ML20205F961
| ML20205F961 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/25/1988 |
| From: | Traficonte J MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20205F966 | List: |
| References | |
| CON-#488-7368 OL, NUDOCS 8810280167 | |
| Download: ML20205F961 (3) | |
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,7dEddf EXhETED UNC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '88 OCT 26 PS :57 ATOMIC SAFETY AND LICENSING BOARD
- rr, Before the Administrative Judges
- '
Ivan W.
Smith, Chairman Gustave A.
Linenberger, Jr.
Dr. Jerry Harbour
)
In the Matter of
)
Docket Nos. 50-443-OL
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50-444-OL PUBLIC SERVICE COMPANY
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(Off-Site E )
OF NEW HAMPSHIRE, ET AL.
)
)
(Seabrook Station, Units 1 and 2
)
October 25, 1988
__)
MOTION OF THE JOINT INTERVENORS TO EXTEND TIME WITHIN WHICH TO REPLY TO THE NRC STAFF'S THIRD SET OF IRIERROGAIORIES_AND DOC 1HiENT_REQUES_TS Pursuant to 10 C.F.R.
$ 2.711, the Joint Intervenors hereby request that the time to answer or otherwise respond to the NRC Staff's Third Set of Interrogatories and Requests for Production of Documents be enlarged.
As grounds for this motion the Joint Intervenors state:
1.
NRC Staff's "Third Set of Interrogatories and Request For Production was filed on October 6, 1988.
Intervenors received this document on or about October 11, 1988.
2.
ThesE discovery requests seek infoxmation and documents obtainable only from several different agencies within the Commonwealth of Massachusetts.
Since receipt of these request-the Massachusetts Attorney General's office has been steadily working on responding to them, an extremely labor intensive and time consuming process which includes contacting many government agencies including, inter alif,the e910200167 gj[8$$43 PDR
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Massachusetts Civil Defense Agency, Department of Public Health, Department of Public Safety, the State police, the l
National Guard and the Governor's Office.
3 3.
One Assistant Attorney General has been working on full time on nothing else but these requests.
Contacts with each of the above-mentioned agencies has been accomplished, and i
the process of gathering information and documents is well under way.
While the Mass AG has already accumulated a signif. cant amount of documentary material, there is still a great deal more to be gathered.
4.
Tnese documents, which constitute thousands of pages, j
must be reviewed and evaluated before complete responses to the Staff's requests may be formulated.
Although this reveiw is i
proceeding apace, in order to finish the review and provide responsive answers to the discovery requests, the Mass AG will need more time.
1 5.
With respect to the Joint Intervenor towns, the burden in responding to this discovery is also great.
Although the scope of their document search is far smaller than that for the I
Mass Ag, their resources for conducting such searches is also I
far less.
?
6.
For the reasons set forth above, the Mass AG and the I
Joint Intervenor towns needs additional time to December 10, 1988, file a preliminary response to these interrogatories and l
requests to produce this preliminary response will provide answers to only those interrogatories which can be answered i
from a cursory review of the documents in hand at that time.
Thereafter, depending on the volume of relevant documents which
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we uncover, full arid complete responses will be provided as quickly as possible, but we estimate at this time that the responses can be provided by January 12, 1988.
7.
As additional support f or this niotion, see the Mass AG's Motion for Extention of Discovery Schedule to be filed on October 26, 1988.
Respectfully Submitted, JOINT INTERVENORS:
J
~
1 BY:
3chn Traficonte f
' Assistant Attorney General yuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108 (617) 727-2200 DATED:
October 25, 1988 e
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