ML19263E877

Forwards Page 5 of Applicant Opposition to Intervenor Miami Valley Power Project Motion to Amend Petition to Intervene.Page Was Omitted from Original Filing

ML19263E877
Person / Time
Site:	Zimmer
Issue date:	05/14/1979
From:	Conner T CONNER, MOORE & CORBER
To:	Stephens C NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 7906250415
Download: ML19263E877 (2)

Text

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• United States Nuclear Regulatory 'Y Commission Washington, D. C. 20555 In the Matter of The Cincinnati Gas & Electric Company, et al.

(William H. Zimmer Nuclear Power Station)

Docket No. 50-358

Dear Chase:

Attached is a copy of page 5 of " Applicants' Opposition to Intervenor Miami Valley Power Project's Motion to Amend Its Petition for Leave to Intervene," in the captioned pro-ceeding, which was inadvertently omitted from our submission.

Sincerely, M d Cnwe+.O Troy Q nner, Jr. U

)&

Counsel for the Applicants

/dr Attachment cc: All Parties 7906250 V/S 2214 209

protection in general or insulating materials in particular.

Certainly, the Motion does not meet the requirements of 52.714 to demota rate that MVPP's representative provides even >

effective lay assistance on this subject.

Nowhere are Mr. Hofstadter's qualifications or creden-tials stated. Moreover, the Motion itself demonstrates a total lack of technical competence sufficient to assist the Board in developing a sound record. For example, the Support for Proposed Contention 17 incorrectly states that the cable tray insulation design for the Zimmer facility is the same a's for Browns Ferry. This is simply incorrect. As shown in Section 8.3.3.2 and Applicants' Response to Question 9,

p. 09-1, Revision 8 (September 1978), all Zimmer safety-related cables are qualified to IEEE-383. .

Further, MVPP erroneously states that the Zimmer cable trays will be stacked vertically three on top of each other, with only one tray wrapped with Kaowool. The criteria for cable tray insulation are stated in Section 8.3.3.2, p. 8.3-30, FSAR, as well as Applicants' Responses to Question 7, p. Q7-1 and Question 12, p. 012-1, Revision 11 (February 1979).

MVPP argues that the test was inadequate because "merely turning a straight section on its side does not adequately test a vertical fitting" (emphasis supplied). The proposed contention relates to insulation which was the subject of the tests described in Revision 12. This test has nothing to do 2214 210