ML20079Q217

Submits List of Stipulations Re Citizens Assoc for Sound Energy Exhibits for Verification of Authenticity & Possible Admission Into Evidence

ML20079Q217
Person / Time
Site:	Comanche Peak
Issue date:	05/06/1983
From:	Ellis J Citizens Association for Sound Energy
To:	Horin N DEBEVOISE & LIBERMAN
References
NUDOCS 8305110397
Download: ML20079Q217 (2)

Text

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CASE (CITIZENS ASSN. FOR SOUND ENERGY)

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Dear Bill:

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Subject:

In the Matter of x! iH' Application of Texas Utilities Generating Company, et al. for An Operating License For

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Comanche Peak Steam Electric Station Units #1 and #2 (CPSES)

Stipulation regarding CASE Exhibits As we discussed Wednesday and yesterday, we would like to attempt to reach a stipulation regarding certain CASE Exhibits before the . hearings week after next, if possible. Judge Bloch has indicated that it would be help-ful and would expedite things if this could be done prior to the hearings.

As we discussed, we have identified documents which were attached to our recent Briefs and Testimony, which we would like for you to. stipulate to as to their authenticity (and, wherever possible, to their admission into evidence). This will save a lot of cross-examination time and avoid our having to go over a lot of already-plowed ground in the hearings. We are identifying the Exhibits by the numbers which we have assigned to them; if this is not sufficient, please let me know and we'll supply more detailed descriptions:

Attached to CASE's 4/20/83 Brief on LOCA:

705 752 743 753 744 754

. 745 755 l 746 756 747 757 748 759 and 760 - the stipulation needed 749 here is that the 1980 version of 750 this table has the correct values l

for SA-36 steel at 300 FU and 400 0F-Attached to Jack Doyle's 4/26/83 Surrebuttal Testimony (CASE Exhibit 761):

758 761B l 8305110397 830506 PDR ADOCK 05000445 G PDR l

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3 Attached to CASE's 5/3/83 Answers to Applicants and Staff's Briefs on LOCA:

764 765 678 excerpts 677 Dr. Chang's deposition Attached to Jack Doyle's 5/4/83 Supplemental Surrebutal Testimony (CASE Exhibit 763):

716 763A (if you are familiar with it) 763B 763C-1 thru C-5 763D-1 thru D-4, and D-6 thru D-9 (and when we get it, D-5) 763E 763F 763G 763H 7631 Attached to Mark Walsh's 5/4/83 Surrebuttal Testimony (CASE Exhibit 766):

714 We will also attempt to identify for you, in the hopes of obtaining similar stipulations prior to the hearings (or at the beginning of the session on Monday, perhaps) CASE Exhibits which we will be using in the cross-examination of the NRC Staff. (Realistically, though, I'm not sure how much in advance we will be able to get them to you.) Would it be best to get copies of them to TU in Dallas, rather than mailing them to Washington? Let's talk about this one next time we have a phone conversation.

Sincerely,

CASE (Citizens Association for Sound Energy) db Mrs.) Juanita Ellis President cc

Service List (Mailed 5/7/83)

Express Mail to Board and Parties l

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