ML20215H671
| ML20215H671 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/22/1986 |
| From: | Ellis J, Roisman A Citizens Association for Sound Energy, GREGORY, M., TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20215H673 | List: |
| References | |
| CON-#486-1237 CPA, NUDOCS 8610240083 | |
| Download: ML20215H671 (3) | |
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.}f BEFORE THE DOCKETED UNITED STATES gaaC NOCLEAR REGULATORY COMMISSION 8erore the Atomic Safety and Licensing 8)hr In tne Matter of CFFKE0* "
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j TEXAS OTILITIBS GENERATING COMPANY,
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Okt. Nos. 50-446-CPA et al.
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(Comancne Peak Steam Electric
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Station, Unit 1)
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CONSOLIDATBD INTERVSNORS' MOTION FOR LEAVd TO FIL8 A REPLY BRIEF Attached to this motion is a Reply Drief addressing three issues raised by TOEC ano the Staff in their responses to Consolidated Interveno'rs' pending Motion to Admit Amended Contentions Or, In the' Alternative, For Reconsideration of Certain Previously Denied Contentions.
We believe this Reply will nelp focus the inquiry by this Boara on the issues to be decided and correct serious errors of law which infect the pleadings of TUEC anc the Starf.
Because the errors go to the neart of the proper law to apply to tne pending motion, it is important tnat Consolidated Intervenors ce given the opportunity,
-absent oral argument, 'to clarify these matters.
In aadition, the normal procedure in dealing with contentions wnose aamission is opposea is tnat the intervenor be 91ven an oppor tunity, in oral argument, to respond to objections raiseo.
Objections to contentions are difficult to anticipate and witnout tnis opportunity for oral argument tne party seeking aamission of tne contentions would nave no chance to respond to hDk khgCK83 861022 05000445 i
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tne arguments aovancea against i t.
This Reply Brief is in lieu ot oral. argument.
Finally, in this case, Consolidated Intervenors felt compelled to move quickly to seek to amend tneir contentions for tear tnat tney woula ce held to have been untimely.
Thus full written analysis of CLI-do-15, as now set forth in Consolidated Intervenors Comments on CLI-86-15 (10/7/86), which we incorporate of reference in tne attached Reply Brief, was not possiole.
We Delieve tne proper interpretation of CLI-86-15 is central to resolving the pending motion.
For all tnese reasons we urge that the Board grant leave for Consolidated Intervenors to file the attacned Reply Brief.
Snoula tne Board aeclae that oral. argument is warranted nere, the attached Reply Brief, wnile userui, would not be essential to preserve Conso11aatea Intervenors' rights to reply to the arguments aavanced oy TUSC and the Staff.
Should this Board decide not to grant leave to file the Reply Brief, we request oral argument as the only other way to protect our rights.
Respectfully suomittea,
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ANTh0NY Z.
(91SMfAN Trial Lawyers for Public Justice i
2000 P S treet, NW, foil washington, D.C.
2003o (202) 4o3-8000 Counsel for Meadie Gregory i
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JU 1TA BLLIS
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,, South Polk o
callas, TX 75224 (214)s40-9446 Representative for CASE Dated:
October 22, 1966 D
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