ML20132C553

Forwards Notice of Appearance for Bp Garde,Per ASLB 850917 Order.Certificate of Svc Encl

ML20132C553
Person / Time
Site:	Comanche Peak
Issue date:	09/24/1985
From:	Roisman A TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:	Bloch P, Grossman H, Jordan W Atomic Safety and Licensing Board Panel
References
CON-#385-616 OL-2, NUDOCS 8509270086
Download: ML20132C553 (5)

Text

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! TRIAL. l.AWYERS FOR Pusuc JUSTICE, P.C.

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j COUN5tuCRS AT LAW j m 6H C7A g7g7

! 2000 P STREET. NORTHWEST USNRC t

ANTHONY 2. ROISMAN MASHINGTON, D.C. 20036 (202)463-8600 ExtCUTM DIRECTOR l ARTHUR .RvANT STAFF ATTORNEY

'85 SEP 26 A10:44 5ANDRA SHEPHtRD OmCt MANAGER g((l({ (i { .ilt M 00CKETtHU is SEPVH?

September 24, 1985 BRANCH Peter Bloch, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Herbert Grossman Alternate Chairmen Atomic Safety and Licensing Board Washington, D.C. 20555 Walter H. Jordan, Member Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: In the matter of Texas Utilities Generating Company, et al. (Comanche Peak Steam Electric Station, Units 1 and 2), Docket Nos. 50-445-2 and 50-446-2 Gentlemen:

As requested in the Board?s Order of September 17, 1985, enclosed is the Notice of Appearance for Ms. Garde. Inasmuch as the Order was issued before CASE had the opportunity to respond, there are a few points that we wish to make for the record:

1. We acknowledge that we made a mistake, albeit an honest mistake. We shall take steps to avoid similar mistakes in the future.

2. Our informal dealings with Applicants since last ,

February have been substantially fruitless, but we will in the future " exhaust our informal remedies" before formal filings as the Board has directed.

3. The document, while signed by Ms. Garde, was prepared under my supervision and I fully accept responsbility for it.

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4. We do not believe that raising issues regarding the conduct of counsel for CPSES, if well-founded, are ad hominem attacks since the character and competence of Applicants is.in large measure governed by who they contract with and how they control those contractors.

We regret that our filing created the impression that we

-were "grandstanding" and stress that it was not our intent.

Sincerely, 6E N b w Anthon Executive Y.he Roisman Director' g ,,

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• UNITED STATES OF AMERICA l

NUCLEAR REGULATORY COMMISSION 3-gg, UaRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'85 SEP 26 A10:44 In the Matter of )

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TEXAS UTILITIES GENERATING COMPANY, et al.

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Docket Nos. 50-445-EhC and 50-446-2 b

HANCH bt

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(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

NOTICE OF APPEARANCE Notice is given that the undersigned appears on behalf of Citizens Association for Safe Energy in the above captioned matter. In accordance with Section 2.713, 10 C.F.R. Part 2, the following information is provided:

Name: Billie Pirner Garde Address: Trial Lawyers for Public Justice 2000 P Street, NW Suite 611 Washington, D.C. 20036 Telephone: 202-463-8600 Name of Party: Citizens Association for Sound Energy 3 h U- a BILLIE PIRNER GARDE Trial Lawyers for Public Justice 2000 P Street, NW Washington, D.C. 20036 (202) 463-8600 DATED at Washington, D.C. this 24th day of September, 1985. j 4

September 24, 1985

"> cc;ggygg USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'85 SEP 26 A10 M4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD CFFICE C :;3t ;m DOCXETING 4 SEfivir.r In the Matter of ) SRANCH

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TEXAS UTILITIES GENERATING )

COMPANY, et al. ) Docket Nos. 50-445-2

) and 50-446-2 (Comanche Peak Steam Electric )

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and corr,ect copies of CASE's Notice of Appearance have been sent to the names listed below this 24th day of September, 1985, by:

Express mail where indicated by *; Hand-delivery where indicated by **; and First Class Mail unless othenvise indicated.

4 Administrative Judge Peter B. Bloch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Herbert Grossman ,

Alternate Chairman ASLB Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom, Dean

• Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74074

2-Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 Ms. Ellen Ginsberg, Law Clerk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert A. Wooldridge, Esquire Worsham, Forsythe, Sampels

& Wooldridge 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 Nicholas Reynolds, Esquire Bishop, Liberman, Cook, Purcell & Reynolds Wa i gt n DC b36 Stuart Treby, Esquire Geary S. Mizuno, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Renea Hicks, Esquire Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis President, CASE 1426 S. Polk Dallas, Texas 75224 s f Q ANTHONT'Z. ROISMAN gy L