ML20111C127

Fourth Set of Interrogatories & Requests to Produce Documents Re Contention 8 Concerning bid-rigging.Certificate of Svc Encl.Related Correspondence

ML20111C127
Person / Time
Site:	Vogtle
Issue date:	03/11/1985
From:	Johnson T, Teper D CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20111C124	List: ML20111C123 ML20111C127
References
OL, NUDOCS 8503140291
Download: ML20111C127 (8)

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%RRES UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,

ss ., p In the Matter of ) "

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GEORGIA POWER C0., et al. ) Docket Nos, 50-424 and 50-425

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^!i ;$g (Vogtle Electric Generating Plant, ) 7',fC .

] Units 1 and 2) ) p B

CAMPAIGN FOR A PROSPEROUS GEORGIA / GEORGIANS AGA1NST NUCLEAR ENERGY FOURTH SET OF INTERR0GATORIES AND REQUESTS TO FR0 DUCE Pursuant to 10 CFR Sections 2.740 (b) and 2.741, Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy (hereinafter " CPG /GANE")

hereby serves its Fourth Set of Interrogatories and P,equests to Produce upon the Applicant in the above-styled proceeding. These interrogatories ar.d requests to produce involve CPG /GANE's Contention 8.

Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information known to the Applicant including its officers, employees, agents, advisors or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control of, or are otherwise available to, the Applicant, including its officers, employees, agents, advisors or counsel. In answering each interrogatory and responding to each request, please recite the interrogatory or request preceding each answer or response. Also, identify the person providing each answer or response, including but not limited to his or her name, address, employer, current position and a statement of professional qualifications.

These interrogatories and requests shall be continuing in nature. Thus, whenever any information is obtained which renders any previous response incorrect or incomplete or indicates that a response was incorrect or incomplete when made, the Applicant is hereby requested to supplement its previous response to the 8503140291 850311 1 PDR ADOCK 05000424 G PDR

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appropriate interrogatory or request to produce.

The term " document" shall include any writings, drawings, graphs, charts, photographs, and other data compilations from which information can be obtained.

CPG /GANE requests that at dates to be agreed upon, the Applicant make available for inspection and copying all documents subject to the requests set forth below.

Requests for Documents Pursuant to 10 CFR Section 2.741, CPG /GANE requests Applicant, by and through its attorneys, make available for inspection and copying, at a time and location to be designated, any.and all documents of whatsoever description identified in the responses to the Intervenors' interrogatories below, including but not limited to:

(1) any written record of any oral communication between or among Applicant, its advisors, consultants, contractors, agents, attorneys, and/or any other persons, including but not limited to the NRC staff, the Intertenors, and their advisors, consultants, contractors, agents, attorneys and/or any other persons; i

and (2) any documents, correspondence, letters, memoranda, diagrams, reports, charts, photographs, or any other writing of whatsoever description, including but not limited to work papers, prior drafts and notes of meetings,

'f If Applicant maintains that some documents should not be made available for inspection, Applicant should specify the documents and explain why such are not being made available. This requirement extends to any such document, described above, in the possession of or.available to the Applicant, its advisors, consultants, agents or attorneys.

Interrogatories Pursuant to 10 CFR Section 2.740(b), CPG /GANE requests the Applicant by and through its attorneys coswer separately and fully in writing, under oath or 2

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. affirmaticn, by persons having knowledg3 cf the information requested, the following interrogatories.

! A. General Interrogatories i

The following interrogatories apply to CPG /GANE Contention 8:

1. Please identify (by nace, business address, occupation and employer) a) all individuals who have knowledge or information responsive to each interrogatory and designate the interrogatory or the part thereof which that individual answered. ,

2. Have Applicants identified an expert or experts whom they will call in this proceeding? If so, please identify the witness, the subject matter on which he or she will testify and the substance of that testimony, the witness's educational and professional background, and any previous proceedings in which that person has testified.

Interrogatories Relating to CPG /GANE Contention #8

1. ApplicApts refused to respond to the following Intervenors' question in Intervenors' Second Set of Interrogatories: When the Applicant recently fired employees involved in procurecent due to allegations of bid-rigging, what investigations were performed to assure that quality of materials and work was not affected as well as pricing? What was the result of these investigations? Please provic:e details, including copies of the investigation results. Contrary to a Applicants claim, this question is entirely within the scope of Contention 8 as admitted by the Board. Flease provide a conplete response to this interrogatory.

2. Applicants refused to respond to the following Intervenors' question in ,

1 Intervenors' Second Set of Interrogatories: Have any employees or bidders alleged 9

that political or personal favoritism has resulted in preferential treatment being given to some contractors? Please provide details. Contrary to Applicants' claim, this question is entirely within the scope of Contention 8 as admitted by the Board.

Please provide a complete response to this question.

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. '3. Applicants refused to resp:nd to the following Intervenors' question in )

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Intervenors' Second Set of Interrogatories: Has any contractor, including but not limited to Westinghouse Corporation and Bechtel, taken officials of the Applicant on trips to Europe or provided other benefits to them? Please provide details.

Contrary to the Applicants claims, this question is entirely within the scope of Contention 8 as admitted by the Board; if Applicants selected vendors based on any criteria other than quality assurance, then the selection process has an impact on the issurance of quality. Please answer this question fully.

4. Please describe in detail each citation for viclation of NRC rules, regulations and procedures at Plant Vogtle since the construction permit was issued.

5. Applicants refused to respond to the following Intervenors' question in Intervenors' Second Set of Interrogatories: Have there been any allegations of harassment or intimidation of inspectors at Plant Vogtle? If so, list each sLch

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incident and provide details. Contrary to the Applicants claims, this question is

! clearly within the scope of Contention 8 as admitted by the Licensing Board. Please 1 provide a complete response to this question.

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6. Applicants refused to respond to the following Intervenors' question in i Intervenors' Second Set of Interrogatories: List every act of vandalism directed at the structure of Planc Vogtle or components thereof, giving the date, extent and location of each incident, and explain how the vandalism was discovered. Contrary to the Applicants' claims, this question is entirely within the scope of Contention j 8 as admitted by the Board. Please provide a complete response to this question.

7. Applicants refused to respond to the following Intervenors' question in j Intervenors' Second Set of Interrogatories: Have any workers been fired for any

reason by the Applicant ar.d/or its contr, actors / subcontractors following allegations of poor construction or QA practices at Plant Vogtle they made to the NRC, news media, or. any ,other person or entity? Provide details. This question is entirely within the scope of Contention 8 as admitted by the Board. Please respond to this 4

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question in full.

8 .~ Applicants refused to respond to the following Intervenors' question in Intervenors' Second Set of Inte rogatories: Does the Applicant or any of its contractors or subcontractors maintain any quota or target system for dismissing workers? Provide details. Contrary to the Applicants' claims, this question is entirely within the scope of Contention 8 as admitted by the Board. Please respond in full to this question.

9. Applicants refused to respond to the following Intervenors' question in Intervenors' Second Set of Interrogatories: What vendor provides core drilling at the site? What experience does this vendor have in this field? What tra'ining do its workers have in core drilling? Provide details. Contrary to the Applicants' clains, this question is entirely within the scope of Contention 8 as admitted by the Licensing Board. Please provide a complete response.

10. Appl,1 cants refused to respond to the following Intervenors' question in Intervenors' Second Set of Interrogatories: What tests have been conducted on the lifting eyes of concrete ha+-h covers? Provide details of the testing, including resul ts. Contrary to the Applicants' claims, this question is entirely within the scope of Contention 8 as admitted by the Board. Please respond fully to this question.

11. Applicants refused to respond to the following Intervenors' question in Intervenors' 5econd Set of Interrogatories: What measures have been taken regarding unqualified motors in Limitorque motor-operated valves? Please provide details of the problem and the Applicant's response thereto. Contrary to the Applicants' claims, this question is entirely within the scope of Contention 8 as admitted by the Board; please provide a complete response.

12. Applicants refused to respond to the following Intervenors' question in Intervenors' Second Set of Interrogatories: Describe in detail any problems the 5

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,[ Applicant has experienccd with th? residual heat rcmoval system, including potential consequences and measures to correct each problem. Contrary to the Applicants' claims, this question.is entirely within the scope of Contention 8 as admitted by the Board. Please provide a complete response.

13. Describe all deviations from design specifications and procedures at Plant Vogtle.

U. Requests to Produce Relating to CPG /GANE Contention fj! '

1. Applicants refused to respond to the following Ir,tervenors' request to produce in Intervenors' Second Set of Interrogatories and Requests to Produce: Provide copies of all contracts with A & W 011. This request is within the scope of Contention 8 as admitted by the Board and Intervonors request compliance with this request.

2. Applicants refused to respond to the following Intervenors' request to produce in Interv,,enors' Second Set of Interrogatories and Requests to Produce: Provide a copy of the contract for the Westinghouse NSSS. This is within the scope of Contention 8 as admitted by the Board; Intervenors request that Applicants provide this information.

i j 3. Applicants refused to respond to the following Intervenors' request to produce in Intervenors' Second Set of Interrogatories and Requests to Produce: Provide a 3

copy of the contract with Bechtei. This is relevant to Contention 8; Intervenors request a copy be provided.

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4. Applicants refused to respond to the following Intervenors' request to produce in Intervenors' Second Set of Interrogatories and Requests to Produce: Provide all

information relating to the " inadequate. core cooling system" as discussed at the i'

meetings June 12 and June 27, 1984. This question is within the scope of Contention j 8 as admitted by the Board. In fact, Applicants acknowledge the relevance of this i

information as they request that'Intervenors provide "each and every document which i

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has been received...in resp:nse to a freedom of information act request mada to the Nuclear Regulatory Commission pertaining to doecuments regarding the adequacy of the core cooling system of Vogtle Nuclear Power Plant" (p. 84, " Applicants' Fourth Set of Interrogatories and Request for Production of Documents") which the Applicants state is "on Contention 8" (ibid., p. 1). Please provide a complete response to this request.

5. Applicants refused to respond to the following Intervenors' request to produce in Intervenors' Second Set of Interrogatories and Requests to Produce: Provide all documents' relating to core drilling into rebars at Plant Vogtle. Contrary to Applicants' claims, this is entirely within the scope of Contention 8 as admitted by  !

the Board. Please respond fully to this question.

Respectfully submitted, this, the lith day of March, 1985, s+m T, / l g'

,/ .i Tim Johnson Doug Teper Campaign for a Prosperous Georgia Georgians Against Nuclear Energy 175 Trinity Avenue, S.W. 1253 Lenox Circle, N.E.

Atlanta, Georgia 30303 Atlanta, Georgia 30306 i

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.' 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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BEFORE THE AT0 HIC 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 Campaign for a Prosperous Georgia / Georgians Against Nuclear Energy Fourth Set of Interrogatories and Requests to produce were served by deposit with the U. S. Postal Service in the City of Atlanta with first class postage attached to be delivered to the Secretary of the Comission. the members of the Licensing Board and all others listed below, this eleventh day of March, 1985.

j Asum j' y-Tim Johnson Doug Teper /

Campaign for a Prosperous Georgi. Georgians Against Nucle /ar Energy SERVICE LIST

?!orton B. Margulies, Chairman Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission 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 Comission 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 Comission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Atomic Safety & Licensing Board Panel Ruble A. Thomas U.S. Nuclear Regulttory Comission Southern Company Services, Inc.

Washington, D.C. 20555 P. O. Box 2625 Birmingham, Alabama 35202 .

George F. Trowbridge et al.

Shaw, Pittman, Potts TTrowbridge Bradley Jones, esq.

1800 M Street, N.W. Regional Counsel, U.S. NRC Washington, D.C. 20036 101 Marietta Street, Ste. 3100 Atlanta, Georgia 30303

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