ML20214S971

Motion for Leave to File Response to NRC 860926 Proposed Findings of Fact & Conclusions of Law Re New England Coalition on Nuclear Pollution Contention I.B.2

ML20214S971
Person / Time
Site:	Seabrook
Issue date:	12/04/1986
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20214S976	List: ML20214S971 ML20214T049
References
CON-#486-1776 OL-1, NUDOCS 8612080438
Download: ML20214S971 (2)

Text

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December 4, 1986 UW!{

UNITED STATES NUCLEAR REGULATORY COMMISSION 16 DEC -5 R2:35 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD crrict o . u - ar

_____________________________________ occsuma c n>via

) BRANCH In the Matter of )

)

Public Service company of )

New Hampshire, et al. ) Docket Nos. 50-443 OL-1

) 50-444 OL-1 (Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY

) PLANNING & TECHNICAL

_____________________________________) ISSUES NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S MOTION FOR LEAVE TO FILE RESPONSE TO NRC STAFF PROPOSED FINDINGS AND TO APPLICANTS' REPLY TO NECNP'S PROPOSED FINDINGS Introduction On November 26, 1986, the NRC Staff filed Proposed Findings of Fact and Conclusions of Law with respect to NECNP Contention I.B.2. In those Proposed Findings, the NRC Staff offers numerous arguments in support of its position that Applicants have met the NRC's environmental qualification requirements for time duration.

Becar.se the NRC has taken a position in support of Applicants, and has offered new arguments in support of Applicants' license application, the New England Coalition on Nuclear Pollution i ("NECNP") seeks the Board's leave to file a response to those i

arguments.

Applicants filed a reply to NECNP's Proposed Findings on De-cember 1, 1986. In its Reply. Applicants raise for the first time a challenge to the scope of NECNP Contention I.B.2 as inter-8612080438 861204 PDR ADOCK 05000443 G PDR i S'oo.

preted by NECNP. Because Applicants' interpretation of the scope of Contention I.B.2 would foreclose the Board's consideration of important safety issues raised by NECNP, the Coalition moves the Board to consider the attached response to Applicants' legal arguments.

Respectfully submitted,

[M Diane Curran HARMON & WEISS 2001 "S" Street N.W. Suite 430 Washington, D.C. 20009 (202) 328-3500 December 4 1986

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