ML19294B081

Interrogatories Re Joint Intervenors 791210 TMI-2 Related Amended Contentions,Per 790925 Stipulation.Requests Info on Free Hydrogen Estimate During Emergency & on FSAR Provisions Re Accumulation of Hydrogen.W/Certificate of Svc

ML19294B081
Person / Time
Site:	Waterford
Issue date:	02/19/1980
From:	Blake E, Glasspiegel H LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
References
NUDOCS 8002270102
Download: ML19294B081 (5)

Text

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February 19, 1980 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 INTERROGATORIES ON TMI-2 RELATED CONTENTIONS OF JOINT INTERVENORS On December 10, 1979, the Joint Intervenors amended their contentions by filing six TMI-2 related contentions. By Order dated January 11, 1980, the Licensing Board admitted the addi-tional contentions. Applicant's interrogatories on the addi-tional TMI-2 contentions are submitted herewith, pursuant to the terms of the September 25, 1979 Stipulation on Discovery Schedule, which was approved by the Licensing Board on September 28, 1979.

Under 10 C.F.R. Section 2.740b, these interrogatories are to be answered separately and fully in writing and under oath or affirmation. Answers must be served on all parties and the Licensing Board. As agreed in the Stipulation, Inter-venors have thirty (30) days to respond to this request, and fifte.en (15) days to file objections to any interrogatory herein. 8003270lQ

2-For each interrogatory set forth below, in addition to supplying a direct answer to the question, provide (1) the identity and location of persons having knowledge of discover-able matters pertaining to the question; (2) the identity of each person expected to be called as an expert witness at the hearing, the subject matter on which he or she is expected to testify, and the substance of his or her testimony; and (3) the titles, dates and authors of all documents on which Intervenors' direct answer to the question is based, including citations to the section numbers and pages containing information relied on by Intervenors.

Interrogatories for Joint Intervenors' Contention 28 Interrogatory No. 28-1 What specific quantity of free hydrogen do you expect to form in the primary system of the Waterford plant during a Nuclear Emergency? Provide the basis for your estimate of free hydrogen, including all necessary reactor conditions and the mechanism for creation and accumulation of such estimate of free hydrogen.

Interrogatory No. 28-2 What amount of hydrogen do you believe constitutes " danger-ous quantities," as that term is used in Contention 28? Describe

in detail the mechanism by which Joint Intervenors contend that such " dangerous quantities" will be produced and accumulated?

Interrogatory No. 28-3 Does Section 6.2.5 of the Final Safety Analysis Report for Waterford 3 provide adequate plans which demonstrate how Applicant will alleviate the accumulation of dangerous quanti-ties of hydrogen within the containment? If your answer is other than an unqualified "yes," fully explain the basis for the answer.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: gt424f . Jd Erne f L. Blake, J f. 4/

Har H. Glasspiegel Co sel for Applicants 1800 M Street, N.W.

Washington, D.C. 20036 (202) 331-4100 Da ted: February 19, 1980

February 19, 1980 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 the foregoing document, entitled " Applicant's Interrogatories on TMI-2 Related Con-tentions of Joint Intervenors" were served on those persons listed on the attached Service List by deposit in the United States mail, first class, postage prepaid, this 19th day of February, 1980.

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shy Larry H' Glasspiegell Counse for Applicant Dated: February 19, 1980

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 Metairie, Louisiana 70005 Commission 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 Atomic Safety and Licensing 881 West Outer Drive Board Panel Oak Ridge, Tennessee 37830 U.S. Nuclear Regulatory Henry J. McGurren, Esquire Commission Washington, D.C. 20555 Office of the Executive Legal Director Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Panel 20555 U.S. Nuclear Regulatory .

Washington, D.C.

Commission Washington, D.C. 20555 Docketing and Service Section (21)

Office of the Secretary -

U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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