ML19310A197
| ML19310A197 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/21/1980 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Bowers E Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19310A195 | List: |
| References | |
| NUDOCS 8006060257 | |
| Download: ML19310A197 (4) | |
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- 5. ) 9 (CITIZENS ASSN. FOR SOUND ENERGY)
N April 21, 1980 0321MD 6
U3NRC APR 2 8880 e 5 Elizabeth S. Bowers, Esq., Chairman 6-1 Atomic Safety and Licensing Board 3
Office of the 4 U. S. Nuclear Regulatory Commission 0,
Docketint & Seah Washington, D. C.
20555 b
Dear Ms. Bowers:
SUPJECT:
I'n the Matter of Application of Texas Utilities Operating Company, et al. for an Operating License for Comanche Peak Steam Electric Station Units #1 and E2 (CPSES) --
CASE k/10/80 Position on Contentions In reviewing subject Position on Contentions, I find thac I inadvertently made the following typographical omissions and errors, which we request be corrected:
Page 7, first full paragraph, line 9 -- change "would" to "we".
Page 9 -- add #1 in upper right-hand corner.'
Page 9, paragraph 1, line 5 -- change capital letter "C" to lover case "c".
Page 9, last line -- change " discharge" to " discharges".
Page 21, paragraph 2, line h -- add semi-colon (;) at the end of the line.
Page 26, under EXPIANATION, line 2 -- insert "6, item 5, paragraph 3, page 26" following " Contentions 2, pages 10 and 11;" (to conform with paragraph 1, line 2, page 26).
Page 26, under EXPLtJMTION, line 3 -- insert "(in its 3/28/60 letter to CASE regarding Staff's views on our contentions)" following "One of the criticisms of the Staff".
Page 26, paragraph 3, line 3 -- insert "or possibilities" following" stances already of such sabotage attempts" (to conform witn paragraph 3, line 8, page 28).
P2ge 30, paragraph 4, line h -- change "know" to "known".
Page 30, 2nd line from the bottom -- change "know" to known".
Page 31, paragraph 2, line 5 -- delete "at this time".
Page 39, paragraph 2, line 4 -- change"CRF" to "CFR".
Page h7, paragraph 1, line 2 -- insert "and item 17" following "10 and 11, and 19, items 1 through 8".
Page 47, paragraph 2, line 1 -- change " incorporation" to " incorporate".
Page 47, paragraph 2, line 2 -- insert at end of line "and item 17 on page 56".
Page 22, paragraph 2: line 1 -- change "consistenly" to " consistently";
line 2 -- change "approproate" to " appropriate".
Page 33, line 6 -- change" Energy" to " Environmental".
l 8006060 Q g
2 We apologize for any inconvenience these inadvertent errors may have caused.
However, in our effort to get the filing,in the mail and operating under the difficult conditivas as outlined in our h/10/80 Position on Contentions, there was not time to proofread our filing before placing it in the mail.
In hope of providing a helpful tool to all Parties, we are also attaching herewith aTableofContentsforour4/10/80PositiononContentions.
Sincerely, CASE (CITIZENS ASSOCIATION FOR SOUND ENERGY) ed'- [MS
(.rs.) Juanita'Ellis President cc: with Attachment to all Parties on Attached Service List S
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TABLE OF CONTENTS 7 Office cf t':e Secret:7 FOR g
Dacketir.g & StMce 9
Srg h/lO/80 CASE POSITION ON CONTENTIONS g
m Brief Description
- Py Statement of CASE overall position on contentions and background 1
Contention No.1 APPLICANT WILL NOT COMPLY WITH REGUIATIONS 9
Centention No. 2 Incorporated into other CASE Contentions Contention No. 3 ERISINCOMPLETEANDINACCURATE;$'FACCURATEAND COMPLETE, THERE IS NO NEED FOR CPSES 1h Contention No. 4 Incorporated into Contention No. 3 Contention No. 5 Incorporated into Contention No. 3 Contention No. 6 DECOMMISSIONING; SUPPLIER COMMI'IMENT; FUEL COST AND SUPPLY; WASTE STORAGE; TRANSPORTATION OF WASTE; AND SHORTENED LIFE OF PLANT 20 Contention No. 7 SPENT FUEL ACCIDENT 26 Contention No. 8 CLASS 9 ACCIDENT 33 Contention No. 9 RADIATION EFFECTS 37 Contention No. 10 EFFECT OF ACCIDENTS IN PLANTS OF.SIMILAR DESIGN k0 Contention No. 11 Incorporated into Contention No. 6 Contention No. 12 IMERGENCY PIANNING h3 Contention No. 13 Incorporated into Contention No.,12 Contention No. 14 Incorporated into Contention No.12 Contention No.15 Incorporated into Contention No.12 9
TAELE OF CONTENTS FOR h/10/60 CASE POSITION ON CONTENTIONS (continued)
Brief Description
- M Contention No. 16 APPLICANT NOT FINANCIALLY QUALIFIED k5 Centention No.17 Incorporated into Contention No. 9 Contention No. 18 Incorporated into Contention No. 6 Contention No.19 WORKMANSHIP 47 Letter of March 20, 1950 andattachmentfromGusSpek.b,C'hairman, President's Council on Environmental Quality, to John Ahearne, Chairman, Nuclear Regulatory Ccemission ATIACMIT A Letter of February 18, 1960 from CASE to NRC Staff ATIACEMENT B Letter of October 30, 1979 from CASE to NRC Staff ATIACHMENT C FEDERAL REGISTER Pages 18023 through 18026, "10 CFR Part 20, Standards for Protection Against Radiation; Advance Notic,e of Proposed Rulemaking, Nuclear Regulatory Con: mission" ATI1CHMENT D Page from March 21, 1980 THE NATIONAL UlOERWRITER, Property &
Casualty Insurance Edition, " Predicts Nuclear Rate Rise of 63%"
ATIACEMENT E 5' This Brief Description is not intended to fully cover everything c +aised in the contention, nor is it intended to limit the scope of the cot..ention, but is merely to assist all parties and the Board in quickly identifying the contention's basic content. In CASE's 4/10/80 Position on Contentions, an itemization follows the contention number and brief description indicating the specific CASE Contentione in our 5/7/79 Contentions which are covered by each contention.
(Refer to CASE 4/10/80 Position on Contentions, page 2.)
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