ML20094F012

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Answer Opposing Applicant 840517 Motion for Summary Disposition of Certain Case Allegations on Aws & ASME Code Provisions Re Design Issues.Related Correspondence
ML20094F012
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/06/1984
From: Ellis J
Citizens Association for Sound Energy
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20094E903 List:
References
OL, NUDOCS 8408090463
Download: ML20094F012 (2)
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Text

r-e R El].TE D L ., ':?o::CENCE 8/6/84 .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

%fD In the Matter of i l .Y AGj. -

TEXAS UTILITIES GENERATING I Docket Nos. 50-445 f All!11 COMPANY, et al.- l ander @0-4_46-1 i UCiggg,'MC g"7g,,

(Comanche Peak Steam Electric Station Station, Units 1 and 2) i iM Vr l ,

CASE'S ANSWER TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF CERTAIN CASE ALLEGATIONS REGARDING AWS AND ASME CODE PROVISIONS RELATED TO DESIGN ISSUES Pursuant.to 10 CFR 2.749, CASE (Citizens Association for Sound Energy),

Intervenor herein, files this, its Answer to Applicants' 5/17/84 Motion for Summary Disposition of Certain CASE Allegations Regarding AWS and ASME Code Provisions Related to. Design Issues d /.

CASE's Answer is as stated in the attached CASE's Answer to Applicants' Statement of Material Facts As to Which There Is No Genuine Issue of Fact, which has been prepared in the form of an Affidavit and which was prepared under the supervision of CASE witness Mark Walsh.

Since the issues discussed are highly technical and complex, CASE could do little more than repeat the statements made by Mr. Walsh, which would serve little purpose and unduly burden the record. This is true with the following exceptions. We do wish to specifically call to the Board's H/ See discussion of background and procedures to be followed regarding the series of Motions for Summary Disposition on design and design quality assurance (OA) filed by Applicants, contained in the Board's 6/29/84 Memorandum and Order (Written-Filing Decision, #1: Some AWS/ASME Issues, at pages 1-3); see also transcript of 7/26/84 on-the- i record telephone conference call.

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attention the discussion under answer 2 (page 6), answer 10 (pages 16 and 17), and answer 15 (page 21), it appears to CASE that Applicants have made statements which are very misleading and either constitute or border on material false statements. We ask that the Board consider Applicants' statements in that light.

As stated by Mr. Walsh, Applicants' Motion for Summary Disposition does not adequately address the actual issues which have been raised. However, even in the limited context of Applicants' Motion, it is clear from reviewing the answers by Mr. Walsh that there are many genuine issues of fact which are still in controversy. We believe the Board should decide in CASE's favor regarding those issues (as well as regarding the many issues which have not yet been adequately addressed by Applicants).

Respectfully submitted, Owh f/AD rs.) Juanita Ellis, President

. 1426 S. Polk Dallas, Texas 75224 214/946-9446 2

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