ML20246N063

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Motion of FEMA for Leave to File Proposed Findings.* Requests to File Encl Proposed Findings Re Section 1 of Commonwealth of Ma Proposed Findings
ML20246N063
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 08/31/1989
From: Flynn H, Mcpheters L
Federal Emergency Management Agency
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20246N069 List:
References
CON-#389-9123 OL, NUDOCS 8909080029
Download: ML20246N063 (2)


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r,y ugust 31, 1989 r

'. A UNITED STATES OF AMERICA

'89 SEP -1 All :50 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSINE: DARD[

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r p ts p JUDGE IVAN W. SMITH, CHAIRFAN JUDGE RICHARD F. COLE JUDGE KENNETH A.-McCOLLOM

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In the Matter of

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Public Service Co. of New Hampshire,

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Docket No. 50-443-OL et al.

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50-444-OL

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Offsite Emergency (Seabrook Station, Units 1 & 2)

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Planning Issues

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MOTION OF THE FEDERAL EMERGENCY MANAGEMENT AGENCY FOR LEAVE TO FILE PROPOSED FINDINGS The Federal Emergency Management Agency (FEMA) moves for leave to file Proposed Findings of Fact and Conclusions of Law in Response to the Massachusetts Attorney General's (MassAG's) Proposed Findings.

The Proposed Findings rhich FEMA seeks ~ leave to file respond only to Section 1 of the M.sasM:'s Proposed Findings.

FEMA endc,rses tne Proposed Findings filed by the Nuclear Regulatory " m ission (NRC) Staff. However, in the casa of the MassAG's Section 1, FEMA has a direct interest which is different from that of NRC Staff. The MassAG's Section 1 in particular calls into question the nature of FEMA's findings and the reliability of the finding proc.ss.

It also challenges FEMA's good faith. FD% submits that it is in the interest of FEMA and all the parties, as well as potentially helpful to l

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4 the-Atomic. Safety and Licensing Board, to have FEMA's views explained'.in

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Counsel for FEMA have corisulted ;with counsel for NRC Staff, the -

Applicants,:; and the MassAG. 'NRC:. Staff s'upports'this Motion for. Leave to File' Propose.d Findings. The Applicants and the MassAG do not opposeLit.

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4 Respectfully submitted, m.w, f.,

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H M OSEP p LYNN g. -. -

IMo&PW LINDA HUBER McPHETERS-Counsel for the Federal Emergency Management Agency 500 C Street, S.W.

Washington, D.C. 20472~

Telephone (202) 646 ~-4105 -

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