ML20206J759

NRC Staff Motion for 2-day Extension of Time to Respond to Motions to Reopen Record & Late Filed Contentions.* Certificate of Svc Encl

ML20206J759
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-#488-7520 OL-1, NUDOCS 8811290108
Download: ML20206J759 (5)

Text

11/14/88 7MO DCf.KC TQ t:miic UNITED STATES OF AMERIC A NUCLE AR REGUL ATOR Y COMMISSION

'88 NOV 18 P3:10 B EFO R E T HE C OMMISSIO_N_ qre n t .Gt - 3 v0Cv

• g . ' . n In the Matter r:f )

Docket Nos. 50 443 OL-01  :

PUBLIC SERVICE COMPANY OF 50-444 OL-01 N E W H A M P S HIR E , g,al. On-site Emergency Planning i and Safety Issues

-(Seabrook S'ation, Units 1 and 2)

NRC STAFF MOTION FOR TWO DAY EXTENSION OF TIME TO RESPOND TO MOTI0 tis TO REOPEtt THE RFCORD AND LATE-FILED C,0NTENTIONS The NRC staff respectfully asks for a two (2) day extension of time

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to file its response to intervenors motions and late-filed cententions based on Applicants' plan to fund decomissioning if the low-power operation has occLrred and a full power license is not granted for Seabrook Unit 1.  !

In CLI-88-07, 28 NRC (September 22, 1988), the Comissict  !

requested that applicants provide, within 30 days, adequate docunentation '

of the'r plan and appropriate commitments to provide reasonable assurance '

of adequate funding for decomissioning of Seabrook, in the event a low i power, but not a full power license, is issued for Seabrook. Intervenors were given 10 days thereafter to file motions and late filed cententions l

based on such a plan. Opposition te such motions were to be filed within ten days of service of those motions. Intervenors motiens were served on November 2,1988, and a reply in opposition, considering the time for mailing, is due on Noverbsr 14, 1988.

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

8811290100 g ggoj43 PDR ADOCK ppn f

2 and subparts. Although, working diligently the Staff has not been able to conplete the preparation of the necessary affidavits and a brief to properly respond to all 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 decommission Seabrook in the event a low power license, but not a full power license, is granted for its

) operation.

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

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION T"W BEFORE TH_E COMMISSION gg myjg p3:jj In the Matter of )

Docket Nos 50-h 3.0L-01.'

56h44'0L,01 PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ~et~ al.

On-site Emergency g Plannin/ "9' C and Safety Issues (SeabrookStation, Units 1and2)

CERTIFICATE OF SERVICE I hereby certify that copies o' "NRC STAFF MOTION 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 mail, first class or: as indicated by an asterisk, by deposit in the Nuclear Regulatory Comission's internal mail system, this 14th dey of November 1988:

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

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

Sheldon J. Wolfe, Esq. Chaiman* Washington, DC 20472 Adninistrative Judge Atomic 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, Chairnan Atomic Safety and Licensing Board Board of Selectmen U.S. Nuclear Regulatory Comittion Town Office Washington, DC 20555 Atlantic Avenue North Hampton, NH 03870 Mr. Emeth A. Luebke Administrative Judge Judith H. Mizner, Esq.

4515 Villard Aver.ue Silverglate Gertner, Baker, Chevy Chase, Maryland 20815 Fine, & Good 88 Board Street Pbfiip Ahren Esq. Resten, 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.

P,ebert K. Gad, III. Esq.

Ropes & Gray 225 Franklin Street Boston, MA 01:'120

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

Assistant Attorney General Lagoulis, Clark, Hill-Whilton Office of the Attorney General & McGuire One Ashburton Place, 19th Floor 79 State Street Boston, MA 02108 Newburyport, MA 01950 George Dana Bisbee, Esq. Allen Lampert Assistant Attorney General Civil Defense Director Office of the Attorney General Town of Brentwood 25 Capitol Streec 20 Franklin Concord, NH 03301 Exeter, NH 03833 Ellyn R. Weiss, Esq. William Ancstrong 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 V. 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 and Licensing Paul McEachern, Esq. Appeal Panel (8)*

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

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

Amesbury, MA 01913 Office of the Secretary U.S. Nuclear Regulatory Commission Sandra Gavutis, Chairman Washington, DC 20555 Board of Selectmen RFD #1, Box 1154 Peter J. Matthews, Mayor Kensington, NH 03S27 City Hall Newburyport, MN 09150 William S. Lord Beard of Selectmen Ashod N. Amirian, Esq.

Town Hali - Friend Street Town Counsel for Merrimac Amesbury, MA 01913 376 Main Street Haverhill, MA 08130 Sheldon J. Wolfe, Esq.

Administrative Judge 1110 Wimbledon Drive McLean, VA 22101

'i Mrs. Anne E. Goodman, Chairman Michael Santosuosso, Chairman Board of Selectmen Board of Selectmen 13-15 Newmarket Road South Hampton, NH 03827 Durham, NH 03824 Hon, Gordon J. Humphrey

< United States Senate 531 Hart Senate Office Building Washington, DC 20510 Edwin . Reis

. Depu Assistant General ounsel 1

.