ML20108E157

Response to NRC Interrogatories 1-7.Certificate of Svc Encl. Related Correspondence

ML20108E157
Person / Time
Site:	Vogtle
Issue date:	12/10/1984
From:	Johnson T CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20108E155	List: ML20108E153 ML20108E157
References
OL, NUDOCS 8412140279
Download: ML20108E157 (7)

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RELATED CORRESPONDENCE UNITED STATES OF AMERICA DCCKETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BQ800

• DED 13 NO:48

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In the Matter of )

) r ,v~- = cecyrcs GEORGIA POWER CO., et al. ) Docket Nos. 50 R4TNDid $6-425

) 2RANC1 (Vogtle Electric Generating Plant, )

Units 1 and 2) v )

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CPG /GANE'S RESPONSE TO NRC STAFF'S INTERROGATORIES Intervenors respond herein to "NRC Staff's Interrogatories to Campaign for a Prosperous Georgia (CPG) and Georgians Against Nuclear Energy (GANE)."

Interrogatory 1,: Identify all documentary or other material that you intend to rely on during this proceeding to support CPG /GANE Contentions 7, 8, 10.1, 10.3, 10.5, 10.7,11,12 and 14 or which you may offer as exhibits on these contentins or refer to in preparation for or during your cross-examination of NRC Staff or Applicant witnesses. Provide, if available, copies of any documents you intend to rely on.

RESPONSE: In addition to the documents filed by the Applicants, Intervenors have used and will use the following documents: "An Overview of Equipment Survivability-l Studies at Sandia National Laboratories," Proceeding, International Meeting on Light Water Reactor Severe Accident Evaluation, August 28-September 1,1983; "UCS Petition for Emergency and Remedial Action," February 7,1984; " Savannah River Plant Burial Ground Management Appraisal Report," June 2-13, 1980, unpublished, US-DOE /SR Draft Report, final draft November 1,1982, by William Lawless; " Savannah River Plant Offsite Radioactive Releases," draft December 15, 1985, WilliamLawless(undergoing peer review comments for publication January 1985); DOE SRP L-Reactor FEIS, Report #

DOE /EIS-0108 (3 volumes) (1984) (and the drafts therefor); Dupont Letter Report, J.

S. Roberts, September 10,1984, " Deep Wells 905-20A, 31A, and 82A Service History, 0412140279 841210 PDR ADOCK 05000424 Q PDR

8/4/84-8/15/84;" " Technical Summary of the A/M Groundwater Remedial Action Program,"

J. L. Steel, Dupont draft report, ca. 3/84; " Assessment of the ?resence of Volatile Organice Compounds of Water Supply Well 53A-A/M Area, Savannah River Plant,"

Geraghty & Miller, Dupont subcontractor report, 1983; "Delaval Diesel Generating Operating Experience," unpublished summary of TDI prdblems as described in NRC and other documents in the ptblic record; "IE Information Notice No.,83-58:

Transamerica~Delaval Diesel Generator Crankcshaft Failure" (SSIN No. 6835, IN 83-58), U. S. NRC Office of Inspection & Enforcement, August 30, 1983; "IE Information Notice No. 83-51: Diesel Generator Failures" (SSIN No.: 6835, IN 83-51), U.S. NRC Office of Inspection & Enforcement, August 5,1983; "Evaluatin for a Significant Deficiency / Evaluation for a Substantial Safety Hazard," attached to a letter from D.

O. Foster (Georgia Power Company) to James P. O'Reilly (NRC), August 6,198.2; Letters from R. E. Boyer (TDI) to Director, Office of Inspection & Enforcement, NRC, December 9, 1981 and September 27, 1983; report attached to letter from Foster to O'Reilly, March 1,1983; "Transamerica Delaval has supplied the DSR and DSRV engines to the following sites...", bnpublished summary of problems with TDI generators; and "Transamerica Delaval Incorporated Vendor Program Branch Inspection History

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Summary of Nine Inspections During 1979-1983." I Interrogatory 2 a) Identify each persol you rely on to substantiate in whole or in part the CPG /GANE Contentions set out in Interrogatory 1 above. b) Provide the address and educational and professinal qualifications of all persons named in your response to 2a above, c) Identify which of the above persons or any other persons you may call as witnesses at a hearing on the contentions set out in Interrogatory 1.above, and identify which portions of each Contention set out in Interrogatory 1 above that '

each such person will support.

RESPONSE: Dr. Howard Deustch, Professor of Chemistry, Georgia Institute of

Technology, 765 Mytric Street, N.E., Atlanta, Georgia 30308; Carol Gelbaum,1714 N.

Holly Lane, Atlanta, Georgia 30329, geologist formerly with State of Georgia and Georgia Institute of Technology; Professor William Lawless, Paine College, P. O. Box 12172, Augusta, Georgia 30904, formerly employed in management of nuclear waste cperations at Sa.9nnah River Plant (fir. Lawless will testify regarding groundwater);

Dr. James Ruttenber, medical doctor and Ph.D. ecologist, Myrtle Street, Atlanta, Georgia 30308; Doug Teper, 1253 Lenox Circle, Atlanta, Georgia 30306, frequent intervenor in regulatory cases; Tim Johnson, Campaign for a Prosperous Georgia,175 Trinity Avenue S.W., Atlanta, Georgia 30303, trained by National Association of Regulatory Utility Comissioners, former staff of Consumers' Utility Counsel and Public Service Comission, member of former NRC .visory comittee (regarding decomissioning of power plants); Marc Merlin, nuclear physicist formerly with RAND Corporation, Atlanta, Georgia; Robert Pollard, engineer formerly with Nuclear Regulatory Comission, Union of Concerned Scientig.t s, l'asliington, D.C.

With the exception of Mr. Lawless, who will testify on those portions of groundwater relating to the Savannah Piver Plant, Intervenors have not yet selected its witnesses.

Interrogatory 3: With respect to Contention 7, which asserts that Applicants have not adequately addressed the value of the groundwater below the Plant Vogtle site l and fails [ sic] to provide adequate assurance that the groundwater will not be contaminated, please state a) the basis for your belief that an accidental spill of radioactive water on the Vogtle site could result in radioactive contamination of either the shallow or deeper acquifers under Plant Vogtle; b) the basis for your belief that the Tuscaloosa acquifer may not be isolated from the surface to the Plart Vogtle site; and c) the basis for your belief that any or all deep aquifers i

are hydraulically connected anywnere in the vicinity of the plant.

l RESPONSE: a) and b) There has been clearly documented contamination of the l Tuscaloosa Aquifer below the Savannah River Plant (SRP), which has a very similar l

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e hydrogeology to the Plant Vogtle site (for details, please see CPG /GANE's Response to Applicants' First Set of Interrogatories and Request for Production of Documents"). This is true despite claims by SRP personnel that the Tuscaloosa .

aquifer 'c ould not be contaminated by spills at SRP. c) There is really no such thing as an " isolated" aquifer, as demonstrated at SRP and elsewhere.

Interrogatory 4: Subcontention 10.1 (Integrated Dose v. Dose Rate) alleges that Applicants' testing methods are inadequate because the Applicants only use high levels of radiation or integrated dose. In support of this subcontention you cite research performed at Sandia Laboratory for the proposition that many materials, including polymers found in cable. insulation and jackets, seals, rings and gaskets, may experience greater damage from lower dose rates. State whether the research performed at Sandia forms the sole basis for subcontention 10.1. If not, please state the full and complete basis for the assertions made in the subcontention in question.

RESPONSE: At present, tne Sandia research and references cited therein fonn the basis for Intervenors' contention.

Interrogatory 5: Subcontention 10.3 (Cable in Multiconductor Configurations) cites

, aSandiastudy(notidentified)forthepropositionthatintestsofEPRcable i

material, multiconductor configurations performed "substantially worse than single conductor configurations and that qualification testing implying only single conductors may not be representative of n:ulticonductor performance." You further allege that the results of this report have not been considered in Applicants' testing program.

a. State the full name of the report, the author, the report number and publication date of the Sandia study cited in support of subcontention 10.3.

RESPONSE: "An Overview of Equipment Survivability Studies at Sandia National Laboratories," Proceeding, International Meeting on Light Water Reactor Severe  ;

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Accident Evaluation, August 28-September 1, 1983.

b. Is the study identified in response to interrogatory 5a the sole basis for subcontention 10.37 If not, please state the additional bases which you allege support the subcontention.

i RESPONSE: At present, the Sandia study and the references cited therein are the basis for subcontention 10.3.

c. State the full bases for your assertion that the results of the Sandia report must be considered in Applicants' testing program.

. RESPONSE: The concept of environmental qualification is fundamental to NRC-j regulation of nuclear power reactors. For Intervenors' full bases, please see the j bases for CPG-10, pp. 21-26, " Supplement to Petition for Leave to Intervene and

! Request for Hearing," Campaign for a Prosperous Georgia, April 11, 1984.

Interrogatory 6_: Subcontention 10.5, which challenges the qualification of solenoid valves used at Vogtle, is based on. test results perfonned by ASCO and Franklin i

i Research Center and upon an NRC Board Notification Issuance. Are the test results

and Board Notification issuance the sole bases in support of subcontention 10.57 If l not, please state the full and complete bases for the allegations contained in the subcontention. In addition, state the full name or title of the test results, the 1

- authors, test or report number and date of issuance'of the test results in question.

If available to you, attach copies of any such test results.

RESPONSE: At present, the contention is based on the test results performed by ASCO and Franklin Research Center and upon an NRC Board Notification issuance.

( InterrogatoryJ,: State in detail the showing CPG and GANE believe the Applicants j must make to demonstrate, as set out in Contention 11, their basis for confidence l that no unacceptable radiation releases will occur as a result of steam generator I

tube failures occasioned by vibration-induced fatigue cracking and by bubble collapse within the Vogtle steam generators.

l RESPONSE: The Applicants trust demonstrate that they have adequately cddressed the 5

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4 problems at other plants and that they have corrected these problems. These corrections must be based on empirical' demonstrations that they do indeed resolve the problems.

The above responses were prepared in their entirety by Tim Johnson based on his

personal knowledge and on CPG /GANE's Response to Applicants' First Set of Interrogatories and Request for Production of Documents, December 5,1984.

Respectfully submitted this, the 10th day of December,1984, h "%

Tim Johnson Executive Director.

Campaign for a Prosperous Georgia 175 Trinity Ave. S.W.

Atlanta, Georgia 30303 for Intervenors C e ign for a Prosperous Georgia and Georgians Against Nuclear Energy i

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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 CPG /GANE's Response to NRC Staff's Interrogatories were served by deposit with the U. S. Postal Service in the City of Atlanta for first class delivery to those listed on the attached Service List this 10th day of December, 1984.

Tim Johnson kN Executive Director Campaign for a Prosperous Georgia frir tii*.enelica r.

ctnpaign for a Prosperous Georgia and Georgians Against Nuclear Energy

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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) )

SERVICE LIST Morton B. Margulies, Chairman 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 Section 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.

Atomic Safety & Licensing Board Office of the Executive Legal 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 George F. Trowbridge Ernest L. Blake, Jr.

David R. Lewis Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington,'D.C. 20036

. James E. Joiner Sumner C. Rosenberg Troutman, Sanders, Lockerman & Ashmore .

127 Peachtree Street N.E.

-Atlanta, Georgia 30303

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