ML20246N005
| ML20246N005 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/01/1989 |
| From: | Brock M MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20246N008 | List: |
| References | |
| CON-#389-9132 OL, NUDOCS 8909080016 | |
| Download: ML20246N005 (2) | |
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l UNITED STATES OF AMERICA L
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o-ATOMIC SAFETY AND LICENSING BOARD
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Before the Administrative Judges:
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Ivan W.
Smith, Chairman Dr. Richard F.
Cole Kenneth'A. McCollom i
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In the Matter of.
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Docket Nos. 50-443-OL
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50-444-OL OF.NEW HAMPSHIRE, EI AL.
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l PUBLIC SERVICE COMPANY
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(Off-Site EP) l
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ll (Seabrook Station, Units 1 and 2)
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September 1, 1989
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'l MOTION TO.ADMTT REPLY TO APPLICANTS' AND STAFF'S RESPONSES l
TO INTERVENERS' MOTION TO ADMIT CONTENTION OR IN THE l
ALTERNATIVE TO REOPEN THE RECORD AHD REQUEST FOR HEARING l
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l Now comes Mass AG, SAPL, and NECNP (hereinafter
" Interveners"), and move this Board to accept and admit.the Il reply, filed herewith, to the responses of the Staff and l
l Applicants to INTERVENERS' MOTION TO ADMIT CONTENTION OR IN THE ALTERNATIVE TO REOPEN THE RECORD AND REQUEST FOR HEARING, dated
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July 21, 1989.
(" Motion").
In support hereof, Interveners j
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state:
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The Motion, with incorporated Contention, raises t-significant issues as to Applicants' incompetence to conform to i
89090B0016 h0.) 443 PDR ADOCK PDR pf7
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- procedures, regulatory requirements, and industry standards'for l-safe management and operation; l-
' ;2.
In this proceeding, Interveners'have traditionally
'been' afforded the' opportunity to reply to Applicants' and L
Staff's responses to' contentions; 3.
Both Applicants and' Staff have raised new issues not-addressed in the July.21 Motion, including that this Board-should make new. law by. extending the " fundamental flaw" standard for exercise contentions to Interveners' contention that concerns defects in Applicants'~ low power operations; i
4.
The' Reply will assist the Board by providing a more l'
complete record for decison; 5.
The Staff response, following= Applicants', was not received by Mass AG until August 22.
This reply therefore has been filed as promptly as reasonably possible.
Respectfully submitted, JAMES M.
SHANNON ATTORNEY GENERAL I
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katthew T.
Brock
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Assistant Attorney General Nuclear Safety Unit One Ashburton Place Boston, MA 02108 (617) 727-2200..
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