ML20209H287

Forwards Proposed Findings of Fact & Conclusions of Law in Form of Partial Initial Decision

ML20209H287
Person / Time
Site:	South Texas
Issue date:	11/07/1985
From:	Sinkin L Citizens Concerned About Nuclear Power, INC., SINKIN, L.A.
To:	Bechhoefer C, John Lamb, Shon F Atomic Safety and Licensing Board Panel
Shared Package
ML20209H293	List: ML20209H287 ML20209H304
References
CON-#485-109 OL, NUDOCS 8511110062
Download: ML20209H287 (2)

Text

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.nne Thursday, November 7, 1985 W llEf J

Charles Bechhoefer gs Chairman 6

'b Atomic Safety and Licensing Board s

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Nuclear Regulatory Commission Washington, D.C.

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Frederick J.

Shon L

'gac a Gl Administrative Judge 41?31

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Atomic Safety and Licensing Board c.

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Nuclear Regulatory Commission

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N Washington, D.C.

20555 Dr. James C. Lamb, III Administrative Judge Atomic Safety and Licensing Board 313 Woodhaven Road Chapel Hill, North Carolina 27514

Dear Members of the Board:

Enclosed is Citizens Concerned About Nuclear

Power, Inc.'s Proposed Findings of Fact and Conclusions of Law in the Form of a Partial Initial Dec. i si on.

I delivered the

text, absent a Table of

Contents, to the Applicants. at 5:30 p.m.

on October 5 and to the NRC Staff at 10:30 a.m.

on October 6.

Today, I am hand delivering copies to Chairman Bechhoefer and Judge Shon, sending a copy Express Mail to Judge

Lamb, and either hand delivering or-mailing the remaining copies.

.I am also delivering the final bound copy to the Applicants and the NRC Staff counsel today.

The unexpected delay in the delivery of this document is traceable to a last minute decision to eliminate a significant part of the proposed findings and opinion which dealt with

the, performance of Applicants' counsel. I made this decision prior to re:eiving Applicants' response to my motion to withdraw an earlier

motion, a response I have still not read and probably will not respond to.

My decision was based on a

desire to reestablish a

more professional relationship between CCANP's representative and Applicants' counsel.

This has been a long and difficult proceeding, characterized at times by hostility between myself and opposing counsel.

Obviously, we should refrain from such

activity, and the Board spoke to this issue after the prehearing conference.

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-i Members of the Board November 7, 1 85 Page Two i

Having decided to eliminate this section of the opinion and

brief, I then.had'to.make changes to the existing document.

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these changes not been necessary, the document. would have been delivered on time to all parties.

Once the. text was in the hands of.the Applicants and the NRC

Staff, I

began preparing the final, document _-for printing.

As I did so, I noticed typographical errors.

Since the two parties requiring hand delivery had the text, I decided to clear up the final copy ' prior to mailing the remaining copies.

By hand delivering the final copy to Chairman Bechhoefer and Judge Shon and Express mailing Judge Lamb's

copies, these copies are delivered in advance. of the day they would have

arrived, if mailed on October 5.

I-apologize for the delay and recognize that I

should have contacted.the Board for an extension.

I do not believe any party was prejudiced by the delay, since Applicants received the text within an hour of its due time and the NRC Staff counsel was too busy' working on his own findings when I delivered ours to have had any time to look at ours anyway.

Sincerely, c

ir Lanny Sinkin Repreventative for "CCANP c.c.

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