ML20215E713
| ML20215E713 | |
| 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-#486-1927 OL, NUDOCS 8612230082 | |
| Download: ML20215E713 (2) | |
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12/15/86 m-UNITED STATES OF AMERICA NUCLEAR REGULATORY COPMISSION DOCKETED
' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD V
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-In the Matter of l
Docket Nos 8 P2 22 D
TEXAS UTILITIES ELECTRIC COMPANY, et al.
CFFICf F M tgp (ApplicatiEfoWaC ~ W (Comanche Peak Steam Electric Operating License)-
Station, Units 1 and 2)
CASE'S MOTION FOR EXTENSION OF TIME TO FILE MOTION TO COMPEL REGARDING APPLICANTS' 12/2/86 ANSWERS TO CASE CPRT PROGRAM PLAN INTERROGATORIES (SET NO. 12)
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On 9/18/86, CASE filed its CPRT Program Plan Interrogatories (Set No.
12 - Sampling). Applicants requested, and CASE did not object to, an extension of time in which to respond; and Applicants mailed their response on.12/2/86. (Applicants' responses to Sets 8-11 were filed on 12/8/86.)
It will be necessary for CASE to file a motion to compel regarding Applicants' 12/2/86 responses. However, we request an extension of time until 12/23/86, which is the same time motions to compel would normally be due to be filed on Sets 8-11.
There are valid reasons for this. First, the instructions which were to apply to CASE's 12th Set are the same as those which were to apply to the other Sets, and this will be the subject of discussion (and will hopefully be resolved) during the prehearing conference scheduled for 12/15/86 (perhaps continuing on 12/16/86). Also, from the 12/9/86 letter from Ms.
Garde to the Board Chairman regarding the upcoming prehearing conference (received by CASE in Dallas on 12/13/86), it is apparent that many of the same generic categories listed therein also apply to matters which will be h
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the. subject of our motion to compel regarding responses to' CASE's 12th Set,
-and are therefore likely to be resolved at the 12/15/86-12/16/86 prehearing conference.
It would be preferable to have the Board's. rulings on these matters prior to the filing of our motion to compel regarding'the 12th' Set, so that unnecessary time and effort of the Board and parties will not be wasted and so that'the record will not be unnecessarily burdened.
An additional reason for the need for an extension is that Mrs. Ellis has only recently been able to discuss this with the individual who assisted CASE in preparing the questions on sampling (partly because of Mrs. Ellis's recent illness and partly because of that individual's' schedule) to work on our motion to compel.
If CASE in Dallas does not have access to a copy of the 12/15/86-12/16/86 prehearing conference. transcript in time to prepare cur motion to compel by 12/23/86, we may request an additional extension of time so that we can have the benefit of that transcript and details of any Board rulings made which may be applicable to our motion to compel regarding the 12th Set.
Obviously, Applicants will not be harmed by.this extension; further, they have already had the benefit of an extension themselves in filing their 12/2/86 responses.
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.
Respectfully submitted, 21 D J
A$4) s.) Juanita Ellis, President ASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2