ML20010C149

Second Set Interrogatories Directed to La Consumer League, Inc.Certificate of Svc Encl.Related Correspondence

ML20010C149
Person / Time
Site:	Waterford
Issue date:	08/13/1981
From:	Blake E LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	LOUISIANA CONSUMER'S LEAGUE, INC.
References
NUDOCS 8108190186
Download: ML20010C149 (12)

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.. RELATED_ C_0RRESPONDENCR August 13, 1981 4

UNITED STATES OF AMERICA k NUCLEAR REGULATORY COMMISSION '

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Before the Atomic Safety and Licen_s_ing Board 1 0

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LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

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(Waterford Steam Electric ) G Station, Ut?.t 3) ) ' ~t

($ph) Wh APPLICANT'S INTERROGATORIES TO LOUISIANA CONSUMER'S LEAGUE, INC.9

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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.

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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

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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

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. 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.

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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.

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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.

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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. 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 ,

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August 13, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4

Before the Atomic Safety and Licensing Board In the Matter of )

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. LOUISIANA POWER & LIGHT COMPANY )

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Docket No. 50-382 (Waterford Steam Electric )

Station, Unit 3) )

l CERTIFICATE OF SERVICE

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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.

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UNITED STATES OF AMERICA NUCLETR REGULATORY COMMISSION Before the Atom'i c Safety and Licensing Board In the Matter of )

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LOUISIANA POWER & LIGHT COMPANY ) Dc7ket No. 50-382

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(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

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