ML20070C555
| ML20070C555 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/09/1982 |
| From: | Kinder E NEW HAMPSHIRE, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8212140227 | |
| Download: ML20070C555 (3) | |
Text
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UNITED STATES OF AMERICA f
NUCLEAR REGULATORY COMMISSIO :
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DEC.13 %
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Cthevergk Before the a
ATOMIC SAFETY AND LICENSING BOARD d\\
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In the matter of:
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PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE)
Docket Nos.:
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and
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50-444.
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(Seabrook Station, Units 1 and 2) i THE STATE OF NEW HAMPSHIRE'S MOTION TO FILE RESPONSIVE PLEADING REGARDING THE STATE'S MOTION TO COMPEL ANSWERS TO ITS FIRST SET OF INTERROGATORIES TO PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, INC. AND PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE'S RESPONSE THERETO On October 15, 1982, the State of New Hampshire (hereinafter the State) served Interrogatories and Requests for ProductionofDocumentsontheAfpQcant, Public Service I
Inc. / he2e'inaEEer Applicant).
On Company of New Hampshire, November 5, 1982, the State re'ceived Answers,to the Interrogatories and subsequ.tly on November 23, 1982, the
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Applicant produced the documents reque'sted.
On November 15, 1982, the State filed a Motion to Compel Answers alleging that the Applicant provided incomplete and evasive answers.
Although counsel for the State and counsel for the Applicant attempted to resolve the problems raised in s03 W
821214o227 e21209 PDR ADOCK 05000443 G
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/ the Motion to Compel, they were unable to do so in large measure because of the time constraints which required the filing of a answer to the Motion to Compel by the Applicant by December 3, 1982.
Based upon a telephone conversation with Applicant 's counsel on December 3, 1982 and based upon the Applicant's answer, the State wishes to file a responsive pleading which briefly clarifies the State's position and withdraws the Motion to Compel with regard to several of the Interrogatories at issue.
Therefore, the State respectfully requests that this Board accept the State's attached response to the Applicant's answer to the State's Motion to' Compel.
Respectfully submitted, THE STATE OF NEW HAMPSHIRE GREGORY H. SMITH ATTORNEY GENERAL cm By
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E. Tupper Kinder Assistant Attorney General Environmental Protection Div.
Office of Attorney General State House Annex Concord, New Hampshire 03301 603/271-3678 Dated:
December 9, 1982
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Tupper Kinder, Esquire, do h th day oft of the foregoing Motion has been maile December, 1982, by first class mail, po ge gret$i i t[o:
e.QW Helen F.
Hoyt, Chm.
Dr. E m m'e t. 'A. _ L u e b k e Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. NRC U. S.. NRC Washington, D.C.
20555 Washington, D.C. 20555 Dr. Jerry Harbor Jo Ann Shotwell, Asst. AG Administrative Judge
~ Office of the Attorney General Atomic Safety and Licensing One Ashburton Place, 19th Floor Board Panel Boston, MA 02108 U.S. NRC Washington, D.C.
20555 Mrs. Beverly Hollingsworth 822 Lafayette Road Roy P. Lessy, Jr.,
Esquire P.O. Box 596 Robert Perliss, Esquire Hampton, New Hampshire 03842 Office of Executive Legal Dir.
U.S. NRC William S. Jordan, II, Esquire Washington, D.C.
20555 Ellyn R. Weiss, Esquire Harmon and Weiss Robert A.
Backus, Esquire 1725 I Street, N.W.
116 Lowell Street Suite 506 P.O. Box 516 Washington, D.C.
20006 Manchester, N.II.
03105 Edward J. McDermott, Esquire Phillip Ahrens, Esquire Sanders and McDermott Assistant Attorney General 408 Lafayette Road State House, Station #6
- Hampton, N.H.
03842 Augusta, Maine 04333 Atomic Safety and Licensing Thomas G.
- Dignan, Jr.,
Esquire Board Panel Ropes and Gray U.S. NRC 225 Franklin Street Washington, D.C.
20555 Boston, Massachusetts 02110 m
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Tupper Kiriddr V 4 Dated:
December 9, 19 8.
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