ML19323D809

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

ML19323D809
Person / Time
Site:	Waterford
Issue date:	04/24/1980
From:	Larry Jones GILLESPIE & JONES, OYSTERSHELL ALLIANCE, INC., SAVE OUR WETLANDS, INC.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8005220366
Download: ML19323D809 (5)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 5' APR 2 919ED * }

Ciliatf theSc?efety 6 hueting & Service BEFORE TIIE ATOMIC SAFETY & LICENSING BOARD Branch Y V 1-In the Matter of *

LOUISIANA POWER & LIGIIT COMPANY Docket No. 50-382 (Waterford Steam Electric Station ,

Unit 3)

JOINT INTERVENORS ANSWERS TO NRC STAFF SUPPLEMENTAL INTERROGATORIES Now before the Atomic Safety & Licensing Board comes, Joint Intervenors, Oystershell Alliance, Inc. and Save Our Wetlands, Ille., and give answer to the Commission's Staff Supplemental Interrogatories, dated February 19,1980, as foHows:

25.1 Any non-zero amount of fuel melting requires remedial action.

Uranium oxide fuel melts at 5200 F, an unacceptable temperature.

27.2 " Nuclear Emergency" means any radiological incident that requires utility employees or the general public to take protective action.

27.3 Radiation monitors that will not go off scale or ' pegged' during a Class Nine accident. This problem is discussed in Section 2.1.8.6 of

" Discussion of Lessons Learned Short Term Requirements."

27.4 Regulatory rules require " adequate" radiation monitoring for a 10 mile radius plume pathway and a 50 mile ingestion pathway. Refer to NUREG-0396, December,1978. Joint intervenors believe these figures will be scaled upward.

29.5 "NRC mandated TMI-based changes" are still being promulgated as new information is digested. The main references for this are:

(1) NUREG-0578 f

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(2) NUREG-0585 (3) " Discussion of " Lessons Learned Short Term Requirements" (4) Nuclear Regulatory Commission SpecialInquiry Group (5) Report of the President's Commission on The Accident at Three Mile Island.

Joint Intervenors believe a definitive listing of "NRC mandated TMI-based changes"is premature.

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Respectfully Submitted, GILLESPIE & JONES l

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& f LYS YL. JON ES, J .

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14 Veterans Blv Suitef01 A tairie, Louisia 70005 (504) 835-6458 l

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April 24,1980 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 the Commission's Staff Supplemental Interrogatories are true and correct to the best of his knowledge, information and belief.

I.n . snsk

' GARY JZ GROESCIV /

Sworn to and subscribed before me, Notary, this 24th day f April,19

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

CERTIFICATE OF SERVICE

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I hereby certify that on April 24, 1980, I mailed copies of Save Our Wetlands, Inc. and Oystershell Alliance, Inc.'s, JOINT INTERVENORS ANSWERS TO TIIE COMMISSION'S STAFF SUPPLEMENTAL INTERROGATORIES to all individuals or entities appearing on the attached Service List, postage prepai irst class in the United States 1 Mail. I

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IgMAN . JON F;6, 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. IIarry Foreman Box 395, Mayo University of Minnesota 55455 Dr. Walter II. 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 IIenry J. McGurren, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C. 20555

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George F. Trowbridge, Esquire

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

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

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