ML20155D004

Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position

ML20155D004
Person / Time
Site:	Seabrook
Issue date:	10/30/1998
From:	Repka D NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO), WINSTON & STRAWN
To:	NRC COMMISSION (OCM)
Shared Package
ML20155D007	List: ML20155D004 ML20155D012
References
CON-#498-19683 CLI-98-18, LA, LA-2, NUDOCS 9811030082
Download: ML20155D004 (2)

Text

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00CKETED U*dEber 30,1998 l

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFiG; F R: ,

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BEFORE THE COMMISSION i

In the Matter of

)

)

North Atlantic Energy Service Corporation )

Docket Nos. 50-443-LA

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

MQIION FOR I F AVE TO FII F REPT V On October 15,1998, pursuant to 10 C.F.R. 2.107(a), North Atlantic Energy Service I

Corporation ("NAESCO"), the applicant in the above-captioned proceedings, filed a motion requesting issuance of an order terminating these two proceedings. NAESCO also stated its that the issues raised in the Commission's Order of September 17,1998, CLI-98-18, are moot.

On October 26,1998, Seacoast Anti-Pollution League ("SAPL") and New England Coalition on Nuclear Pollution ("NECNP"), the petitioners to intervene with respect to these ma filed a response to NAESCO's motion, stating a qualified objection to termination of the pro The petitioners oppose " mooting of this proceeding, unless the Commission provides another forum for development of policy guidance on how licensees should present requests to amend technical specifications so as to assure the Commission can review related changes to assure all safety iss are properly resolved in favor of the public health and safety."

The petitioners have raised a novel issue affecting this proceeding and the interests i

l of NAESCO. Accordingly, NAESCO requests leave to file the attached reply to the petitioners' 9811030002 981030 PDR

• ADOCK 05000443 eor gog

response. NAESCO believes this reply is necessary to assure that the Commission is fully aware of NAESCO's position on this matter.

Respectfuuy oubmitted, l i

db I-4 David A. Repka I WINSTON & STRAWN 1400 L Street, N.W.

Washington, D.C. 20005-3502 (202) 371-5726  !

Lillian M. Cuoco NORTHEAST UTILITIES SERVICE COMPANY l 107 Selder Street Berlin, Connecticut 006037 ATTORNEYS FOR NORTH ATLANTIC ENERGY SERVICE CORPORATION Dated in Washington, D.C.

this 30th day of October,1998 r-I

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