ML20010J622

Request for ASLB Approval of Joint Intervenors Revised Contention 17 Re Emergency Planning.Nrc & Joint Intervenors Join in Request.Certificate of Svc Encl

ML20010J622
Person / Time
Site:	Waterford
Issue date:	10/01/1981
From:	Blake E LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8110060276
Download: ML20010J622 (4)

Text

______ _ _ _ _ _ _ _ . _

Applictnt 10/1/81 W "

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is UNITED STATES OF AMERICA #

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NUCLEAR REGULATORY COMMISSION ,g n 7 jggj r,, k k 4('[^;" m 94 1

. . _ . , . s Before the Atomic Safety and Licensing Board i

In the Matter of )

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LOUISIN A PONER & LIGHT COMPANY ) Docket No. g

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(Waterford Steam Electric )

Station, Unit 3) ) g OCT 0 II

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kEQUEST FOR BOARD APPROVAL 9k%

OF REVISED JOINT INTERVENOR g ,s

,,, CONTENTION 17 h S' By Order dated September 12, 1979, the Beard admitted Joint latervenors' Contention 17 on the adequacy of emergency planning for Waterford 3. As adtri+.ted, Contention 17 reads:

17. Applicant has failed to adequately make provision, according to the Emergency Plan con-tained in Chapter 13,3 of the FSAR, for the fol-lowing emergency contingencies:

a. Evacuation of individuals located in the immediate vicinity of the site, within St. Charles Parish in the event of a serious reactor incident.

b. Evacuation of population masses located within a 20 mile radius of the Waterford 3 site in the event of a serious reactor incident, as was contemplated during the recent crisis at the 3 Mile Island Facility in Pennsylvania.

c. Storage of potassium iodide in locations which are readily accessible to affected individuals as protection Ah against thyroid irradiation.

d. Evacuation of residents of the 5e n I Greater Metropolitan New Orleans Area.

8110060276 0110 DR ADOCK 05000

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BLsed on recent discussions, Applicant, Joint Intervenors and the NRC Staff have agreed that Contention 17 should be revised to more accurately reflect current NRC regulations in the area of emergency planning. It has been agreed among these parties that Contentica 17 should be modified to read:

17. Applicant has failed to adequately raake provision, according to the Emergency Plan con-tained in Chapter 13.3 of the FSAR, for the fol-lowing emergency contingencies:

a. Evacuation of individuals located within the 10-mile plume exposure pathway emergency planning zone for the Waterford 3 site in the event of a serious reactor incident, as required by applicable NRC regulations.

b. Storage of potassium iodide in locations which are raadily accessible to affected individuals as protection against thyroid irradiation.

Applicant requests that the Board approve the proposed revi-sion in Joint Intervenors' Contention 17. Counsel for Applicant has been authorized by counsel for the NRC Staff and counsel for Joint Intervenors to state that those parties join in this request.

DATED: October >

1981.

Respectfully submitted, SHAW, PITT"AN, POTTS & TROWBRIDGE 1800 M Str et, N.W.

Washington, D.C. 20036 (202) 822-1000 BY: h*

• Ernest L. Blake, Jr.

James B. Hamlin Counsel for Applicant Louisiana Power & Light Company

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• UNITED STATEE 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 a true and correct copy of the fore-going REQUEST FOR BOARD APPROVAL OF REVISED JOINT INTERVENOR CONTENTION 17 was served by United States mail, postage prepaid, this 1st day of October, 1981, upon each person on the attached Service List.

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{ Jdmes B. Hamlin l

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UNITED STATES OF AMERICA 1 N0lLEAR REGULATORY COMMISSION Before 'he Atomic Safety and Licensing Board In the Matter of )

)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

)

(Waterford Steam Electric )

Station, Unit 3) )

l 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. 20555 Dr. Harry Foreman Louisiana Consumers League, Inc.

Director, Center for 535 No. 6th Street ,

Population Studies Baton Rouge, Louisiana 70802 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 Sherwin E. Tur.k, Esquire Commission Office of the Executive Washington, D.C. 20555 Legal 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 (3) Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 r

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