ML20054B677

Petition to Participate as Interested State.Specific Aspects of Subj Matter Listed.Certificate of Svc Encl

ML20054B677
Person / Time
Site:	Waterford
Issue date:	04/15/1982
From:	Guste W, Watkins L LOUISIANA, STATE OF
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8204190050
Download: ML20054B677 (5)

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'82 AD 15 an:?2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF .

DOCKET NOS. 50-382 LOUISIANA POWER & LIGHT COMPANY (WATERFORD STEAM ELECTRIC STATION,.

UNIT 3)

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fb PETITION FOR LEAVE TO PARTICIPATE AS AN INTERESTED REggg,gq 9

, STATE IN FACILITY OPERATING LICENSE PROCEEDINGS y __

AND FOR A HEARING OF THE ISSUE RAISED -

APRJ g I982D-I SUA SPONTE ON MARCH 18, 1982 i'~ ~10 q c 1::ry iavi g:,,

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I. IDENTIFICATION OF PETITIONER f The State of Louisiana on its own behalf, and on behalf of i ts citizens petitions the Nuclear Regulatory Commission (NRC) for leave to participate in the above-captioned matter pursuant to the Commission's " Rules of Practice for Domestic i Licensing Porceedings" in 10 CFR, Part 2, a t S 2. 714 (a) (1) .

Petitioner is a state, represented by the Attorney General, Willian J. Guste, Jr. Its objectives and purposes include:

1. To promote the interests and rights of all citizens in the State of Louisiana, in harmony with the general welfare of our state and nation, by whatever means.

2. To represent the interests of the citizens of Louisi-ana before legislative and adninistrative bodies at the national,

[ state and local levels, and where appropriate, to provide assistance to Louisiana citizens in pursuing judicial remedies provided by law. %O J l

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I 8204190050 820415 l l PDR ADOCK 05000382

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1 A number of petitioner's citizens live within 15 and 30 l miles of the proposed facility, and as represented by their police jury have requested the Attorney General to intervene in this i

proceeding as an intervenor without opposition to the operating license. An even larger number of petitioner's citizens obtain their drinking water from the Mississippi River adjacent to over which the proposed facility is to be located.

II. INTERESTS OF THE PETITIONER

~The interests of petitioner and the Louisiana citizens 4

it represents which may be affected by the results of this

proceeding are the potential financial, health, safety and environmental problems associated with this nuclear power station.

III. SPECIFIC ASPECTS OF THE SUBJECT MATTER FOR WHICH INTERVENTION I IS SOUGHT i

Intervenor believes that without its intervention adequate consideration will not be given in this proceeding to its views i in regard to:

1. The reliability of one Shutdown Heat Removal System 1

on the System 80 design as evaluated in

2. Whether, in the broader view, the feed and bleed system to (EFWS) be evaluated to provide back up for the Emergency Feed Water System is adequate or Rowsome & Murphy estimates.

3. Whether there are other back up systems to EFWS to provide back up in the event of the EFWS failure.

4. Whether the issue of a Shutdown Heat Removal System is merely generic or is sufficiently at issue in this proceeding to be handled at this licensing staae.

5. The risk assessment reasonably determined for all EFWS.

IV. CONCLUSION Petitioner prays that the specific contentions to be made by petitioner be considered and included as part of the conditions of such operating license. , .,'

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DATED:

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$7 .'GUSTF, JKV WILLIAM Attorne General State Louisiana 234 Lo ola Avenue 7th Floor ,

New Orleans, Louisiana 70112 l 504/568-5575 A' .

LINDA B. WATKINS Assistant Attorney General Department of Justice 7434 Perkins Road Suite C Baton Rouge, Louisiana 70808 COUNSEL FOR STATE OF LOUISIANA l

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V. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing petition for leave to participate was mailed on the day of ,

1982, postage pre-paid, first class U.S. Mail to the following:

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N Y LINDA B. WATKINS

. Assistant Attorney General

1. Secretary to the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Docketing and Service Section

2. Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

3. Mr. Troy B. Conner, Jr.

Attorney at Law 1747 Pennsylvania Ave., NW Washington, D.C. 20006

4. Sheldon J. Wolfe, Esquire U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D.C. 20555

5. Dr. Harry Foreman Box 395, Mayo University of Minnesota Minneapolis, Minnesota 55455

6. Dr. Walter J. Jordan '

881 West Outer Drive Oak Ridge, Tennessee 37830

7. Chairman, Atomic Safety and Licensing i Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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8. Chairman, Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

9. Docketing and Service Section .

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

10. Sherwin E. Turk, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ll. W. Malcolm Stevens, Esquire Monroe & Lemann Whitney Building 625 Gravier Street New Orleans, Louisiana 70112

12. Mr. Lyman L. Jones, Jr.

Gillespie & Jones Post Office Box 9216 Metairie, Louisiana 70005

13. Mr. Bruce W. Churchill Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 t

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