ML20035B566
| ML20035B566 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/25/1993 |
| From: | Marucci M CO-OPERATIVE CITIZEN'S MONITORING NETWORK, INC. (CCMN |
| To: | |
| References | |
| CON-#293-13810 OLA, NUDOCS 9304020159 | |
| Download: ML20035B566 (2) | |
Text
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UNITED STATES CF AMERICA NUCLEAR CEGULATORY CCMMISSION i
'93 WR 29 P ? :55 EECORE TWE OT^*1C EaFETV cMD LICENSING EC04D in the Matter f
Ncrtheast Nuclear Energy Co.
)
Docket No. 50-3S6-OLA.
i Millstone !! *iuc l e ar Fower Flant
) (Spent F;el cool Design)
CCCPEo4TIVE CI~IZEN'S MONITCRING NETWORK AFFIRMATION OF TIMETABLE: FCR RESPONSES TO ASLB ORDER COR CCMN TO RESPOND _
I TO DISCOVERY REQUESTS FROM NRC STAFF AND NNECO.
CCMN intends te honor the ASLP order to respond to NNECO and i
NRC. interrogatories.
In fact, CCMN's response to NRC l
interrogatories were sent prior to the issuance of that order.
In our response to NRC of March 9,
1993, CCMN indicated that Dr. Kaku would respond to certain NRC questions at his deposition.
f NNECO counsel, David Repka. had contacted CCMN to inform us that the propcsed March 22 date was not suitable to NRC 1
C o u n e. e 1.
I personally gave him permission to contact Dr.
l Kaku directiv to find a suitable time for all three parties.
[
Since CCMN was not notified until March 15 that NNECO had nc intention of deposing Dr. Kaku, we had assumed it was from i
difficulty of NNECO counsel and Dr. Kaku in finding a suitable time.
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1 in fact Dr. Kaku was never cortacted and, as of March 21, was expecting to be deposed on March 22.
When I-contacted him on March Elst, he said he would need at least until March 31 to respond in writing.
The bulk of NNECD questions l
must be answered by Dr. Kaku and it was agreed earlier that l
those responses would be accepted at his deposition.
[
We find it inappropriate that the board talk of sanctions when in fact we seem to have been set up.
But we can honor your order based on the fact that service was by first class mail mailed on March 16 to which we add five days for delivery and the 10 days following service that you specify.
Therefore, we will mail our response on April 1,
1993.
Because we have a tentative conference call set April 7th at 2 P.M.-we can, as a courtesy, fax our responses to NNECO and NRC counsel and the chairman of the Board if.any party so e
indicates that it is des ceo.
. Summary judgements are not what we seek.
We do still-seek a
public h ea r i r.g.
Mr. Thomas Martin of the NRC and CT.
Congresswoman Rosa DeLauro have indicated that hearings were l
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9304020159 930325
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PDR ADOCK 05000336
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f to be. held and that the license would not be given until one I
was held.
Obvicusly the latter is not true.
It.sould be a I
shame that both were not true.
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YQ Maecn 25.*.993 Mary Ellen Marucci l
C:ordinatcr, :CMN,Irc.
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i served by first class mail on Maren 26, 1993 from New Haven, i
l CT to those listed celow.
Those marked with an
(*)
were I
faxed on March E5, 1993.
l Mg s
March 26, 1993 Mary Ellen Marucci Office cf Ccmmission Appellate Adjudication U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 I
Administrative Judges Attn: Chairman, Ivan W.
Smith l
Atomic Safety and Licensing Board
'i U.S.
Nuclear Regulatory Commission 1
Washington, D.C.
20555 John T.
Hull, Esq.
Office of the General Counsel L
U.S.
Nuclear Pegulatory Commission i
)
Washington, D.C.
20555 l'
Office of the Secretary i
j Attention: Docketing and Service Section l
l U.S.
Nuclear Regulatory Commission j
Washington, D.C.
20555 j
Nicholas Reynolds, Esq.
Winston & Strawn E
1400 L Street, N.W.
Washington, D.C.
20005 Professor Michio Kaku Department of Physics City College of New vert L
138th Street and Corvent Avenue New York, NY 10031 1
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