ML20069F995
| ML20069F995 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/23/1982 |
| From: | Jordan W HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | Harbour J, Hoyt H, Luebke E Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20069F998 | List: |
| References | |
| NUDOCS 8209280322 | |
| Download: ML20069F995 (1) | |
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C0CKETED HARMON & WEISS '
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o" WI L LI AM S. JORD AN, lil LEE L. BISHOP OF COUNSEL DIANC CURRAN L.THOM AS GALLOWAY LYN N E BER NABCI LUCIA S. ORTH September 23, 1982 L/ c/ 3 Helen F.
Hoyt, Esq., Chairperson l
Dr. Jerry Harbour, Administrative Judge Dr. Emmeth A.
Luebke, Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Chairman Hoyt and Members of the Board:
I am enclosing NECNP Objections to Prehearing Con-ference Memorandum and Order and Motion to Certify Objections to the Appeal Board.
You should be aware that the need to respond'to the Board's Memorandum and Order has effectively prevented us from beginning discovery until today.
As a result, we have lost more than one week of discovery from the three month period that you established, or approximately 8% of the time available.
We will begin discovery immediately.
With the number of NECNP contentions that you have admitted, we expect that it will not be possible to complete discovery within the deadline that you have established, although we will make every effort to do so.
Should you or the Appeal Board reinstate any of the improperly denied contentions, we will have lost so much discovery time that it will be impossible to complete discovery by December 15, 1982.
Sincerely, UNl/W,'(
Willian('S. Jordan, III WSJ,III:cla Enclosure cc:
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