ML20153H447

Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc

ML20153H447
Person / Time
Site:	Seabrook
Issue date:	10/01/1998
From:	Repka D NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO), WINSTON & STRAWN
To:	NRC COMMISSION (OCM)
References
CON-#498-19588, CON-#498-19589 CLI-98-18, LA, LA-2, NUDOCS 9810020048
Download: ML20153H447 (4)

Text

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/ 9 58 DOCKETED NcYber 1,1998 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIg . ,

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BEFORE THE COMMISSION l i

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North Atlantic Energy Service Corporation ) Docket Nos. 50-443-LA 3

) 50-443-LA-2 (Seabrook Station) ) i JOINT MOTION FOR SCHFDIII F DEFERRAT_

North Atlantic Energy Service Corporation ("NAESCO"), Seacoast Anti-Pollution League ("S APL"), and New England Coalition on Nuclear Pollution ("NECNP") (collectively, "the Parties") jointly request a temporary deferral of the briefing schedule as established by the Commission's Order ofSeptember 17,1998 (CLI-98-18). The Parties request this deferral in order to accommodate further discussions ofpossible settlement of these two proceedings. The Parties respectfully request that the briefing schedule be deferred initially by two weeks. If the Parties can agree to terms in that time and submit a settlement agreement for Commission approval pursuant to 10 C.F.R. 2.203, the briefing schedule would be further deferred pending Commission action on the agreement.

The Parties believe that this schedule deferral is in their individual best interests as well as the public interest. While a settlement agreement is not a certainty, the discussions are at a point such that the Parties believe that settlement is possible, and that the resources of the Parties are best spent on the negotiations rather than the preparation oflegal briefs. Moreover, at this time the 9810020048 981001 #

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4 i impact of the deferral on the overall schedule for the proceeding is small and acceptable. The Parties l will also keep the Commission informed on their progress on this matter.

Counsel for SAPL and NECNP has reviewed this Motion, has consented to it, and has authorized the undersigned to submit it as ajoint motion on behalf of the Parties.

Counsel for the undersigned has also discussed this matter with counsel for the NRC Staff. The NRC Staff has indicated that it has no objection to the proposed deferral with the understanding that it would apply to the Staff as well.

l Respectfully submitted, k k David A. Repka D

WINSTON & STRAWN 1400 L Street, N.W.

Washington, D.C. 20005-3502 .

i (202) 371-5726 ATTORNEYS FOR NORTH ATLANTIC ENERGY SERVICE CORPORATION Dated in Washington, D.C. i this 1st day of October,1998  ;

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O DOCKETEO USHRC  !

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g g _) p4 3g BEFORE THE COMMISSION OFK C c' ' t .,

RLU).9 s WJ i ADJUD'C.4 , SL:J:F In the Matter of )

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North Atlantic Energy Service Corporation ) Docket Nos. 50-443-LA

) 50-443-LA-2 (Seabrook Station) ) )

CERTIFICATE OF SERVICE I hereby certify that copies of" JOINT MOTION FOR SCHEDULE DEFERRAL" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk (*) by hand delivery service, or as marked by two asterisks (**), by ovemight delivery, this 1st day of October,1998. For those parties marked by a diamond (0), a copy has also been provided this same day by e-mail.

Chairman Shirley Ann Jackson

• B. Paul Cotter, Jr.*O U.S. Nuclear Regulatory Commission Chairman One White Flint North Atomic Safety and Licensing Board 11555 Rockville Pike U.S. Nuclear Regulatory Commission Rockville, Maryland 20852-2738 Two White Flint North 11545 Rockville Pike Rockville, Maryland 20852-2738 Commissioner Nils J. Diaz* Dr. Charles N. Kelber*0 U.S. Nuclear Regulatory Commission Administrative Judge One White Flint North Atomic Safety and Licensing Board 11555 Rockville Pike U.S. Nuclear Regulatory Commission Rockville, Maryland 20852-2738 Two White Flint North 11545 Rockville Pike Rockville, Maryland 20842-2738 Commissioner Edward McGaffigan, Jr.* Linda W. Little**O U.S. Nuclear Regulatory Commission 5000 Hermitage Drive One White Flint North Raleigh, NC 27612 11555 Rockville Pike Rockville, Maryland 20852-2738

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L Office of the Secretary *0 Steven R. Hom, Esq.*0 U.S. Nuclear Regulatory Commission Office of the General Counsel One White Flint North U.S. Nuclear Regulatory Commission 4 11555 Rockville Pike One White Flint North '

Rockville, Maryland 20852-2738 11555 Rockville Pike Attn: Docketing and Service Station Rockville, Maryland 20852-2738

'(original A two copies)

Robert A.Backus** Office ofCommission Appellate Adjudication

• Backus, Meyer, Solomon, U.S. Nuclear Regulatory Commission Rood & Branch One White Flint North 116 Lowell Street 11555 Rockville Pike P.O. Box 516 Rockville, Maryland 20852-2738 Manchester, NH 03105-0516 Adjudicatory File Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission

- Washington, DC 20555 i

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David A.Repka \

N l Winston & Strawn Counsel for North Atlantic Energy Senice Corporation I i:

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