ML20079Q080
| ML20079Q080 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/07/1983 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8305110357 | |
| Download: ML20079Q080 (4) | |
Text
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSI..NG 80ARD,0 M ca i.., iv n in the Matter of APPLICATION OF TEXAS UTILITIES I
Docket Nos~. 50-445 I
~'
GENERATING' COMPANY, ET AL. FOR AN OPERATING LICENSE FOR I
and 50-446 I
COMANCHE PEAK STEAM ELECTRIC STATION UNITS El AND #2 I
(CPSES)
CASE'S ANSWER TO NRC STAFF'S MOTION TO WITHDRAW NRC STAFF'S SEPTEMBER 1982 PREFILED TESTIMONY In the NRC Staff's cover letter dated May 5,1983, to which was attached the Staff's prefiled testimony for the May hearings, the statement is made in the last sentence of the second paragraph:
"The enclosed testimony and the testimony pre-filed in March replace the September 1982 testimony of Messrs. Chen and Tapia."
CASE takes this as a motion, and thus is filing this Answer to that mo tion.
CASE is opposed to the NRC Staff's withdrawing the September 1982 prefiled testimony of Messrs. Chen and Tapia, for the following reasons:
(1) Messrs. Chen and Tapia swore to the statements made in their September 1982 prefiled testimony under oath; (2) There was cross-examination testimony regarding their prefiled September 1982 testimony, which is still in the record (and should remain in the' record);
(3) Since the Staff had not previously indicated that they would be withdrawing their September 1982 prefiled testimony, references are made to portions of it in Jack Doyle's prefiled testimony 9305110357 830507
{DRADOCK 05000445 F
/
4
< 4 (for example, see 5/4/83 Supplementary Surrebuttal Testimony of 1
Jack Doyle, CASE Exhibit 763, pages 15,16, and perhaps others --
we did not spend a great deal of time attempting to identify particular portions); and (4) The Staff has made no showing as to why the September 1982 prefiled testimony of Messrs. Chen and Tapia should be withdrawn.
For the preceding good reasons, CASE moves that the Licensing Board deny the NRC Staff's motion to withdraw the September 1982 prefiled testimony i
of Messrs. Chen and Tapia.
1 Respectfully submitted, SG ffirs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) i 1426 S. Polk l
Dallas, Texas 75224 214/946-9446 l
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i' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS10l1 BEFORE THE ATOMIC SAFETY AND LICENS!flG BOARD In the Matter of l
i APPLICATI0ft 0F TEXAS UTILITIES t.
.~
GErlERATING COMPANY, ET AL. FOR
/Q-
Docket Nos. 50-445 AN OPERATING LICENSE FOR I
'g and 50-446 COMAllCHE PEAK STEAM ELECTRIC Q
's STATION UNITS #1 AND #2 (CPSES) l s
CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's ANSWER TO NRC STAFF'S MOTION TO WITHDRAW NRC STAFF'S SEPTEMBER 1982 PREFILED TESTIMONY have been sent to the names listed below this 7th day of May
,1983_,
by: Express Mail where indicated by
- and First Class Mail elsewhere.
- 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 Commission Oak Ridge, Tennessee 37830 Washington,.D. C.
20555
- Nicholas S. Reynolds, Esq.
Atomic Safety and Licensing Appeal Panel Debevoise & Liberman; U. S. Nuclear Regulatory Commission 1200 - 17th St., N. W.
Washington, D. C.
20555 Washington, D. C.
20036 Docketing and Service Section
- Marjorie Ulman Rothschild, Esq.
Office of the Secretary Office of Executive Legal Director U. S. Iluclear 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 Safe'ty 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
Certificate of Service Page 2
- David J. Preister, Esq.
Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 Jchn Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 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 l
I hu-,udt.84/a; 6FArs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 i
l
.