ML20082H295

Answer to ASLB 831025 Memorandum (Procedure Re Qa). Encl Affidavits Show Specific Plant Deficiencies

ML20082H295
Person / Time
Site:	Comanche Peak
Issue date:	11/28/1983
From:	Ellis J Citizens Association for Sound Energy
To:
Shared Package
ML20082H284	List: ML20082H280 ML20082H295 ML20082H301 ML20082H306 ML20082H316 ML20082H326 ML20082H330 ML20082H342 ML20082H351 ML20082H360 ML20082H370
References
NUDOCS 8312010089
Download: ML20082H295 (6)

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UNITED STATES OF AMERICA NUCLEAR REGULATGRY COMMISSION 11/28/83 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

~l'n the Matter of APPLICATION.0F TEXAS UTILITIES Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR -

and 50-446 AN.0PERATING LICENSE FOR  !

, COMANCHE PEAK STEAM ELECTRIC STATION UNITS #1 AND #2 (CPSES)

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.s CASE'S ANSWER TO BOARD'S 10/25/83 MEMORANDUM (PROCEDURE CONCERNING QUALITY ASSURANCE) e b

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UtlITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 11/28/83

] BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of APPLICATION OF TEXAS UTILITIES I GENERATING COMPANY, ET AL. FOR I Docket Nos. 50-445 All OPERATING LICENSE FOR I and 50-446 COMANCHE PEAK STEAM ELECTRIC I STATION UNITS #1 AND #2

'(CPSES) j CASE'S ANSWER TO BOARD'S 10/25/83 MEMORANDUM (PROCEDURE CONCERNING QUALITY ASSURANCE)

In its 11/9/83 (1) Partial Answer to Board's 10/25/83 Memorandum (Pro-cedure Concerning Quality Assurance); (2) Motion for Additional Hearings; and (3) Motion for Protective Orders, CASE partially responded to the Board's subject Memorandum. Since that' time, the Board has communicated to the parties i a modification to the procedures established in its Memorandum lessening the extent of the specificity required in identifying deficiencies which CASE's witnesses propose to attempt to show the Board.

Despite the reservations of both CASE an'd its witnesses (as discussed on pages 18 through 23 of our 11/9/83 pleading), several of our witnesses are willing to attempt to show the Board specific deficiencies at the plant.

These are outlined in the affidavits which are attached to this pleading.

We note that Applicants, in their 11/21/83 Answer to CASE's Response to Board Memorandum and CASE's Motion for Hearings, have requested (page 4) that the Board " verify the procedures it now believes are in place for identi-fication of these alleged deficiencies." CASE believes that this would be helpful also, especially in light of the telephone conversation with the

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Board Chainnan Friday, 11/25/83, wherein the Chairman requested that CASE respond regarding the Staff's Answer to our 11/9/83 pleading (which CASE has not yet received) insofar as whether or not (and if so, what) prejudice would occur to CASE if there were a delay of no more than two months before any hearings are held. The Board has requested that CASE respond by Wednesday, November 30, in this regar'd.

As discussed in our 11/9/83 pleading (pages 20-21), our witnesses are thoroughly convinced that if they have to be too specific in the locations, etc. of the deficiencies, it would assure that the problems will have been corrected or removed by the time the Board actually makes its site visit.

In light of the possibility that hearings may be delayed (and, we assume, the site visit as well, since it would be all but impossible -- and in some O instances, actually impossible -- for CASE to bring our witnesses down for both hearings and the site visit), this is even more a concern of CASE now.

Our witnesses, in their attached affidavits, have indicated the extent of detail.which they feel will not defeat the purpose of the site visit. As will be noted, some have included more detail than others, There are some other potential witnesses whom we have not been able to contact for some time or who have indicated that they do not wish to testify. We will make one more attempt to contact them and if we are still unable to do so, will file a motion for their affidavits which we already have to be accepted as limited appearance statements by the Board. We are extremely reluctant to take this approach, since we believe that the testi-many of these individuals (and especially Roy Combs, Dennis Culton, and O

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J. R. Dillingham) is vitally important to the issues of intimidation, etc.;

they are some of the individuals who have been most severely damaged in that regard.

. CASE will continue to try to work with the Board to accommodate the Board's desire to find ways in which it can assure itself that Comanche

- Peak has been built such that it can be confidently licensed by the Board.

Respectfully submitted, iss 2 - us C f Juanita Ellis, President ASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 O

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of - l i

APPLICATION OF TEXAS UTILITIES Q GENERATING COMPANY, ET_AL FOR. Q Docket Nos. 50-445 ,

AN OPERATING LICENSE FOR Q and 50-446 COMANCHE PEAK STEAM ELECTRIC Q 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 Answer to Board's 10/25/83 Memorandum (Procedure Concerning Quality Assurance);

and CASE's Summary'of the Record Regarding Intimidation, etc., and Discouracement have been sent to the names listed below this 28th day of November , 198_3_,

by: Express Mail where indicated by

• and First Class Mail elsewhere.

Administrative Judge Peter B. Block , Alan S. Rosenthal, Esq. , Chairman U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Board Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission

/ ) Washington, D. C. 20555 Washington, D. C. 20555 Dr. Venneth 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. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555

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Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission l W 20555 O ashington, D. C. .

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. Certificate of Service Page 2 l

( David J. Preister, Esq.

Assistant Attorney General Environmental Protection Division j' P. 0.- Box 12548, Capitol' Station Austin, Texas. 78711 John Collins Regional Administrator,- Region IV

' . S. Nuclear Regulatory Commission U

! 611 Ryan Plaza Dr., Suite 1000

[- . Arlington, Texas 76011 f

( - Mr. R. J. Gary - ,

Executive Vice President and.

General Manager Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas' 75201 i

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' Lanny Sinkin-

- 114 W. 7th, Suite 220 '

Austin, Texas 78701 . '

I

, Dr. David H. Boltz i

2012 S.-Polk

(]) Dallas, Texas 75224 L w~m A bA _. -

fMrs.) Juani'ta ETlis, President

' CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 t

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