ML20024D066
| ML20024D066 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/28/1983 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8308030109 | |
| Download: ML20024D066 (4) | |
Text
.
UNITED STATES OF AMERI '
NUCLEAR REGULATORY COMMI ON
.gg BEFORE THE ATOMIC SAFETY AND LIhhiNS M BJA W " E t
(g maa e
In the Matter of I
M8 i
/
APPLICATION OF TEXAS UTILITIES I
Dodk 50-445.
I GENERATING COMPANY, ET AL. FOR and 50-446 AN OPERATING LICENSE FOR COMANCHE PEAK STEAM ELECTRI.C STATION UNITS #1 AND #2 I
(CPSES)
CASE'S MOTION TO SUPPLEMENT THE RECORD CASE (Citizens Association for Sound Energy), Intervenor herein, hereby files this, its Motion to Supplement the Record, pursuant to 10 CFR 2.730.
All of the documents which CASE seeks to have admitted into the record are referenced and discussed in detail in CASE's 7/28/83 Answer to Applicants' 7/15/83 Sumary of the Record Regarding Weave and Downhill Welding, which is being sent in the same mail with this instant pleading.
CASE hereby moves that the Board accept the following documents into the record:
Exhibits PX 5, PX 6, PX 7, PX 11, and PX 14 from the Department of Labor hearings before Administrative Law Judge Ellin M. O'Shea --
These.are discussed in more detail on pages 11 and 12 of CASE's 7/28/83 Answer. These documents represent the opinions and recommendations of high-ranking Brown & Root personnel regarding Charles Atchison's quali-fications and expertise; these individuals have not testified in our hearings and these documents are not discussed specifically in the 12/3/82 Department of Labor Administrative Law Judge's decision (admitted into evidence as CASE Exhibit 738 by Board Memorandum and Order dated January 4,1983) or the 6/10/83 Decision and Final Order by Departgent of Labor Secretary Raymond J'. Donovan (which was the basis for the Licens~ing.
Board's 7/6/83 Memorandum and Order (Collateral Estoppel; Atchison Case)).
Since it is not clear at this time when and/or if further hearings will be held regarding Atchison-related matters, CASE moves that these documents be admitted into the record of these proceedings.
8308030109 830728
~
PDR ADOCK 05000445 G
CASE Exhibit 849, NRC I&E Report 82-25/82-13, regarding major problem _s with TUGCO's vendor surveillance practices, specifically regarding Chicago Bridge & Iron (CB&I) -- This_is discussed in more detail on pages 14 and 15 of CASE's 7/28/83 Answer. This report demonstrates the serious nature and extent of the problem raised by Mr. Atchison regarding CB&I pipe whip restraints.
It is an important supporting document regarding
'Mr. Atchison's concerns.
Since it is not clear. at this time when and/or if further hearings will be held regarding Atchison-related matters, CASE moves that this document be admitted into the record of these proceedings.
CASE Exhibits 735, 736, and 739, NRC I&E Report 82-14, regarding problems with NPSI pipe whip restraints -- This is discussed in more detail on pages 16 and 17 of CASE's 7/28/83 Answer. This report documents that there were sufficient questions raised by Mr. Atchison's concerns for
'the NRC to state that " Region IV does plan to perform additional in-spections.of vendor shop performed welding and this issue remains open."
These are important supporting documents regarding Mr. Atchison's concerns.
Since it is not clear at this time when and/or if further hearings will be held regarding Atchison-related matters, CASE moves that these documents be admitted into the record of these proceedings. L1/
CASE Exhibit 737, regarding additional problems with NPSI pipe whip restraints -- This is discussed in more detail on page 17 of CASE's 7/28/83 Answer. This report documents that numerous deficiencies in welding of NPSI pipe whip restraints were discovered. Although he is not credited by the NRC for bringing -this problem to light, this appears to CASE to obviously be an important supporting document regarding Mr.
Atchison's concerns.
Since it is not clear at this time when and/or if further hearings will be held regarding Atchison-related matters, CASE moves that this document be admitted into the record of these proceedings.
For the reasons stated herein and in the attached CASE's 7/28/83 Answer to Applicants' 7/15/83 Summary of the Record Regarding Weave and Downhill We.lding, CASE moves that the preceding-listed documents to admitted into the record.
Respectfully submitted, Q
[L JNrs.) Juanita Ellis, President u.
CASE (Citizens Association for Sound Energ' )
9 1426 S. Potk - Sallas, Texas 75224 214/946-944E I
CASE filed a motion on' December 14, 1982 to supplement its admitted exhibits.
CASE Exhibits 735, 736, and 739 were included in that motion.
In its 1/4/83 Memorandum and Order, the Licensing Board as constituted at that time stated:
" Rulings on the admissibility of the remaining exhibits (other than CASE Exhibit 738, which was accepted into evidence at that time) will be deferred until the evidentiary hearing is resumed."
UNITED STATES OF AMERICA NUCLEAR REGULATO.a.Y COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
]
-In the Matter of l
^
APPLICATION OF TEXAS UTILITIES GENERATING COMPANY, ET'AL. FOR Docket Nos. 50-445 AN OPERATING LICENSE FOR i
and 50-446
. COMANCHE PEAK STEAM ELECTRIC l
STATION UNITS #1 AND #2 (CPSES)
. l CERTIFICATE OF SERVICE,
. By my signature below, I hereby certify that true and correct copies of CASE's Motion to Supplement the Record; and CASE's Answer to Applicants 7/15/93 8
-Summarh of the _ Record Regarding Weave and vownr. ll '41 ding have been sent to the names ~ listed below this 28th day of July
, 198 3,
by:. Express Mail where indicated by
- and First Class Mail elsewhere.
Attachments sent to names marked by
- only Administrative Judge Peter B. Bloch Alan S. Rosenthal, Esq., Chairman U. S. Nuclear Regulatory Comission Atomic Safety and Licensing Appeal Board 4350 East / West Highway, 4th. Floor U. S. Nuclear Regulatory Commission Bethesda, Maryland 20014 Washington, D. C.
20555 Dr. Kenneth A.' McCollom, Dean-Dr. W. Reed Johnson, ' Member Division of Engineering, Atomic Safety and Licensing Appeal Board Architecture and. Technology U. S. Nuclear Regulatory Commission
- Oklahoma State University Washington, D. C.
20555 Stillwater, Oklahoma 74074 Thomas S. Moore, Esq., Member
- Dr. Walter H. Jordan Atomic Safety.and Licensing Appeal Board
.881 W. Outer Drive U. S. Nuclear Regulatory Comission Oak Ridge, Tennessee 37830 Washington, D. C.
20555 j
- _ Nicholas S. ~Reynolds, 'Esq.
Atomic Safety and Licensing Appeal Panel Debevoise & Liberman U. S. Nuclear Regulatory Comission 1200 - 17th St., N. W.
Washington, D. C.
20555 l
- Washington, D. C.
20036 Docketing and Service Section (3 copies)
- Marjorie Ulman Rothschild, Esq.
. Office of the ' Secretary Office of. Executive Legal Director, USNRC U. S. Nuclear Regulatory Comission
' Maryland National Bank Building Washington, D. C.
20555 7735 Old Georgetown Road - Room 10105 Bethesda, Maryland 20814
- Ms. Lucinda Minton, Law Clerk Atomic pfety and Licensing Board Panel Atomic Safety. and Licensing Board 4350 East /Wes't Highway, 4th Floor Panel Bethesda, Maryland 20014 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 i
4 t
. + -
-,-w
,r
,,-u-rmen,w--,.n-
,n,
,---,,----,r--,.--,r
- w c-. n e.
.~n
~~-.-g.
Certificate of Service Page 2
- David J. Preister, Esq.
Assistant Attorney General Envirornental Protection Division Supreme Court Building.
Austin, Texas 78711 John Collins Regional Administrator, Region IV U. 5. Nuclear Regulatory Conmission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Mr. R. J. Gary Executive Vice President and General Manager
-Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas
'75201
' Lanny Alan Sinkin -
'838 East Magnolia. Avenue San Antonio, Texas 78212 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Qw W (jfirs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 C
e g
g v,
~w-r p~-
r
-m, an-p
,r
--a--
pw.
,e-