ML19294B092: Difference between revisions
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February 19, 1980 | February 19, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ) | ||
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 | LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382 | ||
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f' 0 0 2 27 0 ll3 | f' 0 0 2 27 0 ll3 | ||
For each interrogatory set forth below, in addition to supplying a direct answer to v e 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. | For each interrogatory set forth below, in addition to supplying a direct answer to v e 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 Louisiana Consumer's League Additional Contentions 1, 2, 3 and 4 Interrogatory No. 1-1 LCL asserts in its additional Contention 1 related to the TMI accident that Applicant "has not provided a quality assur-ance program for non-safety related components whose proper function is necessary for the correct operation of safety systems." | Interrogatories for Louisiana Consumer's League Additional Contentions 1, 2, 3 and 4 Interrogatory No. 1-1 LCL asserts in its additional Contention 1 related to the TMI accident that Applicant "has not provided a quality assur-ance program for non-safety related components whose proper function is necessary for the correct operation of safety systems." | ||
: a. Identify by reference to Applicant's FSAR for Water-ford 3 (a copy ~ of which has been provided to LCL) the " safety systems" to which LCL refers in this Contention. | : a. Identify by reference to Applicant's FSAR for Water-ford 3 (a copy ~ of which has been provided to LCL) the " safety systems" to which LCL refers in this Contention. | ||
: b. Identify those "non-safety related components" at Waterford 3 whose proper function LCL contends is necessary for the correct operation of Waterford 3 safety systems. 0 | : b. Identify those "non-safety related components" at Waterford 3 whose proper function LCL contends is necessary for the correct operation of Waterford 3 safety systems. 0 | ||
: c. For each non-safety related component identified in response to b. above, explain in detail why LCL contends the component's proper function is necessary for the correct opera-tion of each safety system identified in response to a. above. | : c. For each non-safety related component identified in response to b. above, explain in detail why LCL contends the component's proper function is necessary for the correct opera-tion of each safety system identified in response to a. above. | ||
Interrogatory No. 2-1 Does LCL contend that the " incorrect operator action" referred to in additional Contention 2 initiates the "postu-lated event" or occurs after initiation of the postulated event? | Interrogatory No. 2-1 Does LCL contend that the " incorrect operator action" referred to in additional Contention 2 initiates the "postu-lated event" or occurs after initiation of the postulated event? | ||
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Washington, D.C. 20036 (202) 331-4100 Dated: February 19, 1980 3 | Washington, D.C. 20036 (202) 331-4100 Dated: February 19, 1980 3 | ||
February 19, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ) | |||
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 | LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382 | ||
| Line 62: | Line 54: | ||
Con el for Applicants Dated: February 19, 1980 | Con el for Applicants Dated: February 19, 1980 | ||
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) | |||
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 | LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382 | ||
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(Waterford Steam Electric Station, ) | (Waterford Steam Electric Station, ) | ||
Unit 3) ). | Unit 3) ). | ||
~ | ~ | ||
SERVICE LIST Sheldon J. Wolfe, Esquire Lyman L. Jones, Jr., Esquire Chairman, Atomic Safety and Gillespis'&: Jones.. | SERVICE LIST Sheldon J. Wolfe, Esquire Lyman L. Jones, Jr., Esquire Chairman, Atomic Safety and Gillespis'&: Jones.. | ||
Licensing Board Suite 201 U.S. Nuclear Regulatory 1420 Veterans Memorial Boulevard Metairie, Louisiana 70005 Commission Washington, D.C. 20555 | Licensing Board Suite 201 U.S. Nuclear Regulatory 1420 Veterans Memorial Boulevard Metairie, Louisiana 70005 Commission Washington, D.C. 20555 | ||
_ Stephen M. Irving, Esquire Dr. Harry Foreman Suite 1601 Director, Center for Popula- One American Plaza tion Studies Baton Rouge, Louisiana 70825 | _ Stephen M. Irving, Esquire Dr. Harry Foreman Suite 1601 Director, Center for Popula- One American Plaza tion Studies Baton Rouge, Louisiana 70825 | ||
' Box 395, Mayo University of Minnesota Luke B. Fontana Minneapolis, Minnesota 55455 824 Esplanade Avenue New Orleans, Louisiana 70116 Dr. Walter E. Jordan Atomic Safety and Licensing 881 West Outer Drive Board Panel Oak Ridge, Tennessee 37830 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 Commission Appeal Board Panel 20555 U.S. Nuclear Regulatory Washington, D.C. | ' Box 395, Mayo University of Minnesota Luke B. Fontana Minneapolis, Minnesota 55455 824 Esplanade Avenue New Orleans, Louisiana 70116 Dr. Walter E. Jordan Atomic Safety and Licensing 881 West Outer Drive Board Panel Oak Ridge, Tennessee 37830 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 Commission Appeal Board Panel 20555 U.S. Nuclear Regulatory Washington, D.C. | ||
Commission Docketing and Service Section (21) Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 | Commission Docketing and Service Section (21) Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 | ||
.}} | .}} | ||
Latest revision as of 15:42, 1 February 2020
| ML19294B092 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/19/1980 |
| From: | Blake E, Glasspiegel H LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | LOUISIANA CONSUMER'S LEAGUE, INC. |
| References | |
| NUDOCS 8002270113 | |
| Download: ML19294B092 (6) | |
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 LOUISIANA CONSUMER' S LEAGUE On December 10, 1979, the Louisiana Consumer's 7.eague, Inc. (LCL) amended its contentions by filing four TMI-2 re-lated contentions. By Order dated January 11, 1980, the Licensing Board admitted the additional contentions. Appli-cant's interrogatories on the additional TMI-2 contentions are submitted herewith, pursuant to the terms of the Septem-ber 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 fifteen (15) days to file objections to any interrogatory herein.
f' 0 0 2 27 0 ll3
For each interrogatory set forth below, in addition to supplying a direct answer to v e 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 Louisiana Consumer's League Additional Contentions 1, 2, 3 and 4 Interrogatory No. 1-1 LCL asserts in its additional Contention 1 related to the TMI accident that Applicant "has not provided a quality assur-ance program for non-safety related components whose proper function is necessary for the correct operation of safety systems."
- a. Identify by reference to Applicant's FSAR for Water-ford 3 (a copy ~ of which has been provided to LCL) the " safety systems" to which LCL refers in this Contention.
- b. Identify those "non-safety related components" at Waterford 3 whose proper function LCL contends is necessary for the correct operation of Waterford 3 safety systems. 0
- c. For each non-safety related component identified in response to b. above, explain in detail why LCL contends the component's proper function is necessary for the correct opera-tion of each safety system identified in response to a. above.
Interrogatory No. 2-1 Does LCL contend that the " incorrect operator action" referred to in additional Contention 2 initiates the "postu-lated event" or occurs after initiation of the postulated event?
Interrogatory No. 2-2 To the extent LCL contends such " incorrect operator ac-tion" occurs after initiation of the postulated event, iden-tify with particularity the " incorrect operator action" which LCL contends the Applicant should consider in each of the accident analyses in Chapter 15 of the FSAR.
Interrogatory No. 3-1 Identify with particularity each of the operator actions which LCL characterizes as " operator performance during the Three Mile Island accident" which form the basis for additional Contention 3.
Interrogatory No. 4-1 What do you consider to be the best estimate of the fis-sion product releases that actually occurred during the TMI-2
accident? Identify the source of this best estimate. If the source is an individual: provide identity and qualifications; identify releases by source and quantity of release, the calcu-lations by which each estimate was derived, and the authorita-tive basis for the estimates given. If the source is a docu-ment: provide author, title, date, and citations to the sec-tions and pages containing the estimates of fission product releases on which Intervenors rely.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: M,, N4/M/
Ern t L. Blake,fJr/
Ha y H. Glasspiegel Counsel for Applicants 1800 M Street, N.W.
Washington, D.C. 20036 (202) 331-4100 Dated: February 19, 1980 3
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 Louisiana Consumer's League" 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.
m
/ / ' Y "Harr H. Glasspie/ gel (/
Con el for Applicants 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 Gillespis'&: Jones..
Licensing Board Suite 201 U.S. Nuclear Regulatory 1420 Veterans Memorial Boulevard Metairie, Louisiana 70005 Commission Washington, D.C. 20555
_ Stephen M. Irving, Esquire Dr. Harry Foreman Suite 1601 Director, Center for Popula- One American Plaza tion Studies Baton Rouge, Louisiana 70825
' Box 395, Mayo University of Minnesota Luke B. Fontana Minneapolis, Minnesota 55455 824 Esplanade Avenue New Orleans, Louisiana 70116 Dr. Walter E. Jordan Atomic Safety and Licensing 881 West Outer Drive Board Panel Oak Ridge, Tennessee 37830 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 Commission Appeal Board Panel 20555 U.S. Nuclear Regulatory Washington, D.C.
Commission Docketing and Service Section (21) Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555
.