ML19282C149
| ML19282C149 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/13/1979 |
| From: | Sekuler S ILLINOIS, STATE OF |
| To: | Rowe J ISHAM, LINCOLN & BEALE |
| References | |
| NUDOCS 7903210079 | |
| Download: ML19282C149 (2) | |
Text
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.e p co@g jWILLIAM J. scott ATTORNEY GENERAL 6C)
STATE OF ILLINolS g
TELEPHCNE ISO NORTH LA SALLE STREET
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7'* 85oo CHICAGO 60601
?e sp &.& 9 February 13, 1979 e
Mr. John Rowe, Esq.
Isham, Lincoln & Beale One First National Plaza Chicago, Illinois 60690
Dear John:
This is to inform you that I will be unable to file the State of Illinois response to Applicants and NRC Staff's motions for summary disposition in the Zion case by February 15, 1979 as we had informally agreed.
I will file some response by February 21, 1979 as required by 10 CFR S2.749(a).
The reasons for the delay are as follows:
1.
The transcripts of the Depositions of Leider, Pliml and Tramm have not yet been received.
I am relying on those trans-cripts for responses to motions in regard to at least two contentions.
2.
The affidavits from Resnikoff in Buffalo, N.Y.
and MHB in Palo Alto, California have not yet been received.
I have been informed that they will both be forthcoming within a few days.
3.
I have been unable to obtain an affidavit from Dr. Cember as he has been incapacitated for the past month with a broken leg.
He will be out of town until Wednesday, February 14.
I plan to have his affidavit by the end of this week.
4.
The SER has not been made available so that the State's consultants have been unable to prepare complete responses.
5.
The State has declared both February 12 and February 19 office holidays.
Therefore I will not be able to file before February 21 due to lack of back up staff to help process the response.
I apologize for the delay.
As you knew our policy has been to meet deadlines whenever possible to speed the hearing process.
7 903 2100~li
In this case it is simply impossible to meet the early date. I do not think this minor change will influence the timing of the litigation as the SER is yet to be published and no date has been set for the S2.752 pre-gearing conference, therefore the Board will have received our first response before their next meeting.
I thank you for your indulgence in this matter.
Very truly yours, SUSAN N.
SEKULER Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 793-2491 SNS: dan CC:
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