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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20065J1171982-09-29029 September 1982 Request for Production & Copy of Certain Documents. Documents Should Be Delivered within 15 Days in Order to Avoid Prejudicing Intervenors in Subsequent Proceedings ML20038A6461981-11-0202 November 1981 Revised Answers to Interrogatories on Contentions 8/9. Certificate of Svc Encl ML20011A2801981-09-20020 September 1981 Suppl to Answers to Interrogatories 1-14,2-26 & 8/9-21. Certificate of Svc Encl.Related Correspondence ML20140B6041981-09-0101 September 1981 Answers to Applicant Second Set of Interrogatories Re Contentions 1,2,8,9.Certificate of Svc Encl.Related Correspondence ML20010C1781981-08-13013 August 1981 Third Set of Interrogatories Directed to Joint Intervenors, Save Our Wetlands,Inc & Oyster Shell Alliance.Certificate of Svc Encl.Related Correspondence ML20010C1491981-08-13013 August 1981 Second Set Interrogatories Directed to La Consumer League, Inc.Certificate of Svc Encl.Related Correspondence ML20008G1781981-06-10010 June 1981 Second Set of Interrogatories Directed to Joint Intervenors Re Contentions 1,2 & 8/9.Certificate of Svc Encl ML20003F6211981-04-15015 April 1981 Responses to Joint Intervenors' Interrogatories 19-1 Through 19-7 Re Fuel Element Assembly Guide Wear Problem. Affidavits & Certificate of Svc Encl ML19345G4981981-03-25025 March 1981 Responses to Joint Intervenors' Interrogatories 1-1 Through 2-16 Re Contentions 1 & 2 Alleging Util Has Not Shown Facility Operation Is in Public Interest.Affidavits & Certificate of Svc Encl.Related Correspondence ML19345G5551981-03-25025 March 1981 Responses to La Consumer League 791113 Interrogatories 11-14 Re Emergency Plans.Affidavits & Certificate of Svc Encl ML19345G4991981-03-25025 March 1981 Responses to Joint Intervenors' Interrogatories 17-1 Through 17-136 Re Population Estimates,Evacuation Time,Radiological Emergencies & Evacuation Procedures.Affidavit & Certificate of Svc Encl.Related Correspondence ML19323F6461980-04-24024 April 1980 Answers to Applicant 800219 Supplemental Interrogatories. Includes Info Re Amount & Danger of Hydrogen Gas & Combustible Gas Control Sys.Affidavit & Certificate of Svc Encl.Related Correspondence ML19323D8091980-04-24024 April 1980 Answers to NRC Supplemental Interrogatories.Includes Info Re Fuel Melting,Nuclear Emergency & Radiation Monitors During Class 9 Accident.Affidavit,Certificate of Svc & Related Correspondence Encl ML19316A8881980-04-22022 April 1980 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 ML19312D8231980-03-24024 March 1980 Answers to Applicant Interrogatories Re TMI-2 Related Contentions.Urges Consideration of Possible Component Interactions Per Sandia Labs 791221 Rept Re Interaction Methodology.W/Certificate of Svc,Affidavit & Cover Ltr ML19294B0921980-02-19019 February 1980 Interrogatories Re La Consumer League 791210 TMI-2 Related Amended Contentions Admitted Per ASLB 800111 Order,Under 790925 Stipulation.Requests Identification of PSAR Sections Re QA & Operator Action Allegations.Certificate of Svc Encl ML19294B0811980-02-19019 February 1980 Interrogatories Re Joint Intervenors 791210 TMI-2 Related Amended Contentions,Per 790925 Stipulation.Requests Info on Free Hydrogen Estimate During Emergency & on FSAR Provisions Re Accumulation of Hydrogen.W/Certificate of Svc ML19262C3481980-01-16016 January 1980 Joint Intervenors Response to First Set of Interrogatories & Request for Documents.Includes Info Re Calculations for Demand for Electrical Power & Possible Diminution of Demand. Certificate of Svc Encl ML19262C3391980-01-16016 January 1980 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 ML19262C0731980-01-0404 January 1980 Response to NRC Interrogatories & Request for Documents.Name of Witnesses Who Will Testify in Support of Contentions Will Be Provided When Determined.Includes Info Re Impact on Transmission Lines.Affidavit & Certificate of Svc ML19276H7591979-12-26026 December 1979 Response to La Power & Light Co Interrogatory on Contention 3.Excerpt from La Civil Code & Certificate of Svc Encl ML19253C9261979-11-23023 November 1979 First Set of Interrogatories.Seeks Info Re Contentions 1,2,8,9,12,17 & 19-22 ML19256F8461979-11-19019 November 1979 Interrogatories of La Consumer'S League for Response by Util ML19211A5001979-11-13013 November 1979 Submits Interrogatories Prepared for Util.Requests Info Re Transmission Lines,Draft Emergency Plan & Evaluation of Impact of Gasoline Shortage.Forwarding Ltr Encl ML19211A2191979-11-12012 November 1979 First Interrogatories Directed to Intervenor La Consumers League,Inc,Per 790925 Stipulation.Requests Identification of Statutes by Title & Citations to Judicial Decisions Forming Basis for Contention 3(d).Certificate of Svc Encl ML19211A2251979-11-12012 November 1979 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 1982-09-29
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission ML20065P4121994-04-25025 April 1994 Comment on Proposed Rule 10CFR50 Rule Re Code & Stds Re Subsections IWE & Iwl.Expresses Deep Concern About Ramifications of Implementing Proposed Rule ML20058G6211993-12-0606 December 1993 Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 ML20058B6891993-05-0707 May 1993 Affidavit of RP Barkhurst to File W/Nrc Encl TS Change Request NPF-38-135 ML20058E0251990-10-12012 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20055E9871990-06-29029 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity ML19353B2241989-12-0101 December 1989 Comments on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Util Endorses NUMARC Comments W3P89-0196, Comment Opposing Proposed Rule 10CFR50 Re Maint Programs at Nuclear Plants.Proposed Rule Would Require Establishment of Maint Programs Based on Reg Guides That Have Not Been Developed,Proposed or Approved1989-02-28028 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs at Nuclear Plants.Proposed Rule Would Require Establishment of Maint Programs Based on Reg Guides That Have Not Been Developed,Proposed or Approved ML20235V4571989-02-27027 February 1989 Comment Supporting Proposed Chapter 1 Re Policy Statement on Exemption from Regulatory Control.Agrees W/Recommendations & Limits Proposed by Health Physics Society in L Taylor Ltr to Commission ML20205P9691988-10-26026 October 1988 Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear License Renewal. Supports Contents of NUREG-1317 & Endorses NUMARC Comments on Rulemaking & Position Paper by NUMARC Nuplex Working Group W3P88-1366, Comment Supporting Proposed Rule 10CFR50 Conserning Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants or Utilization Facilities1988-07-13013 July 1988 Comment Supporting Proposed Rule 10CFR50 Conserning Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants or Utilization Facilities ML20135F0931987-04-0909 April 1987 Testimony of Bb Hayes Before Senate Government Governmental Affairs Committee on 870326 Re Discovery of Sensitive NRC Document in Files of Senior Official of Louisiana Power & Light Co ML20212N5781986-08-27027 August 1986 Order Imposing Civil Monetary Penalty in Amount of $50,000 Based on Violations Noted in Insp Conducted on 860101-31. Violation Noted:Plant Entered Mode 3 While Relying on Action Requirements of Tech Spec 3.6.2.1 ML20202G3811986-04-10010 April 1986 Order Imposing Civil Penalties in Amount of $130,000,based on Safety Insps of Licensee Activities Under CPPR-103 Conducted from June 1983 - Sept 1985.Supporting Documentation Encl ML20210B9141986-02-0505 February 1986 Notice of Publication of Encl 841219 Order.Served on 860206 ML20198H4461986-01-30030 January 1986 Memorandum & Order CLI-86-01 Denying Remaining Portion of Joint Intervenors 841108 Fifth & Final Motion to Reopen Record Re Character & Competence of Util Per 850711 Decision ALAB-812.Dissenting View of Palladino Encl.Served on 860130 ML20137J3531986-01-17017 January 1986 Order Extending Time Until 860214 for Commission to Act to Review ALAB-812.Served on 860117 ML20138P5301985-12-20020 December 1985 Order Extending Time Until 860117 for Commission to Review ALAB-812.Served on 851220 ML20137U4821985-12-0505 December 1985 Order Extending Time Until 851220 for Commission to Act to Review ALAB-812.Served on 851205 ML20138S0051985-11-15015 November 1985 Order Extending Time Until 851206 for Commission to Review ALAB-812.Served on 851115 ML20138H2451985-10-24024 October 1985 Order Extending Time Until 851115 for Commission to Act to Review ALAB-812.Served on 851024 ML20133F2711985-10-0404 October 1985 Order Extending Time Until 851025 for Commission to Act to Review ALAB-812 .Served on 851007 ML20134L5981985-08-28028 August 1985 Notice of Appearance of R Guild & Withdrawal of Appearance by L Bernabei & G Shohet for Joint Intervenors.Certificate of Svc Encl ML20137J2801985-08-26026 August 1985 Answer in Opposition to Joint Intervenors 850809 Petition for Commission Review of Aslab 850711 Decision ALAB-812, Which Denied Joint Intervenors 841108 Motion to Reopen Record.Kw Cook 850821 Affidavit Encl ML20137J2941985-08-21021 August 1985 Affidavit of Kw Cook Re Recent Equipment Failures Discussed in Joint Intervenors 850809 Petition for Review.Certificate of Svc Encl ML20136J1961985-08-19019 August 1985 Answer Requesting That Commission Deny Joint Intervenors 850809 Petition for Review of ALAB-812 Denying Motion to Reopen QA & Character Competence Issues.Certificate of Svc Encl ML20133L8901985-08-0909 August 1985 Petition for Review of ALAB-812,denying Joint Intervenor Motion to Reopen Record of OL Hearing to Litigate Util Lack of Character & Inability to Assure Safe Operation in Light of Const QA Breakdown.Certificate of Svc Encl ML20133L0421985-08-0808 August 1985 Order Extending Time Until 850920 for Commission to Act to Review ALAB-812.Served on 850808 ML20128Q1861985-07-23023 July 1985 Request for Extension of Time Until 850809 to File Appeal to 850711 ALAB-812 Denying Joint Intervenors Motion to Reopen Record.Certificate of Svc Encl ML20209F1921985-07-11011 July 1985 Decision ALAB-812 Denying Joint Intervenors 841108 Motion to Reopen Record on Const QA & Mgt Character & Competence, Except Insofar as Issues Re Matters Under Investigation by Ofc of Investigation Are Raised.Served on 850711 ML20116P1931985-05-0606 May 1985 Response to NRC & Util Responses to Aslab 850322 Memorandum & Order ALAB-801.Motion to Reopen Record of Licensing Proceedings for Litigation of Util Competence Should Be Granted.Supporting Documentation & Svc List Encl ML20116H3341985-04-30030 April 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20100K3221985-04-10010 April 1985 Supplementary Comments Attesting to Validity of Statements of Fact in Sser 9 & Clarifying & Explaining Current Position on Resolution of Allegation A-48.Util Can Safely Operate & Manage Facility.Certificate of Svc Encl ML20111C7021985-03-14014 March 1985 Affidavit of RP Barkhurst Re Power Ascension Testing Program to Be Performed at Levels Above 5% of Rated Power.Facility & Operating Staff in Excellent State of Readiness to Proceed W/Power Ascension ML20112A9381985-03-14014 March 1985 Affidavit of RP Barkhurst Re Power Ascension Testing Program Performed at Levels Above 5% Rated Power & Delay in Issuance of Full Power Operating Authority.Related Correspondence ML20111B6541985-03-12012 March 1985 Motion for Leave to File Reply to Applicant Answer to Joint Intervenors Motion for Leave to File Supplemental Memorandum & Applicant Response to Supplemental Memorandum.Svc List Encl ML20102C1351985-02-28028 February 1985 Response Opposing Joint Intervenors 850225 Motion for Leave to File Supplemental Memorandum & Response to Suppl.Suppl Untimely Filed.Allegations Unsupported.Certificate of Svc Encl ML20195F5871985-02-25025 February 1985 Affidavit of Rk Kerr Re 841120 Meeting W/Cain,Dd Driskill, R Barkhurst,Admiral Williams & Rs Leddick to Discuss Licensee 1983 Drug Investigation 05-001-83(966) & 841206 Meeting Between Licensee & NRC in Arlington,Tx ML20107M7461985-02-25025 February 1985 Supplemental Memorandum in Support of Joint Intervenors Motion to Reopen.Determination by Aslab That Joint Intervenors Met Burden to Reopen Record for Litigation of Contention That Util Mgt Lacks Competence Requested ML20107M7321985-02-25025 February 1985 Motion for Leave to File Supplemental Memorandum in Support of Motions to Reopen.Request Based on Recent Public Repts Re Instability & Lack of Independence of Mgt of Applicant & Lack of Respect for NRC ML20101T3701985-02-0101 February 1985 Answer Opposing Joint Intervenors 850125 Motion for Leave to File Reply to Applicant 841130 & Staff 841221 Answers.Motion Should Be Denied & Reply Brief Rejected.Certificate of Svc Encl ML20101U3411985-01-25025 January 1985 Joint Intervenors Motion for Leave to File Reply to Applicant & NRC 841221 Responses to Joint Intervenors 841108 Motion to Reopen Three QA & Mgt Integrity Contentions for Litigation ML20101U3511985-01-25025 January 1985 Joint Intervenors Reply to Applicant & NRC 841221 Responses to Joint Intervenors 841108 Motion to Reopen Three QA & Mgt Integrity Contentions for Litigation.Certificate of Svc Encl 1996-08-07
[Table view] |
Text
. , _
.. RELATED_ C_0RRESPONDENCR August 13, 1981 4
UNITED STATES OF AMERICA k NUCLEAR REGULATORY COMMISSION '
f*
IDE y AUG 141981 > IG.
Before the Atomic Safety and Licen_s_ing Board 1 0
, Ar.a In the Matter of ) /Iy \
)
LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382
)
(Waterford Steam Electric ) G Station, Ut?.t 3) ) ' ~t
($ph) Wh APPLICANT'S INTERROGATORIES TO LOUISIANA CONSUMER'S LEAGUE, INC.9
[ [
/;l (SECOND SET)
y.- N 7 {\
Pursuant to 10 C.F.R. S 2.740b, Louisiana Power and Light Company (" Applicant") submits the following interroga-tories to be answered separately and fully in writing under oath or affirmation by Louisiana Consumer's League, Inc.
("LCL"). In accordance with paragraph 3 of the September 25, 1979 Discovery Stipulation, these interrogatories relate to new information in the NRC Staff's Safety Evaluation Report Related to the Operation of Waterford Steam Electric Station, Unit No.
3 ("SER") bearing on allowed Contentions. Pursuant to para-graph 5 of the Discovery Stipulation, these interrogatories must be answered within 30 days, and any objections to the N interrogatories must be made within 15 days. Answers and / l objections must be served on all parties and the Licensing Board.
-8108190186 810813 DRADOCK05000g
O.
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1 INTERROGATORIES ON CONTENTION 3 i
l 3-1. Does LCL contend that the arrangements made by Applicant for traf fic ' control, and in particular the agreement between Applicant and the United States Coast Guard for traffic control on the Mississippi River (SER S 2.1.2) do not consti-tute " appropriate and effective arrangements . . . to control traffic" as required by 10 C.F.R. S 100.3(a)?
3-2. If the answer to the preceding interrogatory is affirmative, state in detail all facts that support LCL's contention that Applicant has not provided for appropriate and effective arrangements to control traffic within the exclusion area.
3-3. If the answer to Interrogatory No. 3-1 is affirmative, identify by author, title and date all documents upon which LCL relies in contending that Applicant has not provided for appropriate and effective arrangements to control traffic within the exclusion area.
3-4. If the answer to Interrogatory No. 3-1 is affirmative, identify all persons whom LCL expects to testify
)
on its behalf concerning its contention that applicant has not provided for appropriate and effective arrangements to control traffic within the exclusion area.
3-5. The SER (S 2.1.2) states that up to ten people may be fishing within the exclusion area at any given time.
Does LCL contend that such usage will prohibit Applicant from controlliag activities within the exclusion area?
- 6. If tho' answer to the preceding interrogatory is affirmative, state in detail all facts that support LCL's contention that such usage will prohibit Applicant from controlling activities within the exclusion area.
3-7. If the answer to Interrogatory No. 3-5 is affirmative, identify by author, title and date all documents upon which LCL relies in contending that uch usage will proh'ibit Applicant from controlling activities within the exlcusion area.
3-8. If the answer to Interrogatory No. 3-5 is affirmative, identify all persons whom LCL expects to testify on its behalf concerning its contention that such usage will prohibit Applicant from controlling activities within the exclusion area.
3-9. State whether LCL contends that the SER (S 2.1.2) is incorrect in stating that, with regard to activi-ties within the exclusion area not related to the operation of Waterford 3, "these activities . . . will not interfere with normal operation of the nuclear facility. The Applicant has the authority to control such activities and has described 4
procedures to be followed for these activities in the event of an emergency," and that " Applicant has the requisite authority
l l
. 1 over -the entire exclusion area as defined in 10 C.F.R.
S 100.3(a)."
3-10. If th'e answer to the preceding interrogatory is affirmative, state in detail all facts that support LCL's contention that Applicant has not demonstrated that it can ,
control activities in the exclusion area as required by 10 C.F.R. S 100.3(a).
3-11. If the answer to Interrogatory No. 3-9 is affirmative, identify by author, title and date all documents upon which LCL relies in contending that Applicant has not demonstrated its ability to control activities in the exclusion area as required by 10 C.F.R. S 100.3(a).
3-12. If the answer to Interrogatory No. 3-9 is affirmative, identify all persons whom LCL expects to testify on its behalf concerning its contention that Applicant has not demonstrated that it can control activities in the exclusion area as required by 10 C.F.R. S 100.3(a).
3-13. State separately for each answer to the preceding interrogatories on Contention 3 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.
t
INTERROGATORIES ON CONTENTION 4 4-1. The SER (S 13.3.2.10) states that the Waterford 3 Emergency Plan contains. provisions for recommending offsite
, protective measures, including evacuation, depending on projected dose to the environs,and includes maps and informa-tion regarding evacuation routes, areas, shelters and area population distribution. Does LCL contend that these provi-sions do not include recommendations for evacuating the low population zone?
4-2. If the answer to the preceding interrogatory is affirmative, state in detail all facts that support LCL's contention that no provisions have been made for evacuating the low population zone.
4-3. If the answer to Interrogatory No. 4-1 is affirmative, identify by author, title and date all documents upon which LCL relies in contending that Applicant has failed to make provisions for evacuating the low population zone.
4-4. If the answer to Interrogatory No. 4-1 is affirmative, identify all persons whom LCL expects to testify on its behalf concerning its contention that Applicant has failed to make provisions to evacuate the low population zone.
4-5. State separately for each answer to the preceding interrogatories on Contention 4 the name, address,
- . j employer, position and qualifications of the person or persons drafting the answer and, if different, of the person or persons supplying the informat, ion upon which the answer was based.
INTERROGATORIES ON CONTENTION 6 6-1. The SER (S 6.3.2) states that a failure modes 4
and effects analysis was presented by the Applicant covering 1
the mechanical equipment in the ECCS. This analysis indicated that no single active failure could prevent the ECCS from fulfilling its short- and long-term functions. Does LCL contend that a postulated operator error during a loss of coolant accident ("LOCA") would have more severe effects upon the capability of the ECCS to perform its core cooling func-tions than the active failures analyzed by Applicant?
6-2. If the answer to the preceding interrogatory is affirmative, state in detail all facts that support LCL's contention that a postulated operator error during a LOCA would nave more severe effects upon ECCS capability than the analyzed active failures.
6-3. If the answer to Interrogatory No. 6-1 is affirmative, identify by author, title and date all documents
, upon which LCL relies in contending that a postulated operator error during a LOCA would have more severe effects upon ECCS 4
capability than the analyzed active failures.
c_
1 ,
6-4. If the answer to Interrogatory No. 6-1 is
affirmative, identify all persons whom LCL expects to testify on its behalf concerning its contention that a postulated operator error during a LOCA would have more severe effects upon ECCS capability than the analyzed active failures.
6-5. State separa*.ely for each answer to the preceding interrogatories on Contention 6 the name, address, emplo'yer, 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 AMENDED CONTENTION (TMI-RELATED) l lA-l. Appendix C of the SER (at C-12, 13) discusses the current status of the Staf f's ef forts towards resolving generic task A-17, " Systems Interaction in Nuclear Power Plants," and concludes:
It is expected that the development of sys-tematic ways to identify,' rank, and evaluate systems interactions will go further to reduce the likelihood of intersystem failures resulting in the loss of plant safety func-tions. However, the studies to date indicate that current review procedures and criteria supplemented by the application of post-TMI findings and risk studies provide reasonable assurance that the effects of potential
. systems interactions on public safety will be within the effects on public safety pre-viously evaluated.
Therefore, the staff concludes that there is reasonable assurance that Waterford 3 can be operated before the final resolution of this generic issue without endangering the health and safety of the public.
l
..._--% _ _ . - . . . _ . . ,_.e-y,- , , . , . . , _ - - , _ . . , . -g..
F. .
State whether LCL disagrees with this statement.
1A-2. If the answer to the preceding interrogatory is affirmative, state'in detail all facts that support LCL's contention that Waterford 3 cannot be operated pending final resolution of this generic issue without endangering the health and safety of the public.
lA-3. If the answer to Interrogatory No. lA-1 is affirmative, identify by author, title and iate all documents upon which LCL relies in contending that Waterford 3 cannot be operated pending final resolution of this generic issue without endangering the health and safety of the public, lA-4. If the answer to Interrogatory No. lA-1 is affirmative, identify all persons whom LCL expects to testify on its oehalf concerning its contention that Naterford 3 cannot be operated pending final resolution of this generic issue without endangering the health and safety of the public.
lA-5. State separately for each answer to the preceding interrogatories on Amended Contention (TMI-Related)
- 1 the name, address, employer, position and qualifications of the person or persons draftirig the answer and, if different, of the person or persons supplying the information on which che I answer was based.
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. . ]
l INTERROGATORIES ON AMENDED CONTENTION (TMI-RELATED) 4 4A-1. Table 15.8 of the SER states that, with respect to the dose ca'lculations performed for a postulated LOCA, it was assumed that 50% of the iodine and 100% of the noble gases were released to the containment. Does LCL contend that thesa fission product releases are less than those which occurred during the Three Mile Island Unit 2 accident?
4A-2. If t"e answer to the preceding interrogatory is affirmative, statt in detail all facts that support LCL's contention that fission product releases to the containment assumed for a postulated LOCA, as set forth in Table 15.8 of the SER, are less than those that actually occurred during the Three Mile Island Unit 2 accident.
4A-3. If the answer to Interrogatory No. 4A-1 is affirmative, identify by author , title and date all documents upon which LCL relies in contending that the assumed fission product releases to the containment' for a postulated LOCA, as set forth in Table 15.8 of the SER, are less than those that actually occurred during the Three Mile Island Unit 2 accident.
4A-4. If the answer to Interrogatory no. 4A-1 affirmative, identify all persons whom LCL expects to testify on its behalf concerning its contention that the assumed fission product releases to the containment for a postulated LOCA, as set forth in Table 15.8 of the SER, are less than
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those that actually occurred during the Three Mile Island Unit 2 accident.
4A-5. State' separately for each answer to the preceding interrogatories or. Amended Contention (TMI-Related) 4 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 on which the answer was based.
1 DATED: August 13, 1981.
Respectfully submitted, SHAN, PITTMAN, POTTS & TRONBRIDGE 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 By: -
f Ernest L. Blake, Jr.
James B. Hamlin Counsel for Applicant ,
f..
August 13, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4
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) )
l CERTIFICATE OF SERVICE
-t F
I hereby certify that copies of Applicant's Interrogatories To Louisiana Consumer's League, Inc. (Second Set) , dated August 13, 1981, were served upon those persons on the attached Service List, by deposit in the United States mail, postage prepaid, this 13th day of August, 198,1.
f - J h, Ernest L. Blake, Jr.~
DATED: August 13, 1981.
4 l
UNITED STATES OF AMERICA NUCLETR REGULATORY COMMISSION Before the Atom'i c Safety and Licensing Board In the Matter of )
-)
LOUISIANA POWER & LIGHT COMPANY ) Dc7ket No. 50-382
)
(Waterford Steam Electric )
Station, Unit 3)- )
SERVICE LIST Sheldon J. Wolfe, Esqui re 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 Population Studies Baton Rouge, Louisiana 70802 Box 395, Mayo University of Minnesota Luke B. Fontana .
Minneapolis, Minnesota 55455 824 Esplanade Avenue l New Orleans, Louisiana 70116
) Dr. Walter H. Jordan 1
881 West Outer Drive Atomic Safety and Licensing Oak Ridge, Tennessee 37830 Board Panel U.S. Nuclear Regulatory Jcseph R. Gray, Esquire Commission 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 i Docketing and Service Section (3) Washington, D.C. 20555 Office of the Secretary ,
U.S. Nuclear Regulatory Commission
- Washington, D.C. 20555 s
1 1
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