ML20080S311

Requests Stipulations/Admissions to Authenticity of Documents Attached as Offer of Proof to Citizens Assoc for Sound Energy Motion to Add New Contention & Motion for Discovery

ML20080S311
Person / Time
Site:	Comanche Peak
Issue date:	10/13/1983
From:	Ellis J Citizens Association for Sound Energy
To:	Reynolds N LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
Shared Package
ML20080S315	List: ML20080S311 ML20080S326
References
NUDOCS 8310180339
Download: ML20080S311 (3)

Text

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CASE (CITIZENS ASSN. FOR SOUND ENERGY)

October 13, 1983

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21L/946-9W6 13 OCT 17 P4:06 Mr. Nicholas S. P.eynolds, Esq. CFFitt OF SLClit :

Debevoise & Liberman 00CKEijNG & SE?i J 1200 - 17th St., N. W.

Washington, D. C. 20036

SUBJECT:

In the Matter of Application of Texas Utilities Generating Company, et al. for An Operating License for Comanche Peak Steam Electric Station Units #1 and #2 (CPSES)

Request for Stipulations or Adnissions Regarding Documents Attached as An Offer of Proof to CASE's (1) Motion to Add a New Contention (Contention 26), (2) Motion for Discovery, and (3) Offer of Proof As discussed on pages 15 and 16 of subject pleading, under today's date, we request that Apolicants stipulate or admit to the authenticity of the documents discussed.

I We also ask that you bring these documents with you to the hearings begin-ning October 17, 1983, since we will be asking cross-examination questions regarding some cf thea.

We'll appreciate your cooperation in this matter.

Sincerely, l

CASE (Citizens Association for Sound Energy)

M E Yb Mrs.) Juanita Ellis President l

cc: Service List l

l Footnote to Stuart Trebj, NRC, Washington: As indicated in the abwe, please l bring the docunents attached to the above-referenced Motion with you to the j hearings next week; we will be dev.g some cross-examining on them. Thanks.

je 8310180339 83101J DR ADOCK 05000 {,

UNITED STATES OF AMERICA 10/13/83 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of-APPLICATION OF TEXAS UTILITIES Docket Nos. 50-445 GEHERATING COMPANY, ET AL. FOR and 50-446 g

AN OPERATING LICENSE FOR COMANCHE PEAK STEAM ELECl?.IC I STATION UNITS #1 AND #2

~(CPSLS) g INDEX TO CASE'S (1) MOTION TO ADD A NEW CONTENTION,

(?) MOTION FOR DISCOVERY, AND (3) 0FFER OF PROOF Page '

PROPOSED CONTENTION 26 1 REGULATIONS GOVERNING NEW CONTENTIONS 3 GOOD CAUSE EXISTS FOR CASE'S NOT HAVING FILED THIS CONTENTION PRIOR TO THIS TIf E 5

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Did not hava access; r.ew information; just received; discovered in connection with DP&L rate hearings 5 Applicants . attempted to prevent CASE from obtaining .

the infonnation, then attempted to preunt CASE from obtaining the information except under a protective order 6 Testirny in these proceedings by both Applicants and the NRC Staff regarding the magnitude and extent of prot'lems in construction and/or design at Comanche Peak has been misleading 9 CASE is attiempting to review, analyze, and prepare the documents received in a controlled, organized fashion,

, as directed by the Licensing Board 14 1

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Index Page 2 Page DISCUSSION OF SPECIFIC PROBLEM AREAS' AND DOCUMENTATION --

0FFER OF.PR0OF 15 Listing of all systems at Comanche Peak which have and have not been turned over to operations 17 In direct contradition with testimony in these proceedings 19 Questions raised 20 Use of proper guidelines at Comanche Peak 22 General Information Regarding Tests 23 Punchlists 24 Tests Performed 26 Thermal Expansion Test (CASE Exhibit 860) 26 Containment Temperature Survey (CASE Exhibit 857) '35 Control Room Heating & Ventilation System Performance (CASE Exhibit 859) 37 Steam Generator Safety and Relief Valves (CASE Exhibit 862) 38 Containment Integrated Leak Rate Test (CASE Exhibit 863) 39 Reactor Coolant Pump Test (CASE Exhibit 861) 40 I

Auxiliary Feedwater Turbine Driven Funp (CASE Exhibit 856) 41 Hot Functional Test Sequence (CASE Exhibit 858) 43 Major Problem Areas 46 l

l NEED FOR DISCOVERY 50 INFORMATION OBTAINED IS RELEVANT, MATERIAL, AND VITALLY IMPORTANT FOR THE RECORD 51 l CASE'S MOTION WILL NOT DELAY THE PROCEEDINGS 54 CASE'S MOTIONS 54 l

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