ML20012C718
| ML20012C718 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/16/1990 |
| From: | Reis E NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#190-10104 LBP-89-17, LBP-89-32, OL, NUDOCS 9003230112 | |
| Download: ML20012C718 (5) | |
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USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOAR $h h h h h imi tp In the htter of Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF 50-444 OL NEW HAMPSHIRE, e,t_ g.
Off-site Emergency Planning
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(Seabrook Station, Units 1 and 2)
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NRS i,TAFF MOTION FOR A TWO DAY EXTENSION OF TIME TO RESPOND TO BRIEF ON APPEAL OF LBP-89-32 AND LBP-89-17 The NRC Staff hereby moves for a two (2) day extension until March 21, 1990, to file its brief in response to briefs filed on appeal of LBP-89-32 and LBP 89-17. The Staff had previously been granted a one week extension of time to file this response.
This additional two day extension is necessary because of the large amount of work in connection with the Seabrook facility has rendered it practically impossible to complete this brief in the scheduled time. The scheduled work of this week on this brief, as well as the week before, was severely disrupted by hearings on March 14, 1990, before the Subcommittee on General Oversight and Investigations of the House of Representatives' Committee on Interior and Insular Affairs and by responding to allegations concerning the facilities readiness to receive a license.
The NRC Staff has contacted or attempted to contact all parties who have filed briefs on this appeal.
It has been advised by attorneys for the l-Massachusetts Attorney General, the City of Newburyport, the Towns of l
Hampton, Newbury, Amesbury and Salisbury, the New England Coalition on Nuclear Pollution and the Applicants that they have no objection to this extension of time. The Staff has also attempted to contact the attorneys DRBIG HTED QBISIEAR 4
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L for the. Seacoast Anti-Pollution League and the Town of West Newbury to advise them of this motion, but has been unable to connunicate with them.
For the above-stated reason the NRC Staff requests a two (2) day extension to file the subject brief.
Respectfully submitted, h5/
Edwin J. Reis Deputy Assistant General Counsel for Reactor Licensing i
Dated at Rockville Maryland l
this 16th day of March 1990 t
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um UNITED ST;.TES OF AMERICA NUCLEAR REGULATORY COMMIS$10N BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of crNCE N sicarTARY Docket Nos. 50I4WOQQJ'M PUBLIC SERVICE COMPAi,Y OF 50-444 OL NEW HAMPSHIRE, g al.
Off-site Emergency Planning (SeabrookStation, Units 1and2)
CERTIFICATE OF SERVICE I
I hereby certify that copies of "NRC STAFF MOTION FOR A TWO DAY EXTENSION OF TIME TO RESPOND TO BRIEF ON APPEAL OF LBP-89-32 AND LBP-89-17" in the above captioned proceeding have been served on the following by deposit in the United States mail, first c1 Ass or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, as indicated by double asterisks, by express mail, this 16th day of March 1990:
IvanW. Smith, Chairman (2)*
Peter Brann, Esq.
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Comission State House Station 6 Washington, DC 20555 Augusta, ME 04333 Richard F. Cole
- John Traficonte. Esq.**
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place, 19th Floor Washington, DC 20555 Boston, MA 02108 Kenneth A. McCollom**
Geoffrey Huntington, Esq.**
Administrative Judge Assistant Attorney General 1107 West Knapp Street Office of the Attorney General Stillwater, OK 14075 25 Capitol-Street l
Concord, NH 03301 Thomas G. Dignan, Jr., Etq.**
Robert K. Gad, III, Esq.
Diane Curran E q.**
Ropes & Gray Harmon, Curran & Tousley One International Place 2001 S Street, NW Boston, MA 02110 2624 Suite 430 Washington, DC 20009
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Robert A. Backus, Esq.**
Jack Dolan Backus, Meyer & Solomon Federal Emergency Management Agency
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116 Lowell Street Region !
Manchester, NH 03106 J.W. McConneck Post Office &
l Courthouse Building, Room 442 Boston, MA 02109 H. J. Flynn, Esq.
Judith H. Mizner, Esq.
Assistant General Counsel 79 State Street Federal Emergency Management Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Robert Carrigg, Chairman Board of Selectmen Paul McEachern Esq.**
Town Office Shaines & McEachern Atlantic Avenue 25 Maplewood Avenue North Hampton, NH 03862
'P.O. Box 360 Portsmouth, NH 03801 Mrs. Anne E. Goodman, Chairman Board of Selectmen George Hahn, Esq.
13-15 Newmarket Road Attorney for the Examiner Durham, NH 03824 Hahn & Hesson 350 Sth Ave Suite 3700 Hon. Gordon J. Humphrey New York, NY 10118 United States Senate 531 Hart Senate Office Building R. Scott Hill-Whilton, Esq.
Washington, DC 20510 Suzanne P. Egan, Esq.
Lagoulis, Hill-Whilton
& Rotondi Richard R. Donovan 79 State Street Federal Emergency Management Agency Newburyport, MA 01950 Federal Regional Center 130 228th Street, S.W.
Allen Lampert Bothell, Washington 98021-9796 Civil Defense Director Town of Brentwood Peter J. Matthews, Mayor 20 Franklin City Hall Exeter, NH M833 Newburyport, MA 01950 William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter, NH 03833 South Hampton, NH 03E27 10 Front Street Exeter, NH 03833 Ashod N. Amirian, Esq.
Town Counsel for Merrimac Gary W. Holmes. Esq.
145 South Main Strees; Holmes & Ellis P.O. Box 38 47 Winnacunnet Road Bradford, MA 01835 Hampton, NH 03842 Barbara J. Saint Andre, Esq.
Kopelman and Paige, P.C.
77 Frankin Street Boston, MA 02110
O. o 3-Ms. Suzanne Breiseth George Iverson, Director Board of Selectmen NH Office of Emergency Management Town of Hampton Falls State House Office Park South Drinkwater Road 107 Pleasant Street Hampton Falls, NH 03844 Cont.ord, NH 03301 Atomic Safety and Licensing Robert R. Pierce Esq.*
Board Panel (1)*
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Secretary (2)*
U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Washington, DC 20555 Appeal Panel (6)*
Attn: Docketing and Service Section U.S. Nuclear Regulatory Comission Washington, DC 20555 fh+3 l*
Edwin J. Re)f Deputy Assistant General Counsel for Reactor Licensing l