ML20033C054
| ML20033C054 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 11/20/1981 |
| From: | Oneill J O'NEILL, J. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20033C047 | List: |
| References | |
| NUDOCS 8112020613 | |
| Download: ML20033C054 (2) | |
Text
r UNITED STATES CF AMERICA J
NUCIEAR REGULATORY COMMISSICN JETEL SFORE THE ATOMIC SAFETY AND LICENSING BOARD
'Nr WfQ In the Matter of CONSUMERS F0WER CCMPANY Docket # 50-155 81 NOV 25 P3:10 (Big Rock Point)
(Snent
.al Pool Exnansion)
L C;kE TA F Y 0 & SEP.WCE Intervenor O'Neill's Resconse to Motions for Summar RD'iCdnosition and Motion in Sup, ort of Christa-Maria's Motion te Amend Defense of Contention TI D of O'Neill The crash of a B-52 bomber must be e::amined because the.,onnequencer would be disastrous, t.
A B52 crash would breach containment.
Neither Consumers nor NRC Staff dispute this.
2.- iA B52 crashed within one mile of Big Rock Power Station in 19 71, killing all aboard.
This is not disputed.
The danger of a collision is real.
3.
Summary disposition motions are based solely upon discussions of robability. of_a bomber crash.
4 Ti's risk may now be greater due to the use of military air traffi-.
ontrollers to replace fired civilian controlers.
Training o; ir controllers is a lagthy process, so the increased risk is lasc ng.
This is not discussed in the summary disposition motions.
5 When the consequences of an accident are so great, it is not valid to dismiss the danger on the basis of project edflow. risk.
This was tragically denonstrated by the Three Mile Island accidents Class 9 accidents were not er.amined.because they were considered im ossible.
B16 Rock is not protected againht the crash of a B52 Bomber.
Contention II D should be examined in the hearing to protect the
,the public safety.
Other Contentions I sunport the arguments made by Christa-Xaria et al against summary disposition.
0112O20613 811120 PDR ADOCK 05000155 G
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2.
'81 NOV 15 P2:47 Motion to Amend Contention II D of O'Neill
... H D n 0 lr * '
In admitting Contention IID the Board recognized;iRd'\\,(F o'o t ent i a l danger of a B52 Bomber crash breiching containiant.
Which is the ir.portant 'oint, the particular aircruft crashing or the breach of containment?
The breach of containment is obviously the concern.
There are many other airplane that would crack the dome if they were to crash into it.
These must be examined.
The Board at the Special Frehearing Conference expressed itz willingness to at any time examine real safety problems.
Planen that pose this real safety hazard include civilian airliners and the jets of the Chio National Guard.
This oxpanded contention must also be understood to include an examination of planes crashing into the control room buildinF.,
which is not hardened, and consequently causing an accident that would breach containment.
Such an accident could be caused by a light plane.
There are no restrictions to civilian air traffic over theplant.
The danger of such a collis$on, causing dama6e to the dome or the vulnerable control room, is demonstrated by an incident on May h, 1990.
The Concerned Gitizens for the Charlevoix Area were exercising their constitutional right to assembly just outside the plant grounds, at the junction of the highway and the plant access road.
A red biplane b 1zzed the group and performed acrobatic maneuvers above our heads.
We did not find this display of irresponsible airmanship so close to a nuclear power plant comforting, yet the pilot violated no airspace sanctions because non exist.fThat plane could have crashed into the control room building, causing an accident that would have breached containment.
This possibility is not addressed by the utility nor the NRC Staff in motions for summary disposition.
This danger must be considered.
Respectfully submitted, s(,
I G/
u,.
John O'Neill Intervenor pro se 30uto 2, Box LE T.nnle City, Michigan Lc6(4