ML19211A225

First Interrogatories Directed to Joint Intervenors,Per 790928 Stipulation.Requests Identification of Geologic Activities Raised in Contention 23,as Discussed in Saucier Rept.Certificate of Svc Encl

ML19211A225
Person / Time
Site:	Waterford
Issue date:	11/12/1979
From:	Glasspiegel H, Trowbridge G LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
References
NUDOCS 7912170217
Download: ML19211A225 (6)

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• November 12, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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Before the Atomic Safety and Licensing Board m, ,

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APPLICANT'S FIRST INTERROGATORIES TO JOINT INTERVENORS Under the terms of the September 25, 1979 Stipulation on Discovery Schedule, approved by the Licensing Board on Septem-ber 28, 1979, it was agreed that first round discovery requests with respect to the contentions initially allowed by the Licen-sing Board would be made within 60 days of the Licensing Board's Order on contentions, dated September 12, 1979. Applicant hereby files its first interrogatories pursuant to the approved Stipulation.

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, Intervenors have forty-five (45) days to respond to this initial request, and fifteen (15) days to file objections to any interrogatory herein.

Interrogatories on Contention 8/9 8/9-1 Specify, in detail, all publications, investiga-tions, consultations, analyses, or surveys i591 122 7912170 217

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i utilized as the bases of Contention 8/9. Pro-vide complete citations of published informa-tion, as well as copies of all unpublished or otherwise unavailable written material utilized in establishing a basis of the contention for the occurrence of a cumulative and/or synergis-tic relationship between low-level radiation and known or auspected carcinogens in the vicinity of Waterford 3.

8/9-2 Provide the identity and location of persons having knowledge of discoverable matters related to Contention 8/9, and 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 sub-stance of his testimony. Note that 10 C.F.R.

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.

Interrogatories on Contention 21 21-1 Indicate whether Sections 2.4.3, 2.4.10, 3.4 and 9.2.5 of the Applicant's Final Safety Analy-sis Report (" FSAR" ) " appropriately evaluate the 1591 123

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effects of maximum possible flood conditions" for

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those structures and conditions identified in 21(a) and 21(b). If not, describe in what respects evaluations contained in the identi-fied FSAR sections are inappropriate.

21-2 For 21(c) , describe a scenario of events for a maximum possible flood which would constitute

" physical isolation of essential personnel in the control room in the event of a medical emer-gency, resulting from closure of the primary entrance way into the containment structure,"

describe what you consider to be the " effects" of such physical isolation and describe how these effects would threaten or adversely affect the public health and safety.

21-3 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 emer-gency requiring evacuation, resulting frcm closure of the primary entrance way into the containment structure," describe what you con-sider to be the " effects" of such lack of 1591 124

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accessibility and describe how these effects would threaten or adversely affect the public

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health and safety.

Interrogatories on Contention 23 23-1 Identify the specific " geologic activities" discussed in the referenced Saucier Report which are the subject of Contention 23.

23-2 Explain how such activities would cause ex-ternal flooding of the Waterford facility.

23-3 Explain how such activities would threaten the structural integrity of the fuel handling building, containment structure and reactor auxiliary building.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE

• By: ,/ffy AC+ts/ J

' yGeofge F.' Trowbridge/

Harry H. Glasspiegel Counsel for Applicants 1800 M Street, N.W.

Washington, D.C. 20036 (202) 331-4100 Dated: November 12, 1979 1591 125

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UNITED ST3T7,S OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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LOUISIANA POWER & LIGHT COMPANY ) Docket 50-382

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(Waterford Steam Electric Station, )

Unit 3) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing document, entitled " Applicant's First Interrogatories to Joint Inter-venors," were served by deposit in the U.S. mail, first class, postage prepaid, this 12th day of November, 1979, to those per-sons on the attached service list.

N HaffH. Glasspieghl Dated: November 12, 19.79 1591 125

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

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LOUISIANA POWER & LIGHT COMPANY ) Docket 50-382

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(Waterford Steam Electric Station, )

Unit 3) )

SERVICE LIST Sheldon J. Wolfe Docketing and Service Section Atomic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Henry J. McGurren, Esq.

Dr. Harry Foreman, Director Office of the Legal Director Center for Population Studies U.S. Nuclear Regulatory Box 395, Mayo Commission University of Minnesota Washington, D.C. 20555 Minneapolis, Minnesota 55455 Lyman L. Jones, Jr.

Dr. Walter H. Jordan Gillespie & Jones 801 West Outer Drive Suite 201 Oak Ridge, Tennessee 37830 1420 Veterans Memorial Boulevard Chairman, Atomic Safety and Metairie, Louisiana 70005 Licensing Board Panel U.S. Nuclear Regulatory Luke B. Fontana Commission 824 Esplanade Avenue Washington, D.C. 20555 New Orleans, Louisiana 70116 Chairman, Atomic Safety and Stephen M. Irving Licensing Appeal Board Counsel for Petitioner U.S. Nuclear Regulatory One American Plaza Commission Suite 1601 Washington, D.C. 20555 Baton Rouge, Louisiana 70825 1591 127