ML20094F082

Answer Opposing Applicant Motion for Summary Disposition Re Consideration of Friction Forces in Design of Pipe Supports W/Small Thermal Movements.Related Correspondence

ML20094F082
Person / Time
Site:	Comanche Peak
Issue date:	08/06/1984
From:	Ellis J Citizens Association for Sound Energy
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20094E903	List: ML20094E895 ML20094E921 ML20094E938 ML20094E956 ML20094F012 ML20094F042 ML20094F058 ML20094F082 ML20094F149 ML20094F187
References
OL, NUDOCS 8408090488
Download: ML20094F082 (2)

Text

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UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD DhEED In the Matter of i TEXAS UTILITIES GENERATING Docket Nos. 5 4400f '9 Aff ;;7 COMPANY, et al. l and 50-446-1 l DFF (Comanche Peak Steam Electric Station 1 03C$n-9Ni h ;g" Station, units 1 and 2) I *Nc$

CASE'S ANSWER TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION REGARDING CONSIDERATION OF FRICTION FORCES IN THE DESIGN OF PIPE SUPPORTS WITH SMALL THERMAL MOVEMENTS Pursuant to 10 CFR 2.749, CASE (Citizens Association for Sound Energy),

Intervenor herein, files this, its Answer to Applicants' Motion for Summary Disposition Regarding Consideration of Friction Forces in the Design of Pipe Supports With Small Thermal Movements 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 a joint Affidavit and which was prepared under the supervision of CASE witnesses Jack Doyle and Mark Walsh.

Since the issues discussed are highly technical and complex, CASE could do little more than repeat the statements made by Messrs. Walsh and Doyle, which would serve little purpose and unduly burden the record. This is true with the following exceptions. We do wish to specifically call the Board's i

g/ See discussion of background and procedures to be followed regarding the series of Motions for Summary Disposition on design and design quality assurance (OA) flied by Applicants, contained in the Board's 6/29/84 Memorandum and Order.(Written-Filing Decision, #1: Some AWS/ASME 1ssues, at pages 1-3); see also transcript of 7/26/84 on-the-record telephone conference call.

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t attention to the. discussion under answer 6 (page 6). 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 Nkssrs. Walsh and Doyle, 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 taviewing the answers by Messrs. Walsh and Doyle 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, i

222 lALJ Ks.')JuanitaEllis, President TASE (Citizens Association for Sound Energy) .

1426 S. Polk Dallas, Texas 75224

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