ML19262B508

Objections to Joint Intervenors' 791123 Interrogatories Re Contentions 8,9,21 & 22.Interrogatories Vague.Info Is Equally Accessible to Intervenors.Info Requested Outside Scope of Contentions.Certificate of Svc Encl

ML19262B508
Person / Time
Site:	Waterford
Issue date:	12/06/1979
From:	Trowbridge G LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 7912280140
Download: ML19262B508 (4)

Text

December 6, 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 OBJECTIONS TO CERTAIN OF JOINT INTERVENORS' INTERROGATORIES On November 23, 1979, Joint Intervenors Oystershell Alliance, Inc. and Save Our Wetlands, Inc. submitted interrog-

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atories to Applicant. By agreement of counsel reflected in a letter dated November 29, 1979, from counsel for Applicant to counsel for Joint Intervenors, the schedule for answers and objections to some of the interrogatories has been deferred.

Applicant submits herewith its objections to certain of the remaining interrogatories.

Interrogatories for Contention 8/9. A large number of these interrogatories, dealing with the cumulative or syn-ergistic effects of low level radiation and other environmental pollutants, call for research, studies, investigations and cal-culations in order to provide information which Applicant does nct have and which Applicant does not plan to obtain in develop-ing its own case on Contention 8/9. The sources of information, 1648 304 79122p0

to the extent they exist, are equally accessible to Joint Intervenors. Applicant therefore objects to the interroga=

tories to the extent that the information requested involves such research, studies, investigations or calculations. To the extent that Applicant may already have in its possession information responsive to the interrogatories, or can readily compile such information from available data in its posses-sion, the requested information will be supplied.

Applicant further objects to Interrogatory 8/9-17 on the ground that it is not possible to discern from the in-terrogatory the information requested by Joint Intervenors.

Interrogatories for Contention 21. Applicant ob-jects to Interrogatory 21 4 as outside the scope of the con-tention.

Interrogatories for Contention 22. Applicant objects to Interrogatories 22-4, 22-5, 22-7 and 22-8 as outside the scope of the contention.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By A/ 'a h s

'V George F. Trowbridge [

Dated: December 6, 1979 1648 305 December 6, 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) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Objec-tions to Certain of Joint Intervenors' Interrogatories,"

dated December 6, 1979, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 6th day of December, 1979.

/ -

Y m.AL horge F. bowbridge  !

Dated: December 6, 1979 1648 306

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.

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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. McGurren, Esquire Commission Office 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 1648 307