ML20155G907
| ML20155G907 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/07/1988 |
| From: | Traficonte J HAMPTON, NH, MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20155G910 | List: |
| References | |
| CON-#488-7236 OL-1, NUDOCS 8810180090 | |
| Download: ML20155G907 (3) | |
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~ R b,b' a UNITED STATES OF AMERICA N'hiil? NUCLEAR REGULATORY COMMISSION UWRC ATOMIC SAFETY AND LICENSING BOARD 26 TT 11 PS:01 Before Administrative Judges: Sheldon J. Wolfe, Chairman 0FUM a U CC X L i.*E M "U . D' Emmeth A. Luebke d Dr. Jerry Harbour ) In the Matter of ) ) PUBLIC SERVICE COMPANY OF ) Docket No.(s) NEW HAMPSHIRE, ET AL. ) 50-443/444-OL-1 (Seabrook Station, Units 1 and 2) ) On-site EP ) ) JOINT INTERVENORS MOTION FOR LEAVE TO FILE REPLY TO THE RESPONSES OF THE APPLICANTS AND STAFF TO THE ON-SLIE_.EXERCJ SE CONTENTION The Massachusetts Attorney General, the New England Coalition Against Nuclear Pollution, the Soacoast Anti-Pollution League, and the Town of Hampton, New Hampshire ("Joint Intervonors") move for leave to file the accompanying reply to the responses of the Staff and the Applican".s to the Joint Intervenors On-site Exercise Contention. As grounda for this motion, the Joint Intervenors state: 1. The procedural issues presented by this contention are complex and further briefing will throw additional light on the matter. 2. The Staff and the Applicants have disagreed on the appropriate standard to be applied to this contention. QO 90$ P ys a
3. The Joint Intervonors believe they have a right to ) file a contention arising out of the June 1988 on-site exercise without meeting any additional procedural barrier. As a consequence, they believe they have a right to reply to the responses of the Applicants and Staff. 4. No delay is involved. The Joint Intervenors received the Staff's response on October 5, 1988 and file this reply on the Board by Facsimile on October 7, 1988. For all the reasons set forth above, this Board should grant the Joint Intervenors' Motion for Leave to File the accompanying Reply. Respectfully Submitted JAMES M. SHANNON ATTORNEY GENERAL COMMONWF.ALTH OF MASSACHUSETTS A s$ Jo,n Traficonte A sistant Attorney General . clear Safety Unit J L epartment of Fhe Attorney General One Ashburto't Plece Boston, MA 02108 (617) 727-2200 On Behalf of: Town of Hampton Matthew T. Brock, Esq. Shaines & McEachern 25 Maplewood Avenue P.O. Box 360 Portsmouth, NH 03801 i 5 (603) 436-3110, e .,.,c,..., ..,.-,-m---
s Nsw England Coalition a on Nuclear Pollution Diane Curran, Esq. 1 Harmon, Curran & Towsley Suite 430 2001 S.
- Street, N.W.
Washington, DC 20009 (202) 328-3500 i Seacoast Anti-Pollution League Robert A. Backus, Esq. Backus, Meyer & Soloman 116 Lowell Street P.O. Box 516 Manchester, NH 03106 (603) 668-0730 ? I Dated: October 7, 1988 G [ l I h j l , r 6 e nm .e---.---re .m-----,--nwn - n n-w w - w c r. -- n en -m-v r,.- n w -m- - w - - - ~r-}}