ML19270G146

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Forwards Util Testimony & Exhibits to Be Presented as Evidence at Public Hearing During Week of 790618.W/o Encl
ML19270G146
Person / Time
Site: North Anna, 05000399  Dominion icon.png
Issue date: 04/27/1979
From: Christman J
HUNTON & WILLIAMS
To: Buck J, Mike Farrar, Rosenthal A
NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
V-8-50-20-29-15, NUDOCS 7906050053
Download: ML19270G146 (4)


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707 EAST M AIN sTRECT P. o. Box 1535 RIcitxoxn, VIROINIA 23212 Tc L c p w o N E (804) 788-8200 C A sLc H UN TWAN D WBIIINGTON, D. C. Orricz 1730 PENN$YLVANIA AvC.N. W. 20036 April 27 1979 P. O. Box 19230 8

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c Alan S. Rosenthal, Esquire 7

  1. I S C Atomic Safety & Licensing Appeal Board

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97' U.S. Nuclear Regulatory Commission 72;r.(

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Dr. John H. Buck

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Atomic Safety & Licensing Appeal Board

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U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Michael C. Farrar, Esquire Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Virginia Electric and Power Company North Anna Power Station, Units 1 & 2 Docket Nos. 50-338 OL & 50-339 OL Turbine Missile and Pump House Settlement Testimony _

Gentlemen:

Enclosed you will find the written testimony and exhibits that Vepco proposes to present as evidence at the public hearing to be held the week of June 18.

I am serving a copy of each of those documents on the other parties to this proceeding and filing a copy of this cover letter, with-out the other documents, with the Commission's Docketing &

Service Section in the usual manner.

The enclosed testimony and exhibits are the following:

790605065 3,

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HUNTON & WILLI AMS 1.

Vepco's Testimony on Service Water Pump House Settlerent 2.

Vepco Testimony on Probability of Generating Turbine Missiles and Turbine Overspeed Pro-tection System 3.

Vepco's Testimony on P2 and P3 and Turbine Inspection 4.

North Anna Units 1 and 2 FSAR Appendix E 5.

North Anna Units 1 and 2 FSAR S 10.2.1 6.

Tables and Figures for Pump House Settle-ment Testimony, North Anna Units 1 and 2, Virginia Electric and Power Company 7.

Professional Qualifications of D. H. Shaffer, J. R. Coombe, B. N. MacIver, A.

S. Lucks, R.

Bradbury, M. F. Smith, and J. A. Ahladas I will also supply the Appeal Board and parties with copies of the proposed revised Technical Specification 3/4.7.12 on settlement as soon as it is ready.

I cannot supply it to-day because it is still undergoing review by Vepco's Station and System Nuclear Safety and Operating Committees.

I propose to have the testimony, the tables and figures for the pump house settlement testimony, and the professional qualifications bound into the hearing transcript; the other documents I'd prefer to treat as exhibits.

I will get in touch with the other parties and try to reach agreement before the hearing on a sensible system for numbering and identifying the exhibits.

It may be possible that we can stipulate all the documents into evidence.

If it suits the Board, I propose to present Vepco's testimony by means of two panels of witnesses, one for pump house settlement and one for turbine missiles.

Messrs. Brad-bury, MacIver, and Lucks of Stone & Webster will be en the

HUNTON & WILLIAMS settlement panel and Messrs. Shaffer, Smith, Coombe, and Ahladas on the missile panel.

In addition, I hope to have one or more Vepco employees on the settlement panel, but I don't yet know for certain who those people will be; it de-pends in part on who will be available the week of June 18, something that cannot yet be determined in at least one case.

As soon as I've identified the appropriate people and made sure they can be available for the hearing, I will serve their professional qualifications on the Board and parties.

If this way of proceeding is objectionable to anyone, either party or Board member, I hope he will let me know.

I should like to mention that one of Vepco's wit-nesses, Dr. Shaffer, has other commitments June 21 and 22, and so I hope it will be possible to schedule the hearing so that he can testify June 18, 19, or 20.

Vepco's testimony about pump house settlement uses the settlement figures through the March 1979 survey only; there was simply not enough time to incorporate the April 1979 survey results.

You should know, however, that the April survey results indicate a difference in elevation since March of approximately 0.01 foot between reference monument B and all the other monitoring points in the ser-vice water reservoir area, including those on the pump house.

These readings could be interpreted to indicate set-tlement greater than would be expected on the basis of the settlement history of the area, and Vepco is investigating to see whether they can be validated.

We will keep the Appeal Board informed and update our testimony as necessary.

Our pump house settlement testimony does not ex-plicitly address the questions and contentions of the North Anna Environmental Coalition, but we believe that the ces-timony does adequately deal with the safety issues raised

/

HUNTON & WILLI AMS by the Coalition over the years.

In particular, we have reviewed the correspondence from the Coalition and added to the testimony where doing so seemed necessary to cover a Coalition question that would not :therwise have been addressed.

To the extent that the Coalition's contentions involve not the safety of the power plant but rather the circumstances in which various events were reported to the NRC, Vepco believes the contentions are irrelevant to this proceeding.

The Coalition has requested enforcement action based on an alleged failure to report information about foundation settlement at North Anna (see 43 Fed. Reg. 59451),

and that matter is a separate proceeding altogether, urs very truly,

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James N. Christman Counsel for Virginia Electric and Power Company 126/625 Enclosures Richard M. Foster, Esquire cc:

Anthony J. Gambardella, Esquire Daniel T. Swanson, Esquire Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Board Chief Docketing & Service Section