ML19262A648
| ML19262A648 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/13/1979 |
| From: | Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | LOUISIANA CONSUMER'S LEAGUE, INC. |
| Shared Package | |
| ML19262A647 | List: |
| References | |
| NUDOCS 7912070248 | |
| Download: ML19262A648 (10) | |
Text
11/13/79 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMTSSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
LOUISIANA POWER AND LIGHT COMPANY
)
Docket No. 50-382
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(Waterford Steam Electric Station,
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Unit 3)
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NRC STAFF INTERR0GATORIE5 T0, AND REQUEST FOR DOCUMENTS FROM, LOUISIANA CLNSUMER'S LEAGUE, INC.
The NRC Staff hereby requests that Louisiana Consumer's League, Inc. (LCL),
pursuant to 10 CFR SG 2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce or make available for inspection and copying, all documentary material identified in the responses to interrogatories below.
As agreed in the
" Stipulation on Discovery Schedule," forwarded to the Board by letter of Septembe r 25, 1979, LCL will have 45 days to respond to the interrogatories.
Each response to the interrogatories below shall be under oath or affirma-tion of the individual (s) who contributed thereto.
For all references requested in these interrogatories, identify them by author, title, date of publication and publisher if the reference is published, and if it is not published, identify the document by the author, title, the date it was written, the qualifications of the author relevant to this proceeding, and where a copy of the document may be obtained.
15i2 006
~7912070E N 1
LCL Contention No. 2_/
2.
The applicant he not demonstrated that it has two independent sources of offsite power and, therefore, will not be in compliance with 10 CFR 50 APP. A Criterion 17. The applicant intends to provide two transmission lines on towers about 100 feet high located 250 feet apart between the proposed facility and a switch-yard through which seven transmission lines pass. About 700 feet from the switchyard is a main line of the Missouri-Pacific Rail-road.
Both transmission lines pass over this railroad about 250 feet apart and 100 feet above.
This is a major line with 18 trains a day averaging 100 cars in length passing under these transmission lines every day.
This railroad serves all chemical plants on the west side of the Mississippi River and commonly carries cargoes which are flammable and/or explosive.
Pas. acci-dents in the area have involved five or more railroad cars, a distance easily sufficient to impact both proposed transmission lines.
In addition, the applicant's switching station is unpro-tected and located in an area which could easily be impacted by railroad accidents.
2-1 a.
Upon what person or persons do you rely to substantiate your case on Contention 2?
1]
The numbering and wording of the contentions stated in these inter-rogatories cos forms to that accepted by the Atomic Safety and Licensing Board in its.'icmorandum and Order dated September 12, 1979.
1522 007 b.
Provide the addresses and education and professional qualifica-tions of any persons named in your responses to a. above.
c.
Identify which of the above persons you intend to call as wit-nesses on this contention.
2-2.
Provide summaries of the views, positions or proposed testimony on Contention No. 2 of all persons named in response to interroga-tory 2-1, that you intend to present during this proceeding.
2-3.
Identify all documentary or other material that you intend to use during this proceeding to support this contention and that you intend to effer as exhibits on this contention or refer to during your cross-examination of witnesses presented cy Applicant and/or the NRC Staff.
2-4.
Identify all documentary or other infonnation which supports the following lar.guage in the second half of the Sixth sentence of Contention 2:
"... and commonly carries cargoes which are flammable and/or explosive."
2-5. Describe in detail (noting all assumptions and bases for any assumptions) the " impact [on] both proposed transmission lines" noted in the seventh sentence cf Contention 2.
1522 003 2-6. Provide all assumptions and bases for the following statement:
... the applicants switching station is unprotected and located in an area which could easily be impacted by railroad accidents."
LCL Contention No. 3 3.
The applicant has not demonstrated that it can control activities in the exclusion area as is required by 10 CFR 100.3 in that:
a.
It cannot control oil and gas drilling activity in the Mississippi River.
b.
It cannot control surface activities on the Mississippi River.
Its agreement with the U.S. Coast Guard leaves the detemination of the method and extent of control to be exercised to that agency.
c.
The statutory authority relied upon by the U.S. Coast Guard in its agreement with the applicant applies only to hazards to vessels and could not be used to control activities not related to vessels.
d.
Under Louisiana law, the applicant cannot deny use of the banks of the Mississippi River that are within the exclusion area for purposes incidental to the navigable character of the waterway.
3-1 a.
Upon what person or persons do you rely to substantiate your case on Contention 3?
b.
Provide the addresses and education and professional qualifica-tions of any persons named in your response to a. above.
c.
Identify which of the above persons you intend to call as wit-nesses on this contention.
1522 009
. 3-2.
Provide summaries of the views, positions or proposed testimony on Contention No. 3 of all persons named in response to Interroga-tory 1-1, that you intend to present during this proceeding.
3-3.
State the specific bases and references upon which the persons in Interrogatory 3-1 rely to substantiate their views regarding Contention 3.
3-4.
Explain in detail the type and location of oil and gas drilling activity in the Mississippi River which would prohibit the Appli-cant from making an appropriate demonstration that it can control activities in the exclusion area as is required by 10 CFR 100.3.
3-5.
Specifically detail how the activities set forth in interroga-tory 3-4 above would prohibit the Applicant from demonstrating that it can control activities in the exclusion area as is required by 10 CrR 100.3.
3-6.
With regard to Contention 3B, what specific " control of surface activities" are you referring to.
Identify the specific language in the agreement between the Applicant and the U.S. Coast Guard which causes you to believe that the Applicant will not be able to demonstrate that it can control activities in the exclusion area as is required by 10 CFR 100.3.
1522 070 3-7.
Identify the specific statutory authority (section(s) and language) you reference in Contention 3C.
Identify the specific authority (section(s) and language) of Louisiana law that you reference in Contention 3D.
3-8.
Identify all documentary or other material that you intend to use during this proceeding to support this contention and that you intend to offer as er.hibits on this contention or refer to during your cross-examination of witnesses presented by the Applicant and/or the NRC Staff.
LCL Contention No. 4 4.
The applicant has not provided an adequate emergency plan in that:
a.
The State of Louisiana's emergency plan is not in final form.
b.
No provisions have been made for evacuating the low population zone particularly with regard to poor persons and the aged and/or infim.
4-1 a.
Upon what person or persons do you rely to substantiate your case on Contention 4?
b.
Provide the addresses, education and professional qualifications of any persons named in response to a. above.
c.
Identify which of the above persons you intend to call as witnesses on this contention.
1522 071 4-2.
Provide summaries of the views, positions or proposed testimony on Contention No. 4 of all persons named in response to Interroga-tory 4-1, that you intend to present during this proceeding.
4-3.
Indicate what provisions must be set forth in the State of Louisiana's emergency plan to enable the Applicar.t to satisfy the Commission's statutory and regulatory requirements with regard to emergency plcnning.
4-4.
Indicate the basis for your response to Interrogatory 4-3.
4-5.
Indicate the provisions of the State of Louisiana's law that require the State of Louisiana's emergency plan to be in final form prior to issuance of an NRC operating license.
4-6.
Indicate the emergency plan provisions that you believe are necessary with regard to the evacuation of the low population zone particularly with regard to poor persons and the aged and/or infirm.
Indicate the bases (both legal and technical) for your belief that each provision is required.
4-7.
Identify all documentary or other material that you intend to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or refer during your 1522 072
cross-examination of witnesses presented by the Applicent and/or the NRC Staff.
LCL Contention No. 6 6.
The applicant has not evaluated the effect of a premature shutdown of the emergency core cooling system due to operator error during a loss of coolant accident, 6-1 a.
On wnat person or persons do you rely to substantiate your case on Contention No. 6?
b.
Provide the addresses, education and professional qualifications of any persons named in your response to a. above.
c.
Identify which of the persons identified in a. you intend to call as witnesses on this contention in this proceeding.
6-2.
Provide summaries of the views, positions, or proposed testimony on Contention No. 6 of all persons named in response to Interroga-tory 6-1 that you intend to present during this proceeding.
6-3.
State the specific basis and provide the analyses, assumptions and references upon which the persons named in response to Interroga-tory 6-1 rely to substantiate their views regarding Contention No. 6.
1522 073
9-6-4.
Identify all documentary or other material you intend to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or refer to during your cross-examination of witnesses presented by the Applicant and/or the NRC Staff.
Respectfully submitted,
-//
/ l l 5-I J,;;.m') /',hzd)'if G He$ry.' McGu rren Counsel for NRC Staff Dated at Bethesda, Maryland this 13th day of November, 1979 1522 074
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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)
LOUISIANA POWER AND LIGHT COMPANY )
Docket No. 50-382
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(Waterford Steam Electric Station, )
Unit 3)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERROGATORIES TO, AND REQUEST FOR DOCUMENTS FROM, SAVE OUR WETLANDS, INC. AND OYSTERSHELL ALLIANCE, INC." and "NRC STAFF INTERROGATORIES T0, AND REQUEST FOR DOCUMENTS FROM, LOUISIANA CON-SUMER'S LEAGUE, INC." in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, d. rough deposit in the Nuclear Regulatory Commission's internal mail system, this 13th day of November,1979:
Sheldon J. Wolfe, Esq., Chairman
- Mr. Luke Fontana Atomic Safety and Licensing Board 824 Esplanade Avenue U.S. Nuclear Regulatory Commission New Orleans, LA 70116 Washington, DC 20555 Mr. M. Stevenson Dr. Walter H. Jordan Monroe & Lemann 881 West Outer Drive 1424 Whitney Building Oak Ridge, TN 37830 New Orleans, LA 70130 Dr. Harry Foreman, Director Atomic Safety and Licensing Board Box 395, Mayo Panel
- University of Minnesota U.S. Nuclear Regulatory Commission Minneapolis, MN 55455 Washirgton, DC 20555 E. Blake, Esq.
Atomic Safety and Licensing Appeal George F. Trowbridge, Esq.
Panel (5)*
Shaw, Pittman, Potts & Trowbridge U.S. lucelar Regulatory Commission 1800 M Street, N.W.
Washirgton, DC 20555 Washington, DC 20036 Docketing and Service Section ( )*
Mr. Stephen M.
Irving Office of the Secretary One American Place, Suite 1601 U.S. Nuclear Regulatory Commission Baton Rouge, LA 70825 Washington, DC 20555 Mr. Lyman L. Jones, Jr.
Suite 910 - Security Homestead Building 4900 Veterans Memoral Blvd.
Metairie, LA 70002 1522 075 e
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t n'nrg pj McGurren e
Counsel for NRC Staff