ML20094N295

Answer to Applicant 840518 Motion for Summary Disposition of Case Allegations Re Section Property Values.Aslb Should Decide in Case Favor.Related Correspondence

ML20094N295
Person / Time
Site:	Comanche Peak
Issue date:	08/13/1984
From:	Ellis J Citizens Association for Sound Energy
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20094N262	List: ML20094N258 ML20094N295 ML20094N301
References
OL, NUDOCS 8408160153
Download: ML20094N295 (2)

Text

p .. ', -1 RELATED CCraWONDg 8WM .

. UNITED STATES OF AMERICA

' PA) CLEAR REGULATORY COPHISSION

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BEFORE THE AT(NIC SAFETY AND LICENSING BOARD In the Matter of "04 Agg 73 P12;;7 TEXAS UTILITIES GENERATING- Docket Nos. 50-445-l ~

COMPANY, et al.- and 50-446-1 ~- .

(Comanche Peak Steam Electric Station -

Station . Units 1 and 2) l CASE'S ANSWER TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION ,

REGARDING CASE ALLEGATIONS REGARDING SECTION PROPERTY VALUES  !

Pursuant to 10 CFR 2.749, CASE (Citizens Association for Sound Energy),

Intervenor herein, files this, its Answer to Applicants' 5/18/84 Motion for Summary Disposition of CASE Allegation Regarding Section Property Values.

l_1) . .

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 pre pared in the form of an Affidavit and which was prepared under the supeevision 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 the Board's fl/ See discussion of background and procedures to be followed regarding  ;

the series of Motions for Summary Disposition on design and design quality assurance (QA) filed by Applicants, contained in the Board's 6/29/84 Memorandum and Order (Written-Filing Decision, fit Some AWS/ASME Issues, at pages 1-3); see also transcript of 7/26/84 on-the-4 record telephone conference call.

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attention to the discussion under answer 4 (page 8), answer 5 (page 9), and answer 6 (pages 9 and 10). It appears to CASE that Applicants have made statements which are very misleading and either constitute or border on material falso 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 regar6ing the many issues which have not yet been adequately addressed by Applicants).

Raspectfully submitted, thM - I' Q$('s.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 t

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