ML20148H916
| ML20148H916 | |
| Person / Time | |
|---|---|
| Site: | Seabrook |
| Issue date: | 01/20/1988 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#188-5420 OL-1, NUDOCS 8801270328 | |
| Download: ML20148H916 (5) | |
Text
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January 20, 19dI!PgETED p
UNITED STATES OF AMERICA
'88 JAN 26 P2:20 NUCLEAR REGULATORY COMMISSION OFFICE OF SECAr 1Asv before the DOCKET tr& Eitvict-ATOMIC SAFETY AND LICENSING APPEAL BOARD
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In the Matter of
)
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 5 0-4 4 3 -OL-1 NEW HAMPSHIRE, et al.
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50-4 4 4 -OL-1
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(Onsite Emergency (Seabrook Station, Units 1 and 2)
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Planning and Safety
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Issues)
APPLICANTS' REQUEST FOR A FURTHER EXTENSION OF TIME TO FILE THEIR OPPOSITION TO MOTION OF ATTORMEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS TO ADMIT LATE-FILED CONTENTION AND REOPEN THE RECORD Applicants request an extension of time to February 22, 1988 to file their opposition to the motion of the Attorney General for the Commonwealth of Massachusetts ("Mass. AG") to admit his late-filed contention on the notifi* cation system for Massachusetts and reopen the record.
This Appeal Board previously granted Applicants an extension of time to January 26, 1988.
Applicants are currently developing alternatives to fixed sirens for early notification and clear instruction to the populace in the Massachusetts communities within the Seabrook EPZ and believe those plans would be germane to the SBS LOSER SS0h!A 5
b9
I Mass. AG's motion.
Regarding Mass. AG's motion to reopen on the Newburyport sirens issue, the NRC Staff has suggested that this Appeal Board defer ruling until Applicants submit fuller alternative notification plans, taking into account the loss of fixed sirens in neighboring Massachusetts towns.
Applicants expect to have their plans developed and ready for submission by February 22, 1988 and therefore request this further extension of time to that date.
Applicants are informed that Mass. AG does not assent and that the Staff does assent to this request.
By their attorneys, p
Thomas G."Dignan, Jr.
Kathryn A. Selleck Martha Siegel Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 __
00CKEYE0 USNRc
'88 JW 26 P2:20
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CERTIFICATE OF SERVICE oneoftheattornh[h"fM'AM I, Thomas G.
Dignan, Jr.,
Applicants herein, hereby certify that on January 20pR S,8,dE made service of the within document by depositing copies thereof with Federal Evoress, prepaid, for delivery to (or where indicated, by depositing in the United States mail, first class, postage paid, addressed to):
Alan S.
Rosenthal, Chairman Howard A.
Wilber Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Panel U.
S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Thomas S.
Moore Mr. Ed Thomas Atomic Safety and Licensing FEMA, Region I Appeal Panel 442 John W. McCormack Post U.S.
Nuclear Regulatory Office and Court House Commission Post Office Square East West Towers Building Boston, MA 02109 4350 East West Highway Bethesda, MD 20814 Administrative Judge Sheldon J.
Robert Carrigg, Chairman Wolfe, Esquire, Chairman Board of Selectmen Atomic Safety and Licensing Town Office Board Panel Atlantic Avenue U.S.
Nuclear Regulatory North Hampton, NH 03862 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Judge Emmeth A.
Luebke Diane Curran, Esquire Atomic Safety and Licensing Andrea C.
Ferster, Esquire Board Panel Harmon & Weiss 5500 Friendship Boulevard Suite 430 Apartment 1923N 2001 S Street, N.W.
l Chevy Chase, MD 20815 Washington, DC 20009 l
l Dr. Jerry Harbour Stephen E. Merrill, Esquire Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee, Esquire U.S.
Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street l
4350 East West Highway Concord, NH 03301-6397 i
Bethesda, MD 20814
Atomic Safety and Licensing Sherwin E.
Turk, Esquire Board Panel Office of General Counsel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission East West Towers Building 15th Floor 4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852
- Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S.
Nuclear Regulatory 116 Lowell Street Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Mr.
J.
P.
Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S.
Sneider, Esquire Matthew T.
Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney 25 Maplewood Avenue General P.O.
Box 360 One Ashburton Place, 19th Flr.
Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A.
Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
- 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
- Senator Gordon J. Humphrey Mr. Peter S.
Matthews One Eagle Square, Suite 507 Mayor l
Concord, NH 03301 City Hall l
(Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F.
Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 1
10 Front Street Amesbury, MA 01913 Exeter, NH 03833 I
-2 I
l
H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
Wash!.ngton, DC 20472 Gary W.
Holmes, Esquire Richard A. Hampe,' Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 Judith H. Mizner, Esquire Charles P.
Graham, Esquire Silverglate, Gertner, Baker, McKay, Murphy and Graham Fine, Good & Mizner 100 Main Street 88 Broad Street Amesbury, MA 01913 Boston, MA 02110 C
n,/
Thomas G.
DJ1jnan, Jr.
(*=U.S. First Class Mail.)
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