ML19345B886

Request for Leave to Reply to Applicant & NRC Answers to Intervenor New England Coalition on Nuclear Pollution Motion to Suspend Const Due to Newly Acquired Info

ML19345B886
Person / Time
Site:	Seabrook
Issue date:	11/26/1980
From:	Jordan W, Weiss E NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SHELDON, HARMON & WEISS
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 8012020673
Download: ML19345B886 (2)

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- TIUCLEAR RE!;ULATORY COM?t [SSION V

~' " Y,79 @bD > b, i BEFORE THE ATOMIC S?.PETY AND LICI? S TNG APPEAL IK ' Cilin 00Qg ? se y,,

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In the Matter of )

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PUBLIC SERVICE COMPAN O? ) Docket Nog',250-443 Wi NEU HNIPSHIRE, et al. ) 9K;dO-443

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) w L MECNP T10TJ.ON POR LEAVE TO REPLY Pursuant to 10 CFR 2.730(c), NECNP moves that it be granted leave to respond to the answers of the Licensee and the Staf f to IIECNP's Motion to Suspend Construction.

Normally, a moving party has no right to reply to answers to such a motion. However, in this circumstance, NECNP did not have access to the factual information and opinions contained in the affidavits filed by the Licensee and the Staff and was unab]a to present any judgment on particular f acts in its liotion. With the affidavits in hand, we are now able to present such a judgment, just as the Licensee and Staff were able to do in their ansviers.

Accordingly, we request permission to file a reply. We intend to present an affidavit of an expert who has evaluated the information presented by the Licenace. Ne also intend to respond briefly to the legal arguments nade by both the Licensta and t',a Staff, and particularly to what we view as a misreading, if not a misrepresentation, of the Commission's Order.

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No hope to file this reply hv Pritfay, necember 5, 1980.

The delay is occasioned by the tact the" it to:)k us a few days to 1ocate an expert, and the expert is in Calif ornia.

Respec tf ull y sub:ni t ted ,

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Ellyn-R. Weiss */ / "

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IWlli ua &.' JordEri,~III Ilarmon & Weisn 1725 1 Street, N.N.

Suite 506 Washington, D.C. 20006 (202) 833-9070 Counsel for . Jew T:ngland Coalition on Nuclear Pollution November 26, 1980 cm m c-D D oo o P] . . 2