ML20093D928
| ML20093D928 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/09/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | |
| Shared Package | |
| ML20093D907 | List: |
| References | |
| OL, NUDOCS 8410110468 | |
| Download: ML20093D928 (4) | |
Text
.
10/9/84 W}*" j.~.
- w..e, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 84 DCT 11 m n'o BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
$h',. (,,C In the Matter of l
e i
i o.>
TEXAS UTILITIES GENERATING l
Docket Nos. 50-445-OC COMPANY, et al.
l and 50-446-D {
l (Comanche Peak Steam Electric Station l
Statior., Units 1 and 2) i CASE'S ANSWER TO APP'LICANTS' REPLY TO CASE'S ANSWER TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION REGARDING LOCAL DISPLACEMENTS AND STRESSES CASE (Citizens Association for Sound Energy), Intervenor herein, hereby files this, its Answer to Applicants' Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Local Displacements and Stresses.
We discussed in some detail the reasons we believe the Board should allow this and similar Answers to Applicants' replies to CASE's Answers to Applicants' Motions for Summary Disposition in our 10/1/84 and 10/2/84 Answers di, so we will not repeat those same arguments here but incorporate them herein by reference. We note that Applicants have filed a 10/4/84 Motion to Strike those two pleadings and any future such Answers by CASE, and we urge that the Board deny Applicants' Motion.
CASE believes that the Board must (especially because of the very unusual nature of the method adopted for handling the design / design QA/QC issues in this proceeding) base any decision in this matter primarily on its ultimate responsibility to assure a complete record on which to base a n/ See CASE's 10/1/84 Answer to Applicants' Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Consideration of i
Friction Forces; and CASE's 10/2/84 Answer to Applicants' Reply to l
CASE's Answer to Applicants' Motion Regarding Alleged Errors Made in Determining Damping Factors for OBE and SSE Loading Conditions.
8410110468 841009 I
PDR ADOCK 05000445 1
(
Q PDR n
1 i
reasoned, informed decision. This cannot be accomplished if the Board allows Applicants to use their replies to provide new information and analyses which CASE has not had the opportunity to address previously. CASE urges that the Board assure that all the cards are on the table on these important mattore. This unusual procedure also requires that the Board take into consideration the requirements of 10 CFR 2.743(a) and 2.754(a), since we are, in effect, engaged in hearings by mail on the design / design QA/QC issues.
CASE will attempt not to abuse our filing of these Answers; for example, we are not responding to Applicants' many comments with which we merely disagree, but we are, rather, attempting to restrict our responses to addressing new information, analyses, argument, etc., included in Applicants' Replies. The Board must have CASE's response to such new information in order to have a complete record and in the interest of fairness and due process.
For the preceding reasons, the Board should accept our instant pleading and future such pleadings as being necessary to the Board's arriving at a valid decision in these proceedings.
Our Answer in this instance is contained in the a'ttached Affidavit of CASE Witness Jack Doyle.
Respectfully submitted,
<2wx f%,
gkfs.~)Juanit'aEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk i
Dallas, Texas 75224 214/946-9446 2
I ' ' ^_- ' E n r.K UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIdG %0AP g [ '
In the Matter of -
}{
}{
TEXAS UTILITIES ELECTRIC
}{
Docke t No s. 50-445-1 COMPANY, et al.
}{
and 50-446-1 (Comanche Peak Steam Electric
}{
Station, Units 1 and 2)
}{
CERTIFICATE OF SERVICE By my signatttre below, I hereby certify that true and correct copies of CASE'sWAnswer to Applicants' Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Local Displacements and Stresses have been sent to the names listed below this 9th October,193_4,
day of by: Express Mail where indicated by
- and First Class Mail elsewhere.
- Administrative Judge Peter B. Bloch
- Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor
& Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
Washington, D.C.
20036
- Ms. Ellen Ginsberg, Law Clerk U. S. Nuclear Regulatory Commission
- Geary S. Mizuno, Esq.
4350 East / West Highway, 4th Floor Office of Executive Legal Bethesda, Maryland 20814 Director U. S. Nuclear Regulatory
- Dr. Kenneth A. McCollom, Dean Commission Division of Engineering, Maryland National Bank Bldg.
Architecture and Technology
- Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814
- Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak Ridge, Tennessee 37830 U. 3. Nuclear Regulatory Commission Washington, D. C.
20555 1
Chairman Renea Hicks, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission
. Supreme Court Building Washington, D. C.
20555 Austin, Texas 78711 John Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000
-Arlington, Texas 76011 Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701 Dr. David H. Bolt:
2012 S. Polk Dallas, Texas 75224 Michaefid. Spence $ President Texas Utilities Generating Company Skyway Tower 400 North Olive St., L.B. 81 Dallas, Texas 75201 Docketing and Service Section (3 copies)
Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Md-
~)
~
@p4.)JuanitaR11is,~ President GSE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2
.,