Text

Fourth Set of Interrogatories & Request for Production of Documents Received by Legal Environ Assistance Foundation in Response to FOIA Request Re Eccs.Certificate of Svc Encl. Related Correspondence
	ML20099C524
Person / Time
Site:	Vogtle
Issue date:	03/05/1985
From:	Joiner J; GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	; CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY
Shared Package
ML20099C485	List: ML20099C482; ML20099C524;
References
	OL, NUDOCS 8503110345
	Download: ML20099C524 (86)
	v • d • e

.

March 5, MLATEDW 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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Before the Atomic Safety and Licensina Board '/'f0

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In the Matter of ) c ,. .

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GEORGIA POWER COMPANY, ) Ogg'#E?eg t. . .

et al. ) Docket Nos. 5074%~Ebjg

) 50-425 (Vogtle Electric Generating ) s, Plant, Units 1 and 2) ) ..

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APPLICANTS' FOURTH SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS These interrogatories and request for production of documents are directed to Joint Intervenors Campaign For a Prosperous Georgia / Georgians Against Nuclear Energy and pertain to Contention No. 8 as accepted by the Atomic Safety and Licensing Board in its " Memorandum and Order (Ruling on Intervenors' Objections to Order of Septem-ber 5, 1984 and Other Matters)" (Nov. 5, 1984). These discovery requests constitute the Applicants' second round of discovery requests on Contention No. 8.

The interrogatories are filed pursuant to 10 C.F.R.

S 2.740b, which requires that they be answered separately and fully in writing under oath or' affirmation. According to the Stipulation of Parties on Discovery Schedule, such answers shall be served within 30 days after service of the interrogatories. These interrogatories are intended to be continuing in nature, and the answers must be immediately supplemented or amended, as appropriate, 8503110345 050305 PDR ADOCK 05000424 Q PDR

1 should Intervenors obtain any new or differing information responsive to the interrogatories.

The request for production of documents is filed pursuant to 10 C.F.R. $ 2.741, which requires that Inter-venors produce and either furnish copies of, or permit Applicants to inspect and copy, any documents that are responsive to the request and that are in the possession, custody, or control of Intervenors. In accordance with the Stipulation of parties on Discovery Schedule and with 10 C.F.R. S 2.741, such production must be effected within 30 days after service of this request. The request for production of documents is also continuing in nature, and Intervenors must produce immediately any documents they obtain which are responsive to the request.

I. INSTRUCTIONS The following instructions and definitions apply to Applicants' interrogatories and request for production of documents.

1. When identification of a document is requested, briefly describe the document (i.e., letter, memorandum, book, pamphlet, etc.) and state the following information as applicable to the particular document: name, title, author, date of publication and publisher, addressee, date l

l l

written or approved, the Applicants' identification number t

(for those documents which have been produced by Applicant i f

i

i to Intervenors in this proceeding), and the name and address of the person (s) having possession of the document.

2. When identification of a person is requested, state that person's full name, present employer or busi-ness affiliation, present address, and present telephone number.

3. "VEGP" means the Vogtle Electric Generating Plant, Units 1 and 2.

4. "Intervenors," "you," or "your" refers to Georgians Against Nuclear Energy (hereinafter "GANE")

and/or Campaign for a Prosperous Georgia (hereinafter

" CPG"), and all members, employees, agents, consultants, attorneys, or other representatives of GANE or CPG.

5. " Correspondence" shall be construed broadly and shall mean letters; all recordings, transcriptions, and notes of telephone calls or conversations; inter-office and intra-office memoranda; telegrams; telex messages; notes; and reports.

6. " Document" means any handwritten, typed, printed, graphic, photographic, mechanically recorded, computer stored, filmed, or other verbal or pictorial matter of whatever character, however produced or reproduced, of any kind and description. " Document" shall also mean every copy of a document when such copy is not an identical duplicate of the original.

7. "QA/QC" refers to the VEGp quality assurance and quality control programs and functions.

8. " Contention No. 8, as admitted by the Board" shall me5n your Contention No. 8, as restated by the Atomic Safety and Licensing Board in this proceeding, which is as follows:

Applicants have not and will not implement a l quality assurance program for plant Vogtle for welding, for properly documenting the placement of concrete, for adequately testing concrete, for the preparation of correct concrete quality test records, for procuring material and equipment that meet applicable standards, for protecting equipment and for taking corrective action as required, so as to adequately provide for the safe functioning of diverse structures, systems and components, as required by 10 CFR part 50, Appendix B, such that reasonable assurance exists that operation of the facility will not endanger the public health ar.d safety.

9. " Contention No. 8 activities" shall mean:

a) welding; b) documenting the placement of concrete; c) testing concrete; d) preparation of concrete quality test records; e) procuring material and equipment; f) protecting equipment; and g) taking corrective action in response to Notices of Violation as required by the NRC.

10. If any Interrogatory calls for a yes or no answer, or calls for you to cite evidence upon which you rely, and you choose merely to incorporate prior documents

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

1 r D

! in response to that Interrogatory, Applicants will

?- interpret your response as a statement that you have go evidence to support or prove your allegation other than the evidsnce specifically cited in the document which is i

9 incorporated.

t

11. Many of these Interrogatories contain separate l sub-parts (a), (b), (c), etc. You are required to answer i each sub-part separately.

5 II. INTERROGATORIES

! In answering each interrogatory, please recite the i

i interrogatory before providing the response.

I i

A. Specific Interrogatories Contention 8 (Quality Assurance) 4 i

l. PROCUREMENT:

8.1-17 l

In response to Interrogatory Number 8.1-1, you stated:

" anonymous allegations of file doctoring suggests that i

vendors were not qualified on the basis of the quality

assurance' program at Vogtle but rather on the basis 13f i past work with the Applicants." State by answering yes or no: '

j

' Please carefully read and comply with the preceding enumerated Paragraph 10 of the Instructions set forth at page 4, above.

4

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(a) Do you contend that it is improper to select vendors on the basis of past' work if that vendor also has an effective quality assurance program?

(b) -Are you capable of identifying any specific vendor who does not have an effective quality assurance program at VEGP?

(c) Are you capable of identifying any specific allegation, anonymous or otherwise, of " file doctoring"?

8.1-18 If your response to Interrogatory 8.1-17(b) is "yes",

identify each vendor whom you contend did not have an effective quality assurance program.

8.1-19 If your response to Interrogatory 8.1-17(b) is "yes",

answer Interrogatory 8.1-1(a).

8.1-20 If your response to Interrogatory 8.1-17(c) is "yes,"

state the substance of each such allegation, the date the allegation was first made known to you, how the allegation was first made known to you, whether the allegation was in writing or verbal, and, the source of the allegation.

8.1-21 When you refer to " anonymous allegations" in Response to Interrogatory 8.1-1, do you mean: (1) that the

Please carefully read and comply with the preceding enumerated Paragraph 11 of the Instructions set forth at page 5, above.

individual (s) making the allegation or statement is unknown to you and that you are incapable of giving any identifying information with regard to that person (s); or, (2) you sre capable of identifying the individual (s) but refuse to share the identify of the individual (s) with the Applicants in response to this discovery based upon a claim of privilege or other objection?

8.1-22 If you are capable of identifying the individual (s]

referred to in the preceding interrogatory, respond to Interrogatory 8.1-1(b).

8.1-23 In response to Interrogatory Number 8.1-1, you have incorporated allegations set forth in " Supplement to Peti-tion for Leave to Intervene and Request for Hearing, Cam-paign for a Prosperous Georgia", dated April 11, 1984 (hereinafter " CPG's Supplement to Petition") and " CPG /

GANE's Response to NRC Staff's Second Set of Interroga-tories", dated December 19, 1984 (hereinafter " CPG /GANE Response to NRC Staff's Second Interrogatories"). Specif-ically identify each document' which you will introduce at the time of hearing before the ASLB and identify each Please carefully read and comply with the preceding enumerated Paragraph 1 of the Instructions set forth at page 2, above.

i witness' whom you will ca.11 at the time of hearing in support of the allegations set forth in response to Interrogatory 8.1-1.

8.1-24 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such tha* it is responsive to the preceding interrogatory.

8.1-25 In response to Applicants' Interrogatory Number 8.1-1, i

you have stated that: "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

"There is no such additional information" or by incorpo-rating your prior response to Interrogatory 8.1-1.

l l

l e

Please carefully read and comply with the preceding i enumerated Paragraph 2 of the Instructions set forth at

! page 3, above.

l l l- - _ _ _ _ , _ _ _ _ _ _ . _ _ . _ _ . _ _ . _ _ _ _

O 8.1-26 In response to Interrogatory Number 8.1-2, you have stated that "[b]reakdowns in the Applicants' method of selecting qualified vendors could result in unsafe and uncorrected conditions at Plant Vogtle. (emphasis added]." Respond by answerina yes or no to Interrogatory 8.1-2 which asks: "Do you contend that Applicants' method of approving qualified vendors has resulted in any unsafe and uncorrected condition at VEGP? (emphasis added.]"

8.1-27 If your response to the preceding Interrogatory is "yes," answer Interrogatory 8.1-2 subparts (a), (b), (c) and (d).

8.1-28 In response to Applicants' Interrogatory Number 8.1-2, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the alle-gations set forth in response to Interrogatory 8.1-2.

8.1-29 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Fetition or CPG /GANE's Response to NRC Second Interrogatories, specify by docu-ment and page number where either of those pleadings iden-tifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.1-30 In response to Applicants' Interrogatory Number 8.1-2, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and 'aquest to produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.1-31 In response to Interrogatory Number 8.1-4, you have stated: "[a]nonymous informants have alleged that the Applicants fail to audit their vendors adequately."

Respond by answering yes or no: are you capable of iden-tifying any specific allegation (anonymous or otherwise) that "the applicants failed to audit their vendors ade-quately" as referred to in response to Interrogato'ry 8.1-4?

8.1-32 If your response to the preceding Interrogatory is "yes", state the substance of each such allegation and further state: the date the allegation was first made known to you, how the allegation was first made known to you, whether the allegation was in writing or verbal and the source of the allegation.

8.1-33 When you refer to " anonymous informants" as used in

. response to Interrogatory 8.1-4, do you mean: (1) that the individual making the allegation or statement is unknown to you and that you are incapable of giving any identifying information; or (2) you are capable of iden-tifying the individual but refuse to share the identity of the individual with Applicants based upon a claim of privilege or other objection?

8.1-34 In response to Applicants' Interrogatory Number 8.1-4, you have incorporated allegations set forth in CPG's Supplement to_ Petition and CPG /GANE's Response to NRC

- Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the alle-gations set forth in response to Interrogatory 8.1-4.

8.1-35 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.1-36 In response to Applicants' Interrogatory Number 8.1-4, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up qbastions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by Frating:

" Joint Intervenors have no such additional information."

8.1-37 In response to Applicants' Interrogatory Number 8.1-5, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the alle-gations set forth in response to Interrogatory 8.1-5.

8.1-38 If your response to the preceding interrogatory re-incorporates CPG's Suppletaent to Petition or CPG /GANE's

A Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.1-39 State by answering yes or no whether you are presently capable of responding to Interrogatory 8.1-7.

8.1-40 1

If your response to the preceding Interrogatory is "yes", respond to Interrogatory 8.1-7.

8.1-41 State by answering yes or no whether you are presently l capable of responding to Interrogatory 8.1-8.

8.1-42 If your response to the preceding Interrogatory is "yes", provide a response to Interrogatory 8.1-8.

~

8.1-43 State by answering yes or no whether you are presently capable of providing a response to Interrogatory 8.1-9 subparagraphs (a), (b), and (c).

8.1-44 i If your answer to the preceding Interrogatory is "yes," respond to Interrogatories 8.1-9(a),(b) and (c).

8.1-45 In response to Interrogatory Number 8.1-9, you have incorporated allegations set forth in cpg's Supplement to

Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and. identify each witness whom you will call at the time of hearing in support of the allegations set forth in response to Interrogatory 8.1-9.

8.1-46 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.1-47 In response to Applicants' Interrogatory Number 8.1-9, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance. Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.1-48 In response to Applicants' Interrogatory Number 8.1-11, you have incorporated allegations set forth in

i CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.1-11.

8.1-49 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.1-50 In response to Applicants' Interrogatory Number 8.1-11, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." Provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

2. WELDING:

8.2-20 In response to Applicants' Interrogatory Number 8.2-1, you have. stated that "Intervenors will provide further

' information if warranted following review of Applicants' i responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-

ance." Provide such further information. If you have no such further information, indicate that fact by stating

" Joint Intervenors have no such additional information."

8.2-21 In response to Interrogatory Number 8.2-1, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allegations set forth in .

response to Interrogatory 8.2-1.

8.2-22 If your response *o the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings 4

identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-23 Respond by answering yes or no: Do you contend that the cracking in the containment pipe rack welds is pres-ently an uncorrected condition at VEGp?

8.2-24 Respond by answering yes or no: Do you have any knowledge of the facts and circumstances surrounding the cracking in the containment pipe rack welds other than i 1

that which is set forth in the letter from D.O. Foster to James P. O'Reilly dated October 17, 1984, which is referred to in Response to Interrogatory 8.2-l?

8.2-25 If your reply to the preceding interrogatory is "yes,"

answer fully interrogatory 8.2-1 including its subparts.

8.2-26 Identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of your allegation that the cracking in the containment pipe rack welds evidences a deficiency in the quality assurance program at VEGP.

8.2-27 If your response to the preceding interrogatory re-incorporates cpg's Supplement to petition or cpg /GANE's Response- to NRC Staf f 's Second Interrogatories, specify by

! document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-28 In response to Interrogatory 8.2-3 you have stated

"[alll Notices of Violation relate to implementing the required test procedures for welds." Do you mean that you do not rely in support of your Contention No. 8 upon any Notices of Violations which relate to any other aspect of the construction of VEGp (i.e. concrete, procurement,

> failure to take corrective action, welding procedures which do not relate to testing the welds)?

! 8.2-29 i If your answer to the preceding interrogatory is "no",

please respond to Interrogatory 8.2-3 and limit your response to the question which is asked in Interrogatory 8.2-3.

l 8.2-30 In response to Applicants' Interrogatory Number 8.2-3, you have stated that "Intervenors will provide further information if warranted following review of Applicants'

responses to Intervenors' ' Third Set of Interrogatories

~

and Request to Produce

and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.2-31 In response to Interrogatory Number 8.2-3, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allegations set forth in response to Interrogatory 8.2-3.

8.2-32 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-33 In response to Applicants' Interrogatory Number 8.2-4, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.2-34 In response to Interrogatory Number 8.2-4, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allegations set forth in response to Interrogatory 8.2-4.

8.2-35 If your response to the preceding. interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-36 In response to Interrogatory 8.2-5 you state "[w] eld-ing deficiencies in containment liner penetrations are fundamentally dangerous." Please respond by stating yes or no whether you contend any deficiency involving welds in containment liner penetrations has resulted in any uncorrected deficient condition at VEGP?

8.2-37 If your answer to the preceding interrogatory is "yes", respond to Interrogatory 8.2-5.

8.2-38 In response to Applicants' Interrogatory Number 8.2-5, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce

and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-

. ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.2-39 In response to Interrogatory Number 8.2-5, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allegations set forth in response'to Interrogatory 8.2-5.

8.2-40 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-41 Please state by answering yes or no whether you are presently capable of responding to Interrogatory 8.2-6.

8.2-42 If you are presently capable of responding to Inter-rogatory 8.2-6, respond to that Interrogatory by answering yes or no.

~ ~

8.2-43 In response to Interrogatory Number 6.2-6, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allegations set forth in response to Interrogatory 8.2-6.

8.2-44 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG / GAGE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-45 Please state by answering yes or no whether you are presently capable of responding to Interrogatory 8.2-7.

8.2-46 If you are capable of responding to Interrogatory 8.2-7, please state yes or no whether you contend any failure as alleged in Interrogatory 8.2-6 evidences a deficiency in the quality assurance program at VEGP?

8.2-47 If your response to the preceding Interrogatory is "yes", please respond to Interrogatories 8.2-7(a),(b),(c),

(d) and (e).

8.2-48 In response to Interrogatory Number 8.2-7, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document

which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allegations set forth in response to Interrogatory 8.2-7.

8.2-49 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-50 Please state by answering yes or no whether you are presently capable of responding to Interrogatory 8.2-8.

8.2-51 If you are capable of responding to Interrogatory 8.2-8, please state yes or no whether you' contend that any failure as alleged in Response to Interrogatory 8.2-6 has resulted in an uncorrected deficiency at VEGP.

8.2-52 If your response to the preceding Interrogatory is "yes", please respond to Interrogatories 8.2-8(a),(b),

(c),(d) and (e).

8.2-53 In response to Interrogatories 8.2-9, 8.2-10 and 8.2-11, you have stated: "

. . . for example, the

)

August 31, 1983 notice of violation 50-424 & 425/83-16."

please answer ves or no whether this is the only instance in which you contend that Applicants failed to assure that nondestructive testing of welds was conducted consistent

.with applicable codes?

8.2-54 If your answer to the preceding Interrogatory is "no",

state each and every other instance which you contend to support your contention that applicants failed to assure that nondestructive testing of welds was conducted con-sistent with applicable codes.

8.2-55 In response to Applicants' Interrogatory Number 8.2-9, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." please provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.2-56 s

In response to Interrogatory Number 8.2-9, you have incorporated allegations set forth in cpg's Supplement to

}

Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allegations set forth in response to Interrogatory 8.2-9.

8.2-57 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-58 In response to Interrogatory 8.2-12 you have stated:

"Please see the letter from James P. O'Reilly to Georgia Power, 28 September 1983 '. . .

" Please state yes or no

. whether you know of any other " allegation" made by "a Walsh Company boilermaker that improper welding and work practice had occurred" other than those allegations which are set forth in the letter from James P. O'Reilly referred to in response to Interrogatory 8.2-12.

8.2-59 If your response to the preceding Interrogatory is "yes", please fully respond to Interrogatories 8.2-12(a),

(b),(c),(d) and (e).

8.2-60 In response to Applicants' Interrogatory Number 8.2-12, you stated that: "Intervenors will provide fur-ther infdrmation if warranted following review of Appli-cants' responses to Intervenors' ' Third Set of Interroga-tories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." Please provide such further informa-tion. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.2-61 In response to Interrogatory Number 8.2-12, you have incorporated allegations set forth in CPG's Supplement to Petition and cpg /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allegations set forth in response to Interrogatory 8.2-12.

8.2-62

If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by j document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-63 In response to Interrogatory 8.2-14 you state "Appli-cants have repeatedly been cited by the Nuclear Regulatory

" please state yes Commission for inadequate welding . . .

or no whether you know of any claim of inadequate welding other than those described in Notices of Violation received from the Nuclear Regulatory Commission.

8.2-64 If your response to the preceding Interrogatory is "yes", respond to Interrogatories 8.2-14(a),(b) and (c).

8.2-65 In response to Applicants' Interrogatory Number 8.2-13, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." please provide such further informa-tion. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

I l

l I 8.2-66 In response to Interrogatory Number 8.2-13, you have incorporated allegations set forth in CPG's Supplement to Petition-and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allegations set forth in response to Interrogatory 8.2-13.

8.2-67 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-68 Please respond by answerino yes or no whether you are aware of any instance in which Applicants have been ". . .

restricting quality assurance methods to explicitly desig-nated procedures in disregard to more comprehensive stan-dards of engineering practice . . . (as set forth at page l

14 of your Amendment to Supplement to Petition to Inter-vene and for Rehearing filed May 27, 1984).

l

8.2-69 If your response to the preceding Interrogatory is "yes", please respond to Interrogatories 8.2-18(a),(b),(c) and (d).-

8.2-70 In response to Applicants' Interrogatory Number 8.2-16, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." Please provide such further informa-tion. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.2-71 In response to Interrogatory Number 8.2-16, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call 'at the time of hearing in support of the allegations set forth in response to Interrogatory 8.2-16.

8.2-72 If your response to the preceding interrogatory

're-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.2-73 In response to Interrogatory 8.2-17, you have incor-porated by reference CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interroga-tories. Please cite by document and page number specif-ically where either of those pleadings identifies and describes the "more comprehensive standards of engineering practice" which should have been followed, as requested in Intarrogatory 8.2-17.

8.2-74 In response to Interrogatory 8.2-19, you have stated "yes. Please see relevant responses above." However, you have also stated that you ". . . have not and will not inspect Applicants' welds." (See Response to Interroga-tory 8.2-18.) Please respond by answering yes or no whether you know of any particular weld at VEGP which is presently unsafe.

8.2-75 If your response to the preceding Interrogatory is "yes", please respond to Interrogatories 8.2-19(a),(b),(c) and (d).-

3. CONCRETE:

8.3-13 In respcnse to Applicants' Interrogatory Number 8.3-4, l you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and dequest to Produce' and the Applicants' Re:sponses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.3-14 In response to Applicants' Interrogatory Number 8.3-4, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.3-4.

8.3-15 If your response to the preceding interrogatory re-incorporates CPG's Supplement to petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.3-16 In response to Applicants' Interrogatory Number 8.3-5, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.3-17 In response to Applicants' Interrogatory Number 8.3-5, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the alle-gations set forth in response to Interrogatory 8.3-5.

8.3-18 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.3-19 Respond by answerinc Yes or no whether you know of any testing (adequate or inadequate) of lifting eyes of con-crete covers.

8.3-20 If your answer to the preceding Interrogatory is "yes," please identify each document upon which you rely in support of your contention that the testing of concrete covers was inadequate.

8.3-21 If your response to Interrogatory 8.3-19 is "yes,"

please identify each witness upon which you rely in sup-port of your contention that the testing of lifting eyes of concrete covers was inadequate.

9 8.3-22 In response to Applicants' Interrogatory Number 8.3-6, you have incorporated allegations set forth in CPG's Supplement to Petition and cpg /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each-document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the alle-gations set forth in response to Interrogatory 8.3-6.

8.3-23 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or cpg /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.3-24 In response to Applicants' Interrogatory Number 8.3-6, I

you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality l

l

-J5-l l

assurance." Provide such further information. If you have no such further inform-tion, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.3-25 Please state by answering yes or no whether you con-tend that any test of lifting eyes of concrete hatch covers has resulted in any uncorrected deficient condition at VEGP.

8.3-26 .

If your response to the preceding Interrogatory is "yes," respond fully and completely to Interrogatories 8.3-7(a),(b),(c),(d),(e),(f) and (g).

8.3-27 l

Please respond by answering yes or no whether you are aware of any allegations made by former or present employees of inadequate concrete QC testing and/or falsi-fication of QC test records other than those allegations l

l which are referred to and discussed in I & E Report 83-06 l

l (the July 1981/ October 1982 SALP).

8.3-28 l

If your answer to the preceding Interrogatory is "yes," please respond fully and completely to Interroga-tories 8.3-8(a),(b),(c) and (d).

I i i

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i l 8.3-29 In response to Applicants' Interrogatory Number 8.3-8, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.3-8.

8.3-30 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.3-31 In response to Applicants' Interrogatory Number 8.3-8, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to l

Intervenors' follow-up questions concerning quality assurance." provide such further information. If you have no such further information, indicate that fact by l

l L

stating: " Joint Intervenors have no such additional information."

8.3-32 please respond by answerina yes or no whether there is any basis for your contention that " Applicants' QA/QC program has been inadequate with' regard to properly docu-menting the placement of concrete" other than the facts and circumstances which are discussed in I & E Report 83-06 (the July 1981-October 1982 SALp).

8.3-33 If your response to the preceding Interrogatory is "yes," please respond fully and completely to Interroga-tory 8.3-10(a),(b),(c) and (d).

8.3-34 In response to Applicants' Interrogatory Number 8.3-10, you have incorporated allegations set forth in cpg's Supplement to petition and cpg /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.3-10.

8.3-35 If your response to the preceding interrogatory re-incorporates cpg's Supplement to petition or cpg /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.3-36 In response to Applicants' Interrogatory Nunber 8.3-10, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' .

Responses to Intervenors' follow-up questions concerning quality assurance." Provide such further information. If '

you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.3-37 Please respond by answering yes or no whether you have ,

any basis for your contention "that Applicants' QA/QC program has been inadequate with regard to testing of con-crete," other than that which is specifically described in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories.

8.3-38 If your answer to the preceding Interrogatory is "yes," respond in full to Interrogatories 8.3-il(a),(b),(c) and (d).-

8.3-39 In response to Applicants' Interrogatory Number 8.3-11, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.3-11.

8.3-40 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.3-41 In response to Applicants' Interrogatory Number 8.3-11, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." Provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.3-42 Please respond by answering yes or no whether you are aware of any basis for your contention that " Applicants' QA/QC program has been inadequate with regard to prepara-tion of correct concrete quality test records" other than that which is set forth in CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's-Second Interrogatories.

8.3-43 If your response to the preceding Interrogatory is "yes," please respond to Interrogatory 8.3-12(a),(b),(c) and (d).

8.3-44 In response to Applicants' Interrogatory Number 8.3-12, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.3-12.

8.3-45 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or cpg /GANE's Response'to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.3-46 In response to Applicants' Interrogatory Number 8.3-12, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." Provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.3-47 Please state by responding yes or no whether you are presently capable of answering Interrogatories 8.3-13(a),

(b),(c),(d) and (e).

8.3-48 If your response to the preceding Interrogatory is "yes," provide a response to Interrogatory 8.3-13, includ-ing its subparts.

8.3-49 In response to Applicants' Interrogatory Number 8.3-13, you have incorporated allegations set forth in cpg's Supplement to petition and cpg /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.3-13.

8.3-50 If your response to the preceding interrogatory re-incorporates CPG's Supplement to petition or cpg /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.3-51 In response to Applicants' Interrogatory Number 8.3-13, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.3-52 In rssponse to Interrogatory No. 5 of NRC Staff's Second Interrogatories, you have stated, inter alia, "there are voids in the auxiliary building concrete."

Specifically identify each document which you will intro-duce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allegation that "there are voids in the auxiliary building concrete."

8.3-53 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NPC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it

. is responsive to the preceding interrogatory.

4. EQUIPMENT PROTECTION:

8.4-9 In response to NRC Staff's Second Interrogatories, you stated: "In 1974, the Georgia power QA manual did not adequately describe the QA program for . . . procure-ment." Identify specifically and with detail each and every deficiency which you contend related to the QA manual for procurement in 1974.

8.4-10 If your response to the preceding Interrogatory merely incorporates the allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories, state specifically by line and page where those documents specify the purported deficiency in the QA manual with regard to procurement.

8.4-11 In response to Applicants' Interrogatory Number 8.4-1, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.4-1.

8.4-12 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.4-13 In response to Applicants' Interrogatory Number 8.3-13, you have stated that "Intervonors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." Provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.4-14 Respond by stating yes or no whether you are aware of any basis for the contention that Applicants' " method of equipment storage at VEGP evidences a deficiency in the quality assurance program at VEGP" other than facts and circumstances which are described at I & E Report 83-06 (the July 1981-October 1982 SALP).

8.4-15 If your response to the preceding Interrogatory is "yes," please respond specifically to Interrogatories 8.4-1(a),(b),(c),(d) and (e).

8.4-16 In response to Interrogatory 8.4-3, you stated " Inter-venors have not personally inspected the electrical cabi-nets on site." Please respond by answerina yes or no whether you have any knowledge of facts or circumstances regarding damage done to any electrical cabinets on site.

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8.4-17 If your response to the preceding Interrogatory is "yes," please respond to Interrogatories 8.4-3(a),(b),

(c),(d),(e), and (f).

8.4-18 At page 13 of cpg /GANE's Response to Applicants' Second Set of Interrogatories and Request for Production of Documents, you purport to answer Interrogatory 8.4-5 and yet there is a response to Interrogatory 8.4-5 also appearing on page 14 of your response. Please state by answering yes or no whether your response no. 8.4-5 which begins at page 13 is actually intended as your response to 8.4-4.

8.4-19 If your response to the preceding Interrogatory is "no," please provide a response to Interrogatory No. 8.4-4.

8.4-20 In response to Applicants' Interrogatory Number 8.4-5, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega- -

tions set forth in response to Interrogatory 8.4-5.

8.4-21 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.4-22 In response to Applicants' Interrogatory Number 8.4-4, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.4-23 In response to Applicants' Interrogatory Number 8.4-5, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically iden'tify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.4-5.

8.4-24 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.4-25 In response to Applicants' Interrogatory Number 8.4-5, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.4-26 In response to Applicants' Interrogatory Number 8.4-6, you.have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC i Staff's Second Interrogatories. Specifically identify-j each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you I

! will call at the time of hearing in support of the allega-i tions set forth in response to Interrogatory 8.4-6.

i 8.4-27 If your, response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response'to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.4-28 In response to Applicants' Interrogatory Number 8.4-6,

-you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.4-29 In response to Applicants' Interrogatory Number 8.4-7, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.4-7.

8.4-30 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response'to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.4-31 In response to Applicants' Interrogatory Number 8.4-7, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce

and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.4-32 In response to Applicants' Interrogatory Number 8.4-8, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.4-8.

8.4-33 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.4-34 In response to Applicants' Interrogatory Number 8.4-8, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

5. CORRECTIVE ACTION:

8.5-4 Please answer by responding yes or no whether cpg's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories sets forth any specific instance in which Applicants have failed to take correc-tive action as alleged in Contention No. 8.

8.5-5 If your response to the preceding Interrogatory is "yes," please specify by pleading and by page number each time you'have described the specific instance to which you refer.

8.5-6 If your response to Interrogatory 3.5-4 is "yes,"

please respond to Interrogatory 8.5-1(a),(b),(c) and (d).

8.5-7 In response to Applicants

Interrogatory Number 8.5-1, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.5-1.

8.5-8 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by i

document and page number where either of those pleadings identifies documentary evidence or witnesses such that it l

is responsive to the preceding interrogatory.

8.5-9 In response to Applicants' Interrogatory Number 8.5-8, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors',' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.5-10 In response to Applicants' Interrogatory Number 8.5-2, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you

- will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.5-2.

8.5-11 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.5-12 In response to Applicants' Interrogatory Number 8.5-2, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information.'

8.5-13 In response to Interrogatory 8.5-3, you have stated "yes," that Applicants' failure to take corrective action in response to any Notice of Violation has resulted in an unsafe and uncorrected condition at VEGP. In support of that accusation, you have incorporated allegations described in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories.

Please now respond by answering yes or no whether CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories sets forth any fact or cir-cumstance upon which you rely in support of your conten-tion that Applicants' failure to take corrective action in response to any notice violation has resulted in an unsafe and uncorrected condition at VEGP.

I l

1 8.5-14 If your response to the preceding Interrogatory is "yes," specify by document and page number each and every reference to the allegation that Applicants' failure to take corrective action in response to any notice of viola-tion has resulted in an unsafe and uncorrected condition at VEGP.

8.5-15 In response to Applicants' Interrogatory Number 8.5-3, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.5-3.

8.5-16 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.5-17 In response to Applicants' Interrogatory Number 8.5-3, you have stated that "Intervenors will provide further

information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Inte rveno'rs ' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

6. GENERAL:

8.6-32 In response to Interrogatory 8.6-1, you have incorpo-rated by reference CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interroga-tories. Please state by answering yes or no whether either of these two documents identifies each violation by

" Applicant to NRC regulations, rules or other requirements which violation (s) you contend involved a Contention No. 8 activity, as referred to in Interrogatory 8.6-1.

8.6-33 If your response to the preceding Interrogatory is "yes," please specify by document and page number where either of the two documents incorporated in response to Interrogatory 8.6-1 identifies any violation by Applicants of NRC regulations, rules or other requirements which vio-lation(s) you contend involved a Contention No. 8 activity.

8.6-34 In response to Applicants' Interrogatory Number 8.6-1, you have incorporated allegations set forth in CPG's Supplemen't to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.6-1.

8.6-35 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.6-36 In response to Applicants' Interrogatory Number 8.6-1, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.6-37 In response to Interrogatory 8.6-2, you incorporated CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Please state ves or no whether either of these two documents identifies each violation of NRC regulations by Applicants in the con-struction methods (which violation relates to a Contention 1 No. 8 activity) which you contend undermines the confi-dence and capability of the coolant and containment systems to perform their essential tasks.

8.6-38 If your response to the preceding Interrogatory is "yes," please specify by document and page number where either of the two documents incorporated is responsive to Interrogatory 8.6-2.

8.6-39 In response to Applicants' Interrogatory Number 8.6-2,

- you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.6-2.

8.6-40 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response'to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.6-41 In response to Applicants' Interrogatory Number 8.6-2, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.6-42 In response to Interrogatory 8.6-3 you have incorpo-rated CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Please state yes or no whether either of these two documents explains the basis for your contention that a violation referred to in response to Interrogatory 8.6-3 has adversely affected or evidences a deficiency in the quality assurance program at VEGP.

8.6-43 If your response to the preceding Interrogatory is "yes," please specify by document and page number where either of the two documents incorporated in response to Interrogatory 8.6-3 responds to Interrogatory 8.6-3.

8.6-44 In response to Applicants' Interrogatory Number 8.6-3, you have incorporated allegations set forth in cpg's Supplement to petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.6-3.

8.6-45 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.6-46 In response to Applicants' Interrogatory, Number 8.6-3, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce

and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

"Jo i r.t Intervenors have no such additional information."

8.6-47 Respond to Interrogatory 8.6-4.

8.6-48 In response to Interrogatory 8.6-5 you have stated:

"If workers were rdequately trained, the problems should not have occurred." Please identify specifically the

" problems" to which you refer.

8.6-49 In response to Interrogatory 8.6-5, you have incorpo-rated CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Please state yes or no whether either of these two documents addresses the questions raised in Interrogatories 8.6-5(a),(b),(c) and (d).

8.6-50 I If your restcase to the preceding Interrogatory is l

"yes," please spec;fy by document and page number where either of those documen's are ret onsive to Interrogatory 8.6-5(a),(b),(c) and (d).

l l

c l !

l i

8.6-51 In response to Applicants' Interrogatory Number 8.6-5, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.6-5.

8.6-52 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to URC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it 4

is responsive to the preceding interrogatory.

8.6-53 In response to Applicants' Interrogatory Number 8.6-5, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Interrogatories and Request to Produce

and the Applicants' Responses to Intervenors' follow-up questions concerning quality assur-ance." Provide such further information. If you have no such further information, indicate that fact by stating:

" Joint Intervenors have no such additional information."

8.6-54 Please re'spond to Inte,rrogatory 8.6-7.

8.6-55 If y6ur response to Interrogatory 8.6-7 incorporates either CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, please specify by document and page number where either of those documents is responsive to Interrogatory 8.6-7.

8.6-56 Specifically identify each document which you will introduce at the time of hearing for the ASLB upon which you which rely in support of your contention that any procedure has been changed because workers were unable to comply with original procedures.

8.6-57 Specifically identify each witness whom you will call

~

at the time of hearing before the ASLB in support of your

. contention that any procedure has been changed because workers were unable to comply with original procedures.

8.6-58 Please respond to Interrogatory 8.6-8.

8.6-59 If your response to Interrogatory 8.6-8 incorporates either CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, please specify by

document and page number where either of those documents is responsive to Interrogatory 8.6-8.

(

8.6-60 Please respond to Interrogatory 8.6-9.

8.6-61 If your response to Interrogatory 8.6-9 incorporates to Petition or CPG /GANE's Response eitperCPG'sSupplement to NRC Staff's Second Interrogatories, please specify by document and page num' er where either of those documents is responsive to Interrogatory 8.6-9.

8.6-62 in response to Interrogatory 8.6-11, you have incorpo-rated CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Please state by answering yes or no whether either of these documents specifically identifies any " failure" to which you refer when you allege (at page 17 of CPG's Supplement to Peti-tion) that "[t]he number of past and continuing failures

. . . indicates an undue risk to health and safety of the public."

8.6-63 If your answer to the preceding Interrogatory is "yes," please specify by document and page number where either of those documents is responsive to the questions ,

asked in Interrogatory 8.6-11, including its subparts.

8.6-64 In response to Applicants' Interrogatory Number 8.6-11, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.6-11.

8.6-65 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.6-66 In response to Applicants' Interrogatory Number 8.6-11, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." Provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.6-67 In rdsponse to Interrogatory 8.6-12, you have incorpo-rated CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Please state by answering yes or no whether either of these two documents addresses the specific questions raised in Interrogatory 8.6-12, including its subparts.

8.6-68 If your response to the preceding Interrogatory is "yes," please specify by document and page number where either of those two documents incorporated in response to Interrogatory 8.6-12 is responsive to any of the questions raised in Interrogatory 8.5-12, including its subparts.

8.6-69 In response to Applicants' Interrogatory Number 8.6-12, you have incorporated allegations s,et forth in i

CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.6-12.

8.6-70 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response'to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or wirnesses such that it is responsive to the preceding interrogatory.

8.6-71 In response to Applicants' Interrogatory Number 8.6-12, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." Provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.6-72 In response to Interrogatory 8.6-13, you have objected to providing the names of the individuals requested ". . .

on the grounds that it is a violation of privacy of individuals who may have spoken to Intervenors." Please respond by answering yes or no to each of the following subparts:

(a) Do you plan to reveal the names of those indi-viduals at the time of hearing before the ASLB; (b) Do you plan to use, at the time of hearing before "the ASLB, the substance of any information or allegation provided by any such individual; (c) Do you plan to call any such individual as a witness at the time of hearing before the ASLB.

8.6-73 State the substance of any testimony you will solicit from any witness at the time of hearing before the ASLB (whether the witness wishes to remain anonymous or not) which testimony will relate to interrogatory 8.6-13.

8.6-74 In response to Interrogatory 8.6-13 you have objected to identifying the individuals requested ". . . on the grounds that it is a violation of privacy of individuals who may have spoken to Intervenors." Please respond by

- answering yes or no whether you have inquired of those individuals whether they would allow you to identify them to Applicants in response to this discovery.

8.6-75 In response to Interrogatory 8.6-15 you have incorpo-rated CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Please state by responding yes or no whether there are any other facts or circumstances upon which you rely in support of Contention No. 8 other than those which are specifically described in CPG's Supplement to Petition and in response to NRC Staff's second Interrogatories.

8.6-76 If your response to the preceding Interrogatory is "yes," please respond to Interrogatory 8.6-15.

8.6-77 In response to Applicants' Interrogatory Number 8.6-15, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.6-15.

8.6-78 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.6-79 In response to Applicants' Interrogatory Number 8.6-15, you have stated that "Intervenors 14ill provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." Provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.6-80 In response to Interrogatory 8.6-16 you have incorpo-rated CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Please state by responding yes or no whether there are any other facts or circumstances upon which you rely in support of Contention No. 8 other than those which are specifically described in the CPG's Supplement to petition and in response to NRC Staff's Second Interrogatories.

8.6-81 If your response to the preceding Interrogatory is "yes," please respond to Interrogatory 8.6-16.

8.6-82 In response to Applicants' Interrogatory Number 8.6-16, you have incorporated allegations set forth in CPG's Supplement to petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.6-16.

8.6-83 If your response to the preceding interrogatory re-incorporates cpg's Supplement to petition or cpg /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.6-84 In response to Applicants' Interrogatory Number 8.6-16, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." provide such further information. If you have nc such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.6-85 In response to Interrogatory 8.6-17, you stated: "It depends upon the reasons behind the specific Stop Work Orders. . .. Please respond by answering yes or no whether you have any knowledge of any of the reasons behind any of the Stop Work Orders at VEGP.

~

8.6-86 If your response to the preceding Interrogatory is "yes," please respond to Interrogatory 8.6-17, including its subparts.

8.6-87 Please respond by answering yes or no whether you con-tend that there has been any failure at VEGP to issue a Stop Work Order when needed.

8.6-88 If your response to the preceding Interrogatory is "yes," please explain in detail the basis for your allega-tion and include within your explanation:

(a) the Stop Work Order to which you refer; (b) the particular work to which it was or should have been directed; (c) the date it was or should have been issued; (d) the manner in which it affected the QA program; (e) the identify of all persons whom you believe to have knowledge of facts or circumstances upon which you base your contention; (f) the identification of any document upon which you rely in support of your contention or explanation.

8.6-89 Respond by stating yes or no whether you contend that any corrective action following the issuance of a Stop Work Order has been inadequate prior to resumption of work.

8.6-90 If your response to the preceding Interrogatory is "yes," please explain in detail the basis for such conten-tion and include within your explanation:

(a) the Stop Work Order to which you refer; (b) the particular work to which it was directed; (c) the date it was issued; (d) the corrective action which should have been taken; (e) the corrective action which was, in fact, taken (if any);

(f) the identity of all persons whom you believe to have knowledge of facts or circumstances upon

. which you base your contention; (g) the identification of any document upon which you rely in support of your contention or explanation.

8.6-91 If your response to Interrogatory 8.6-88 or 8.6-90 incorporates either cpg's Supplement to petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, please specify by document and page number where either of these documents incorporated in response to these Inter-rogatories is responsive to the Interrogatories.

8.6-92 In response to Interrogatory 8.6-19, you stated: "It depends upon the reasons for the deviations." State by answering yes or no whether you have any knowledge of the reasons for any of the deviations from original design specifications or procedures at VEGP.

8.6-93 If your response to the preceding Interrogatory is "yes," please respond to Interrogatory 8.6-19, including its subparts.

8.6-94 If your response to Interrogatory 8.6-92 incorporates either CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those two documents is responsive to that Interrogatory or Interrogatory 8.6-19.

8.6-95 In response to Interrogatory 8.6-22, you have incorpo-rated CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Please state yes or no whether either of these two documents explains the basis for your statement which is quoted in Interrogatory 8.6-22.

8.6-96 If your response to the preceding Interrogatory is "yes," please specify by document and page number where either of these two documents is responsive to Interroga-tory 8.6-22.

8.6-9'7 In response to Applicants' Interrogatory Number 8.6-22, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.6-22.

8.6-98 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.6-99 In response to Applicants' Interrogatory. Number 8.6-22, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality issurance." Provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.6-100 In response to Interrogatory 8.6-23, you have incor-porated CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. State yes or no whether either of these two documents identifies any vendor or contractor or subcontractor who has f ailed to comply with any quality assurance requirements within the scope of your Contention No. 8.

8.6-101 If your response to the preceding Interrogatory is "yes," specifically describe by document and page number where either of these two documents is responsive to Interrogatory 8.6-23.

8.6-102 In response to Applicants' Interrogatory Number 8.6-23, you have incorporated allegations set forth in CPG's Supplement to Petition and CPG /GANE's Response to NRC Staff's Second Interrogatories. Specifically identify each document which you will introduce at the time of hearing before the ASLB and identify each witness whom you will call at the time of hearing in support of the allega-tions set forth in response to Interrogatory 8.6-23.

8.6-103 If your response to the preceding interrogatory re-incorporates CPG's Supplement to Petition or CPG /GANE's Response to NRC Staff's Second Interrogatories, specify by document and page number where either of those pleadings identifies documentary evidence or witnesses such that it is responsive to the preceding interrogatory.

8.6-104 In response to Applicants' Interrogatory Number 8.6-23, you have stated that "Intervenors will provide further information if warranted following review of Applicants' responses to Intervenors' ' Third Set of Inter-rogatories and Request to Produce' and the Applicants' Responses to Intervenors' follow-up questions concerning quality assurance." Provide such further information. If you have no such further information, indicate that fact by stating: " Joint Intervenors have no such additional information."

8.6-105 In response to Interrogatory 8.6-24, you have objected on the grounds that "[t]o fully respond would be unduly ,

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

burdensome." How many individuals have you spoken to who fall within the description of Interrogatory 8.6-24?

8.6-106 In response to Interrogatory 8.6-24, you have objected on the grounds that a response "would violate the privacy of individuals who may have communicated with Inter-venors . . . Please respond by answering yes or no to each of the following subparts:

(a) Do you plan to reveal the names of those indi-viduals at the time of hearing before the ASLB; (b) Do you plan to use, at the time of hearing before the ASLB, the substance of any information or allegation provided by any such individual; (c) Do you plan to call any such individual as a witness at the time of hearing before the ASLB.

8.6-107 State the substance of any testimony you will solicit from any witness at the time of hearing before the ASLB (whether *.he witness wishes to remain anonymous or not) which testimony will relate to interrogatory 8.6-24.

8.6-108 Please respond by answering yes or no whether you are presently capable of identifying any person who fits the description set forth in Interrogatory 8.6-24.

8.6-109 Please state by answering yes or no whether you are capable of responding to Interrogatory 8.6-25, even though you refuse to respond to the Interrogatory on a claim of privilege.

8.6-110 Please respond by answering yes or no whether you have had any communication with Governmental Accountability Project concerning the quality assurance program at VEGP.

8.6-111 Please state by answering yes or no whether you have any communication with Union of Concerned Scientists concerning the quality assurance program at VEGP.

8.6-112 In response to Interrogatory 8.6-26, and Interrogatory 8.6-27, you have objected to answering partially on the grounds that "

. . . it violates privacy . . . [and] . . .

violates constitutional rights . . .. Please respond by answering yes or no whether you plan to reveal their names or use their testimony at a hearing before the ASLB on your Contention No. 8.

8.6-113 With regard to any communication with Government Accountability Project or Union of Concerned Scientists which you might have had, have you consulted with either

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

of those organizations to determine whether they object to your identifying that communication to Applicants in response to Interrogatory 8.6-26 or 8.6-27?

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8.6-114 In response to Interrogatory 8.6-29, you have stated:

"Intervenors will make available all documents used in formulating these responses, with the exception of those which might violate privacy." Applicants, through their counsel, have now reviewed the documents produced by Intervenors on Wednesday, February 20, 1985. None of those documents describe the Interrogatory response to which the document pertained nor is your answer to Inter-rogatory 8.6-28 responsive to this aspect of the Inter-rogatory. Please identify, by document description,'

the Interrogatory response to which the document which has been produced pertains.

8.6-115 s In response to Interrogatory 8.6-29, you have not identified or produced any document which "might violate privacy." Please identify each document which has been withheld from production on the ground that it "might violate privacy."

5 Please carefully read and comply with the preceding enumerated Paragraph 1 of the instructions set forth on page 2 above.

S.6-116 In response to Interrogatory 8.6-30, you have stated:

"These responses were prepared in their entirety by Doug Teper and Tim Johnson." Please respond by answering yes or no whether either Mr. Teper or Mr. Johnson consulted any other person in forming their response to any Inter-rogatory set forth herein or in Applicants' Second Interrogatories.

8.6-117 If your response is "yes", please respond to Interrogatory 8.6-30.

8.6-118 Identify each and every person who has provided infor-mation or with whom you have consulted in forming your response to any of the preceding Interrogatories and with regard to each person identified, please state the response to which that person was consulted or provided information.

8.6-119 To the extent you have not done so already in response to any particular Interrogatory, identify each document which you have consulted in formulating your response, or which relates to your response, to any of the preceding Interrogatories and describe the Interrogatory response to which the document pertains.

8.6-120 Respond to Interrogatory 8.6-31.

8.6-121 Identify each document upon which you will rely at the time of hearing in support of your Contention No. 8.

8.6-122 Identify each witness whom you will call in support of your Contention No. 8 at the time of hearing before the ASLB.

8.6-123 State the substance of any testimony you will solicit from any witness at the time of hearing before the ASLB (whether the witness wishes to remain anonymous or not).

III. REQUEST FOR PRODUCTION OF DOCUMENTS Applicants request that Intervenors respond in writing to the following requests for production of documents and produce or make available for inspection and copying at a designated location the original and each copy of the documents requested below that are in possession, custody or control of Intervenors.

The document shall be deemed to be within the " con-1 trol" of Intervenors if Intervenors have ownership, pos-

. session or custody of the document or a copy thereof or have the right to secure the document or copy thereof from any person or public or private entity having physical possession thereof.

The instructions and definitions set forth in Part I

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of these Interrogatories and Request for Production of Documents are also applicable to this Request for Produc-tion of Documents.

Documents Requested 8-47. Each and every document which has been received by Legal Environment Assistance Foundation in response to a freedom of information request made to the Nuclear Regulatory Commission pertaining to documents regarding the adequacy of the core cooling system of Vogtle Nuclear Power Plant.

8-47. Any document upon which you have relied or which relates to your response to any of the preceding Interrogatories.

8-49. Each and every document upon which you will rely at the time of hearing before the ASLB in support of your Contention No. 8.

Respectfully submitted, b.

Jhmes E. Joinet, P.C.

Charles W. Whitney Kevin C. Greene Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN

& ASHMORE George F. Trowbridge, P.C.

Bruce W. Churchill, P.C.

David R. Lewis SHAW, PITTMAN, POTTS

& TROWBRIDGE Dated: March {fh,1985

-me-

I UNITED STATES OF AMERICA ' 'j ' '. [ l' NUCLEAR REGULATORY COMMISSION

.n . -3

.35 Before the Atomic Safety and Licensing._ Board G0Ci(Tina'i 55gy,b BRANCH In the Matter of )

)

GEORGIA POWER COMPANY, et al. ) . Docket Nos. 50-424

' ~'

) 50-425 (Vogtle Electric Generating Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' Fourth Set of Interrogatories And Request For Production Of Documents, dated March 5, 1985, were served upon those persons on the attached Service List by deposit in the United States mail, postage pre-paid, or where indicated by an asterisk (*) by hand delivery, this 5th day of March, 1985.

b. b James E. Joinfr, P.C.

Counsel for Applicants Dated: March 5, 1985

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the matter of: :

GEORGIA POWER COMPANY, e_t_ a l_. : Docket Nos. 50-424

50-425 (Vogtle Electric Generating :

Plant, Units 1 and 2) :

SERVICE LIST .

Morton B. Margulies, Chairman Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U.S. Nuclear Regulatory Comission Atlanta, Georgia 30306 Washington, D.C. 20555 Jeanne Stiorthouse Gustave A. Linenberger 507 Atlanta Avenue Atomic Safety and Licensing Board Atlanta, Georgia 30315 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 S Laurie Fowler & Vickie Breman Legal Environmental Assistance Dr. Oscar H. Paris Foundation Atomic Safety and Licensing Board 1102 Healey Building U.S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D.C. 20555 5 Tim Johnson Bernard M. Bordenick, Esquire Campaign for a Prosperous Georgia Office of Executive Legal Director 175 Trinity Avenue, S.W.

U.S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Carol A. Strangler U.S. Nuclear Regulatory Comission 425 Euclid Terrace Washington, D.C. 20555 Atlanta, Georgia 30307 Atomic Safety and Licensing Appeal Dan Feig Board Panel 1130 Alta Avenue U.S. Nuclear Regulatory Comission Atlanta, Georgia 30307 Washington, D.C. 20555 Docketing and Service Section Bradley Jones, Esq. (Regional Counsel)

Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Suite 3100, 101 Marietta Street Washington, D.C. 20555 Atlanta, Georgia 30303

ML20099C524

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