ML19289E886

Contentions of La Consumers League.Amends Original Petition. Affidavit of L Samuel & Certificate of Svc Encl

ML19289E886
Person / Time
Site:	Waterford
Issue date:	04/04/1979
From:	Irving S LOUISIANA CONSUMER'S LEAGUE, INC.
To:
References
NUDOCS 7905290300
Download: ML19289E886 (5)

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I UNITED STATES OF A! ERICA ,

. .."JCLEAR REGULATORY CO MISSION 1

4 BEFORF THE ATOUC S AFr"'Y A'ID LICr'T3I'i'i BO ARD l l it j 1 ,

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[LOUISIANAPOWER&LIGHTCO:/PANY DOCKET No. 50-382 s

[ (Waterford Steam Electric l J Station, Unit 3)

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C0!!TE?ITIO?iS OF THE LOUISI A!IA COilSU?ER'S LEAS'JE. I?n.

f l The original petition of the Louisiana Consumer's League, bInc.isherebyamendedbyaddingtheretothefollowingcontentions.

1. The applicant has not provided adequate criteria for

[ redundancy, recording, qualification and testing of post accident i

and incident =onitoring. This question was originally raised in section 7.3 of the Waterford III SER and has not been resolved by the applicant in subsequent filings. The applicant has, therefere, not provided infomation required by the SER.

2. The applicant has not demonstrated that it has two independent sources of offsite power and, therefore, will not be in ec=pliance with 10CFR 50 APP. A Criterion 17 The applicant intends to provide two tranc=issicn lines on towers about 100 feet high located 250 feet apart between the proposed facility and a switchyard through which seven transmission lines pass. About 703 feet frc= the switchyard is a =ain line of the Missouri-Pacific Railroad. Both transmission lines pass over thi; rail-road about 253 feet apart and 103 feet above. This is a =ajor line with 13 trains a day averaging 100 cars-in lengt'c pascing under these transmission lines every day . This railrcad sen es 2048 100 r49052 90300 '

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ll all chemical plants on the west side of the ?nssissippl River

,i and commonly carries cargoes which are fla==able and/or explosive.

Fast accidents in the area have involved five or more railroad ca-s, a distance easily sufficient to impact both proposed trans-missien lines. In addition, the applicant's switching station is

!! unpratected and located in an area which could easily be impacted h

by railroad accidents. i j; 3. The applicant has not demonstrated ' hat it can control activitie? in the exclusien area as is required by 100FR 100.3 I in that:

A. It can not control oil and gas drilling activity in the Mississippi River.

B'. It can not control surface activities on the Mississippi River. Its agree =ent with the U.S. Coast Guard lezves the determination of the method and extent of control tc be ex-exercised to that agency.

C. The statutory authority relied upon by the U.S. Coast Guard in its agreement with the applicanc applies only to hazards to vessels and could not be used to control activities not related to vessels.

D. Unaer Louisiana law, the applicant can net deny use of the banks of the Mississippi River that are within the exclusion area for purposes incidental to the navigable character of the waterway.

L. The applicant has not provided an adequate emergency plan in that:

A. The State of Louisiana's e=ergency plan is not in final for=.

3. No provisions have been made for evacuating the icw ecpulation :ene particularly with regard to poor persons and the aged and/or infirm.

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i g 5. The applicant has not evaluated the probability and

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d consequences, to members of LOL and the general public, of  !

,{accidentsmoreseriousthanthedesignbasisaccident (class 9 t' accident), like the accident which occurred recently at the Three '

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' Mile Island Nuclear Plant in Pennsylvania.  !

6. The applicant has not evaluated the effect of a premat I

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I. ure shutdown of the emergency core cooling system due to operator l, error during a loss of coolant accident.

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lj 7. The applicant has made no provision for the removal of h

4 a hydrogen gas bubble from the reactor veccel during an accident I

!f ll sequence like the one that occurred at the Tiree Mile Island I

' Nuclear Plant in Pennsylvania.

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- Respectfully submitted, i

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'! ST3FHEM MILLER IRVING  !

1 Attorney f or Interve.. ors l h 1601 One American Place ,

3aton Rouge, LA 70?25

( 50L) 3 33-9970 l 4 I i i Dated: April L, 1979 E-f0l 3_

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AFFTPAVIT OF LAP 3Y S AWEL U z

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P Larry Samuel, being duly sworn to tell the truth, deposes

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1. He is President of the Louisiana Consumer's League,

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Inc.

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d 144 Elk Place, Sc'.te 1202

' ?Iew Orleans, LA 70112 ,

3. He is aware of the contents of the Amended Petition for; I

Leave to Interiene in Facility Operating License

, Proceedings by the Louisiana Consumer's League, Inc.

I and attests that the infor nation contained therein is h true and correct to the best of his informat'en and belief.

b M47.' .me LARRv 'S A'.'UEL SWOR:I TO A:ID SUSSCRIBED BEFORE G 0:I THIS CAY CF ,

1979.

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h o CERTIFICAT? 0F 9FP7TCE P

d I hereby certify that a copy of the above and foreoing .

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" Amended Petition was mailed on the 9th day of April - 1979 postage !

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[l pre-paid, first class in the United States Mail to the following: '

- I el l t li l hSheldonJ.Wolfe Henry J. McGurrca, Esq. '

i U.S. !Iuclear Regulatory Office of Executive Legal O Cornission Director l

! Atomic Safety and Licensing U.S. Iluelear Regulatory 1 Board Panel Commission l

] Washington,D.C. 20555 Washington,D.C. 20555 e

!' Dr. Harry Foreman Lynan L. Jones, Jr.

F Box 395, Mayo Gillespie & Jones University of Minnesota 910 Security Homestead a Minneapolis, Minnesota 55L55 Building L900VeteransMemorialElvd.

Dr. Walter H. Jordan Metairie, LA 70002 931 West Cuter LYive Oak Ridge, Tennessee 37330 Luke B. Fontana

?24 Esplanade Avenue Chairman, Atomic Safety and Iew Orleans, LA 70116 Licensing Board Panel U.S. Iluclear Regulacory  !

Comission Washington,D.C. 20555 Chairman, Atomic Safety and i

Licensing Appeal Board U.S. !!uclear Regulatory Con =ission Washington,D.C. 20555 v' Docketing and 3ertice Section Office of the Secretary U.S. !!uclear Regulatory Co=is sion Washington,D.O. 20555 I also certify that a copy of the ateve and foregoing Amended Petition was hand-delivered to Mr. Ernie Blake, attorney for the applicant and/or his agent on the Lth day of April, 19~9.

STEPHE'I :/ ILLER IR7I::G 2048 104

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