ML20216J765
| ML20216J765 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/29/1987 |
| From: | Roisman A Citizens Association for Sound Energy, ROISMAN, A.Z. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#387-3921 OL, NUDOCS 8707070010 | |
| Download: ML20216J765 (4) | |
Text
1 0
b J0W ii UNITED STATES NUCLEAR REGULATORY COMMISSION j
Before the Atomic Safety and Licensina Board 87 JW 30 P2 :49 i
gr-In the Matter of
)
U>L M
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1 TEXAS UTILITIES ELECTRIC COMPANY,
)
Dkt. Nos. 50-445, 446-0 L et al.,
)
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(Comanche Peak Steam Electric Station
)
Units 1 and 2)
)
I CASE REQUEST FOR EXTENSION OF TIME TO RESPOND TO TUEC PETITION FOR DIRECTED CERTIFICATION j
i i
CASE requests an extension of time from July 6, 1987, until July 22, 1987, to respond to Texas Utilities Electric Company's Petition for Directed Certification of Licensing Board order of March 12, 1987.
CASE seeks this extension of time because its principal counsel on this issue, Anthony Z. Roisman, has preexisting commitments that have and will make it impossible for him to turn hin attention to this petition until at least July 17, 1987.
Mr.
Roisman currently has principal responsibility for filing an opposition to a motion to dismiss in English v. General Electric Co.,
now due in U.S.
District for the Eastern District of Virginia on July 10, 1987.
He is also principal attorney responsible for filing a motion for preliminary injunction in Shinozaki v.
Anzon in U.S.
District Court for the Eastern District of Pennsylvania, which was scheduled by the court to be filed on June 26, 1987.
He is also principal attorney responsible for filing a complaint and motion for preliminary injunction in Dublin Scarboro Improvement Association v.
Harford 8707070010 870629 PDR ADOCK 05000445 d {h o
PDR y
C-County, Maryland in U.S.
District Court for Maryland, due to be filed on July 2, 1987.
He is also scheduled to be in San I
Francisco from July 10 through July 16 on matters related to several other cases and to attend the ATLA Annual Meeting.
Defendant should not be prejudiced by this, since it apparently did not consider the Licensing Board's action on March 12, 1987, to be of sufficient moment to necessitate the filing of a petition for directed certification (which may be untimely) i until June 19, 1987.
Furthermore, a brief skim of the petition l
suggests that the only alleged injury TUEC asserts is the possibility that CASE will have access to this information for use at trial without TUEC also having access.
In a recent informal phone conversation the parties were told by the Chairman i
of the Atomic Safety and Licensing Board that the next available date for hearings is March 1988, and thus TUEC is not in imminent danger of any serious consequences.
For the foregoing reasons, CASE requests that the Board grant an extension until July 22, 1987.
Respectfully submitted, I
I' h WM
' ANTHONY Z. P I Myi 1401 New Y k Avd., NW, #600 I
Washingtor, C
20005 (202) 628-3500 I
Counsel for CASE Dated:
June 29, 1987 l
1 DOCUi?
U #0 '~
UNITED STATES NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board 87 WN 30 P2 :49 0 F R...,.
In the Matter of
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I'OCMtig7 17 1
- vlt N y
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TEXAS UTILITIES ELECTRIC COMPANY,
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Dkt. No. 50-445, 446 et al.,
)
)
(Comanche Peak Steam Electric Station
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that CASE REQUEST FOR EXTENSION OF TIME TO RESPOND TO TUEC PETITION FOR DIRECTED CERTIFICATION was served today, June 29, 1987, upon the following by first class mail, postage prepaid, or by hand where marked with an asterisk
(*),
or by Federal Express where marked by two asterisks (**).
Peter B.
Bloch Administrative Judge U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Kenneth A. McCollom j
1107 West Knapp Stillwater, OK 74075 Dr. Walter H.
Jordan 881 West Outer Drive Oak Ridge, TN 37830 Elizabeth B. Johnson Oak Ridge National Laboratory P.O.
Box, Building 3500 Oak Ridge, TN 37830 i
Docketing and Service Section I
Office of the Secretary U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
h f
l Geary S. Mizuno, Esq.
Office of Executive Legal Director U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 I
Robert A.
Wooldridge, Esq.
Worsham, Forsythe, Sampels, and Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, TX 75201 Thomas G.
Dignan, Jr.
Ropes & Gray J
225 Franklin Street
)
Boston, MA 02110 W.
G.
Counsil Executive Vice President Texas Utilities Electric Co.
Skyway Tower, 25th floor 400 North Olive Street Dallas, TX 75201 Juanita Ellis, President Citizens Association for Sound Energy 1426 South Polk Dallas, TX 75224 Billie P. Garde Government Accountability Project - Midwest Office 3424 North Marcos Lane Appleton, WI 54911
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Anthony t Refsman y
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