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| Filcd: January 14, 1983 gxrs C0gyF UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4 t, .
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| .4^ hCH before the ATOMIC SAFETY AND LICENSING BOARD
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| In the Matter of )
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| PUBLIC SERVICE COMPAN1 OF NEW ) Docket Nos. 50-443 OL HAMPSHIRE, et al. ) 50-444 OL
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| (Seabrook Station, Units 1 & 2) )
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| APPLICANTS' MOTION TO COMPEL ANSWERS TO JNTERROGATORIES BY SEACOAST ANTI-POLLUTION LEAGUE Pursuant to C.F.R. 55 2.740(f), 2.740b, the Applicants move that the Board issue an order compelling Seacoast Anti-Pollution League ("SAPL") to answer interrogatories l
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| propounded to SAPL by the Applicants on December 8, 1982.
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| I In support of this motion, the Applicants say as follows:
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| I. The Applicants filed and served their " Applicants' Interrogatories and Request for the Production of Documents to Seacoast Anti-Pollution League" on December 8, 1982.
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| L 8301180187 830114
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| , PDR ADOCK 05000443 G PDR
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| v 2. The time within which SAPL was required to file and serve its answers to those interrogatories elapsed on December 28, 1982.
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| : 3. SAPL neither sought nor obtained any enlargement of the time for answering these interrogatories from the Board nor did it seek or obtain the Applicants' consent to a late filing of answers to these interrogatories. Nor has SAPL applied for or obtained any protective order.
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| : 4. As a consequence of the foregoing, SA?L is wholly in default of its obligations as an admitted party to this proceeding.
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| WHEREFORE, the Applicants move that this Board enter an order compelling Seacoast Anti-Pollution League to answer the interrogatories propounded to it by the Applicants on December 8, 1982 forthwith.
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| BJ
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| * p r a, or ys, Av Je
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| (-~~~
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| i , h pr . , ,,
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| Thomas G/Dignan,
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| . r-R. K. Gad III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone: (617) 423-6100 Dated: January 14, 1983.
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| CERTIFICATE OF SERVICE I, Rcbert K. Gad III, one cf the attorneys for the Applicants herein, hereby certify that on January 14, 1983 I made service of the within " APPLICANTS' MOTION TO r,OMPEL ANSWERS TO INTERROGATORIES BY SEACOAST ANTI-POLLUTION LEAGUE" by mailing copies thereof, postage prepaid, to:
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| Helen Hoyt, Chairperson Rep. Beverly Hollingworth Atomic Safety and Licensing Coastal Chamber of Commerce Board Panel 209 Winnacuanet Road U.S. Nuclear Regulatory Commission Fampton, NH 03842 Washington, DC 20555 Dr. Emmeth A. Luebke William S. Jordan, III, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 1725 I Street, N.W.
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| U.S. Nuclear Regulatory Commission Suite 506 Washington, DC 20555 Washington, DC 20006 Dr. Jerry Harbour E. Tupper Kinder, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Office of the Attorney General U.S. Nuclear Regulatory Commission 208 State House Annex Washington, DC 20555 Concord, NH 03301 Atomic Safety and Licensing Roy P. Lessy, Jr., Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, DC 20555 U.S. Nuclear Regulatory Lommistion Washington, DC 20555 Atomic Safety and Licensing Appeal Robert A. Backus, Esquire Board Panel 116 Lowell Street U.S. Nuclear Regu?.atory Commission P.O. Box 516 Warhington, DC 20555 Manchester, NH 03105 I
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| [ Philip Ahrens, Esquire Edward J. McDermott, Esquire Assistaat Attorney Ger.)ral Sanders and McDermott Department of the Attorney Professional Association General 408 Lafayette Road Augusta, ME 04333 Hampton, NH 03842 I
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| f Jo Ann Shotwell, Esquire David L. Lewis Atomic Safety and Licensing Assistant Attorney General
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| : Board Panel 2nvironmental Protection Bureau U.S. Nuclear Regulatory Commission Department of the Attorney General Rm. E/W-439 One Ashburton Place, 19th Floor Washington, DC 20555 Boston, MA 02108 Mr. John B. Tanzer Ms. Olive L. Tash 5 Morningside Drive R.F.D. 1, Daltan Road Hampton, NH 03842 Brentwood, NH 03833 State Representative Edward F. Meany Roberta C. Pevear 155 Washington Road Drinkwater Road Rye, NH 03G70 Hampton Fall s, NH 03844 Mrs. Sandra Gavutis RFD 1 East Kingston, NH 03827 ('- ~~s
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| Robert K. Gap' III nn-- -}}
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