ML20083A420

Request for Equivalent Time for Contention VI-1 Interrogatories.Limerick Ecology Action Time Limit of 840206 Requested.Certificate of Svc Encl.Related Correspondence

ML20083A420
Person / Time
Site:	Limerick
Issue date:	12/10/1983
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8312200282
Download: ML20083A420 (1)

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Pollution Patrol BROAD AXE, PA. Dec.10, 1983 U.S. Nuclear Regulatory Commission '83 DEC 14 P2:46 Washington, D.C. 20555 I

BEFORE THE ATOMIC SAFETY & LICENSING BOARD h h- [ ['((g.,,

BRANCH In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (LIMERICK GENERATING STATION and 50-353 Units 1 and 2)

Judges Lawrence Brenner, Chairman; Richard F. Cole; Peter A. Morris Gentlemen:

REQUEST FOR EQUIVALENT TIME-Contention VI-l was the last accepted conter. tion in the Limerick licensing hearings. It was accepted after contentions of LEA, I-41; I-42 and LEA Series VIII as per " Memorandum and Order" of November 21, 1983.

Contention VI-l is far more involved and covers more years of activity requiring discovery at site, then time necessary for accep-ted contentions of LEA.

It is unfair that contention VI-l is denied-equivalent time for interrogatories than LEA, and I move that the, Board extend discovery time at least to that of LEA.

I so move because of Applicant's delayed answers to my interro-gatories together with Applicant's interrogatories sent to me chich I cantt answer because they have delayed answers to interrogatories I sdbmitted. As a result hearing time required for hearings on V-4 now prevent attention to VI-l interrogatories.

I, therefore, plead and require as much or more time than LEA limit of Feb. 6, 1984.

Resp fully submitted,'.

RP ION PATROL 8312200282 B31210 ,

PDR /, DOCK 05000352 G PDR Frank . Romano, Chairman 61 Forest. Ave.

FRR/jc,h I certify the above has been served on the Service List.

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