ML20039B064

Joint Requirements for ASLB Approval of Revised Joint Intervenor Contentions 17 & 26.Mods More Particularly Reflect Joint Intervenor Concerns.Certificate of Svc Encl

ML20039B064
Person / Time
Site:	Waterford
Issue date:	12/15/1981
From:	Churchill B, Larry Jones JOINT INTERVENORS - WATERFORD, JONES, L.L., LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8112220247
Download: ML20039B064 (5)

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DOCKETED C SNO.C UNITED STATES OF AMERICA PUCLEAR REGULATORY COMMISSION 11 DEC 17 P2::02 Before the Atomic Safety and Licensing Board, r r E ECRETMY

'% i,aG & SERVICE In the Matter of ) WLMCH

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

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(Waterford Steam Electric ) 4, Station, Unit 3) ) f> { U

)) H E c ggifG O JOINT REQUEST FOR BOARD APPROVAL _: 72 OF REVISED JOINT INTERVENOR  ; OggD 7%fg f; ,.

CONTENTIONS 17 AND 26 k,.. A C , 4:r g

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By Order dated September 12, 1979, the Board adrh t'ed- # ih sqd i Joint Intervenors' Contention 17 on the adequacy of enar"ency planning for Waterford 3. By Order dated October 15, 1981, the Board approved a stipulated revision of Contention 17.

By_ Order dated January 11, 1980, the Board admitted Joint Intervenors' Contention 26, which is a'so l related to the adequacy of emergency planning for Waterford 3.

The two contentions presently read as follows:

17. Applicant has failed to adequately make provision, according to the Emergency Plan contained in .

Chapter 13.3 of the FSAR, for the following emergency contingencies:

a. Evacuation of individuals located within the 10-mile plume exposure. pathway emergency planning zone for the Waterford 3 site in the event of a serious reactor incident, as required by applicable NRC regulations.

'b. Storage of potassium iodide in locations which' are readily accessible to affected individuals as protection against thyroid irradiation.

26. Applicant has not presently provided in its emer-gency planning for the following: 3 811222O247 811215' * / l

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a. A responsive accident and recovery sequence (emergency procedures for responding to a .

credible Nuclear Emergency) to be carried out by applicant during' emergency procedures for nuclear emergency. -

b. An adequate plan for communication and coordina-tion with and between applicant, state and local authorities and the NRC.

c. An adequate plan for allocation of decision making capability with and between applicant, state and local authorities and the NRC.

On the basis of recent discussions between Joint Intervenors and Applicant, the aforementioned parties have agreed that Conten-tions 17 and 26 should be modified to more particularly reflect and describe the allc gations and conerns of Joint Intervenors.

Accordingly, Joint Intervenors and Applicant have agreed that

, Contentions 17 and 26 should be consolidated and modified to read as follows:

17/26(1). Applicant has failed to adequately make pro-vision, according to the Emergency Plan con-tained in Chapter 13.3 of the FSAR, for evacuation of individuals located within the 10-mile plume exposure pathway emergency planning zone for.the Waterford 3 site in-the event of a serious reactor-incident, as required by applicable NRC regulations, in that:

(a) the provisions for notifying residents of evacuation procedures are inadequate; (b) the roads and highways necessary for such evacuation are inadequate; (c) the evacuation warning system is inadequate;-

(d) there is not an adequate command decision structure, including appropriate guidance, for commencing evacuation; (e) the Emergency Plan fails to provide for realistic and comprehensive evacuation drills, in that the provisions for moving individuals are not actually tested;

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. (f) procedures are inadequate for evacuating people who.are: ,

(i) without vehicles (ii) school children (iii) aged or crippled (iv) sick and hospitalized (v) imprisoned (vi) transient workers.

17/26(2). Applicant has failed to adequately make provi-sion, accordicJ to the Emergency Plan contained in Chdpter 13.3 of the FSAR, for distribution and/or storage of potassium iodide in accordance with accepted public health practice in loca-tions which are readily accessible to affected individualc as protection against thyroid irradiation.

No part of these contentions is to be construed in a manner inconsistent with NRC rules and regulations.

Joint Intervenors and Applicant request that the Board approve the proposed revision of the Joint Intervenors' Contentions 17 and 26.

Respec ull su iitted, GILLE PIE & JO- S I

By _,

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LYF.N L[ JON , , J FF.

A orney fo oint ntervenors P O. Box 9 6 Metairie, uisia a 70005 (504) 835- 458 SHAW, PITTMAN, POTTh & TROWBRIDGE B _r j ,[

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BRt1CE WWGfCHILL -

Counsel for Applicant 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: December 15, 1981

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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

)

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

.. )

(Waterford Steam Electric )

Station, Unit 3) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Joint i Request for Board Approval of Revised Joint Intervenor Contentions 17 and 26" were served, by deposit in the U.S. Mail, first class, postage prepaid, to all those on the attached Service List, this th day of December, 1981.

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j Dated: December 15, 1981.

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/ SERVICE LIST t

Sheldon J. Wolfe, Esquire U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D. C. 20555 Dr. Harry Foreman Box 395, Mayo University of Minnesota Minneapolis, Mirnesota 55455 Dr. Walter H. 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 Sherwin E. Turk, Esquire Office of Executive Legal Director -

U.S. Nuclear Regulatory Commission Washington, D. C. 20555 W. Malcolm Stevenson, Esquire Monroe & Lemann Whitney Building 625 Gravier Street New Orleans, Louisiana 70112 i

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