ML20155K041

Motion to Compel Response from Listed Parties to 860428 Interrogatories.No Responses Received Nor Any Requests for Protective Order.Certificate of Svc Encl.Related Correspondence

ML20155K041
Person / Time
Site:	Seabrook
Issue date:	05/16/1986
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
References
CON-#286-254 OL, NUDOCS 8605270293
Download: ML20155K041 (5)

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RI.ATED CORRESPOM Dated: May 16, 1986 a t .s UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION 3y before the MAY 2 0 G36*' jh

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2 ) Planning Issues

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APPLICANTS' MOTION TO COMPEL RESPONSE TO INTERROGATORIES

1. On April 28, 1986, the applicants filed and served (in hand or by Federal Express) interrogatories upon the following:

Town of Brentwood Town of Seabrook Town of North Hampton Town of Salisbury City of Newburyport Town of Amesbury New England Coalition on Nuclear Pollution Town of Rye Town of Newbury Attorney General of the Commonwealth

, of Massachusetts

' City of Portsmouth h

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2. Copies of these interrogatories were also distributed to the Board and, for purposes of this motion are incorporated herein by reference.

3. Pursuant to both NRC regulations and a prior scheduling order of this Board, responses were due to these interrogatories on or before May 14, 1986.

4. No responses of any kind to the interrogatories have been received from any of the entities listed in Paragraph 1 hereof. Nor was any request for a protective order pursuant to 10 CFR S 2.740(c) filed by any such entity.

WHEREFORE, pursuant to 10 CFR & 2.740(f), applicants move the Board to enter an order compelling those entities listed in Paragraph 1 hereof to respond to the interrogatories.

By their attorneys, r

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Thonfhs G.gan, Jr.

R. K. Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 i

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t CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attorneys for the Applicants herein, hereby certify that on May 16, 1986, I made service of the within Applicants' Motion to Compel Response to Interrogatories by depositing copies thereof with Federal Express, prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):

Helen Hoyt, Chairperson Robert Carrigg, Chairman Atomic Safety and Licensing Board of Selectmen-Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Dr. Emmeth A. Luebke Diane Curran, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 2001 S Street, N.W.

U.S. Nuclear Regulatory Suite 430 Commission Washington, DC 20009 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commiccion Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814

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• Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814

• 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 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 General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RED 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 Washington, DC 20510 Board of Selectmen (Attn: Tom Burack) Town of Newbury Newbury, MA 01950

• Senator Gordon J. Humphrey Mr. Peter J. Matthews 1 Pillsbury Street Mayor

! Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950

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b Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RED Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.

Washington, 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 Mr. Ed Thomas FEMA, Region I 442 John W. McCormack Post Office and Court House Post Office Square Boston, MA 02109

(*= Ordinary U.S. First Class Mail.)

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