ML19262C339

Joint Intervenors Response to Applicant First Set of Interrogatories.Includes Info Re Damage to Water Intake &/ or Discharge Structures in Ms River & Relationship Between Low Level Radiation & Carcinogens.Certificate of Svc Encl

ML19262C339
Person / Time
Site:	Waterford
Issue date:	01/16/1980
From:	Larry Jones AFFILIATION NOT ASSIGNED, GILLESPIE & JONES
To:	ARKANSAS POWER & LIGHT CO.
References
NUDOCS 8002110293
Download: ML19262C339 (8)

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Ik NUCLEAR REGULATORY COMMISSION

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fey BEFORE THE ATOMIC SAFETY & LICENSING BOARD s

'A In the Matter of LOUISIANA JOWER & LIGHT COMPANY Docket No. 50-382 (Waterford Steam Electric Station -

Unit 3)

JOINT INTERVENORS ANSWERS TO APPLICANT'S FIRST INTERROG ATORIES Under the terms of the September 25, 1979 Stipulation on Discovery Schedule, approved by the Licensing Board on September 28,1979, Joint

, Intervenom hereby file their first set of interrogatories pursuant to the

. approved Stipulation.

Under 10 C.F.R. Section 2.74b, these interrogatories are to be answered separ,:.tely and fully in writing and under oath or affirmation.

Answers must be served on all parties and the Licensing Board. As agreed in the Stip'ulation, Applicant has forty-five (45) days to respond to this initial request, and fifteen (15) days to file objections to any interrogatory herein. ,

- n Interrogatory 8/9 .

Specify,- in detail, all publications, investigations, consultations, analyses, or surveys utilized as the bases of Contention 8/9. Provide complete citations of published information, as well as copies of all unpublished or otherwise unavailable written material utilized in establishir~ a basis of the contention for the occurrence of a cumulative and/or synergistic relationship between low-level _ radiation and known or 1946 041 800211 0

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suspected carcinogens in the vicinity of Waterford 3.

Answer - The publications, investigations, analyses, and surveys utilized by Joint Intervenors is the bases of Contention 8/9 are identified with particularity in Joint Intervenors Answers to NRC Interrogatories 8/9-4 and 8/9-11, 8/9-6, 8/9-7, 8/9-10(b and c), 8/9-15, 8/9-16, and 8/9-19.

Interrogatory 8/9 ,

Provide the identity and location of persons having knowledge of discoverable matters related to Contention 8/9, end provide the identity of each person expected to be called as an expert witness at the hearing, the subject matter on which he is expected to testify, and the substance of his testimony. Note that 10 C.F.P_ Section 2.740(e) requires you to seasonably supplement your response to this question to include information acquired after the time of your initial response.

Answer - The individuals and locations of persons having knowledge of discoverable matters relating to Contentions 8/9 are listed in the Answers to NRC Interrogatories as numbered above.

At the present time Joint Intervenors have not yet determined the identity of all witnesses who will be called to testify and support of this Contention; ' nevertheless Joint Intervenors are cognizant of the requirements of 10 CFR Section 2.740(e) and the identity of all witnesses -

will be seasonably supplemented to Applicant and the Nuclear Regulatory

y. s Commission. -

Interrogatory 21 Indicate whether Sections 2.4.3, 2.4.10, 3.4 and 9.2.5 of the Applicant's Final Safety Analysis Report ("FSAR") " appropriately evaluate 1946 042 2

January 16,1980 the effects of maximum possible flood conditions" for those structures and conditicns identified in 21(a) and 21(b). If not, describe in what respects evaluations contained in the identified FSAR sections are inappropriate.

Answer - Sections 2.4.3, 2.4.10, 3.4 and 9.2.5 of the PSAP sppear to be inappropriate inasmuch as Joint Intervenors are unable to determine that analysis has been given to the interruption of water supplies from the intake and discharge structures, as they bear on ordinary plant operations and operation of safety systems.

Joint Intervenors are reliably informed that there have been several occasions when ordinary river traffic, not even in situations involving maxin.um possible Good, have caused damage to the water intake and/or discharge structures in the Mississippi River, which obviously would result in drastic curtailment of supplies of saailable water.

Interrogatory 21 Fcr 21(c), describe a scenario of events for a maximum possible Good which would constitute " physical isolation of essential personnel in the control room in the event of a medical emergency, resulting from closure of the primary entrance way into the containment structure," describe-what you conside'r to be the " effects" of such physical isolation and describe how these effects would threaten or adversely affect the public health and safety.

Answer - Joint Intervenors understand that in the event of nooding conditions, the control room personnel will be isolated from the outside world, with the result that any normal medical emergency could reduce the effectiveness of the number of personnel required for safe operation of the facility for the duration of the nooding conditions.

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., January 16,1980 In Eddition to limitations on the number of personnel involved, the effect of isolation itself, and the absence of prior psychological testing and screening could be the disabling of control room personnel due to depression, neurosis, and/or cycosis resulting from the fact of such isolation.

Interrogatorv 21 .

For 21(d), describe a scenario of events for a maximum possible flood which would constitute " lack of accessibility of essential personnel in the control room in the event of an emergency requiring evacuation, resulting from closure of the primary entrance way into the cor.tainment structure,"

describe what you consider to be the " effects" of such lacic of accessibility and describe how these effects would threaten or adversely affect the

• public health and safety.

Answer 3 a. A scenario of events for maximum possible flood constitutihg " lack of accessibility of essential personnel in the control

. room in the event of an emergency requiring evacuation"is itself the result of the closure of the primary entrance way into the containment structure,

,. based upon plans which have been provided by Inter fenor.

b. The effects of such lack of accessibility would appear to be self evident on the basis of any medical emergency, and would include the lack

, of sufficient number of personnel to adequently man the control room, and the potential for adverse behavice by an individual suffering from depression, neurosis and/or cycosis, or other mental, disorder or disability.

Interrogatory 23 r Identify the specific geologie 8ctiv,ities" discussed in the referenced 4

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.. January 16,1980 Saucier Report which are the subject of Conter'stion 23.

Answer - The " geologic activities" discussed in the Saucler Report include flooding caused by level breaching which is the result of movement of surface and lower strata in the Mississippi Basin; as well as fault lines clearly drawn through the vicinity of the Waterford 3 site.

Such activities would cause external flooding of the Waterford fscility as a result of breaches of the level induced either by surface or sub-surface strata action.

, Such activities would threaten the structural integrity of the fuel handling building containment structure and reactor auxilliary building as a result of the water pressures developed by such flood waters.

Respectfully C bmitted, GILLESP & JON h BY /W

~LYM L. JONES, J 14 Veterans Blvd , uite 20 M irie, Louisian 70005 (504) 835-6458 9

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- January 16,1980 STATE OF LOUISIANA PARISH OF JEFFERSON BEFORE ME, the undersigned, did appear GARY L. GROESCH, a person of the full age of majority and a resident of the Parish of Orleans, who did declare on oath that the Answers provided herein to Applicant's First Interrogatories are true and correct to the best of his knowledge, information and belief.

. - .2 dA'11Y fROESCH /

Sworn to and subscribed before me, Notary, this 16 h of January, O.

W OTA PUBIlC

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of LOUISIANA POWER AND LIGHT COMPANY DOCKET NO. 50-382 (Waterford Steam Electric Station Unit 3)

CERTIFICATE OF SERVICE I hereby certify that on January 18,1980, I mailed copies of Save Our Wetlands, Inc. and Oystershell Alliance, Inc.'s, JOINT INTERVENORS ANSWERS TO APPLICANTS FIRST INTERROGATORIES to all individuals or entities appearing on the attached Service List, p e prepaid, first class in the United States Mail v i n_ $ W IgMA JON , JR.

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SERVICE LIST Sheldon J. Wolfe, Esquire U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D. C. 20555 Dr. Harry Foreman

• Box 395, Mayo University of Minnesota 55455 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, Tennessee 37830 Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Chairman, Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission

• Washington, D. C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Henry J. McGurren, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C. 20555 George F. Trowbridge, Esquire

& Harry J. Glasspiegel, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.

Washington, D. C. . 20036 W. Malcolm Stevenson, Esquire Monroe & Lemann Whitney Building 625 Gravier Street New Orleans, Louisiana 70112 Stephen Irving, Esquire One American Place, Suite 1601 Baton Rouge, Louisiana 70825 e

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