ML19253C152
| ML19253C152 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/30/1979 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Chandler L, Ulman M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 7911300052 | |
| Download: ML19253C152 (2) | |
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'allas, Texas 752C8 x
21h/9k6.ok-o' Dalla h
(CITIZENS ASSN. FOR SOUND ENERGY)
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October 30, 1979 g
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Ms. Marjorie B. U1=an and
' a Mr. Larry Chandler 9
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Counsels for NEC Staff
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'Jashin6 ton, D. C.
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Dear Marjorie and Larry:
u Sub,} ect : rockets 50 kk5 and 50 Lho i
Application of Texas Utilities g
Generati:g Ccepany for as hj Operstiug License for Cc:anche J
w31 UIL UI jj Peak Steam Electric Station Units El and #2 (CPSES)
In response to your letter dated October k,1979, there are several itens which need attention:
1.
Contention No. 7 (old Contention Nos. 9 and 17), Radiation Effects.
In reviewing our notes on the conference where ve vorhed out the wording of the contentions, we believe ve discussed thoroughly at that ti=e exactly what we meant by this contention, and that the wording finally agreed upon after =uch discussion reflects what we vanted to ecver by this contention. Further, the Staff agreed at that ti=e that this was a valid contention.
In your 8/31/79 conference call, you indicated that you now feel that we are atte=pting to challecge Appendix I, which is not per=issable. Frankly, we
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are at a lo.s to understand your change of stance at thia point and would request I
an explanation.
I Further, if the Staff insists on chacging its support of this contention, ve vould like to revise our vording of the contention, for pur;czes of clarifi-cation only, to the folleving:
"Neither the Applicant nor the Staff has adequately considered the health effects of low level radiation on the population surrounding CFSES as re-quired by 10 CFR 51.20 (c) and 10 CFR 50 57 (a)(6)."
This would not change the = caning as originally agreed upon and as outlined in our original bases but vould clarify the exact =eanin6 sccevhat.
2.
Contention No. 5 (cid Contention No. 7), Spent Fuel. As I recall, Larry, in our 8/31/79 conference call, you stated that a "secccd Ger=an report" repudiates Ge. an Report No. 290. In reviewinr,the infor:ation ve have, this does not see:
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~ to be the case. Please advise exactly what Ger=an report you are referring to, seed us a copy of this second Ger=an report, and advise in which specific areas it repudiates Report No. 290. Here again, we request an explacation for the Staff's change in position.
3 Contention No.10 (old Cov.ention Nos.12,13, ik and 15), Evacuation.
We do cot believe the wording in your October 4 Stipulation accurately reflects whatIagreedtooverthephoneos9/18/79 We request that the folleving wording be used to replace the wording of ite:n 7, page 3, of your Stipulation:
"The parties stipulate to the consolidation of contentions 12,13, ik, and 15 into the la=guage of revised contention 10, as set forth in the Attach:nent, but agree to defer for the present, consideration of this contention in light of probable changes in Cce=ission require =ents reSarding e=ergency planning, with the understacding that the Intervenor vill be given the opportunity to pursue this contention in the operating license hearings at a later cate, before the operating license is issued."
h.
Ites h, page 2, of your Stipulation should read: "The Staff and Intervecor also agree that contentions 6 and 18 (ccobined) and 16....." etc. and "The Applicant dces not agree that contentions 6 and 13 (cc=bined) and 16....." etc.
5 Item 7, page 3, of your Stipulation should read "The parties stipulate to the consolidation of contentions 12,13, ik and 15 into the lacs.:sse of revised contention 10....." etc. This contention, when renu =bered, vould beco=e No.10 rather than No. 12.
6.
The wording regarding Contention 2 should = ore accurately read:
"With-drawn; included in other contentions" or si= ply " Included in other contentions."
Ve vould request new stipulations with corrected attach =ent referred to in the stipulations actually attached thereto and referenced as an exhibit before signing.
Tha:ls for your help in working out these problems.
Sincerely, CASE (CITI S ASSOCIATICN FOR SCUND ENERGY)
(Mrs.) Juanita Ellit President ec: Service List 1442 260 u.uw,> mJ