ML20024J293

Forwards Cajun Electric Power Cooperative,Inc Further Responses to Gsu Discovery Requests.Related Correspondence

ML20024J293
Person / Time
Site:	River Bend
Issue date:	09/30/1994
From:	Rudebusch T CAJUN ELECTRIC POWER COOPERATIVE, INC., DUNCAN, WEINBERG, MILLER & PEMBROKE, P.C. (FORMERLY
To:	Wetterhahn M GULF STATES UTILITIES CO., WINSTON & STRAWN
References
CON-#494-15766 OLA, NUDOCS 9410130163
Download: ML20024J293 (28)

Text

-

/5744 wmummuw Wau- u%i wAu Ac t L. ouNcAN trintst; "dik ,a h?*' f ?MbY' f; b,h, towano witNSERG

-I - DM"b"8 t a s JAMES D PEMBRoEE SUITE BOO 4

"'"t a ' *t "s ac c

,9 pic w uoN o ' ^u'N 20 McC ANDLE ss towtas acerpt weisstac 1615 M S T R E ET, N . W. 3, 3 ,,,,oo ,e,,,tg J ANIC C L. low E R WASHIN GTON, D. C. 20036

/ ef sorrnty c.ccNica ( 5*N'a CL'aa c^uroaNia esos4 THOM AS L RUDtsuSC M (;t 8.oe) see-440 u,c ,cL p.posTAn 'aoa 4e7-e27 vans 4 - swoNawiLca Q .4d/$' /$

,coccopy,,e... 7. 37, ,,co ,,u,,u, ,,,,,,

ouN st t September 30, 1994 ' 2 ' 5' a "" 3 ' 8 racoca cn t. u, u c a. ;o.

T mom AS J. LTNCH ArcHARDM. p[L2 9 "a aolo

• a c c o u s s. s a. IJAND DELIVERY or covasu

? ADM8?TED IN WASHINGTON ONLY Mark J. Wetterhahn, Esq.

Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005 Re: Gulf States Utilities Company, (River Bend Station), NRC Docket No. 50-458-OLA

Dear Mr. Wetterhahn:

I enclose Cajun Electric Power Cooperative, Inc.'s further Responses to GSU's Discovery Requests.

Please call if you have any questions.

Sincerely, lr D.

e A D_.

_ J_ W Thomas L. Rudebusch

, Enclosure cc: lionorable Richard F. Cole (by mail) lionorable Peter S. Lam ( "")

lionorable B. Paul Cotter, Jr.( " " )

Ann P. Hodgdon, Esq. " "

( )

Robert B. McGehee, Esq. ""

( )

John Schwab, Esq. " "

( )

9410130163 940930 PDR ADOCK 05000458 Q PDR }f'q'

Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company Docket No. 50-458-OLA

1. Identify each and every safety issue, concern, or allegation (individually or collectively " matter") related to the operation of River Bend station that has ever been identified, or raised by Cajun to GSU, EOI or NRC (state which). For each such matter raised, identify the following:

a. A detailed description of the nature of the issue, concern or allegation.

b. The manner in which the safety of the facility was asserted to be or could be affected.

c. Any rule, regulation, license or NRC guidance or licensee commitment which was violated or threatened to be violated.

d. The structure, system and/or component to which the issue related, giv ng all specifics such as system or component identifying mark or number shown on the component or relevant engineering drawings, figures, or ,

diagrams.

c. The date on which the matter was discovered or identified.

f. The date the matter was reported to GSU, EOI and/or the NRC, and the person to whom it was reported. <

g. The persons discovering the matter.

h. The manner in which the matter was discovered or identified, e.o., plant tour, review of drawings or documents.

i. The person reporting the matter to GSU, EOI and/or the NRC.

j. The name of each and every person who gave further information, opinion, or conclusions concerning that matter to Cajun, GSU, EOI and/or the NRC, and a description of such communication and an identification 4 of any written communication.

k. Describe the resolution of the matter proposed by GSU or EOI and if such resolution was not deemed satisfactory by cajun so state, describing why the resolution was unsatisfactory in relation to applicable rules and regulations of the NRC and the River Bend operating License.

1. If the issue is still pending, state the status of the matter.

m. Identify all documents associated with each matter  ;

identified. ,

i l

l l

l l

l Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company Docket No. 50-458-OLA ,

RESPONSE ,

In addition to Cajun's pleadings in this case, During the '-

spring of 1988, Larry Johnson of Cajun informed the River Bend Plant Manager, Tom Plunkett, Pete Freehill and Ken Suhkre, all of Gulf States, there was a possible problem with the service water lines providing cooling water to the hydrogen coolers. Mr. Johnson reported this potential problem as a result of a plant tour during a refueling outage.

PREPARER Victor J. Elmer I

b I

l

. l Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company l Docket No. 50-458-OLA

2. For each such Cajun individual identified in Interrogatory 1, provide:

I

a. Full name, address, telephone number, employer, employer's address, date of birth, education, employment experience, a description of all training in scientific and technical disciplines.

b. A description of his expertise in the operation of nuclear power plants, including the areas of expertise I claimed.

c. An identification of the nuclear power plants at which )

such individual has been employed, been a consultant or provided consulting services, the dates on which those services were performed, the facility, the entity to which such services were provided and whether such individual had unescorted access at such facility.

d. An identification of all NRC licenses held and the dates on which such licenses were active.

RESPONSE ,

Larry G. Johnson 10829 Danbury Baton Rouge, LA 70809 DOB: 11-22-50 Education: B.S. Mechanical Engineering Work Experience prior to joining Cajun:

Middle South Utilities - Mississippi Power & Light Co. Grand Gulf Nuclear Station Contracts and Construction Superintendent. In charge of contracts and plant modification in a 1250 MW nuclear power plant (BWR). This position involves coordination, planning and scheduling of .

both outage and non-outage work efforts. Responsibilities include organizing contractor personnel and their facilities to support both maintenance and design change package work,  !

especially during outages. This assignment is a front-line field position requiring daily interface with both the contractor and upper management. The administrative portion of this position involves supervising contract administrators, procedure development, budget analysis, and tracking mechanisms to ensure that the proper tools are in place to carry out and control the contractor work effort on plant modification and maintenance packages.

Middle South Services, Inc. - New Orleans, LA Mechanical Field Encineer (6/84 to 2/86). Assigned to the Task Force initiating the Plant Modification and Outage Section of a

_ =._ _

9 Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company Docket No. 50-458-OLA 1240 MW nuclear power plant (BWR). The assignment was to establish this organization and to have it in place as soon as possible to support plant outage efforts. Once this group was established, I continued working within it by being involved with the planning and implementation of the Ten-Year (ISI) plan and the IHSI efforts on Recirculation system. Mechanical Field Enaineer (11/81 to 6/84).

Assigned to the Containment /Drywell area of a 1250 MW nuclear power plant (BWR) as a contractor coordinator.

Activities involved monitoring construction and QA efforts in this area and coordinating the Preservice/ Inservice inspection of the Reactor Pressure Vessel.

Power Systems, Inc. - Schaumberg, Illinois, Assistant Pipina Superintendent (10/80 to 11/81). F"pervised craft in the installation of piping systems in a 560 MW coal-fired power plant. I also participated in the bid, procurement, and subcontract phase of this project. Instrument Superintendent (10/78 to 10/80). Supervised craft in the mechanical installation of all instrumentation in a 600 MW coal-fired power plant.

PREPARER Victor J. Elmer i

l 1

. .4 4

Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company pocket No. 50-458-OLA

3. Identify every Cajun representative having unescorted access to the River Bend site since operation has begun. Provide the following information for each such person identified:

a. Name, title, employer, education, training, professional or technical experience in nuclear power operation, dates on which individual had unescor*ed access, badge number, if known.

b. Duties and responsibilities of such individual having unescorted access at the River Bend, the dates on which such individual visited or worked at River Bend, any efforts exerted by such individual to seek out safety _

issues, the periods that the individual accessed the nrotected area, the restricted area, vital areas and/or radiologically controlled areas.

c. Any safety issues, concetns or allegations observed or identified by such individual and identify any documents associated with each.

RESPONSE

a. & b.

Larry Johnson - See response to No. 2 Bill Curren - Nuclear Operations Coordinator (now works for Entergy at River Bend)  !

Will Day - Cost Specialist Phillip G. Harris - Chief Systems Officer (no longer employed by Cajun)

Jack M. Miller - Director, System Planning Layne McKinney - Joint Operations Director Gary Hall - Vice President and Corporate Controller Joe Gore - Consultant All Cajun employees can be reached at:

10719 Airline Highway ,

Baton Rouge, LA 70816 Additional research is being conducted.

b. This information is available at the River Bend site.  ;

Cajun has requested this data,

c. See response to No. 2.

PREPARER Victor J. Elmer

Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilitiec Company Rqgket No. 50-458-OLA

4. Identify the individuals associated with Cajun who have had escorted access to the River Bend Station. For each such individual, state the dates on which they had escorted access, whether the escort was provided by Cajun or GSU or EOI, the nature of any safety-related matters or matters important to safety (collectively " safety matters") which were discussed in the presence of such individuals, a description of the substantive way which such individuals contributed to identification of or discussion of safety matters. Identify all documents prepared by such individuals relating to their identification of safety issues, concerns or allegations.

RESPONSE

1. Larry Celestine

2. William L. Curran i

3. William S. Day

4. JD Gore

5. Gary F. Hall

6. Larry G. Johnson

7. Sonia B. LeCoq

8. Lester L. McKinney

9. Lester J. Migues, Jr.

10. Jack M. Miller

11. Don M. Mosier

12. Mikel L. Nesom

13. James M. Purtle

14. Vaughn M. Reynolds

15. Vernon W. Webb

16. Charles W. Wright Off and on since July 1990 the following Cajun paralegals visited the River Bend site on various occasions for discovery purposes:

1. Archie Kranske l

2. Natka Boyd

3. Wendy Decker

4. Lisa Goings

5. Margaret Stephens

6. Sharon (Driver) Cologne ]

7. Cavery Uthappa

8. Robert Bonney

9. Karen Emmich

10. Ginger Alumbaugh Listed below are some of the trips made to River Bend by Cajun's attorneys and consultants:

I 1

l l

l Cajun Electric Power Cooperative, Inc.'s, l Responses to First Set of Interrogatories of Gulf States Utilities Company  ;

Docket No. 50-458-OLA Date Company Fames February 1, 1989 Robert Perkins Cajun Electric John Riley Canatom Corp.

Jack Hazan Canatom Corp.

November 1989 Don Mor.ier Chartec November 21, 1990 Don Mosier Chartec March 6, 1990 Don Mosier Chartec March 8, 1990 Don Mosier Chartec Gordon Lorimer Canatom March 9, 1990 Don Mosier Chartec Week of Feb. 23, 1990 Don Mo3ier Chartec Gordon Lorimer Canatom Corp.

March 30, 1990 Jack Hazen Canatom Corp.

January 7, 1991 Don Mosier Chartec Neil Craik Canatom Corp.

January 21, 1991 Don Mosier Chartec January 22, 23, 24, 1991 Don Mosier Chartec January 23, 24 Neil Craik Canatom Corp.

Week of Jan. 25, 1991 John Riley Canatom Corp.

Gordon Lorimer Canatom Corp.  ;

April 9, 10, 1991 William Messersmith, G. Alex Weller, Joseph McReynolds, Michael Farrell, William Kohler, Allen Campbell, Michael Bell, Victor Stilwell, Larry Moriarty, Ken Biron, John Treiber, Gordon Lorimer, '

John Riley, Lorne Phillips, Don Mosier, Frederick Bott, David Campbell July 7, 1991 Dennis Johnson July 12, 1991 Gordon Lorimer Canatom Corp.

John Riley Canatom Corp.

John Treiber Canatom Corp.

Larry Moriarty Canatom Corp.

Lorne Phillips Canatom Corp.

Ken Biron Canatom Corp.

i j

Cajun Electric Power Cooperative, Inc.'s, I Responses to First Set of Interrogatories of j Gulf States Utilities Company (

Docket No. 50-458-OLA July 24, 1991 Tolbert Young Ernst & Young July 26, 1991 Dale Bridenbaugh MHB Technical Asso.

November 20, 1991 Don Mosier Chartec I

January 29, 1992 Richard Hubbard MHB Technical Asso.

March 16, 1992 Marty Cuerdon A2S Chuck Soppet Atlas Consulting B. D. Harvey Cajun Electric Kevin Boyd AES March 31, 1992 B. D. Harvey Cajun Chuck Soppet Atlas Consulting Marty Cuerdon A2S John Kirby (?) Atlas Consulting Week.of Nov. 14, 1992 Dennis Johnson Cajun Electric B. D. Harvey Cajun Electric July 15, 16, 1992 Richard Kelly Atlas Consulting July 15, 16, 1992 Richard Bonney Cajun Electric August 1992 Richard Kelly Atlas Consulting August 11 - 13, 1992 Richard Bonney Cajun Electric Week of Jan. 24, 1994 Neil Craik Canatom Corp.

Don Mosier Chartec April 14, 1994 Dennis Connolly Alston & Byrd April 14, 1994 Hunter Holliday Alston & Byrd April 14, 1994 Beth Kirby Alston & Byrd April 14, 1994 Scott Mayfield Alston & Byrd April 14, 1994 Jennifer Moore Alston & Byrd April 14, 1994 Ron Reid Alston & Byrd April 14, 1994 Frank Smith Alston & Byrd PREPARER Victor J. Elmer

1 Cajun Electric Power Cooperative, Inc.'s, ,

Responses to First Set of Interrogatories of l Gulf States Utilities Company Docket No. 50-458-OLA t

5. Identify employees of Cajun, its agents or consultants who met with GSU, its employees, EOI, EOI employees, their +

contractors, or any tier of subcontractor, with regard to any safety matter, stating the place and date of the meeting, the names of all individuals present, a detailed description of the specific safety matters discussed, the  ;

resolution of such safety matters, to the extent Cajun knows, the contribution of Cajun to the discussion or resolution of such safety matters, and any followup by Cajun with regard to such safety matters. Identify all documents prepared by Cajun associated with such issues.

RESPONSE

See Response to No. 1.

i PREPARER Victor J. Elmer i

6 Y

i l

l 1

l i

l

t Cajun Electric Power Cooperative, Inc.'s, f

Responses to First Set of Interrogatories of Gulf States Utilities Company {;

pocket No. 50-458-OLA

6. Identify all documents prepared by Cajun representatives I reviewing the operation of River Bend relating to operation, ,

safety, funding of safe operation or decommissioning of the  !

unit. ,

RESPONSE

I t

Cajun Electric Power Cooperative, Inc., i Decommissioning Analysis River Bend Nuclear Facility (Prepared by Russ Wasson in 1985 from GSU-provided data.)

PREPARER Victor J. Elmer ,

5 4

I t

i l

T S

i l

L i

1

, ,- _ ~

. . - - . . . . ~

Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company Docket No. 50-458-OLA

7. Identify each meeting with the NRC, its employees or agents i relating to safety matters at which Cajun was represented j through its directors, officers, employees, Members, j consultants, contractors, counsel or other agents. For each  !

such meeting, state the names of the NRC employees present, i the date of the meetings, the subject matter of the meeting, I the substantive contribution of Cajun to the discussion of ,

safety matters, if any, and the resolution of any such  ;

safety matters raised by Cajun. Identify all documents prepared by Cajun associated with such meetings.

RESPONSE

See Response to No. 10.

PREPARER Victor J. Elmer i

1 6

I I

i i

Cajun Electric Power Cooperative, Inc.'s, '

Responses to First Set of Interrogatories of Gulf States Utilities Company Docket No. 50-458-OLA

8. Describe each communication between Cajun and the NRC i employees or agents relating to substantive safety matters.

For each such instance, state the names of the NRC employees with whom such communications occurred, state the date of [

the communication, state the subject matter of the  !

communication, the substantive contribution of Cajun to the l communication of any safety matters, and the resolution of -i any such safety matters.

RESPONSE

See Response to No. 10. l t

PREPARER Victor J. Elmer i

)

t b

I i

e i

4 t

i I

I r

i i

i

=_- - - _ = .

i t

l Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company Docket No. 50-458-OLA (

i

9. Describe any systematic plan or procedure for review by ,

Cajun or its consultants of safety matters arising at River (

Bend, identifying any document associated with such plan or  ;

procedure, the author of such document or plan, anyone  ;

reviewing or concurring in such document, when it was '

prepared, the dates of any amendments thereto, the dates on l which it was implemented, and any safety matters evaluated,  :

discovered or dispositioned in accordance with such procedure or plan.

EESPONSE i Cajun has prepared a Comprehensive Monitoring Program

(" CMP") for review by Cajun or its consultants of safety matters arising at River Ben _. The CMP is intended to provide timely information about the performance of River [

Bend and the quality of its operations. The CMP also  !

i provides insight as to how well the facility is operating relative to its peers. It also provides an understanding i for expenditures made by GSU to support plant operations, provides guidance to GSU as to Cajun's position as it '

relates to plant operations, is intended to ensure that the operation of River Bend is fully integrated into Cajun's operation, and provides for the representation of Cajun cr.

site et River Bend.  !

The CMP provides for field observations, attendance at selected meetings and review of selected documents. It also provides for statistical analysis involving performance trends, operations and maintenance practices, outage management, system design / equipment improvements and personnel training. CMP involves the development of a '

computer data base and analysis and the comparison of plant ,

data to other plants. Finally, CMP involves accounting,  !

auditing, budgeting, contract administration, compliance reviews and management reviews.  !

l PREPARER Victor J. Elmer I l

1 1

4 Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilitie.- Company Docket No. 50-458-OLA

11. Describe any limitations in access to River Bend or to information regarding safe operation which existed prior to December 31, 1993.

RESPONSE

Cajun was denied access to INPO information.

PREPARER Victor J. Elmer 4

4 l

l l

l i

I

~

i l

l l

l

Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company Docket No. 50-458-OLA

13. Identify the additional documents, records, and River Bend operational or safety data Cajun asserts it needs to assure safe operation of the facility. Identify how each such document or communication would be utilized to assure safe operation of the facility.

RESPONSE

f Cajun needs access to INPO field notes, final evaluation and exit meetings with the Plant manager.

PREPARER Victor J. Elmer

{

I t

P

]

l Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of ,

Gulf States Utilities Company Qpcket No. 50-458-OLA .

15. Identify the River Bend cost management and regulatory  ;

reports Cajun contends must be submitted or made available to it to assure safe operation of the facility. Describe how each such report is necessary to assure the safety of the facility.

1

RESPONSE

Cajun requires any regulatory reports which identify topics or issues related to safe operation of the facility and all cost management documents which address how the topics and F

issues will be addressed.

EREP_AREE Victor J. Elmer  !

[

a l

i i

r 5

i t

Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company Rocket No. 50-458-OLA

16. Identify the Institute for Nuclear Power Operation ("INPO")

meetings Cajun is presently or has been in the past permitted to attend and identify the INPO documents to which Cajun presently or has in the past had access.

BESPONSE Cajun has been allowed to attend INPO exit meetings open to the general public. Cajun has been denied access to the daily briefing with the plant manager and denied access to  ;

the informal exit meeting. Cajun has been allowed to review  ;

INPO field notes on past occasions, but not allowed to  ;

retain copies of field notes. l PREPARER Victor J. Elmer >

l l

I t

+

1

i Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of [

Gulf States Utilities Company  ;

Docket No. 50-458-OLA  !

18. Identify the additional INPO documents (or specific types  ;

and subject matter of INPO documents) and meetings to which Cajun asserts access is necessary to assure safe operation of the facility and the bases for that assertion.

RESPONSE

Access to INPO briefings, informal exist meetings and field ,

t notes and reports would aid in the safe operation of the plant. With participation, cajun representatives have and can assist in the safe operation of the facility.

PREPARER Victor J. Elmer I

f I

I e

i r

4  !

1 I

i l

[

J 1

_ _ - - - _ . - . -- = _ _ - . _

l l

i Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of .

Gulf States Utilities Company l Docket No. 50-458-OLA j l

22. Define the exact differences in the operation of River Bend before and after the issuance of each of the disputed  ;

license amendments which has or could result in a significant reduction in the " margin of safety" or in the  :

level of " reasonable assurance" of safety at River Bend.

RESPONSE ,

As a result of the license amendments, resources allocated to operation, including maintenance, and the funding of decommissioning could be reduced or jeopardized, thereby affecting the margin of safety or the level of " reasonable assurance" of safety at River Bend. GSU will no long i operate River Bend. EOI, which seeks to assume operation of River Bend, will provide no funding for River Bend operations. Rather, funding will be provided by a

• subsidiary of Entergy Corporation.

PREPARER Victor J. Elmer i

l

[

r i

r

4 Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company Docket No. 50-458-OLA

33. Please provide all Cajun budgets and balance sheets for '

River Bend for the years 1991 to 1995, including but not limited to the budgets for River Bend O&M and decommissioning expenses. ,

RESPONSE

Attached are Cajun's River Bend budgets for the years 1991 through 1994. Cajun is in the process of developing its 1995 River Bend Budget but it is not complete at this time.

Cajun does not have balance sheets for River Bend.

l PBEPARER Victor J. Elmer  ;

i i

I e

4 4

i i

CAJUN ELFflRIC POWER COOPERATIVE,INC NRCRf133.WK1 l RIVER BEND BUDGET l CAJUN's 30% SHARE  !

1 t

l 1991 1992 1993 1994 l IlUIXHir IlUDGI?r IlUDGl?r IlUDGIsr {

CAPTTAL BUDGET l Fuel:

Nuclear Fuel Purchases $ 7,345,560 $ 4,024,711 $ 2,237,309 $ 7,121,400 (

(40D)

Interest During Processing 1,505,010 1,234,776 927,951 616,618 ~!

(35D)

Irss: Amortization (18.149,5N) (7,697,251) (16,222,192) (13,687,000) {

(40D)

(9,298,934) (2,437,764) (13.056,932) (5,948,982) l Change in Fuel Inventory (40D) t Opital FJIrnditures 4,860,060 401,300 3,361,680 4,880,000 Opital Projects (70E) i 31,500 396,000 650,000- 540,000 Engineering Studies (70G)  ;

Subtotal 4,891,56L 797,300 4,011,680 5,420,0(~ j la)w Irvel Waste Fund 75,000 0 600,000 1,200,000 (70E) l Spire Parts Inventory 0 0 1,4 % ,000 0  ;

(70E) 4,966,560 797,300 6,107,680 6,620,000 j Subrotal CapitalExpenditures 1,416,900 1,416,900 1,416,900 1,416,900 b Decommissioning (50A) i

_ (223,564) (5,532,352) 2,087,918 Total Capital (2,915,474) l OPERATING BUDGET  !

Ftgi: .

18,149,504 7,697,251 16,222,192 13,687,0(V) i Fuel Amortization (40D) 2,066,415 952,653 2,193,600 1,973,744 i Spent Fuel & D&D Fees (40F) 20,215,919 8,649 9N 18,415,792 15,660,744 Total Fuel i 1,800,000 1,981,200 2,000,000 1,900,000 Insurance _: (50A)

G&M and A&_G; i

6,572,160 7,081,800 6,600,000 5,681,200 Admin andGeneral (70A) 34,833,322 41,140,000 31,229,840 33,900,072 i O)rrations and Maint. (7011)

Interest on Funding-Tns -ups/Adj. (35D) 1,028,195 127,776 111,600 44,268  !

42,433,677 48,349,576 37,941,440 39,625,540 Subtotal (lkM and A&G l 36,404,964 36,516,639 36,168,422 36,052,476 j Depeciation 100,854,560 95,497.319 94,525,654 93,238,760 Total Operating Total River Bend Budget $ _ 97p_39,086 $ 95,273 755 $ 88,993,302 $ 95,326,678 (

i Note: Exclu&s Cajun indirect River Bend related costs (internal labor, legal, etc.)

t g > --,e, - , e-

Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of l

~

Gulf States Utilitics Company Docket No. 50-458-OLA

37. Please provide all minutes of Cajun Board of Directors' meetings or meetings of the officers of Cajun which reflect any material, documents, or discussions regarding the River Bend Litigation, the impact of a GSU or Cajun victory in the j River Bend Litigation or the bankruptcy of GSU or Cajun on: [

a. Cajun's or GSU's ability to operate and maintain River Bend;

b. the funding of Cajun or GSU's operation and [

decommissioning of River Bend; 7

c. the potential shutdown of River Bend;

d. the procedures for the shutdown of River Bend. .

EESPONSE i

See Response to No. D-1.

i PREPARER Victor J. Elmer i

e l

l l

l l

' ' - --. - _ ___ __. _ _ ___ _ _ l

ME L -u-- M 6 -,.,- - e s_amm -

i Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company p_ocket No. 50-458-OLA

38. Please provide copies of all documents submitted to the -

Board of Directors or officers related to the matters referenced in Subsections a-d of Request 37.

RESPONSE

See Response to No. D-1.

PREPARER Victor J. Elmer i

4 i

l i

L

l

\

l l

Cajun Electric Power Cooperative, Inc.'s, i Responses to First Set of Interrogatories of ,

Gulf States Utilities Company  ;

Docket No. 50-458-OLA ,

39. Please provide copies of all documents sent to the Rural Electrification Administration or received by Cajun from that agency relating to the matters referenced in  ;

Subsections a-d of Request 37.

RESPONSE

See Response to No. D-1.

PREPARER Victor J. Elmer  ;

I I

r E

t I

i 1

i

l. I l

1 I

l 1

k

Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company o

Do_cket No. 50-458-OLA

40. For each of the seven conditions contained in proposed Contention 5 of Cajun Electric Power Cooperative Inc.'s Amendment and Supplement to Petition for Leave to Intervene, Comments and Request for a Hearing dated August 1, 1993, identify:

a. The legal basis in the Atomic Energy Act of 1954, 42 U.S.C. S 2011, et sea., Energy Reorganization Act of 1974, 42 U.S.C. S 5801, et sea., or in the NRC Rules and Regulations for such condition.

b. The effect on safe operation of the facility were each condition separately imposed. <

c. Whether all such proposed conditions are collectively necessary, if not, or all combinations of conditions which Cajun deems necessary and the basis for each response,

d. Whether and where any such conditions have previously ,

been imposed by the NRC on any other light-water reactor licensee.

RESPONSE

a.-d. Cajun has not prepared the legal or technical analysis GSU seeks in these questions beyond that contained in its pleadings.

PREPARER Victor J. Elmer

f Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company pocket No. 50-458-OLA D-1 Provide copies of all documents identified in the responses to the General and Specific Interrogatories set forth above, in accordance with Instruction C, above.

RESPONSE

Copies of documents identified to date are available for inspection at the offices of Duncan, Weinberg, Miller &

Pembroke, 1615 M Street N.W., Suite 800, Washington, DC -

20036.  ;

f I

t l

STATE OF LOUISIANA PARISH OF EAST BATON ROUGE The preceding interrogatory responses were prepared under my direction and the matter and facts contained herein are true and correct to the best of my knowledge.

Dated this the 295 day of Icpr~ ,19 90.

MSEdn Vfctor ElmeV Vice President Operations Cajun Electric Power Cooperative, Inc. I SWORN to and subscribed before me, the undersigned authority in and for the said parish and state. Witness my signature and official seal of office on this the

) 4 f* day of Jep d ,19 6 P.

k./(1/f /bf'&

NOTARY PUBLIC My commission expires at death.

I l

______ ____ __ _ _ . __ __ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _