ML20107J088

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Third Motion for Summary Disposition Re Lack of Independence &/Or Credibility of Cygna
ML20107J088
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 11/02/1984
From: Ellis J
Citizens Association for Sound Energy
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20107H934 List:
References
OL, NUDOCS 8411090371
Download: ML20107J088 (2)


Text

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.-{ s 11/2/84 $$["U - UNITED STATES OF-AMERICA ~ NUCLEAR REGULATORY. COMMISSION ~64. NOV -g - BEFORE THE ATOMIC : SAFETY AND LICENSING BOARD

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-In the Matter'of 'i. kNu ~ I w.4, 6o ' TEXAS UTILITIES: GENERATING-l. Docket Nos. 50-445-G

COMPANY, et' al.

l and 50-446-D Q. l (Comanche 1 Peak' Steam Electric Station l Station, Units -1 and 2) { ~ CASE'S THIRD MOTION FOR

SUMMARY

DISPOSITION, REGARDING LACK OF INDEPENDENCE AND/OR CREDIBILITY OF CYGNA'

Pursuant to 10 CFR 2.749(a),. CASE (Citizens Association for Sound Energy), Intervenor herein, files this, its Third Motion.for Summary

' Disposition, Regarding Lack of. Independence'and/or Credibility of Cygna. JCASE's Third Motion is as set forth in the attached Affidavit'of CASE 1 Witness Jack Doyle. As with CASE's 10/6/84 First-Motion for Summary

Disposition, our Third Motion addresses certain aspects of the Cygna Phases 1 and 2'and Cygna Phase 3 Reports.

(See also CASE's 11/2/84' Answer to, and Motions _Regarding, Applicants' Motions to Set Schedule for Briefs Addressing Cygna: Phase 3 Iss'ues and for Expedited Responses, which is being sent in the

same mail.as CASE's-instant motion.)

lL The issue of Cygna's. independence and/or credibility is of vital [, / (1 importance'in these proceedings, since part of Cygna's reviews are the -direct' result of the Board's 12/28/83 Memorandum and. Order (Design Quality [- iAssurance).(see Applicants',10/5/84 Motions to Set Schedule for Briefs . Addressing Cygna Phase 3 Issues and for Expedited Responses, page 1), and L L j 8411090371 841102 'gDRADOCK 05000445 L .i PDR L l. 1 q lp i

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since:the Board may rely, fin part, upon the Cygna Phases 1 and 2 and Cygna ~ Phase 3 Reports in making its decision on whether or not to grant an operating license for Comanche. Peak. For the reasons stated above and in the attached Affidavit of CASE ' Witness _ Jack Doyle, CASE moves that the Licensing Board rule favorably on

s CASE's Motion.

Respectfully submitted, /AN f/A *, rs.) Juanita Ellis, President CASE (Citizens Association for Sound LEnergy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 } 2 L_}}