ML20052D749
| ML20052D749 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/04/1982 |
| From: | Semmel H ANTIOCH SCHOOL OF LAW, WASHINGTON, DC, BIER, MILLS, CHRISTA-MARIA, ET AL |
| To: | |
| Shared Package | |
| ML20052D743 | List: |
| References | |
| ISSUANCES-OLA, NUDOCS 8205070176 | |
| Download: ML20052D749 (5) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Docket No. 50-155-OLA Consumers Power Company (Spent Fuel Pool Modification)
(Big Rock Point Nuclear Power Plant) c l
City of Washington
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District of Columbia)
Herbert Semmel, being duly sworn deposes and says:
i I am counsel for Intervenors Christa-Maria, Mills and Bier in this proceeding.
On or about April 27, 1982, Janice Moore, counsel for staff
.erein, called me and advised me that the Staff had determined it required approximately ten weeks to review certain new material.
This material consisted of:
)
( 1)
Alleged " correction" of errors in materials submitted by Licensee concerning the structural integrity.of the expanded pool at elevated temperatures.
(2)
Additional materials to be supplied by Licensee by May 5, on the1 issue'of a drop'of the spent fuel cask.
s 8205070176 820505 ODR ADOCK 05000155 PDR g
(3)- Additional analysis of the overhead crane, specifically-i whether the_ site conditions at Big Rock Point are sufficiently anomalous to require modification of the generalized soil site specific spectra.
Ms.-Moore stated she expected to file a motion for an indefinite postponement of the hearing.
I told her I would support such a motion as Intervenors wished the Staff to have adequate time to review these new materials and that Intervenors had their own reasons to request a postponement (see below).
On or about August 29, Ms. Moore attempted to reach me by phone, but we were unable to make contact until the morning of I
the following Monday, May 3.
At that time she informed me that the staf f had changed its position and was only requesting a short extension of time to file testimony, to May-21, and i
May 14 respectively on the first two issues and June 25 on the third issue.
This decision had been made the prior week and Ms. Moore explained her efforts to reach me by phone were unsuccessful.
This was due to my absence from my office on othe r business.-
I have been informed by my clients that three physicists are willing to appear as witnesses for Intervenors but cannot do so until September.
Two of these physicists, Dr. Gordon Thompson of the Union of Concerned Scientists and Dr. Marvin Resnikoff of New York City are occupied in June with the.
United Nations Special Session on Disarmanent and events
- relating to the Session.
The Session begins about June 11 and
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and the events several days earlier.
In addition, Professor Mark-Ross of the University of Michigan Physics Department is willing to appear as'a witness for Intervenors but is t
unavailable until September.
Herbert Semmel I.
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Sworn to before me this day of May, 1982.
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i CERTIFICATE OF SERVICE I certify that on the 5th day of May 1981, the above Motions and attached affidavit of Herbert Semmel were served on the attached list by personal delivery at the addresses r
listed or by U.S. mail, first class postage prepaid.
t HERBERT SEMMEL r
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g At -i Safety and Licensing J csp Cs;1c T.nquire E:ard Panel I she-, Linen]n and Beale 3
U.S.
Nuclear Regulatorj 12 2 0 Conne :icutt' Ave, N.W.
Core ssien Suisc 325 Washingten, D.C.
20555 Washington, D.C.
20036
. Esq., Chairman Peter-B..Bloch, 3-Atomic Safety and Licensing W
Board Panel U.S. Nuclear Regulatory
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Commission Washington D.C.
20555 l
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i C-I Dr. Oscar H. Paris Atomic Safety and Licensing l
Board Pane'l U.S. Nuclear Regulatory Docket nc and Service Se ction Commission office of t.he Secretarv Washington D.C.
20555 u,3, g;;3,37 ge g;3,tegj Cornission Mr. Fredrick J. Shon Washington, D.C.
20555 Atomic Safety and Licensing John O'Neill, II Board Panel Reute 2, Box 44 U.S. Nuclear Regulatory Maple City, MI 49664 Commission Washington D.C.
20555 Janice E.
Moore, Esq.
Counsel for NRC Staf f U.S. Nuclear Regulatorf Corrission Washington, D.C.
20555
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