ML20024A101
| ML20024A101 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/09/1983 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Reynolds N, Rothschild M DEBEVOISE & LIBERMAN, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD), TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8306150406 | |
| Download: ML20024A101 (2) | |
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. C A GTE T= m (CITIZENS ASSN. FOR SOUND ENERGYI 214/946-9446 EXPRESS MAIL June 9, 1983
'83 d 13 EDZ9 Nicholas S. Reynolds, Esq.
Marjorie Ulman Rothschild, Esq.
Debevoise & Liberman Office of Executive Legal Director 1200 - 17th St., N. W.
U. S. Nuclear Regulatory Commission Washington, D. C.
20036 Maryland National Bank Building 7735 Old Georgetown Road - Room 10105 Bethesda, Maryland 20814
Dear Nick and Marge:
l
SUBJECT:
In the Matter of l
Application of Texas Utilities l
Generating Company, et al. for An Operating License for l
Comanche Peak Steam Electric Station Units #1 and #2 (CPSES)
Docket Nos. 50-445 and 50-446 Cross-Examination Documents We are attaching documents which we know we will be asking questions on during cross-examination in the hearings beginning June 13, 1983.
Since we only received the prefiled testimony of Applicants' and Staff's witnesses day-before-yesterday, there may be a few others; also, we are supposed to pick up some documents from Applicants this afternoon and perhaps a few others later. We will advise you as soon as we know for certain regarding the remainder of the documents. We don't expect that there will be many.
We've indicated whether Applicants' or Staff's witnesses will be cross-examined.
Also, for some, we have indicated basically what we will be asking questions about, to give the witnesses as much assistance as possible in advance of the hearings to review the documents to save everyone's time in the hearings themselves.
CASE Exhibit 844 - 3/11/83 Office Memorandum, TUSI, J. S. Marshall to H. C. Schmidt, re: NRC " erosion of confidence" in stating CPSES is a safe plant.
(This was attached as Enclosure 3 to the March 30, 1983, letter from Thomas l
M. Novak, NRC, Washington, to ASLB for CPSES, along with other attachments.) -- STAFF AND APPLICANTS l
CASE Exhibit 845 - 11/19/82 Regional Construction Assessment Team Inspections, Temporary Instruction 2512/07 Revision 1, from NRC ne ovo Inspection and Enforcement Manual (Questions will concern OP primarily manner in which CPSES CAT inspectors handled 88 their inspections, etc.) -- STAFF a)n 0
4 CASE Exhibit 849 - I&E Report 50-445/82-25, 50-446/82-13, re: Vendor (Chicago Bridge & Iron Co.) failure to adequately control inprocess oc fabrication activities; and NRC's questions "whether current 0@
surveillance practices sufficiently address vendor in-
$g process. activities, and whether the TUGC0 vendor performance 8g measurement system gives a sufficient weighting to signifi-i cant identified product deficiencies and deficiencies of a ronterino nat'tro. -- STAFF m
l TSCD
-.<j '
CASE Exhibit 850 - I&E Report 50-445/82-24,50-446/82-12,re: Systematic Assessment of Licensee Performance (SALP) for period October 1,1981, through September 30, 1982. - STAFF NRC Staff Exhibit 13B - FR Vol. 47, No. 46, 3/9/82, 9987-9995, General Statement of Policy and Procedure for Enforcement Actions
- STAFF NRC Staff Exhibit 181 - I&E Report 50-445/80-25,50-446/80-25, SALP for period August 1, 1979, through July 31, 1980 - STAFF NRC Staff Exhibits 182-195 - NRC Trend Analyses for CPSES, 1976, 1977, 1978, and 1979 - STAFF (The I&E. Reports cross-examination will have to do with whether there is anything in the reports which the CAT team sees as being similar to their findings in the CAT report, whether this is of concern to the CAT team, whether they were aware of these items, whether this indicates that there may be a continuing problem with specific areas, etc.
This also applies to the NRC Trend Analyses.)
I'll be in touch with Messrs. Treby and Horin sometime today (hopefully) and will be advising them of the preceding at that time. This should reach you by tomorrow in time for you to have before the week-end (in any event, you'll be advised today in case you want to go ahead and get copies of the documents into the hands of your witnesses).
Sincerely, CASE (Citizens Association for Sound Energy)
&~W rs.) Juanita Ellis, President Attachments (to parties and ASLB only) l cc:
Service List - Express Mail to parties and ASLB; First Class to balance i
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