ML20137U948

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Motion for Leave to File Reply in Further Support of Request for Imposition of Fine,For Suspension of Const Activities & for Hearing on Application to Renew CP
ML20137U948
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/14/1986
From: Roisman A
Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:
NRC COMMISSION (OCM)
Shared Package
ML20137U953 List:
References
CON-#186-105 CPA, NUDOCS 8602190385
Download: ML20137U948 (2)


Text

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/ 05 00CMETED UNITED STATES USHRC NUCLEAR REGULATORY COMMISSION Before the Commission GFFICf 07 ?? : ~<

In'the Matter of 00CKElthc 4 d 3

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BRANC3

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TEXAS' UTILITIES GENERATING COMPANY,

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Dkt. Nos. 50-445-OL

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50-446-OL (Comanche Peak Steam Electric

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Station, Units 1 and 2

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CASE MOTION FOR LEAVE TO FILE A REPLY Pursuant to 10 CFR 92.730(c), CASE requests leave to file the attached reply brief in further support of.its requests (CASE Request.for Imposition of Fine, for Suspension of Construction Activities, and for a Hearing on Application to Renew Construction Permit (1/31/86); CASE Request for Stay of Effectiveness of Construction Permit Extension and For Other Relief (2/11/86)).

The motion should be granted because:

1)

The short time available to CASE to file its papers, particularly in light of ~ the use by Staff and Applicants of mail s

service when CASE has used hand delivery, made it difficult for CASE to address'all possible justifications which Staff and Applicants might present for the illegal actions involved here; 2)

Those justifications include a gross departure from the statute and relevant case law; 3)

The reply brief is short and will help to focus the issues involved.

?N' 8602190385 860214 o 33 PDR ADOCK 05000445 0

PDR

For the foregoing reasons, we request leave to file the attached reply brief.

Respectfully submitted, s'

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' ANTHONY Z.

RO N

Trial Lawye for Public Justice 2000 P Stre t, NW, #611 Washington, D.C.

20036 (202) 463-8600 Counsel for CASE Dated:

February 14, 1986 l

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