ML19316A888

Answers to NRC Interrogatories on Intervenor Amended Contentions.Includes Statements Re Ability of Operators to Recognize LOCA & to Take Measures to Mitigate Effects. Certificate of Svc & Affidavit Encl

ML19316A888
Person / Time
Site:	Waterford
Issue date:	04/22/1980
From:	Irving S LOUISIANA CONSUMER'S LEAGUE, INC., PUBLIC LAW UTILITIES GROUP
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19316A883	List: ML19316A882 ML19316A888
References
NUDOCS 8005280025
Download: ML19316A888 (5)

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UNITED STATES OF AMERICA '6 ' ICC*ct['8$

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$ if f il Pafore the Atomic Safaty and Licensing Board *).

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i In the Matter of LOUISIANA POWER AND LIGHT COMPANY DOCKET NO. 50-3?2 l

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i ANSWERS TO THE tiRC STAFF'S INTERROGATORIES ON AMENDED CONTENTIONS CF THE LOUISIANA CONSUMER'S LEAGUE. INC.

5 1 In response to the NRC Staff's interrogatories on amended k contentions the Louisiana Consumer's League states the following:

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INTERROCATORY ON AMENDED CONTENTION 1: 1 This interrogatory requests data substantially similar to i that requested by the applicant in its interrogatory 1-1. The I I

i answer to that interrogatory is hereby adopted as the LCL's re-

! sponse to this interrogatory.

I INTERRnCATORY ON AMENDED CONTENTION 2: (

5 Generally it should be assumed that an operator might not recognize a loss of coolant accident as such and would, therefore, [

not take appropriate measures to mitigate the effects of the 4 3

accident. An operator acting on such a belief might even take actions which increase the severity of the accident such as f I l

throttling the HPSI during a LOCA. To evaluate such an accident [

s j 1) No credit for operator performance should be assumed for a i

i conservative period of time within which the operator must identif" i the accident and take appropriate maasures. In view of the time

! necessary to identify the accident at TMI this period sho21d be i

at least 21. hours; 2) Adverse actions tak*n by operators )f TMI f

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during the postulated accident as well as any other operator ,'

actions which might reasonably be taken by an operator who is l unaware that a LOCA is in progress. See LCL response to applicant i s )

interrogatories, number 2-2 for more detail. {

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. In support of the above assumption the following documentatio: .

is offered. Volume I. Three Mile Island-A Report to the Com- ,

missioners and the Public, NRC, pgs. L2. 43, 46, 47, 53 and 91.  !

See also. NUREG 0600, pgs. I-2-21, I-A-13, I-L-34, and Appendix -ll j ,

I-A items number 78, 192, 197, 221, 265, and 266.

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INTERROGATORY ON AMENDED CONTE'ITION L: ;1

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Lake Barrett, Preliminary Estimates of Radioactivity Releases from Thraa Mile Island, dated April 12, 1979 estimates releases at 13 million curies of Xel33 and 1.4 curies of I-131. The releases .

are believed to have come from various pathways out of the reactor '

auxiliary building due to the accumulation of heavily contaminated I I

water at that location. Other pathways include the station vent l >

stock where the particulate filter and its holder were missing for  ;

an indeterminate period (NUREG 0600, pg. II-A-33) and the steam generator atmospheric dump valves. 4 INTERROGATORY O'l CONTENTIONS 1-L:

i Contentions to date are based an published literature and '

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unpublished reports which are known to exist. No witnesses have as yet been chosen to testify regarding any particular issue.

Respectf I'IS. ,

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STEPNEN M. IR' ING Attorney for ntervenors -

l Louisiana C . sumer's Lear te

, j 1601 One Ame ican Place Baton Rou e, LA 70?25 l 504/393-9 70 l l Dated: April 22, 19$0 4

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! CERTIFICATE ,

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1 I hereby certify that a copy of the above and foregoing i document entitled " Answers to NRC Staff's Interrogatories on  :

i Amended Contentions of the Louisiana Consumer's League, Inc." were served on those perons listed on the attached service list by deposit in the United States mail, first class, postage prepaid, this 22nd day of April, 1990. ,s

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tlNITED STATES OF AMERICA I

4 MitCLEAR REGtILATORY C0mIGGION

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parnra th a Atomic naratv and Licensine Board i d

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lIntheMatterof LO1tTOTAMA POWER AND LIG11T COMPAr!Y DOCKET NO. 50-3#2 f l 1 (Waterford Staam Electric Gtation, )

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i 3ERVTCE-LIST t l

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l, Sheldon J. Wolfa, Esq. Lynan L. Jones, Jr., Esq. 3 Chairman, Atomic Safety and Gillespie & Jones l, l

Licensing Board 1h20 Veterans Memorial B

} U.S. Nuclear Ragtlatory Suita 201 j Commission Matairia, LA 70005 l1 2 n '. <, '. (

wa .h i nc.' on . n.C. Luke D. Fontana, Esq. I}a9 Dr. llarry Foraman 42L Esplanade Avenue -2 Director, Center for New Orleans, LA 70116 i

Foupulation Studies  !

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' Box 395, Mayo Harry H. Glasspiegel, Esq. >

liniversity of Minnesota Ernast L. Blake, Jr. 's f Minnaapolis, Minnasota 55455 Counnal for Applicants t

-j Ghaw, Pittman, Potts &

Dr. Waltar H. Jordan Trowbridge l M1 West Outer Drive 1900 M Street, N.W. .T Oak Ride,e, Tannessaa 3T430 Washington, D.C. 20036 'j

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McCurran, Esq. Atomic Cafety & Licensing  ;;

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Orrice of the Ex=cutiva Lac,a1 Board Panel +;

i i U.S. ?!uclaar Regulatory t Diractor i U.S. Nuclear Racilatory Commission Commintion Washington, D.C. 20555

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Wanhine, ton, D.C. 2 0 ',5 ',

l Atomic Safety & Licensing  ;

I Docketing and Sarvica Section(21) Appeal Board Panel L 11.3. Nuclear Regulatory .

! Office of the Sacratary [

H.G. Nuclear Rae,nlatory Commi -ion Ccmmission l l Wanhine,tou. D.C. 20'.'.5 Washinte, ton, D.C. 20555 6

!',.jSecretary to the Commission '

yU.S. Nuclear Regulatory Commission qWashington, D.C. 20555 i

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4 AFFIDAVIT ,

3 TATE OF LOUISIANA l

PARISH OF EAST BATON ROUGE ,

BEFORE ME, the undersigned authority, personally came and

! appeared: STEFHEN MILLER IRVING, who, after being duly sworn first l

by me, did depose and say that the above and fore 6oing " Answers ,

to NRC Staff's Interrogatories on Amended Contentions of the  ;

E ouisiana Consumer's League, Inc." are true and correct to the

'best of his knowledge and belief. 1

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Hd' MMI VING SWORN TO AND SUBSCRIBED BEFORE ME this 22nd day of April, 1990. AT BATON ROUGE, IOUIS!ANA. i s  % /

NOTARY F6BLIC 1

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