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Category:INTERVENTION PETITIONS
MONTHYEARML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20237C6981998-08-18018 August 1998 Sapl/Necnp Reply to Naesco Response to Proposed Contentions.* Board Should Admit Sapl/Necnp Contentions 1-4 & North Atlantic Energy Svcs Corp Arguments to Contrary. W/Certificate of Svc ML20237C6791998-08-18018 August 1998 Sapl/New England Coalition on Nuclear Pollution Reply to Staff Answer to Contentions.* Petitioners Believe Board Can & Should Give Cases Consideration W/O Filing of Addl,But Not Substantively Different Contention.W/Certificate of Svc ML20237A0501998-08-10010 August 1998 North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied ML20236X9281998-08-10010 August 1998 NRC Staff Answer to Contentions.* for Reasons Stated,All of Contentions Proposed Should Be Rejected & Proceeding Should Be Terminated.W/Certificate of Svc ML20066H2581991-02-14014 February 1991 Response of Ma Atty General & Necnp to ASLB Order of 910124.* Intervenors Believe ASLB Should Reopen Record, Permit Discovery & Hold Hearing on Beach Sheltering Issues. W/Certificate of Svc ML19332D7241989-11-21021 November 1989 Intervenors Motion for Clarification Or,In Alternative,For Reconsideration.* Clarification or Reconsideration of Scheduling Requirements Set by Commission 891121 Order Requested.Certificate of Svc Encl ML19332D5191989-11-15015 November 1989 Applicant Answer to Intervenors Motion to Admit late-filed Contention & Reopen Record Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Sys Network & Wcgy.* Motion Should Be Denied Since Results Unlikely to Change ML19325E0171989-10-20020 October 1989 Applicant Answer to Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Motion to Assert Addl Bases for Original Onsite Exercise Contention JI-Onsite Ex-1 Should Be Denied.W/Certificate of Svc ML19325E0011989-10-20020 October 1989 Applicant Response to Intervenors Motion to Amend Intervenors Motions of 890929 & 1013 to Admit Contentions on 890927 Onsite Emergency Plan Exercise.* Issue Re Admittance Committed to Board Discretion.Certificate of Svc Encl ML20248J3511989-10-13013 October 1989 Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Advises That Applicant Contentions Filed on 890929 to Admit Addl Bases Re Scope of Onsite Exercsise Should Be Admitted.W/Certificate of Svc ML20248J0601989-09-28028 September 1989 Intervenors Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Requests Hearing & to Engage in Discovery for Hearing on Contention.Supporting Documentation & Certificate of Svc Encl ML20247Q6761989-09-22022 September 1989 Intervenors Second Informational Suppl to Low Power Contentions Filed on 890721 & 0828.* Incorporates Encl Plant Startup Test Procedure 1-ST-22,Rev 2 Into Low Power Testing Contentions.W/Supporting Info & Certificate of Svc ML20246N1001989-09-0101 September 1989 Intervenors Reply to Responses of Applicant & Staff Re Intervenors Motion to Admit Contention,Or,In Alternative,To Reopen Record & Request for Hearing.* Contention Raises New Issues & Should Be Admitted.W/Certificate of Svc ML20247E0321989-07-21021 July 1989 Intervenors Motion to Admit Contention,Or in Alternative,To Reopen Record & Request for Hearing.* Requests Contentions Re Deficiencies in Training,Mgt Control,Supervision, Communication & Procedure Compliance Be Admitted ML20246P2041989-07-0505 July 1989 Joint Intervenor (Ji) Contentions on Spmc & June 1988 Graded Exercise.* ML20248F4691989-04-0303 April 1989 Seacoast Anti-Pollution League (Sapl) Trial Brief on Contention Ji 56 & Sapl Contentions EX-2,4,6,7,8,12,13 & 14.* Svc List Encl ML20206M9761988-11-23023 November 1988 NRC Staff Response to 881114 Board Order Requesting Comments on Significance of ALAB-903 for Seabrook Proposed General Exercise Contentions.* Contentions & Bases Should Be Denied. Certificate of Svc Encl ML20206M9431988-11-22022 November 1988 New England Coalition on Nuclear Pollution Comments on Significance of ALAB-903 to Seabrook Offsite Exercise Contentions.* Svc List Encl ML20206M9031988-11-22022 November 1988 Seacoast Anti-Pollution League Comments on Significance of ALAB-903 to Exercise Contentions.* Svc List Encl ML20205R7201988-11-0202 November 1988 Town of Hampton Contention on Applicant Plan to Fund Decommissioning Costs of Seabrook Station.* Supporting Documentation & Certificate of Svc Encl ML20205R5661988-11-0202 November 1988 Seacoast Anti-Pollution League Contentions on Applicant Plan in Response to NRC Order CLI-88-07.* Supporting Documentation Encl ML20205R5441988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Financial Qualifications to Operate Seabrook Nuclear Power Station.* Supporting Documentation & Certificate of Svc Encl ML20205R4971988-11-0202 November 1988 New England Coalition on Nuclear Pollution Contentions on Applicant Decommissioning Plan,Motion for Stay of Low Power Operation & Motion to Reopen Record.* Supporting Info & Svc List Encl ML20205R4821988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Decommissioning Plan for Seabrook Nuclear Power Station.* ML20205E0011988-10-24024 October 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to Commonwealth of Ma Atty General Exercise Contentions.* Certificate of Svc Encl ML20205E0271988-10-21021 October 1988 New England Coalition on Nuclear Pollution (Necnp) & Town of Hampton (Toh) Reply to Applicant & NRC Staff Responses to Contentions Toh/Necnp EX-2 & Toh/Necnp EX-3.* Svc List Encl ML20205D8051988-10-21021 October 1988 Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl ML20206C1951988-10-18018 October 1988 Seacoast Anti-Pollution League (Sapl) Reply to Applicant & Staff Responses to Sapl Contentions on June 1988 Graded Exercise.* Svc List Encl ML20204G9731988-10-13013 October 1988 NRC Staff Response to Intervenors Contentions on Graded Exercise.* Proposed General Exercise Contentions Should Be Admitted for Litigation & Proferred Contentions Should Be Denied Admission.Certificate of Svc Encl ML20154S4571988-09-28028 September 1988 Applicant Response to Intervenor Contentions on June 1988 Seabrook Exercise.* Intervenor Contentions Should Be Disposed Of.Certificate of Svc Encl ML20154P3461988-09-21021 September 1988 New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl ML20154K8741988-09-21021 September 1988 Commonwealth of Ma Atty General Exercise Contentions Submitted in Response to June 1988 Plant Initial full- Participation Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154K9331988-09-21021 September 1988 Town of Hampton & New England Coalition on Nuclear Pollution Emergency Planning Contentions on 880628-29 Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154N9061988-09-20020 September 1988 Seacoast Anti-Pollution League Contentions on Graded Exercise.* Svc List Encl ML20154D7431988-09-12012 September 1988 New England Coalition on Nuclear Pollution Petition for Review of ALAB-899.* Petition Should Be Granted on Basis That Integrity of RCS Significantly Paramount to Safe Operation of Plant.W/Certificate of Svc ML20151A6461988-07-0707 July 1988 NRC Staff Response to Town of Salisbury Amended Contentions Re Applicant Plan for Commonwealth of Ma Communities.* Applicant Untimely Amends to Contentions Should Be Rejected. Certificate of Svc Encl ML20151A6301988-07-0606 July 1988 NRC Staff Response to City of Haverhill Detailed Contentions.* City of Haverhill late-filed Contentions Should Be Rejected.Certificate of Svc Encl ML20196G7031988-06-27027 June 1988 Applicant Response to City of Haverhill Detailed Contentions.* Contentions Should Be Rejected & City Should Be Denied Admission as Party,Per 10CFR2.714.Supporting Documentation & Certificate of Svc Encl ML20196A3761988-06-22022 June 1988 New England Coalition on Nuclear Pollution (Necnp) Reply to Applicant & NRC Staff Response to Necnp Contentions on Spmc.* Certificate of Svc Encl ML20196A3991988-06-22022 June 1988 Reply of Massachussetts Atty General to Responses of NRC Staff and Applicant to Contentions 7 Through 83 Filed by Massachussetts Atty General.* Certificate of Svc Encl ML20196A5261988-06-22022 June 1988 Town of Amesbury Reply to NRC Staff & Applicant Responses to Town of Amesbury Contentions on Seabrook Plan for Massachussetts Communities.* Certificate of Svc Encl ML20196A8701988-06-20020 June 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to First Six Contentions Filed by Commonwealth of Ma Atty General.* ML20151N6271988-06-17017 June 1988 Town of Salisbury Reply to Applicant Response to Intervenor Contentions on Seabrook Plan for State of Ma Communities ML20151A8361988-06-17017 June 1988 Reply of Town of West Newbury to Responses of Applicant & NRC Staff to Intervenors Contentions Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl ML20151N6461988-06-17017 June 1988 Town of Salisbury Amended Contentions Re Applicant Plan for State of Ma Communities.Certificate of Svc Encl 1999-07-20
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20237C6981998-08-18018 August 1998 Sapl/Necnp Reply to Naesco Response to Proposed Contentions.* Board Should Admit Sapl/Necnp Contentions 1-4 & North Atlantic Energy Svcs Corp Arguments to Contrary. W/Certificate of Svc ML20237C6791998-08-18018 August 1998 Sapl/New England Coalition on Nuclear Pollution Reply to Staff Answer to Contentions.* Petitioners Believe Board Can & Should Give Cases Consideration W/O Filing of Addl,But Not Substantively Different Contention.W/Certificate of Svc ML20237A0501998-08-10010 August 1998 North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied ML20236X9281998-08-10010 August 1998 NRC Staff Answer to Contentions.* for Reasons Stated,All of Contentions Proposed Should Be Rejected & Proceeding Should Be Terminated.W/Certificate of Svc ML20066H2581991-02-14014 February 1991 Response of Ma Atty General & Necnp to ASLB Order of 910124.* Intervenors Believe ASLB Should Reopen Record, Permit Discovery & Hold Hearing on Beach Sheltering Issues. W/Certificate of Svc ML19332D7241989-11-21021 November 1989 Intervenors Motion for Clarification Or,In Alternative,For Reconsideration.* Clarification or Reconsideration of Scheduling Requirements Set by Commission 891121 Order Requested.Certificate of Svc Encl ML19332D5191989-11-15015 November 1989 Applicant Answer to Intervenors Motion to Admit late-filed Contention & Reopen Record Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Sys Network & Wcgy.* Motion Should Be Denied Since Results Unlikely to Change ML19325E0171989-10-20020 October 1989 Applicant Answer to Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Motion to Assert Addl Bases for Original Onsite Exercise Contention JI-Onsite Ex-1 Should Be Denied.W/Certificate of Svc ML19325E0011989-10-20020 October 1989 Applicant Response to Intervenors Motion to Amend Intervenors Motions of 890929 & 1013 to Admit Contentions on 890927 Onsite Emergency Plan Exercise.* Issue Re Admittance Committed to Board Discretion.Certificate of Svc Encl ML20248J3511989-10-13013 October 1989 Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Advises That Applicant Contentions Filed on 890929 to Admit Addl Bases Re Scope of Onsite Exercsise Should Be Admitted.W/Certificate of Svc ML20248J0601989-09-28028 September 1989 Intervenors Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Requests Hearing & to Engage in Discovery for Hearing on Contention.Supporting Documentation & Certificate of Svc Encl ML20247Q6761989-09-22022 September 1989 Intervenors Second Informational Suppl to Low Power Contentions Filed on 890721 & 0828.* Incorporates Encl Plant Startup Test Procedure 1-ST-22,Rev 2 Into Low Power Testing Contentions.W/Supporting Info & Certificate of Svc ML20246N1001989-09-0101 September 1989 Intervenors Reply to Responses of Applicant & Staff Re Intervenors Motion to Admit Contention,Or,In Alternative,To Reopen Record & Request for Hearing.* Contention Raises New Issues & Should Be Admitted.W/Certificate of Svc ML20247E0321989-07-21021 July 1989 Intervenors Motion to Admit Contention,Or in Alternative,To Reopen Record & Request for Hearing.* Requests Contentions Re Deficiencies in Training,Mgt Control,Supervision, Communication & Procedure Compliance Be Admitted ML20246P2041989-07-0505 July 1989 Joint Intervenor (Ji) Contentions on Spmc & June 1988 Graded Exercise.* ML20248F4691989-04-0303 April 1989 Seacoast Anti-Pollution League (Sapl) Trial Brief on Contention Ji 56 & Sapl Contentions EX-2,4,6,7,8,12,13 & 14.* Svc List Encl ML20206M9761988-11-23023 November 1988 NRC Staff Response to 881114 Board Order Requesting Comments on Significance of ALAB-903 for Seabrook Proposed General Exercise Contentions.* Contentions & Bases Should Be Denied. Certificate of Svc Encl ML20206M9431988-11-22022 November 1988 New England Coalition on Nuclear Pollution Comments on Significance of ALAB-903 to Seabrook Offsite Exercise Contentions.* Svc List Encl ML20206M9031988-11-22022 November 1988 Seacoast Anti-Pollution League Comments on Significance of ALAB-903 to Exercise Contentions.* Svc List Encl ML20205R7201988-11-0202 November 1988 Town of Hampton Contention on Applicant Plan to Fund Decommissioning Costs of Seabrook Station.* Supporting Documentation & Certificate of Svc Encl ML20205R5661988-11-0202 November 1988 Seacoast Anti-Pollution League Contentions on Applicant Plan in Response to NRC Order CLI-88-07.* Supporting Documentation Encl ML20205R5441988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Financial Qualifications to Operate Seabrook Nuclear Power Station.* Supporting Documentation & Certificate of Svc Encl ML20205R4971988-11-0202 November 1988 New England Coalition on Nuclear Pollution Contentions on Applicant Decommissioning Plan,Motion for Stay of Low Power Operation & Motion to Reopen Record.* Supporting Info & Svc List Encl ML20205R4821988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Decommissioning Plan for Seabrook Nuclear Power Station.* ML20205E0011988-10-24024 October 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to Commonwealth of Ma Atty General Exercise Contentions.* Certificate of Svc Encl ML20205E0271988-10-21021 October 1988 New England Coalition on Nuclear Pollution (Necnp) & Town of Hampton (Toh) Reply to Applicant & NRC Staff Responses to Contentions Toh/Necnp EX-2 & Toh/Necnp EX-3.* Svc List Encl ML20205D8051988-10-21021 October 1988 Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl ML20206C1951988-10-18018 October 1988 Seacoast Anti-Pollution League (Sapl) Reply to Applicant & Staff Responses to Sapl Contentions on June 1988 Graded Exercise.* Svc List Encl ML20204G9731988-10-13013 October 1988 NRC Staff Response to Intervenors Contentions on Graded Exercise.* Proposed General Exercise Contentions Should Be Admitted for Litigation & Proferred Contentions Should Be Denied Admission.Certificate of Svc Encl ML20154S4571988-09-28028 September 1988 Applicant Response to Intervenor Contentions on June 1988 Seabrook Exercise.* Intervenor Contentions Should Be Disposed Of.Certificate of Svc Encl ML20154P3461988-09-21021 September 1988 New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl ML20154K8741988-09-21021 September 1988 Commonwealth of Ma Atty General Exercise Contentions Submitted in Response to June 1988 Plant Initial full- Participation Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154K9331988-09-21021 September 1988 Town of Hampton & New England Coalition on Nuclear Pollution Emergency Planning Contentions on 880628-29 Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154N9061988-09-20020 September 1988 Seacoast Anti-Pollution League Contentions on Graded Exercise.* Svc List Encl ML20154D7431988-09-12012 September 1988 New England Coalition on Nuclear Pollution Petition for Review of ALAB-899.* Petition Should Be Granted on Basis That Integrity of RCS Significantly Paramount to Safe Operation of Plant.W/Certificate of Svc ML20151A6461988-07-0707 July 1988 NRC Staff Response to Town of Salisbury Amended Contentions Re Applicant Plan for Commonwealth of Ma Communities.* Applicant Untimely Amends to Contentions Should Be Rejected. Certificate of Svc Encl ML20151A6301988-07-0606 July 1988 NRC Staff Response to City of Haverhill Detailed Contentions.* City of Haverhill late-filed Contentions Should Be Rejected.Certificate of Svc Encl ML20196G7031988-06-27027 June 1988 Applicant Response to City of Haverhill Detailed Contentions.* Contentions Should Be Rejected & City Should Be Denied Admission as Party,Per 10CFR2.714.Supporting Documentation & Certificate of Svc Encl ML20196A3761988-06-22022 June 1988 New England Coalition on Nuclear Pollution (Necnp) Reply to Applicant & NRC Staff Response to Necnp Contentions on Spmc.* Certificate of Svc Encl ML20196A3991988-06-22022 June 1988 Reply of Massachussetts Atty General to Responses of NRC Staff and Applicant to Contentions 7 Through 83 Filed by Massachussetts Atty General.* Certificate of Svc Encl ML20196A5261988-06-22022 June 1988 Town of Amesbury Reply to NRC Staff & Applicant Responses to Town of Amesbury Contentions on Seabrook Plan for Massachussetts Communities.* Certificate of Svc Encl ML20196A8701988-06-20020 June 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to First Six Contentions Filed by Commonwealth of Ma Atty General.* ML20151N6271988-06-17017 June 1988 Town of Salisbury Reply to Applicant Response to Intervenor Contentions on Seabrook Plan for State of Ma Communities ML20151A8361988-06-17017 June 1988 Reply of Town of West Newbury to Responses of Applicant & NRC Staff to Intervenors Contentions Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl ML20151N6461988-06-17017 June 1988 Town of Salisbury Amended Contentions Re Applicant Plan for State of Ma Communities.Certificate of Svc Encl 1999-07-20
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] |
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NEtATED CORRESPONDLF%4 x ,
l UNITED STATES AMERICA ,
l 'l . . I, NUCLEARREGULATORYCOMMISSION{ '; -
before the ATOMIC SAFETY AND LICENSING BOARD l
~- l In the matter of:
PUBLIC SERVICE COMPANY OF Docket Nos. : 50-443 OL NEW HAMPSHIRE and 50-444 OL (Seabrook Station, Units 1 and 2)
MEMORANDUM ON 10 CFR S2.714 (a) (1)
AND REVISED CONTENTION III OF THE TOWN OF HAMPTON IQ EVACUATION TIME ESTIMATE FEPORT EX XLD ASSOCIATES, INCL INTRODUCTION The Town of Hampton submits that the Hampton Revised Contention III on the KLD Evacuation Time Estimate (ETE) Study filed herewith should not be deemed " late filed." See NRC Staff Response to Hampton Contention III. In anticipation of Applicant's objection on this issue, however, the Town addresses the late filed requirements of 10 CPR S2.714 (a) (1) .
TOWN OF HAMPTON MEMORANDUM JE SUPPORT QE " LATE FILED" REVISED CONTENTION III 9994 Cun. On or about February 22, 1986, the Town of Hampton filed with this Board Contentions of the Town of Hampton to Radiological Emergency Response Plan f or the Town of Hampton, New Hampshire, November 1985. Town of Hampton Contention III enumerated certain deficiencies in the Evacuation Time Estimate (ETE) Study prepared by C.E. Maguire, Inc., which then constituted a portion of the 1
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l State RERP. At the prehearing conference on March 25 and 26, 1986, however, the State confirmed its intention to delete the Maguire report Ifrom the State RERP and to substitute the ETE prepared by KLD Associates, Inc. The State further represented that the KLD ETE would lbecompletedonoraboutMay1, 1986.
Apparently, based upon these representations by the State, this Board, by Order dated April 29, 1986, held "that any consideration of the admissibility of Hampton Contention III is premature."
On or about April 28, 1986, the State provided the Town of Hampton with KLD Progress Report 47 which apparently represents the last report of the KLD ETE. See May 5, 1986 letter of New Hampshire Attorney General. KLD Progress Reports #1 - #6 were previously provided to the Town. It is therefore undisputed that the State of New Hampshire, through its late filing of major revisions to the State RERP, plainly prevented the Town of Hampton f rom filing contentions on the State ETE within the time f rame originally established by this Board. The Town therefore has good cause for " late filing" Hampton Revised Contention III.
Other Mgang in EIgiggi PetitigngIsl IntereRI. A substantial portion of the KLD ETE is directed toward the problems poned by evacuation of the beach population.. Since the Town of Hampton has the largest peak summer population of any town within the EPZ, the KLD ETE i raises substantial saiety questions and concerns for Hampton of ficials, I
who are uniquely qualified to assess the deficiencies in the ETE.
Other participants to this proceeding, without knowledge of local i 2
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- conditions, equipment, and personnel in Hampton, theref ore cannot be
! expected to f ully and adequately protect the Town's interest in this j case.
t Ez12D1 2p Whish E e t i t i o n e r s Can C o n t r i bnig 19 D e v e lDPESDI 21 2 EsspId. At the summer hearing, the Town will present testimony by G1; u Eastman, Chairman, Hampton Board of Selectmen; Dona Janetos, Vice Chairman, Hampton Board of Selectmen; Robert Mark, Hampton Police Chief; Philip Richards, Hampton Town Manager; and other Hampton of ficials on traf fic and road conditions within the Town, lack of adequate and/or trained personnel to carry out assigned duties under the KLD ETE, lack of sheltering for Town residents and transients, and other issues as set forth in the Basis to Revised Hampton Contention III. The Town believes this evidence is essential to this Board to determine whether the State RERP cannot provide reasonable assurance of adequate protection to the Hampton population, and to transients within the Town, in the event of radiological emergency.
The Exteni Ts Whish Dihar Enriins Hill Present 2211119D212' Interest. This f actor is " closely related" to the second f actor set f orth in 52.714 (a) (1). In the matter of Commonweath Edison Company (Braidwood Station Units 1 and 2), Docket Nos. 50-456, 50-457, 42486 at p.4, and the Town of Hampton therefore believes it has fully and adequately addressed this factor as set forth above.
The Extent 19 Which ihn E211119nnID1 EAI11s19a119D Will Broaden ths .IngMan pl Delay thR EISS22d1Ds. The Town of Hampton's Revised Contention III should not delay these proceedings. The Town has 3
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already provided detailed objections to the State's original ETE l prepared by the Maguire Corporation within the filing deadline established by the Board. Since these issues have now been rendered moot by the State's substitution of the KLD ETE, Hampton's Revised Contention III, which addresses substantially identifical deficiencies within the KLD ETE, should not delay these proceedings beyond the time required to address Hampton's original, and timely filed, contentions on the State ETE.
HAMPTON REVISED CONTENTION III The Evacuation Time Estimate Study (ETE) prepared by KLD Associates, Inc., and incorpor'ated into the State of New Hampshire Radiological Emergency Response Plan (RERP), is based upon inaccurate f actual data and unreasonable or misleading assumptions and thereby fails to provide reasonable assurance that adequate protective measures can be implemented, or that adequate facilities, equipment, or personnel will be provided to the Town of Hampton in the event of radiological emergency. 10 CFR 550.47 (a) (1), 50.47 (b) (1) (10).
BASIS: The KLD ETE is based upon the following inaccurate, unreasonable, or misleading f acts or assumptions:
- 1. ,The KLD ETE unreasonably estimates vehicle counts within the EPZ, including beach areas, utilizing data obtained on only two weekends, and the intervening work week, in August, 1985. KLD Progress Report il (hereinafter KLD #1) Appendix E-13. KLD relies upon these limited vehicle counts as part of "the basis for computer analysis of 4
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- an Evacuation Plan and computation of ETE." KLD #1, pp.5,6. KLD concedes, however, that this traffic data was gathered during a period of " occasional rain," KLD #1, p. 7 , "this period of time was not particularly appealing to beachgoers," KLD fl, Appendix E-13, "the data j will not reflect peak conditions". . . and there is "some uncertainty" j on the accuracy of the data. On its face, therefore, the KLD ETE i
' admits to an inadequate factual base to provide reasonable projections for traffic counts and movements during an evacuation within the EPZ, and particularly the beach areas. Additionally, since even this limited data was obtained by KLD during poor beach weather, it must be assumed that KLD's vehicle counts, -and theref ore ETE ' projections, are l
i unreasonably low.
- 2. The KLD ETE unreasonably relies upon a telephone survey to l
estimate the time required f or notification of an emergency, elapsed times to commence evacuation trips, and the total population to be evacuated from the EPZ. KLD #1, p.7, KLD #2, p.9. Those persons surveyed constitute less than one percent of the individuals residing within the EPZ, KLD #1, Appendix F-6, there is absolutely no showing by KLD that this minimal percentage of residents is in any way representative of the EPZ population as a whole, and therefore the telephone survey represents an inadequate f actual base f rom which to make these ETE projections. For example, while KLD concedes that "we know of no survey which has accumulated empirical information describing the rate at which notification inf ormation is received,"
KLD # 2, p.7, it nevertheless baldly claims that the telephone survey 5
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can provide "a reasonable estimate of a notification time f rame." KLD i
- 2, p.7. The Town suggests, however, that limited information obtained by telephone f rom an apparently nonrepresentative segment of the EPZ l popula tion is wholly inadequate to make these significant ETE projections. Based upon the admitted deficiencies in its data base, therefore, the KLD ETE necessarily fails to provide reasonable assurance on the accuracy of these ETE estimates.
- 3. The KLD ETE computes the number of vehicles to be evacuated from the beach areas merely by counting parking spaces and parking capacity. KLD # 1, p.15, 2 0. The KLD ETE theref ore f ails to account for the virtual bumper to bumper traffic that routinely, and continually, travels through the beach areas during the summer. These vehicles in transit represent not only a significant additional number of vehicles to be evacuated, but also present a substantial impediment to all parked vehicles attempting to leave the EPZ. See also KLD #1, Appendix E-4, 5; KLD # 2, p.9.
- 4. The KLD ETE erroneously assumes that local officials, including police and fire department personnel, will be available to implement the State evacuation plan. KLD #2, p.4 0. Since the Town of Hampton has stated it does not intend to provide this assistance or implement the State RERP, the KLD ETE fails to provide reasonable assurance that adequate personnel are available to implement the evacuation plan. Additionally, even assuming that the State could timely provide an equivalent number of State personnel to fulfill these local functions, the KLD ETE recognizes that local personnel are 6
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i juniquely qualified to determine potential traffic problems and l bottlenecks, which may not be readily apparent to State personnel l unf amiliar with the local area.
KLD #2, p.4 0.
l 5. The KLD ETE unreasonably assumes that 151 " traffic guides" i
l will be available to implement traf fic control procedures during an i
l evacuaton, including 25 f or the Town of Hampton. KLD # 4, p.ll. The i
KLD ETE wholly fails, however, to demonstrate the availability of these substantial number of trained traffic personnel. Additionally, since State Police Troop A has only 31 troopers available for evacuation traffic control throughout the entire EPZ, it is unreasonable to expect that the State can adequately and promptly supplement these personnel deficiencies, particularly in view of the substantial additional duties
- p. 2 8, and l imposed on Troop A for overall traf fic surveillance, KLD #7, as specified in the State Compensatory Plan. See Compensatory Plan, Troop A New Hampshire State Police, Emergency Response Procedures, p.2.
The KLD ETE further unreasonably assumes the availability of an additional 27 New Hampshire " traffic guides" to regulate access control posts on the perimeter of the EPZ to restrict traffic entrance into the EPZ during an evacuation. KLD # 6, p.13. As set f orth above, there is no showing that in f act these trained personnel will be available to j perform these specified duties.
I i 6. The KLD ETE unreasonably assumes that adequate equipment and personnel will be available to plow roads and driveways, and to assure that evacuation routes remain passable, if evacuation is required during a snowstorm. KLD #2, p.19, 24. For example, KLD incorrectly l
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j assumes that the time to plow the driveways during an evacuation is identical to the time required f or snow clearance under non-emergency
, conditions. The ETE therefore unreasonably fails to account for
- evacuation traf fic congestion which must impede or prohibit a plow truck from reaching certain homes on roads, and unreasonably f ails to consider that a substantial number of those private individuals i perf orming snowplow services may elect to promptly evacuate the EPZ rather than complete their routes.
- 7. The KLD ETE unreasonably assumes that buses will encounter "little impedance" when entering the EPZ to evacuate schools and those without priva te ' vehicles. KLD #7, p.17. This assumption is unsupportable. For example, the State RERP.provides that the i
Timberlane Bus Company of Salem, New Hampshire shall provide 35 buses to evacuate the Town of Hampton during a radiological emergency. These Timberlane buses, however, would be required to maneuver through thousands of evacuating vehicles headed for the " host" communities of Manchester and Salem. KLD #4, Appendix J. It can only be reasonably anticipated that a substantial number of these buses would be greatly i
delayed, if not prohibited, from reaching the EPZ against the evacuation traffic flow. The KLD ETE further unreasonably assumes that evacuation buses traveling to the EPZ could travel 40 miles per hour on "at-grade primary highways," such as Route 1, and 50 miles per hour on access controlled roads. KLD #7, p.17. Anyone familiar with the routine bumper to bumper traffic on Route 1 during the year, and particularly the summer months, however, would recognize these 8
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estimates as wholly unrealistic. While recognizing that buses and vans l evacuating special f acilities "will be embedded within the overall l
! traf fic streams evacuating the EPZ," KLD #7, p.19, the ETE further unreasonably f ails to account f or the additional and substantial impact of these emergency vehicles, often traveling against the flow of traffic, in delaying the overall evacuation of vehicles f rom the EPZ.
KLD # 2, p.9. Further, the KLD ETE unreasonably calculates the time within which buses may travel evacuation routes to pick up passengers by assuming that all buses will travel with the flow of evacuating traf fic KLD #7, p.18. It must be assumed, however, that many of these buses will be required, albeit unsuccessf ully, to travel Against the flow of traffic to reach designated pickup locations. The ETE's calculations that buses may theref ore be expected to travel through evacuation traffic and to reach and load passengers at special f acilities within 40 minutes is plainly unrealistic. KLD 47, p.18.
- 8. The KLD ETE unreasonably relies upon inadequate data to compute the number of persons to be evacuated f rom the EPZ in the event of radiological emergency. First, KLD computes overall population figures based upon a " compromise estimate" of 2.8 persons per vehicle, although KLD concedes that it lacks " definitive data" on this issue.
KLD # 2, p.9. Second, as previously discussed, KLD relies upon a telephone survey of less than one percent of EPZ residents, without any determination that this sample is representative, to compute the number of residents and transients without private transportation. Third, KLD concedes that it has made no computations with respect to populations 9
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I l of special f acilities or private citizens with medical needs located within the EPZ. KLD #7, p.l. Fourth, KLD f ails to include within its a
population estimates the substantial number of individuals traveling through the EPZ, including the beach areas, at the time notification of an emergency may be given. KLD # 2, p.9. Accordingly, on its face, the i
KLD ETE lacks adequate data to compute the number of individuals or vehicles to be evacuated f rom the EPZ during an emergency. Without such reasonably adequate data, therefore, KLD's computations regarding time estimates to complete evacuation must seriously be called into question.
For reasons set forth above, the KLD ETE fails to provide reasonable assurance that adequate protective measures can or will be implemented in the event of radiological emergency.
Dated: May 23, 1986 Respectfu ly submitted SHAINES M E CHF,RN By:
Paul McEachern By: ,
Matthew T. Brock Attorneys for the Town of Hampton,NH l
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UNITED STATES OF AMERICA
! NUCLEAR REGULATORY COMMISSION i
} BEFORE. Tile ATOMIC SAFETY AND LICENSING BOARD i
In the matter of PUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL NEW HAMPSHIRE, et al. 50-444 OL I
(Seabrook Station, Units 1 and 2)
CERTIFICATE Qf SERVICE I hereby certify that copies of Memorandum on 10 CFR 52.714 (a)(1) and Revised Contention III of the Town of Hampton to Evacuation Time Estimate Report by T.L D Associates, Inc. in the above-captioned proceeding have been served on the following by deposit in the United States mail .on this 23rd day' of May,1986.
Helen Hoyt, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission East West Towers Building 4th Floor 4350 East West Highway Bethesdia, MD 20814 Dr. Jerry Harbour Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
1 SH AINES M ADRIGAN A Mc[ ACHERN Prost em%et a%Ocabo%
24 partswoODAvghet P o not wo . Poptguovite kee p )V'
i Beverly llollingworth i209 Winnacunnet Road
!Ilampton,NH 03842 i Sandra Gavutis, Chairman l Board of Selectmen RFD 1 Box 1154 l Route 107 lKensington,NH 03827 Dr. Emmeth A. Luebke Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Carol S. Snieder Assistant Attorney General Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 -
Stephen E. Merrill Attorney General George Dana Bisbee Office of the Attorney General 25 Capitol Street Concord NH 03301-6397 Richard A. Hampe, Esq.
New llampshire Civil Defense Agency 35 Pleasant Street Concord, NH 03301 Calvin A. Canney, City Manager City IIall 126 Daniel Street Portsmouth, Nil 03801 Roberta C. Pevear State Representative Town of flampton Falls Drinkwater Road flampton Falls, Nil 03844 2
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Robert A. Backus, Esq.
1 Backus, Meyer & Solomon 4 116 Lowell Street i
Manchester, NH 03106 Edward A. Thomas Federal Emergency Management Agency l 442 J.W. McCormack (POCH) i Boston, MA 02109 i
H. Joseph Flynn, Esq.
I Assistant General Counsel
!FederalEmergencyManagementAgency 500 C Street, S.W.
Washington, D.C. 20472 Jane Doughty Seacoast Anti-Pollution League 5 Market Street Portsmouth, NH 03801 Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission l Washington,D.C. 20555 i
l Allen Lampert Civil Defense Director Town of Brentwood 20 Franklin Street Exeter, NH 03833 Angie Machiros, Chairman Board of Selectmen 25 High Road Newbury, MA 01950 Jerard A. Croteau, Constable 82 Beach Road P.O. Box 5501 Salisbury, MA '01950 Diane Curran, Esq.
Harmon & Weiss 2001 S Street, N.W.
Suite 430 Washington, D.C. 20009 3
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Philip Ahrens, Esq.
! Assistant Attorney General
' Office of the Attorney General State House Station, #6 Augusta, ME 04333 l Thomas G. Dignan, Jr., Esq.
! Ropes & Gray 225 Franklin Street Boston, MA 02110 l Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docket and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i J.P. Nadeau, Esq.
Selectmen's Representative Board of Selectmen
- 10 Central Road l Rye, NH 03870 Michael Santosuosso, Chairman Board of Selectmen South Hampton, NH 01913 Stanley W. Knowles, Chairman Board of Selectmen &
P.O. Box 710 North Hampton, NH 03862 William Armstrong
' Civil Defense Director Town of Exeter 10 Front Street Exeter, NH 03833 Peter J. Matthews, Mayor City Hall Newburyport, MA 01950 i
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William s. Lord Board of Selectmen Town Hall - Friend Street Amesbury, MA 01913 Mrs. Anne E. Goodman, Chairman Board of Selectmen
! 13-15 Newmarket Road Durham, NH 03824 lGaryW. Holmes,Esq.
j Holmes & Ellis 47 Winnacunnet Road l Hampton, NH 03842 i
Sherwin E. Turk, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Tenth Floor
, 7735 Old Georgetown Road
, Bethesda, MD 20814 l
! Dated: May 23, 1986 Matthew T. Brock, Esq.
l 5
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