ML20008G178

Second Set of Interrogatories Directed to Joint Intervenors Re Contentions 1,2 & 8/9.Certificate of Svc Encl

ML20008G178
Person / Time
Site:	Waterford
Issue date:	06/10/1981
From:	Churchill B LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	JOINT INTERVENORS - WATERFORD
References
NUDOCS 8107020394
Download: ML20008G178 (18)

Text

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UNITED STATES OF AMERICA [6- O'f 7 NUCLEAR REGULATORY COMMISSION Z JUN 151981 r

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

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APPLICANT'S INTERROGATORIES TO JOINT INTERVENORS (SECOND SET) d uY ",Q /

• 4 43 Tursuant to 10 C.F.R. S 2.740b, Louisiana Powe Company (" Applicant") submits the following interrogatories to be answered separately and fully in writing under oath or affirmation by Save Our Wetlands, Inc. and Oystershell Alliance, l Inc. (" Joint Intervenors") . In accordance with paragraph 3 of l

the September 25, 1979 Discovery Stipulation, these interroga-tories relate to new information in the NRC Staff's Draft i Environmental Statement (" DES") bearing on allowed contentions.

Pursuant to paragraph 5 of the Discovery Stipulation, these interrogatories must be answered within 30 days, and any objections to the interrogatories must be made within 15 days.

Answers and objections must be served on all parties and the Licensing Board.

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INTERROGATORIES ON CONTENTION 1

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1-1. State whether Joint Intervenors contend that the peak load responsibility forecasts for 1983-1986 for Applicant and'the 1 MSU System set forth in DES Table 2.1 are " higher than reasonable,"  !

as alleged in Joint Intervenors' Contention 1(a) .

1-2. If the answer to the preceding interrogatory is affirma-tive, describe in detail all the facts that support Joint Intervenors' conten, tion that the load forecasts are unreasonably high.

1-3. If the answer to Interrogatory No. 1-1,is affirmative,

. identify by author, title and date all documents upon which Joint Intervenors rely in contending that the load forecasts are unrea .

sonably high.

1-4. If the answer to Interrogatory No.1-1 is affirmative, identify all persons whom Joint Intervenors expect to testify on l their behalf concerning the reasonableness of the load forecasts and for each person state his or her address, employer, position l

and qualifications.

1-5. If the answer to Interrogatory No. 1-1 is affirmative, state in detail:

i (a) The peak load responsibility that Joint Intervenors contend Applicant and the MSU System will encounter for the years 1983-1986; l <

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i (b) The method by which Joint Intervenors cal-culated their estimates of peak load responsibility; (c) The author, title and date of each document upon which Joint Intervenors relied in making their peak load responsibility estimates; and (d) The name, address, employer, position and qualifications of each person who assisted or contributed in making Joint Intervenors' peak load responsibility estimates.

1-6. State whether Joint Intervenors contend that the DES is incorrect in stating (S 2.4.1) that " adequate supplies of oil for generating electricity are uncertain."

l-7. If the answer to the preceding interrogatory is affirma-tive, state the name and address of each oil supplier who will make a firm and certain commitment to meet Applicant's fuel oil require-ments for the period 1983-1986, and state the price per barrel at which each such supplier will sell the oil during that period.

1-8. State whether Joint Intervenors contend that the DES is incorrect in stating (S 2. 4.1) that "[nlatural gas, as supplied under firm contracts, has been curtailed in the past" and that "such gas supplies may be further curtailed and that acceptable replacement fuels will be difficult to acquire."

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l-9. If the answer to the preceding interrogatory is affirma-tive, state the name and address of each gas supplier who will guarantee to supply Applicant's natural gas requirements without curtailment for the period 1983-19E6, and state the price per mcf at which each such supplier will supply the natural gas during that period.

1-10. The DES states (S 3.2) that "the only alternative available at the operating license stage is limited to denying the operation of the facility and thereby not permitting the constructed nuclear facility to be added to the applicant's generating system."

State whether Joint Intervenors contend that this statement is incorrect.

1-11. If the answer to the preceding interrogatory is affirma-tive, state in detail with respect to each alternative to operation of Waterford 3:

(a) The nature of the alternative; (b) All the facts that support Joint Intervenors' contention that the alternative is reasonable; (c) The environmental and economic costs of the 4

alternative, and the method by which such costs were calculated; (d) The author, title and date of all documents upon which Joint Intervenors rely in proposing the alternative; and 1

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(e) The name, address, employe,r, position and qualifications of each person expected to testify on behalf of Joint Intervenors with respect to the alternative.

1-12. The DES states (S 3.2) that "(t]he alternative of not operating the facility will involve incurring the environmental and economic costs of construction of Waterford 3 without receiving the benefit of the power Waterford 3 would produce." State whather Joint Intervenors contend that it would be reasonable to incur these economic and environmental costs without obtaining any coun-terbalancing benefit.

1-13. If the answer to the preceding interrogatory is affirma-tive, describe in detail the rationale,for Joint Intervenors' contention. ,

1-14. State separately for each answer to the preceding interro-gatories on Contention 1 the name, address, employer, position and qualifications of the person or persons drafting the answer and, if different, of the person or persons supplying the information upon which the answer was based.

INTERROGATORIES ON CONTENTION 2 .

2-1. The DES estimates (SS 2.2, 5.10) the cost of safely l

decommissioning Waterford 3 to range from $21 nillion to $43 million (1978 dollars), based in part on NUREG-0586. State whether Joint Intervenors contend that this estimate is materially inaccurate.

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2-2. If the answer to the preceding interrogatory is affirma-tive, state in detail all the facts that support Joint Intervenors' contention that the estimate is inaccurate.

2-3. If the answer to Interrogatory No. 2-1 is affirmative, identify by date, author and title all documents that support Joint Intervenors' contention that the estimate is inaccurate.

2-4. If the answer to Interrogatory No. 2-1 is affirmative, identify all persons whom Joint Intervenors expect to testify on their behalf cor.cerning the accuracy of the estimate.

2-5. If the answer to Interrogatory No. 2-1 is affirmative, state,in detail:

(a) Joint Intervenors' estimate of the cost, (in 1978

' dollars) of decommissioning Waterford 3; (b) Tha method by which Joint Intervenors calculated their estimate of decommissiening costs; (c) The date, title and author of each document upon which Joint Intervenors relied in making their escimate of decommissioning c'o sts; and i (d) The name, address, employer, position and l gualifications of each person who assisted in making l

l Joint Intervenors' estimate of decommissioning costs.

t 2-6. The DES assumes (S 2.2) that Waterford 3 will operate at a capacity factor of 60 percent in its first year of operation.

State whether Joint Intervenors contend that this assumption is inaccurate.

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2-7. If the answer to the preceding interrogatory is affirma-tive, state in detail all the fact's that support Joint Intervenors' contention that the assumption is inaccurate.

2-8. If the answer to Interrogatory No. 2-6 is affirmative, identify by date, author and title all documents that support Joint Intervenors' contention that the assumption is inaccurate.

2-9. If the answer to Interrog 'ary No. 2-6 is affirmative, identify all persons whan Joint Intervenors expect to testify on their behalf concerning the accuracy of the assumption.

2-10. If the answer to Interrogatory No. 2-6 is affirmative, state in detail:

(a) Joint Intervenors' estimate of the capacity factor of Waterford 3 in its first year of operation; (b) The method by which Joint Intervenors calculated their estimate of the capacity factor; (c) The date, title and author of each document upon which Joint Intervenors relied in making their estimate of the capacity factor; and (d) The name, address, employer, position and qualifications of each person who assisted in making Joint Intervenors' estimate of the capacity factor.

2-11. The DES estimates (Table 6.2) that in the first year of operation the cost of fuel and the costs of operating and maintenance

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for Waterford 3 will be 14.23 mills /kWh. State whether Joint Intervenors contend that this cost estimate is materially inaccurate.

2-12. If the answer to the preceding interrogatory is affirma-tive, state in detail all the facts that support Joint Intervenors' contention that the estimate is inaccurate.

2-13. If the answer to Interrogatory No. 2-11 is affirmative, identify by date, author and title all documents that support Joint Intervenors' contention that the cost estimate is inaccurate.

2-14. If the answer b3 Interrogatory No. 2-11 is affirmative, identify all persons whom Joint Intervenors expect to testify on their behalf concerning the accuracy of the cost estimate.

I 2-15. If the answer,63 Interrogatory No. 2-11 is affirmative, state in detail:

(a) Joint Intervenors' estimate of the first year's fuel, operating and maintenance costs for Waterford 3; (b) The method by which Joint Intervenors cal-l l culated their estimate of fuel, operating and maintenance costs; j (c) The date, title and author of each document upon which Joint Intervenors relied in making their estimate of fuel, operating and maintenance costs; and (d) The name, address, employer, position and qualifications of each person who assisted in making Joint i Intervenors' estimate of fuel, operating and maintenance Costs.

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2-16. The DES states ($ 2.2) that its fuel cost estimate is based in part upon Table 11 of NUREG-0480. State whether Joint Intervenors contend that the estimates of spent fuel storage, transportation and disposal costs in Table 11 are materially inaccurate.

2-17. If the answer to the preceding interrogatory is affirma-tive, state in detail all the facts that support.foint Intervenors' contention that the estimate is inaccurate.

2-18. If the answer to Interrogatory No. 2-16 is affirmative, identify by date, author and title all documents that support Joint Intervenors' contention that the spent fuel cost estimates are in accurate .

2-19. If the answer to *Interrogato'ry No. 2-16 is a5firmative, identify all persons whom Joint Intervenors expect to testify on their behalf concerning the accuracy of the spent fuel cost estimates.

2-20. If the answer to Interrogatory No. 2-16 is affirmative, state in detail:

i (a) Joint Intervenors' estimate of the spent fuel costs for Waterford 3; (b) The method by which Joint Intervenors calculated their estimate of spent fuel costs; (c) The date, title and author of each document upon which Joint Intervenors relied in making their estimate of spent fuel costs; and

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(d) The name, address, employer, position and quali-fications of each person who assisted in making Joint Intervenors' estimate of spent fuel costs.

2-21. The DES estimates (SS 2.2, 6.6.2) 'that the fuel-cost savings during the first year of operation of Waterford 3 will be approximately. $230 million. State whether Joint Intervenors contend that this estimate is materially inaccurate.

2-22. If the answer to the preceding interrogatory is affirma-tive, state in detail all the facts that support Joint Intervenors' contention that the estimate is inaccurate.

'2-23. If the answer to Interrogatory No. 2-21 is affirmative, identify by date, author and title all documents that support Joint .

Intervenors' contention that the estimate is inaccurate.

2-24. If the answer to Interrogatory No. 2-21 is affirmative, identify all persons whom Joint Intervenors expect to testify on their behalf concerning the accuracy of the estimate.

2-25. If tne answer to Interrogatory No. 2-21 is affirmative, state in detail:

(a) Joint Intervenors' estimate of the first year's fuel-cost savings; (b) The method by which Joint Intervenors calculated their estimate of the first year's fuel-cost savings;

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(c) The date,. title and author of each docu-ant upon which Joint Intervenors relied in making their estimate of the first year's fuel-cost savings; and (d) The name, address, employer, position and quali-fications of each person who assisted in making Joint Intervenors' estimate of:the first year's fuel-cost savings.

2-26. State separately for each answer to the preceding interro-gatories on Contention i the name, address, employer, position and qualifications at the person or persons drafting the answer and, if 4 different, of the person or persons supplying the information upon which the answer was based.

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, INTERROGATORIES ON CONTENTION 8/9 ,

8/9-1. The DES states (S 5. 9.1. 5.l (1) ) that the " occupational risk associated with the industrywide average radiation dose is 5

about 11 potential premature deaths /10 man-ye:rs attributable to i cancer." State whether Joint Intervenors contend that this statement is materially inaccurate.

8/9-2. If the answer to the preceding interrogatory is affirmative, state in detail all the facts that support Joint Intervenors' contention that the occupational risk estimate is i inaccurate.

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8/9-3. If the answer to Interrogatory No. 8/9-1 is affirma-tive, identify by date, author and title all documents that support i

i Joint Intervenors' contention that the occupational risk estimate

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8/?-4. If the answer to Interrogatory No. 8/9-1 is affirma-1 tive, identify all persons whom Joint Intervenors expect to testify on their behalf concerning the accuracy of the occupational risk estimate.

8/9-5. If the answer to Interrogatory No. 8/9-1 is affirma-tive. state in detail:

(a) Joint Intervenors' estimate of the occupational risk; (b) The method by which Joint Intervenors cal-culated their estimate of the occupational risk; (c) The date, title and author of each document 4 upon which Joint Intervenors relied in making their estimate of the occupational risk; and (d) ,The name, address, employer, position'and qualifications of each person who assisted in making i

Joint Intervenors' estimate of the occupational risk.

8/9-6. The DES estimates (S 5.9.1.5.2(3)) that the risk of potential premature death from cancer to the maximally exposed individual from exposure to radioactive effluents from one year of i normal reactor operation at Waterford 3 "is less than one chance in a million . . . over the average lifetime." State whether t

Joint Intervenors contend that this estimate is materially inaccurate.

I 8/9-7. If the answer to the preceding interrogatory is affirmative, state in detail all the facts that support Joint Intervenors' contention that the risk estimate is inaccurate.

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' affirmative, identify by date, author and title all documents that support Joint-Intervenors' contention that the risk estimate is inaccurate.

8/9-9. If the answer to Interrogatory No. 8/9-6 is affirmative, identify all persons whom Joint Intervenors expect to testify on their behalf concerning the accuracy of the risk estimate.

8/9-10. If the answer to Interrogatory No. 8/9-6 is affirmative, state in detail:

(a) Joint Intervenors' estimate of the risk to

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the maximally e posed individual; (b) The method by'which Joint Intervenors cal-culated their estimate of the risk to the maximally exposed individual; (c) The date, title and author of each document upon which Jcint Intervenors relied in making their -

estimate of the risk te the maximally exposed individual; and (d) The namo, address, employer, position and qualifications of each person who assisted in making Joint Intervenors' estimate of the risk to the maximally exposed individual.

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'8/9-11. The DES estimates (S T. 9.1. 5. 2 (3) ) that the ri.sk of potential premature death from cancer to the average individual within 50 miles of Waterford 3 from exposure to radioactive effluents from normal operation of the reactor "is less than 1 percent of the risk'to the maximally exposed individual." State whether Joint Intervenors contend that this estimate is materially inaccurate.

8/9-12. If the answer to the preceding interrogatory is affirmative, state in detail all the facts that support Joint

ntervenors' contention that the risk estimate is inaccurate.

8/9-13. If the answer ta Interrogatory No. 8/9-11 is affirmative, identify by date, author and title all documents that support Joint Intervenors' contention that tha risk estimate is inaccurate.

8/9-14. If the answer to Interrogatory No. 8/9-11 is affirmative, identify all persons whom Joint Intervenors expect to testify on their behalf concerning the accuracy of the risk l estimate.

I 8/9-15. If the answer to Interrogato f No. 8/9-11 is affirmative, state in detail:

(a) Joint Intervenors' estimate of the risk to the average individual within 50 miles of Waterford 3; (b) The method by which Joint Intervenors cal-culated their estimate of the risk to the average individual within 50 miles of Waterford 3; 14 -

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(c) The date, title and author of each document upon which Joint Intervenors relied in making their estimate of the risk to the average individual wl. thin 50 miles of Waterford 3; and (d) The name, address, employer, position and qualifications of each person who assisted in making Joint Intervenors' estimate of the risk to the average individual within 50 miles of Waterford 3.

8/9-16. The DES estimates (S 5. 9.1. 5. 2 (4 ) ) that the risks to the general United States population from exposure to radio-active effluents and transportation of fuel and waste from each year of normal operation of Waterford 3 "are a very small fraction (less than 0.001 percent) of the risks to the U.S. population from each year of exposure to natural background radiation." State whether Joint Intervenors contend that this estimate is materially inaccurate.

8/9-17. If the answer to the preceding interrogatccy is affirmative, state in detail all the facts that support Joint Intervenors' contention that the risk estimate is inaccurate.

8/9-18. If the answer to Interrogatory No. 8/9-16 is affirmative, identify by date, author and title all documents that support Joint Intervenors' contention that the risk estimate is inaccurate.

8/9-19. If the answer to Interrogatory No. 8/9-16 is affirmative, identify all persons whom Joint Intervenors expect to testify on their behalf concerning the accuracy of the risk estimate.

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8/9-20. If the answer to Interrogatory No. 8/9-16 is affirmative, state in detail:

(a) Joint Intervenors' estimate of the risk to the general population; (b) The method by which Joint Intervenors cal-culated their estimate of the risk to the general l population; (c) The date, title and author of each document upon which Joint Intervenors relied in making their estimate of the risk to the general population; and (d) The name, address, employer, position and qualifications of each person who assisted in making Joint Intervenors' estimate of the risk to the general population.

8/9-21. State separately for each answer to the, preceding interrogatories on Contention 8/9 the name, address, employer, posi-tion and qualifications of the person or persons draf ting the answer I

and, if different, of the person or persons supplying the information upon which the answer was based.

DATED: June 10, 1981.

Respectfully submitted, l

SHAW, PITTMAN, POTTS & TROWBRIDGE c

1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 l \

BY. W V yc6A7. Churchill James B. Hamlin Counsel for Applicant 7,cis., ,: '. , . .s ,. > . : . . - ..

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s June 10, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l Before the Atomic Safety and Licensing Board In the Matter of )

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

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(Waterford Steam Electric )

! Station, Unit 3) )

CERTIFICATE OF SERVICE I hereby certify that copies of Applicant's Interrogatories To Joint Intervenors (Second Set) , dated June 10, 1981, were served upon those persons on the attached Service List, by deposit j in the United States mail, postage prepaid, this 10th day of June, 1981.

n Gr4ce W. T.batrchill l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before tha Atomic Safety and Licensing Board In the Matter of )

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

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(Waterford Steam Electric )

Station, Unit 3) )

SERVICE LIST

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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 Stephen M. Irving, Esquire Dr. Harry Foreman Louisiana Consumers League, Inc.

Director, Center for 535 No. 6th Street Po,pulation 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 Joseph R. Gray, Esquire Commission i

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

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