ML20080F109

Position on Scheduling of Offsite Emergency Planning Issues. Proposed Schedule Listed.Certificate of Svc Encl

ML20080F109
Person / Time
Site:	Seabrook
Issue date:	09/13/1983
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:
References
NUDOCS 8309190167
Download: ML20080F109 (4)

Text

Datcd:

Scpt mbar 13, 1983 00CHETED USNC 23 9716 A11:44 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CffT hP E' I

BRANCH before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of

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PUBLIC SERVICE COMPANY OF NEW

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Docket Nos. 50-443 HAMPSHIRE, et al.

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50-444

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(Seabrook Station, Units 1 & 2)

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APPLICANTS' POSITION AS TO SCHEDULING.0F OFFSITE EMERGENCY PLANNING ISSUES It is the Applicants' understanding that the last of the Massachusetts local plans is supposed to be available November 30, 1983 and the suggested schedule is based upon that " trigger date".

It should be noted that with respect to the State Plan and any local plan made available prior to November 30, 1983, the time to formulate contentions will be longer by virtue of the earlier availability.

At the hearing the Applicants suggested the possibility that matters might be facilitated by declaring discovery open at this time which would permit interested parties to 9309190167 830913 PDR ADOCK 05000443 o[

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obtain the draft plans which Massachusetts is reluctant to release voluntarily.

Unfortunately it appears that the language of 10 CFR $ 2.740(b) precludes the opening of discovery prior to the admission of contentions.

Thua absent a willingness by Massachusetts to engage in voluntary discovery prior to the admission of contentions no discovery is possible.

The schedule set forth below collapses the times set out in the Board's earlier tentative schedule and also removes any particularized scheduling for the Summary Disposition process.

Summary disposition can be utilized under the rules of practice standing alone.

Nov. 30, 1983 Last local plans available to parties Dec.

9, 1983 Contentions due - in hand Dec. 15, 1983 Responses (other than Staff) to contentions due - in hand Dec. 19, 1983 Staff Responses due - in hand Dec. 23, 1983 Responses of original propounders of contentions due - in hand.

Jan.

6, 1984 Board Ruling on contentions -

Discovery opens Jan. 20, 1984 Discovery closes Feb.

3, 1984 Last discovery response due March 1,

1984 Direct Testimony Filed March 12, 1984 Rebuttal Testimony Filed March 19, 1984 Hearing Respectfully submitted, M6Es's ' ~ - lgnan, Jr.

R.

K.

ad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100.

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b-CERTIFICATE OF SERVICE 1

I, Thomas G..Dignan, Jr.,

one of the attorneys for the Applicants herein, hereby certify that.on September 13, 1983, I made service of the within document by mailing copies thereof, postage prepaid, to:

Helen Hoyt, Chairperson Brian P.

Cassidy, Esquire Atomic Safety and Licensing Regional Counsel Board Panel Federal Emergency Management U.S. Nuclear Regulatory Commission Agency - Region I Washington, D.C.

20555 442 POCH Boston, MA 02109 Dr. Emmeth A. Luebke William S. Jordan, III, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 1725 I Street, N.W.

U.S. Nuclear Regulatory Commission Suite 506 Washington, DC 20555 Washington, DC 20006 Dr. Jerry Harbour George Dana Bisbee, 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 Atomi'c 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 Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Robert A.

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

Nuclear Regulatory Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Anne Verge, Chairperson Assistant Attorney General Board of Selectmen Department of the Attorney Town Hall General South Hampton, NH Augusta, ME 04333 David R.

Lewis, Esquire Jo Ann Shotwell, Esquire Atomic Safety and Licensing Assistant Attorney General Board Environmental Protection Bureau U.S. Nuclear Regulatory Commission Department of the Attorney General Washington, DC 20555 One Ashburton Place, 19th Floor Boston, MA 02108 l

Mr. John B. Tanzer Brentwood Board of Selectmen 5 Morningside Drive R.F.D., Dalton Road Hampton, NH 03842 Brentwood, NH 03833 State Rep. Roberta C.

Pevear Calvin A. Canney, City Manager Drinkwater Road City Hall, 126 Daniel Street Hampton Falls, NH 03844 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Patrick J. McKeon RFD 1 Selectmen's Office East Kingston, NH 03827 10 Central Road Rye, NH 03870 Senator Gordon J. Humphrey Mr. Angie Machiros U.S.

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

Tom Burack)

Town of Newbury Newbury, MA 01950 Town Manager's Office Richard E.

Sullivan, Mayor Town Hall - Friend Street City Hall Amesbury, MA 01913 Newburyport, MA 01950 Ms. Diana P.

Randall Donald E. Chick, Town Manager i

70 Collins Street Town of Exeter Seabrook, NH 03874 10 Front Street Exeter, NH 03833 Senator Gordon J-Humphrey one Pillsbury Street Concord, NH 03301 (Attn:

Herb Boynton) b Tltenfis G. Dftfnan, Jr.

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