ML19323D197
| ML19323D197 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/10/1980 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19323D198 | List: |
| References | |
| NUDOCS 8005210244 | |
| Download: ML19323D197 (3) | |
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UNIED STATES OF AMERICA NUCLZAR REGUIATORY CO}HISSION EEFORE TE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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i APPLICATION OF TEXAS UI'ILITIES l
Docket Nos. 50 W5 GENERATING CCHPANY, ET AL. FOR AN i
and 50 hko OPERATING LICENSE FOR CCHANCE
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MOTION TO CONbIDER 2
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'O CASE CONTENTION NO. 8 0F. -
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Dcdetig[0 S! rih 3 POSITION ON CONTENTIONS BY E
CASE (CITIZENS ASSOCIATION FOR SOUND EERGY) o, s
CCNES NOW CASE, INTERVENOR EEREIN, and moves this Board to consider the admissability of CASE's Contention No. 8 J.n subject pleading attached hereto prior to consideration of CASE's or othe$ Intervenors' other contentions fer the following reasons:
I.
CASE has recently received a copy of the March 20, 1980 letter and attachments frcm Gus Speth, Chairman, President's Council on Environmental Quality, to John'Ahearne, Chairman, U. S. Nuclear Regulatory Commission, concerning the issue of whether or not to consider,the possibility of, results of, and effects on health, property and lives of a Class 9 accident at each individual nuclear power plant. This report concluded that Class 9 accidents l
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should be considered in the Environmental Impact Statement for each individual nuclear power plant (Attachment A, page 10, of attached pleading).
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In order to facilitate preparation of this Environmental Ispact Statement, Applicant should be required to address Class 9 accidents in both its Environmental Report and its Fiy Safety Analysis Report. This has not l
been done.
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In light of the far-reaching effects a ruling for CASE on the ad-missability mf this contention would have, CASE :naintains that this Board should render its decision on this issue.before considering the remaining contentions, both for the benefit of the Intervenors and especially for the benefit of the Applicant and the NRC Staff, as Applicant and Staff have not considered Class 9 accidents in any of their pleadings or reports previously filed in the construction licensing sta'ge or the operating licensing stage.
WHEREFORE, PREMISED CONSIDERED, CASE prays that this Board consider CASE's Contention No. 8 in our attached pleading of 4/10/80 before considering CASE's or other Intervenors' other contentions.
Respectfully submitted, a ni4 >
( % ) Juanita Ellis, President CASE (CITIZENS ASSOCIATION FOR 30UND ENERGY) 1426 S. Polk Dallas, TX 75224 214/946-9446 t
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UNITED STATES OF AMERICA
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BE70RE THE ATOMIC SAFETY AND LICENSING BOARD _
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In the Matter of Docket Nos. 50-445 qp gh
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TEXAS UTILITIES GENER. TING COMPANY, ET AL. )
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CERT..IF..IC._ ATE OF SERV.I_CE I hereby certify that copies of " POSITION ON CONT 0F POSITION ON CONTENTIONS BY CASE (CITIZENS AS in the above-captioned proceeding have been served on the following by depo in the United States mail, first class, this 10th daf of April, '.980:
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David J..Preists'r, Esq.-
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Elizabeth S. Bowers, Esq., Chairman
- Assistant Attorney General hl Atomic Safety and Licensing Board EnvironmentalfProtection Division U.S. Nuclear Regniatory Ccamission P. O. Box I2548, Capitol Station
~ '1 Washington, DC 20555 Austin, TX 78711 1
Dr. Forrest J. Remick, Member
~f Mr. Richard Fouke Atomic Safety and Licensing Board 305 E.. Hamilton Avenue 1668-3 Ca~rter Dr,1ve
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Arlington, TX.76010 P
State College, PA 16801 I
Atomic Safhty and Licensing Board Dr. Richard Cole, Member
- Atomic Saf ety and Licensing Board [
. Panel
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U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Conmiission t
Washington, DC 20355 t
Washington, DC 20555 Atomic Safety and Licensing Appeal h
Nicholas S. Reynolds, Esq.
Panel (5)*
Debevoise & Liberman U.S. Nuclear-Regulatory Cosumission 1200 17th Street, N.W.
Washington, DC 20555 Washington, DC 20036 Docketing and" Service Section (7)*
Marjorie Rothschild.
office of t.he. Secretary Counsel for NRC Sthff U.S. Nuclear' Regulatory Commission U. S. Kuclear Regulatory Commission Washington, DC, 20555 Washington, D. C.
20535 Mr. Geoffrey M. Cay West Texas Legal Services 100 Main Street (Lawyers Bldg.)
Fort Worth, TX 76102 i
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(%) Juanita Ellis, President of CASE l
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