ML20106A249
| ML20106A249 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/04/1985 |
| From: | Johnson T CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY |
| To: | GEORGIA POWER CO. |
| Shared Package | |
| ML20106A232 | List: |
| References | |
| OL, NUDOCS 8502110089 | |
| Download: ML20106A249 (23) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of GEORGIA POWER CO., et al. ) Docket Nos. 50-424 and 50-425
)
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
CPG /GANE'S RESPONSE TO APPLICANTS' SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS t-
- Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy respond herein to " Applicants' Second Set of Interrogatories and Request for Production of Documents."
A. Specific Interrogatories Contention 8 (Quality Assurance) 8.1-1 Yes. Anonymous allegations of file doctoring suggest that vendors were I qualified not on the basis of the " quality assurance" program at Vogtle but rather on the basis of past work with the Applicants. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated
. April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further
.information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.1-2 Breakdowns in the Applicants' method of selecting qualified vendors could result in unsafe and uncorrected conditions at Plant Vogtle. The purpose of having 1
- DR 0-ohD4 PDR L' _
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r a methodology fSr approving only qualified vendors is to assure that the only vendors who are hired are those who will perform satisfactorily and will avoid unsafe conditions; breakdowns in this methodology (or weaknesses in the methodology) raise questions as to the safety of the work conducted by the vendors. Intervenors hereby incorporate by reference the basis for their contention as described in
" Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.1-3 Intervenors assume that Applicants' reference is to Intervenors' Interrogatory No. 3 of our Second Set of Interrogatories and Requests to Produce, since Interrogatory No. 2 does not use the phrase " Applicants' method of auditing vendors to assure compliance with contract specifications." In Interrogatory 3, Intervenors use the phrase " Applicants' method of auditing vendors to assure compliance with contract specifications" to include all methods of assuring that contractors are complying with the requirements of their contracts and by implication with all NRC regulations and standards. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
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' Deficiencies in the Applicants' auditing program obviously have serious 8.1-4_ Yes.
implications for the Vogtle QA/QC program. Anonymous informants have alleged that the Applicants fail to audit their vendors adequately. In addition Intervenors l
i hereby incorporate by reference the basis for their contention as described in i
" Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Caorgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the
. Applicants' Responses to Intervenors' followup questions concerning quality 4
assurance.
8.1-5 If the informants' information is accurate, there is substantial reason to believe that unsafe conditions at the plants would result. In addition, Intervenors hereby incorporate by reference the basis for their contention as described in
" Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for
! a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to
- Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality 1
assurance.
8.1-6 " Engineering change notice" refers to changes from original equipment specifications. For example, see Notice of Violation concerning Design Change Notices. Nov. 30 1984, Inspection Report Nos. 50-424 & 425/84-30.
( 8.1-7 Intervenors will provide a response to this interrogatory following examination of the Applicants' response to Intervenors' " Third Set of l-Interrogatories and Requests to Produce" and the Applicants' Responses to ,
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7 Intervensrs' follcwup questiens concerning quality assurance.
8.1-8 Please see the response to 8.1-7 above.
8.1-9 Yes. If the vendor (s) performed inadequately (in whatever way or ways) then the QA program should have prevented their being hired. If the vendor (s) performed adequately, then the question is raised as to why they were dismissed. In addition, Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.1-10 Yes.
8.1-11 Yes. Many, many examples could be cited, such as the installation of 239 inadequate circuit breakers in equipment at Vogtle; to cited all such examples would be unduly burdensome on the Intervenors, and we hereby refer the Applicants to the NRC's Public Document Room (as well as the Applicants' own records) as evidence. In addition Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984.
Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.1-12 Use of inferior materials or equipment by definition can result in compromising of safety at Vogtle. The response to 8.1-11 above is incorporated 4
9 herein by reference.
8.1-13 Intervenors hereby incorporate by reference the above responses related to procurement.
8.1-14 Intervenors object to this interrogatory on the grounds that it is vague, a violation of possible confidences, an invasion of privacy and would do nothing to resolve the issues of concern raised by Intervenors in this proceeding. Beyond that, Intervenors state that individuals claiming to work for the Applicants or the 4
' Applicants' vendors have expressed certain concerns, as outlined herein, and have
! withheld their names from Intervenors in order to prevent retaliation by Applicants.
! 8.1-15' Please see the response to 8.1-14 above.
8.1-16 Please see the response to 8.1-13 above.
! Welding 8.2-1 Yes. Please see letter and attachment from Donald O. Foster to James P.
O'Reilly dated October 17, 1984. An adequate QA program would prevent such
- problems. In addition, Intervenors hereby incorporate by reference the basis for I their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and
" CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following l
review of the Applicants' responses to Intervenors' " Third Set of Interrogatories l
I and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.2-2 Yes. In the words of Georgia Power's D. O. Foster, "this condition is f
! reportable as a substantial safety hazard and a significant deficiency." Please see response to 8.2-1 above.
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8.2-3 All Notices of Violation relate to implementing the required test procedures i
for welds. Some relate specifically to welding, including but not limited to Report
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I t
r N3.s 50-424 & 425/83-16, Appendix A, August 31, 1983. Others relate to walding to the extent that breakdowns in QA anywhere demonstrate the possibility of breakdowns in QA everywhere. In addition, Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of I Interrogatories and Requests to Produce" and the Applicants' Responses to 4
Intervenors' followup questions concerning quality assurance.
8.2-4 Yes. An adequate QA program should prevent the deficiencies in welding which
! have been so widespread at Plant Vogtle. In addition Intervenors hereby incorporate by reference the basis for their contention as described in " Suppl ment to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NkC Staff's l Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning' quality assurance.
8.2-5 Welding deficiencies in containment liner penetrations are fundamentally dangerous. This is self-evident. In addition Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for ,
Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April ' 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of l
_ Interrogatories" Jated December 19, 1984. Intervenors will provide further 1
information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the 6
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' Applicants' Responses to Intervenors' followuo questions concerning quality assurance.
8.2-6 Intervenors have not examined Applicant's construction sheets for examination of reactor coolant pressure boundary welds, but will respond if and when we have an opportunity to do so. In addition. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants.' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.2-7 See response to 8.2-6.
8.2-8 See response to 8.2-6.
8.2-9 Yes. See, for example, the August 31, 1983 Notice of Violation 50-424 &
i i 425/83-16. In addition, Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and i Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and r
" CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of. Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.2-10 See 8.2-9 above.
j 8.2-11 See 8.2-9 above.
8.2-12 Please see the letter from James P. O'Reilly to Georgia Power, 28 September 1983,
Subject:
Summary of Meeting--Docket Nos. 50-424 & 50-425, which was 7
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specifically referenced in our " Supplement (s] to Petition [s] for Leave to Intervene."
8.2-13 Yes. Inadequate radiography and welding procedures obviously lead to lack of confidence in safety; welding literally holds the facility together. In addition, Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for i Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984.
Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Proouce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.2-14 The Applicants' long history of problems with welding denenstrates the inadequacy of the Applicants' QA/QC program with regard to welding. Applicants have repeatedly been cited by the Nuclear Regulatory Commission for inadequate welding, a
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fundamentally clear indication of breakdowns in the QA/QC program. Please see the basis for Intervenors' contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.2-15 Yes. Please see the response to 8.2-14 above.
8.2-16 Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to retition for Leave to Intervene and Request for
' Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984.
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Inthry2nors will prcvide furth r information if warranted following review of the l Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.3-11 Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984.
Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.3-12 Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984.
Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Aes?onses to Intervenors' followup questions concerning quality assurance.
8.3-13 Yes. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and
- t. Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and
' CPG /6ANE's Response to NRC Staff's Second Set of Interrogatories" dated December
-19, 1984. Intervenors will provide further information if warranted following l
review of.the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
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r-Equipment P_rotection 8.4-1 Yes. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and
" CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following
+ reyfew of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup
. questions concerning quality a qurance.
8.4-2 Yes.- Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and
- i. ,
Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and Y A " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December
.19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.4-3 Intervenors have not personally inspected the electrical cabinets on site.
Intervenors hereby incorporate by reference the basis for their contention as e s .
L f;.4 described in " Supplement to Petition for Leave to Intervene and Request for. Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' l
responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
l 8.4-5 Yes. Intervenors hereby' incorporate by reference the basis for their 13
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T contenticn as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and
" CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors wil.1 provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance. o 8.4-5 Yes. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and
" CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.4-6 Yes. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and
" CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December
'19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intarvenors' followup questions concerning quality assurance.
8.4-7 Yes. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and l Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and
" CPG / GAME's Response to'NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further infonnation if warranted following i
+ 14 i
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review of the Applicants' responses to Intervenors' " Third Set of Interrogatories i and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
- 8.4-8 Intervenors hereby incorporate by reference the basis for their contention as 1
described in " Supplement to Petition for Leave to Intervene and Request for Hearing, i
Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to i NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors f
l will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and i
the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
.'I Corrective Action >
8.5-1 Yes. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and
[ Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and
> " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatcries and Requests to Produce" and the Applicants' Responses to Intervenors' followup
! questions concerning quality assurance.
8.5-2 Yes. Intervenors hereby incorporats by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing', Campaign for a Prosperous Georgia" dated April 11, 1984 and "CFG/GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19,1984. ~ Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup 15
e
. qu2sticns ccncerning quality assurance.
8.5-3 Yes. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and
" CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
General 8.6-1 Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, i
Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to J
NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' i responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and l
the Applicants' Responses to Intervenors' followup questions concerning quality l
assurance.
8.6-2 Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to l
NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors
! will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and l the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
!- 8.6-3 Intervenors hereby incorporate by reference the basis for their contention as I
f described in " Supplement to Petition for Leave to Intervene and Request for Hearing, 16 i
Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.6-4 Intervenors will respond to this Interrogatory upon completing review of Applicants' responses to Intervenors' discovery que::tions related thereto, f' 8.6-5 Yes. If workers were adequately trained, the problems should not have occurred. In addition, Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and i
" CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following l
review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup
! questions concerning quality assurance.
l 8.6-6 Please see related responses above.
8.6-7 Intervenors will respond further following review of Applicants' responses to related questions by the Intervenors.
8.6-8 Please see response to 8.6-7 above..
8.6-9 Please see response to 8.6-7 abeve.
8.6-10 Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984.
Intervenors will provide further information if warranted following review of the l
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- Applicants' resp:nses to Intervenors' " Third Set of Interrogatories and Requests to i Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.6-11 Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984.
Intervenors will provide further information if warranted following review of the ,
Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.6-12 Yes. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and
" CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December j 19, 1984. Intervenors will provide further information if warrarited following review of the Applicants' responses to Intervenois' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup l questions concerning quality assurance.
8.6-13 Intervenors object to this Interrogatory on the grounds that it is a violation of the privacy of individuals who may have spoken to Intervenors.
l Intervenors further state that many individual claiming to work for the Applicants' or their contractors have made certain allegations to the Intervenors but have withheld their names to prevent feared reprisals by the Applicants' or their i contractors.
i 8.6-14 Please see 8.6-13 above.
t 8.6-15 Please see the responses above. In addition Intervenors hereby incorporate
! by reference the basis for their contention as described in " Supplement to Petition i
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for Leave to Intervene and Rrquest for Hearing, Campaign for a Prosparous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.6-16 Please see the responses above. In addition. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene a:d Request for Hearing, Campaign for a Prosperous Georgia" ,
dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance..
8.6-17 It depends upon the reasons behind specific Stop Work Orders, the possible failure to issue Stop Work-Orders when needed, and the adequacy of corrective action L
prior to' resumption of work.
l 8.6-18 Please see response to 8.6-17 above.
8.6-19 It depends upon the reasons for the deviations. Intervenors will further respond as needed following review of the Applicants' responses to related inquiries by the Intervenors.
8.6-20 Please see response to 8.6-19 above.
8.6-21 Please see the responses above. In addition, Intervenors hereby incorporate l by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" i
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datcd April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Sat of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.6-22 Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11, 1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984.
Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to Intervenors' followup questions concerning quality assurance.
8.6-23 Please see the responses above. Intervenors hereby incorporate by reference the basis for their contention as described in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11.-1984 and " CPG /GANE's Response to NRC Staff's Second Set of Interrogatories" dated December 19, 1984. Intervenors will provide further information if warranted following review of the Applicants' responses to Intervenors' " Third Set of Interrogatories and Requests to Produce" and the Applicants' Responses to-Intervenors' followup questions concerning quality assurance.
8.6-24. Intervenors object to this Interrogatory on the grounds that it is vague
~
': and not subject to response. To fully respond would be unduly burdensome, would violate the privacy of individuals who may have communicated with Intervenors, would restrict the free flow of infonnation, .would not contribute to resolution of any issues in this proceeding and could even detract from resolution of issues in this proceeding.
20
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r-
- 8.6-25 Pleasa sea respanse to 8.6-24 above.
8.6-26 Intervenors object to this Interrogatory on the grounds that it violates privacy, attempts to restrict free flow of informatien, violates constitutional rights of certain individuals and would not lead to resolution of any issues in this proceeding.
8.6-27 Intervenors object to this Interrogatory on the grounds that it is vague, not subject to response, burdensome, violates privacy, violates constitutional rights and would not contribute to resolution of any issues in this proceeding.
8.6-28 Please see the responses to the two preceeding interrogatories.
8.6-29 Intervenors will make available all documents used in formulating these
. responses, with the exception of those which might violate privacy.
8.6-30 These responses were prepared in their entirety by Doug Teper and Tim Johnson.
8.6-31 Intervenors have not yet selected their expert witnesses for this contention, but will inform Applicants' when such experts have been selected.
l REQUEST FOR PRODUCTION OF DOCUMENTS l Intervenors will make the requested documents available for inspection at 175 i
Trinity Avenue at a time mutually acceptable to Intervenors and Applicants.
I However, Intervenors object to making available correspondence or similar information which would violate the privacy or constitutional rights of anyone.
'V Tim Johnson Executive Director Campaign for a Prosperous Georgia l 175 Trinity Ave. S.W.
Atlanta, Georgia 30303 21 l
I hereby affirm that the information I provided for Intervenors' Responses to Applicants' Second and Third Sets of Interrogatories and Requests to Produce is true to the best of my information and be11ef.
This, the fourth day of February, 1985, fj q Tim Johnson I-l i
6
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the-Matter of GEORGIA POWER CO., et al. ) Docket Nos. 50-424 and 50-425
)
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
CERTIFICATE OF SERVICE This_is to certify that copies of the foregoing Intervenors' Responses to Applicants' second and third sets of interrogatories and requests to produce were served by deoosit with the U. S. Postal Service in the City of Atlanta with first class postage attached to be delivered to the Secretary of the Commission, the members of the Licensing Board and all others listed below, this fourth day of February, 1985.
Y n/
' %/"%W Tim Johnson Campaign for a. Prosperous Georgia SERVICE LIST Horton B. Margulies, Chaiman Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar H. Paris Docketing and Service Saction Atomic Safety & Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. -20555 Washington, D.C. 20555 Mr. Gustave A. Linenberger. Bernard M. Bordenick, esq.
Office of the Executive Legal Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety & Licensing Board Panel Ruble A. Thomas U.S. Nuclear Regulatory Commission Southern Company Services, Inc.
Washington, D.C. 20555 P. O. Box 2625 Birmingham,-Alabama 35202
' James E. Joiner Sumner C.'Rosenberg Troutman, Sanders, Lockerman & Ashmore
.127 Peachtree Street, N.E.
Atlanta, Georgia 30303 i
L- .