ML20053A495
| ML20053A495 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/21/1982 |
| From: | Gallo J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE |
| To: | Bloch P, Paris O, Shon F Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20053A496 | List: |
| References | |
| ISSUANCES-OLA, NUDOCS 8205260150 | |
| Download: ML20053A495 (4) | |
Text
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e ISHAM, LINCOLN & BEALE CO'JNSELORS AT LAW 1120 CONNECTICUT AVENUE N W = suite 840 WASHINGTON O C 20036 EDWARD $ ISHAM 1872 1902 202 833 9730 CHICAGO OFFICE
,, THREE FIRST NATONAL PLAZA RG2ERT T LINCOLN. 1872-1689
.j May 21, 1982
'Iti' E f*2$ E TELEK.2 5288 Peter B.
Bloch, Esquire Dr. Oscar H.
Paris Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Liccnsing Board Panel Board Panel U.
S.
Nuclear Regulatory U.
S. Nuclear Regulatory Commission Commission Washington, D.
C.
20555 Washington, D. C.
20555 Mr. Frederick J.
Shon Administrative Judge Atomic Safety and Licensing Board Panel U.
S. Nuclear Regulatory Commission i
Washington, D. C.
20555 RE:
In the Matter of Consumers Power Company (Big Rock Point Nuclear Power Plant), Docket No.
50-155-OLA (Spent Fuel Pool Modification)
Gentlemen:
Pursuant to the Order of the Atomic Safety and Licensing Board, I am hereby filing the following testimony which is to be presented in this proceeding at the hearings scheduled to commence on June 7, 1982.
1.
The testimony of Mr. Peter Yanev and Dr. Rolfe Jenkins on O'Neill Contention II.C. as it relates to the issue of the seismic qualifica-tion of the overhead crane located inside the containment building at Big Rock Point is being submitted.
Mr. Yanev's testimony consists of his professional qualifications and two reports.
One report, entitled " Seismic Analysis of the 75-Ton Containment Crane," dated April 14, 1982, l
war sent to the Licensing Board and parties on 5C)3 9 s I
{
8205260jgg >
Peter B.
Block, Esquire l
Dr. Oscar H.
Paris l
Mr. Frederick J. Shon l
May 21, 1982 Page 2 April 15, 1982, and that distribution is not being duplicated here.
The other report, entitled, "On the Performance of Large Gantry and Bridge Cranes in Past Earthquakes," dated May 7, 1982, is enclosed.
No testimony is being submitted on whether "the threading on the fire water system piping is seismically safe, and whether it is necessary for the safety of the enlarged spent fuel pool that 200 gallons per minute of makeup water be available to protect the pool from the conse-quences of a drop of a spent fuel transfer cask."
See page 47 of the Licensing Board's Memorandum and Order (Concerning Motions for Summary Disposition), dated February 19, 1982.
Any testimony on these issues would be im-material and irrelevant due to the fact that the testimony of other Licensee witnesses estab-lishes that neither the spent fuel transfer cask nor the overhead crane will fall into the spent fuel pool.
The question of the seismic qualification of the threaded piping of the fire water system is presently being evaluated by Licensee and the NRC Staff as a part of the NRC's Systematic Evaluation Program.
This general matter is, of course, not at issue in this case.
2.
The testimony of Mr. Raymond Sacramo with re-spect to that aspect of Christa-Maria Contention 8 and O'Neill Contention IIIE-2 concerning the effects of pool boiling on the spent fuel pool concrete, liner and racks is being submitted.
Mr. Sacramo's testimony includes, inter alia, a report entitled, " Structural Analysis of the Spent Fuel Pool Liner and Concrete Due to Coolant System Failure for the Big Rock Point Nuclear Power Plant," Revision 1 to NUS-3567, dated April 27, 1982.
This report was trans-mitted to the Licensing Board and parties as an enclosure to my letter of April 28, 1982, and I
Peter B.
Block, Esquire Dr. Oscar H.
Paris Mr. Frederick J.
Shon May 21, 1982 Page 3 that submission is not being duplicated here.
Licensee intends to also present Dr. Daniel A.
Prelewicz in support of this testimony.
The Licensing Board, in its February 19, 1982, Memorandum and Order (Concerning Motions for Summary Disposition), granted the Licensee's and the NRC Staff's motions on the pool boiling aspect of this issue with exception of the ef-fects of point loading and 247'F on the concrete pool.
Licensee now understands that the NRC Staff is raising additional issues in this matter.
Accordingly, Licensee is withdrawing Mr. Sacramo's affidavit of September 28, 1981.
Instead, Licensee will rely on the enclosed testimony of Mr. Sacramo to meet the issues presented by the Intervenors and the NRC Staff.
3.
The testimony of Lt. Colonel Gary P. Betourne concerning the genuine issues.of fact remaining under O'Neill Contention II.D. as they relate to the matter of USAF B-52 flights is being sub-mitted.
Colonel Betourne's testimony includes his deposition on this issue which was trans-mitted to the Licensing Board and parties as a part of Licensee's October 5, 1981, Motion for Summary Disposition, and that submission is not being duplicated here.
Licensee is also exploring the possibility of providing a witness from the Bayshore radar site.
If the Air Force agrees to make such a witness available, no new testimony will be presented.
Any such witness would merely support the testimony already submitted by Colonel Betourne.
The Licensing Board requested, at pages 42-43 of its February 19, 1982 Memorandum and Order (Concerning Motions For Summary Disposition), further information concerning Licensee's interaction with insurers.
The affidavit of Mr.
J.
D.
Cooper is being provided along with relevant correspondence in re-sponse to this request.
J
Peter B.
Block, Esquire Dr. Oscar H. Paris Mr. Frederick J.
Shon May 21, 1982 Page 4 This filing completes the testimony on Licensee's direct case.
Licensee, of course, expects to file rebuttal testimony during the course of the upcoming hearings.
Sincerely, 0
-b
/os:ep=r J
h Gallo Enclosure JG/pm cc:
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