relationship to the total effort" (emphasis added).
Particularly important to the efficacy of the overall. response effort'to a radio-L logical emergency at Seabrook will.be interaction and cooperation at the State levels of government.
The' integration of efforts on both sides of the border could:best be assessed'in an integrated hearing.
WHEREFORE, the above' named movants request that the presently scheduled hearings on the New Hampshire plans be suspended'until such time as contentions on the Massachusetts plans have been filed.and are ripe for litigation.
Respectfully submitted Seacoast Anti-Pollution League l
By its Attorney BACKUS, MEYER &' SOLOMON l
Dated:
August 4, 1987 c/ g#fg-f_
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1065Rf A. BACKUS-i 116 Lowell Street Manchester, NH 03105 603-668-7272 Town of Hampton
.New England Coalition on Nuclear Pollution Town of Amesbury l
[
By' r
Authorized Represen(atdve)
CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing
" Seacoast Anti-Pollution' League's, Town of Hampton's, Town of Amesbury's and New England Coalition on Nuclear Pollution's Motion to Continue the Licensing Hearings on the New Hampshire Radiological Emergency Response Plans", was sent this date, first class mail, postage prepaid to those names on the attached service list, or federal expressed to those names indicated by an asterisk.
- 6beft K. 'Backus R
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CERTIFICATE OF SERVICE AND SERVICE LIST
'%q.
L y..
Thomas Dignan, Esq.*
Jose Asst.Gn.Cnsl.
Helen Hoyt. Chm.
Fed. ph FlynnAfgmt. Agcy.
opes & Gray Atomic Safety & Lic Brd.g7 N[2dd Ift9ttDilin St.
Admn. Judge Emerg.
]
500 C.St. So. West Washington, DC 20472 USNRC Boston, MA 02110
]
Washington, DC 20555 QFO.
I w>un:.>
N Office of Selectmen Dr. Jerry Harbour
- Dhicketing & Serv. Sec. *j
-Town of Hampton Falls Admin. Judge OfficeoftheSecretary{
Hampton Falls, NH 03844' Atomic Safety & Lic Brd.
USNRC USNRC Washington, DC 20555 Washington, DC 20555
)
I Sherwin E. Turk, Esq. #
Dr. Gustave A. Linenberger
- Jane Doughty j
Office of Exec. Legl. Dr.
Admin Judge SAPL USNRC Atomic Safety & Lic. Brd.
5 Market Street Washington, D.C.
20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq.
Paul McEachern, Esq.
George Dana Bisbee, Esq.
Asst. Atty. General Matthew Brock, Esq.
Attorney General's OFF.
State House, Sta. #6 25 Maplewood Ave.
State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsnouth, 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
'Ibun Hall-Friend St.
Boston, MA 02108 Washingcon, DC 20009 Amesbury, MA 01913 Richard A. Hampe, Esq.
Maynard Young, Chairman Sandra Gavutis New Hampshire Civil Delense Board of Selectmen Town of Kensington Agency 10 Central Road Box 1154 Hampe & McNicholas Rye, NH 03870 East Kingston, N.H.
03827.
35 Pleasant St.
Concord, NH 03301 Judith H. Mizner, Esq.
Edward Thomas Mr. Robert Harrison Silverglate, Gertner, FEMA Pres, & Chief Exec. Officer j Baker, Fine,-Good & Mizner 442 J.W. McCormack (POCH)
PSCO 88 Broad Street Boston, MA 02109 P.O. Box 330 Boston, MA 02110 Manchester, NH 03105 Roberta Pevear State Rep.-Town of Hampt Falls Drinkwater Road Hampton Falls, NH 03844 i
Atomic Safety and Licensing Board Panel U.S. NRC Washington, D.C.
20555
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