ML20141E490

Motion for Extension of Deadline to File Contentions on Evacuation Time Study Until 30 Days from Date of Receipt of Latest Draft of Study.W/Certificate of Svc

ML20141E490
Person / Time
Site:	Seabrook
Issue date:	02/19/1986
From:	Brock M, Mceachern P HAMPTON, NH, SHAINES & MCEACHERN
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20141E409	List: ML20141E406 ML20141E490
References
OL, NUDOCS 8602250267
Download: ML20141E490 (4)

Text

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a 00CMETED 4 USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '

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Before-theAtomicSafetyandLicensingBo$fdU([jqN g

In-the Matter of i

PUBLIC SERVICE COMPANY Docket Nos. 50-443-OL 4

OF NEW HAMPSHIRE 50-444-OL (Seabrook Station, Units I'and II t i

MOTION TO EXTEND DEADLINE

, FOR FILING CONTENTIONS l

ON EVACUATION TIME STUDY i

Now comes Intervenor, Town of Hampton, and moves this Board

to enter an order extending the deadline within which the parties to this proceeding may file contentions concerning the evacu-ation time study to be submitted to the Board by the State of New Hampshire as part of the Radiological Emergency Response Plan for the State and effected local governments. In support of this motion, the Town of Hampton states:

1. That on January 17, 1986, this Board issued a Memo-randum and Order which established a deadline of February 24,  !

! 1986 for filing contentions against the'New Hampshire Radio-

] logical Emergency Response Plan (RERP), and against RERP for local governments filed with the State plan.

i 2. That said Order of the Board further provided an

, opportunity to file new contentions " based upon the latest draft of New Hampshire's plans (to) provide for all parties a fairer opportunity for full participation in these proceedings."

3. That as part of the latest draft of the State and local plans prepared by the State, an updated and amended Evacuation i i

Time Study, the KLD 3rd Revision so called, is currently being prepared as part of the mandatory requirements for the State 1

.l RERP. NUREG, Protective Response, pg. 63, Appendix 4.  ;

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4. That as of the date of this filing, the latest draft of the Evacuation Time Study under preparation by KLD has not been provided to the Town of Hampton and, on information and belief, i has not been provided to this Board.  !

5. That pursuant to this Board's Order of January 17, i 1986, the Town of Hampton should be granted an extension of 30 days from the date of receipt of the latest draft of the Evacu-i ation Time Study in order to provide the Town with a full and fair opportunity for comment and for filing contentions on the ETS.

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6. That alternatively this Board should decline to consider any Evacuation Time Study subsequently filed by the State in' reaching its determination whether the State and local RERP provide reasonable assurance that adequate protective measures can and will be taken in.the event of a radiological emergency. 10 CFR, Section 50.47 (a) .

Dated: February 19, 1986 SHAINES & McEACHERN By Palfl McEachern u f

By \ '

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k k< W N Matthew'T. Brock Attorneys for the Town of Hampton, New Hampshire I

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CERTIFICATE OF SERVICE 00kk 0

I, Matthew T. Brock, one of the attorneys for the Applicants herein, hereby certify that on the 21st day of Feb'BiaM 74 51 Q7 1986, I made service of the within document by mailing copies thereof, postage prepaid, to: ,p Administrative Judge Helen Hoyt Administrtive Ju Il Chairperson J. Wolfe, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Dr. Emmeth A. Luebke Dr. Jerry Harbour Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Philip Ahrens, Esquire Thomas J. Dignan, Jr.,

Assistant Attorney General Esquire, R.K. Gad, III, Department of Attorney General Esquire, Ropes & Gray State House Station 6 225 Franklin Street Augusta, ME 04333 Boston, MA 02110 Jo Ann Shotwell, Esquire Robert G. Perlis, Esquire Assistant Attorney General Office of the Executive Legal Department of the Attorney Director General U.S. Nuclear Regulatory One Ashburton Place, 19th Floor Commission Boston, MA 02108 Washington, DC 20555 Ms. Diana P. Randall Robert A. Backus, Esq.

70 Collins Street 116 Lowell Street Seabrook, NH 03874 P.O. Box 516 Manchester, NH 03105 Diane Curran, Esquire Anne Verge, Chairperson Harmon & Weiss Board of Selectmen 1725 I Street, N.W. Town Hall Suite 506 South Hampton, NH 03827 Washington, DC 20006 i

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1 Ms. Roberta C. Pevear- Mr. Patrick J. McKeon The Town of Hampton Falls Selectmen's Office Drinkwater Road 10 Central Road Hampton Falls, NH Rye, NH 03870 Mrs. Sandra Gavutis Mr. Calvin A. Canney The Town of Kensington City Manager RFD 1 City Hall East Kingston, NH 03827 125 Daniel Street Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. Angle Machiros U.S. Senate Chairman of the Board of Washington, DC 20510 Selectmen (Attn: Tom Burack) Town of Newbury Newbury, MA 01950 Senator Gordon J. Humphrey Mr. Richard E. Sullivan U.S. Senate Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Thomas Powers Town Manager's Office Town Manager Town Hall Town of Exeter Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn Brentwood Board of Selectmen Assistant General Counsel RFD Dalton Road Office of General Counsel Brentwood, NH 03833 Federal Emergency Management Agency Gary W. Holmes, Esquire 500 C Street, S.W. Holmes & Ells Washington, DC 20472 47 Winnacunnet Road Hampton, NH 03841 Richard A. Hampe, Esquire Stephen E. Merrill, Esquire Hampe & McNicholas Attorney General 35 Pleasant Street Office of the Attorney Concord, NH 03301 General 25 Capitol Street George Dana Bisbee Concord, NH 03301-6397 Assistant Attorney General Office of the Tttorney General 5 Capitol Street Concord, NH 03301-6397

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w. tW Matthew T. Brock

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