ML20125B195

Motion for Extension Until 850628 to Respond to ASLB 850524 Memorandum & Order (Re Case Mgt Plan) Directing Applicant to File Statement of Current Mgt Views.Motion W/O Prejudice. Certificate of Svc Encl

ML20125B195
Person / Time
Site:	Comanche Peak
Issue date:	06/10/1985
From:	Reynolds N BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#285-352 OL, OL-2, NUDOCS 8506110343
Download: ML20125B195 (6)

Text

Ich June 10, 1985 DCCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 85 WN 10 P2:31 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD CFF!CE 0r SECat_TARY 00CXEiltG & SEPvici ERANCH In the Matter of ) Docket Nos. 50-445-1,

) 50-446-1, TEXAS UTILITIES ELECTRIC ) 50-445-2 and COMPANY, ET AL. ) 50-446-2

)

(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)

APPLICANTS' MOTION TO EXTEND TIME On May 24, 1985, the Board in the main docket described above entered a Memorandum and Order entitled " Memorandum-(Case Management Plan)" in which the Applicants were directed to file, by June 15, 1985, a statement of Current Management Views that complies with the discussion contained in such Memorandum.

Because of the circumstances described below, Applicants respectfully request that the time for such filing be extended to the 28th day of June, 1985. The NRC Staff has no objection to such extension. The Intervenor CASE opposes the request.

8506110343 850610 ADOCK 050go445 PDR g G PDR

9 Since the receipt of the Board's May 24, 1985 Memorandum described above, the Applicants have received SSER Number 11, an extensive document dealing with quality assurance / quality control issues and concerns raised by the NRC Staff's Technical Review Team. In addition, since such time a two-day meeting has been scheduled by the NRC Staff with the Applicants, to take place in Arlington, Texas on Thursday and Friday, June 13th and 14th,

.1985,.at which time Applicants are to present their program for responding to all design adequacy and QA/QC issues raised by the TRT, the parties and witnesses before the ASLB, the NRC Staff, Cygna and other sources. It is Applicants' understanding that such meeting will include a number of NRC Staff management.

Because of these developments, which require a substantial effort on the part of Applicants, and its counsel, time does not permit a proper and full response to this Board's request for Current Management Views.

Applicants believe that no prejudice to any party or to the proper and efficient conduct of the responsibilities of this Board will result from granting Applicants' request for extension of time. Since the request for Current Management Views was initiated by the Board itself, and not by CASE, and since any delay will not prejudice CASE, Applicants fail to see any basis for their objection.

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Applicants respectfully request that their application for extension of time'be granted and that they be allowed until the 28th day of June, 1985, to file the response directed in the first numbered paragraph of the Memorandum as contained on page 5 of this Board's May 24, 1985 Memorandum as described above.

Applicants further respectfully request that the Board act on this motion expeditiously.

Respec ul submitted, l ,

l Nichoy $ S./)Reynolds Willi /A.fH arin BISHOP LI}$RMAN, COOK, PURCELL Y REYNOLDS 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9817 Counsel for Applicants June 10, 1985

y-UNITED STATES OF AMERICA

' NUCLEAR REGULATORY COMMISSION 00LMETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD USHRC .

'85 JUN 10 P2:32 In the Matter of ) Docket Nos. 50-445-1,  !

) 50-446 Kr nr "CRtTAP TEXAS ~ UTILITIES ELECTRIC ) 50-445 cmhkG'5 5ERVICf.

COMPANY, ET AL. ) 50-446 2 BRANCH

)

(Comanche Peak Steam Electric ) (Application for Station, Units 2 and 2) ) Operating Licenses)

CERTIFICATE OF SERVICE I hereby' certify that copies of " Applicants' Motion to Extend l

Time",:in the above-captioned matter was served upon the following persons by express mail (*) or deposit in the United States mail, first class,. postage prepaid, or by hand delivery

(**) on the 10th. day of' June, 1985.

• • Peter B. Bloch, Esquire Chairman, Atomic Safety Chairman, Atomic Safety and and Licensing Appeal Licensing Board Panel-U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Dr. Walter H. Jordan Mr. William L. Clements 881 West Outer Drive Docketing and Service Oak Ridge, Tennessee 37830 Branch U.S. Nuclear Regulatory

• Dr. Kenneth A. McCollom Commission Dean,_ Division of Washington, D.C. 20555 Engineering, Architecture and Technology ~ **Stuart A. Treby, Esquire Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 I

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g-Chairman, Atomic Safety

• Elizabeth B. Johnson and Licensing Board Oak Ridge National Panel Laboratory U.S. Nuclear Regulatory Post Office Box X-Commission Building 3500 Washington, D.C. 20555 Oak Ridge, Tennessee 37830 Robert D.-Martin Renea Hicks, Esquire Regional Admihistrator, Assistant Attorney General Region IV Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548 611 Ryan Plaza Drive Capitol Station Suite 1000 Austin, Texas 78711 Arlington, Texas 76011

• Mrs. Juanita Ellis Lanny A. Sinkin President , CASE 3022 Porter Street 1426 South Polk Street Suite 304 Dallas, Texas 75224 Washington, D.C. 20008 Nancy Williams *

• Ms . Billie P. Garde Cygna-Energy Services, Inc. Citizens Clinic Director 101 California Street Government Accountability Suite 1000 Project San Francisco, CA 94111 1555 Connecticut Avenue, N.W.-

Suite 202 Washington, D.C. 20036

• • Herbert Grossman, Esquire ** Ellen Ginsberg, Esquire Alternative Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 I'

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• • Anthony Z. Roisman, Esquire Mr. James E. Cummins Trial Lawyers for Public Resident Inspector /

Justice Comanche Peak Electric Suite 611 Station 2000 P Street, N.W. ,c/o U.S. Nuclear Regulatory Washington, D.C. '20036 Commission -

I P.O. Box 38 Glen Rose, Texas 76043 Joseph Gallo, Esquire g' Isham,' Lincoln & Beale Suite 840 1120 Connecticut Avenue, N.W.

Washington,.D.C. 20036 f

William A. Hor :, n cc: John W. Beck Robert A. Wooldridge, Esq.