ML20038C052

Forwards Applicant'S Answer Supporting NRC Motion for Summary Disposition of Contention 25, & Supporting Testimony

ML20038C052
Person / Time
Site:	Comanche Peak
Issue date:	11/20/1981
From:	Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Cole R, Mccollom K, Mark Miller Atomic Safety and Licensing Board Panel
Shared Package
ML20038C053	List: ML20038C052 ML20038C054 ML20038C055 ML20038C056 ML20038C057 ML20038C058 ML20038C059 ML20038C061 ML20038C063 ML20038C064
References
NUDOCS 8112090481
Download: ML20038C052 (3)

Text

f uw orrects or ny.KETED DEB EVOIS E & LIBERMAN UTC 62 00 S EVENTE ENT H S T ri E r, N . w.

WASHINGTON. D C.70036

'81 NOV 23 P12:11 -

TELEPHONE (202) 857- 9800

.J . DGRETARY

. . ! >,G & SERVICt.

3RA!4CH November 20, 1981 Marshall E. Miller, Esq. Dr. Kenneth A. McCollom Chairman, Atomic Safety and Member, Atomic Safety and Licensing Board Licensing Board U. S. Nuclear Regulatory Dean, Division of Engineering, Commission Architecture and Technology Washington, D.C. 20555 Oklahoma State University Stillwater, Oklahoma 74074 V

Dr. Richard Cole s ,9\

tiember, Atomic Safety and Licensing Board

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U. S. Nuclear Regulatory DEC3 1981

• 1 Commission , ,, ,

Washington, D.C. 20555 cwis ca. //

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Re: Texas Utilities Generating Company, et al. h/

Comanche Peak Steam Electric Station, Units 1 and 2) Docket Nos. 50-445 and 50-446 1

Centlemen:

Submitted herewith is Applicants' Answer in Support of the NRC Staff's Motion for Summary Dispcsition of Contention 25 (Financial Qualifications). The cffidavit of E. A. Nye, Executive Vice President l and Chief Financial Officer of Texas Utilities Company, is attached to and supports Applicants' Answer.

l With regard to Contention 9 (effect of gaseous releases), also sub-mitted herewith is the Stipulation executed by CFUR and Applicants on November 20, 1981. By the terms of the Stipulation, CFUR has S

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6 withdrawn Contention 9 from this proceeding. However, because the Stipulation is contingent upon its acceptance by the NRC Staff and upon dismissal of Contention 9 by the Board, Applicants are also submitting the prepared testimony of Mr. B. T. Lancaster, Radiation Protection Engineer of Texas Utilities Generating Company ("TUGC0"),

pursuant to the Board's Schedulino Order of July 24, 1981. Of course, Applicants anticipate that Contention 9 will be dismissed and that the testimony of Mr. Lancaster will be unnecessary.

With regard to Contention 25 (financial qualifications), submitted herewith pursuant to the Board's Scheduling Order is the prepared testimony of E. A. Nye, Executive Vice President and Chief Financial Officer of Texas Utilities Company.

With regard to Board Question 2, (operations QA program), submitted herewith pursuant to the Board's Schedulino Order is the prepared testimony of (1) B. R. Clements, Vice President, Nuclear, of TUGCC; (2) D. N. Chapman, Manager of Quality Assurance of TUGC0; (3) R. A.

Jones, Manager of Plant Operations of TUGC0; and (4) A. Vega. Quality Assurance Services Supervisor of TUGCO.

In view of the withdrawal of Contention 9 by CFUR, the order for addressing issues at the hearing proposed by the NRC Staff may be less than optimal. The Staff proposed that Board Question 2, Contention 9, and Contention 25 be addressed in that order, due to the availability of the Staff's witness on Contention 25 only on December 2 (the first day of hearings) and December 7-

12. Obviously the Staff expected that hearings on Board Question 2 and Contention 9 would occupy the week of December 2. However, with the wirthdrawal of Contention 9, it now appears likely that hearings on Contention 25 will occur during the week of December 2.

^

Accordingly, Applicants suggest that Contention 25 be addressed first, on December 2, so that the Staff's witness may attend at least the first day of hearings on that issue. Applicants would not object if the Staff wishes to present its direct case on Contention 25 first in order to attempt to have its witness examined, cross-examined, and discharged on the first day.

Applicants could follow with their direct case on Contention 25.

Upon completion of hearings on Contention 25, the parties could address Board Question 2.

Respec fu sub itted, i

Nichola S. eynolds Counsel for plir. ants cc: Service List

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