ML20054C126

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Suppl to New England Coalition on Nuclear Pollution 820402 Request for Clarification of Schedule for Filing Contentions.Intervenor Does Not View NRC Counsel as Having Created or Added to Any Confusion.Certificate of Svc Encl
ML20054C126
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 04/14/1982
From: Jordan W
HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8204200082
Download: ML20054C126 (4)


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'82 f.P 16 T01 :24' UNITED STATES OF AMERICA SlQ NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD /

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SUPPLEMENT TO NECNP REQUEST FOR CLARIFICATION OR EXTENSION Ih the last paragraph of NECNP Request for Clarification of Schedule for Filing Contentions or for an Extension of Time, filed April 2, 1982, we made the following statement:

As a result of the confusion which has arisen from the recent informal conversation between NRC staff attorney Roy Lessy and the Board Chairman, NECNP requests clarification of the Board's schedule.

Upon reflection, we are concerned that this language l

may create a misimpression concerning the role of NRC Staff l

1 Counsel or his responsibility for confusion that has developed l

concerning the schedule for filing contentions.

Accordingly, NECNP emphasizes that it does not view NRC Staff Counsel

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as having contributed to or created any confusion.

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contrary, we understand he approached the Board Chairman 1

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after having been contacted by other parties who were uncertain about the schedule.

Since the parties agreed, this appears to have been a proper, and indeed, helpful action on his part.

The confusion arose from NECNP's point of view only when NRC Staff Counsel relayed the results of his conversa-tion.

He reported, we understand accurately, that the Board Chairman considered the contentions to be due on April 6, 1982.

Until that time, we had no reason to be confused since the Order, when read in conjunction with the regulations, did not establish a special early deadline for the supplemental contention filing.

As a result, we had previously concluded that contentions were due on April 21 pursuant to 10 CFR 2.714(b).

The contact between NRC Staff Counsel and the Board Chairman served to inform us that the Board apparently had a contrary interpretation, which allowed NECNP to notify the Board of the conflicting views.

We trust that this will also allow the Board and the parties to undertake any reordering of the hearing or filing schedule that may be necessary to assure both thorough and efficient consideration of the proposed contentions.

Respectfully submitted,

-~s>f&. x William Mordan, III Dated:

April 14, 1982 HARMON & WEISS 1725 I Street, N.W.

Suite 506 Washington, D.C.

20006 (202) 833-9070

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COf9tISSION BEFORE Tile ATOMIC SAFETY AND LICENSING llOAHD

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In the Matter of

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PUBLIC SERVICE COMPANY OF

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NEW HAMPSHIRE, et al.,

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Docket Nos.

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(Seabrook Station Units 1 and 2)

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50-433 OL

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50-444 OL

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CERTIFICATE OF SERVICE I hereby certify that copies the the SUPPLEMENT TO NECNP REQUEST FOR CLARIFICATION OR EXTENSION in the above captioned proceeding have been served on the following by deposit in the United States mail, first class, this 14th day of April, 1982.

l itelen Hoyt, Esq., Chairman Docketin<l Service Section Atomic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Robert L. Chiesa, Esq.

Paula Gold, Asst. Atty. General Wadleigh, Starr, Peters, Dunn Stephen M.

Leonard, Asst. Atty.

& Kohls Jo Ann Shotwell, Asst. Atty.

95 Market Street Office of the Atorney General Manchester, Nil 03101 Environnental Protection Div.

one Asburton Place, 19th Floor Lynn Chong noston, MA 02108 Bill Corkum Gary McCool Nicholas J. Costello Box 65 1st Essex District Plymouth, NH 03264 Whitehall Road Amesbury, MA 01913 E. Tupper Kinder, Esq.

Assistant Attorney General Tomlin P.

Kendrick Environmental Protection Division 822 Lafayette Road Office of the Attorney General P.O.

Box 596 State llouse Annex Ilampton, Nil 03842 Concord, NH 03301

Robert A. Backua, Ecq.

Rep. Arnie Wight 116 Lowell Strsot Stato of New flXmpshire P.O.

Inox 516 Ilouse of liepresentatives Manchester, NH 03105 Concord, Nil 03101 Phillip Ahrens, Esq.

Paul A. Fritzche, Esq.

Assistant Attorney General Public Advocate State llouse Station 66 State llouse Station #12 Augusta, i1E 04333 Augusta, MC 04333 Wilfred L. Sanders, Esq.

Donald L. lierzberger, MD Sanders and McDermott Hitchcock llospital 408 Lafayette Road llanover, fHI 01755 llampton, Nil 03842 Thomas G. Dignan, Jr., Esq.

Edward J. McDermott, Esq.

Ropes 6 Gray Sanders and McDermott 225 Franklin Street 408 Lafayette Road Boston, MA 02110 llampton, Nil 03842 Sen. Rolmrt I..

Preston Mr. Robert F.

Preston State of New Ilanpahire 226 Winnacunnet Road Senate llampton, NH 03842 Concord, Nil 03301 Dr. Emmeth A. Luebke Administrative J.udge Dr. Oscar H. Paris Atomic Safety and Licensing Administrative Judge Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C. 20555 Cooperative Members for IW Isssy, Esq.

Responsible Investment U.S. Nuclear Regulatory Consnission Box 65 Washinjton, D.C.

20555 Plymouth, NH 03264 Atomic Safety and Licensing Ms. Patti Jacobson Board Panel 3 Orange Street U.S. Nuclear Regulatory Commission Newburyport, MA 01950 Wash'ington, D.C.

20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555

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Date:

April 14, 1982 William S.' Jordan, III

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