ML20054H274
| ML20054H274 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/21/1982 |
| From: | Eddleman W AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8206230180 | |
| Download: ML20054H274 (2) | |
Text
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UNITED STATES OF AMERICA NUCLEAR RFDULATORY (DMMISSION June 21,1982 j
Before the ATOMIO SAFETY AND LICENSING BOARD Dockets !$0-400/401 0.L.
\\
Pursuant to the June 3 conference call and the Board's order served June 7, 1982 as regards a list of 20 contentions to first be discussed at the special prehearing conference now scheduledsfumf for July 13-1h,1982, Wells Eddleman states the following:
(1) since at this stage of theproceeding it is not necessary to reach the merits of any contention, but only to establish that contentions are sufficiently specific to put Applicants on notice "at least generally,"what they are expected to defend against,U the following in no way states, nor can the Board require me to qvtod,pperhwt'or state, which are thej"best" contentions I have filed.
I object to that part of the Board's Order served June 7 as impuum improper and irrelevant, for the above reasons.
- Yet, (2) it is obvious from the conference call (transcript not yet at the LPDR) of June 3 that the Board wants me to list the fi=st 20 contentions I want to have discussed at the July 13-14 conference, and perhaps a further "next 20".
Subject to the above, I have no l
some of problem doing that.
The list of contentions follows, with those 4
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related to a contenti on designated for discussion pla ced in parentheses parenthesis and in it a list for some listed contentions.
A lack of esa(ne does not mean there j
are not related contentions to one listed.
3 7 (69,8)
First 20 to discuss: #'s 3(127x, ete;6-5-82 amendment),4,71, 14,41-42f,G
^
15(16thru23,y4,95,104,114,126,126x,129etc),57(56,1,2,29,30,32,97
/
103,6 81,99,139,140),46,47(48-51,97,110,115,125,130),54(53,133,33,34),59,60, 106,6%
64 (24-28,etc),VeS et 78(134)R,84,87,105,112,115,132.
Next 20:
j 7 0, 71, 72,116,131,136,137, 6, 33, 73,110, 91, 97,103,120,10,128, Q d(dds M"~
l 8206230100 820621 l
PDR ADOCK 05000400 G
f 0 )-
CERTIFICATE OF SERVICE I hereby certify that the following have been served with a cony of the lists of first 20 and second 20 oontentions to discuss, as I wrote them, on the back of this page.
Service was by first class US mail, postage prepaid, in a depository under the exclusive care & custody of the US Postal Service, on June 21, 1982.
'!<W This 21st day of June,1982.- -
Wells Eddleman l
ATOMIC SAFETY AND LICEN3ING BOARD and to all petitioners to Dockets 50-400/401 0.L.
intervene.
Judges Kelley, Carpenter and Bright US NRC Washington DC 20555 (one copy enclosed for each judge)
Marjorie Ulman Rothschild l
Counsel for NRC Staff USNRC Washington, DC 20555 Secretary of the Commission USNRC Washington DC 20555 l
(3 copies)
George F. Trowbridge Shaw Pittman Potts & Trowbridge 1800 M St. NW Washington Do 20036 (CP&L has not responded as to whom to serve; I assume Trowbridge is still the one, but this once I'll also serve Richard Jones in Raleigh, since CP&L doesn't seem to use its resources to answer l
even a simple question.)
Richard B. Jones l
Legal Department CP&L Box 1551 Daleigh NC 27602 l
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