ML20206N052
| ML20206N052 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/07/1988 |
| From: | Brian Lee NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| To: | Zech L NRC COMMISSION (OCM) |
| References | |
| CON-#488-7257 CPA, OL, NUDOCS 8812020227 | |
| Download: ML20206N052 (3) | |
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NUCLEAR MANAGEMENT AND RESOURCES COUNCIL a t,e sw w. see m. v.wmn oC m 2m '88 OCT 12 A10 :38 a m.4m Byton Lae, Jr.
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October 7,1988 The Honorable Lando W. Zech, Jr.
Chairman U. S. Nuclear Regulatory Comission Washingt:n, DC 20555
Dear Chairman Zech:
RE:
Texas Utilities Electric Comoany (Comanche Peak Steam Electric Station. Units 1 and 2)
Docket Nos. 50 445 and 50 446
Dear Commissioners:
This letter is submitted on behalf of the Nuclear Management and Resources Council, Inc. ("NUMRC") in response to a situation that could disrupt. the settlement of the licensing proceedings involving Comanche Peak Steam Electric Station and that has potential generic implications to all comercial member power plants. NUMARC is the organizattor, of the nuclear power industry that is responsible for coordinating the combined efforts of all utilities licensed by the NRC to construct or operate nuclear power plants, and of other nuclear industry organizations, in all matters involving generic regulatory policy issues and on the regulatory aspects of generic operational and technical issues affesting the nuclear power industry.
Every utility responsible for constructing or operating a comercial nuclear power plant in tie United States is a member of NUMARC.
In addition, NUMARC's members include major architect-engineering firms and all of the major nuclear steam supply system ver. dors.
NUMARC believes that the recent settlement of the Comanche Peak ilcensing proceedings after nine years of complex and protracted litiga*. ion is fully in accord with Comission policy and represents a significant milestone in the resolution of contested licensing prce.eedings.
In essence, the parties to that proceeding, with the assistance and support of the NRC Staff, developed a sound program for resolving technical issues, thereby eliminating the need for recourse to the adjudicatory process.
Recently, there has been an effort to disrupt the settlement and to reinstitute contentious licensing proceedings.
Specifically, there is presently pending before the Comission a Petition ta Intervene by Citizens for Fair Utility Regulation (CFUR).
Filings by the Applicants and the NRC Staff show that the CFUR Petition fails to raise any significant safety or other issues and does not provide a sufficient basis for reinstituting licensing proceedings.
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.I Landn W. Zech, Jr.
October 7, 1988 Page 2 In light of the important public policy whir.h is fostered by the settlement of the Comanche Peak licensing procoecings, NUMARC believes that the Comission itself should act promptly and decisively to deny the Petition, without referring the petition to a Licensing Board with the inevitable attendant delay that would result.
Prompt action by the Comission will serve to reinforce the Comission's policy to resolve contested proceedings and will lend necessary stability to the adjudicatory process.
In sumary, NUMARC believes that the recent settlement of the Cemanche Peak licensing proceedings represents sound regulatory policy.
Th d policy has important implications to all licensed facilities. That policy will be seriously undermined if additional unnecessary proceedings of any kind are allowed to be initiated before a Licensing Board. Conversely, prompt action by the Comission to reinforce the Comission's policy will encourage niembers of the nuclear industry ind parties representing other interests to resolve contested proceedings whenever possible.
NUMARC, therefore, urges the Comission to itself act on the CFUR Petition and deny the Petition without further delay.
Sincerely, n J
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ByfonLee,Jr.
BL/RWB:bb cc: Kenneth M. Carr Thomas M. Roberts Kenneth C. Rogers Victor Stello, Jr.
cc Distribution List
DISTRIBUTION LIST Peter B. Bloch, Esquire Susan M.
Theisen, Esquire Chairman Assistant Attorney General Atomic Safety and Licensing Attorney General of Texas Board Environtantal Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548 Washington, D.C.
20555 Austin, Texas 78711-1548 Adjudicatory File Dr. Walter H. Jordan Atomic Safety and Licensing 881 West Outer Drive Board and Panel Docket Oa's Ridge, Tennessee 37630 U.S.
Nuclear Regulatory Commission Robert D. Martin Washington, D.C.
20555 Regional Administrator, Region IV Alan S. Rosenthal, Esq.
U.S. Nuclear Regulatory Chairman Commission Atomic Safety and Licensing 611 T.yan Plaza Drive Appeal Panel Suite 1000 U.S. Nuclear Regulatory Arlington, Texas 76011 Commission Washington, D.C.
20555 Dr. Kenneth A. McCollom Administrative Judge Assistant Director for 1107 West Knapp Inspection Programs Stillwater, Oklahoma 74075 Comanche Peak Project Divi sion U.S.
Nuclear Regulatory Janice E. Poore, Esquire Commission Office of the General Counsel P.O. Box 1029 U.S. Nuclear Regulatory Granbury, Texas 76048 Commission Washington, D.C.
20555 1
Juanita Ellis President, CASE Anthony Roisman, Esquire 1426 South Polk Street 1401 New York Avenue, N.W.
i Dallas, TX 75224 Suite 600 Washington, D C.
20005 William L. Clemer.t s Docketing & Service Branch Robert A. Wooldridge, Esqcire U.S. Nuclear Regulatory Worsham, Forsythe, Sampels &
Commission Wooldridge Washington, D.C.
20555 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201 Billie Pirner Gardo Government Ar. countability W. G. Counsil Project Executive Vice President Midwest Office Texas Utilities Electric Company 104 E. Wisecnsin Avenue - B Generating Division Appleton, WI 54911-4897 400 N. Olive, L.B.
81 Dallas, Texas 75201 Richard L. C rlf fin, Esquire 600 North Main Fort Worth, Texas 76106
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