ML20206C341

NRC Staff Motion for 2-day Extension of Time to Respond to Motions to Reopen Record & late-filed Contentions.* Extension Requested to Respond to Applicant Plan to Fund Decommissioning.W/Certificate of Svc

ML20206C341
Person / Time
Site:	Seabrook
Issue date:	11/14/1988
From:	Reis E NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	NRC COMMISSION (OCM)
References
CON-#488-7481 CLI-88-07, CLI-88-7, OL-1, NUDOCS 8811160227
Download: ML20206C341 (5)

Text

22/ 4/88 iWF/

J. DOLKETED 09&C UtlITED STATES OF AMERIC A NUCLE A R- REGUL ATOR Y COMMISSION

~88 NOV 14 P2 :45 B EFO R E ', .E C O M MISSIO N p g., . , ,

00CEO Mi-. U VKI.

Hm In the Matter of )

Docket Hos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF 50-444 OL-01 N E W H A M PSHIR E, et ,al. On-site Emergency Planning and Safety Issues (Seabrook Station, Units 1 and 2)

NRC STAFT MOTION FOR TWO DAY EXTENSION OF TIME TO RESPOND TO MOTIONS TO REOPEN THE RECORD AND LATE-FILED C,0NTENTIONS _

The NRC staff respectfully asks for a two (2) day extension of time to file its response to intervenors motions and late-filed contentions based on Applicants' plan to fund decomissioning if the low-power operation nas occurred and a full power license is not granted for Seabrook Unit 1.

In CLI-C8-07, 28 NRC (September 22, 1988), the Comission requested that applicants provide, within 30 days, adequate docunentation of their plan and appropriate comitments to provide reasonable assurance of adequate funding for decomissioning of Seabrook, in the event a low power, but not a full power license, is issued for Seabrook. Intervenors were given 10 days thereafter to file motions and late filed contentions based on such a plan. Opposition to such motions were to be filed within ten days of service of those mctions. Intervenors motions were served on November 2, 1988, and a reply in opposition, considering the time for mailing, is due on Nnverrber 14, 1980.

The Staff requests an additional two (2) days to file its opposition because four motions to reopen were received, which have many contentier.s

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and subparts. Although, working diligently the Staff has not been able to complete the preparation of t.'e necessary affidavits and a brief to properly respord to al' four motions.

Wherefore the Staff respectfully requests a two day extension of time until November 16, 1988, to file its response to the subject motions to reopen the record and the proffered contentions on the financial qualification of the applicants to decormission Seabrook in the event a low power license, but not a full power license, is granted for its operation.

Respectfully submitted.

Edwin J. eis Deputy Assistant General Counsel Reactor Licensing Branch Dated at Rockville Maryland this 14th day of November, 1988

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION E[

BEFORE THE COMMISSION '88 NOV 14 P2:45 In the Hatter of ) . .

Docket Nos. 50-4430$h,k,n;..,Y,dgj PUBLIC SERVICE COMPANY OF l 50-444 OL-01 im WH NEW HAMPSHIRE, g a_1,. On-site Emergency Planning and Safety Issues (Seabrook Station, Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that copies n' "NRC STAFF HOTION FOR TWO DAY EXTENSION OF TIME TO RESPOND TO MOTIONS TO REOPEN THE RECORD AND LATE-FILED CONTENTIONS" in the above-captioned proceeding have been served on the following by deposit in the United States reail, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Comiss ion's internal mail system, this 14th day of November 1988:

Samuel J. Chilk (15)* F. J. Flynn, Esq.

Office of the Secretary Assistant General Counsel U.S. Nuclear Regulatory Comission Federal Emergency Management Washington, DC 20555 Agency 500 C Street, S.W.

Sheldon J. Wolfe, Esq. Chairman

• Washington, DC 20472 Administrative Judge Atonic Safety and Licensing Board Calvin A. Canney U.S. Nuclear Pegulatory Comission City Hall Washington, DC 20555 126 Daniel Street Portsmouth, NH 03801 Dr. Jerry Harbour

• Administrative Judge Robert Carrigg, Chaiman Atcmic Safety and Licensing Board Board of Selectmen U.S. Nuclear Regulatory Comission Town Office Washington, DC 20555 Atlantic Avenue North Hampton, NF 03870 Mr. Emeth A. Lucbke Administrative Judge Judith H. Mizner, Esq.

4515 Villard Avenue Silverglate, Gertner, Baker, Chevy Chase, Maryland 20815 Fine, & Good 88 Board Street Philip Ahren, Esq. Boston, MA 02110 Assistant Attorney General Office of the Attorney General J. P. Nadeau State House Station Board of Selectmen Augusta, ME 04333 10 Central Street Rye, NH 03870 Thomas G. Dignan, Jr. , Esq.

Robert K. Gad, III, Esq.

Ropes & Gray 225 Franklin Street Boston, Ws 010110

Carol S. Sneider, Esq. R. Scott Hill-Whilton, Esq.

Assistant Attorney General Lagoulis, Clark, Hill-Whilton 0ffice of the Attorney General & McGuire One Ashburton Placo, 19th Floor 79 State Street Boston, MA 02108 Newburyport, MA 01950 George Dana Bisbee, Eso. Allen Lampert Assistant Attorney General Civil Defense Director Office of the Attorney General Town of Brentwood 25 Capitol Street 20 Franklin Concord, NH 03301 Exeter, NH 03833 Ellyn R. Weiss, Esq. William Armstrong Diane Curran, Esq. Civil Defense Director Harmon & Weiss Town of Exeter 2001 S Street, NW 10 Front Street Suite 430 Exeter, NH 03833 Washington, DC 20009 Gary F. Holmes, Esq.

Robert A. Backus, Esq. Holmes & Ellis Backus, Meyer & Solomon 47 Winnacunnet Road 116 Lowell Street Hampton, NH 83842 Manchester, NH 03106 Atomic Safety 6nd Licensing Paul McEachern, Esq. Appeal Panel (8)*

Matthew T. Brock, Esq. U.S. Nuclear Regulatory Commission Shaines & McFachern Washington, DC 20555 25 Maplewood Avenue P.O. Box 360 Atem1c Safety and Licensing Portsmouth, NH 03801 Board Panel (1)*

U.S. Nuclear Regulatory Commission Charles P. Graham, Esq. Washington, DC 20555 McKay, Murphy & Graham 100 Main Street Docketing and Service Section*

Amesbury, PA 01913 Office of the Secretary U.S. Nuclear Regulatory Commission Sandra Gavutis, Chairman Washington, DC 20555 Board of Selectmen RF0 #1, Box 1154 Peter J. Matthews, Mayor Xensington, NH 03627 City Hall Newburyport, MN 09150 William S. Lord Beard of Selectmen Ashod N. Amirinn, Esq.

Town Hall - Friend Street Town Counsel for Ferrimac  ;

Amesbury, MA 01913 376 Main Street Haverhill, MA 08130 Sheldon J. Wolfe, Esq.

Administrative Judge 1110 Wimbledon Drive McLean, VA 22101

s Mrs. Anne E.' Goodman, Chairman Michael Santosuosso, Chairman Board of Selectmen Board of Selectmen 13-15 Newmarket Poad South Hampton, NH 03827 Durham, NH 03824 Hon. Gordon J. Humphrey United States Senate 1 531 Hart Senate Office Building Washington, DC 20510

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