ML20028E320

Motion to Strike Proferred Testimony of Witness DC Bley on Contention 2.2(a) Re Use of Brackish Water Inside Containment.Subj Testimony Discusses Probability Issue Concerning Improvements to Containment Drainage Sys

ML20028E320
Person / Time
Site:	Indian Point
Issue date:	01/18/1983
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8301210219
Download: ML20028E320 (2)

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

I ATOMIC SAFETY AND LICENSING BOMD 1 Administrative Judges:

James Gleason, Chairman 83 JN:20 R0$

Dr. Oscar H. Paris In the Matter of Frederick 3. Shon .

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H CONSOI.IDATED EDISON COMPANY OF NEW YORK . Doc'ket Nos. 50-247-SP (Indian Point, Unit 2) 50-236-SP POWER AUTHORITY OF THE STATE OF NEW YORK January 18, 1983 (Indian Point, Unit 3)

WEST BRANCH CONSERVATION ASSOCIATION'S MOTION TO STRIKE THE PROFFERED TESTIMONY 9E_EllEEEE_EEEEIE_9 _ ppg!_gg_ggEJggIlgy_2 2a The assessment of improvements to the containment drainage systems was removed from review in these cases by November 15 Order, pagc 13, of the Atomic Safety and Licensing Board when it deleted WBCA's contention 2.2(d).

Therefore WBCA has had no opportunity to discuss the im- , ,

provements in sumps 7-controls,'etc'. ...

listed in the Direc-r tor's Order of Februar'y 11, 1980; .iahdi the flood at In-

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dianPointUnit#2knOctober1980; or to present other  :*

failure modes that h' ave not been considered.

Under contention 2.2(a).the question is whether brackish water, because of its corrosive properties, should or should not be used inside containment.

for West Branch Conservation Association 443 Buena Vista Road ),

New City, N.Y. -

914/634-2327 by Z$p,po, rah S. Fleisher 8301210219 830118 Secretary PDR ADOCK 05000247 G PDR S,'o

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.The proferred testimony simply discusses the proba-bility issue regarding the improvements.

WBCA made exactly this distinction when it asked for 2.2(d) and was told it would not serve a useful purpose to enter into the broad subject of quality control and in-spection procedures. .

2.2(a) concerns itself with corrosion and the quality of Hudson River water not with the probability of several types of flooding.

Because witness Bley's testimony as proferred is not to the subject of 2.2(a) as defined by the ASLB, WBCA moves that it not be admitted,.- - " ~ -

(Although Licensee's testimony was due in hand on January 12 for 2.2(a) WBCA did not receive it from Coned until January 14, Bley, we read.it an.the 15th, a i Saturday,and submit this paper the first working day thereafter, the 17th.) .

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