ML20028E858
| ML20028E858 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/24/1983 |
| From: | Steptoe P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE |
| To: | Bechhoefer C, Cowan F, Harbour J Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20028E859 | List: |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8301280240 | |
| Download: ML20028E858 (4) | |
Text
- "
NTED CORRE.SPONDENCR 00tHETED ISHAM, LINCOLN & BEALE "C COUNSELORS AT LAW
'33 .!"! 27 Pi :11 THatE FmST NATIONAL PLAZA CHICAGO. ILUNotS toget
' wASHmGTON OFFICE RT T L C N. I EX. t wum s s Au. i.872,..e ""co""Eig,gewue.w w wAsHagTge ==
January 24, 1983 In the Matter of )
) Docket hos. 50-329-OM CONSUMERS POWER COMPANY ) 50-330-OM
) 50-329-OL (Midland Plant, Units 1 ) 50-330-OL and 2) )
Charles Bechhoefer, Esq. Dr. Jerry Harbour Atomic Safety & Licensing Atomic Safety & Licensing Board Panel Board Panel U.S. Nuclear Regulatory Com- U.S. Nuclear Regulatory Com-mission mission Washington, D. C. 20555 Washington, D. C. 20555 Dr. Frederick P. Cowan 6152 N. Verde Trail Apt. B-125 Boca Raton, Florida 33433
Dear Administrative Judges:
Enclosed is the testimony of Dr. Palanichamy Shunmugavel concerning the effect of seismic shakedown on the Auxiliary Building and his testimony concerning buried Category I duct banks at the Midland site. The former testimony is relevant to Stamiris contentions 4 (C) and 4 (D) and Sinclair contention 24; the duct bank (conduit) testimony is relevant to Stamiris contentions 4 (A) (4) , 4 (C) (f) and Warren contention 3.
Applicant is also filing today by separate mailing l its water hemmer testimony addressing Sinclair Operating License Contention 3.
In its Memorandum and Order dated December 30, 1982-the Licensing Board requested the Staff and the Applicant to file briefs with respect to the relevance of certain 7
Licensee Event Reports which Ms. Sinclair proposed as a basis for her station blackout contention, Sinclair O.L. contention
- 11. The Board was particularly interested in the similarities 9301290240 830124 PDR ADOCK 05000329 ^
T PDR
(
, F(Q)
~
r Administrative Judges January 24, 1983 Page 2 if any between the diesel generators at Midland and the diesel generators at the other reactors where these LERs occurred. Unfortunately, although we understand the Board's question, we are unable to answer it. Applicant has been able to ascertain that the diesel generators at the other reactors are not the same type as those at Midland (in fact one of the other plants has no diesel generators) but we don't know enough about the other plants' diesel generators at the present time to be able to address whether the differences are significant for purposes of Sinclair con-tention 11 and the LERs Ms. Sinclair relies on. The NRC Staff, having recently completed a thorough survey of diesel generator reliability, may have much more information on the subject than we do, particularly with respect to other plants. Therefore, for purposes of determining whether Ms. Sinclair has proposed an acceptable further basis for contention 11, Applicant must defer to the NRC Staff.
During the November and December, 1982 hearings, Applicant agreed to provide certain information to the Board and other parties; for example, we agreed to provide lists of Category I structures not included in the Seismic Margin RevJew program (Tr. 9720) and lists of underground pipe and us.tlities hit by drilling (Tr. 10137) . We are completing gathering this information and we should be able to send almost all of it out in the coming week. In addition, we anticipate filing transcript corrections for the November-December hearings in the next week.
Respectfu y itt ,
[V t, .A L/ !Af Philip P. Stgptoe~, f One of the AEtorneys for Consumers Power Company cc Service List Isham, Lincoln & Beale 3 First National Plaza Chicago, Illinois 60602 (312) 558-7500
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of Doc.ket Nos. 50-329 OM 50-330 OM CONSUMERS POWER COMPANY Docket Nos. 50-329 OL (Midland Plant Units 1 and 2) 50-330 OL CERTIFICATE OF SERVICE I hereby certify that copies of the " Testimony of Dr. Palanichamy Shunmugavel on Behalf of the Applicant Regarding Structural Evaluation of the Auxiliary Building for Seismic Shakedown Settlement at the Midland Site" and the " Testimony of Dr. Palanichamy Shunmugavel on Behalf of the Applicant Regarding Seismic Category I Duct Banks at the Midland Site" were served on the persons shown in the attached service list by deposit in the U.S. Mail, postage prepaid, this h day of a ary, 1983.
h f i 1
U
% w PhiINteptop l
i l
SERVICE LIST Frank J. Kelley, Esq. Steve Gadler, Esq. i Attorney General of the 2120 Carter Avenue State of Michigan St. Paul, Minnesota 55108 Carole Steinberg, Esq.
Assistant Attorney General Atomic Safety & Licensing Environmental Protection Div. Appeal Panel 720 Law Building U.S. Nuclear Regulatory Comm.
Lansing, Michigan 48913 Washington, D. C. 20555 Myron M. Cherry, Esq. Mr. C. R. Stephens Cherry & Flynn Chief, Dock.eting & Services Suite 3700 U.S. Nuclear Regulatory Comm.
Three First National Plaza Office of the Secretary Chicago, Illinois 60602 Washington, D. C. 20555 Mr. Wendell H. Marshall Ms. Mary Sinclair 4625 S. Saginaw Road 5711 Summerset Street Midland, Michigan 48640 Midland, Michigan 48640 Charles Bechhoefer, Esq. William D. Paton, Esq.
Atomic Safety & Licensing Counsel for the NRC Staff Board Panel U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Comm. Washington, D. C. 20555 Washington, D. C. 20555 Atomic Safety & Licensing Dr. Frederick P. Cowan Board Panel 6152 N. Verde Trail U.S. Nuclear Regulatory Comm.
Apt. B-125 Washington, D. C. 20555 Boca Raton, Florida 33433 Ms. Barbara Stamiris 5795 North River Road Mr. D. F. Judd Route 3 Babcock & Wilcox Freeland, Michigan 48623 P. O. Box 1260 Lynchburg, Virginia 24505 Dr. Jerry Harbour Atomic Safety & Licensing James E. Brunner, Esq. Board Panel Consumers Power Company U.S. Nuclear Regulatory Comm.
212 West Michigan Avenue Washington, D. C. 20555 Jackson, Michigan 49201 Lee L. Bishop, Esq.
Harmon & Weiss 1725 "I" Street N.W. 9506 Washington, D. C. 20006