ML20069F995

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Forwards New England Coalition on Nuclear Pollution Objections to ASLB 820913 Prehearing Conference Memorandum & Order & Motion to Certify Objections to Aslab.Response Caused Delay of Discovery for 1 Wk
ML20069F995
Person / Time
Site: Seabrook  NextEra Energy icon.png
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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WI L LI AM S. JORD AN, lil l LEE L. BISHOP , OF COUNSEL I DIANC CURRAN L.THOM AS GALLOWAY I LYN N E BER NABCI LUCIA S. ORTH September 23, 1982 L/ c/ 3 l

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: Service List h

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