ML20093B105

Answer to Applicant Reply to Case Answer to Applicant Motion for Summary Disposition Re Consideration of Friction Forces

ML20093B105
Person / Time
Site:	Comanche Peak
Issue date:	10/01/1984
From:	Ellis J Citizens Association for Sound Energy
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20093B084	List: ML20093B081 ML20093B105 ML20093B148
References
OL, NUDOCS 8410090450
Download: ML20093B105 (2)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OCT -9 f.!0 54 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD " ~ ~

In the Matter of i

TEXAS UTILITIES GENERATING COMPANY, et al.' DocketNos.50-445"/ O and 50-446[ dL (Comanche Peak Steam Electric Station i Station, Units 1 and 2)

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CASE'S ANSWER TO APPLICANTS' REPLY TO CASE'S ANSWER TO APPLICANTS' MOTION FOR SUW MRY DISPOSITION REGARDING CONSIEGATION OF FRICTION FORCES CASE (Citizens Association for Sound Energy), Intervenor herein, files this, its Answer to Applicants' Reply to CASE's Answer to Applicant Motion for Sumary Disposition Regarding Consideration of Friction Forces .

As discussed in the attached Affidavit by CASE Witness Mark Walsh ,

this response is necessary because Applicants Reply contains information (including the use of new calculations not provided previously) to which .

Walsh believes it is necessary for him to respond in order toecord make the r complete.

This is consistent with the Board's often-stated desire to all the cards on the table and to have a complete record regarding these design / design QA issues.

Also, it is absolutely essential in order for the Board to have an adequate basis to make an informed, reasoned judgeme ,

especially in light of the unusual handling of the design / design QA issues and the desire of the Board and all parties to handle these matters if at all possible in writing and without the necessity for additional hearings .

We ask that the Board allow this pleading on that basis.

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It is very disturbing to CASE that the fruits of having to do too much in too short a time are now becoming apparent, to the detriment of CASE, its witnesses, ard the record. Because of this, there are two instances cited in the attached Affidavit of Mark Walsh where more time would undoubtedly have saved everyone a lot of time and effort now. This is an additional reason for the Board's allowing this instant pleading.

CASE's further Answer is cont' a ined in the Affidavit of Mr. Walsh which is attached hereto.

Respectfully submitted, .

0s/s k ff/ '. ,

s.] Juanita Ellis, President ASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446

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