ML19294B081
| 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
..
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 8003270lQ herein.
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.
e sh
%/
/
Larry H' Glasspiegell y
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 Suite 201 Licensing Board 1420 Veterans Memorial Boulevard U.S. Nuclear Regulatory Commission Metairie, Louisiana 70005 Washington, D.C.
20555 Stephen M.
Irving, Esquire Suite 1601 Dr. Harry Foreman Director, Center for Popula-One American Plaza Baton Rouge, Louisiana 70825 tion Studies
' Box 395, Mayo Luke B.
Fontana University of Minnesota 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 Atomic Safety and Licensing U.S. Nuclear Regulatory Appeal Board Panel Commission 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
.