ML20212E825
| ML20212E825 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/30/1986 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20212E831 | List: |
| References | |
| CON-#187-2087 OL, NUDOCS 8701050472 | |
| Download: ML20212E825 (2) | |
Text
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UNITED STATES OF AMERICA 12/30/86 NUCLEAR REGULATORY COMMISSION Da n -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
_ OL-In the Matter of I
Dockd87NodAN 5@4953 :23 i
and 50-446-eg, TEXAS UTILITIES ELECTRIC i
Tc',[
(Appficak g lfor an'Q COMPANY, et al.
l l
wn (Comanche Peak Steam Electric l
Operating License)
Station, Units 1 and 2) l CASE'S PARTIAL RESPONSE TO APPLICANTS' 12/1/86 RESPONSE TO BOARD CONCERNS CASE (Citizens Association for Sound Energy) hereby files this, its Partial Response to Applicants' 12/1/86 Response to Board Concerns. This l
response was authorized by the Board Chairman, without objection by Applicants, to be filed on December 30, 1986.
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CASE could comment on each and every one of Applicants' statements, because there is much that we do not agree with; however, this is only a partial pleading. Applicants' Response sets forth their legal position in a manner that confirms many of legal theories which CASE has believed Applicants were relying on all along; however, we have not attempted here to make our legal arguments or address Applicants' legal arguments. This l
pleading is limited to some specific points and comments which CASE Witness Jack Doyle, from his perspective of having been involved in these proceedings for over four years, believed might be helpful to the Board and were important to make at this time. We have attempted to include sufficient quotations (with appropriate references) from Applicants' pleading to allow the Board to easily follow Mr. Doyle's points without quoting Applicants' entire pleading.
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8701050472 861230 PDR ADOCK 05000445 1
O PDR
CASE will be addressing Applicants' Response at other appropriate times, and this should be considered to be only a partial response. We believe this is appropriate, since Applicants' Response was not ordered by the Board, and was not actually a Motion.
For the assistance of Applicants, we note that CASE considers that some of the items discussed in Mr. Doyle's affidavit touch on generic flaws in Applicants' Program Plan regarding design / design QA issues. We will be advising Applicants in the. future in more detail regarding these.
(This is in accordance with CASE's 9/15/86 letter to the Board under
Subject:
Memoria11zation of Changes in Recent Board Orders and/or Filing Dates for Certain Pleadings, item 4, page 3.)
Respectfully submitted, f}nrs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2
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