ML20215E675
| ML20215E675 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/15/1986 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#486-1928 OL, NUDOCS 8612230068 | |
| Download: ML20215E675 (4) | |
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'12/15/86
. UNITED STATES OF AMERICA NUCLEAR REGULA70RY COMMISSION DOCKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD U3NRC ob In the Matter of l
Docket No9 5 g
TEXAS UTILITIES ELECTRIC
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COMPANY, et al.
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(Comanche Peak Steam Electric l
Operating Lic6nsd):"
Station, Units 1 and 2) l CASE'S MOTION FOR EXTENSION OF TIME TO FILE ANSWER TO APPLICANTS' 12/1/86 RESPONSE TO BOARD CONCERNS On 12/1/86, Applicants filed their Responce to Board Concerns (their responses "(1) to the ' concerns' dxpressed by the Board in the Board's
' MEMORANDUM (Board Concerns)' dated June 26, 1986 (hereinafter ' Concerns Memo'); (ii) to the ' concerns' expressed and questions asked by the Board during the prehearing conference held in Dallas, Texas, on August 18 and 19, 1986; and'(iii) to selected assertions made by CASE during that same pre-hearing conference").'
It is CASE's understanding that it,would normally be allowed to respond within ten days to Applicants' Response since it could be considered to k a Motion, and we do desire to file an answer. However, we request an extension of time past the ten-day period (which would be 12/16/86). At this time, we believe an additional ten days should be sufficient; however, since this would make the due date Friday, 12/26/86, the day after Christmas, we request an extension until 12/30/86, the following Tuesday, as the mailing date. Should additional time be needed, we will so request when that becomes evident.
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p There are valid reesons for this extension. First, Applicants' Response is 52 pages long, and it took them almost six months to respond to, the Board's 6/26/86 Concerns Memo. There is much research to be done and there are many references which need to be looked up, all of which require additional time.
Obviously, Applicants will not be harmed by this extension; further, they have already had the benefit of up to six months, in effect an extension, themselves in filing their 12/1/86 Response.
This pleading in writing was necessitated by the unavailability of Applicants' counsel to speak to Mrs. Ellis. Mrs. Ellis advised Judge Bloch by telephone on the morning of 12/15/86 that she was sending him this pleading by overnight delivery.-
Kespectfully submitted, 2D -_b2 A LJ s.) Juanita Ellis, President SE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 I
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'86 DEC 18 P2:22 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORETHEATOMICSAFETYANDLICENSINGBOARDh f.
y uRAktu In the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos. 50-445"6T-COMPANY, et al.
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and 50-446 -c94-(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 PROGRESS REPORT (III); CASE'S MOTION FOR EXTENSION OF TIME TO FILE ANSWER TO APPLICANTS' 12/1/86 RESPONSE TO BOARD CONCERNS; and CASE'S MOTION FOR EXTENSION OF TIME TO FILE MOTION TO COMPEL REGARDING APPLICANTS' 12/2/86 AN5WERS TO CASE CPRT PROGRAM PLAN INTERROGATORIES (SET NO.12) 15th December 6
have been sent to the names listed below this day of
,198
&IXMMXMM where indicated by
- and First Class Mail elsewhere.
by:
1 Federal Express
- 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 Geary S. Mizuno, Esq.
P. O. Box X, Building 3500 Office of Executive Legal Oak Ridge, Tennessee 37830 Director U. S. Nuclear Regulatory Dr. Kenneth A. McCollom Commission 1107 West Knapp Street Washington, D. C.
20555 7_
Stillwater, Oklahoma 74075 Dr. W lter H. Jordan Chairman, Atomic Safety and Licensing a
Carib Terrace Board Panel 552 North Ocean Boulevard U. S. Nuclear Regulatory Commission Pompano Beach, Florida 33062 Washington, D. C.
20555 1
6y 3
.I Chairman Renea Hicks, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General
. Board Panel.
Environmental Protection Division 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. Herman Alderman Lanny A. Sinkin Staff Engineer Christic Institute Advisory Committee for Reactor 1324 North Capitol Street Safeguards (MS H-1016)
Washington, D. C.
20002 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Robert A. Wooldridge, Esq.
Worsham, Forsythe, Sampels William Counsil, Vice President
& W oldridge Texas Utilities Generating Company 2001 Btfan Tower, Suite 3200 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 4
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
' Midwest Office 94111-5894 3424 N. Marcos Lane Appleton, Wisconsin 54911 1
Mark D. Nozette, Counselor at Law Roy P. Lessy, Jr., Esq.
Heron, Burchette, Ruckert & Rothwell Wright & Talisman, P. C.
1025 Thomas Jefferson Street, N. W.,
1050 Seventeenth St., N.W.
Suite 700
(
Washington, D. C.
20036-5566 Washington, D. C.
20007 i
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$ s.) Juanita Ellis, President (ASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2