ML20198E195

Response Opposing New England Coalition on Nuclear Pollution 860512 Motion for Reconsideration of Denial of Extension of Time for Answering 860429 Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20198E195
Person / Time
Site:	Seabrook
Issue date:	05/16/1986
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
References
CON-#286-253 OL, NUDOCS 8605270310
Download: ML20198E195 (5)

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May 16, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION /

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ATOMIC SAFETY AND LICENSING Boa RD rnNGS scre"Wjcu

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In the Matter of

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PUBLIC SERVICE COMPANY OF

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Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.

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50-444-OL

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Off-site Emergency (Seabrook Station, Units 1 and 2

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Planning Issues

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APPLICANTS' RESPONSE TO NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S MOTION FOR RECONSIDERATION OF DENIAL OF EXTENSION OF TIME FOR ANSWERING INTERROGATORIES On April 29, 1986, the applicants' filed a set of interrogatories upon New England Coalition on Nuclear Pollution (NECNP).

Under a previously issued Board Order, answers were due in hand to these interrogatories on May 14, 1986.

On May 12, 1986, only two days before the date on which answers were due, NECNP filed a joint motion with Seacoast Anti-Pollution League (SAPL), Town of South Hampton (TOSH), and the Town of Hampton Falls (HF) seeking, inter alia, an extension of time for answering the interrogatories

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4 served upon NECNP, SAPL, POSH and HF by the applicants.

This motion was denied by the Board.

Thereafter, SAPL, TOSH and HF filed responses to the applicants' interrogatories.

NECNP filed the motion to reconsider,at bar.

Applicants oppose the motion and say the same should be denied.

Applicants' realize, however, that this motion, like the original motion for an extension of time, is addressed to the sound discretion of the Board.

We respectfully suggest that the Board should exercise its discretion to deny the motion because to do otherwise is to permit NECNP to obtain by indirection relief it was once denied when requested directly.

Respectfully submitted,

_,ars M

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Thomas G.

Dignan, Jr.

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K. Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for applicants

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3-t CERTIFICATE OF SERVICE I, Thomas G.

Dignan, Jr.,

one of the attorneys for the Applicants herein, hereby certify that on May 16, 1986, I made service of the within Applicants' Response to New' England Coalition on Nuclear Pollution's Motion for Reconsideration of Denial of Extension of Time for Answering Interrogatories by depositing copies thereof with Federal Express, prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):

Helen Hoyt, Chairperson Robert Carrigg, Chairman Atomic Safety and Licensing Board of Selectmen Board Panel Town Office U.S.

Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway

.Bethesda, MD 20814 Dr. Emmeth A.

Luebke Diane Curran, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 2001 S Street, N.W.

U.S.

Nuclear Regulatory Suite 430 Commission Washington, DC 20009 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S.

Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814

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• Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S.

Nuclear Regulatory Director Commission U.S.

Nuclear Regulatory Commission Washington, DC 20555 Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814

• Atomic Safety and Licensing Robert A.

Backus, Esquire Appeal Board Panel 116 Lowell Street U.S.

Nuclear Regulatory P.O.

Box 516 Commission Manchester, NH 03105 Washington, DC 20555 Philip Ahrens, Esquire Mr.

J.P.

Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S.

Sneider, Esquire Matthew T.

Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O.

Box 360 Boston, MA 02106 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A.

Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

• Senator Gordon J.

Humphrey Mr. Angie Machiros U.S.

Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn:

Tom Burack)

Town of Newbury Newbury, MA 01950

• Senator Gordon J.

Humphrey Mr. Peter J.

Matthews 1 Pillsbury Street Mayor Concord, NH 03301 City Hall (Attn:

Herb Boynton)

Newburyport, MA 01950

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Mr. Thomas F.

Powers, III Mr. William S.

Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H.

Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.

Washington, DC 20472 Gary W.

Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 Mr. Ed Thomas FEMA, Region I 442 John W. McCormack Post Office and Court House Post Office Square Boston, MA 02109

(*= Ordinary U.S.

First Class Mail.)

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