ML20205F424
| ML20205F424 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/23/1987 |
| From: | Pratt B Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2920 OL, NUDOCS 8703310159 | |
| Download: ML20205F424 (2) | |
Text
JA2A TRIAL LAWYERS FOR PUBLIC JUSTICE. P.C gGCHETED COUNSELLORS At LAW USNRC SulTE 611 2000 P STREET. NORTHWTST g g g g 37 ANTHONY Z ROtWAN WASHINGTON. D.C. 20036 (202)463-8600 f.xtCUfnt DIRIC TOR
""'ll""*?$RNn, OFFICE OF 5L 2ti.n r
~'
5 Af 00CMEigrgEPVICf.
situt ceRoc DiatC70R. [NMRONMENTAL
. WHl5ft!BLOWTR f*RottCT aA g g NAGER ILATHLEEN CUMBERBATCH 5(CRITARY Peter B.
Bloch Administrative Judge U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Kenneth-A. McCollom Administrative Judge 1107 West Knapp Stillwater, OK 74075 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, TN 39830 RE:
Texas Utilities Electric Co. (Comanche Peak, Units 1 & 2)
Dkt Nos. 50-445, 446 - C(
Gentlemen:
CASE's Opposition to Applicants' Motion to Compel, filed on March 17, 1987, was mailed out with page 3 missing.
Enclosed is a copy of that page 3.
I apologize for this oversight.
Sincerely, hWt-k arbara Pratt B
I Secretary to Mr. Roisman enclosure cc:
service list 8703310 9${$$$$45 PDR AD PDR ApSoS o
o
,1 curiously incuusistent with their present position, resisted.
Applicants' Oojection to " CASE's Requests for admissions" and Motion for a Protective Order (3/1/65), pp. 3-6:
2.
. lf the Requests are... intenced to evoke an admission or denial of tne facts asserted in the various paragraphs of the Staff documents reproduced in the Requests, then the Applicants respectfully request that.the work that is now ongoing and described above be ueemed, when published, responses to these Requests, and tnat_no further response is required.
That work is, as the board is aware, precisely the attempt to assess the TRT " findings" that any response to these Requests (so interpreted) would require.
There seems little point in restating the response.
3.
If the Requerts are intended to call for an admission or. denial of the facts asserted in the.various paragraphs of the Staff
. documents reproduced in the Requests, and the Board disapproves our suggested procedure described in paragraph 2 and desires a formal response to the requests as sucn, then the Applicants suggest that no response is possible until the work described above has been completed and move for a protective order relieving them of any obligation to respond until that time.
t Over two years have passed, during which Applicants have systematically missed virtually every promised aeadline for 1
completion of results reports.
Compare Applicants' First Pprogress Report (7/30/86), pp.
4-6, with Applicants' Fourth Progress Report (2/10/87),
p.
3 and first attachment.
Meanwhile, CASE has tried to move this' proceeding toward resolution of the generic issues (CPRT inherent defectst, which once resolved can obviate substantial unnecessary hearing time.
The celay in reaching a resolution of those issues is solely attributable to Applicants' delay in responding to legitimate discovery, '
.-n-,,--.
,---r.-nn.-
--..,-,- -,-,,,-. ~, -., - - - -, - - - - - - -, - -, -,, -
n, w.,--,
-