ML20207S630
| ML20207S630 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/16/1987 |
| From: | Roisman A Citizens Association for Sound Energy, GREGORY, M., TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2829 CPA, OL, NUDOCS 8703200112 | |
| Download: ML20207S630 (2) | |
Text
\\2f37 TRIAL LAWYERS FOR Pualic JUSTICE. P.C.
00CMETED COUN5tLLORS '.T taw SulTE 611 2000 T' STREET. NORTHWEST W MAR 19 P3 :47 ANTHONY t ROewAN l)LLCUTM OfRICTOR WASHINGTON. D.C. 20036 (202)463 86A nRTHuR sRv4NT STAf f ATTORNEY OFFICE DF het it,f.,(
00CKETihG t SEFvlCf.
situt cARoc DIRECTOR. LNVIRONMENTAL WHt5TLL8LOWTR l'ROJECT BARBARA l'RATT Of flCE MANAcER CMTHLttN CUMBERBATCH SECRETARY March 16, 1987 Peter B.
Bloch, Chairman Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission 4350 East-West Highway, 4th floor Bethesda, MD 20814 Dr. Walter H. Jordan Administrative Judge 881 West' Outer Drive
-Oak Ridge, TN 37830 i
Dr. Kenneth A. McCollom Administrative Judge t
1107 West Knapp Stillwater, OK 74075 RE:
Texas Utilitias~ Electric Co. (Comanche Peak)
Dkt. Nos. 50-445, 446-OL; Dkt. No. 50-445-CPA Gentlemen:
By this letter Intervenora~ CASE and Meddie, Gregory seek to supplement their Motion for Appointment of Legal Counsel for the Minority-Applicants and for Clarification.of Discovery and Other Responses Received.from Applicants (3/9/87) with the following references, all contained in the Request for Modification of Licenses filed with the Director.of Nuclear Reactor Regulation on March 11, 1987, by Applicant Brazos Electric Power Cooperative, Inc.:
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$m 1.
Request, pp. 30-39 (particularly p. 38):
in support of our i _ $@;
argument that the Minority Applicants must have their own no counsel here and are not free to obtain their own counsel.
1 : e O
2.
Exhibit 16, p. 2:
in support and extension of our argument Nt
- 08 that Minority Applicants have not, except on rare occasions, responded to the discovery requests of-CASE and inquiries by this Board or the Staff.
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Em 3.
Request,.pp.~40-42, and Exhibit'17:
in support of our g@o argument that the Minority Applicants may in fact have 3'
positions on legal issues which differ from those expressed 0
by the attorneys-appearing on behalf of all Applicants.
t.
1
4, 1
4.
Exhibit 19:
in support of our argument that counsel appearing on behalf of-the Applicants may suppress relevant information which one of the Minority Applicants wants to bring to the attention of the Board.
It is our understanding that a copy of the Request for Modification of Licenses has been served on the Board and the parties, and thus copies of the-referenced pages and exhibits are not enclosed with thi's letter.
Sincerely, s
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Anthony 61 man AZR/bp cc:
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