ML20093N270

Answers to First Set of Interrogatories & Response to Request for Production of Documents.Certificate of Svc Encl. Related Correspondence

ML20093N270
Person / Time
Site:	River Bend
Issue date:	07/24/1984
From:	Watkins L JOINT INTERVENORS - RIVER BEND, WATKINS, L.B.
To:	GULF STATES UTILITIES CO.
References
OL, NUDOCS 8408010258
Download: ML20093N270 (10)

Text

. _- _. . _ _ _ _ _ _ _ _ . - _ . _

,) f

• '. RELATED CC;i.UETCTiDEUCE

tvri--

UNITED STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION v34 41 26 tl127 BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the Matter of GULF STATES UTILITIES CO., DOCKET NOS. 50-458; 50-459 h4 Et al (River Bend Station, Units 1 & 2) -

r ANSWERS TO APPLICANT'S E

FIRST SET OE INTERROGATORIES The Joint Intervenors answer the applicant's first set of interrogatories, which pertain t'o Contentions Numbers 1 and 2, as follows:

1. Requires no answer.

2. . Requires no answer.

t

'3.  : Requires no answer.

Intervenors have not yet retained expert

- 4 .- 'The' Joint When the information witnesses for. Contentions Numbers 1 and 2.

requested ,in Interrogatory Number 4 is known by the Joint. In-tervenors,-it will be provided to applicant.

5.- The. Joint Intervenors have not yet identified factual When the-information requested witnesses for Contentions 1 or 2.

Intervenors, it E in' Interrogatory Number 5 is knownLby the Joint will be provided to applicant.

G 2 503

/

Y .

/

6. Insofar as Interrogatory Number 5 requests information

't o be used on cross-examination, it is o bj ec ted to.

However, the

, Joint Intervenors intend to use the current, or previous, versions of the RBS-FSAR and SER and those documents

, identified heein, among others. As other documents are identified, which will be used at the hearing, the information requested in Number

, 6 will be provided to applicant, i

7. Requires no answer.

8. Requires no answer.

9. . Requires no answer.

10. , Requires no answer. ,

11. Intervenors are not obligated to do the Applicant's legal research.' The contention is spec-ifically addressed to the Applicant's c6mpliance with I &"E Bulletin 81-03, " Flow Blockage of Cooling Watdr to Safety Components by Corbicula (Asiatic Clam) and Mytibis (EuAsel)" and to " Report on Service Wateer System Flo Blockage. by Bivalve Mol.lusks at Arkansas Nuclear one and I - Brunswick" by the Office for Analysis and Evaluation of Operational Data dated February, 1982$ See also, Vol. 47, Federal Register, No. 92, Wednesday, Wy 19, 1992 Notices.

s 12. ,Iptervenors are not ob' a J nor able to identify every written document which'hou?- r ceivably relevant to the claim,, inquir,0. Without in a n y ,J r. y limiting this response to these d,ocuments, intervenors call the attention of the applicant to their own letter dated Febrn'ary 14, 1983, which states in

. pertinent'part, that GSU does not have sufficient data to make a deroiled' assessment of intrustion potential.

l 2

/

P"

.'f.

i

13. The applicant proposes a biofouling system consisting of chlorination with sodium hypochlorite. Chlorination may not

/

be adequate in some systems. See " k'h a t Are We Doing About the Asiatic Clam", Enerev Manacement, January, 1982; Good News:

Corbicula Fluminea is Being Brought Under Control, Enerav Management", July, 1982,

14. Th-: applicant admits the clams are present in .the river as is demonstrated by the Applicant's own monitoring. Whether or not clams presently exist at the si t'e in sufficient quantity to present a problem is, in our opinion, a purely academic question as this clam has no enemies and is spreading throughout the area.

Intervenors are not aware of the experience of other plants on the Mississippi River with clams nor are they in a position to obtain this information easily. Intervenors do not have this information.

15. See number 13 above.

16. See number 13 above.

17. This-information is presently unknown to the applicant,

.as is indicated by their letter of February 14, 1983. Until the applicant is better able to respond, intervenors will be unable to do so.,

18. See number 14 above.

19. N/A

20. This question cannot be answered. See number 17 above.

21. This question cannot be answered. See number 17 above.

22. (a) Personal familiarity with the continuing problems of the Old River Control Structure obtained by living in the erea.

3

Y /

/

are not obligated to do tr e (b) The intervenors for the applicant to locate all such reports includi.g research i

those not published. Specifically, see the following:

Louisiana Water Resources Research Institute Bulletin (1) 12, September, 1980; "If the Old River Control Structure Fails",

by R.G. Kazmann and D.B. Johnson.

(2) " Water on the Mississippi", Discover, March, 1983.

"C1d River Control Structure", 96th (3) Senate Hearings, Congress. ,

(4) Rural Louisiana, ' Taming Ole Man River", page 6-7.

note that Rural Louisiana is published by the (5) Please Louisiana Association of Electric Cooperatives (LAEC), a closely related entity of Applicant, Cajun

• Electric. LAEC is apparently the opinion that the Old River Control Structure may not be of salvagable.

23. This question asks the intervenors to generate

. mathmatical probabilities which are based on such diverse factors as (1) meteorlogical conditions over the next 30 plus years; (2) the willingness of Congress to appropriate money; (3) soil conditf:ns under the Old River Control Structure; (4) the ability of the U.S. Army Corps of Engineers given sufficient funding and numerous factors. Intervenors believe that such probabilties cannot be calculated to any meanin gf ul accuracy.

24 See documents referred to in number 22 above.

25. Unknown. There are failures which cannot be repaired.

26. See number 22 above.

27. Unknown.

4

//

/?'

.e r

28. Unknown. Also, " Steady State Conditions" do no necessarily represent ti.e point where River Eend would be affected. The question is rather, "At what point the salinity of makeup cooling water for the reactor would be affected".

29. Failure of the Old River Control Structure presents a long-term problem for the plant. It is not contended that the plant cannot be shut dcwn safely assuming the adverse ~ salinity conditions are identified. The contention is that the plant is not designed to operate with salt water and virtually every component of the cooling tower water system would be affected if the plant continued to operate under adverse salinit y conditions .

In addition, there could be a longer term adverse impact on well water used for the makeup wateer for the reactor condensate cycle. All regulatory requirements dealing with corrosion and state water quality criteria could potentially be violated.

30. All sections dealing with corrosion at all points of the plant cooling system.

31. This question cannot be fully answered at this time; however, at a minimum, facilities should be provided to desalinate cooling tower makeup water.

32.

• See the Kazmann and Johnson article referred in Number 22 above.

33. See number 22 above.

34. Obviously, the Mississippi River ic not going to divert itself into the channel it now occupies.

35. See number 22 above.

36. Unknown. Potentially none at all.

5

/

37. Unknown, except that there would be a substantial increase.

Respectfully submitted, O

LINDA B. W A'i E IN S Attorney at Law 355 Napoleon Street Baton Rouge, LA 70802 504/343-3034 STEPHEN M. IRVING Attorney at Law 355 Napoleon Street Baton Rouge, LA 70802 504/346 ,8774 i

JAMES W. PIERCE Attorney at Law P. O. Box 23571 Baton Rou8e, LA 70893 504/388-9574 ON BEHALF 0F JOINT INTERVENORS D

. - - . . . . . ft

/!

,/

/ ,

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the Matter of-GULF STATES UTILITIES CO., DOCKET NOS. 50-458; 50-459 Et al (River Bend Station, Units 1 & 2)

RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS Those documents identified herein will be made available et the office of Stephen M. Irving, Attorney at Law, 355 Napoleon Street, Baton Rouge, Louisiana, 70802 (One of the counsel for Joint Intervenors) on or after August 1, 1984.

Respectfully submitted, M ,

E_.2 LINDA B. WATKINS Attorney at Law 355 Napoleon Street Baton Rouge, LA 70802 504/343-3034 7

/ -

4 s ,

STEPHEN M. IRVING Attorney at Law j 355 Napoleon Street Baton Rouge, LA 70802 504/346-8774 l J A M ES k' . PIERCE Attorney at Law

! P. O. Bc :: 23571 Baton Rouge, LA 70893 504/388-9574 ON BEHALF 0F JOINT INTERVENORS I

o e

9 8

s - .- --

/ *

/

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD

+

In the Matter of GULF STATES UTILITIES CO., DOCKET NOS. 50-458;.50-459 Et al (River Bend Station, Units 1 & 2)

CERTIFICATE DF SERVICE I HEREBY CERTIFY that copies of " Answers to Applicant's First Set of Interrogatories" and " Response to Request for Production of Documents", in the above captioned proceeding, have been served on the following, by deposit in the U.S. mail, first  :

class, postage pre-paid, correctly addressed to the last known address on this 24th day of July, 1984:

Dr. Richard F. Cole William J. Guste, Jr.

Administrative Judge Attorney General Atomic Safety.& Licensing State of Louisiana Board Panel 234 Loyola Ave. 7th Floor U.S. Nuclear Regulatory Comm. New Orleans, LA 70112 Washington, D.C. 20555 Troy B. Conner, Jr.

B. Paul Cotter, Jr., Chairman Mark J. Wetterhahn Administrative Judge Conner & Wetterhahn Atomic Saf ety & Licensing 1747 Pennsylvania Ave , NW Board Panel Suite 1050 U.S. Nuclear Regulatory Comm. Washington, D.C. 20006 Washington, D.C. 20555 Jamec E. Booker Mr. Gustave A. Linenberger G.S.U.

Administrative Judge P. O. Box 2951 Atomic Safety & Licensing Beaumont, TX 77701 Board Panel U.S. N.R.C. Ian Douglas Lindsey, Esq.

Washington, D.C. 20555 David McNeil, Esq.

Staff Attorneys La. Dept. of Justice 7434 Perkins Rd. Suite C Baton R ~o u g e , LA 70808 9

~ . , - . , . , . . . . . . , . . . . ,.. . , , . . . . , . _ _ , . .- ..

mmmmmm I

' d j'

4 Gretchen'R. Rotschild Louisianians for Safe Lagery, Inc.

1659 Glenmore Ave.

70808 Baton Rouge, LA H. Anne Plettinger t 712 Carol Marie Dr.

Baton Rouge, LA 70806 Atomic Safety & Licensing Appeal Board

~

U.S. N.R.C.

Washington, D.C. 20555 Docketing & Service Section Office of the Secretary ,.

U.S. N.R.C.

Washington, D.C. 20555 e

f William F. Patterson

, Counsel for NRC Staff

~

U.S. N.R.C.

Washington, D.C. 20555

}?) -

LINDA B. WATKINS On Behalf of Joint Intervenors i

n L

1 a o m

y 10 m-