ML20210B757
| ML20210B757 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/27/1987 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#287-3309 CPA, OL, NUDOCS 8705060010 | |
| Download: ML20210B757 (6) | |
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DOCKETED USNRC CNN0003 and JNN0003 04/29/87 BNN0001
'87 MAY -4 P12:20 Correction to 4/27/87 CNN0001
& JNN0002, Response of CASE &
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JI to 4/3/87 B/0, 00Ci5~Im. s
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Computerization BH/4 N C "
N/A C A S E==
(CITIZENS ASSN. FOR SOUND ENERGY)
April 29, 1987 Administrative Judge Peter B. Bloch Dr. Kenneth A. McCollom Atomic Safety and Licensing Board 1107 West Knapp Street U. S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075 Washington, D. C.
20555 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830
Dear Administrative Judges:
Subject:
In the Matter of Texas Utilities Electric Company, et al.
Comanche Peak Steam Electric Station, Units 1 and 2 Docket Nos. 50-445-OL and 50-446-OL, and 50-445-CPA Application for an Operating License, and Application for a Construction Permit Corrections to Pages 1, 3, and Service List of CNN0001 and JNN0002, 4/27/87 Response of CASE (in OL) and Joint Intervenors (in'CPA) to Board's 4/3/87 Memorandum and Order (Proposed Order Concerning Standardized Computer Filing Formats)
We are attaching hereto corrected pages 1, 3, and the Service List for subject f11ing.
0705060010 870427 PDR ADOCK 05000445 PDR O
D s
The single change on page 3 is the third word of the first line:
"in" should be "is."
We did not notice the error until all copies.had been typed, copied, collated, and stapled; there was not sufficient time to redo them and still get them in the mail by our deadline of 4/27/87. However, we did change all copies with pen and ink since the error could have made it difficult to understand the sentence.
The single change on page 1 is in the third line of the standardized computer format information: we inadvertently inserted an extra "0"; it should read "BNN0001" instead of "BNN00001." We did not notice this error until we were preparing this letter.
In addition, although the basic information on the Service List was correct, some of the addresses were not (although copies were mailed to the correct addresses); in addition, we decided to send copies to Ms. Garde and Mr. Roisman by Federal Express rather than First Class Mail as was indicated. We are therefore also attaching a revised Service List.
We apologize for any inconvenience which may have been caused by these inadvertent errors.
Respectfully submitted, CASE (Citizens Association for Sound Energy)
-t.Let w Y
,fMrs.) Juanita Ellis President cc:
Service List Attachments: Revised pages 1, 3, and Service List 2
.m CNN0001 and'JNN0002 04/27/87 BNN0001 CASE's Response to 4/3/87 B/0 i
JI's Response to 4/3/87 B/0 Computerization Prejudice to Due Process N/A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' In the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos. 50-445-OL COMPANY, et al.
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and 50-446-OL (Comanche Peak Steam Electric
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Station, Units 1 and 2)
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(Application for an
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Operating License)
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Docket Na. 50-445-CPA
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(Application for a
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Construction Permit)
RESPvdSE OF CASE (IN OL) AND JOINT INTERVENORS (IN CPA)
TO BOARD'S 4/3/87 MEMORANDUM AND ORDER' (Proposed Order Concerning Standardized Computer Filing Formats)
This Response to the Board's 4/3/87 Memorandum and Order (Proposed Order Concerning Standardized Computer Filing Formats) is being filed on behalf both of CASE in the Operating License (OL) proceedings and the Joint Intervenors (CASE and Meddie Gregory) in the Construction Permit Application (CPA) proceedings /1/. Throughout this pleading, rather than having to continually refer both to CASE and Joint Intervenors, when we are speaking on behalf of both, we will usually simply refer to Intervenors; and when we use that term
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when voicing a position or concern, the Board should consider that we are i
i speaking on behalf of all Intervenors in both dockets.
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inevitably occur is that we will become a second-class party, almost like an interested party because we will not -- and cannot -- be on equal footing. We will not have equal access to the information, and essentially by default it will become an ex parte situation, because the other two parties (Applicants and NRC Staff) will be able to communicate with the Board and we will not.
Intervenors will have handicaps which will prevent full, reasoned, and intelligent participation.
In addition to the lack of machine capability is person power. The Board has its own personnel available, Jack Whetstine, as well as having available an administrative staff to assist with the computerization; CASE does not have such personnel, and those individuals who are available are. working at full capacity already.
In addition to the fact that we have lawyers or representatives in three dif f erent locations (Dallas, Texas; Washington, D.C.; and Appleton, Wisconsin), we also have expert witnesses all over the country. These experts have no capability to get on'a computer system; it would require their physical location at a computer or instead of being able to send hard copies back and forth in the mail, it would be using hard copies plus the additional task of converting to computerized records.
This brings us to yet a third f actor, which is the sheer amount of time involved to organize and maintain a computerized system. These are the three primary reasons it would be absolutely impossible for Intervenors to stand on equal footing with the other parties, and why Intervenors must regretfully oppose the Board's Order and consider the possibility of an appeal should it become necessary.
CASE has already contributed'much to these proceedings. We have done so by a lot of hard work (by CASE and its witnesses and whistleblowers) and an ability to read, digest, and analyze the issues. We are certain that the Board does not 3
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAPS in the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos. SC-445 -cL COMPANY, el d.
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and SC-446 -oL (Comanche Peak Steam Electric
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Station, Units 1 and 2)
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Doexet Nc. 50-445-CPA REVISED CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of RESPCr!SE OF CASE (IN OL) AIC JOINT INTERVENORS (IN OPA) TO BOARD'S 4/3/87 MDiCRANDUM AfD ORDER (Procosed Order Concerning Standardized Coc puter Filine Formats) have been sent to the names listed below this 27th day of Acril
,198 7 by: EmpeeGGKERD1 where indicated by
- and First Class Mall elsewnere.
Federal Express
- Administrative Judge Peter E. Bloch Thomas C. Dignan, Jr., Esq.
U. S. Nuclear Regulatory Commission Ropes & Gray 4350 East / West Highway, 4th Floor 225 Franklin Street Bethesda, Maryland 20814 Loston, Massachusetts 02110 Judge Elizabeth E. Johnson Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Geary S. Mizuno, Esq.
Office of Executive Legal Dr. Kenneth A. McCollom Dire ctor 1107 West Knapp Street U. S. Nuclear Regulatory Stillwater, Oklahoma 74075 Coemission Washington, D. C.
20555 Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 831 W. Outer Drive Board Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Com=ission Washington, D. C.
20555 1
- , ~. cs 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.
20555 Austin, Texas 78711 Mr. Robert Martin
- Anthony Z. Roisman, Esq.
Regional Administrator, Region IV 1401 New York Ave., N.W., Suite 600 U. S. Nuclear Regulatory Commission Washington, D. C.
20005 611 kyan Plaza Dr., Suite 1000 Arlington, Texas 76011 Mr. Herman Alderman Lanny A. Sinkin Starr 2ngineer Christic Institute Advisory Committee for Reactor 1324 North Capitol Street Saf eguards (MS H-1016)
Washington, D. C.
20002 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Robert A. Wooldridge, Esq.
Worsham, Forsythe, Samoels William Counsil, Vice President
& Wooldridge Texas Utilities Generating Company 2001 Bryan Tower, Suite 3200 Skyway Tower Dallas, Texas 75201 400 North Olive St., L.B. 81 Dallas, Texas 75201 Robert A. Jablon, Esq.
Spiegel & McDiarmid Docketing and Service Section 1350 New York Avenue, N.W.
(3 copies)
Washington, D. C.
20005-4798 Of fice of the Secretary U. 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, Calif ornia Midwest Office 94111-5894 104 E. Wisconsin Appleton, Wisconsin 54915-8605 Mark D. Nozette, Counselor at Law Heron, Burchette, Ruckert & Rothwell 1025 Thomas Jef f erson Street, N. W.,
Suite 700 Washington, D. C.
20007
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(f s (Mrs.) Juanita Ellis, President
'C5SE (Citizens Association for Soun,d Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2
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