ML20059M604
| ML20059M604 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/24/1990 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20059M606 | List: |
| References | |
| CON-#490-10850 OL, NUDOCS 9010050090 | |
| Download: ML20059M604 (2) | |
Text
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USNRC 1:
Septemberg4,dT All :10 UNITED STATES OF AMERICA
?U!CE DT SECiti1ARY before the-00CKL NJG 3 'ONICIT iwtdwi NUCLEAR REGULATORY COMMISSION.
In the Matter of PUBLIC SERVICE COMPANY _
Docket Nos. 50-443-OL
- OF. NEW HAMPSHIRE, at al.
50-444-OL (Seabrook Station, Units 1 (Offsite Emergency and 2)
Planning and Safety Issues)
LICEN8EE8' REPLY TO INTERVENORS'-MOTION TO FILE "8UPPLEMENTAL AFFIDAVIT IN SUPPORT:OF-p EMERGENCY-MOTION TO RE-OPEN THE. RECORD ON.
THE ADEQUACY OF THE-8TAFFING OF'THE NHRERP.
AND - FOR' INMEDIATE - SHUTDOWN I
c-1 Under - date of,SeptemberL 7, 1990. SAPL has filed-a motion forl
. leave to file a supplemental affidavit in support of a' motion now pending.before the Commission to reopen the record in!this rproceeding:and for an immediate shutdown of Seabrook1 Nuclear, Power Station.
The Motion is not authorized by the rules of
-: practice.
Moreover the affidavit.it seeks to introduce is not a-Ef a ctual.. a f fidavit, but rather is an exercise.in hearsay and 1
' argument which reads more like a brief than an affidavit.
Therefore the Motion should be denied.
However, Licensees recognize that the acceptance of this filing.is a matter committed to the sound discretion of the
.STAntKPL,58 4
9010050090 900924
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PDR ADOCK 05000443 O
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Commission and, in-the event that that discretion should be exercised in favor'of accepting the affidavit, Licensees move that'the commission also accept and consider the Affidsvit of
~
George L.
Iverson attached hereto, which addresses the Supplemental Af fidavit which is the subject of the Motion.
Respectfully submitted, 7Q '
/YY!
^
1aomas G. Agnan, Jr.
Jeffrey 7. Trout Ropes & Gray One International Place Boston, MA 02110-2624 (617) 951-7000
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Counsel for Licensees
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