ML19296B991
| ML19296B991 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/19/1980 |
| From: | Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | LOUISIANA CONSUMER'S LEAGUE, INC. |
| Shared Package | |
| ML19296B988 | List: |
| References | |
| NUDOCS 8002250013 | |
| Download: ML19296B991 (4) | |
Text
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Interrogatorv on Contention 251/
1.
Provide the bases for Contention 25e and indicate with bases the degree of fuel melting that requires taking remedial action.
Interrogatories on Contention 27 2.
Define what you mean by " Nuclear Emergency" as this term is used in-Con-tention 27.
3.
Identify the radiation monitoring, referenced in Contention 27, that you believe to be " adequate" during each " Nuclear Emergency" identified in your response to Interrogatory 2, above.
4 Define for each "Suclear Emergency" the specific " areas surrounding the facility which would be affected " giving for each such designated area the bases for its specific designation.
Interrocatorv on Contention 29 5.
Specifically identify the "NRC-mandated TMI-based changes" that you reference in Contention 29.
'Interrocatorv on Contentions 24 throuch 29 6.
a.
Upon what person or persons do you rely to substantiate your case on Contentions 24 through 29?
Indicate for each person identified, the specific contention that person is being relied upon to substantiate.
1-
~he numbering ef the contentions stated in these interrogatories conforms te that accepted by the Atomic Safety and Licensing Board in its Order dtted January 11. 1980.
8002250 (3)
I
- b.
Provide the addresses and educational and professional qualifica-tions of any persons named in your response to 6a, above.
c.
Identify which of the persons identified in your response to Interrogatory 6a, above, you intend to call as witnesses.
d.
Provide su== aries of the vie s, positions or proposed testimony on Contentions 24 through 29, of all persons identified in response te Interrogatory 6a, above, that you intend to present during this proceeding.
e.
State the specific bases and references upon which the persons identified in response to Interrogatory 6a rely to substantiate their views regarding Contentions 24 through 29.
Respectfully submitted,
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L Henry J. McGurren Cou'nsel for NRC Staff Dated a: Sethesda, Mary. land this 19:5 dcy of February, 1980
02/19/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the."atter of
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LOCSL*.';A P0FR AND LIGHT COMPANY )
Docket No. 50-382
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(Wa.c: ford Steam Electric Station, )
Jait 3)
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NRC STAFF INTERROGATORIES TO, AND REQUEST FOR DOCUMENTS FROM, LOUISIANA CONSUMER'S LEAGUE. INC.
The NEC Staff hereby requests that Louisiana Consumer's League, Inc. (LCL),
pursuant to 10 CFR SS 2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce or take available for inspection and copying, all documentary material iden-tified in the responses to interrogatories below.
As agreed in the "Stipu-lation on Discovery Schedule," forwarded to the Board by letter of September 25, 1C79, LCL will have 45 days to respond to the interrogatories below.
Each response to the interrogatories below shall be under oath or affirmation of the individual (s) who contributed thereto.
For all references requested in these interrogatories, identify them by author, titic, date of publication and publisher if the reference is published, and if it is not published, identify the document by author, title, the date it was written, the quali-ficcti:ns of the author relevan; to this proceeding, and where a copy of the decuran may be obtained.
on Amended Contention 11/
Interrogatory 1.
Identify the "non-safety related components," referenced in amended Contention 1, that you believe the applicant has not provided for in a quality assurance program.
Interrogatorv on Amended Contention 2 2.
Identify, giving the basis therefor, the " incorrect operator actions" during a postulated event that you believe should be evaluated in an accident analysis.
In addition, state in detail how each such " incorrect operator action" should be evaluated in an accident analysis, giving the bases for any assumptions.
Interrocatorv en Amended Contention 4 3.
Specify the bases for Contention 4.
In particular indicate where the referenced TMI-2 fission product releases occurred and identify the extent of each TMI-2 fission product release into the atmosphere.
Interrocatory on Amended Contentions 1 through 4 4
2.
Upon what person or persons do you rely to substantiate your case on caended Contentions 1 through 4?
Indicate for each person identified the specific contention that person is relied upon to substantiate.
1 The numberlag of the contentions stated in these interrogatories conforms 7
- that accepted by the Atomic Safety and Licensing Board in its Order dated January ll, 1980.
b.
Provide the addresses and educational and professional qualifi-cations of any persons named in your response to Interrogatory 4a, above.
c.
Identify which of the persons identified in response to Inter-rogatory 4a, above, you intend to call as witnesses, d.
Provide sum = aries of the views, positions or proposed testimony on amended Contentions 1 through 4, of all persons identified in response to Interrogatory 4a, above, that you intend to pre-sent during this proceeding.
e.
State the specific bases and references upon which the persons identified in response to Interrogatory 4a rely to substantiate their views regarding amended Cententions 1 through 4.
Respectfully submitted,
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i Henry J. McGurren Counsel for NRC Staf f Dated at Bethesda, lbryland this 19t': day of February, 1980
UNITED STATES OF MdERICA 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 TO, 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 indi-cated by an asterisk, through deposit in the Nuclear Regulatory Co= mission's internal mail system, this 19th day of February, 1980:
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 6 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 Washington, DC 20555 E. Blake, Esq.
Atomic Safety and Licensing Appeal George F. Trowbridge, Esq.
Panel (5)*
Shaw, Pittman, Potts & Trowbridge U.S. Nucelar Regulatory Commission 1800 M Street, N.W.
Washington, DC 20555 Washington, DC 20036 Docketing and Service Section (7 )
- Mr. Stephen M.
Irving Office of the Secretary One American Place, Suite 1601 U.S. Nuclear Regulatory Co= mission Baton Rouge, LA 70825 Washington, DC 20555 Mr. Lyman L. Jones, Jr.
Suite 910 - Security Homestead Building 4900 Veterans Memoral Blvd.
Metairie, LA 70002
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Henry [gj McCurren Counsel for NRC Staff