ML20206S237
| ML20206S237 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/17/1986 |
| From: | Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-738 OL-1, NUDOCS 8609220136 | |
| Download: ML20206S237 (7) | |
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NUCLEAR REGULATORY COMMISSION 73'
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In the Matter of
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Docket Nos. '50-443 c OL-1 V NEW HAMPSHIRE, et al.
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On-site Emergency Planning I
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(Seabrook Station, Units 1 and 2)
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I NRC STAFF'S MOTION FOR s
ONE-DAY EXTENSION OF TIME
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7 Pursuant to 10 C.F.R. 85 2.711 and 2.730, the NRC Staff (" Staff")
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hereby requests a one-day extension of time to file its,sup'plemental response to Interrogatory 16, and to provide a list of documents being c t, produced in response to Interrogatory 1, of "SAPL's Interrogatones and
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Requests for Documents to the NRC Staff" ("S APL's Interrogatories '),
filed August 8, 1986.
In support of this motion, the Staff states Ns
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follows:
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1.
The Staff filed its initial response to SAPL's Interrogatories on U i-August 25, 1986.
On September 3,1986, SAPL filed a motion to compel; ' '"
the Staff to provide further responses to eight of its interrogatorios s
pertaining to NECNP Contention I.B.2, including Interrogatodes I and 16. AI l
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"SAPL's Motion to Compel Response to Interrogatories by NRC Staff and Objection to NRC Staff Motion for a Protective Or' der," dated September 3,1986.
8609220136 860917 PDR ADOCK 05000443 G
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- 2. _ On September 10, 1986, a telephone conference call was held by the Licensing Board and parties, at which time the Board directed the Staff to file a further response to Interrogatory 16 and to provide a list of the documents which the Staff had previously indicated, in response to Interrogatory 1,
were available for SAPL's inspection and copying. 2_/
The Board directed that this further response should be filed by September 16, 1986, upon being informed by Staff counsel that the Staff's reviewer was out of town and was not scheduled to return to the ofnce until that date (Tr. 56-57).
3.
On the morning of September 16, 1986, the undersigned Staff counsel met with the Staff's reviewer, and proceeded to prepare the i
document list and supplemental interrogatory answer required by the Board's order.
Staff counsel again met with the Staff's reviewer that afternoon to review the document list and supplemental interrogatory i
and by approximately 4:45 pm a final document was ready for
- answer, signature and filing; however, a notary public could not be located at that time to witness the reviewer's signing of an affidavit attesting to the correctness of the information set forth in the Staff's supplemental l
response, and the reviewer was required to leave the office in order to catch his ride home before the final document could be properly executed.
l 4.
Shortly after 5:00 pm on September 16, 1986, upon being unable to locate a notary public prior to the reviewer's departure from the office, Staff counsel attempted to contact Counsel for SAPL (Robert 2/
Transcript of Telephone Conference, September 10, 1986, at Tr.
56-57.
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, 1 Backus,-Esq.) to request his consent to a one-day extension of time for
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the filing of the Staff's supplemental response.
At, that time, Staff counsel was informed by Mr. Backus' office that he had already left for the day and had not left a number where he might be reached.
5.
Upon being unable to contact Mr. Backus, Staff Counsel called the Licensing Board Chairman to inform hiin of these facts and to request the extension sought herein.
The Chairman has requested that the Staff continue to attempt to ascertain S APL's position with respect to the motion, and directed the Staff to file a written motion for extension of
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time sett$ng forth the relevant circumstances.
6.
Staff counsel again attempted to contact Mr. Backus on the morning of September 17, 1986, but was unable to reach him before the filing of this motion.
7.
The Staff's' reviewer executed the referenced affidavit on the morning of September 17, 1986, and the Staff's supplemental response to SAPL's interrogatories is being served herewith.
In order to avert any unnecessary delay,
this motion and the accompanying supplemental l
response are being served by Express Mail upon SAPL and the other parties.
8.
The Staff submits that it exercised due diligence in attempting to complete its supplemental response to SAPL's Interrogatories on September 16, 1986, as required by the Board's ruling.
Further, upon recognizing that a properly executed document could not be served on September 16, 1986, the Staff exercised due diligence in attempting to obtain SAPL's consent to a one-day extension of time and in alerting the l
Board to the Staff's need for such an extension.
e.o WHEREFORE, the Staff respectfully requests a one-day extension of time for the filing of the accompanying supplemental response to SAPL's Interrogatories.
Respectfully submitted, Sherwin E. Turk Senior Supervisory Trial Attorney Dated at Bethesda, Maryland this 17th day of September,1986 e
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00LKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0FFICE OF SEue.IAe 00CKETING A SERVICf.
BRANCH In the Matter of
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443 OL-1 NEW HAMPSHIRE, et al.
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50-444 OL-1
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On-site Emergency Planning (Seabrook Station, Units 1 and 2)
)
and Safety Issues CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S MOTION FOR ONE-DAY EXTENSION OF TIME" in the above proceeding have been served on the following by deposit in the United State mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system or, as indicated by a double asterisk, by express mail, this 17th day of September,1986.
Sheldon J. Wolfe, Chairman
- Dr. Emmeth A. Luebke*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Jerry Harbour
- Carol Sneider" Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor Washington, D.C.
20555 Boston, MA 02108 Beverly Hollingworth Stephen E. Merrill 209 Winnacunnet Road Attorney General Hampton, NH 03842 George Dana Bisbee**
Assistant Attorney General Sandra Gavutis, Chairman Office of the Attorney General Board of Selectmen 25 Capitol Street RFD 1 Box 1154 Concord, NH 03301-6397 Kensington, NH 03827 Richard A. Hampe, Esq.
New Hampshire Civil Defense Agency 107 Pleasant Street Concord, NH 03301 l
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. 3 Calvin A Canney, City Manager Allen Lampert City Hall Civil Defense Director 126 Daniel Street Town of Brentwood Portsmouth, NH 03801 20 FrankHn Street Exeter, NH 03833 Roberta C. Pevear State Representative Angie Machiros, Chairman Town of Hampton Falls Board of Selectmen Drinkwater Road 25 High Road llampton Falls, NH 03844 Newbury, MA 09150 Mr. Robert J. Harrison Jerard A. Croteau, Constable President and Chief Executive Officer 82 Beach Road, P.O. Box 5501 Public Service Co. of New Ilampshire Salisbury, MA 01950 P.O. Box 330 Manchester, NH 03105 Diane Curran, Esq.**
Harmon & Weiss Robert A. Backus, Esq.**
2001 S Street, N.W.
Backus, Meyer & Solomon Suite 430 116 Lowell Street Washington, D.C.
20009 Manchester, NH 03106 Edward A. Thomas Philip Ahrens, Esq.
Federal Emergency Management Agency Assistant Attorney General 442 J.W. McCormack (POCII)
Office of the Attorney General Boston, MA 02109 State House Station, f 6 Augusta, ME 04333 H.J. Flynn, Esq.
Thomas G. Dignan, Jr., Esq.**
Assistant General Counsel Ropes & Gray Federal Emergency Management Agency 225 Franklin Street 500 C Street, S.W.
Boston, MA 02110 Washington, D.C.
20472 j
Jane Doughty Atomic Safety and Licensing Seacoast Anti-Pollution League Board
- l 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, D.C.
20555 f
Atomic Safety and Licensing Paul McEachern, Esq.
Appeal Panel
- Matthew T. Brock, Esq.
l U.S. Nuclear Regulatory Commission Shaines & McEachern Washington, D.C.
20555 25 Maplewood Avenue P.O. Box 360 Portsmouth, NH 03801 i
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, 3 Docketing and Service Section*
William Armstrong Office of the Secretary Civil Defense Director U.S. Nuclear Regulatory Commission Town of Exeter Washington, D.C.
20555 10 Front Street Exeter, NH 03833 Maynard L. Young, Chairman Board of Selectmen Peter J. Matthews, Mayor 10 Central Road City Hall Rye, NH 03870 Newburyport, MA 09150 Michael Santosuosso, Chairman William S. Lord Board of Selectmen Board of Selectment South Hampton, NH 03827 Town Hall - Friend. Street Amesbury, MA 01913 Mr. Robert Carrigg, Chairman Mrs. Anne E. Goodman, Chairman Board of Selectmen Board of Selectmen Town OfHce 13-15 Newmarket Road Atlantic Avenue Durham, NH 03824 North Hampton, NH 03862 R. K. Gad III, Esq.
Gary W. Holmes, Esq.
Ropes & Gray Holmes & Ellis 225 Franklin Street 47 Winnacunnet Road Boston, MA 02110 Hampton, NH 03842 Judith H. Mizner, Esq.
Silverglate, Gertner, Baker Fine and Good 88 Broad Street Boston, MA 02110 i
t-Sherwin E. Turk Senior Supervisory Trial Attorney s
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