ML20027A126

Submission of Interrogatories by Applicant Wiep to Intervenor Lakeshore Citizens for Safe Energy. Interrogatories Addressed to Contentions Contained in Intervenor'S Amended Contentions

ML20027A126
Person / Time
Site:	Point Beach
Issue date:	10/02/1978
From:	Trowbridge G SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
References
NUDOCS 7810130225
Download: ML20027A126 (6)

Text

Oct ber 2, 1978

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UNITED STATES OF AMERICA "

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~qa % 3 t BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

In the Matter of ) Docket Nos. 50-266

) 50-301 WISCONSIN ELECTRIC POWER )

COMPANY , ) Amendment to Licensse Nos.

, _ , , . ) DPR-24 and DPR-27 (Point Beach Nuclear' Plant, ) (Increase Spent Fuel Units 1 and 2) ) Storage capacity) s APPLICANTS' INTERROGATORIES TO INTERVENOR SET NO. 1 Pursuant to Sections 2.740 and 2.740b of the Commission's Rules of Practice, Wisconsin Electric Power Company (Applicant) requests that Lakeshore Citizens for Safe Energy (Intervenor) answer separately and fully in writing, under oath or affirma-tion, each of the interrogatories - contained herein. Applicant i requests that the person or persons. answering each interrogatory be identified. This set of interrogatories is addressed to specified contentions or subcontentions contained in Intervenor's Amended Contentions as revised by Order of the Atomic- Sahety -and - ., .

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Licensing Board dated September 1, 1978. ,

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Contention 3b

1. Specify and describe the " increased worker activity" which Intervenor contends will be necessitated by compaction.

2. Explain the mechanism or. mechanisms by which Intervenor contends that such increased worker activity .

may result in a blockage of either the entrance or dis-charge coolant water pipe.

Contention 3d (as revised) i

1. Specify and describe the " increased worker i

activity at the pool" to which this contention refers.

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'2. Explain separately the way, including specific ,

! mechanism or mechanisms, in which Intervenor contends that such increased worker activity may increase the possibility of each of the following' accidents:

(a) Loss of volume of coolant. water in the spent fuel pool.

l (b) Loss of volume or flow of service water through the heat exchanger. ,

(c) Loss of service water pnsps. ,

Contention 3e (as revised)

1. Specify and describe the " increased worker activity ,

, at'the pool" to which this contention, as revised, refers. .i

2. Explain the way, including specific mechanism or.

mechanisms, in which Intervenor contends that such increased .

worker activity may increase the possibility of damage i to the pool liner. .

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Contention 5

1. Specify the incident or incidents which Intervenor

1. contends'could result in a pool failure.

2. State with respect to eac'h such incident whether, and if so how, the fuel storage expansion program will contribute either to the likelihood of the incident or  ;

to the potential for pool failure as a result of the incident.

L Contention 6 (as revised)

1. Specify and describe the " increased activity" 'rhich Intervenor contends could result in pool leakage.

2. Explain the mechanism or mechanisms by which Intervenor contends that such increased activity mal

• result in pool leakage.

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Contention 9

1. Specify each incident associated with the storage of spent fuel which Intervenor contends might creat s an evacuation or emergency situation for which a medical and health care-plan would be necessary.

2. Explain fully any causal connecrions which Intervenor I

contends may exist between the occurrence of such incident-l and more dense and increased storage of spent fuel.

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3. Explain in what respect Intervenor contends that

-the medical and health care plan contained in Applicant's emergency plan is inadequate to cope with injuries in evacuation or emergency situations due to more dense and increased storage of spent fuel. A copy of Applicant's emergency plan, as revised and updated to September 12, 1977, has previously been furnished to Intervenors.

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e Respectfully submitted, ,

SHAW, ITTMAN, POTTS & TROWBRIDGE j$$}N

• m & J orgey . Trowbridge [

t Dated: October 2, 1978 e

Octobsr 2, 1978 UNITED STATES OF AMERICA NUCLEAR REGULATORY COleiISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of ) Docket Hos. 50-266

) 50-301 WISCONSIN ELECTRIC POWER )

COMPANY ) Amendment to License Nos.

) DPR-24 and DPR-27 (Point Beach Nuclesr Pla,nt, ) (Increase Spent Fuel Units 1 and 2) ) Storage Capacity) 1

. CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Interrog-atories to Intervenor Set No. 1," dated October 2, 1978, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 2nd day of October, 1978.

M/ . /

y p orge F.'Trowbridge/

f Dated: October 2, 1978 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-266

) 50-301 WISCONSIN ELECTRIC POWER )

COMPANY ) Amendment to License Nos.

) DPR-24 and DPR-27 (Point Beach Nuclear Plant, ) (Increase Spent Fuel Units 1 and 2) .

) Storage Capacity)

, ( SERVICE LIST Marshall E. Miller, Esq. Bruce A. Berson, Esq.

Chairman Office of the Executive Atomic Safety and Licensing Legal Director Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Ccmmission Washington, D.C. 20555 Washington, D.C. 20555 Ms. Mary Lou Jacobi Dr. E=meth A. Luebke Vice Chairperson Atomic Safety and Licensing Lakeshore Citizens for Board Safe Energy U.S. Nuclear Regulatory ' 932 N. 5th Street Commission Manitowcc, Wisconsin 54220 Washing ton, D.C. 20555 Patrick W. Walsh, Esq.

Dr. Paul W. Purdem Assistant Attorney Gen ~eral 245 Gulph Hills Road The State of Wisconsin .

Radnor, Pennsylvania 19087 Department of Justice 114 East, State Capitol ,

Decketing and Service Section Madison, Wisconsin 53702 .

Office of the Secretary U.S. Nuclear Regulatory Comrission Washington, D.C. 20555 e