ML20082L109

From kanterella
Revision as of 23:35, 19 April 2020 by StriderTol (talk | contribs) (StriderTol Bot insert)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
Opposes ASLB Conclusion Re J Laverty Participation in Proceeding & Requests Continuation of Proceedings Be Deferred Until Conflict of Interest Matters Resolved
ML20082L109
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 11/30/1983
From: Sugarman R
SUGARMAN & ASSOCIATES
To: Eilperin S, Gotchy R, Kohl C
Atomic Safety and Licensing Board Panel
References
NUDOCS 8312050414
Download: ML20082L109 (2)


Text

.

SUGARM AN & DENWO RTH C D'J E T E

ATTORN EYS AT LAW 'w' U sont oos nOCERT J. SUGARM AN S uit C sio. NO RTH AM E RIC AN S UIL DING JOANNE R.DENWORTH 121 SOUTH BROAD STREET ' $ g 2 M *. % * ' **

PHILAD ELPHIA. PENNSYLVANIA 19107 ROSIN T. LOCKC (215) 54 6-016 a ge- 4tOSCRI RAYMONO ELLIOTT, P. C.*

CCCi.CiMMEM::

E fu PLL,me .. .

November 30, 1983 Christine N. Kohl, Esquire, Chairman i Administrative Judge U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Stephen F. Eilperin Administrative Judge U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Reginald L. Gotchy Administrative Judge U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Application of Philadelphia Electric Company Docket No. 50-252/ 50-253 .

Dear Judges:

I have a copy of several letters which came in too rapid -

a succession to permit time for intervenors to respond.

Despite the Board's finding, which was rendered, apparently, immediately upon receipt of the letter from General Counsel, inter-venors believe that further inquiry is required into the matter of Ms. Laverty's disqualification, and therefore that of Conner &

Wetterhahn. Specifically, appellants do not believe that Ms. Laverty's statements and descriptions of the tour are sufficient to relieve her of the burden of substantial participation in the Limerick pro-ceedings, including those directly related to the supplemental cool-ing water issues.

Moreover, and specifically, appellants do not agree with the conclusion, in view of Ms. Laverty's purely conclusory statement, that she did not " participate" in disposing of Del-AWARE's 2.206 petition. Appellants request a detailed description of who in Commissioner Robert's office did " participate" in a specialized sense.

8312050414 831130 G PDR ADOCK 05000252

a .

Christino N. Kohl, Esquire, Chairman November 30, 1983 -

Stephen F. Eilperin Dr. Reginald L. Gotchy In view of Ms. Laverty's foot-dragging in disposing of this matter, appellants believe that justice requires that the argument scheduled for December 5 be deferred until answers to these questions are provided and the Board can make an intelligent decision. Alternatively, appellants request that the Board forward to the General Counsel or other appropriate body within the NRC the information and questions, and defer continuation of the proceedings until such matters are resolved.

Sincerely, r \.\u

.w \

Robert J. Sdgdrman RJS/kc cc: Conner & Wetterhahn General Counsel

^' - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ . _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __