ML20062G199

Intervenor Response to NRC Staff Motion for Summary Disposition.Intervenor Bursey Points Out Discrepancies Surrounding Contention A-6 & A-7;asserts That Matl Issues of Fact Exist for Bd'S Consideration.Cert of Svc Encl

ML20062G199
Person / Time
Site:	Summer
Issue date:	11/22/1978
From:	Bursey B External Citizen/Individual/Media (Affiliation Not Assigned)
To:
References
NUDOCS 7812270139
Download: ML20062G199 (2)

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NUCLEAx REC /JLATORY COMMISSION nELATED C010ge%DM 11/22/78 6 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 8 4$$ '

In the Matter of ) 7LA d;hg~

) '3 SOUTH CAROLINA ELECTRIC & GAS C0. ) h Docket No. 50-395 q

" I (Virgil C. Summer Nuclear Station )

Unit No.1) )

INTERVENOR RESPONSE TO NRC STAFF MOTION FOR

SUMMARY

DISPOSITION OF CONTEN In regards to both contentions A-6 and A-7, the intervenor asserts that there are genuine issues of material fact yet to be determined in the applicants ability to mitigate accidents that could result in the release of radioactivity above pennissible levels .into the Broad River. The applicant's emergency I

O apparatus (designed to mitigate the severity of accidents) within the reactor containment, has never been tested under stress conditions. Some calculations '

used to detennine a design basis event in the applicant's FSAR have proven erroneous. In September, 1978, there was an earthquake at the Summer Site that j

was below the projected ,maximam intensity, but surpassed the maximum projected ground acceleration anticipated by the applicant. The ability of tanks to with-I

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stand earthquakes (see section 3 of the staff motion to dismiss, page.14),must be re-evaluated.

(.'> In regards to contention A-6, the discrepancy in the temperature of effluents .

being returned to natural waters must be further explored. The applicanfs original figures of 4.3 degrees above ambient for returning efflu.ents ha's been lowered to 3.0 to coincide with state requirements. The applicant has not demonstrated what different means will be employed to reduce the temperaturc effluents to meet the NPDES permit stipulations. Until this discrepancy is clarified, conten-ion A-6 sh]uld be retained for consi.f= ration by the board.

Respectfully submitted, O

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Brett Bursey 7 8 1 2 2 7 0 l'5 \

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UNITED STATES OF AMERICA 4gDN NUCLEAR REGULATORY COMMISSION .

In the Matter of )

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SOUTH CAROLINA ELECTRIC & ) Docket No. 50-395 g @, f GAS COMPANY, et al. )

(Virgil C. Summer Nuclear ) o -

Station) )

, y gg C CERTIFICATE OF SERVICE

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O Q A I herby certify that copies of "INTERVENOR RESPONSE TO NRC STAFF M D FOR E

SUMMARY

DISPOSITION OF CONTENTIONS", dated November 22, 1978, in the i @

matter, have been served upon the following by deposit in the United States Mcil this 22nd day of November,1978:

Ivan W. Smith, Esq.

George Fischer, Esq.

Chairmar., Atomic Safety and Vice President and General V Licensing Board U. S. Nuclear Regulatory . Counsel Commission South Ca'rolina Electric & Gas Company Washington, D. C. 20555 Post Office Box 764 Columbia, South Carolina 29202 Dr. Frank F. Hooper Member, University of Steven C. Goldberg, Esq.

Michigan Camp Filibert Roth Office of-the Executive Legal Director Iron River, Michigan 49335 U. S. Nuclear Regulatory Commission Mr. Gustave A. Linenberger Washington, D. C. 20555-Member, Atomic Safety and Licensing Board Panel Mr. Brett Allen Bursey U. S. Nuclear Regulatory Route 1, Box 93-C Commission Little Mountain, South Carolin Washington, D. C. 20555

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29075 Chairman, Atomic Safety and Mr. Chase R. Stephens Licensing Appeal Board Panel Docketing and Service Sec. tion U. S. Nuclear Regulatory Office of the Secretary

• Commission U. S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C. 20555 Chairman, Atomic Safety and Licensing Board Panel O. S. Nuclear Regulatory Richard P. Wilson, Esq.

Commission Assistant Attorney General Washing ton, D. S.C. Attorney General's Office C. 20555 P. O. Box 11549 Columbia, S.C. 29211 D

b ._ d mbw-cq Brett Bursey