ML20080K541
| ML20080K541 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/26/1983 |
| From: | Dignan T, Gad R PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8309290217 | |
| Download: ML20080K541 (4) | |
Text
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Dattd:
Scptemb2r 26, 1983 i
90CMETED USNRC 13 SP 28 P453 UNITED STATES OF AMERICA CrricE cr EEcpyn NUCLEAR REGULATORY COMMISSI6FUy'g'=,jdG' '
before the ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY OF NEW
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Docket Nos. 50-443 HAMPSHIRE, et al.
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50-444
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(Seabrook Station, Units 1 & 2)
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APPLICANTS' RESPONSE TO SAPL*S OBJECTIONS TO BOARD ORDER RULING ON ADMISSIBILITY OF CONTENTIONS ON THE NEW HAMPSHIRE RERP AND MOTION FOR RECONSIDERATION By motion filed under date of September 14, 1983 SAPL seeks reconsideration of this Board's rulings with respect to five contentions proposed by SAPL and rejected by the Board.
Applicants can add little to what was said in the Board's Order with respect to the Board's original rulings which the Applicants believe were correct.
In addition what SAPL appears to be doing is arguing that it would ignore this Board's early and oft-expressed view that while acknowledging its power to do so, the Board would not redraft contentions for parties but rule on them as stated.
8309290217 030926 PDR ADOCK 05000 4
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4 There has been no secret about this from the outset and SAPL acted at its peril in standing on its language.
In addition, contrary to SAPL's assertion, the Board's requirements of specificity result in no improper shift of burden.
The applicant has the burden of proof; but the intervenor has the burden of drafting contentions with specificity.
SAPL has failed to meet this burden.
Respectfull mitted frCJnc Thomas G.
Dignan, Jr.
R.
K.
Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100
i CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr.,
one of the attorneys for the Applicants herein, hereby certify that on September 26, 1983, I made service of the within document by mailing copies thereof, postage prepaid, to:
Helen Hoyt, Chairperson Brian P. Cassidy, Esquire Atomic Safety and Licensing Regional Counsel Board Panel Federal Emergency Management U.S. Nuclear Regulatory Commission Agency - Region I Washington, D.C.
20555 442 POCH Boston, MA 02109 Dr. Emmeth A.
Luebke William S. Jordan, III, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 1725 I Street, N.W.
U.S. Nuclear Regulatory Commission Suite 506 Washington, DC 20555' Washington, DC 20006 Dr. Jerry Harbour George Dana Bisbee, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Office of the Attorney General U.S. Nuclear Regulatory Commission 208 State House Annex Washington, DC 20555 Concord, NH 03301 Atomic Safety and Licensing Roy P.
- Lessy, Jr., Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Robert A.
Backus, Ecquire Board Panel 116 Lowell Street U.S. Nuclear Regulatory Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Anne Verge, Chairperson Assistant Attorney General Board of Selectmen Department of the Attorney Town Hall General South Hampton, NH Augusta, ME 04333 David R.
Lewis, Esquire Jo Ann Shotwell, Esquire Atomic Safety and Licensing Assistant Attorney General i
Board Environmental Protection Bureau U.S. Nuclear Regulatory Commission Department of the Attorney General l
Washington, DC 20555 One Ashburton Place, 19th Floor Boston, MA 02108 Mr. Charles Cross, Esq.
Brentwood Board of Selectmen Shaines, Madrigan, & McEachern R.F.D., Dalton Road l
25 Maplewood Avenue Brentwood, NH 03833 j
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P.O.
Box 366 I
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s Portsmouth, NH 03801 State Rep. Roberta C.
Pevear Calvin A. Canney, City Manager Drinkwa"er Road City Hall, 126 Daniel Street Hampton Falls, NH 03844 Portsmouth, NH '03801 Mrs. Sandra Gavutis Mr. Patrick J. McKeon RFD 1 Selectmen's Office East Kingston, NH 03827 10 Central Road Rye, NH 03870 Senator Gordon J. Humphrey Mr. Angie Machiros U.S.
Senate Chairman of the Board of Washington, DC 20510 Selectmen (Attn:
Tom Burack)
Town of Newbury Newbury, MA 01950 Town Manager's Office Richard E. Sullivan, Mayor Town Hall - Friend Street City Hall Amesbury, MA 01913 Newburyport, MA 01950 Ms. Diana P. Randall Donald E. Chick, Town Manager 70 Collins Street Town of Exeter Seabrook, NH 03874 10 Front Street Exeter, NH 03833 Senator Gordon J. Humphrey one Pillsbury Street Concord, NH 03301 (Attn:
Herb Boynton) s p
[ L-f M.L V Thomas G.
D).afttan, Jr.
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