ML19320B797
| ML19320B797 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/09/1980 |
| From: | Steptoe P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE |
| To: | Oneill J AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8007150052 | |
| Download: ML19320B797 (3) | |
Text
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7/9/80 UNITED STATES OF AMER.TCA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- In the Matter of
)
)
CONSUMERS POWER COMPANY
)
Docket No. 50-155
)
(Big Rock Point Nuclear Power
)
Station)
)
LICENSEE'S SECOND SET OF INTERROGATORIES TO JOHN O'NEILL Pursuant to 10 CFR S2.740b, Consumers Power Company
(" Licensee") requests that Intervenor John O'Neill, II answer the following interrogatories fully, in writing, under oath or affirmation.
1.
O'Neill Contention IIE-3 states that the Application has not " adequately analyzed" the possibility of criticality occuring in the Big Rock Point Plan spent fuel pool because of the increased density of spent fuel storage in the additional racks.
(Contention IIE-3 assumes that there is no gross distortion of the racks for purposes of the criticality analysis).
Please explain in detail, with i
specific reference to Section 4 of Applicant's Description 1
and Safety Analysis Report, dated April 28, 1979, and with i
specific reference to Applicant's Answers to Christa-Maria's Interrogatories 9-22 through 9-30, dated March 21, 1980,
,8007.15005%
vo in what_way or ways Applicant's criticality analysis :Us inadequate, aus alleged in contention IIE-3.
2.
Identify all documents examined or relied upon and all persons consulted in responding to paragraph 1, above.
Respectfully submitted, s.
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.t Philip P.#Steptoe[
One of,the Attorneys for Consumers Power Company l
ISHAM, LINCOLN & BEALE Suite 4200 One First National Plaza Chicago, Illinois 60603 (312) 558-7500
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- f' Mr. John O'Neill, II Route 2, Box 44 Maple City, Michigan 49664
Dear John:
Enclosed is a second set of interrogatories for you to answer, addressing the criticality contention, O'Neill Contention II E-3.
As you know, I wrote you informally on May 8, 1980 seeking clarification of this contention.
Since we have yet to receive a written responne from you, we are now making a formal request for this information.
You need not furnish copies of documents identified in these interrogatories if they are publicly available.
However, please identify them carefully by title, author, date, publisher, and type of document.
Under the schedule approved by the Licensing Board in its Order of January 17, 1980, you have fourteen (14) days after your receive this letter to answer these inter-rogatories.
Please call me if you have any questions.
I hope the summer season at your restaurant is going well.
I appreciate you must be busy, but please do the best you can in answering these interrogatories.
Sim erely, Nr l,i Phi' lip P. Steptoe PPS/kb ENC.
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