ML20214C934

Response to ASLB 861104 Order & Motion to Defer Hearing Schedule & Alternative Proposed Schedule.Scheduling & Hearing Should Be Deferred Due to Need for Coordination Between States of Ma & Nh in Evacuation Planning

ML20214C934
Person / Time
Site:	Seabrook
Issue date:	11/19/1986
From:	Brock M, Mceachern P HAMPTON, NH, SHAINES & MCEACHERN
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20214C935	List: ML20214C934 ML20214C950
References
CON-#486-1594 OL, NUDOCS 8611210290
Download: ML20214C934 (3)

Text

k,.

l UNITED STATES OF AMERICA gng ,

NUCLEAR REGULATORY COMMISSION rmer BEFORE THE ATOMIC SAFETY AND LICENSING BOARD j

'86 NDV 20 All :33 l 1

In the matter of g, .

00CKliin '. .cf l PUBLIC SERVICE COMPANY OF Docket No. 50-443-OL EW" ,

NEW HAMPSHIRE, et al 50-444-OL Seabrook Station, Units 1 and 2 I TOWN OF HAMPTON RESPONSE TO BOARD ORDER OF NOVEMBER 4, 1986 AND MOTION TO DEFER HEARING SCHEDULE AND ALTERNATIVE PROPOSED SCHEDULE NOW COMES the Town of Hampton, pursuant to this Board's KEEORANDUM AND ORDER dated November 4, 1986, and requests this Board to defer establishing a hearing schedule or, alternatively, to schedule the various events leading to the commencement of the off-site hearings.as follows:

I. The Town of Hampton requests this Board to defer establishing a schedule for events leading to hearings on off-site issues. In view of the need for coordination between Massachusetts and New Hampshire in evacuation planning, a Messachuset'ts plan could likely lead to further substantial revision of the NHRERP. Judicial economy therefore strongly suggests that this Board defer further scheduling and hearings until such time as an integrated hearing for both New Hampshire and Massachusetts on off-' site emergency issues can be held. By way of further support for the Town of Hampton's position, the Town relies upon, and incorporates by reference, EDI 8611210290 861119 PDR ADOCK 05000443 G PDR SH AINES M ADRIGAN & McFACHERN - PROFESSONAL ASSOO4Tch 29 MAPLEWOOD AVENUE PO Box MO Poet 5MOtJTH hw0 38901

t  ? ,

e ENGLAND COALITION ON NUCLEAR POLLUTION'S RESPONSE TO MOTION FOR DECISION ON MOTIONS FOR

SUMMARY

DISPOSITION AND FOR HEARING SCHEDULE WITH RESPECT TO EMERGENCY PLANNING ISSUES and SEACOAST ANTI-POLLUTION LEAGUE'S RESPONSE AND OBJECTION TO MEMORANDUM AND ORDER OF NOVEMEDR 4, 1986 AND MOTION FOR CLARIFICATION AND RECONSIDERATION.

II. Alternatively, should this Board decline to defer a further hearing schedule as requested above, the Town of Hampton would propose the following schedule for the various events leading the commencement of the hearings on the off-site issues raised by NHRERP. In proposing this schedule, the Town of Hampton requests this Board to consider in particular that the strict deadlines for responding to discovery requests on prior contentions resulted in numerous towns being unable to timely, fully, or properly respond to the voluminous discovery requested by Applicant. The proposed schedule is as follow:

January 1, 1987 Parties other than staff respond to contentions.

January 15, 1987 Staff responses to contentions.

February 12 & 13, 1987 Prehearing conference.

February 23, 1987 Board order ruling on contentions, discovery commences.

March 31, 1987 Discovery closed (last discovery request due).

2 SH AtNES. M ADRIGAN & McEACHERN - Ppos tssaowaL Association 33 baPLEWOOD avtNut - PO Bon MO PORTswouTH hw 03801

April 30, 1987 Answers to last interrogatories due.

Mey 14, 1987 Deadline for motions for summary disposition.

June 14, 1987 Responses opposing or supporting motions due.

June 29,1987 Opposing parties may file responses to new facts and arguments presented in state-ments supporting motions for summary disposition.

July 13, 1987 Board order ruling on motions for summary disposition.

August 17, 1987 Pretrial testimony due.

September 15, 1987 Hearings commence.

The Town of Hampton would request that the hearings be scheduled at a location within the Emergency Planning Zone.

Dated: November 19, 1986 Respectfully submitted, SHAINES & McEACHERN Attorne s for the Town of Hampton By -

faul M(Eachern By -

Matthew T. Brock 3

SHAINES. M ADRIGAN & McEACHERN - PRortssomat associarios 25 warttwooo av.Nur - Po son 360 PoRisuoUTH NM 03R01