ML20134E741
| ML20134E741 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/14/1985 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML20134E721 | List: |
| References | |
| OL, NUDOCS 8508200417 | |
| Download: ML20134E741 (6) | |
Text
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C A S E = =. -
(CITIZENS ASSN. FOR SOUND ENERGY)
August 14, 1985
],[
FEDERAL EXPRESS
'85 AJG 19 P12:06 Mr. Vincent S. Noonan, Director Comanche Peak Project UFFICI F h._ >
U Division of Licensing d,
I' ' '
U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Subject:
In the Matter of Texas Utilities Electric Company et al.
Comanche Peak Steam Electric Station, Units 1 and 2 Application for an Operating License Docket Nos. 50-445 and 50-446 CASE's First Critique of Applicants' Comanche Peak Response Team (CPRT) Plan Dear Mr. Noonant CASE appreciates this opportunity to present some input i..to the Staff's consideration of Applicants' CPRT Plan, although we are disappointed that the Staff chose not to await any of CASE's specific comments before filing its NRC Staff Evaluation of the Comanche Peak Response Team Program Plan (which CASE obtained a copy of yesterday, 8/13/85).
We want to make very clear at the very outset, however, that CASE's presentation of these specific criticisms of the CPRT Plan should not be construed as changing CASE's basic position:
that Comanche Peak is i
unlicensable in its present condition, and that, at a minimum, a 1007.
reinspection is needed of both design and construction.
CASE does not consider the Applicants' CPRT Plan to be adequate - or to have the capability at this point in time of becoming adequate (dt.e to 0500200417 050014 f2DR ADOCK 050 S
I
the basic and fundamental failure early on to assure that it would be an independent protocol-controlled effort) -- to assure that Comanche Peak has been designed and constructed such that the public health and safety will not be jeopardized.
In addition, CASE does nct consider the Plan to be adequate for the specific detailed reasons discussed in the attached.
Even though our first initial response was necessarily very rushed and allowed only a partial assessment at this time, and though we were working under the handicaps of k
the lack of specificity in the Plan and the lack of necessary documents, it is obvious that there are major and very fundamental flaws in the Plan which will doom it to failure and end up proving nothing.
Again, thank you for the opportunity for us to have this input (albeit after the Staff's tentative decision).
We will be filing additional specific critiques in the future.
Respectfully submitted, CASE (Citizens Association for Sound Energy) ff? h Agg
' Mrs.) Juanita Ellis President cc:
Service List -- Docket 1 Administrative Judge Herbert Grossman
m
.C A S E==
(CITIZENS ASSN. FOR SOUND ENERGY) 00E PII,[I August 14, 1985 mssau
'85 AJG 19 P12:06 FEDERAL EXPRESS Mr. Vincent S. Noonan, Director GFF CE 0- Stcut a.
Comanche Peak Project 00ChETihG & SEeVL i Division of Licensing BRANCH U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Subject:
In the Matter of Texas Utilities Electric Company et al.
Comanche Peak Steam Electric Station, Units 1 and 2 Application for an Operating License Docket Nos. 50-445 and 50-446 CASE's First Critique of Applicants' Comanche Peak Response Team (CPRT) Plan
Dear Mr. Noonan:
CASE appreciates this opportunity to present some input into the Staff's consideration of Applicants' CPRT Plan, although we are disappointed that the Staff chose not to await any of CASE's specific comments before filing its NRC Staff Evaluation of the Comanche Peak Response Tean Program Plan (which CASE obtained a copy of yesterday, 8/13/85).
We want to make very clear at the very outset, however, that CASE's presentation of these specific criticisms of the CPRT Plan should not be construed as changing CASE's basic position:
that Comanche Peak is unlicensable in its present condition, and that, at a minimum, a 100%
reinspection is needed of both design and construction.
CASE does not consider the Applicants' CPRT Plan to be adequate - or to have the capability at this point in time of becoming adequate (due to i
1 t
cu <=
the basic and fundamental failure early on to assure that it would be an independent protocol-controlled effort) -- to assure that Comanche Peak has been designed and constructed such that the public health and safety will not be jeopardized.
In addition, CASE does not consider the Plan to be adequate for the specific detailed reasons discussed in the attached. Even though our first initial response was necessarily very rushed and allowed only a partial assessment at this time, and though we were working under the handicaps of the lack of specificity in the Plan and the lack of necessary documents, it is obvious that there are major and very fundamental flaws in the Plan which will doom it to failure and end up proving nothing.
Again, thank you for the opportunity for us to have this input (albeit after the Staff's tentative decision). We will be filing additional specific critiques in the future.
Respectfully submitted, CASE (Citizens Association for Sound Energy)
.<tMd Mrs.) Juanita Ellis President c'c :
Service List -- Docket 1 Administrative Judge Herbert Grossman 2
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't p CO M N gpgNCF DOCKETED USN1C p
'85 A!JG 19 P!2:06 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CFFICE C SECR_ N DCCXETmG & SEMV BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ERANCH In the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos. 50-445-1 and -2 COMPANY, et al.
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and 50-446-1 and -2 (Comanche Peak Steam Electric
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Station, Units 1 and 2)
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CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Motion for Dnmediate Board Order for Applicants to Preserve Evidence; CASE's First Critique of Applicants' Comanche Peak Response Team (CPRT) Plan, and cover letters to Licensing Board and to Vincent Noonan have been sent to the names listed below this 14th day of August
,1985_,
by: EXpEEEEXMXEX where indicated by
- and First Class Mail elsewhere.
Federal Express
- Administrative Judge Peter B. Bloch
- Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor
& Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
Washington, D.C.
20036
- Judge Elizabeth B. Johnson Oak Ridge National Laboratory
- Geary S. Mizuno, Esq.
P. O.. Box X, Building 3500 Office of Executive Legal Oak Ridge, Tennessee 37830 Director U. S. Nuclear Regulatory
- Dr. Kenneth A. McCollom Commission c/o Neal McCollom Maryland National Bank Bldg.
4851 Winesanker Way
- Room 10105 Fort Worth, Texas 76133 7735 Old Georgetown Road 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 Washington, D. C.
20555
- Administrative Judge Herbert Grossman U. S. Nuclear Regulatory Commission 4350 East / West Highway, 4th Floor Bethesda, Maryland 20814 1
l 1
l J'.
I Chairman Renea Hicks, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division j
U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.
20555 Austin, Texas 78711 Mr. Robert Martin Anthony Z. Roisman, Esq.
Regional Administrator, Region IV Trial Lawyers for Public Justice U. S. Nuclear Regulatory Commission 2000 P Street, N. W., Suite 611 611 Ryan Plaza Dr., Suite 1000 Washington, D. C.
20036 Arlington, Texas 76011 Mr. Owen S. Merrill i
Lanny A. Sinkin Staff Engineer 3022 Porter St., N. W.,
- 304 Advisory Committee for Reactor Washington, D. C.
20008 Safeguards (MS H-1016)
U. S. Nuclear Regulatory Commission Dr. David H. Boltz Washington, D. C.
20555 2012 S. Polk Dallas, Texas 75224 Robort A. Wooldridge, Esq.
Worsham, Forsythe, Sampels William Counsil, Vice President
& Wooldridge Texas Utilities Generating Company 2001 Bryan Tower, Suite 2500 Skyway Tower Dallas, Texas 75201 400 North Olive St., L.B. 81 Dallas, Texas 75201 Thomas G. Dignan, Jr., Esq.
Ropes & Gray Docketing and Service Section 225 Franklin Street (3 copies)
Boston, Massachusetts 02110 Office of the Secretary L. S. Nuclear Regulatory Commission Ms. Nancy H. Williams Washington, D. C.
20555 Project Manager Cygna Energy Services Ms. Billie P. Garde 101 California Street, Suite 1000 Government Accountability Project San Francisco, California 1
1901 Que Street, N. W.
94111-5894 Washington, D. C.
20009 tbrk D. Nozette, Counselor at Law Heron, Burchette, Ruckert & Rothwell 1025 Thomas Jefferson Street, N. W.,
Suite 700 Washington, D. C.
20007 e nda f1?Al-gs.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1 1426 S. Folk Dallas, Texas 75224 214/946-9446 2
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