ML20004D461
| ML20004D461 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/02/1981 |
| From: | Bursey B AFFILIATION NOT ASSIGNED |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8106090425 | |
| Download: ML20004D461 (2) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of:
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a South Carolina Electric and
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Gas Company, et al.
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Docket No. 50-395 7
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Virgil C. Sumer Nuclear
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Station June 2, 1981
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INTERVENOR BURSEY'S RESPONSE TO STAFF MOTIONS
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FOR SUF".\\RY DISPOSITION OF CONTENTIONS 2,3, and 4(b)
Intervenor Bursey hereby opposes the NRC Staff Motion for Summary Disposition
, of Intervenor's Contention 2,3, and 4 (b).
CONTENTION 2:
I have attatched Dr. Ruoff's response in support of ray contention 2 (financial qualifications).
Dr. Ruoff clearly raises issues of material fact that will necessitate evidenciary hearings on contention 2.
The attatched i affidavits by Dr. Ruoff sets forth factual matters to be resolved in evidenciary hearings on contention 2.
CONTENTION 3: The Applicant's own affiant, Robert Steitler, stated that the applicant's facility is readily adaptable to ATWS mitigation equiptment.
The generic ATWS hearings are not an assurance that the Summer Plant will be retro-fitted with ATWS mitigation equiptment. The intervenor's interest in the ATWS question can only be fully protectede by evidenciary hearings by this board.
CONTENTION 4b: The attatched Intervenor FUA's response in opposition to NRC Staff Motion for Sumary Dispot,ition of Contention 4(b) raises issues of material fact that necessitate evidenciary hearings.
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Brett Bursey Intervenor copies to entire service list 8106090 N G
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UNITED STATES OF AMERICA g
N'JCLEAR REGULATORY COW.ISSION
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SOUTH CAROLINA ELECTRIC & GAS Docket No. 50-395 NA U COMPANY Virgil C. Summer Nuclear Station,
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Unit 1
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I CERTIFICATE OF SERVICE I hereby certify that copies of "Intervenor Bursey's Response to Staff Motions For Sumary Disposition of Contentions 2,3 and 4(b), were served on the following persons by deposit in the U.S. Mail on June 2,1981.
Herbert Grossman, Esq., Chairman Steven Goldburg Atomic Safety and Licensing Board Panel Office of the Executive U.S. Nuclear Regulatory Comission Legal Director U.S. Nuclear Regulator Washington, D.C.
20555
- Comission Dr. Frank F. Hooper Washington, D.C. 20555 School of Natural Resources University of Michigan Joseph B. Knotts, Jr.
Ann Arbor, Michigan 48109 Debevoise & Liberman 1200 Seventeenth Street, N.W.
Mr. Gustave A. l'inenberger Washington, D.C.
20036 Atomic Safety and Licensing Board Palel U.S. Nuclear Regulatory Commission Randolph R. Mahan, Esq.
Washington, D.C.
20555
- S.C. Electric & Gas Company P.O. Box 764 George Fischer, Esq.
Columbia, S.C.
29218 Vice President and General Counsel South Carolina Electric and Gas Atomic Safety and Licensing Board C o.npany Panel P.O. Box 764 U.S. Nuclear Reoulatory Commission Columbia, South Caroli.'a 29202 Washington, D.C.
20555 Richard P. Wilson, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General Panel S.C. Attorney General's Office' U.S. Nuclear Regulatory Comission P.O. Box 11549 Washington, 0.r.
20555 Columbia, South Carolina 29211 Docketing and Service Section Mr. John Ruoff Office of the Secretary P.O. Box 96 U.S. Nuclear Regulatory Comission Jenkinsville, S.C.
29065 Washington, D.C.
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NUCLF.AR REGULATORY COMMISSION O
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In the Matter of:
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SOUTH CAROLINA ELECTRIC AND GAS
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Docket No. 50-395 OL
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COMPANY, et al.
May 27, 1981 (Virgil C. Sumer Nuclear Station, j
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Unit 1)
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I, INTERVENOR FUA'S RE500NSE IN OPPOSITION TO l
NRC STAFF MOTION FOR SUPNARY DISPOSITION OF INTERVENOR BRETT A. BURSEY'S CONTENTION 2 Intervenor Fairfield United Action (FUA) hereby opposes the NRC 4
Staff Motion for Sumary Disposition of Intervenor Brett A. Bursey's Contention A2 regarding the financial qualifications of the Applicants safely to operate and dacomission the V.C. Sumer Nuclear Station.
As set forth in the_ a_ttached Statement of Material Facts There is Genuine Issue and affidavit, genuine issues of material fact t
which should lee litigated before the Board exist.
Moreover, Intervenor FUA maintains that further evidence regarding the issues set forth in Contention A2 exis under the control o Applicants, especially more recent financial information on the Applic FUA is thus unable adequately South Carolina Public Service Authority.
to address the genuine issues of material fact on this contention as Consistent they pertain to the Scuth Carolina Public Service Authority.
l with 10 CFR 2.749(c), the enclosed affidavit sus forth those factua FUA urges the Board either to refuse to grant sumary disposition matters.
or to grant FUA a continuance until such time as Applicant South Ca ting data available I
.Public Service Authority makes current financial and opera lO G0WC6Y
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UNITED STATES OF AMERICA I J "~IO
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NUCLEAR REGULATORY COMMISSION t-@
.I juN 4 1981
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COMPANY, et _al.
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Docket No. 50-395 OL
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(Virgil C. Summer Nuclear Station, )
Unit 1)
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May 27, 1981
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l AFFIDAVIT OF JOHN C. RUOFF CONCERNING THE FINANCIAL QUALIFICATIONS OF THE APPLICANTS My name is John C. Ruoff and my professional qualifications can be found in Attachment A.
The purpose of this review is to examine Contention A2 of Intervenor Brett A. Bursey in the above-captioned proceeding:
Contention A2:
a cations necessary)to safely operate and decommission theThe Sumer station in compliance with NRC rules and regulations; b)
The sum allocated by the Applicant for the decommissioning of the Summer Plant is grossly inade-4 quate and does not conform to the requirements of 10 CFR S 50.33(f).
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As part of this review, I have also examined the Applicants' Response to Request for Additional Financial Information (December 31, 1980) and the NRC Staff's Safety Evaiuation Report, Supplement 1, Section 20 (SSER).
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS' :i N
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SOUTH CAROLINA ELECTRIC AND GAS
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Docket No. 50-395 OL COMPANY, et al.
(Virgil C. Summer Nuclear Station, )
May 27, 1981 Unit 1)
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INTERVENOR FUA'S RESPONSE IN OPPOSITION TO NRC STAFF MOTION FOR SUPNARY DISPOSITION OF INTERVENOR BRETT A. BURSEY'S CONTENTION 4b Intervenor Fairfield United Action (FUA) hereby opposes the NRC Staff Motion for Sumary 01sposition of Intervenor Brett A. Bursey's Contention 4b:
The plans for monitoring site seismicity are inadequate in that they do not consider the seismic effect of filling the reservoir.
Monitoring of site seismicity should con-tinue through 1983.
Since the construction pertnit stage, the impacts of reservoir-induced seismicity on the safe operation of the Sumer Station have been of considerable concern. Monitoring of that seismicity has been carried out and continues. The Advisory Comittee on Reactor Safeguards (ACRS) and its consultants reviewed that monitoring program.
18, 1981,M etter report stated that "the Applicant i
l In its March has, at NRC request, agreed to continue seismic monitoring for at least
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the next two years" (emphasis added).
That would take the monitoring program to at least March of 1983.
The ACRS letter report further urges M NRC Staff Motion for Sumary Disposition, at p.16, erroneously dates this letter report as March 18, 1980.
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