ML20106D580
| ML20106D580 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/22/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20106D567 | List: |
| References | |
| OL, NUDOCS 8410260058 | |
| Download: ML20106D580 (4) | |
Text
_
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l^
I TEXAS UTILITIES GENERATING I
Docket Nos. 50-445-1 COMPANY, et al.
I and 50-44ti-1 I
(Comanche Peak Steam Electric Station i
Station, Units' 1 and 2) l CASE'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE REGARDING APPLICANTS' PLAN AND SUPPLEMENT TO APPLICANTS' PLAN TO RESPOND TO MEMORANDUM AND ORDER (OUALITY ASSURANCE FOR DESIGN) 1.
Applicants (along with the other parties) agreed to handle the design / design OA issues by mail in the form of Motions for Summary Disposition and responses unless the Board believes that additional information or testimony is needed.
~2.
It has been represented by Applicants to the Board and parties that Applicants have filed all of their Motions for Summary Disposition on the design / design 0A issues.
3.
In their 2/3/84 Plan to Respond to Memorandum and Order (Quality Assurance for Design), Applicants stated (page 4):
l "In order to provide additional independence, Applicants intend to retain the services of an expert from the academic comuninity who will be asked to review the basic engineering principles to be l
addressed in the Plan and to provide testimony to the Board.
Applicants are in the process of selecting an individual with the necessary academic and professional background that will qualify j
the person as an indisputable expert. We will provide the Board l
with the name and qualifications when the person is selected."
I I
8410260058 841022 PDR ADOCK 05000445 PDR G
u-4.
In their 3/13/84 Supplement to Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design), Applicants' stated (page 1):
" Applicants also. committed to retain the services of an independent expert to review the basic engineering principles being addressed in the Plan."
5.
Applicants did not include this independent, indisputable expert from the academic community _as a participant in any of their various Motions for Summary Disposition.
9 m
2-
[:
-... 7g ;.
~
+
AL UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
}{
}{
TEXAS UTILITIES ELECTRIC
}{
Docket Nos. 50-445-1 COMPANY, et al.
}{
and 50-446-1
-(Comanche Peak Steam Electric
}{
Station, Units 1 and 2)
}{
CERTIFICATE OF SERVICE By myrsignature below, I hereby certify that true and correct copies of CASE's Second Motion for Summary Disposition, Regarding Applicants' Plan and Supplement to Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design) have been sen't to the names listed below this 22nd day.of October,198j[,-
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 l
4350 East / West Highway, 4th Floor
& Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
T Washington, D.C.
20036
- Judge Elizabeth B. Johnson Oak Ridge National Imboratory
- Geary S. Mizuno, Esq.
P. O. Box X, Building 3500 f
Office of Executive Legal Oak Ridge, Tennessee 37830*
Director U. S. Nuclear Regulatory
- Dr. Kenneth A. McCollon, 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. S. Nuclear Regulatory Commission i
Washington, D. C.
20555 e
I 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.
' 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 Aus'tih, Texas 78701
.3h Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Michael D. 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 JLYa f}/ 1
[gs.)JuanitaEllis, President TASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2