ML20107G121
| ML20107G121 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/05/1984 |
| From: | Trowbridge G GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY |
| References | |
| CON-#484-001, CON-#484-1 OL, NUDOCS 8411070236 | |
| Download: ML20107G121 (25) | |
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Before the Atomic Safety and Licensing Board In the Matter of
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GEORGIA POWER COMPANY, et'al.
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Docket No. 50-424 OL
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50-425 OL (Vogtle Electric Generating Plant,
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Units 1 and 2)
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APPLICANTS' FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS These interrogatories and request for production of docu-ments are directed to Joint Intervenors Campaign For,a Prosper-ous Girorgia/ Georgians Against Nuclear Energy and pertain to contentions accepted by the Atomic Safety and Licensing Board in its " Memorandum and Order on Special Prehearing Conference Held Pursuant to 10 C.F.R.
I 2.715a" (Sept. 5, 1984).
The interrogatories are filed pursuant to 10 C.F.R.
I 2.740b, which requires that they be answered separately and fully in writing under oath or affirmation.
According to stip-ulation, such answers shall be served within 30 days after ser-vice of the interrogatories.
Stipulation of Parties on Discov-ery Schedule, ff. Tr. at 144.
The interrogatories are intended
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to be continuing in nature, and the answers must be immediately
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Esuppl'emented or-amended,'as' appropriate, should Intervenors ob-tain any new or differing information responsive to the inter-regatories.
The request for production of documents is filed pursuant
'to 10 C.F.R. I 2.741, which requires that Intervenors produce and either furnish copies of, orJpermit-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 the parties and with 10 C.F.R. I 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 respon-i sive to the' request.
I.
INSTRUCTIONS
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The following instructions and definitions apply to Appli-l cants' interrogatories and request for p'roduction of documents.
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When identification of a document is requested, briefly describe the document (i.e., letter, memorandum, book, pam-i 4'
phlet, etc.) and state the following information as applicable 1
to the particular document:
name, title, number, author, date l
of publication and publisher, addressee, date written or ap-j proved, and the name and address of the person (s) having pos-session of the document.
When identification of a person is i
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requested, state that person's full name, present employer or business affiliation, present address, and present telephone number.
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"VEGP" means the Vogtle Electric Generating Plant, Units 1 and 2.
2.
"Intervenors," "you," or "your" refers to Georgians Against Nuclear Energy (GANE) and/or Campaign for a Prosperous Georgia (CPG), and all members, employees, agents, consultants, attorneys, or other representatives of GANE or CPG.
3.
" Correspondence" shall be construed broadly and shall mean letters; all recordings, transcriptions, and notes of telephone calls or onversations; inter-office and intra-office memoranda; telegrams; telex messages; notes; and reports.
4.
" Document" means any handwritten, typed, printed, graphic, photographic, mechanically recorded, computer stored, filmed, or other verbal or pictorial matter of whatever charac-ter, however produced or reproduced, of any kind and descrip-tion.
" Document" shall also mean every copy of a document when such copy is not an identical duplicate of the original.
5.
"CP-ER" refers to the VEGP construction permit stage Environmental Report.
6.
"FSAR" refers to the VEGP Final Safety Analysis Re-port.
7.
"OL-ER" refers to the VEGP operating license stage Environmental Report. i'
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o II. -INTERROGATORIES r
In answering each. interrogatory, please recite the' inter-rogatory.before providing the response.
A.
Specific Interrogatories Contention 7 (Groundwater) i 7-1. In Contention 7, Intervenors state that " Applicant has not addressed the value of the groundwater.
Explain-the basis for this statement.
7.2. Identify ~and explain any specific inadequacies'that you contend exist in Applicants' assessment of different acci-dental spillage in the CP-ER at $5 2.5.4 and 5.4.3.2, and OL-ER l
at 5 7A.4.
7-3. Intervenors' Contention 7 also states that " Applicant-fails to provide adequate assurance that the groundwater will not be contaminated.
Explain the basis for this state-l-
ment.,
4 7.4. Intervenors state that " groundwater underlying the Vogtle plant is a valuable resource whose protection.
. can-1 not be assured by (Applicants)."
Explain the basis for this l
statement.
1 7.5. Identify and explain any specific inadequacies that l
you contend exist in Applicants' liquid waste management system as described in the FSAR at i 11.2.
7.6.
Identify and explain any specific inadequacies that you contend exist-in Applicants' assessment of possible 1
l accidental releases in FSAR at i 15.7 and OL-ER at Il 7.1, 7A.
'7.7.
Identify and describe in detail the sequence of hydrologic units beneath'the VEGP site and the geologic forma-tions that comprise or separate those units.
7-8.
Intervenors contend that the water table aquifer below VEGP is a source of drinking water and agricultural sup-ply.
. Identify the precise location of all wells that draw from the water table aquifer belo'er VEGP and that are used for these purposes.
7.9. Intervenors also contend that the water table aquifer below VEGP is used by some commercial establishments.
Identify-all such commercial establishments, describe their use of the water table aquifer beneath VEGP, and identify the precise lo-cation of the wells used by these establishments to draw from the water table aquifer.
7-10. Taking into account the direction of groundwater flow and the effect of intercepting streams, describe the man-
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ner 1,n which you contend that a spill at VEGP would reach any of the wells identified in your response to Interrogatory Nos.
i 7.8 and 7.9.
7-11. Do Intervenors disagree with the assertion that the water table aquifer at VEGP is on an interfluvial high isolated from surrounding water table aquifers, as described in the CP-ER at 5 2.5.4, OL-ER at 2.1.3.8.1.2, and FSAR at i 2.1.12.1.2.3.?
If so, explain the basis for disagreeing with this assertion.
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-- 12. Do'Intervenors contend that' radioactive contaminants
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in the water table ~ aquifer below'the VEGP site could reach and migrate across Beaverdam Creek?
If so, explain the precise
. mechanism for such migration.
7-13. How long do you contend it would take radioactive contaminants released to the water table aquifer at the VEGP site to reach and migrate across Beaverdam Creek?
Explain how h
.t e response was calculated or estimated.
7-14. How far south of the VEGP site do you contend that the marl changes to a limestone formation?
7-15. Identify any other locations where you contend the marl changes to a limestone formation.
Include in your-re-sponse the direction and distance from the plant to such forma-l tion.
i 7-16. Do Intervenors contend that radioactive contaminants
. reaching the water table aquifer below the VEGP site could mi-grate,to the point south of the site where Intervenors assert i
the marl changes to a limestone formation?
If so, explain the
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precise mechanism for such migration.
i 7-17. If Intervenors contend that radioactive contaminants reaching the water table aquifer below VEGP could migrate to
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t the point south of the site where the marl purportedly changes l
t to a limestone formation, state how-long such migration would take.
Explain how the response was calculated or estimated.
7-18. Do Intervenors disagree with the statement in the CP-ER at i 2.5.4 that radioactive contaminants released to the 1 i i
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water table aquifer below the plant site would eventially find
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their way to Mathes (also.known as Mallard)-Pond?
If so, 1
explain precisely the basis for your disagreement.
.7-19. If Intervenors disagree with the statement that ra-r dioactive contaminants released to the water table aquifer below VEGP would find their way to Mathes Pond, state in what direction such contaminants would travel and how long they-would take to reach the plant' site boundary.
Explain the basis t
for your response.
7-20. Do Intervenors disagree with the 350 year estimate.
l in the CP-ER at S 5.4.3.2 and in the FSAR at i 2.4.13.1 of the time it would take a spill at Plant Vogtle to reach Mathes (also known as Mallard) Pond?
If so, state the basis for such i
disagreement.
i 7-21. What is Intervenors' estimate of the time it would l
f take a spill to reach Mathes Pond?
Explain your calculation.
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,7-22. Do Intervenors disagree with the assertion that the 1
t marl beneath the water table aquifer at VEOP forms an effective aquiclude?
If so, explain the basis for disagreeing with this l
i assertion.
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l 7-23. Do Intervenors disagree with the assertion in Appli-t cants' Response to CANE and CPG Supplements to Petitions for 1
l Leave to Intervene (May 7, 1984) at 44 n.29 that the 50 foot pressure differential between the water table aquifer and ter-
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tiary aquifer (upper confined or Lisbon Sands aquifer, herein-after referred to as tertiary) or cretaceous aquifer (lower l
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confined or Tuscaloosa aquifer, hereinafter referred to as i
cretaceous) demonstrates the effectiveness of the marl as an aquiclude?
If you disagree, explain the basis for disagreeing?
t with this assertion.
7-24. Describe the precise mechanism (s) and pathways by which you contend that radioactive releares from VEGP could reach the cretaceous aquifer or the tertiary aquifer and in-ciude in the description an estimate of the time it would take.
7-25. Explain in detail the basis for Intervenors' asser-tion that the marl below the water table aquifer at VEGP has fractures or permeable sections.
Identify all documents that refer to or discuss such fractures or permeable sections.
7-26. Identify the location of any fractures or permeable sections of the marl.
7-27. Do Intervenors contend that fractures in or permen-e ble sections of the marl provide a path for migration of contapinants in the water table aquifer to the cretaceous or tertiary aquifers?
If so, explain in detail the basis for this contention and identify all documents that support it.
7-28. With respect to groundwater, identify each section f
of 10 C.F.R. Part 51, as currently amended and renumbered, that Intervenors contend Applicants do not satisfy.
7-29. With reference to specific regulatory language of each section identified in response to Interrogatory No. 7-28, explain why In*
venors contend that Applicants are not in com-l pliance wit 1. 6. sat section.
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7-30. Provide any information that Intervenors have con-corning the location of wells in the vicinity of VEGP.
7-31. Identify and describe in detail the sequence of hydrologic units beneath the Savannah River Plant and the geo-logic formations that comprise or separate those units.
7-32. Explain, with reference to the specific regulatory language, why Applicants are not in compliance with 10 C.F.R. I 50.34(a)(1) (1984).
7-33. Explain, with reference to the specific regulatory language, why Applicants are not in compliance with 10 c.F.R. I 100,10(c)(3) (1984).
7-34. Identify each person you expect to call as an expert witness with respect to Contention 7.
For each such person, state the subject matter on which he is expected to testify, the substance of the facts and opinions to which he is expected to testify, and a summary of the grounds for each such opinion.
Also, describe the educational and professional qualifications of each such person, and identify any previous proceeding in which that person has testified.
Contention 10.1 (Integrated Dose v. Dose Rate) 10.1-1. Identify the specific polymers that have been shown in NURE0/CR-2157 to be susceptible to differing dose-rate effects (i.e. greater degradation at low dose rates than at a high dose rate during environmental qualification testing), and for each, identify all documents discussing or referring to such susceptibility.
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,10.'l-2.' Identify any safety-related equipment at VEGP that
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Intervenors know contain such polymers.
10.1-3. For each of the polymers identified in response to Interrogatory.No. 10.1-1,-provide the-following information:
a) At approximately wh'at total integrated dose do Intervenors contend that differing dose-rate effects become' discernible?
b) Describe the effect discerned at that total integrated dose with reference to specific mechanical and electrical properties.
c) Explain the basis for the response to (a) d and (b) above.
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d) Identify all documenta that support or other-wise relate to the response to.(a), (b), and (c) above.
10.1-4. Do Intervenors contend that differing dose-rate effec,,ts on the polymers identified in response to Interrogatory.
No. 10.1-1 have been observed in actual operational experience i
at any Tuclear power plant?
If so, provide the following information:
a) At what plant (s) have such effects been i
discerned?
.b) Quantify the effects for each such plant and polymer.
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1 to dose-rate effects observed in actual opera-tional experience.
10.1-5. With respect to seals, rings, gaskets, or other mechanical equipment containing the polymers identified in re-sponse 153 Interrogatory No'.
10.1-1, do Intervenors contend that a maintenance / surveillance program is not an acceptable method to detect and correct irradiation effects?
If Intervenors con-tend that such a program is not an acceptable method of de-i g
tecting and correcting irradiation effects, explain the basis for the response.
10.1-6. Identify each person whom you expect to call as an expert witness with respect to Contention 10.1.
For each such person, state the subject matter on which he is expected to testify, the substance of the facts and opinions to which he is expected to testify, and a summary of the grounds for each such opini,on.
Also, describe the educational and professional qual-(
ifications of each such person, and identify any previous pro-ceeding in which that person has testified.
Contention 10.3 (Multiconductor Configurations) 10.3-1. Identify precisely the SANDIA study or studies re-ferred to by Intervenors in support of their proposition that in tests of EPR cable material, multiconductor configurations performed "substantially worse" than single conductor configu-t rations..--
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10.3-2. Identify all documents referring to or discussing the study identified in your response to Interrogatory No.
i 10.3-1 above.
,10.3-3.
Identify'every multiconductor, other than those-discussed in NUREG/CR-3538, which Intervenors contend has per-
-formed "substantially worse" in qualification tests than did' the corresponding single conductor.
Include in the identifica-tion the precise multiconductor configuration, its insulating-material, and its jacketing material.
10.3-4. Describe the precise chemical or physical mecha-nism(s) that have caused anyLmulticonductor configuration to perform "substantially worse" than the corresponding single conductor in environmental qualification-tests.
10.3-5. For each multiconductor identified in response to Interrogatory No. 10.3-3 above, describe the precise environ-mental conditions under which the multiconductor performed sub-stant,ially worse than the corresponding single conductor.
10.3-6. Do Intervenors contend that any material other than chlorinated polyethelene jacketing in multiconductor con-figurations causes a multiconductor configuration to perform substantial'ly worse than the corresponding single conductor configuration in environmental qualification tests?- If so, explain the basis for your response and identify all documents that support it.
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10.3-7. Identify any insulating or jacketing material other than chlorinated polyethelene that Intervenors claim 12-u
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I would be subject to the same mechanism described in the re-sponse to Interrogatory No. 10.3-4Labove.
Provide the basis-
- -for your. response and identify all documents supporting it.
10.3-8. Identify each person whom you expect to call as an 1
expert witness lwith respect to Contention 10.3.
.For each such 4
- person, state the subject matter on-which he is expected to testify,-'the substance of.the facts and opinions to which he is expected to. testify, and a summary of the grounds for each such opinion.
Also, describe the' educational and professional qual-ifications of each such person, and identify any previous pro-ceeding in which that person has testified.
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i Contention 10.5-(Solenoid Valves) 10.5-1. Identify the specific model numbers of the ASCO 4
solenoid valves that failed tests at the Franklin Research Cen-ter and that are listed in the FSAR at i 3.11 as being used in safety-related applications at VEGP.
E10.5-2. Identify the precise test conditions under which the ASCO solenoid valves failed environmental qualification i
tests at Franklin Research Center.
10.5-3. In the Franklin Research Center tests, did test temperatures to which the solenoid valves were exposed exceed 400H?
10.5-4. If the response to Interrogatory No. 10.5-3 is yes, state by how much the test temperatures exceeded 400H and explain why-the Franklin Research Center test results are applicable to VEGP.
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i 10.5-5. Identify all documents which refer to or discuss the Franklin Research Center tests of the ASCO' solenoid valves.
1 10.5-6.' Explain the basis for Intervenors' statement that "several valves' manufactured by ASCO failed'early after' expo-sure'to 340 degrees.I..."
Identify the model number (s) of the valves in question and all documents that support this state-ment.
10.5-7. What is the basis for Intervenors' statement..that
"... ASCO's own testing had shown poor performance of these valves..."?
Identify the model number (s) of the valves in question, the date of the test, and all documents that support this statement.
10.5-8. Identify each person whom you expect to call as an expert witness with respect to Contention 10.5.
For each such person, state the subject matter on which he is expected to testify, the substance of the facts and opinions to which he is expec,ted to testify, and a summary of the grounds for each such opinion.
Also, describe the educational and professional qual-ifications of each such person, and identify any previous pro-i ceeding in which that person has testified.
Contention 10.7 (Hydrogen Recombiners) 10.7-1. Explain in detail why Intervenors contend that 4
Applicants' environmental qualification of the VEGP hydrogen e
recombiner is inadequate.
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~ 10.7-3. Identify each person whom you expect to call'as an-expert witness with respect to Contention.lO.7.
For each such person, state the subject matter on which he is expected to J
testify,thesubstanceofthefactsandopiniynstowhichheis expected to testify, and a summary of the groun'ds for each such opinion.
Also, describe the educational and~ professional. qual-t ifications of each such person, and identify any previous pro-t ceeding in which that person has testified-.
Contention 11 (Unresolved Safety Issues) i 11-1. Define the term " bubble collapse" and explain whatt phenomenon Intervenors refer to when.Intervenors-use this term.
11.2. Do Intervenors contend that " bubble collapse" is not a type of water hammer?
If so, explain why and identify all docum'ents that support the response.
11-3. Idantify all NRC documents which define or explain the term " bubble collapse."
11-4. Explain in detail the basis for Intervenors' asser-tion that Westinghouse PWR steam generator tubes have shown ev-idence of degradation due to bubble collapse.
Identify all i
documents that support your response.
11-5. Describe the precise mechanism by which Intervenors contend that the VEGP steam generator' tubes are susceptible to 4
damage due to bubble collapse.
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11-6.-What improvements in the VEGP steam generators, if any, do Intervenors~ contend are.necessary to avoid tube damage due to bubble collapse?
11-7. Identify any instance where bubble collapse has dam-aged steam generator tubes, and all documents discussing or re-ferring to'such instances.
11-8. Explain in detail the basis for your contention that Westinghouse PWR steam generator tubes have shown signs of vi-bration-induced fatigue cracking.
Identify all documents that support your response.
11-9. Explain in detail the basis on which'you contend that degradation due to vibration induced fatigue cracking r
might be encountered in.the Westinghouse Model F steam genera-tors psed at VEGP.
11-10. Identify any instance where vibration induced fa-tigue cracking has been detected in the tubes of any Westi,nghouse steam generator, 11-11. What do you contend would be the source (s) of vi-bration that might induce fatigue cracking in the tubes of a Westinghouse Model F steam generator.
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11-12. Do Intervenors deny that vibration induced fatigue cracking is a phenomenon that has been associated only with once-through (non-Westinghouse) steam generators?
If so, explain the basis for the denial and identify all documents that support your position.
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11-13. Do Intervenors contend that Applicants' analysis of flow-induced vibration in the FSAR at 6 5.4.2.3.3 is inadequate or incorrect?
If so, explain in detail why the analysis is in-adequate or incorrect.
11-14. Identify each person whom you expect.to call as an expert witness with respect to Contention 11.
For each such person, state the subject matter on which he is expected to testify, the substance of the facts'and-opinions to which he is expected to testify, and a summary of the grounds for each such opinion.
Also, describe the educational and professional qual ifications of each such person, and identify any previous pro-ceeding in which that person has testified.
Contention 12 (Cooling Tower Releases) 12-1. Define'" salt" as the Intervenors use that term in Contention 12.
12-2. Do Intervenors disagree with the Applicants' salt deposition estimate provided in the OL-ER in response to ques-tions E290.8 and E451.17?
If so, explain precisely why Appli-cants' estimate is in error.
12-3. Do Intervenors disagree with Applicants' methodology for estimating and bounding salt deposition as described in Licensee's letter to the NRC Staff dated September 25, 1984, and in the OL-ER in response to questions E290.8 and E451.17?
If so, explain why..
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12-4. Do Intervenors disagree with' Applicants' cooling-l tower drift parameters (e.g. the' salt concentration in drift or'
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,7 drift rate) as' described in the OL-ER in response to question E290.8?
If so, explain why.
12-5.' Describe in detail what you contend would be the precise environmental effect of salt deposition as estimated by T
Applicants.
Identify all documents on which Intervenors' de-scription of this effect is based.
I 12-6.HWhat types of vegetation do Intervenors contend could be harmed by salt deposition from the VEGP cooling tow-i ers?
12.7. With respect to each. type of vegetation identified in response to Interrogatory No. 12-6, what level of salt depo-sition do Intervenors contend would cause harm?
12-8. What is Intervenors' estimate of salt deposition from the VEGP cooling towers?
Describe in detail the basis for that, estimate and identify all documents which support or otherwise relate to that estimate.
12-9. Describe the precise environmental effect of salt deposition as estimated by Intervenors.
Identify all documents on which Intervenors' description of this effect is based.
12-10. Define " chlorine gas" as Intervenors use the term in Contention 12.
12-11. Describe-the. chemical reactions that Intervenors contend would occur when chlorine.is injected into the cooling 4
tower water at VEGP.
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Do Intervenors agree that chlorine injected into
.the~ cooling tower water will hydrolyze?
If so, what do Inter-venors contend is the rate of reaction and how complete is the hydrolysis at standard temperature and pressure?
If Interve-nors do not agree that the chlorine will hydrolyze, explain in detail the basis for disagreement.
r 12-13. If chlorine were injected into the cooling-tower water to obtain an' initial, momentary concentration of 10 ppm, what concentration of chlorine gas in the cooling tower water
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do Intervenors contend would exist after hydrolysis?
12-14. Describe and explain in_ detail the precise mechani-cal and chemical actions that Intervenors contend would result in the emission-of chlorine gas from the VEGP cooling towers.
12-15. Assuming injection of chlorine into the water in an amount sufficient to obtain an initial concentration of 10 ppm and based on the cooling tower parameters specified in the OL-ER in response to question E290.8, how much chlorine gas l
would be emitted from the cooling towers?
12-16. Assuming the validity of the cooling tower parameters specified in the OL-ER in response to question i
E290.8 and that approximately 420 lbs of chlorine would be in-jected into the cooling tower water over two thirty-minute pe-i
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riods each day, what amount of chlorine gas do Intervenors es-timate would be emitted from each cooling tower-each day?
12-17. What percentage of.the amount of chlorine gas that Intervenors estimate will be emitted from the cooling towers I
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Describe in detail the basis for the response and ' identify all documents which. support that re-sponse.
12-18. What would be the environmental effect of the chlo-rine gas that Intervenors estimate would be released from the cooling towers?
Describe in detail the basis for the response and identify all documents that support the response.
12-19.: Identify each person whom you expect to call as an 3
expert witness with respect to Contention 12.
For each such person, state the subject matter on which he is expected to W
testify, the substance of the facts and opinions to which he is expected to, testify, and a summary of the grounds for each such opinion.
Also, describe the educational and professional qual-ifications of each such person, and identify any previous pro-ceeding in which that person has testified.
4 Contention 14 (Diesel Generators)
'14-1. Specify all defects claimed by Intervenors to have occurred in diesel generators manufactured by Transamerica Delaval, Inc.(TDI) and state whether each such defect is the result of the design or of the manufacture of the generators.
14-2. For each defect identified in response to Interroga-tory No. 14-1, identify all documents that describe the defect, its discovery, reporting, or correction.
14-3. To what common mode failures do Intervenors claim that the VEGP diesel generators are subject?
Explain the basis 20-s
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4 for your response and identify all documents that. support the response.
14-4. With respect to the VEGP diesel generators, in what manner do Intervenors contend that Applicants' QA/QC program was or is deficient?
14-5. In what manner do Intervenors contend that TDI's-QA/QC program was or is deficient?.
14-6. Explain the basis for Intervenors' statement that Applicants failed to properly assess the suitability of the TDI diesel generators.
14-7. Do Intervenors contend that there are any problems with the VEGP diesel generators that have not been adequately corrected?
If so, identify each such problem precisely, and if corrective action has been taken, explain why such action was inadequate.
14-8. Identify each person whom you expect to call as an exper,t witness with respect to Contention 14.
For each such person, state the subject matter on which he is expected to
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testify, the substance of the facts and opinions to which he is expected to testify, and a summary of the grounds for each such opinion.
Also, describe the educational and professional qual-ifications of each such person, and identify any previous pro-ceeding in which that person has testi~fied.
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General Interrogatories G-1 List separately for each interrogatory' response the j
y; name,: title or position,. address, and' employer of;each person l
t who provided'information used in preparing that response.
G.7 List separately for each interrogatory response each document that Intervenors used or. referred. to in preparing the response to that' interrogatory.
G-3 Identify'each document requested by Applicants' Re-quest for Production of Documents'for which Intervenors claim a privilege against production.
Include in the' identification all addressees.or recipients of the' original or copy of the documenti a-brief description of its subject matter, and the' nature of the privilege. claimed.
1 a
f III.
REQUEST FOR PRODUCTION OF DOCUMENTS i
l Applicants request that Intervenors respond in writing to a
the following request for production of documents and produce 1
or make available for inspection and copying at m' designated i
location each of the documents requested below-that are in the possession, custody, or control of-Intervenors.
1 A document shall be deemed to be within the " control" of
{
-the Intervenors if Intervenors have ownership, possession 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
[
l or private entity having physical possession thereof. ~
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Documents Requested' 1
l.
Applicants request that Intervenors produce or make available for inspection and copying each and every document
. 'identifiedorde'scribedintheanswertoanyofthespdcific interrogatories above.
2.
Applicants request that Intervenors produce or make available for inspection and copying each and every document that Intervenors used or refkrred to in preparing the response to any.of the specific or general interrogatories above.
3.
Applicants request.that Intervenors produce or make available for inspection and copying all correspondence between i
Intervenors and anyone else concerning any of the admitted con-4 I
tentions.
i Respectfully submitted,
.//fsf
/l41f J./
196org( F. TroWbridge, PA.
Ernest L. Blake, Jr.,.F.C.
4 David R. Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE James E. Joiner, P.C.
Charles W. Whitney Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN &
i ASHMORE 4
'l Counsel for Applicants Dated: November 5',
1984
..=. -.
s Novemb:r.5, 1984
's UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
GEORGIA POWER COMPANY, et al.
)
Docket No. 50-424
)
50-425 (Vogtle Electric Generating Plant,
)
Units 1 and 2)
)
).
CERTIFICATE OF SERVICE I_hereby certify that copies of " Applicants' First Cet of 1
Interrogatories and Request for Production of Documents," dated November 5, 1984, were served upon those persons on the atta-ched Service List by deposit in the United States mail, postage prepaid, or where indicated by an asterisk (*) by hand deliv-ery, this Sth day of November, 1984.
l
(
mc t
David R. Lewis Dated: November 5, 1984 f
f
UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
^
GEORGIA POWER COMPANY, et al.
)
Docket No. 50-424
)
50-425 (Vogtle Electric Generating Plant,
)
Units 1 and 2)
)
t i
SERVICE LIST Morton B. Margulies, Chairman Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U.S.Nuglear Regulatory Commission Atlanta, GA 30306 Washington, D.C.
20555 Jeanne Shorthouse Mr. Gustave A. Linenberger 507 Atlanta Avenue Atomic Safety and Licensing Board Atlanta, GA 30315 i
U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Laurie Fowler & Vicki Breman Legal Environmental Assistance Dr. Oscar H. Paris Foundation Atomic Safety and Licensing Board 1102 Healey Building U.S. Nuclear Regulatory Commission Atlanta, GA 30303 Washington, D.C.
20555
- Tim Johnson Bernard M. Bordenick, Esq.
Campaign for a Prosperous Georgia Office of Executive Legal Director 175 Trinity Avenue, S.W.
U.S. Nuclear Regulatory Commission Atlanta, GA 30303 Washington, D.C.
20555 Carol A. Stangler-Atomic Safety and Licensing 425 Euclid Terrace Board Panel Atlanta, GA 30307 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dan Feig 1130 Alta Avenue i
Atomic Safety and Licensing Atlanta, GA 30307 Appeal Board Panel U.S. Nuclear Regulatory Commission Docketing and Service Section Washington, D.C.
20555 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 1
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