ML20137J199
| ML20137J199 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/14/1986 |
| From: | Gad R PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-786 OL, NUDOCS 8601220303 | |
| Download: ML20137J199 (5) | |
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DOCKEIED USMC UNITED STATES OF AMERICA'86 JR4 21 P1 :20 NUCLEAR REGULATORY COMMISSION,_____.;;....,
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before the m: A r:4 ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443-OL NEW HAMPSHIRE et al.
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50-444-OL
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(Seabrook Station,
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Off-Site EP Units 1 and 2)
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MOTION FOR THE ESTABLISHMENT OF A SCHEDULE The Applicants, having been informed that the New Hampshire state and local off-site emergency plans have been transmitted to FEMA and the NRC Staff, and that the Staff has served copies of these plans upon the parties, move that the Board establish a schedule for the submission of, response to and ruling upon contentions related to such plans, as follows:
i 8601220303 860114 PDR ADOCK 05000443 G
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Date Item Feb. 24, 1986 Conte ntions on State and Local Plans received.*
Mar. 14, 1986 Responses of any party other than Staff received.*
Mar. 21, 1986 Responses of Staff received.*
Apr. 1 & 2, 1986 Pre-hearing Conference to consider:
ruling on proposed contentions, consolidation of parties and issues, any other item set forth in 10 C.F.R. 5 2.752 and the Commission's Policy Statement (13 NRC 451).
- Means received by the-Board and the other parties in hand on the indicated date.
In support of this motion, the Applicants say as follows:
1.
The proposed schedule is reasonably consistent with the " relative deadlines" contained in the Board's Order of May 23, 1983.
2.
While the Applicants realize that certain contentions have been previously submitted, responded to and, in some cases, ruled upon in connection with prior drafts of some of these plans, the Applicants believe that the orderly admininistration of these proceedings would be advanced by permitting and requiring new contentions with respect to these plans - - -
and by dismissing as moot all prior contentions offered in respect of superceded plans.
(This procedure eliminates any need to compare old plans to new plans, or to interpret the extent to which any previously offered contentions might or might not have become moot 4
by intervening revisions to plans, and it will, we respectfully submit, eliminate any potential for misundertanding or confusion in the future.)
Respectfully submitted,
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Thomas G.
Dignan, Jr.
R.
K. Gad III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone:
423-6100 Dated:
January 14, 1986,
O CERTIFICATE OF SERVICE I,
R.
K. Gad III, one of the attorneys for the Applicants herein, hereby certify that on January 14, 1986, I made service of the within document by mailing copies thereof, postage prepaid, to:
Administrative Judge Helen Hoyt Administrative Judge Sheldon J.
Chairperson Wolfe, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Dr. Emmeth A.
Luebke Dr. Jerry Harbour Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commis: ion Commission Washington, DC 20555 Washington, DC 20555 Ms. Diana P.
Randall G. Dana Bisbee, Esquire 70 Collins Street Assistant Attorney General Seabrook, NH 03874 Office of the Attorney General 208 State House Annex Concord, NH 03301 William S.
Jordan, III, Esquire Robert G.
Perlis, Esquire Harmon, Weiss & Jordan Office of the Executive Legal Suite 430 Director 20001 S Street, N.W.
U.S.
Nuclear Regulatory Washington, DC 20009 Commission Washington, DC 20555 Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel 116 Lowell Street U.S.
Nuclear Regulatory P.O.
Box 516 Commission Manchester, NH 03105 Washington, DC 20555 Atomic Safety and Licensing Anne Verge, Chairperson Board Panel Board of Selectmen U.S. Nuclear Regulatory Town Hall Commission South Hampton, NH 03827 Washington, DC 20555
John McEachern, Esquire JoAnn Shotwell, Esquire Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue Department of the Attorney General P.O.
Box 360 One Ashburton Place, 19th Floor Portsmouth, NH 03801 Boston, MA 02108 Ms. Roberta C.
Pevear Mr. Patrick J. McKeon The Town of Hampton Falls Selectmen's Office Drinkwater Road 10 Central Road Hampton Falls, NH 03844 Rye, NH 03870 Mrs. Sandra Gavutis Mr. Calvin A.
Canney The Town of Kensington City Manager RFD 1 City Hall East Kingston, NH 03827 126 Daniel Street Portsmouth, NH 03801 Senator Gordon J.
Humphrey Mr. Angie Machiros U.S.
Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn:
Tom Burack)
Town of Newbury Newbury, MA 01950 Senator Gordon J.
Humphrey Mr. Richard E.
Sullivan 1 Pillsbury Street Mayor Concord, NH 03301 City Hall (Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Donald E. Chick Town Manager's Office Town Manager Town Hall Town of Exeter Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 Brian P.
Cassidy, Esquire Brentwood Board of Selectmen 4
Regional Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency - Region I 442 POCH Philip Ahrens, Esquire Boston, MA 02109 Assistant Attorney General Department of the Attorney General Augusta, ME 04333 Gary W.
Holmes, Esquire Holmes & Ells 47 Winnacunnet Road Hampton, NH 03841 4
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R.
K.
Gad, III.
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