ML20033A831
| ML20033A831 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/18/1981 |
| From: | Sanders W SANDERS & MCDERMOTT |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20033A829 | List: |
| References | |
| NUDOCS 8111300004 | |
| Download: ML20033A831 (3) | |
Text
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PR0D. & UTIL FAC.s. m1 1 -
e CigI..ED UNITED STATES OF AMERICA *8]
NOV 24 P3:56 NUCLEAR REGULATORY COMMISSION g
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ai%CH In the Matter of
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Docket PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ET AL
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Nos. 50-443
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and 50-444 (Seabrook Station, Units 1 and 2)
)
PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR HEARING NOW COMES WILFRED L.
- SANDERS, JR.,
Attorney for SUN VALLEY ASSOCIATION, of Hampton, County of Rockingham and State of New Hampshire, and petitions to intervene generally pursuant to 10 C.
F.
R.
2.714 upon the following bases and terms :
1.
The application of Public Service Company of New Hampshire for operating licenses for Seabrook Nuclear Stations 1 and 2 was docketed by the Nuclear Regulatory Commission on October 5, 1981.
Petitions for Intervention were required to be filed by November 18, 1981.
2.
The Petitioner is an association comprising of 1
l fifty (50) homeowners a' Seabrook Beach in Hampton, New Hampshire which proportie's are located a very close proximity i
to the Seabrook Station.
l S ANDERS & McDERMOTT. PROFESSIONAL ASSOCIATION. ATTORN=YS AT LAW 8111300004 Bill 18
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PDR ADOCK 05000443 C
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3.
The Seabrook Station facility wil-1 be located in the Seacoast area of New Hampshire, namely Seabrook, within ancillary portions located in several towns in the State of New Hanipshire.
Operation of the facility will have an effect on the health, safety and welfare of the citizens who reside in the vicinity of the f acility site.
4.
Any order in the proceedings will effect the entire Sta'e, but particularly the Seacoast area, a major t
tourist area, responsible for providing employment and business opportunities to thousands of citizens.
5.
The Petitioner further expresses intense interest in the final determinaton of evacuation procedures as it affects the health and safety of upwards of 100,000 people within a one to two mile radius of the planned facility.
Any such impact from a health, safety, and economic point of view is of concern to the above Petitioner.
6.
The Petitioner requests the right to address the above and other concerns as they relate to operating licenses for this Seabrook Nuclear Facility.
RESPECTFULLY SUBMITTED, f
SUN VALLEY ASSOCIATION BY ITS ATTORNEYS, SANDERS AND McDERMOTT PROFESSIO ASSOCIATI rf////
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B W
f' red k ? Sanders,'Jr.
. SANDERS & &"cDERMOTT PROFESSION AL ASSOCIATION
- ATTORNEYS AT LAW 408 LAPAYETTE ROAD = HAMPTON. NEW H AMPSHIRE 03842
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't unf OI M24 P3:56 FlO CERTIFICATE OF SERVICE
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I, Wilfrei L.
Sanders, Jr., Attorney for Sun Valley Association, hereby certify that a copy of the foregoing Petition for Leave to Intervene ar.d Request for Hearing has been mailed to Executive Legal Directe/:, United States Regulatory Commission and Thomas G.
Dignan, Esquire, Ropes &
Gray.
DATED:
November 18, 1981
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Wilf red 'L ' Sanders $- Jr.
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O S ANDER S & McDERMOTT. PROFESSION AL ASSCCIATION e ATTORNE*. S AT LAW 408 LAFAYETTL ROAD = HAMPTON. NEW HAMPSHIRE 038# J m