ML20247L288
| ML20247L288 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/30/1989 |
| From: | Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#289-8678 LBP-88-32, OL, NUDOCS 8906020127 | |
| Download: ML20247L288 (7) | |
Text
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. IfN For the-Appgl Board b
- 6. M Oh..s/30/s9 Secretary to the@.ppeal Board'
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UNITED STATES OF AMERICA 89 "M'-30 P2 56 NUCLEAR REGULATORY C0fetISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPifAL BOARD b'
In the Matter of
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Docket No. 50-443 OL PUBLIC SERVICE COMPANY OF
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50-444 OL NEW HAMPSHIRE, el g.
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Offsite Emergency Planning
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(SeabrookStation, Units 1and2)
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NRC STAFF'S MOTION FOR AN ADDITIONAL EXTENSION OF TIME IN WHICH TO FILE ITS BRIEF IN RESPONSE TO INTERVENOR$' BRIEFS ON APPEAL FROM LBP-88-32 1
The NRC Staff hereby requests an additional five-day extension of time, until Monday, June 5, 1989, in which to file its brief in response to Interveners' four briefs on appeal from the Licensing Board's Partial InitialDecision(PID)ofDecember 30,1988.1/ In support of this request, the Staff states as follows:
1.
Briefs on-appeal from the Licensing Board's PID were filed by theTownofHampton,theSeacoastAnti-PollutionLeague(SAPL),the Massachusetts Attorney General (" Mass AG"), and the New England Coalition l
on Nuclear Pollution (NECNP). The appellants' briefs were filed on or before March 24. 1989, pursuant to a 40-day extension of time granted by the Appeal Board. On May 5,1989, the Appeal Board granted the Staff's request for a 23-day extension of time, until May 31, 1989, in which to file its brief in response to the Interveners' briefs on appeal.
1/
Public Service Co. cf New Hampshire (Seabrook Station, Units 1 and z)
L5P-55-3Z, 25 NRG 667
- Dec.30,1988).
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2.
-As the Staff noted in its previous request for-an-extension, the Interveners' briefs total approximately 250 pages, plus many voluminous attachments. In their briefs, the Interveners raise numerous factual. and legal issues-challenging the PID, evidentiary rulings made by the Board.
.and earlier Board rulings.
3.
The preparation of a brief in response t'o these numerous and detailed Challenges to the Licensing Board _'s PID has entailed considerable effort and has taken longer than the Staff initially estimated.
While the Staff previously estimated that its brief would be completed and ready for filing by May 31,1989,.it has become apparent that the Staff will require several additional days in which to complete its brief.
4 The Staff's. requirement of this additional time is necessitated, in part, by the unexpected length of time it has taken to respond to all of the many arguments raised by the Interveners on appeal.
In addition, the need for this additional time results from the fact that the Staff was required to respond last week to an emergency motion filed by the Mass AG, which required Staff Counsel to spend an entire day and night in the preparation of a responsive pleading -- in effect causing the loss of two days' time which would otherwise have been utilized to respond to Interveners' briefs on appeal.
. 5.-
The granting of this Motion will not harn any other party to this proceeding, will not delay resolution cf the issues before the Appeal Board, and will not delay the issuance of a full power license (if such a licenseshouldbeauthorized).
7.
Staff Counsel has contacted the other parties who filed briefs on appeal-from the P!D. Counsel for the Applicants, NECNP, and the Town J
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of Hampton have authorized the Staff to state that they do not oppose the granting of this Motion. Counsel for the Mass AG has authorized the Staff to state that he does not oppose an extension until Friday, June 2,1989, but opposes an extension until the following Monday.
Counsel for SAPL has stated that he opposes the grant of any extension of time for the filing of the Staff's brief.
WHEREFORE, the Staff respectfully requests an additional 5-day extension of time, until June 6,1989, for the filing of its brief in response to Interveners' appeals from the Licensing Board's PID.
Respectfully submitted, ib Shenvin E. Turk Senior Supervisory Trial Attorney Dated at Rockville, Maryland this 30th day of May, 1989 i
C.m_________________.________________.__
UNfTED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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PUBLIC. SERVICE COMPANY OF NEW l
Docket No.(s) 50-443/444-OL' L
HAMPSHIRE. ET AL; l-(Seabrook Station. Units 1 and 2) 1 1
1.
CERTIFICATE OF SERVICE I hereby certify that-contes of the forecoino AB GRANT OF MOTION DTD 5/30/B9 have been served upon the followine persons by U.S. mail. first class. excent-as otherwise noted and in accordance with the requirements of 10 CFR Sec. 2.712.
Administrative Judoe Administrative Judae Alan S.- Rosenthal. Chairman Thomas S. Moore
' Atomic Safety and Licensino Acceal Atomic. Safety and Licensino Acceal Board Board U.S. Nuclear Reculatory Commission U.S. Nuclear Reculatory Commission-Washinoton. DC 20555 Washinoton. DC 20555 Administrative Judas Howard A. Wit ter Administrative Law Judae Atomic Safetv and Licensino Acceal Ivan W. 3mith. Chairman Boaro Atomic Safety and Licensino Board
.U.S. Nuclear Reculatorv Commission U.S. Nuclear Reculatory Commission Washinoton. DC 20555 Washincton. DC 20555 Administrative Judae Administrative Judoe i
Richard F. Cole Kenneth A. McCollom Atomic Safetv and Licensino Board Atomic Safety and Licensino Board U.S. Nuclear Reculatory Commission U.S. Nuclear Reculatory Commission Washincton. DC 20555 Washincton. DC 20555 l
Administrative Judoe Robert'R. Pierce. Escuire-James H. Carpenter i
Atomic Safety and Licensino Board Alternate Technical Member U.S. Nuclear Reculatory Commission Atomic Safety and.Licensino Board Washinoton. DC 20555 U.S. Nuclerr Regulatory Commission i
Washinoton.-DC 20555 I
Edwin J. Reis. Esc.
Lisa B. Clark
.(
Office of the General Counsel Attornev j
U.S. Nuclear Reculatory Commission Office of the General Counsel 1
Washincton. DC 20555 U.S. Nuclear Raoulatory Commission Washincton. DC 20555 1
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Docket No.(s)S0-443/444-OL AB GRANT OF M0ff0N DTD 9/30/89 Diane Curran. Esc.
Thomas G. Dianan. Jr.. Eso.
Harmen. Curran L.Touslev Rooes & Grav 2001 S Street.
N.W.. Suite 430 One International Place Washincton. DC 20009 Boston. MA 02110 Robert A. Backus. Esc.
Paul McEachern. Esc.
Backus. Never & Solomon Shaines & McEachern 116 Lowell Street 25 Maolewood Avenue. P.O. Box 360 Manchester. NH 03106 Portsmouth. NH 03801 Gary W. Holmes. Esc.
Judith H. Mizner Holmes & Ells Silverolate. Gernter. Baker. Fine.
47 Winnacunnet Road Good and Mitzner Hamoten. NH 03842 88 Broad Street Boston. MA 02110 Charles P. Graham. Esc.
Jane Doherty McKav. Murphy and Graham Seacoast Anti-Pollution Lesaus 100 Main Street 5 Market Street Amesbury. MA 01913 Portsmouth. NH 03801 Leonard Kapelman. Esc.
Ashed N. Amirian. Esc.
Konelman and Palos. P.C.
376 Main Street 77 Franklin Street Haverhill MA 01830 Boston. MA 02110 Georae W.
Watson. Esc.
Edward A. Thomas Federal Emeroency Mansassent Acency Federal Emeroency Manacement Acency l
500 C Street. S.W.
442 J.W. McCormack (PDCH)
Washinoton. DC 20472 Boston. MA 02109 I
Georos D. Bisbee. Esc.
Suzanne Breiseth Assistant Attorney General Board of Selectmen Office of the Attorney General Town of Hamoton Falls 25 Canitel Street Drinkwater Road Concord. NH 03301 Hampton Falls. NH 03B44 i
I-Docket No.(s)S0-a43/444-OL AB GRANT OF N0fl0N DTD 9/30/09 John Traficente. Esc.
Peter J. Brann. Esc.
Chief. Nuclear Safety Unit Assistant Attorney General Office of the Attorney General Office of the Attorney General One Ashburton Placa. 19th Floor State House Station. #6 Boston. MA 02108 Auousta. ME 04333 The Honorable Edward J. Markev. Chairman Richard A. Hamos. Esc.
ATTN Linda Correia Hamne & McNicholas Subcommittee on Enerov Conservation and 35 Pleasant Street Power Concord. NH 03301 House Committee on E<erov and Commerce Washinoton. DC 20515 J. P. Nadeau Allen Lampert Board of Selectmen Civil Defense Director 10 Central Street Town of Brentwood Rve. NH 03870 20 Franklin Street Exeter. NH 03033 i
William Armstreno Sandra Gavutis. Chairman Civil Defense Director Board of Selectmen-Town of Exeter RFD #1 Box 1154 10 Front Street Kensinaten. NH 03B27 Exeter. NH 03833 Calvin A. Cannev Anne Goodman. Chairman City Manaaer Board of Selectmen City Hall 13-15 Newmarket Road 126 Dantel Street Durham. NH 03824 Portsmouth. NH 03801 William S. Lord Peter J. Matthews a
Board of Selectmen Mayor of Newburvoort Town Hall - Friend Street City Hall Amesbury. MA 01913 Newburvoort. MA 01950 R. Scott Hill-Whilton.Escuire Michael Santosuosso. Chairman Laoculis. Hill-Whilton & McGuire Board of Selectmen 79 State Street South Hampton. NH 03827 Nenourvoort.. MA 01950
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Docket fle.(s)S0-443/444-OL
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- A8 GRANT OF MOT!ON DTD-5/30/89 Stanlev W. Knowles Chairman Norman C. Katner-Boarc of Selectmen Suoerintencent of Schools P.O. Box 710 School Administrative Unit No. 21 North Hamoton. NH 03862 Alumni Drive Hamoton. NH 03942.
Sandra F. Mitchell The Honorable Civil Defense Director Gordon J. Humphrev Town of Kensincton ATTN Janet Coit Box 10. RR1 United States Senate East Kinoston. NH. 03827 Washincton. DC 20510 Dated at Rockville. Md. this 30 day of May 1989
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