ML20210E387

Motion for Establishment of self-executing Schedule Based on Expectation That Comanche Peak Review Team Senior Review Team Will Publish issue-specific Action Plan Results Repts. W/Certificate of Svc.Related Correspondence

ML20210E387
Person / Time
Site:	Comanche Peak
Issue date:	03/21/1986
From:	Dignan T ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#186-557 OL, NUDOCS 8603270326
Download: ML20210E387 (6)

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Filed: March 21, 19 6.

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UNITED STATES OF AMERICA g

4 NUCLEAR REGULATORY COMMISSION before.the i

ATOMIC SAFETY AND LICENSING BOARD

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In~the Matter of

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Docket Nos. 50-445g[,

TEXAS UTILITIES GENERATING

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50-446 COMPANY et al.

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-(Application for an (Comanche Peak Steam Electric

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Operating License)

Station, Units 1 and 2)

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MOTION FOR ESTABLISHMENT OF SCHEDULE J

Now come the Applicants and say as follows:

The CPRT Senior Review Team ("SRT") has,'as.of this I

writing approved a number of Issue'Spe'cific Action Plan

("ISAP") Results Reports, and has on its agenda consideration of additional draft Results Reports that are expected to be reviewed and approved prior to the end of March, 1986.

Beyond that, it is expected that additional Results Reports will be reviewed ~and approved by the SRT at various intervals during the months folloiwng March'of 1986.

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g Based on the expectation that SRT will publish Results Reports or groups thereof seriatim during the next few months, the' Applicants hereby propose-a self-executing schedule which will automatically go into effect upon the dr.y on which any result report is made available to the parties, and the documentation in support thereof is available for review.

The Schedule proposed is attached hereto and marked "A"

.N'cholas S.

Reynolds i

William A. Horin BISHOP, LIBERMAN, COOK PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.

Suite 700 Washington, DC 20036 (202) 857-9800 Robert A.

Wooldridge WORSHAM, FORSYTHE, SAMPELS &

WOOLDRIDGE 2001 Bryan Tower, suite 3200 Dallas, TX 75201 (214) 748-9365 i

Roy P.

Lessy, Jr.

MORGAN, LEWIS & BOCKIUS 1800 M Street, N.W.

Washington, QC 20036 4

(202) 331-2706 l

Thomas G.

Dignan, Jr.

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K. Gad III ROPES & GRAY 225 Franklin Street Boston,~MA ~O2110 (617) 423-6100

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Date Event Applicants. serve notice on CASE of the O

approval and publication by SRT of the Results Reports, together with a copy of the Results Report and statement of the

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availability of the CPRT Working Files for the ISAP' covered thereby.

Day 1 Discovery; opens'on the Results Report.

Day 31 Applicants. file and serve their proposed.

direct testimony for;the panel of witnesses for the Results Report.

Day 45 Staff files and serves its proposed direct testimony for the Results; Report.

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Day 61 Discovery closes.

Day 62 CASE serves notice of whether it wishes l

to contest the concl'usions of the Results j

Report.

-If not, then~the matters covered by the Results Report shall be deemed uncontested.

If CASE states it does wish i

to contest the conclusions of the Results 1

Report, CASE shall also. state whether such contest will be conducted solely by cross examination or shall include a direct case.

If CASE statesLthat it wishes.to rely 1

only on cross-examination, the Board establishes hearing date(s) at the earliest time convenient to the Board for j

cross examination (and redirect etc.') of' the canned testimony filed.

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Day 72 If CASE. has elected to file a direct I

case, CASE-files and' serves its proposed t

direct testimony with respect to the j-Results Report.

A ten-day period for

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applicants and staff to conduct discovery

-with respect to the CASE direct 1 testimony i

i opens.

- Day 82 Applicants and Staff file and serve any l

proposed rebuttal. testimony.to CASE's l

filed direct' testimony.

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Thereafter, Board establishes hearing date(s) at the earliest time convenient to the Board for. cross examination (and redirect etc.) of the canned testimony filed.

All service is to be made either in hand on the i

indicated date, or by deposit on that date with Federal i

. Express.

In the event that any date established by the schedule falls on a Saturday, Sunday or holiday, the I

scheduled action may be taken by the next bnsiness day.

l Service upon Applicants to be made upon Ropes & Gray in its j

Boston office; Service on CASE to be made at Trial Lawyers for Public Justice.

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CERTIFICATE OF SERVICE I,

Robert K. - Gad III, one of the attorneys for the Applicants 4

herein, hereby certify that on March 21, 1986, I made service of-i the within " Motion for Establishment of' Schedule," by mailing copies thereof, postage prepaid, to:

i Peter B.

Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector 3

i Administrative Judge Comanche Peak S.E.S.

Atomic Safety and Licensing c/o U.S.

Nuclear Regulatory Board Commission i

U.S. Nuclear Regulatory P.O.

Box 38 Commission Glen Rose, Texas 76043 Washington, D.C.

20555 Dr. Walter H.

Jordan Mr. William L. Clements J

Administrative Judge Docketing & Services Branch 881 W.

Outer Drive U.S.

Nuclear Regulatory Commission

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Oak Ridge, Tennessee 37830 Washington, D.C.-

20555 Chairman Chairman J

Atomic Safety and Licensing Atomic Safety and Licensing l

Appeal Panel-Board Panel U.S. Nuclear Regulatory U.S.

Nuclear Regulatory Commission l

Commission-Washington, D.C.'

20555 Washington, D.C.

20555 1

.Stuart A. Treby, Esquire Mrs. Juanita.Ellis

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Office of the Executive

' President, CASE l

Legal Director 1426 S.

Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 j

Commission 7735 Old Georgetown Road i

Room 10117 Bethesda, Maryland. 20814 4

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Renea Hicks,' Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O.

Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C.

20555 Anthony Roisman, Esquire Joseph Gallo, Esquire Executive Director Isham, Lincoln & Beale Trial Lawyers for Public Justice 1120 Connecticut Avenue, N.W.

2000 P~ Street, N.W.,

Suite 611 Suite 840 Washington, D.C.

'20036 Washington, D.C.

20036 Dr. Kenneth A. McCollom Mr. Lanny A.

Sinkin Administrative Judge Christic Institutt Dean, Division of Engineering, 1324 North Capitw1 ttreet Architecture and Technology Washington, D.C.

20002

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Oklahoma State University Stillwater, Oklahoma 74078 Ms. Billie Pirner Garde Mr. Robert D. Martin Citizens Clinic Director Regional Administrator, Government Accountability Project Region IV s

1901 Que Street, N.W.

U.S.

Nuclear Regulatory Commission Washington, D.C.

20009 Suite 1000 i

611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B.

Johnson Geary S.

Mizuno, Esquire Administrative Judge Office of the Executive i

Oak Ridge National Laboratory Legal Director P.O.

Box X, Building 3500 U.S.

Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Maryland National Bank Bldg.

i Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 i

Nancy Williams 1

Cygna Energy Services, Inc.

101 California Street 4

Suite 1000 I

San Francisco, California 94111 Robert K.

Gad 7II i

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