ML20070D025

Motion for Continuance of Discovery Deadline to 830601. Continuance Fair in Light of Rescheduling of Projected Fuel Loading Dates.Previous Deadline Burdensome & Would Impede Litigation of Intervenor Contention.Related Correspondence

ML20070D025
Person / Time
Site:	Seabrook
Issue date:	12/09/1982
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20070D027	List: ML20070D025 ML20070D066
References
ISSUANCES-OL, NUDOCS 8212140426
Download: ML20070D025 (2)

Text

/  % h_. I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '- '

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BEFORE THE ATOMIC SAFETY AND LICENSING BO ARD- y.;,

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PUBLIC SERVICE COMP ANY OF Docket Nos. 50-443 O L 'E NEW II AMPSHIRE, et al 50-444 OL p N

(Seabrook Station, Units 1 and 2)

MOTION FOR CONTINUANCE OF DISCOVERY DEADLINE NOW COMES the Seacoast Anti-Pollution League ("SAPL"), an Intervence in the above named proceeding, and respectfully requests that the Atomic Safety and Licensing Board continue its December 15, 1982 deadline for discovery to June 1,1983.

SAPL contends that such a continuance would be reasonable and fair to the parties involved in light of the recent rescheduling of projected fuel loading dates by the Applicant. Attached is the letter sent by the Applicant to the Board of November 30, 1982 indicating a projected fuel loading date of September 1984 for Unit I and December 1986 for Unit 2.

SAPL contends that in light of this development, adherence to the December 15th deadline would be unduly burdensome to the parties involved, and would impede SAPL's ability to fully and fairly litigate its contention in this proceeding. At the present time SAPL had not completed discovery, and it still activley involved in acquiring data and documents for' preparation of its case. Due to the complexities of the matters involved in this proceeding, SAPL contends that the granting of this continuance would be in the best interests of all parties to this proceeding.

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.s Respectfully submitted, SEACO AST ANTI-POLLUTION LEAGUE By its Attorneys, LAW OFFICES OF ROBERT A. BACKUS ROBen NUS " ~

P. O. Box 516 Manchester, NH 03105 (603)668-7272 December 9,1982 e

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