ML19211C655

Response to 791210 Joint Intervenors Save Our Wetlands & Oystershell Alliance Addl TMI-related Contentions.Reserves Right to Strike Contention 28 Challenging NRC Criteria for Eccs.Certificate of Svc Encl

ML19211C655
Person / Time
Site:	Waterford
Issue date:	12/26/1979
From:	Trowbridge G LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8001140112
Download: ML19211C655 (4)

Text

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_Dec_ ember 26, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

)

(Waterford Steam Electric Station, )

Unit 3) )

APPLICANT'S RESPONSE TO JOINT INTERVENORS' ADDITIONAL CONTENTIONS On December 10, 1979, Joint Intervenors Save our Wetlands, Inc. and Oystershell Alliance, Inc. filed additional TMI-related contentions numbered 24 through 29. Applicant has no present objection to these additional contentions but reserves the right at a later date to move to strike Contention 28 in whole or in part on either of the following grounds.

First, to the extent it may appear in the course of dis-covery or otherwise that subpart (a) of Contention 28 challenges the adequacy of NRC's acceptance criteria for emergency core cooling systems (as opposed to Applicant's compliance with such criteria) as contained in 10 CFR 50.46, Applicant will oppose subpart (a) as an attack on NRC regulations.

Second, to the extent it may appear in the course of dis-covery or otherwise that subpart (b) of Contention 28 challenges the adequacy of the Commission's criteria for post-accident hydro-gen control (as opposed to Applicant's compliance with such cri-teria) as contained in 10 CFR 50.44, Applicant will oppose subpart 1743 186 g o,,1 g o f/ g G-

(b) as an attack on NRC regulations. Applicant is aware that the Final Report of the Lessons Learned Task Force (pp. 3-6 and A-14,

15) recommends a new rulemaking proceeding which, among other things, would re-examine hydrogen control measures. If the Com-mission adopts this recommendation, Applicant believes that the rulemaking proceeding rather than this hearing should be the forum for resolution of this generic item.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By h * , M ,,

"VGeope 'F.

Tfowbridge [

Dated: December 26, 1979 1743 187

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

)

(Waterford Steam Electric Station, )

Unit 3) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Response to Joint Intervenors' Additional Contentions," dated December 26, 1979, were served upon those persons on the attached Service List by deposit in the United States Mail, postage prepaid, this 26th day of December, 1979.

M ,/ - /

Q Geo[ge P. Tiowbridge /

Dated: December 26, 1979 1743 188

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the' Matter of )

)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

)

(Waterford Steam Electric Station, )

Unit 3) ) .

~

SERVICE LIST Sheldon J. Wolfe, Esquire Lyman L. Jones, Jr., Esquire Chairman, Atomic Safety and Gillespie'&: Jones Licensing Board Suite 201 U.S. Nuclear Regulatory 1420 Veterans Memorial Boulevard Commission Metairie, Louisiana 70005 Washington, D.C. 20555

Stephen M. Irving, Esquire Dr. Harry Foreman Suite 1601 Director, Center for Popula- One American Plaza tion Studies Baton Rouge, Louisiana 70825

' Box 395, Mayo University of Minnesota Luke B. Fontana Minneapolis, Minnesota 55455 824 Esplanade Avenue New Orleans, Louisiana 70116 Dr. Walter H. Jordan 881 West Outer Drive Atomic Safety and Licensing Oak Ridge, Tennessee 37830 Board Panel U.S. Nuclear Regulatory Henry J. McGarren, Esquire Commission Offi:e of the Executive Legal Washington, D.C. 20555 Director U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Appeal Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Docketing and Service Section (21) Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory -

Commission Washington, D.C. 20555 1743 189

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