ML20053A514
| ML20053A514 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/20/1982 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Reynolds N DEBEVOISE & LIBERMAN |
| References | |
| NUDOCS 8205260168 | |
| Download: ML20053A514 (2) | |
Text
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. C A S E==
(CITIZENS ASSN. FOR SOUND ENERGY)
May 20, 1982
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1 -Q Mr. Nick Reynolds 4/E/
Debevoise & Liberman 1200 - 17 th St., N. W.
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Washington, D. C.
20036
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Dear Nick:
SUBJECT:
In the Matter of Application of Texas Utilities Generating Company, et al. for An Operating License for Comanche Peak Steam Electric Station Units #1 and #2 (CPSES)
CASE's Supplementary Answers to Applicants' 8/1/80 First Set of Interrogatories to CASE and Requests to Produce, Question 2 We'll be supplementing our answers to Applicants' intermgatories along as we narrow down the specific issues and documents we will be addressing in the upcoming hearings. We're therefore supplementing our answer to Question 2 of Applicants' L- - - First Set to CASE.
s We will be relying in the hearings on the following, about which we will be in touch with you soon regarding a stipulation as to their authenticity, as suggested in your msponse to the first question of our 5/7/82 Eleventh Set:
i 1
Brown & Root NCR (Nonconformance Report) C650 and its Revisions, regarding the crack in the base mat for Containment No.1.
The QA/QC aspects of the overexcavation (or rock overbreak) insofar as it relates to Contention 5, especially regarding Applicants' apparent lack of analysis as to whether or not the overexcavation may have helped cause the crack in the base mat. We have not determined precisely which documents, slides, or pictures we will be relying on but will be in touch with you soon j
in this regard, as well as to discuss whether or not it will be necessary for us to file. a motion to compel regarding Questions 101-105 of our Eleventh Set.
Respectfully submitted, 1
CASE (CITIZENS ASSOCIATION FOR SOUND ENERGY)
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(Mrs.) Juanita Ellis 5 03 President 9
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m UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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- i o-In the Matter of I
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APPLICATION OF TEXAS UTILITIES I-Docket Nos'. ' 50-,445,,
GENERATING COMPANY, ET AL. FOR AN I
and 50-446 OPERT. TING LICENSE FOR COMANCHE I
PEAK STEAM ELECTRIC STATION I
UNITS #1 AND #2 (CPSES)
I CERTIFICATE OF~ SERVICE By my signature below, I hereby certify that true and correct copies 4
of CASE's 5/20/82 Motion to Strike Applicants' Motion for Sunmary Disposition of CASE's Contention 5 for Late Filing; CASE's Supplementary Answers to NRL 5tatt's 2/22/82 Fourth Set to CASE and to Applicants 8/1/80 h rst 5et to CA5h have been sent to the names listed below tniS 20 tn day of May 1982, by:
Express mail whem indicated by
- and by hrst class Mail elsewnere.
N.
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- Administrative Judge Marshall E. Miller David J.
Preister, Esq.
U. S. Nuclear Regulatory Commission Assistant Attorney General Atomic Safety and. Licensing Board Panel Environmental Protection Division Washington, D. C.
20555 P. O. Box 12548, Capitol Station Austin, TX 78711
- Dr. Kenneth A. McCollom, Daan Division of Engineering, Architecture, and Technology Oklahoma State University Stillwater, Oklahoma 74074
- Dr. Richard Cole, Member Atomic Safety and L'icensing Atomic Safety and Licensing Board Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D.
C.-
20555 Washington, D. C.
20555
- Nicholas S. Reynolds, Esq.
_ Atomic Safety and Licensing Debevoise & Liberman Appeal Panel 1200 - 17th St.,
N. W.
U. S. Nuclear Regulatory Commission Washington, D.
C.
20036 Washington, D. C.
20555
- Marjorie Ulman Rothschild, Esq.
Docketing and Service Section Office of Executive Iagal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Washin'gton, D. C.
20555 i
t_m W hAN)
- (Mrs.) Juanita Ellis, President tASE (CITIZENS ASSOCIATION FOR SOUND ENERGY)
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