ML20247E963

Motion of Commonwealth of Ma Atty General for Leave to File Reply to Certain Applicant Responses to Proposed Findings.* Requests Leave to File Encl Reply

ML20247E963
Person / Time
Site:	Seabrook
Issue date:	09/11/1989
From:	Fierce A MASSACHUSETTS, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20247E968	List: ML20247E963 ML20247E990
References
CON-#389-9169 OL, NUDOCS 8909180054
Download: ML20247E963 (2)

Text

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UNITED-STATES OF AMERICA ~ iX6 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 9b

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Before Administrative Judges: crnu , .,

DOCK!. I M ' NRI U "' "

'Ivan W. Smith, Chairman Dr. Richard F.-Cole Dr.:Kenneth A. McCollom

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In the Matter of )

) Docket Nos. 50-443-OL PUBLIC SERVICE COMPANY.OF ) 50-444-OL NEW HAMPSHIRE, et al. )

) September.11, 1989 (Seabrook Station, Units 1 and 2) )

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MOTION OF THE MASSACHUSETTS ATTORNEY GENERAL ,

FOR LEAVE TO FILE A REPLY TO CERTAIN APPLICANTS'  !

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RESPONSES TO HIS PROPOSED FINDINGS ,

The Massachusetts Attorney Gencral (" Mass AG") hereby moves y for leave to file a.very brief reply to certain of the j D \

Applicants' responses to his proposed findings. These replies which the Mass AG seeks leave to file respond only to the most egregious matters raised for the first time by the Applicants in their responses to the Mass AG's proposed findings. The Mass AG could not have anticipated and responded to these responses in his proposed findings filed on August 14, 1989.

One such egregious response which demands a reply is an assertion by the Applicants'that a Mass AG proposed finding (19.1.78.I.) contains a " fraudulent citation." A few other i

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11 egregious responses for'which replies are necessary are those which assert that a Mass AG proposed finding raises a matter which is not within the scope of any admitted contention. One other response demanding a reply is a misleading statement that:

certain data from the Social Data Analyst survey are not in evidence.

The Mass AG's reply is timely filed. Applicants' Responses-was served on August 31, 1989.

Respectfully submitted, COMMONWEALTH OF MASSACHUSETTS JAMES M. SHANNON ATTORNEY GENERAL Y

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John Traficonte Chief, Nuclear Safety Unit Allan R. Fierce Assistant Attorney General Dept. of the Attorney General One Ashburton Place, 19th F1.

Boston, MA 02108 (617) 727-2200 Dated: September 11, 1989 i

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