ML19296D826
| ML19296D826 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/07/1980 |
| From: | LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML19296D792 | List: |
| References | |
| NUDOCS 8003130297 | |
| Download: ML19296D826 (3) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PORTLAND GENERAL ELECTRIC COMPANY,)
Docket No. 50-344 et al.
)
(Control Building
)
Proceeding)
(Trojan Nuclear Plant)
)
)
ARGUMENT AND DOCUMENTATION IN SUPPORT OF MOTION FOR
SUMMARY
DISPOSITION OF COALITION FOR SAFE POWER'S CONTENTION NO. 22 I.
The Contention At the prehearing conference on March 29, 1979, Coalition for Safe Power's Contention No. 22 was admitted (Tr. 3110-11) to read as follows:
The effect of the steel plate on displacement in the Complex has not been completely analyzed.
II.
Material Facts As To Which There Is No Genuine Issue To Be Heard A.
The analyses performed for the entire Complex in the as-built condition for purposes of ihterim operation established that, during a seismic event, relative displacements between the Control Building and adja-cent structures would not result in contact between structures.
B.
The u.odification work will increase the stiffness of the Complex by the addition of a 3-inch thick steel plate to the west wall (R-line wall) of the Control Building and by adding new concrete walls along column lines N, N' and R.
800310 r' 2.cf7
. C.
Such added stiffness will recuce displacement of the Control Building, thereby reducing relative displace-ment between the Control Building and adjacent struc-tures.
D.
Addition of the steel plate, without more, would affect the sufficiency of the existing space (" gap")
between the Control Building and Turbine Building at two elevations (93 ft and 69 ft) where there are adjacent girders and floor slabs of the Turbine Build-ing.
E.
Prior to installation of the steel plate, appropriate portions of the girders and slabs of the Turbine Build-ing at such elevations will be removed.
F.
Analyses have demonstrated that, after the foregoing actions are taken, the gap between the Control Building and Turbine Building in the modified Complex will remain adequate to prevent the structures from touching during a seismic occurrence.
These material facts are supported in the attached affidavit of Dr. William H.
White on Coalition for Safe Power's Conten-tion No. 22.
III. Discussion The material facts listed above and the attached affi-davit of Dr. White demonstrate that a complete analysis has been performed of the effects of the addition of the steel plate on displacement in the Complex.
. In explaining its Contention No. 22 at the prehearing conference, Coalition for Safe Power (CFSP) made clear that its concern related to the possibility that the addition of the steel plate to the west wall of the Control Building would reduce the gap between the Control Building and Turbine Building so that such buildings might hit each other during a seismic occurrence (Tr. 3096-97).
This concern was also stated in CFSP's supplemental response to Licensee's Interrogatory 12(c) and its response to NRC Staff Interrogatories C22-2 and C22-4.
This matter has been fully addressed in the affidavit of Dr. White (para-graphs 9 and 10) and there are no undisputed facts relating thereto.
No other specific concerns relating to this contention have been identified by CFSP.
CFSP has admitted that the steel plate will not increase deflection.
(See Tr. 3096; CFSP response to NRC Staff Interrogatory C22-4).
Since no factual issues have been raised by CFSP which contradict the facts recited in Dr. White's affidavit, the motion for summary disposition related to CFSP's Contention No. 22 should be granted as a matter of law.