ML19345H411

Answer Opposing Citizens for Fair Util Regulation 810512 Motion for Extension of Three Wks in Which to Respond to Applicant Third Set of Interrogatories.No Good Cause Shown. Certificate of Svc Encl

ML19345H411
Person / Time
Site:	Comanche Peak
Issue date:	05/18/1981
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8105200250
Download: ML19345H411 (4)

Text

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May 18, 1981

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UNITED STATES OF AMERICA .s(,----~.s - '

NUCLEAR REGULATORY COMMISSION N'

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD)

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In the Matter of

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-44  ;,3 COMPANY, ~et al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for f' Station, Units 1 and 2) ) Operating /J LicenssO' 9 [' '

) M APPLICANTS' ANSWER TO CFUR'S MOTION Y

FOR EXTENSION OF TIME .

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Pursuant to 10 C.F.R. $2.730(c) Texas Utilities Generating _-

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Company, et al. (" Applicants"), hereby submit their answer to the May 12, 1981 motion of Citizens for Fair Utility Regulation ("CFUR") for an extension of time in which to respond to Applicants' third set of interrogatories.

CFUR requested an extension of three weeks, until June 2, 1981, in which to respond to Applicants' interrogatories.

Applicants oppose CFUR's motion. Discovery in this f proceeding is progressing at much too slow a pace. Exten-l sions of time in which to respond to valid discovery requests should no longer be granted absent a strong show1. ' of good cause. CFUR has not, however, demonstrated good cause for the requested extension of time. All parties must meet f

numerous deadlines in this proceeding, but no party should be excused from meeting their responsibilities as a participant simply for that reasoh. Accordingly, Applicants urge the g S

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I Board promptly to deny CFUR's motion and order that CFUR  !

I immediately */ provide .:omplete and responsive answers to Applicants' third set of interrogatories.

Respect u submitted, ht, i

Nicholi S[}Reynolds v

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William A. Horin

d. L DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9817 Counsel for Applicants May 18, 1981 1

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j */ CFUR has already received, in effect, a 6-day extension of time by filing the motion for extension. Accordingly, Applicants request

• that the Board inform CFUR by telephone of the Board's decision, and subsequently mail a written Order to the parties.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, et al.

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) 50-446

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, (Comancho Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' Answer To CFUR's Motion For Extension Of Time," in the above-captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 18th day of May, 1981:

Valentine B. Deale, Esq. */ Chairma n', Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel

. Licensing Board U.S. Nuclear Regulatory .

1001 Connecticut Avenue, N.W. Commission Washington, D.C. 20036 Washington, D.C. 20555

Dr. Forrest J. Remick, Member Marjorie Ulman Rothschild, Esq.

Atomic Safety and Licensing Office of the Executive 4

Board Legal Director 305 E. Hamilton Avenue U.S. Nuclear Regulatory State College, Pennsylvania 16801 Commission Washington, D.C. 20555' Dr. Richard Cole, Member Atomic Safety and Licensing David J. Preister, Esq.

Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection

, Commission Division l Washington, D.C. 20555 P.O. Box 12548 Capitol Statien Chairman, Atomic Safety and Austin, Texas 'ic711 *.

Licensing Board Panel l U.S. Nuclear Regulatory Mr. Richard L. Fouke l Commission CFUR l Washington, D.C. 20555 1668B Carter Drive

. Arlington, Texas 76010

• / By hand delivery.

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Arch C. McColl, III, Esq. Dwight H. Moore, Esq.

701 Commerce Street West Texas Legal Services Suite 302 100 Main Street (Lawyers Bldg.)

Dallas, Texas 75202 Fort Worth, Texas 76102 Jeffery L. Hart, Esq. Mr. Chase R. Stephens 4021 Prescott Avenue Docketing & Service Branch Dallas, Texas 75219 U.S. Nuclear Regulatory Commission Mrs. Juanita Ellis Washington, D.C. 20555 President, CASE 1426 South Polk Street Dallas, Texas 75224 4

William A. Horin cc: Homer C. Schmidt Spencer C. Relyea, Esq.

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