ML20134H319
| ML20134H319 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/19/1985 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#385-330 OL, NUDOCS 8508280365 | |
| Download: ML20134H319 (4) | |
Text
',1)
.W W UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'85 AUG 26 Pl2:12 In the Matter of
~l Docket Nos. 50-4450 '
i and 50-4460FFICE CF SECRETAN y TEXAS UTILITIES ELECTRIC 1
,00CXETING & SERvitt COMPANY, et al.
I SRANCH Q
(Application for an (Consnche Peak Steam Electric i
Operating License)
Station, Units 1 and 2)
{
CASE'S MOTION FOR BOARD TO ORDER APPLICANTS TO SUPPLY DOCUMEllTS TO BOARD Throughout these proceedings, it has always been (and still is) CASE --
not the Applicants or the NRC Staff - which has provided the Board with the documents necessary for it to make a reasoned and informed decision.
It was not CASE's responsibility to get the contracts referenced (and in some instances, attached) in CASE's attached two pleadings n / into the hands of the Board - it was the Applicants' responsibility. They have asked the Board to rule' favorably on an incomplete CPRT Plan, without the Board's having complete and vital information in hand, which the Applicants could, and should, have provided before they requested any decision on the CPRT Plan.
CASE urges-that the Board act immediately to stop this blatant and continuing attempt by Applicants to always place the Applicants' burdens on CASE, and that the Board order Applicants to provide the Board with all the documents referenced in the CPRT Plan which have not yet been provided (but are promised at some future, unspecified time), as well as documents which
/1/ See CASE's 8/19/85 Offer of Proof of Lack.of Independence of Applicants' Latest Plan (CPRT Plan); and CASE's 8/19/85 offer of Proof in Support of CASE's 8/14/85 Motion for Immediate Board Order for Applicants to-Preserve Evidence... being sent in this same mailing.
8508280365 850819 PDR ADOCK 05000445 1
C PDR D503
g Applicants are well aware the Board will want and must have before they can rule on Applicants' CPRT Plan. These include (but are not limited to): all contracts and all attachments to such contrcets, letters of understanding, purchase orders, etc., between Applicants and their sub-contractors who will be involved in any way in the CPRT efforts; all resumes of such sub-contractors' employees who will be involved in such efforts; how Cygna Energy Services fits into Applicants' proposed scheme of things; etc.
For the reasons discussed herein, CASE moves that the Board order Applicants to immediately provide the Board with the documents discussed herein.
Respectfully submitted, 0/D s
Ass
's.) Juanita Ellis,~ President ASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2
g D
00f.KETED '
E E 26 R2 M UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE.THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRETA 6 y DGCKETING & SERVICL s
'^ "*
In the: Matter of
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TEXAS. UTILITIES ELECTRIC
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Docket Nos. 50-445 COMPANY, et al.
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and 50-446 (Comanche Peak Steam Electric
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-Station, Units 1 and 2)
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CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of-CASE's Motion for Board to Order Applicants to Supply Documents to Board have been sent to the names. listed below this 19th day of August
,198_5,
by: Express Mail where indicated by
- and First Class Mail elsewhere.
Federal Express where indicated by **
- Administrative Judge Peter B. Bloch
- Nicholas S. Reynolds,- Esq.
U..S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor
& Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
Washington, D.C.
20036
- Judge Elizabeth B. Johnson Oak Ridge National Laboratory
- Gerry S. Mizuno, Esq.
P. O. Box X, Building 3500 Office of Executive Legal Oak' Ridge, Tennessee 37830 Dirac.or-U. S. Nuclear Regulatory
- Dr. Kenneth A. McCollom, Dean Commission Maryland National Bank Bldg.
Division of Engineering, Architecture and Technology
- Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814
- Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C.
20555
- Administrative Judge Herbert Grossman U. S. Nuclear Regulatory Commission a
4350 East / West Highway, 4th Floor Bethesda, Maryland 20814 i
1 b~
o Chairman Renea Eicks, Esq.
Atomic Safety and Licensing Appeal Assis', ant Attorney General Board Panel Environmental Protection Division 2
U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.
20555 Austin, Texas 78711 Mr. Robert Martin Anthony Z. Roisman, Esq.
Regional Administrator, Region IV Trial Lawyers for Public Justice U. S. Nuclear Regulatory Commission 2000 P Street, N. W., Suite 611 611 Ryan Plaza Dr., Suite 1000 Washington, D. C.
20036 Arlington, Texas 76011 Mr. Owen S. Merrill Lanny A. Sinkin Staff Engineer 3022 Porter St., N. W.,
- 304 Advisory Committee for Reactor Washington, D. C.
20008 Safeguards (MS H-1016)
U. S. Nuclear Regulatory Commission Dr. David H. Boltz Washington, D. C.
20555 2012 S. Polk Dallas, Texas 75224 Robert A. Wooldridge, Esq.
Worsham, Forsythe, Sampels William Counsil, Vice President
& Wooldridge Texas Utilities Generating Company 2001 Bryan Tower, Suite 2500 Skyway Tower Dallas, Texas 75201 400 North Olive St., L.B. 81 Dallas, Texas 75201 Thomas G. Dignan, Jr., Esq.
Ropes & Gray Docketing and Service Section 225 Franklin Street (3 copies)
Boston, Massachusetts 02110 Office of the Secretary U.--S. Nuclear Regulatory Commission Ms. Nancy H. Williams Washington, D. C.
20555 Project Manager Cygna Energy Services Ms. Billie P. Garde 101 California Street, Suite 1000 Government Accountability Project San Francisco, California 1901 Que Street, N. W.
94111-5894 Washington, D. C.
20009 Mark D. Nozette, Counselor at Law Heron, Burchette, Ruckert & Rothwell 1025 Thomas Jefferson Street, N. W.,
Suite 700 Washington, D. C.
20007 1miE fN 1, Qfcs'.) Juanita Ellis, President dSE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2