ML20100B348

Reply Opposing Applicant 841114 Motion to Correct ASLB 841105 Memorandum & Order on Contention 8 Re Concrete Quality Test Records.Certificate of Svc Encl

ML20100B348
Person / Time
Site:	Vogtle
Issue date:	11/30/1984
From:	Fowler L CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY, LEGAL ENVIRONMENTAL ASSISTANCE FOUNDATION
To:	Atomic Safety and Licensing Board Panel
References
CON-#484-444 OL, NUDOCS 8412040308
Download: ML20100B348 (5)

Text

. . . ._. _ ._ __ _ _ _ _ _ _

November 30, 1984 UNITED STATES OF AMERICA '

[fD  :

NUCLEAR REGULATORY COMMISSION l l

, )

'84 gg _3 Before the Atomic Safety and Licensing Board P2:p, hfCF e In the Matter of ) 44

} Docket Ncrs. 50-424-h((*

GEORGIA POWER CO., et 61

' ~

) . 50-425

) " 4 [pqct,fy'7 fA@t ?t*'

(Vogtle Electric Generating )

Plant, Units 1 and 2 )

CPG /GANE's REPLY TO. APPLICANT'S MOTION TO CORRECT ASLB'S MEMORANDUM AND ORDER DATED NOVEMBER 5, 1984 In its " Motion to Correct ASLB's Memorandum and Order Dated y November 5, 1984," filed on November 14, 1984, Applicant requests the Board to delete from Contention 8 the words "for the preparation of correct concrete quality test records."

Applicant claims that such a change is appropriate in light of the fact that a NRC investigation stemming from NRC SALP Report (IE Report No. 83-06), which both CPG and GANE alluded to in their original bases, resulted in a finding that allegations of falsification of concrete quality test records were unfounded.

CPG /GANE objects to any amendment of Contention 8. A close examination of the NRC Investigation, documented in IE Report No. 81-09 and attached to Applicant's Motion, reveals that Georgia Power _ Company hasLin fact failed to keep adequate concrete quality control records. .

The NRC's inspection..of quality records related to DSO3

~

p_

m=rarmik O

c.--- v batching, inspection and testing of Unit 1 base mat concrete showed that Applicant had failed to identify the individuals who performed the in-process testing of the plastic concrete. i Applicant had also failed to identify the individuals who inspected the concrete placement for the pour in both Units 1 and 2. Applicant thus violated 10 CFR 50, Appendix B, Criteria XVII, requiring the identification of inspectors, testers or data recorders to be included on records. This incident was reported as Violation Item 424/81-09-01 and 425/81-09-01

" Failure to Maintain Sufficient QA Records in the Area of Concrete Testing." (IE Report No. 81-09 at p. II-14)

The NRC's inspection of the records on cyclinder testing performed during January 1980-1981 showed that Applicant had failed to disclose on the unconfined compression test data sheets the identity of the individuals performing cyclinder tests. NRC identified this "as another example of failure to maintain records as required by 10 CFR 50, Appendix B, Criterion XVII." (IE Report No. 81-09 at II-21)

Failure to identify testing and inspection personnel on records inhibits a close internal check on quality control procedures and hampers outside investigations into allegations of inadequate or unauthorized practices and procedures. As Applicant's own attachment shows that it has failed to maintain adequate inspection and test records to furnish evidence of-activities affecting' quality, as required-by 10 CFR 5 0,-

Appendix B, Criterion XVII, Contention 8 should be preserved in its entirety as stated by the Board. We therefore request that

, .a-Applicant's motion be denied.

Respectfully submitted, W M Laurie Fowler for:

Legal Environmental Assistance Foundation Attorney for Co-Petitioners Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy 6

e t

9 l e , g (  ?  ? f i

- I k I **T ~

• ID

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'Qg.

N'.i g.

In the Matter of )

f'g

)

GEORGIA' POWER CO., et al. OEC s3

) Docket Nos. 5 (Vogtle Electric Generating 24and5$4f}

) ' '

Plant, Units 1 and 2) )

.'jg'-

C CERTIFICATEfOF SERVICE

~

This i is to certify that copies of the foregoing Reply to s%. - '

Applicant's Motion to Correct ASLB Mehegandud'and Order Dated November 5, 1984 have been served to all parties.of record in this proceeding by deposit with the United States Postal Service in the City of Atlanta for delivery by Express Mail or by first class mail this the 30th day of November, 1984.

Respectfully submitted,

, Is M

. Laurie Fowler for:

Legal Environmental Assistance Foundation 1102 Healey Building 57 Forsyth Street ,

Atlanta, GA 30303 404-688-3299 Attorney for Co-Petitioners

~

Campaign for a Prosperous Georgia Georgians Against Nuclear Energy

- ~ - . - . , -

w=m-II g=

ff UNITED STATES OF AMERICA 57 ~ NUCLEAR REGULATORY COMMISSION F- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

GEORGIA POWER CO., et al

- - - - ) Docket Nos. 50-424

) 50-425 (Vogtle Electric Generating )

i Plant, Units 1 and 2) )

SERVICE LIST Morton B. Margulies, Chairman Atomic Safety & Licensing Board Atomic Safety & Licensing Appeal US Nuclear Regulatory Commission Board Panel Washington, D.C. 20555 US Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Oscar H. Paris Atomic Safety & Licensing-Board Docketing and Service Section US Nuclear Regulatory Commission Office of the Secretary Washington, D.C. 20555 US Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Gustave A. Linenberger Bernard M. Bordenick, esq.

Atomic Safety & Licensing Board US Nuclear Regu'.atory Commission Office of the Executive Legal Washington, D.C. 20555 Director US Nuclear Regulatory Commission

- Washington, D.C. 20555 Atomic Safety & Licensing Board Ruble A. Thomas Panel US Nuclear Regulatory Commission Southern Company Services, Inc.

P.O. Box 2625 Birmingham, Alabama 35202 George F. Trowbridge James E. Joiner <

Ernest L. Blake, Jr.

David R. Lewis Sumner C. Rosenberg Shaw, Pi t tma n , Potts & Troutman, Sanders,Lockerman &

Trowbridge Ashmore 1800 M. Street, NW 127 Peachtree Street, NE Washington, D.C. 20036 Atlanta, GA 30303 h

4