ML20112H257

Response to Joint Intervenors Fourth Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20112H257
Person / Time
Site:	Vogtle
Issue date:	03/26/1985
From:	Joiner J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20112H252	List: ML20112H249 ML20112H257
References
OL, NUDOCS 8504020191
Download: ML20112H257 (25)

Text

setATED 00HHewun0NGR,

, g Sqrch 26, 1985

lldM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSf 6N '"' 27 "* ' :

• 1 Before the Atomic Safety and Licensing Board In the matter of  :

GEORGIA POWER COMPANY, et al.  : DOCKET NUMBERS

50-424 and 50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

APPLICANTS' RESPONSE TO INTERVENORS' FOURTH SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS On March 11, 1985, Joint Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy served upon Applicants by mail their Fourth Set of Inter-rogatories and Requests to Produce. In its Memorandum and Order on Special Prehearing Conference Held Pursuant to 10 C.F.R. 2.715a, dated September 5, 1984, the Atomic Safety and Licensing Board (ASLB or Board) adopted a stipulation entered into by the parties that provided for two rounds of discovery. The discovery requests contained in the Intervenors' Fourth Set of Interrogatories and Requests to 8504020191 850326 4 PDR ADOCK 050 0

_f-- . --. . - . -

Produce comprise the Intervenors' second round of discovery requests on Contention No. 8. Applicants provide herein their responses to those discovery requests.

Documents produced by the Applicants in response lo the Intervenors' Interrogatories and Requests to Produce which pertain to Contention No. 8 (including in response to Intervenors' Second Set of Interrogatories and Requests to Produce), will be available at the discovery room established by the Applicants at the Vogtle Electric Generating Plant (VEGP) for inspection and copying until the date for close of discovery on Contention No. 8 estab-lished by the Board's September 5, 1984 Memorandum and Order at 47-48 and the parties' subsequent stipulation adding 30 days to the discovery period for depositions.

I. GENERAL OBJECTIONS A. Objections to Instructions Applicants object to the preliminary instructions contained in Intervenors' Fourth Set of Interrogatories and Requests to produce to the extent that:

1. the Intervenors seek to impose requirements upon the Applicants beyond those permitted by the Nuclear Regulatory Commission's Rules of Practice for Domestic Licensing Proceedings; and

2. those instructions request the production of documents protected from discovery by the attorney-client J.<'

privilege or the work product privilege.

B. Objections to Untimeliness of Intervenors' Fourth Set of Interrogatories and Request for Producticn of Documents Applicants object to [ntervenors' Fourth Set of Interrogatories and Request for Production of Documents on the; ground that they-are untimely. This Fourth Set of Interrogatories and Request to Produce constitutes Intervenors' second round of discovery on Intervenors' Contention No. 8. In its Memorandum and Order on Special Prehearing Conference Held Pursuant to 10 C.F.R. 2.715a, dated September 5, 1984, the ASLB, ordered that discovery on a specific Contention was to be served no later than 120 days after the Order admitting that Contention. The order admitting Contention No. 8 was issued by the ASLB on November 5, 1984._ The time for filing second round discovery on Contention No. 8 expired on March 5,. 1985.

. Int e rve'no rs ' Fourth Set of Interrogatories and Request for Production of Documents (second round discovery on v-M y

1 Contention No. 8) was not, served untii March 11, 1985 and is untimely.'

C. Obiections to purported Scope of Interrogatories and Requests for Documents Applicants object to any interrogatory or request for documents, or portion of an interrogatory or request for documents, which seeks information beyond that which relates to matters in controversy which have been identified by the Board in its Memorandum and Order dated November 5, 1984. See, 10 C.F.R. $ 2.740(b)(1). The scope of Contention No. 8, as admitted by the Board, is s'tated as follows:

Applicants have not and will not implement a quality assurance program for plant Vogtle for welding, for properly documenting the placement of_ concrete, for adequately testing concrete, for the preparation of correct concrete quality test

' Applicants note that this is not the first instance in which Intervenors have disregarded the time require-ments in this licensing proceeding. For instance, Applicants were surved with Campaign for a prosperous Georgia's Amendment To Supplement To petition For Leave To Intervene And Request For Hearing one day before the pre-hearing conference despite the requirement of 10 C.F.R. $ 2.714(b) which states that such supplements to the petition must be filed fifteen days prior to the prehearing conference.

This disregard of time requirements has also affected the discovery schedule. Intervenors' Second Set of Inter-rogatories and portions of Intervenors' Response to Applicants' Second and Third Set of Interrogatories were all served late.

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records, for procuring material and equipment that meet applicable ' standards, for protecting equipment and for taking corrective action as required, so as to adequately provide for the safe functioning of diverse structures, systems and components, as required by 10 CFR Part 50, Appendix B, such that reasonable assurance exists that operation of the facility will not endanger the public health and safety.

Any inquiry into, or request for document concerning, a non-Contention No. 8 activity is beyond the scope of Contention No. 8 and hence beyond the scope of this proceeding. A Contention No. 8 activity is considered to be any one of, or combination of, the following:

1. welding;

2. documenting the placement of concrete;

3. testing concrete;

4. preparation of concrete quality test records;

5. procuring material and equipment:

6. protecting equipment; and

7. taking corrective action in response to Notices of Violation as required by the NRC.

II. SPECIFIC RESPONSES:

A. General Interrogatories 1.

QUESTION: Please identify (by name, business address, occupation and employer) a) all individuals who have knowledge or information responsive to each interrogatory

and designate the interro,gatory or the part thereof which that individual answered.

RESPONSE: Objection. Applicants object to this Interrogatory because it is vague, confusing and not susceptible to a proper response. To the extent this Interrogatory requests information about persons other than those who have provided information used by Applicants in responding to these discovery requests, it is overly broad, burdensome and oppressive.

Subject to this objection, and to the extent this Interrogatory calls for the identity of individuals providing a response to any of the following Inter-rogatories, Applicants state that all responses to Intervenors' Fourth Set of Interrogatories and Request For Production Of Documents have been provided by the undersigned attorneys for Applicants.

2.

QUESTION: 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 testimo-ny, the witness's educational and professional background, and any previous proceedings in which that person has testified.

{,., ,

l RESPONSE: Applicants. currently have not identified an expert whom they will ca.11 as a witness in regard to Contention No. 8. To the extent it is required, this response will be supplemented as required by the NRC Rules of Practice for Domestic Licensing Proceedings.

B. Specific Interrogatories Relating to CPG /GANE Contention'No. 8 1.

QUESTION: Applicants refused to respond to the following Intervenors' question in Intervenors' Second Set of Interrogatories: When the Applicant recently fired employees involved in procurement 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 investiga-tions? Please provide details, including copies of the investigation results. Contrary to Applicants' (sic) claim, this question is entirely within the scope of Contention 8 as admitted by the Board. Please provide a complete response to this interrogatory.

RESPONSE: Objection. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants on January 11, 1985. If Intervenors were dissatisfied with

that response, the proper, recourse was to file a timely motion to compel. No such motion was filed. This partic-ular Interrogatory is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiving their original response of January 11, 1985, Applicants further state that the repeated inquiry into this subject matter by use of an identical question is calculated solely for the purpose of delay and harassment and consti-tutes a burdensome and oppressive inquiry.

2.

QUESTION: Applicants refused to respond to the fol-lowing Inteivenors' question in Intervenors' Second Set of Interrogatories: Have any employees or bidders alleged 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.

RESPONSE: Objection. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse was to file a timely

motion to compel. No suc.h motion was filed. This partic-ular Interrogatory is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiving their original response of January 11, 1985, Applicants further state that the repeated inquiry into this subject matter by use of.an identical question is calculated solely for the purpose of 'elay d and harassment and consti-tutes a burdensome and oppressive inquiry.

3.

QUESTION: Applicants refused to respond to the fol-lowing Intervenors' question in 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' (sic) 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 assurance of quality. Please answer this question fully.

RESPONSE: Objection. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants on January 11, 1985. If Intervenors were dissatisfied with

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that response, the proper. recourse was to file a timely motion to compel. No such motion was filed. This partic-ular Interrogatory is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiving their original response of January 11, 1985, Applicants further state that the repeated inquiry into this subject matter by use of an identical question is calculated solely for the purpose of delay and harassment and consti -

tutes a burdensome and oppressive inquiry.

4.

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

RESPONSE: Objection. Applicants object to this Interrogatory to the extent it is overly broad, calls for information beyond the scope of Contention No. 8 or requests information which is not calculated to lead to the discovery of relevent or admissible evidence. To the extent the information requested in this Interrogatory is within the scope of Contention No. 8, that information is available to the Intervenors in the public record. The request that the Applicants do Intervenors' work and com-pile the information for the Intervenors in response to this Interrogatory is burdensome and oppressive and calculated solely for the purposes of delay and harassment.

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. 5.

QUESTION: Applicants refused to respond to the fol-lowing 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 such incident and procide details. Con-trary to the kpplicants' (sic) claims, this. question is clear'1y within the scope of Contention 8 as admitted by the Licensing Board. Please provide a complete response to this question.

RESPONSE: Objection. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse was to file a timely motion to compel. No such motion was filed. This partic-ular Interrogatory is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiving their original response of January 11, 1985, Applicants further state that the repeated inquiry into this subject matter by use of an identical question is calculated solely for the purpose of delay and harassment and constitutes a burdensome and oppressive inquiry.

6.

QUESTION: Applicants refused to respond to the fol-lowing Intervenors' question in Intervenors' Second Set of r *

. Interrogatories: List ev.ery act of vandalism directed at the structure of plant Vogtle or components thereof, giv-ing 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 8 as admitted by the Board. please provide a complete response to this question.

RESPONSE: Objection. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse was to file a timely motion to compel. No such motion was filed. This partic-ular Interrogatory is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiving their original response of January 11,.1985, Applicants further state that the repeated inquiry into this subject matter by use of an identical question is calculated solely for the purpose of delay and harassment and consti-tutes a burdensome and oppressive inquiry.

7.

QUESTION: Applicants refused to respond to the following Intervenors' question in Intervenors' Second Set of Interrogatories: Have any workers been fired for any reason by the Applicant and/or its contractors /

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 question in full.

RESPONSE: Objection. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse was to file a timely motion to compel. No such motion was filed. This partic-ular Interrogatory is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiving their original response of January 11, 1985, Applicants further state that the repeated inquiry into this subject matter by use of an identical question is calculated solely for the purpose of delay and harassment and consti-tutes a burdensome and oppressive inquiry.

8.

QUESTION: Applicants refused to respond to the following Intervenors' question in Intervenors' Second Set of Interrogatories: 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 acope of Contention 8 as admitted by the Board. Please respond to this question in full.-

RESPONSE: Objection. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants on January 11, 1985. - If Intervenors were dissatisfied with .

that response, the proper recourse was to file a timely motion to compel. No such motion was filed. This partic-ular Interrogatory is merely an attempt to defeat the time requirements of 10 C.F.R. $ 2.740(f). Without waiving their original response of January 11, 1985, Applicants further state that the repeated inquiry into this subject matter by use of an identical question is calculated solely for_the purpose of delay and harassment and consti-

> tutes a burdensome and oppressive inquiry.

I' 9.

QUESTION: 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 training do its workers have in core drilling? Provide details. Contrary to the Applicants' claims, this question is entirely within the scope of Contention 8 as admitted by the Licensing Board. please i

provide a complete response.

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RESPONSE: Objection.. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse was to file a timely motion to compel. No such motion was filed. This partic-ular Interrogatory is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiving their original response of January 11, 1985, Applicants furtner state that the repeated inquiry into this subject matter by use of an identical question is calculated solely for the purpose of delay and harassment and consti-tutes a burdensome and oppressive inquiry.

10.

QUESTION: Applicants refused to respond to the fol-lowing Intervenors' question in Intervenors' Second Set of Interrogatories: What tests have been conducted on the lifting eyes of concrete hatch covers? provide details of the testing, including results. 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.

RESPONSE: Objection. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants on January 11, 1985. If Intervenors were dissatisfied with

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that response, the propet recourse was to file a timely motion to compel. No such motion was filed. This par-ticular Interrogatory is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiv-ing their original response of January 11, 1985, Appli-cants'further state that the repeated inquiry into this subject matter by use of an identical question is calcu-lated solely'for the purpose of delay and harassment and constitutes a burdensome and oppressive inquiry.

11.

QUESTION: Applicants refused to respond to the fol-lowing Intervenors' question in Intervenors' Second Set of Interrogatories: What measures have been taken regarding unqualified motors in Limitorque motor-operated valves?

please provide details of the problem and the Applicants' (sic) 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.

RESPONSE: Objection. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants'on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse was to file a timely motion to compel. No such motion was filed. This partic-ular Interrogatory is merely an attempt to defeat the time

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requirements of 10 C.F.R.,S 2.740(f). Without waiving their original response of January 11, 1985, Applicants further state that the repeated inquiry into this subject matter by use of an identical question is calculated solely for the purpose of delay and harassment and consti-tutes a burdensome and oppressive inquiry.

12.

QUESTION: Applicants refused to respond to the fol-lowing Intervenors' question in Intervenors' Second Set of Interrogatories: Describe in detail any problems the Applicant has experienced with the residual heat removal 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.

RESPONSE: Objection. This Interrogatory is merely an attempt to re-ask a previously asked question. A response to the original question was provided by Applicants on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse was to file a timely motion to compel. No such motion was filed. This partic-ular Interrogatory is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiving their original response of January 11, 1985, Applicants further state that the repeated inquiry into this subject

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matter by use of an ident.ical question is calculated solely for the purpose of delay and harassment and consti-tutes a burdensome and oppressive inquiry.

13.

QUESTION: Describe all deviations from design speci-fications and procedures at Plant Vogtle.

RESPONSE: Objection. Applicants object to this Interrogatory to the extent it is overly broad, calls for information beyond the scope of Contention No. 8 or requests information which is not calculated to lead to the discovery of relevant or admissible evidence. To the extent the information requested in Interrogatory No. 13 is within the scope of Contention No. 8, the information has been made available to Intervenors in response to previous discovery requests. (See Applicants' Response to Intervenors' Second Set of Interrogatories and Request for Production of Documents, at Request No. U-21.) Applicants further object to the request that the Applicants do Intervenors' work and compile the information in response to this Interrogatory on the basis that such a request is burdensome and oppressive and calculated solely for the purpose of delay and harassment.

C. Response to Requests for Production of Documents Relating to CPG /GANE Contention No. 8 Documents produced by Applicants in response to Inter-venors' Second Set of Interrogatories and Requests to

Produce have been available for inspection and copying at the discovery room established by Applicants at VEGP since January 11, 1984. No documents are properly requested in Intervenors' Fourth Set of Interrogatories and Request For Production of Documents. All of the documents which have been made available for inspection and copying pursuant to discovery will remain available at the discovery room until the close of discovery on Contention No. 8.

In response to_the specific requests set forth in Intervenors' Fourth Request for Production of Documents, Applicants state as follows:

1.

REQUEST: Applicants refused to respond to the follow-ing Intervenors' request to produce in Intervenors' Second Set of Interrogatories and Requests to Produce: Provide 4

copies of all contracts with A & W Oil. This request is within the scope of Contention 8 as admitted by the Board and Intervenors request compliance with this request.

RESPONSE: Objection. This request is merely an attempt to re-request a previously requested document.

The response to this request was provided by Applicants to Intervenors on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse was to file a timely motion to compel. No such motion was filed. This request is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiv-ing the original response of January 11, 1985, Applicants n

further state that the repeated request for documents is burdensome and oppressive and calculated solely for the purpose of delay and harassment.

2.

REQUEST: Applicants refused to respond to the follow-ing Intervenors' request to produce in Intervenors' 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; v.

Intervenors request that Applicants provide this infor-mation.

RESPONSE: Objection. This request is merely an attempt to re-request a previously requested document.

The response to this request was provided by Applicants to Intervenors on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse was to timely file a motion to compel. No such motion was filed. This request is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiv-ing the original response of January 11, 1985, Applicants further state that the repeated request for documents is burdensome and oppressive and calculated solely for the purpose of delay and harassment.

3.

REQUEST: Applicants refused to respond to the follow-ing Intervenors' request to produce in Interveners' Second

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Set of Interrogatories an.d Requests to Produce: Provide a copy'of the contract with Bechtel. This is relevant to Contention 8; Intervenors request a copy be provided.

RESPONSE: Objection. This request is merely an attempt to re-request a previously requested document.

The response to this request was provided by Applicants to Intervenors on January 11, 1985. If Intervenors were dissatisfied with that response, the. proper recourse was to file a timely motion to compel. No such motion was filed. This request is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiv-ing the original response of January 11, 1985, Applicants further state that the repeated request for documents is burdensome and oppressive and calculated solely for the purpose of delay and harassment.

4.

REQUEST: Applicants refused to respond to the follow-ing 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 meetings June 12 and June 27, 1984. This question is within the scope of Contention 8 as admitted by the Board. In fact, Applicants acknowledge the relevance of this information as they request that Intervenors provide "each and every document which has

9 been received . . . in response to a freedom of infor-mation act request made to the Nuclear Regulatory Commission pertaining to documents 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.

RESPONSE: Objection. This request is merely an attempt to re-request a previously requested document.

The response to this request was provided by Applicants to Intervenors on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse was to file a timely motion to compel. No such motion was filed. This request is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiv-ing the original response of January 11, 1985, Applicants

- further state that the repeated request for documents is burdensome and oppressive and calculated solely for the purpose of delay and harassment.

5.

REQUEST: Applicants refused to respond to the follow-ing 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 admit' ed c by the Board. Please respond fully to this question.

RESPONSE: Objection. This request is merely an attempt to re-request a previously requested document.

The response to this request was provided by Applicants to Intervenors on January 11, 1985. If Intervenors were dissatisfied with that response, the proper recourse iras to file a timely motion to compel. No such motion was filed. This request is merely an attempt to defeat the time requirements of 10 C.F.R. S 2.740(f). Without waiv-ing the original response of January 11, 1985, Applicants further state that the repeated request for documents is burdensome and oppressive and calculated solely for the purpose of delay and harassment.

Respectfully'~ submit ed, Ja qs E. Joiner,.PsC.

C atles W. Whitneg'/

K v n C. Greene Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN

& ASHMORE George F. Trowbridge, P.C.

Bruce W. Churchill, P.C.

David R. Lewis SHAW, PITTMAN, POTTS &

TROWBRIDGE Counsel for Applicants

March 26, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the matter of  :

GEORGIA POWER COMPANY, et al.  : DOCKET NUMBERS

50-424 and 50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' Response to Intervenors' Fourth Set of Interrogatories and Request for Production of Documents, dated March 26, 1985, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, or where indicated by an asterisk (*) by hand delivery, this 26th day of March, 1985.

Respectfully submitted, g O. .

W v.

James E. Joiner, P.C.

Counsel for Applicants Dated: March 26, 1985

.5 - ,

. UNITED STATES OF_ AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

GEORGIA POWER COMPANY, et al.

) Docket Nos. 50-424

) 50-425 (Vogtle Electric Generating Plant, )

Units'l and 2;) ).

SERVICE LIST Morton B. Margulies, Chairman

• Douglas C. Teper 1253 Lenox Circle

' Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Atlanta, Georgia 30306 Washington, D. C. 20555-

• Laurie Fowler & Vicki Breman Mr. Gustave A. Linenberger Legal Environmental Assistance Atomic Safety and Licensing Board Foundation U. S. Nuclear Regulatory Commission 1102 Healey Building Washington, D. C. 20555 Atlanta, Georgia 30303 Dr. Oscar H. Paris

• Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous Georgia U. S. Nuclear. Regulatory Commission 175 Trinity Avenue, S. W.

Washington, D. C. 20555 Atlanta, Georgia 30303 Bernard M. Bordenick, Esquire 'ocketing and Service Section Office of Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Conmission U. S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C. 20555 Atomic Safety _and Licensing Board Panel Bradley Jones, Esquire U. S. Nuclear _ Regulatory Commission Regional Counsel Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Suite 3100 Appeal Board Panel 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555