ML20093M776

Requests Copy of Rev 5 to MS-46A & Restatement of Applicant Authorization to Use Documents Received by Case in Rate Hearings.Certificate of Svc Encl.Related Correspondence

ML20093M776
Person / Time
Site:	Comanche Peak
Issue date:	10/18/1984
From:	Ellis J Citizens Association for Sound Energy
To:	Horin W BISHOP, COOK, PURCELL & REYNOLDS
References
CON-#484-635 OL, NUDOCS 8410230264
Download: ML20093M776 (4)

Text

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, . s C A S E (CITIZENS ASSN. FOR SOUND ENERGY)

=E C C'J E T ED UNC October 18, 1984 Mr. William A. Horin, Esq.

'84 OCT 22 N1 $9 Bishop, Liberman, Cook, Purcell & Reynolds 1200 - 17th St., N. W. G (E_ p j Q Washington, D. C. 20036 uvC Qm Sear Bill:

Subject:

In the Matter of Texas Utilities Electric Company, et al.

Application for an Operating License for Comanche Peak Steam Electric Station, Units 1 and 2 DecketsNos.50-445and50-4464(

Documents Requested by CASE on Discovery Regarding Applicants' Motion for Summary Disposition Regarding Allegations Concerning Quality Assurance Program for Design of Piping and Pipe Supports for Comanche Peak Steam Electric Station We are still reviewing the documents which CASE requested on discovery regarding subject Motion, and we will be getting back with you regarding some of the documents which you stated in your 10/4/84 letter (page 2) that yor do not intend to provide.

There is one document, however, which you state you do not intend to prov.ide to which we specifically call your attention. It is item 4 on the 8/15/84 list of documents we requested, "Gibbs & Hill Specification MS-46A (all revisions). (Page 16)."

In your letter you state that "The material not provided generally involves matters the content of which are not relied upon in our motion, such as technical specifications (3, 4). .." Clearly this cannot be the reason for not supplying this specification (or, for that matter, item 3, "Gibbs &

Hill Specification MS-200 (all revisions). (Page 16)." since they are both specifically referenced, not only in Applicants' Affidavit, but in Applicants' Statement of Material Facts, which states, in part:

"2. Regulatory requirements and licensing commitments set forth in the license application are incorporated into design specification by Gibbs & Hill for Comanche Peak for both piping (class 2 & 3) and supports. These specifications are transmitted to the responsible design organizations for incorporation in their design process..."

8410230264 841C18 PDR ADOCK 05000445 PDR g 1 3 503

, .my .

, a e Actually, we have-a few bits and pieces of MS-46A which we have received on discovery from time to time on various aspects of the Walsh/Doyle matters,

-and in discussing.this with Ms. Boltz and reviewing our records, we find that we have a complete copy of Revision 5 of MS-46A which we obtained in the rate hearings. So it will not be necessary for you to provide a copy of Revision 5, only the other revisions before and after Revision 5.

We would also like to have, in writing, a restatement of Applicants' authorization to use in the operating license hearings documents we have received in the rate hearings, provided Applicants are advised what they are and are given an opportunity to assure themselves that there is no proprietary information contained in them.

You don't really want to fight with us before the Licensing Board on this one, do you? Please let me know in writing and we'll go from there.

Sincerely, CASE (Citizens Association for Sound Energy)

Ell President cc: Service List o

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COLKrTER UNITED STATES OF AMERICA UNC NUCLEAR REGULATORY COMMISSION

[7- BEFORE THE ATOMIC SAFETY AND LICENSING -BOAf64 OCT 22 A11 :09

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In the Matter'of }{ g.i Of m I,' -

-}{ 00CKETi% & SERVif -

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1 TEXAS UTILITIES ELECTRIC }{ Docket Nos. 50-445 f ANCH

. COMPANY, et al. }{ and 50-446-1 (Comanche Peak Steam Electric }{

, Station, Units 1 and 2) }{

CERTIFICATE OF SERVICE

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By my signature below, I hereby certify that true and correct copies of CASE's Partia1' Answer to Applicants'-Motion for Summary Disposition Regarding Applicants' Motion for Summary Disposition REgarding Applicants' Quality Assurance Proc ram for Design cf _ Piping and Pipe Supports for Comanche Peak Steam Electric Station -- anc; -- CASE's 10/18/84 lettIr to ADDlicants re: Documents Reouest by CASE on Discovery Re: Applicants' Motion for Summary Disposition Re: Allegations Concerning QA for Design

' have been sent to the names listed below thia 18th day of October ,19 8 _4 ,

iby: - Express Mail where indicated by

• and First Class Mail elsewhere.

• Ada.inistrative 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. 20336

• Judge Elizabeth B. Johnson ,

, Oak Ridge National Laboratory

• Geary S. Mizuno, Esq.

P. O. Box X, Building 3500 Office of Executive Legal Oak Ridge, Tennessee 37830 Director-

_ . . U. S. Nuclear Regulatory

• Dr. Kenneth A. McCollos, Dean CommiFsion Division of Engineering, Maryland National Bank Bldg.

Architecture and Technology - Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahon.a' 74074 Bethesda, Maryland 20814

• Dr. Walter H. Jordan' Chairman, Atomic Safety and Licensing

. 881 W.,Our.er Drive Board Panel Oak Ridge ~, Tennessee _ 37830 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 a

1 L

c .

. - 'g g 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. Davic' H. Boltz 2012 S. Polk Dallas, Texas 75224 Michael D. Spence, President Texas Utilities Generating Company Skyway Tower 400 North Ol*ve St., L.B. 81 Dallas, Texas 75201 DocketingLand Service Section (3 copies)

Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555

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( K .) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2

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