ML20062G199
| 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) | |
Text
I M
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W NUCLEAx REC /JLATORY COMMISSION
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nELATED C010ge%DM 6
11/22/78 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 8
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7 In the Matter of
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)
'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 O
apparatus (designed to mitigate the severity of accidents) within the reactor I
containment, has never been tested under stress conditions.
Some calculations '
used to detennine a design basis event in the applicant's FSAR have proven In September, 1978, there was an earthquake at the Summer Site that erroneous.
was below the projected,maximam intensity, but surpassed the maximum projected j
I ground acceleration anticipated by the applicant.
The ability of tanks to with-
~
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 h 'CC w%
Brett Bursey 7 8 1 2 2 7 0 l'5 \\
G
l 40 i,
UNITED STATES OF AMERICA
, T NUCLEAR REGULATORY COMMISSION 4gD N
In the Matter of
)
)
SOUTH CAROLINA ELECTRIC &
)
Docket No. 50-395 g @, f GAS COMPANY, et al.
)
(Virgil C. Summer Nuclear
)
o Station)
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CERTIFICATE OF SERVICE O Q
~
A D
I herby certify that copies of "INTERVENOR RESPONSE TO NRC STAFF M E
FOR
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
. Counsel U. S. Nuclear Regulatory South Ca'rolina Electric & Gas Commission 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 Office of-the Executive Legal Camp Filibert Roth 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 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 Richard P. Wilson, Esq.
O.
S. Nuclear Regulatory Assistant Attorney General Commission S.C. Attorney General's Office Washing ton, D.
C.
20555 P.
O. Box 11549
- Columbia, S.C.
29211 Db._ d mbw-cq Brett Bursey
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